Gateway West Transmission Line Final EIS 

Appendix L 

Responses to Comments on Draft EIS 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS INTRODUCTION This appendix contains the response to comments BLM received on the Draft EIS for the Gateway West Transmission Line Project. The Draft EIS was made available for public review on July 29, 2011. The 90-day public comment period closed on October 28, 2011. During the comment period, BLM held 17 public meetings. Two additional meetings were held for the Sage-Grouse Analysis, which was released for a separate 30-day comment period in August 2012. Table L-1. Draft EIS Public Meeting Locations, Dates, and Attendance 

Meeting Date Meeting Location Attendance 

September 12, 2011 Boise, Idaho 29 September 12, 2011 Kuna, Idaho 16 September 13, 2011 Mountain Home, Idaho 13 September 14, 2011 Melba, Idaho 33 September 15, 2011 Murphy, Idaho 65 September 19, 2011 Twin Falls, Idaho 52 September 20, 2011 Jackpot, Nevada 6 September 21, 2011 Burley, Idaho 95 September 22, 2011 Almo, Idaho 35 September 26, 2011 American Falls, Idaho 41 September 27, 2011 Pocatello, Idaho 17 September 28, 2011 Fort Hall, Idaho 15 September 29, 2011 Montpelier, Idaho 16 October 3, 2011 Kemmerer, Wyoming 52 October 4, 2011 Rock Springs, Wyoming 21 October 5, 2011 Rawlins, Wyoming 26 October 6, 2011 Douglas, Wyoming 66 Total 598 By the time the comment period had closed, BLM had received 371 documents (e-mails or letters) commenting on the Draft EIS. An additional 30 comments were received on the Sage-Grouse Analysis from agencies, groups, and individuals. Comments came from individuals, government agencies, and non-governmental organizations. All the documents submitted were included in a comments database that was made available for public viewing on January 24, 2012, at 

http://www.wy.blm.gov/nepa/cfodocs/gateway_west/index.html. 

COMMENT ANALYSIS A team of analysts reviewed the documents and identified comments. All of the analysts have conducted comment analysis before and had contributed to the writing of the Draft EIS. Comments were categorized by their subject matter and entered into a database. The analysts identified approximately 2,600 individual comments. These comments may have been included in multiple categories. Response to Comments Due to the volume of comments received on the Draft EIS, BLM decided to group and summarize comments that expressed a preference or opposition to the Proposed Route or to an alternative 

route. This information is presented below.

Support and Opposition Approximately 500 of the comm

opposition. The following sum

segments or alternatives and k

alternative. A few things to keesegments and alternatives are: 

 The analyst had to be a

opposition was being maopposition were not cou

 Many commenters made 

the numbers reflect the 

 Comments stating “no o It was assumed that tho

Action, even if they did n

 Some comments were f Not all comments in sup Reasons stated may no Some comments were s Generally, people write 

or are not specific in the

 Comments in support or 

considered a vote. Thes

concerned. 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS Table L-2. Segment and Alternative Support and Opposition 

Support – Number of Commentors and 

Reasons 

Opposition – Number of Commentors and 

Reasons 

No Action 7 support Unable to quantify number opposed to No Action. Segment 1E 3 support Consistent with Governor’s sage-grouse order. 

31 oppose Proximity to Glenrock and i-25, visual quality, unnecessary, wind farms not allowed, elk habitat, private lands, mountains, annexed area of Glenrock, economic impacts. 

Alternative 1E-A 7 support Less impact on Glenrock, fewer people affected, less impact on sage-grouse. 

16 oppose Not consistent with Governor’s sage-grouse order, unnecessary, cost to rate payers, elk habitat, hunting, visual quality, too much road construction. 

Alternative 1E-B 2 support 21 oppose 

Sage-grouse, visual quality, elk habitat, unnecessary, hunting, area has no previous development, limits growth in Glenrock, does not follow existing corridor, too much road construction, private land. 

Alternative 1E-C 23 support Less trees cut, shorter, fewer impacts on wildlife, landowners, follows existing corridor. 

3 oppose Does not meet purpose and need for accessing future wind development, limits growth in Glenrock, visual quality in Glenrock. 

Segment 1W Proposed 3 support Least disturbance. 

9 oppose Additional future renewable energy development in Shirley Basin, property values, visual quality, zoning. 

Alternative 1W-A 5 support Follows existing corridor, shorter, less impacts on wildlife. 

1 opposes Impacts on visual quality. 

Segment 1W(a) Proposed 3 support Follows existing corridor, shorter. 

9 oppose Impacts on irrigated cropland, not adjacent to existing lines, visual quality. 

Segment 1W(c) Proposed 5 support Follows existing corridor. 

0 oppose 

Segment 2 Proposed 10 support Avoids Fort Fred Steele community and historic site, avoids residences, proximity to potential wind development, and minimizes impacts on sagegrouse. 

1 opposes Higher impacts on ranch. 

Table L-2. Segment and A

Support – Number of Commen

Reasons 

Alternative 2A 1 supports Proximity to potential wind developmAlternative 2B 1 supports Proximity to potential wind developmAlternative 2C 1 supports Minimizes impacts on sage-grouse. Segment 4 Proposed 2 support Not close to theFossil Butte National Alternative 4A 32 support Follows existing transmission line, Gooffice selection, less disturbance, leswildlife and people, area already distAlternative 4B 5 support Less impact on wildlife and people. Alternative 4C 5 support Less impact on wildlife and people. Alternative 4D 6 support Follows existing corridors, fewer impahistoric trails. Alternative 4E 5 support Lower quality grouse habitat, follows corridors, fewer impacts on historic trAlternative 4F 6 support Less impact on wildlife and people. 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS Table L-2. Segment and Alternative Support and Opposition (continued) 

Support – Number of Commentors and 

Reasons 

Opposition – Number of Commentors and 

Reasons 

Segment 5 3 support Supports future growth. 

8 oppose Proximity to homes, impacts on farmland, property values, water sources, deer and elk habitat fowl, fishing, camping, and Idaho State lands. Steep mountains. 

Alternative 5A 1 supports 2 oppose 

Access, steep mountains. 

Alternative 5B 0 support 4 oppose 

Impact on cropland, sage-grouse. 

Alternative 5C 8 support Existing transmission lines, not many houses, minimized effects on visual quality and wildlife, less steep ground, avoids Arbon Valley School. 

2 oppose Impact on deer herds, lack of negotiation with Tribes. 

Alternative 5D 0 support 3 oppose 

River crossing location, farmland. 

Alternative 5E 3 support Shortest route. 

0 oppose 

Segment 6 4 support Least impacts. 

1 oppose Proximity to Picabo and Silver Creek Preserve 

Segment 7 Proposed 9 support Avoids forests, supports future growth, fewer impacts on City of Rocks National Reserve. 

19 oppose Better than Segment 5, proximity to homes, businesses, and airport; impacts on cultural resources, farmland, CAFO, wetlands, water sources, deer and elk habitat fowl, fishing, camping, sage-grouse and key habitat. 

Alternative 7A 1 supports 5 oppose 

Detrimental environmental and economic effects, visual quality, non-conformance with land use plans, farms, cumulative impacts on sage-grouse and key habitat. 

Alternative 7B 2 support 6 oppose 

Cropland, detrimental environmental and economic effects, visual quality, non-conformance with land use plans, cumulative impacts on sage-grouse and key habitat. 

Alternative 7C 0 support 1 opposes 

Cumulative impacts on sage-grouse and key habitat. 

Table L-2. Segment and A

Support – Number of Commen

Reasons 

Alternative 7D 0 support Alternative 7E 0 support Alternative 7F 0 support Alternative 7G 0 support Alternative 7H 4 support Avoids Rockland and the Eastfork ReArea, avoids irrigated land. Alternative 7I 17 support Fewer impacts on residents, birds, prfarmland; location of substation, locacrossing Highway 46, use of public laprivate land, and reduced interferencAlternative 7J 14 support Fewer impacts on residents, birds, prfarmland; location of substation, use versus private land, and reduced inteairport. Segment 8 Proposed 16 support Less farmland, shorter route, generaimpacts, minimized impacts on the M
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS Table L-2. Segment and Alternative Support and Opposition (continued) 

Support – Number of Commentors and 

Reasons 

Opposition – Number of Commentors and 

Reasons 

Alternative 8A 2 support 9 oppose 

Too close to populations, proximity to Billingsly State Park, perception of risk from EMF, proximity to Oregon Trail and Toana Road historical sites, visual quality, waterfowl habitat, impacts raptors, and federal listed plants. 

Alternative 8B 4 support Compatible with National Conservation Area, avoids military training range, avoids archaeological district. 

6 oppose Proximity to residences, farms, property values, raptors, and federally listed plants 

Alternative 8C 0 support 1 opposes 

Raptors and federally listed plants. 

Alternative 8D 0 support 1 oppose 

Raptors and federally listed plants. 

Alternative 8E 0 support 2 oppose 

Environmentally sensitive area, raptors, federally 

listed plants. 

Segment 9 Proposed 4 support 26 oppose 

Impacts on private property, farms, visual quality, Mountain Home Training Range and historical features; use of private lands over public, proximity to residences and planned developments, support for Alternative 9D instead. 

Alternative 9A 1 supports 1 opposes Alternative 9B 1 supports Avoids the Wild and Scenic River and parallels existing transmission line. 

2 oppose Impacts on Hagerman Fossil Beds National Monument. 

Table L-2. Segment and A

Support – Number of Commen

Reasons 

Alternative 9C 0 support Alternative 9D 26 support Minimizing impacts on sage-grouse, property, visual quality, and maximiziexisting corridors. Also, it’s not SegmProposed. Alternative 9E 3 support Use of public lands Alternative 9F 1 supports Alternative 9G 0 support Alternative 9H 1 supports Segment 10 1 supports Notes: CAFO – concentrated animal feeding opeEMF – electrical and magnetic field OHV – off-highway vehicle 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100084 RANDY SHEPARD Why doesn't your map page show a closer view of the land the lines shall cross. You map page is like looking at the earth from 

several thousand feet up, how can the land owners share their concerns or comments when we don't have more detailed information?

The 

alteAdthe maPro

100100 T LAMAR WILLIS I highly recommend option the Twin Falls alternative routing for the East-West corridor labeled as 7J Yo100104 SAM SHOULTZ This is a comment on segment 1-E and 1-EB where it crosses over the Fetterman road. Both proposed segments cross our 

ranch, one on the west side, and one going E through us prior to going across the Fetterman RD. Both lines would go through areas of springs and sensitive meadows, and be in locations that would be difficult to build access roads through. The line 

would cross the Marshall road, which runs into the Mule Creek road (that 1-E would cross), an existing maintained county 

road, that if followed by your line, would significantly cut down construction costs, and have far less impact on the area thanconstructing a new route through pristine areas. The impact of the line running along an existing road would be less, overall, to 

the area than the impact of the disturbance caused by new roads and construction in those areas of topography that are 

harder to reach. A line running along the Mule Creek road could possibly still be on our land (sec #9 & #10), but I would certainly be more in favor of that application. Many power lines run along the pathways of roads, this would be no different. Icannot find the numbers on your map for page # etc. asked for above.

Nocurfrom 

100105 CHRIS JAMES, 

KEVIN T SMITH 

The BLM environmental impact statement indicates that there has been little proven evidence that electrical fields caused by 

the power lines significantly impact humans. If that is the case, the lines will not significantly impact wildlife either and that 

should not be a concern for placing the transmission lines on public land. However it is my feeling from my past experience and the experience of others that those high voltage transmission lines do 

negatively impact everything from farm equipment, to livestock, and people. Especially individuals with health risks and implanted cardiac pacemakers. All proposed routes other than the five county approved route, impacts local major highways and roads in the area by crossing or following the right-a-ways. They will impact the majority of the people living in Cassia Co 

at one time or an other.

Ele(Figtranbeithe 

 I support the route that was developed and approved by the five counties in Southern Idaho. They worked together with 

multiple agencies to develop a transmission corridor that would channel future growth and transmission lines on largely public 

ground.

Yo

 I am against the route proposed by Idaho Power. This is a public works project and the majority of it needs to be on public 

land. Private landowners in Southern Idaho should not be required to give up their valuable farm land for transmission lines that in no way benefit them. The power is simply passing through this area rather than being used to power our homes and 

businesses.

Yo

100110 JACK WALTS As an engineer of 39 years experience, I've made a cursory examination of your DEIS and believe it to be sufficient for 

continuance of the project. Please add my name and qualifications to the list of those who support this endeavor.

Yo

100119 PETER HUMM This project is long overdue, so any analysis of the project must include the potential societal impacts of NOT building it, and 

the anticipated effects of a power grid shutdown.

The Se

100122 KRIS KALANGES I continue to support using alternative (originally the proposed route) route 8B. I share the concerns of the Idaho ANG about 

placing high tension power lines and their towers in an area where they would propose hazards to our military personnel in flight. I also have concerns about building the Gateway Project through the Snake River Birds of Prey Conservation Area and 

feel it should not be done. Additionally, the GB-BB Archaelogical District is another natural treasure that we should not be 

disturbing with such a major construction project. I continue to believe that the original route (now 8B) was and is the best all 

around choice.

Yo

100129 TOM SWANSON "Alternative 1E-C would not meet the Proponents need to 'provide 230-kV infrastructure farther east where wind energy 

resources are planned." The word "planned" in the referenced sentence and the word "need" are at best incongruous. The proponent "needs" to install transmission when the resource exists not when it is "planned." The ratepayers do not "need" to pay for something that may 

not happen as the word "planned" implies nor should landowners, recreationists, hunters, etc., be required to alter their 

enjoyment because of what might happen. The existing right-of-way is the proper place to add transmission if it is needed, 

when it is needed; that is 1E-C, not the southern loop of 1E that is outside of the existing right-of-way or IE-B.

YoSethe Ch

100132 TYLER HEPWORTH Public power should be constructed on public land. Please go south and build on public property. The 

line Ap

100133 CHARMAINE 

BERGGREEN 

strong support for the proposed route of segment 8, Midpoint to Hemingway Yo

sup
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100134 PAUL BERGGREEN I ...would like to voice my strong support for the proposed route of segment 8, Midpoint to Hemingway Yo

sup

100136 DOUGLAS 

GOLIGHTLY 

I SUPPORT THE PROPOSED ROUTE THROUGH THE BIRDS OF PREY AREA. Yo

sup

100137 MICHAEL STUKEL I am strongly in favor of the proposed route of Segment 8, Midpoint to Hemingway. Yo100138 MONICA SMITH would like to give my support for the proposed route of Segment 8, Midpoint to Hemingway Yo100139 KENNETH D & 

DEANNA J COULTAS 

I recommend power lines be placed adjacent of other power lines in the area. ... reconsider your choice as your primary route and move the primary south to where the existing lines are currently located.

The dis

 Additionally, power lines will destroy land values and make it hard for those of us who live and vacation here to even sell our 

property or cabins.

The 

 The power lines create a route for future power lines to parallel existing power lines. The power lines can continue to grow 

causing great harm to our scenic beauty and the wildlife in the effected area.

The cor

 I own 1 parcel and my family ones 1 parcel and a cabin in Spring Canyon Ranches. ... Commissary Ridge. My family and I 

vehemently oppose the primary power line route for the Gateway West Transmission Line Project.

Yosup

 The power line will destroy the beautiful scenery that we fell in love with. We bought our property so that we could enjoy these 

views

Inc3.2

100143 ROLLIN ANDERSON I do support the proposed route from Glenns Ferry to Hemingway but I strongly feel that the altternate "8A" is a better route 

and I frankly do not understand why this is not the proposed route.

Yoinc

100145 KELLY TUCKER this Purposed wrought in not the most non- impact wrought going through Lincoln county, nor the most none visual wrought The 

curfrom 

 I know the southern corridors Green 4A 4B 4C 4D 4F will have less impact on wildlife and people. Yo

100147 KIM BRACKETT I feel very strongly that alternative 7j needs to accepted as the viable alternative for this segment (segment 7)...There are no 

homes that would be affected

Inc

 The project proponents state that there is no adverse impact to cattle or people living near a major power line but I know of at 

least on major law suit that Idaho power lost because stray voltage adversely impacting cattle. 

If it could be that cattle are adversly affected what does that do to people?

The and ani

 The private ground that the project would cross in alternative 7j would be mostly agricultural ground but the use of the ground 

in livestock grazing which would be substantially less impact.

Yo

to a

 The original proposed segment 7 would run right through the middle of a confined livestock feeding operation either that or 

over the top of homes, then through another Confined livestock operation a few miles to the west then slicing another farming 

operation the has a Confined Livestock feeding operation permit in place

Yosup

 When it is stated in the DEIS the local landowners opposed the proposed route between Populus and Cedar Hill, perhaps very 

strongly opposed would be a more accurate characterization. In July, 2010, a meeting was held at the Hollister, Idaho school in

the which the proposed gateway west project was discussed. Walt George and other Bureau of land management project 

participants along with Gateway west officials were present. There were 161 people signed in at that meeting. Opposition was fairly intense. It was made clear that the residents of this area who would be affected by the fruition of this project as proposed, 

were concerned about the effects to their quality of life. Folks that live in the Kimberly, Hansen area who already have their homes and lively hoods incumbered by the existing power lines, strongly opposed yet another line being in close proximity to them.

NoCo7K 

100148 LEVI BRACKETT going through the small community near hollister will have a far greater impact than travelling on the state line. The 

at l

 I support alternative 7J of the gateway west project Yo

100149 JANET MECCA I do not understand why you are not following the already transmission line. The 

roulist det

 If the line followed the proposed number 4, or 4F as I see them this will spoil more of the rare Wyo. beauty further Yo

inc

 I do feel that they may go near or even over my small bit of acreage which would be very disturbing to my feelings of peace 

and the aesthetic beauty we experience when we stay in Wyo. My land is part of an original Wyoming homestead and I have 

tried to preserve it for over 20 years as much as possible. Please, spare my land and views.

The roulist det
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100150 C DALE WILLIS JR I am strongly in favor of the proposed route of Segment 8, Midpoint to Hemingway. Yo

sup

100151 DAWAYNE AND 

YVONNE PALMER 

There is no good reason that I have heard yet to divert away from the existing power line coridor just to run the power line through Spring Canyon and then back into the existing coridor

Sewe

100153 JOHN DOOLEY I'm a Landowner on proposed route 1e and also on alternate route 1e-b. My parcel number is [Parcel] under Dooley Oil Inc. I'm 

in the eye of the storm and have no plans on granting the rights for this line to go across my land. I feel that there is no reason 

to have this line in the mountains as there is a already established line that can be accessed.

YoincThe dro

 Also I feel that if the federal goverment didn't make this green energy so financially attractive to the companies we would not 

evan have wind energy, so is it really a viable alternative or is this a feel good option for the boys in Washington. If you have to 

use the law to force your product to market it is not a viable worthy product

Thiproconhav

100154 PAXTON 

ROBINSON 

Because this line is for public good, i feel very strongly as do many others, that it should stay on public grounds, and off our private domains!!!

The tran

 I would like you to use the alternative route along the state line (7I). Yo On the proposed route, my family farm would be severely and adversely impacted Yo

sup

100155 CASIE TAYLOR In Reference to prime farmland section 7. The discounting of validity of using public lands due to the restraints of cost and 

impact does not account for the private land users cost and impact. The proposed red line does not account for private environmental impacts.

The are Ch

100155 CASIE TAYLOR Public power should be on public land not PRIVATE! The 

line Ap

100156 LAURIE 

DARRINGTON 

I live in Elba, one of the places they are talking of putting the line through. We have a beautiful peaceful valley. We would like it 

to stay that way!

Inc

 PUBLIC POWER SHOULD BE ON PUBLIC LAND. The 

line Ap

100158 JOHN WEBER I would have liked to attend a public meeting but it seems the only public meeting in Boise is during the work day. I think this 

was poor judgement having the biggest population city not have a meeting after normal work hours. I hope to see future 

meetings in Boise in the evening.

Nowahel

 In Chapter 1, I don't believe a need has been proven. No

100160 CRAIG MOORE I strongly support the Proposed Route for the power lines Yo100161 RAY STARK The Boise Metro Chamber supports the proposed route for the Gateway West Transmission Line Project. Yo100162 ELVIN LEO & UNA 

CLOYD 

I prefer you to use proposed route A - the one south of Melba City going thru BLM Land close to the existing power lines - Its 

seems like less expense to purchase land for structures and a lot less worry to home owners.

The it is ProPro

100163 BEVERLY MORRIS If the power line is put just about a mile south of me (in the middle of farmland Route 8A), in the near future it will be in the 

middle of Melba - too close to children and too many people in general.

The milSeSe

 The route through the BLM land Route 8 south of Melba seems a much better choice to me. Yo

sup

100164 BERTHA MULLIN I would rather the line went south of the Snake River No

of t

100165 DEANNA RATCLIFF Would rather see it go through private as to go thru BLM No

of t

 I am for the Route that would go down Melba Rd. Yo

100166 ELVIN LEO & UNA 

CLOYD 

I think the Transmission line - Route 8 should go through the BLM land...The north proposal Route 8B would impact many more houses.

Yo

100167 RONALD WRIGHT I very much favor your proposed route 8 through the BLM Birds of Prey Area. This route would have the least impact on the 

Melba area population and others in the vicinity.

Yosup

 ...The alternate Route 8B would be in a much more populas area, one sure to grow in the future. It would affect current and 

future property owners land valuations.

Yo
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100169 US GEOLOGICAL 

SURVEY

3.11-18 The efforts described appear to duplicate by BLM’s Rapid Ecoregional Assessments. Consider using information from BLM.

ThiBL

3.11-20 Paragraph 2 The EIS should clarify certain aspects of the method used by the density disturbance calculator, specifically whether different

disturbances are given different levels of impact. A 2-track road through sagebrush is different than a powerline or a fence. The 

EIS should clarify how these are evaluated to sum up a total disturbance.

In mBo

in trelepriorevcon

Table 3.11-4 The size of the lek is an important feature that should be included and has critical implications for the structure of the population. Changes that influence a small percentage of the leks could have a region-wide impact if those are the largest leks

in the population. Avoiding core areas in Wyoming and Key Areas in Idaho would mitigate this effect.

The 3.1in t

3.11-29 The EIS should describe the cumulative impact on sage-grouse populations related to the fact that more than half (677 

mi) of the proposed transmission line (1,103 mi) would go through sage-grouse habitat.

Cusec

3.11-63 and 3.11-64 “To limit the potential disturbance to this species, one of the Proponents’ primary goals while routing the

Project was to avoid all leks by at least 0.25 mile (in accordance the BLM RMP requirements for “no surface occupancy,” 

which was in place at the time of initial Project design in 2008). However, the centerline of the Project would come within 0.25 

mile of a lek with an “undetermined” management status along Segment 10 and within 0.25 mile of a lek with an “occupied” 

management status along Segment 5 (see Table 3.11-4). In addition, the Proponents attempted to avoid leks by 0.6 mile to the extent possible, based on the assumption made at the time of initial Project design (2008) that the “no surface occupancy” 

requirement would increase from 0.25 mile to 0.6 mile (as of this date, the BLM “no surface occupancy” restriction has been increased to 0.6 mile) Some of the recent work from oil/gas development suggests that activities much further away from the lek (4 km) can have a 

significant influence on the numbers of birds attending a lek. USGS analyses on lek persistence show a significant relationship

between the human footprint out to 5-km of a lek and the probability of extirpation. (all References below).

Segro

3.11-65 PAC-8 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. Peak egg laying and incubation goes into mid-June, and renesting can occur into July. Starting construction activities on 15 May is still going to impact nesting hens. The EIS should describe the impact to nesting, or consider refraining from 

construction activities in the lek and nesting areas during nesting season.

Impby add2). 

3.11-12; 3.11-16 5th paragraph and 3.11-18 Wyoming, Idaho, and Nevada state wildlife agencies are also delineating maps of seasonal habitats for sage-grouse. BLM also 

is generating maps of sage-grouse distributions through their Rapid Ecoregional Assessment projects. These maps would be better choices of information for sage-grouse distribution than the extensive remote-sensing effort or information within the LANDFIRE project.

The laywit

3.10-22 paragraph 2 “Therefore, the spread of noxious weeds due to construction of the Project is not expected to have an 

appreciable impact on wildlife habitat.” Data, modeling results, or published analyses should be provided or referenced to support this statement. Resulting effects on 

fire and native plant composition should be considered.

Sta
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100169 US GEOLOGICAL 

SURVEY (cont.)

3.10.23 “Unfragmented shrublands are a vital habitat characteristic for many wildlife species, but this habitat type has been degraded, fragmented, and eliminated by conversion to agriculture, livestock grazing, invasion of exotic plants, and tree 

succession (Rich et al. 2005). For instance, Hann et al. (1997) estimate that over 30 percent of this habitat type in the Interior 

Columbia Basin has been lost. ... Native grasslands in the Interior West have also experienced degradation and fragmentation and resultant loss of function as wildlife habitat.” And page 3.10-20 para 2. Given that the unfragmented and undegraded habitat has diminished so significantly, the EIS should identify fragments that are important habitat for imperiled wildlife such as sage-grouse. It should describe the specific wildlife issues that are present 

in these areas. It should identify areas that will be further fragmented, and the imperiled wildlife populations that will be affected 

on those areas. The EIS presents too general a picture to understand the extent and impacts of the action. In particular, it should analyze the impact on leks. Leks vary in size, and some leks are far more important to the overall population than 

others. Size of leks that would be impacted should be included in the EIS. While a small percentage of the leks may be affected, if those are the largest leks in the population, it could have a large impact region-wide. Avoiding core areas in Wyoming and key areas in Idaho could mitigate these impacts.

ExifolloSecindwidhowhavHatheNaSagparPreincbei3.1ext

3.10.15-16 Migratory Birds and Raptors 

The section on migratory birds and raptors should describe the effect of the project on species that are declining in population in the range of the project. The project area under consideration intersects Breeding Bird Survey Routes, which provide 

species lists and can be found at http://www.pwrc.usgs.gov/BBS/results/routemaps/routeAssignMap.cfm. Information on the 

status and trends in bird populations can be found at: http://www.mbr-pwrc.usgs.gov/bbs/bbs.html and in the publication: Sauer, J. R., J. E. Hines, J. E. Fallon, K. L. Pardieck, D. J. Ziolkowski, Jr., and W. A. Link. 2011. The North American Breeding Bird Survey, Results and Analysis 1966 - 2009. Version 

3.23.2011 USGS Patuxent Wildlife Research Center, Laurel, MD.

Thiind

3.10.2.2 Effects Common to All Action Alternatives and 3.10-20 and following; page 3.10-40 last paragraph and following. 

More information should be provided on the effects to habitats of particular species from power line construction. Constructionof new roads associated with the power line is likely to provide a corridor for invasive plant species that enter the surrounding sagebrush and alter the dynamics, including increased fire frequencies. These long-term changes are more damaging than 

some of the immediate effects, and should be discussed. Resulting fire may change the effective fragment size for some species.

Invmu

Pages 3.10-2, 3.11-2, and 3.11-3 Regarding the analysis areas for General Wildlife and Fish and Special Status Wildlife and Fish Species Distance from leks. Research has shown that most females will nest within 5 km of a lek (breeding area) in nonmigratory 

populations and within 18 km for migratory populations (Holloran and Anderson, 2005, Connelly et al 2000). These distances 

should be used in the analysis for the purposes of determining impacts to sage-grouse; larger distances include more habitats that need to be considered in the effect of the transmission line. If these larger distances are not used, the EIS should provide 

the justification for using the smaller selected distances.

Lekwe

3.10-36, paragraph 6 The Proponents’ Avian Protection Plan states that if mortalities due to electrocution are documented, 

changes to the distribution lines would be made in order to avoid future mortalities (such as by changing the arrangement of 

the powerlines or by excluding birds from certain areas). 

The EIS should describe a plan for monitoring mortalities that is capable of detecting when they occur.

The req

3.10.39 “The estimated water usage from construction activities on a typical day for transmission line construction would be about 2,140 to 3,340 cubic feet for dust control. If this would occur over an 8-hour period, it would equal a draw of 0.07 to 0.12 

cubic feet per second.” The EIS should describe the maximum proportion of water withdrawn in such a way that it is possible to determine the impact on flow rate. Withdrawal of 2,140 to 3,340 cubic feet over an 8-hour period would have a significantly different effect if the 

amount withdrawn were a significant proportion of the flow, or if the withdrawal were over a shorter than an eight-hour period.

The the

Pro(i.etheM)
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100169 US GEOLOGICAL 

SURVEY (cont.)

3.10-46 and 3.11-8 to 3.11-10 Project operation is expected to have only minor impacts to most migratory bird and game bird individuals, including Species of Conservation Concern and Game Birds Below Desired Condition, because the presence of 

the transmission line, structures, and access roads do not present barriers to movement through fragmentation, create excessive noise, or otherwise cause major behavior changes, for the most part. ...The EIS should include information on the effects of the powerline as described in a recently published paper by Wisdom et 

al (2011), which stated,” Best discrimination between extirpated and occupied ranges, using discriminant function analysis 

(DFA), was provided by five of these variables: sagebrush area (Artemisia spp.); elevation; distance to transmission lines; 

distance to cellular towers; and land ownership.... Mean distance to electric transmission lines was ~2 times farther in 

occupied range than in extirpated range (Fig. 18.4)... “Three additional anthropogenic variables—distance to transmission lines, distance to cellular towers, and landownership—also differed between occupied and extirpated ranges. These variables were the best discriminators among the eight anthropogenic variables considered and ranked among the best 

of all individual variables. These variables have received little attention in landscape research on sage-grouse—only distance to transmission lines has been formally evaluated (Connelly et al. 2000a, Aldridge and Boyce 2007, Walker et al. 2007a). Transmission lines can cause sage-grouse mortality via bird collisions with lines (Beck et al. 2006, Aldridge and Boyce 2007) and facilitate raptor predation of sage-grouse (Connelly et al. 2000a).

The in tsag

gro3.1

3.11_TES_Wildlife and Fish 3.11-3 Core areas should be based on population density of sage-grouse from lek counts. The spatial delineation should be for numbers of sage-grouse counted at leks converted to proportion of the population. The assumption of the core areas is that 

development should be excluded from these zones containing most of the sage-grouse area but should be allowed in areas that have low densities. Discussed in more detail on 3-11-19.

It is Go

3.10.39 “However, according to the Upper Colorado Endangered Fish Recovery Program, any water withdrawal over 4,356,000 cubic feet per year, would result in a may affect, likely to adversely affect determination for four federally listed fish 

species. The Proponents have estimated total construction water use (concrete batching and dust control) at 314.6 acre-feet or 

13,702,747 cubic feet.” The EIS should contain a brief description of the expected time frame for withdrawals and procedures that will be followed to make sure that the 4,356,000 cubic feet per year limitation will not be exceeded.

A sis d

3.11.11 A source should be provided for the (USGS) Gap Analysis Program (GAP). Suggest using http://gapanalysis.usgs.gov/data/.

Cit

200

3.16-11 The first sentence of the last paragraph on page 3.16-11 refers to the NRCS database. This sentence should be modified to indicate that information on this database and how to access it is included in the reference list (suggested sentence) The National Resource Conservation Survey STATSGO database (NRCS, 1995) was used to identify shallow groundwater within the Analysis Area and disturbance areas.

Cit

3.16-7 The first sentence of the paragraph discussing "stream type" on page 3.16-7 discusses The USGS National Database for 

Streams and Waterbodies. This should be included in the list of references and the reader should be supplied with the link to access this database. (suggested reference) USGS, 2005, National Atlas of the United States, Streams and Waterbodies of 

the United States http://nationalatlas.gov/atlasftp.html. Also in this same paragraph, details of the analyses method involving "USGS regression models created using data gathered 

from established stream gages" are given, but no reference is made to who conducted these analyses and where they can be found. If these are the methods used to create information that is presented in the National Database for Streams and 

Waterbodies it should be so stated. As written it implies that these are independent analyses and, if so, there should be a 

reference describing where these analyses can be obtained.

ReCla

3.16-12 Throughout page 3.16-12, databases are discussed as the source of information used in the groundwater analyses (IDWR, 

Wyoming State Engineers Office, USEPA regions 8 and 10). All of these agencies and databases should be referenced in the 

text and listed on the reference list with a link or URL to the appropriate location.

Re

the electromagnetic radiation emitted from transmission lines has a variety of negative effects on other bird species using areas on or near lines (Fernie and Reynolds 2005).

Ad

100170 BRUCE MOWER routing the transmission line along the existing 345 Kv corridor was eliminated because of "viewshed" impacts to historic trails. 

As a landowner adjacent to the proposed route of the Gateway project, the "viewshed" from my summer home, as well as the 

view from numerous other homes in the area, will be irreparably damaged. Most of the landowners along the proposed route 

that crosses Southfork Mountain have built cabins and summer homes on our property in hopes of having a retreat with unspoiled views with some peace and quiet. ...Please reconsider the proposed routing for the Gateway project and move it back where it belongs.

The exihav
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100170 BRUCE MOWER 

(cont.) 

As a landowner adjacent to the proposed route of the Gateway project, the "viewshed" from my summer home, as well as the 

view from numerous other homes in the area, will be irreparably damaged. Most of the landowners along the proposed route 

that crosses Southfork Mountain have built cabins and summer homes on our property in hopes of having a retreat with unspoiled views with some peace and quiet. I guess our desires are not much different from those of the historic trails people. So what makes the visual impacts to us as landowners in and around the proposed route any less important than the impacts to the historic trails? The existing transmission lines to the south of the proposed route have already impacted the trails, so it makes no sense to deviate this project routing from the existing corridor thereby negatively impacting additional areas.

Yo

100173 REED PHILLIPS Why can't these ugly, landscape degrading things put underground? An 

2. 

100174 KELLY MURPHEY There is no common sense and certainly no constitutional foundation involved in the heavy handed appropriation of the private 

property comprising Route 9c.

Any Alte

 closely must refer to a roughly parallel course for the two routes. With this interpretation in mind there is still an opportunity for 

common sense and cost effectiveness to prevail. Put the new line just to the south of the old one!...... The damage to pristine 

sage-grass ecology, several miles of costly land condemnations that will serve to damage private historic farms beyond repair, 

and the endangerment of at least five homes can be reduced, and reduced by a dramatic degree (see Gateway (Gateway ES14,paragraph #2). The impacted lands would then be mostly BLM grazing lands that have been cleared and reseeded three 

times since the 1960’s. There are apparently no known future projects or actions planned that would constrain the exact placement of the new line to the south of the old one (Gateway, 4-59, paragraph #1).

Nonot 

 all of the potentially involved farm ground is in the counties Ag Preservation Zone, and while other uses are not impossible, the 

permission of the County Commissioners is required to break the agreements that lead to this hard earned classification for thelands in question.

No

 The 9c route, if it goes below the current power line, will diagonally cut 4-5 of my carefully designed (rectangular) fields of 15 

and 20 acres. This creates a pattern of tiny fields with unequal row lengths and it will break my federally approved pattern of

year–to-year crop rotation by the making the fields illogical if not impossible to farm by the current method. Some fields and/or 

parts of fields on the south side of the right of way may also have to be abandoned as they would become isolated from flood 

irrigation. With that much total acreage of a small farm taken out of production, the future of our entire farm would be in doubt. 

Certain parts of this ( rotation ) acreage must provide the winter hay that sustains cattle that are being summer grazed on 

poorer ground established in pasture on the other side of the farm, so this sub-operation may also be over

Yo

 A small Wind Power project under consideration may also be in jeopardy because its linear extent has become too limited to 

allow a minimum number of towers.

Nopar

 The power line will be a visual and even a spiritual degradation of our home site, responsible land and wildlife stewardship, 

magnificent views of the mountains, and alter lifestyle well beyond the time of development.

Nopar

 the only logical route is the one currently listed as the proposed route thru Section 9 Yo

sup

100191 ERLE AND 

CHARLEE BARTO 

I strongly urge all new construction and upgrades to power carrying capacity be confined to the existing easement corridor. No

line

 it bothers me that Rocky Mountain Power uses the excuse that the Homeland Security Department dictates the degree of 

separation for newly constructed power lines, using some formula for destruction by flying aircraft.

NoSe

100193 ARIN WESNITZER Alternative 1E-A would cross sage grouse core area outside an existing transmission line corridor, which is inconsistent with 

the Governor’s executive order.

The the 

 Going around the core area along alternative 1E-B will require significant removal of trees on private lands which can be 

avoided by adopting alternative 1E-C.

YoSe

 Going around the core area along alternative 1E-B will require significant removal of trees on private lands which can be 

avoided by adopting alternative 1E-C.

YoSe

100194 KENNETH 

SCHNEIDER 

I wish to urge the usage of exisiting Right of way 1E-C. Yo

Se

100195 LAWRENCE AND 

SHARON BRAINARD 

the existing corridor for transmission lines needs to be used and another corridor should not be created. No

conhav

 I currently have to look at wind turbines in the distance from my cabin porch, and do not want to see transmission lines also.

These lines would greatly effect the scenic beauty of the area

Nolonas 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100196 GOLDEN EAGLE 

AUDOBON SOCIETY

Transmission towers may provide areas for perching for raptor species; however, vertical structures and increased raptor 

perches may deter Sage-Grouse activity

Thi

many of the alternative routes for line crossings at the Snake River Canyon (e.g., crossings near Halverson Lakes and the 

Mouth of Sinker Creek) pose increased collision risk for flying raptors.

Noof c

Alternative route 9D minimizes habitat degradation because it follows an existing transmission line and the line will cross the

Snake River Canyon at its narrowest point, reducing collision risk.

Yo

We encourage development of a plan for a single new Gateway West Transmission Line that runs along route 9D (as proposed by the Owyhee Citizen’s Task Force). We oppose construction of 2 new lines within NCA that will lead to increased habitat fragmentation and invasion of exotic species. We also oppose the other alternative routes for lines crossing the Snake 

River Canyon because they will increase hazards for avian species and diminish the beauty of one of Idaho’s most famous natural areas.

Nowo

100197 PAT MCCAMMON We however have a few concerns about the EIS not taking a hard look at what the Cassia County task force has to say. ...the 

lack of value that was given to the property values in the county is another great concern of ours. Many of the folk that live here 

have made great effort to improve the way of life in the county. Which makes the value of all our property worth way more than 

you have stated in your proposal

Coinfothe in Switthe Co

100198 SUNNY LEE If the Power Lines are put up it will greatly impact the beauty No

 I'm asking that you do not place the power lines on the Fontenelle place or the basin which is near Kemmerer Yo

sup

100199 LYNN 

DAMPMAN,JOHN L DAMPMAN JR 

it’s unconscionable to place industrial-scale, high voltage power lines and towers between I-25 and the town of Glenrock. This 

would not only destroy residents’ view of the mountain but would also serve as a disgustingly unattractive landscape fixture for 

the main entrance into our little town

Yono we

100201 JESSE & MCKELL 

GILLARD 

I DO NOT want the power lines going over Commissary Ridge! Yo

sup

 They need to go along the existing rout Yo

supline

100202 BETTY SLIFER First I am not convinced that it is needed. It CERTAINLY is not needed for Idaho. And why should Idaho citizens suffer from 

living under massive transmission lines and towers and from paying higher power rates so that Vegas, Arizona, and California 

can benefit?

Nopro

 Also, I am concerned that this Project would stimulate the production of coal. No

ana

 If the lines and towers go through private lands, what compensation will there be for landowners Co

cascom

 In short, I am opposed to this Project, and hope that it will not be approved. Yo

100204 TERRY CHASE I strongly urge blm to use aternate 1E-C Yo

Se

in tCh

100205 SUZANNE DILLS I support only the 1E-C route Yo

Se

in tCh

100206 TAMMIE AND BILL 

SCHEETZ 

My husband & I strongly oppose Gateway West 1E route. We moved to Glenrock because of small community. Between 

transmission lines and wind turbines were are losing our views and property values.

YoSe

in tCh

 We feel the alternate route 1E-C would be a better route. Yo

Se

in tCh
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100207 STEVE BERDAHL As a land owner in Natrona and Converse County I would strongly ask that you use corridor 1-EC Yo

Se

in tCh

 not corridor 1E-A or 1E-b. Yo

tabconpro

100208 WYOMING 

LEGISLATURE

It appears to me that the Route alternative for the transmission line should follow as close as possible the option, 1E-C which

is, as much as possible, along the existing transmission line corridor. It appears to be the shortest route and would disrupt the 

least amount of population and disturb the least amount of our geographical features.

YoSein tCh

100209 SAM SHOULTZ Proposed gateway west transmission line segment 1E-B alternative would go through some rough, mountainous terrain, 

interspersed with wet meadows, springs and bogs, and would be expensive to construct, and to maintain, especially when 

there are existing corridors to be utilized, and they run through the plains, a much cheaper route and one easier to maintain.

YoSein tCh

100210 MATT 

DARRINGTON 

I am opposed to the proposed route through Cassia County, Idaho. No

7I, we

 This large transmission line will not only diminish the view shed but will also likely interfere with radio signals. No

we

freqadd

 If the project is approved, the alternative state line route should be followed as it is in a more remote part of the state, does not 

involve so much private property, and will not have such a great impact on as many people.

Yo

100211 DEE AND ANGELA 

DARRINGTON 

The State Line route is the only route that I could accept. I will oppose any other route than the State Line route. Yo

100212 RANDELL PARKER However I am against this project and the construction of new power lines for political purposes. Yo

for 

 Alternative 1E-C is preferable to the other alternatives. Yo

Se

in tCh

100213 DALE ROBBINS, 

SAUNDRA ROBBINS 

We would like to see route 1E-C which follows the existing corridor used for this Transmission Line. Yo

Sein tCh

 We are against the routes of 1E and 1E-A and 1E-B Yo

tabconpro

 Routes1E,1E-A and 1E-B are not needed as there is a proposed 

Wheatland-Chugwater- Aeolus route which would pick up any wind turbines located to the east and south of this area. For these reasons we believe it is totally unnecessary to go through the pristine area in the undisturbed mountainous area of the southern Laramie Range when the same objective can be accomplished by staying in the current corridor, 1E-C.

Yotabconpro

100214 RICK CRONK We the people that have lived here in Wyoming do not need any more junk. "transmissions lines" No100215 ROBERT LOVE Section 4 undermines the state of Wyoming’s efforts at sage grouse conservation ...the governor specifically modified the 

state’s sage grouse conservation plan to establish a corridor for power lines through sage grouse core areas. The DEIS rejects 

these efforts in favor of the proposed route

Yoincplawit

100216 ROBERT AND 

JOANNE HOLLAND 

Your lines would impact the airspace...Your lines need to be routed away from the hills and mountains south of Declo, ID. Our 

lives would be endangered by possibly getting tangled in your power lines.

No
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100217 KERRY MELANIE 

BOWEN 

I farm in the magic valley and contend with one of BPA's power lines. Like gateway's proposal to cut across farm ground 

because it was the least expensive route. What they did was shift the cost of the added construction cost to me with their 

shorter route. Because it cuts across my land the requires me go around the towers, plus the towers make it impossible to install more efficient irrigation systems. Thus it cost me 50 to 75 dollars per acre depending on crop. 

The tag line for this power line is "It is for the public good." If it is good for the public then public assets (public land) should be 

used to build it. The added expense in the grand scheme of things is so small that it should not be considered. But gateway 

west wants to save that money and transfer the cost to farmers that will have to bear the cost of having the power line cross 

their property for ever more

No

Vaof t

100218 PAUL WALDON I'm requesting that you follow the Owyhee County Commissioners reccomendation for Alternative 9D for the corridor as 

developed by the Owyhee County Task Force.It minimizes the impact to private property as well as Sage Grouse habitat.

Nogroas Ch

100219 MICHAEL SMITH I would strongly support all efforts to site this powerline along existing transportation corridors and other power transmission 

corridors to minimize viewshed issues along the pathway.

Noexiin S

100223 THE NATURE 

CONSREVANCY

TNC agrees with the BLM's statement in the DEIS that the extent of compensatory mitigation is a key factor in evaluating the 

project's environmental effects and in shaping BLM's decisions on the project permit (Draft Environmental Impact Statement at 3-11-72 - 3-11-73). In fact, we believe that Gateway West offers an unparalleled opportunity to establish sound policies and 

principles to guide compensatory mitigation for large infrastructure projects in sage grouse habitat.

Nocon

The Nature Conservancy (TNC) respectfully requests that the Bureau of Land Management (BLM) provide an opportunity for 

additional public comment regarding compensatory (offsite) mitigation measures for the Gateway West Transmission Line before BLM prepares the final environmental impact statement (FEIS) for the project. The sage grouse impacts analysis and 

compensatory mitigation measures were not included in the draft environmental impact statement (DEIS) and will not be available to the public prior to the close of comments on the DEIS. ... Rules implementing the National Environmental Policy 

Act (NEPA) emphasize that agencies should make diligent efforts to involve the public and give BLM flexibility to craft 

procedures to accomplish that objective. 40 C.F.R. § 1506.6. In this instance, additional public comment on the mitigation 

measures is likely to produce valuable perspectives for the BLM and to lead to a better and more broadly accepted decision. ...

To ensure that BLM has a full opportunity to incorporate public input on compensatory mitigation, additional public comment should occur as soon as BLM is able to share results of the Habitat Equivalency Analysis (HEA) and draft mitigation measures but before BLM prepares the final environmental impact statement (FEIS). We encourage the BLM to reach out to the Conservancy and other interested organizations as a first step toward developing an interactive process for public engagement on this key element of the Gateway West project.

Adgro

100224 IDAHO 

CONSERVATION LEAGUE

Yet, the draft does not share the information needed to allow the public, the proponents, or agency decision-makers to 

evaluate meaningfully the full range of impacts and the adequacy of mitigation. Under these circumstances, the agency should circulate a revised draft in the form of a Supplemental Environmental Impact Statement (SEIS), per 40 C.F.R. §1502.9. We 

formally request an SEIS including the fully completed HEA, quantification of indirect impacts, a compensatory mitigation plan with projected costs,and a DDC. Such an SEIS will allow the public, the proponents, and the agency to identify the best route, meaningfully evaluate sage-grouse impacts, evaluate compliance with Wyoming Executive Order 2011-5, and plan effective mitigation.

In mBoin treleInteconFin

We are also concerned about coherence with BLM’s Idaho IM 2009-006, regarding incorporation of the Conservation Plan for 

Greater Sage-Grouse in Idaho and Local Working Group conservation plans.

No

Se

We are actively engaged in preparing comments for the Gateway West Draft Environmental Impact Statement (DEIS), and find 

the sage-grouse analysis in the document is inadequate for evaluation and meaningful comment. Without a completed Habitat Equivalency Analysis (HEA) and quantification of indirect impacts, the public, the proponents, and the agency are unable to identify the best routing for the line and the mitigation needs. Without a completed density disturbance calculation (DDC), 

evaluation of compliance Wyoming Governor’s Executive Order 2011-5 is not possible.

In mBo

in treleInteconFinPrereq

100225 SHANE AND 

HEATHER POWELL 

I oppose 1E-A and 1E-B for the following reasons: -These corridors are within a very large elk migration route. If we disturb this historic pattern for the elk we will be damaging 

revenue for the state as licenses decrease.

YosupAlteana
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100225 SHANE AND 

HEATHER POWELL (cont.) 

I oppose 1E-A and 1E-B for the following reasons: ... -The transmission lines are very ugly and will deter tourism in these 

areas. -Building transmission lines through the mountains will be very costly, this is going to affect the already hurting Rocky 

Mountain Power customers. -We are in economic hardship and even if we do see revenue from this project it may be several years from now, possibly too late for some families.

YosupAlteana

 I support IE-C for the following reasons: 

-Parallels 1W and stays in an existing corridor, not damaging additional land. 

-Does not involve core sage grouse areas. -Does not trespass on landowners who are not supportive of the transmission lines. 

-I want our piece of land to remain untouched by the unpleasant city atmosphere. After all, this is why most of us reside in Wyoming. -The power lines will forever change our unique landscape, family history, and property value.

YoSein tCh

 I oppose 1E-A and 1E-B for the following reasons: 

-These corridors are within a very large elk migration route. If we disturb this historic pattern for the elk we will be damaging 

revenue for the state as licenses decrease. -The transmission lines are very ugly and will deter tourism in these areas. -The majority of landowners in these corridors strongly appose the development. -Building transmission lines through the mountains will be very costly, this is going to affect the already hurting Rocky Mountain Power customers. -We are in economic hardship and even if we do see revenue from this project it may be several years from now, possibly too late for some families.

YosupAlteana

100226 SHANE AND 

HEATHER POWELL 

Although I am in favor of renewable energy, I question if mountainous areas are good location for the lines. You know as well 

as any Wyomingite, that we have harsh winters and many months out of the year the roads are drifted and muddy. The skinny 

Fort Fetterman road is very curvy and we have a very difficult time getting a cattle pot around the corners. I feel that in order to get their construction materials and equipment up to the location, they are going to have to build a road to make it easier on 

transportation to and from the work site. I dread that they will forever change the great historic significance that this area provides to Wyoming and our residents

Noconhav

 I would like to oppose 1E-A and 1E-B Yo

supAlteana

100227 SAM CONNOLLY, 

DANIEL ZYVOLOSKI 

[Ranch] would like to see the BLM support the use of mitigation banking as a tool to offset any negative impacts to the landscape in this EIS. Mitigation banking will expedite the NEPA permitting and allow for the overall landscape condition to 

improve for wetlands and sensitive flora/fauna.

Nodis3.9

 In conclusion, [Ranch] supports the construction and operation ofthe proposed Gateway West transmission line as proposed 

by Idaho Power Company and PacifiCorp in the Proposed Action.

Yo

 [Ranch] has no opposition to any of the routes except the proposed 1E segment. Yo

Se

in tCh

 Not only has the proposed lE route drawn stern opposition, thus slowing down the NEPA process, it may not be required due 

to an abundance of power generating resources along the 1W segments.

YoSein tCh

 The routes supported by [Ranch] are those routes that parallel existing transmission lines, thus limiting the impact to the 

landscape.

YoHoconpro

 The Purpose and Need presented by Idaho Power Company and PacifiCorp will benefit [Ranch] and surrounding landowners 

by allowing its world class wind energy resources to get developed. The direct economic benefits to rural Wyoming generated 

by the construction of the transmission line and the royalties provided by the subsequent wind energy generation will allow the

ranching way of life to continue for future generations.

No
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100228 KATHLEEN PATCEG I am very concerned about the transmission line being constructed between Glenrock and I-25. I would like to see it moved to 

a different location

NoGle

conpro

100229 KASEY DRUMMOND I do not want to see these transmission lines within the town limits of Glenrock, WY Yo

supAlteana

100230 STAN MITCHEM, 

KAREN MITCHEM 

The proposed route (1E) that lies between the town of Glenrock and Interstate 25 crosses land that had been annexed into the town for future development. This would adversely affect future development.

YosupAlteana

 The best and most cost effective alternative would be to follow the existing transmission line corridor, rather than covering the 

whole countryside with new transmission lines.

YosupAlteana

100232 DEAN & REVA 

TOBIAS 

Start with placing the Gateway West transmission line in the ALTERNATE 9D as proposed by the Owyhee County Commissioners

Adand as com

100233 KAREN HOPKINS I am opposed to the proposed location of the Gateway West Transmission Line Project as it would have a detrimental effect on 

current economic development plans for that stretch of land which lies between Interstate 25 and the Town of Glenrock

YoSeAlteana

 it would certainly not present a welcoming atmosphere for travelers who may wish to partake in Glenrock services and 

businesses

Nothe 

100234 PAUL ROBINSON The BLM’s mission is to “sustain the health, diversity and productivity of the public lands for the use and enjoyment of present 

and future generations”. Two redundant power transmission lines through untouched land to collect from a “proposed” wind farm hardly conform to your mission

YoSeAlteana

 I am writing to you concerning the proposed 1 E-A and 1E-B power transmission lines through the Laramie Mountain Range. 

These proposed transmission lines would be used to collect energy from proposed wind farms in the area. I am not an 

opponent of “green” energy or even pursuing wind development but we need to be cautions when we as a society begin to destroy pristine lands for development of these ventures.

Yosupconhav

 It doesn’t seem very “green” to me to place a wind farm or transmission lines in an area that would create a negative impact on 

the environment. The proposed 1E-A and 1E-B transmission lines would do just that by disrupting thousands of acres of land 

in a virtually untouched natural treasure.

YoSeAlteana

 Furthermore these lines would affect elk migration routes, sage grouse habitats and countless other species of wildlife. No

The des

100235 HAWKWATCH 

INTERNATIONAL

To the degree possible, the siting of the transmission line in Segment 4 should avoid transecting any high elevation northsouth ridgelines to reduce the risk to migrating raptors that commonly use such features throughout the West (Goodrich and 

Smith 2008).

NoThe in tmig

Where such ridgelines cannot be completely avoided, bird diverters should be used to reduce collision potential. The GWDEIS 

suggests use of flight diverters (GWDEIS WILD-8), but primarily in relation to water crossings. This should be expanded to potential migration corridors as identified here. Additionally, pre- and post-construction surveys at such sites are recommended 

to determine collision risk and actual mortality and guide any necessary mitigation measures.

No

age
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100235 HAWKWATCH 

INTERNATIONAL (cont.)

Both Bald and Golden Eagles are protected by the Migratory Bird Treaty Act (MBTA) and the Bald and Golden Eagle 

protection Act (BGEPA). The Bald Eagle is also a Wyoming BLM sensitive species. Additionally, The U.S. Fish and Wildlife 

Service (USFWS) has expressed a current “no net loss” goal for Golden Eagles, due to concern over the current population 

status (USFWS 2011). Given eagle use of Commisary Ridge as a migration corridor (i.e., average of 438 eagles per year), the proposed route for Segment 4 has the potential to result in unlawful take under the MBTA and BGEPA. An average of 39 

Northern Goshawks (Accipiter gentilis) and 11 Peregrine Falcons (Falco peregrinus), both Wyoming BLM sensitive species, 

also pass through the site each fall. Given these concerns, we cannot agree with the conclusion of the GWDEIS that “The 

Gateway West Project would not have a measurable adverse effect on migratory bird populations or significant bird 

conservation sites” (GWDEIS 2-208 and 4-71) without considerable additional attention being given to the potential migratory raptor collision risk issue outlined here.

Re

Transmission lines and associated structures can also be dangerous for birds due to risk of electrocution or collision. 

Regarding electrocution, we suggest that an Avian Protection Plan be developed for the transmission line in accordance with 

APLIC guidelines (http://www.aplic.org/).

Botbee

Unfortunately, the DEIS does not give adequate consideration to the raptor collision risk associated with the project proponent’s preferred route through Segment 4 that transects a known raptor migration ridgeline (See Figure 1 below). 

HawkWatch International has operated a fall migration count on Commissary Ridge for the past 10 years and has recorded an 

average passage of 3,665 raptors each fall and an average of 268 Golden Eagles (Aquila chrysaetos), 158 Bald Eagles 

(Haliaeetus leucocephalus), and 12 unknown eagles (Mika and Hawks 2011). Although the GWDEIS does acknowledge the 

existence of this HawkWatch site, it fails to address raptor migration passage volume, use of the entire north-south ridgeline for 

migration, or collision risk associated with the proposed line crossing the ridge perpendicular to this migration pathway (see GWDEIS 3.10-16). In contrast, the recently revised Kemmerer RMP (KRMP; BLM 2010) recognizes the migratory importance of the ridge (see KRMP page 3-60) and also acknowledges that powerlines are an ongoing issue for raptor conservation in the area (KRMP page 3-68). However, the GWDEIS fails to recognize these raptor-related topics as potential KRMP conformance issues (GWDEIS Table 2.2-1). Similarly, the list of issues affecting route decision for segment 4 in the GWDEIS did not include

raptor migration issues (GWDEIS 2-61) despite the fact that we submitted comments of this nature during the scoping period 

and annually supply migration reports to the Kemmerer BLM, a primary supporter of this count site.

ComoimpdoeRMfacdisthe 

However, we also suggest that greater use of single-pole support structures will also reduce raptor perching threats to BLM 

species of concern such as sage-grouse, pygmy rabbits (Brachylagus idahoensis), white-tailed prairie dog (Cynomys 

leucurus), ferruginous hawk (Buteo regalis), burrowing owl (Athene cunicularia), sage thrasher (Oreoscoptes montanus), loggerhead shrike (Lanius ludovicianus), Brewer’s sparrow (Spizella breweri), and sage sparrow (Amphispiza belli), etc

Noangadv

Regarding the entire project, we encourage the adoption of the single solid pole-structures for the transmission line towers to

the maximum extent possible in order to avoid supporting increases in common raven (Corvus corax) populations. Lattice-type towers provide perching and nesting substrate for ravens, often increasing their population rapidly in areas with historically 

lower densities (Engel 1992, Steenhof 1993). This is problematic because ravens are known predators of greater sage-grouse 

(Centrocercus urophasianus; Coates 2007).

No

100236 WILLIAM J 

BROCKMAN 

I believe the first paragraph should have stated that the 1,100 miles of power line does not go TO Wyoming and Idaho but originate at the fossil burning (coal) power plants in Wyoming and passes through Southern Idaho with a final possible destination of Las Vegas and Los Angeles.

The 

 As we all know there is already a corridor of B.L.M, Forest Service and State land that is 29 miles wide and runs the length of 

Cassia and Twin Falls Counties. Let's use it

It is of a 

 We know there is already another line permitted to parallel the Valmy line. The long range plan calls for at least 4 to 5 more

lines to be built over the next 25 years as needed. We are not as concerned with the current Valmy line or the next line as we are that a POWER LINE CORRIDOR is being established as we continue to attend meeting after meeting

The Ch

 Lets explore the big question. Do we need it? Probably not. With the wind farms and solar projects being proposed in Southern 

Idaho we may be able to produce our own green energy here at home.

The pow

100237 MICHAEL W AND 

STEPHANIE N WELSH 

This portion of Commissary Ridge is a prolific elk calving ground that needs to be protected from this type of industrialization. 

The area is also critical mule deer summer and winter range that is one of the last non-fragmented winter ranges for the dwindling Wyoming Range Mule deer herd.

NoPrethe Ch

 I am writing to express my concern about the Northern Alternative being considered for Segment 4 of the Gateway West 

Transmission Project. I own property in the path being considered and I am adamantly opposed to its selection. There are many public and private resources that will be negatively impacted by routing the line through this pristine area. Some of the 

impacts will include reduced property values, lower quality of life, reduced tourism, wildlife habitat fragmentation, lower quality 

recreational opportunities, loss of Native American cultural resources, impact to pristing areas of the Sublette Cuttoff of the

Oregon Trail, and an increase in negative health effects.

YosupconAlteana
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100237 MICHAEL W AND 

STEPHANIE N WELSH (cont.) 

B. If the constraints in Option A prove insurmountable, I am also in favor of the BLM Kemmerer FO suggest alternative that 

runs near Highway 30 at the southern edge of the routes being analyzed for Segment 4. Again, this option uses previously established corridors. Impacts to sage-grouse have already been realized. The perches through the areas have already been established.

Yotabcurpre

 C. The most encompassing solution to protect the areas pertaining to sage grouse and historic trails is to skirt the controversial 

Kemmerer region to the south. The first option is to re-enter the West Wide Energy Corridor (Record of Decision) after the 

Bridger substation. Route the new line through the WWEC to an area near Evanston. Near Evanston, parallel the existing 

transmission line North along Wyoming Highway 89 to Highway 16. Parallel the existing transmission line north along Highway 

16 to Sage Junction. From Sage Junction, bear north to reference point 4b.8, 4b.12, 4b.13, 4j, and then 4k. (Please see Exhibits 1A, and 1B) o While slightly longer in length, this solution would make use of the West Wide Energy Corridor that was developed for this very purpose. In doing so, it would route the new line through an area already disturbed by utilities routing, wind farms, and Interstate-80. (This added length of approximately 28 miles, is less than the length added in segment 1 to avoid similar 

constraints in the Laramie Range. Residents of Kemmerer should be afforded the same consideration as the residents of the 

Laramie Range with regard to preserving this pristine area. At the public meeting in Kemmerer, we were informed that each additional mile adds $1 million and that the cost of the overall project is estimated to be $6 billion. Using these estimates, the 

percentage increase in project cost to skirt the areas of controversial constraint near Kemmerer is 0.47%. This is less than one half of one percent. If a project doesn’t have enough contingency built in to handle an overrun of one half of one percent, I 

question its overall feasibility and its justification.) o This solution would parallel existing corridors, completely around the core sage-grouse habitat and mule deer winter range 

southwest of Kemmerer. o This route would avoid the trail concerns of the Kemmerer Field Office. 

o This route would avoid ruining the pristine environmental areas of Commissary Ridge, the Hams Fork, and the Tunp Range. 

o Since the EIS has been completed and approved for the ROD, use of the WWEC will save money, time, and resources. o This route will draw the least amount of public opposition since it is through areas already impacted by industrialization. 

o There will be less impact to the environment in this option. This route will cross far less Greenfield designation. 

o The topography of this route is considerably less steep and rough than the Northern Alternative. It is also very accessible 

and would require minimal road development. It is much better suited for utility routing. o Because of the better access and proximity to larger communities, construction costs would be much cheaper. Concrete availability, crane access, and material supply logistics would be greatly simplified. 

o While wind farm development in the Kemmerer area may be an argument for running the new 500KV through the Kemmerer area, the 345KV line already exists to accommodate this future load. The load could be balanced at the Jim Bridger plant to 

transfer more transmission from the eastern part of the state through the 500KV line along I-80, freeing up the capacity of the345KV to carry the added load of wind farms near Kemmerer. o This option was half heartedly looked at in your draft EIS but your solution ran the line through the metropolitan area of Ogden. Try going north from Evanston so the option doesn’t look so bad on paper.

NoSta

con

 B. If the constraints in Option A prove insurmountable, I am also in favor of the BLM Kemmerer FO suggest alternative that 

runs near Highway 30 at the southern edge of the routes being analyzed for Segment 4. Again, this option uses previously 

established corridors. Impacts to sage-grouse have already been realized. The perches through the areas have already been established. o Your maps show this to contain active FMC Trona mining leases in the area southwest of Kemmerer. Please check this 

information as there are no established Trona mines in this immediate area.

Yotabdescon
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100237 MICHAEL W AND 

STEPHANIE N WELSH (cont.) 

D. From the proposed route (red route) or the southern feasible alternative route (green route) on the Segment 4 map, route 

the new transmission line south from Kemmerer along an established transmission corridor paralleling Highway 189. Parallel 

this existing line around the core wildlife areas and back up along the west side of the core wildlife areas to an area southwest 

of Cokeville meadows. Rejoin the green feasible alternative on the west side of Cokeville meadows and proceed up the Wyoming/Idaho border to the intersection of the 345KV line north of Cokeville. (Please see Exhibit 2.) o This solution would follow existing corridors around the core sage-grouse habitat and mule deer winter range southwest of Kemmerer. o This route would avoid the trail concerns of the Kemmerer Field Office. 

o This route would avoid ruining the pristine environmental areas of Commissary Ridge o This route will draw a lesser amount 

of public opposition. o Less environmental impact. This route will cross far less Greenfield designation. o The topography of this route is considerably less steep and rough. It is better suited for utility routing. 

o There are one or more existing transmission lines along this route that can be paralleled for almost the entire route. 

[Exhibit 2 - Option D - Route Gateway West around Kemmerer Constraint Conflicts Follows existing transmission lines and parallels US-189, I-80, and US-16 (This option uses established corridors around sensitive areas and minimizes conflicts)]

Noconthe conSe

 E. From the proposed route (red route) or the southern feasible alternative route (green route) on the Segment 4 map, route 

the new transmission line southwest from Kemmerer along an established transmission corridor leaving Viva Naughton power plant. Parallel this existing line past Elkol, Scull Point, over the Bear River Divide to a point where the line intersects with an 

existing transmission line running north along highway 16. Parallel the existing line north along Highway 16 to an area southwest of Cokeville Meadows. Rejoin the green feasible alternative on the west side of Cokeville Meadows and proceed up 

the Wyoming/Idaho border to the intersection of the 345KV line north of Cokeville. (Please see Exhibit 3.) o This solution would follow existing corridors. While it would cross some wildlife habitat, the impact to the sage-grouse would 

be minimal since any raptor perches in the area have already been established with the existing transmission line. Impact of 

the overhead power line on big game should not be an issue if activity and construction is limited during the winter months. o This route would avoid the trail concerns of the Kemmerer Field Office. o This route would avoid ruining the pristine environmental areas of Commissary Ridge, the Hams Fork, and the Tunp Range. 

o This route will draw a lesser amount of public opposition since there is already a major transmission line in the area. 

o Less environmental impact. This route will cross far less Greenfield designation than the northern Kemmerer consideration. 

o The topography of this route is considerably less steep and rough. It is better suited for utility routing. 

o There are one or more existing transmission lines along this route that can be paralleled for almost the entire route. The area 

has previously been disturbed. o This option adds a minimal distance while delicately traversing core sage grouse habitat. [Exhibit 3 - Option E - Route Gateway West around Kemmerer Constraint Conflicts. Follows existing transmission lines through controversial sagegrouse habitat and then parallels existing transmission lines north along Highway 16. (This option uses established corridors through sensitive areas and minimizes conflicts)]

Noelim

 A. I prefer that the company run the new 500KV line parallel the existing 345KV Bridger line as initially preferred by Rocky 

Mountain Power, the Governor’s Office, and the Wyoming Game and Fish Department. * (Option A 1) Parallel the Existing 345KV

Yo

 * (Option A2) Upgrade the existing 345 KV Bridger Line in the Preferred and Proposed Route to a higher capacity line. (Use 

the same ROW.)

Noelim

 * (Option A3) Bury the 500 KV line parallel to the 345KV line in areas close to the trail. 

o This practice is done in many major cities in the US. o It is common place in Europe, Asia, Australia, and Canada o Overhead lines are subject to damage from lightning, wind, ice, forest fire, avalanches, and airplanes. Underground lines are not affected by any of these. 

o While the cost is 6 times the price of overhead lines in congested cities, the cost is far less to bury the line in rural areas. 

Once installed, maintenance costs for the buried line are lower. The “view-shed” in debate from the trail observation points isnot a great length. Therefore, the required length of underground transmission is minimal. Any increased cost in underground 

installation would be offset by lower maintenance costs, better access, and shorter routing. Burying a small portion of the line 

will be comparable in costs to those created by crossing steep, forested, undeveloped mountain terrain. o Underground utilities can be put in narrower corridors than overhead utilities. This would allow the new line to be installed

more closely to the existing transmission lines. In future routing, more lines will be able to be installed in the same corridor. 

o The adverse health effects associated with a buried transmission line are far less than those associated with an overhead 

line. o A buried transmission line would be far more aesthetically pleasing. o A buried transmission line would be less detrimental to wildlife by not providing perches for raptors. With the proper surface 

reclamation, the right of way will be hardly noticeable and will even provide forage for ungulates.

A bdisDEtran230
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100237 MICHAEL W AND 

STEPHANIE N WELSH (cont.) 

Worst of all, routing the transmission line in the northern alternative will have a cumulative effect, opening the door to many

more utility corridors to follow. The entire area will go from being one of the most beautiful and serene places in Wyoming, set aside for all people to enjoy, to one industrialized ruin, reserved for big industry. If this alternative is selected, the south end of 

the Wyoming Range will become a stark, long term reminder of what goes wrong when a state loses sight of the qualities that 

make it unique and sacrifices those qualities for short term cost savings.

Nohas alte

 Routing the transmission line through the northern route will cause significant erosion of the steep slopes in the area. There

are many slopes in this considered route that are greater than 15% grade. The soil on these slopes is unstable, resulting from 

a recent forest fire that destroyed plant root systems that tie the soil together. Many hillsides can be seen sloughing as a result. 

Routing the transmission line through this sensitive terrain will do irreparable damage to the environment.

NoPrethe 

 EMF from 500KV lines will interfere with GPS, computers, TVs, cell phones, and other electric devices. Many outdoorsmen 

and county search and rescue personnel rely on GPS in the backcountry to navigate safely, especially in stormy weather. 

Because of the absence of land lines, cell phone use is the main method of communication in the area. Its hindrance will give 

rise to safety and socially related impacts.

No

 There have been a large number of Native American artifacts found on BLM and private land in the area. The riparian areas 

this route crosses were well used by our Native Americans ancestors. Routing the line through this area will impact and 

destroy much of this rich cultural resource.

NoPrethe 

 There are negative health effects of residing near transmission lines of this size. Transmission lines double the risk of leukemia 

in children. The electromagnetic forces (EMF) generated can slow heart rates of people living near the lines. EMF from a 

500KV line is dangerous to people with pacemakers and heart arrhythmias. I have a heart arrhythmia and am opposed to having the transmission line routed in close proximity to my property. The 610 page BioInitiative Report was compiled by 14 

scientists, public health experts, and public policy experts to document the scientific evidence on electromagnetic fields. The

study suggests that worldwide, standards regulating safe levels of electromagnetic fields in nearly every country look to be 

“thousands of times too lenient” (http://www.bioinitiative.org). In an article published in the Salt Lake City Tribune, Cindy Sage, 

an EMF expert reported, "EMF is a documented cancer-causing agent in the US.” It has been documented since 1998. It was also documented as a carcinogen by the World Health Organization International Agency for Cancer Research in 2001. For 

health reasons, the line needs to be routed along pre-existing corridors and away from these existing and future subdivisions.

No

 The mid and upper elevations of South Fork Mountain are also home to a large number of ruffed grouse that will also suffer a 

similar fate. The controversial pygmy rabbit also inhabits the area of route conceptualization and will suffer from increased predation and habitat fragmentation as well.

NoPrethe 

 The maps show that the lynx habitat stops at the forest boundary one mile to the north of the proposed route. In reality, the 

forest extends to the southern end of South Fork Mountain, ten miles to the south of the actual forest boundary. Lynx do not 

recognize the line our Forest Service drew on a map. They inhabit the forest on South Fork Mountain just as they do the forest north of the USFS boundary. These animals will also suffer from the associated loss of habitat and from the increased raptor 

predation on snowshoe hare, which are a staple of the lynx’s diet.

ImpLinare(i.esnoprimthe

 Locals and non-locals alike enjoy many recreational activities in the area and are opposed to the loss of view-shed, to the 

increase in noise, and to the industrialization of our wild lands. Some of the activities enjoyed in the area are hunting, fishing, snowmobiling, photography, hiking, camping, bird-watching, and wildlife watching. Routing along the Northern Alternative will 

be in direct view of the county’s only ski resort. The visual impact will create an undue economic hardship for this business.

NoPre

EIS

 The area is home to a large resident elk herd that relies on the non-fragmented expanses to provide forage and cover 

throughout the spring, summer, fall, and winter. The elk herd will be adversely impacted by the increased traffic, forest 

fragmentation, and by noise of power transmission. This portion of Commissary Ridge is a prolific elk calving ground that 

needs to be protected from this type of industrialization. The area is also critical mule deer summer and winter range that is 

one of the last non-fragmented winter ranges for the dwindling Wyoming Range Mule deer herd. Black bears and mountain lions are frequently spotted in the area of the northern route.

NoPrethe 

 higher predation on the sage-grouse that reside in the area. There are numerous flocks of sage grouse that reside at the base 

of Commissary Ridge and throughout the foothills to the east, contrary to what is reflected by the constraint map. The sage grouse in this area are just as in need of protection here as they area in other areas of the state. Routing the transmission line 

along the Northern Alternative will provide new raptor perches that will adversely impact the sage-grouse in the area. The

NoPrethe 

 The largest impact, and one that could cripple the state economy, is the impact to sage grouse. It is incomprehensible that 

pristine sage grouse habitat could needlessly be sacrificed by running the line through undisturbed sage grouse habitat to preserve a view from the Oregon trail that has already been affected by existing transmission lines. Establishing a line through 

this unaffected habitat will be one more nail in the coffin of the birds becoming listed as endangered species which will have 

the effect of crippling our state economy.

NoPrethe 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100237 MICHAEL W AND 

STEPHANIE N WELSH (cont.) 

The transmission line should be routed parallel to existing transmission line corridors or highway right of ways to avoid industrializing the unspoiled regions of our state and to avoid establishing new sage grouse perceived raptor perches in key sage grouse habitat which will undoubtedly negatively impact the sage grouse.

NoPrethe 

 If allowed to happen, the Northern Alternative will destroy the pristine, non-industrialized views and serenity of Commissary 

Ridge, the Hams Fork, and the Tunp Range.

Yosup

 Surrounding land values will diminish by 50%-80% when a transmission line with 150-198’ towers becomes the predominant 

feature of the landscape and when the sounds of nature are replaced by the incessant buzzing of electricity on its way to 

distant customers. Transmission lines of this magnitude adversely affect future land use and land development potential. In 

and along the Northern Alternative, there is an existing 168 lot (285 Acre) Subdivision called Spring Canyon Ranch. The 

average home and property value in this area is $250K. At 50% real estate devaluation, the resultant loss of investment will total $21 million for the property owners in this subdivision. An additional 640 acre subdivision is planned for the near future on 

Cameron Properties and Lott Partnership lands falling directly within the corridor being considered. One of the main roads for this planned subdivision has already been completed. Considering land in the neighboring Spring Canyon subdivision markets 

for $21K per acre, subdivided land in the new subdivision is expected to sell for $21K per acre as well. The total anticipated 

land value in this upcoming subdivision is $13.44 million. With an expected 50% property devaluation, the total loss of 

investment for this owner will be upwards of $6.72 million. The 55.3 acres that my family and I own is surrounded by the property that Cameron Properties and Lott Partnership intend to subdivide. Similarly, the value of my property will be $21K per

acre with a total property value of $1.6 million. The value of my property will drop by $750,000 if the transmission line is routed 

along the northern alternative. Similar socio-economic impacts will be felt by most of the 550 property owners in the 

surrounding area and in the town of Cokeville

The info

 The visual impact will be realized by those experiencing the Oregon Trail from most locations between South Pass to 

Kemmerer. The biggest impact will be to some of the most pristine areas of the trail along Fontenelle Creek and Pine Grove. It is here that the view from the trail is most like it was when the pioneers travelled it. The eyesore will portray a negative image 

of Lincoln County and will negatively influence tourism.

Yo

 South Fork Mountain on Commissary Ridge has been documented as a major raptor migration corridor. The proposed 

transmission line will bisect this corridor leading to raptor perching related electrocutions

Co3.13.1

100238 KELLY TUCKER I strongly appose the red 4 route going through the hams fork lake mountain fontenelle areas. Yo

sup

100240 ROBERT LOVE I am writing in regard to the assertion that using the existing power line corridor (the 4A Alternative) in Section 4 will ruin the 

Oregon Trail. For starters whatever is there to be ruined was already ruined by the existing power lines. Additional lines would 

do minimal additional damage and would spare areas on the proposed route which have not been damaged at all.

NoThe 

100241 WYOMING HOUSE 

OF REPRESENTATIVES DISTRICT 14

Many of my constituents strongly oppose Alternatives 1E-A and 1E-B in northern Albany County. I want to add my opposition 

to these alternatives.

Yosupof Adet

From a practical standpoint, Alternative 1E-C, which follows Rocky Mountain Power's existing transmission line between Windstar and Aeolus, will result in significantly less impacts to landowners that reside in my district. Furthermore, Alternative 

1E-C is the shortest and most economical route resulting in the least disturbance and the greatest benefit to the public.

YoSein tCh

100242 WALLY JOHNSON There are other sites of historical significance in this area, such as Native American ruins, camps and hunting areas. The area 

possesses a long history of ranching, and settling the West. Fontenelle Creek has been homesteaded and developed by 

hardworking immigrants over 150 years ago.

NoPrethe 

 Barnes Ranch is in the process if placing a Conservation Easement on its holdings. We are working with the Wyoming Game 

and Fish Department, and were advised that the proposed northern alternative for the transmission line will prevent the 

completion of the Easement. This will bring extreme economical hardship on our family and business.

NoPrethe 

 The area encompassed by the proposed route is rich in magnificent history. The Sublette Cutoff of the Oregon Trail is nearby 

and it would be devastating to have a power line running over it. There are other sites of historical significance in this area, 

such as Native American ruins, camps and hunting areas. The area possesses a long history of ranching, and settling the West. Fontenelle Creek has been homesteaded and developed by hardworking immigrants over 150 years ago. This proposed 

route will have great impact on the economical, social, environmental, and also emotional well being of the descendants of 

those settlers.

NoPrethe 

 The proposed line would run through a Sage Grouse Core Area, and this is totally unacceptable. Sage Grouse are under 

consideration as an endangered species. They need protection, and this line will jeopardize them further. Having them 

declared as endangered will impact Southwest Wyoming economically.

NoPrethe 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100242 WALLY JOHNSON 

(cont.) 

We are deeply concerned about the Northern Alternative being considered in Segment 4 of the EIS. The existing transmission line has already been compromised. It is unnecessary and completely ridiculous to disturb a new corridor. We believe that the 

transmission line should parallel the existing route.

Yosup

 We are deeply concerned about the possible health risks associated with high voltage transmission lines. Some research has 

confirmed the presence of chronic lymphocytic cancers and childhood leukemia in human populations associated with ELFEMF (extremely low frequency-electro magnetic fields). Ongoing recent studies have also identified neurodegenerative and 

cardiac diseases. The existing transmission corridor has already been compromised—why compromise more?

Nopro

100243 SWEETWATER 

COUNTY, BOARD OF COMMISSIONERS

An additional item when considering potential impacts to the Town of Wamsutter is that the Creston Substation is planned to be built south of the Town. To help ensure that the impacts from the Creston Substation are properly addressed, the project proponent may consider renaming the Creston Substation the Wamsutter Substation since the Substation is only approximately 2.5 miles from Wamsutter but approximately 14 miles from Creston Jct. This change would also help in 

alleviating the confusion that may be related to the location of the Creston Substation.

Codoc

Municipalities and Incorporated Communities: The municipalities that will potentially receive socioeconomic benefits and 

impacts from the Gateway West Transmission Line Project and potential cumulative impacts from additional industrial projects 

include the Cities of Rock Springs and Green River and the Towns of Wamsutter, Superior and Granger. The unincorporated communities that may receive both Gateway West and cumulative impacts include Point of Rocks, Farson and the 

unincorporated communities surrounding the Cities of Green River and Rock Springs. To provide socioeconomic information 

which will help these communities address potential impacts, it is important that this information is collected and provided in a 

manner that addresses jurisdictional or regional boundaries of the previously mentioned communities.

Coimptha

2010 Census Data: To the greatest extent possible the socioeconomic data in DEIS section 3.4 should be based on 2010 U.S. 

Census data or the most recent data available.

The of p

Free on Board (FOB): In the DEIS Socioeconomic Section 3.4, Sweetwater County encourages the BLM, to the greatest extent 

possible under the BLM's authority, to encourage Rocky Mountain Power, its contractors and subcontractors, to deliver 

construction materials "Free on Board" (FOB) to the County in which the materials will be utilized. This will help ensure that the 

sales tax will be properly allocated and paid to the County where construction and related impacts will occur.

No

Regulatory Framework: DEIS Section 3.17.1.3 discusses the County plans and regulations that the Gateway West Project 

must comply with. The planning and regulatory requirements of six Wyoming Counties and 15 Idaho counties are discussed in 

this Section. After review of the Sweetwater County, Wyoming (Segments 2, 3, and 4) portion of this Section, Sweetwater 

County suggests that the planning and regulatory summary should be revised to read: 

"Sweetwater County has two plans that address land use policies within the County - The 2002 Sweetwater County 

Comprehensive Plan and the Sweetwater County Growth Management Plan. The Sweetwater County Comprehensive Plan is 

the statutorily required land use plan that provides the land use policies that guide development within Sweetwater County as a

whole. The Growth Management Plan is a subset of the 2002 Sweetwater County Comprehensive Plan. This plan focuses on 

development policies and development plans that coordinate growth with the Cities of Rock Springs and Green River.

Thi

Temporary Work Camps: The construction schedule of the Gateway West project is estimated to span five years starting in 2013 and ending in 2018, and it is likely that other industrial projects will begin construction during this same time frame which 

will be competing for the same temporary housing market as the Gateway West Project. To meet the demands of a potentially competitive temporary housing market, companies may consider establishing man camps. If a compelling need can be 

demonstrated, a work camp may be permitted through the Sweetwater County Conditional Use Permit process. Although it is important for Rocky Mountain Power and other companies to keep in mind that it is a policy of the Sweetwater County Comprehensive Plan to encourage "... the location of associated worker housing within existing communities where services 

are and can be provided." For more information on permitting Temporary Work Camps within Sweetwater County, please contact Eric Bingham, Land Use Director at 307-872-3916.

The conconthe aveprohouproas 

The 2002 Sweetwater County Comprehensive Plan contains several general development policies that apply to the Gateway 

West Project. These policies include: • Encourage/support cooperative interaction between local, state and federal agencies and private land owners. 

• Encourage and support environmentally responsible resource development. • Encourage a balance between resource development and environmental protection. • Recognize and protect the County's unique cultural, recreational, environmental and historical resources. • Encourage the location of associated worker housing within existing communities where services are/can be provided. 

• Support the County's traditional land uses and interests. • Promote local (private) concerns and interests as an integral part of public land management decisions. 

• Encourage the proactive, coordinated planning and delivery of public utilities and infrastructure services.

Nores
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100243 SWEETWATER 

COUNTY, BOARD OF COMMISSIONERS

Since the Gateway West Project crosses approximately 140 miles of checkerboard public and private ownership within Sweetwater County, the County encourages the BLM to support Federal, state and county governments applying their 

permitting processes as a whole to both public and private lands across this checkerboard area. Separating the various penrmitting processes into private land permits and public land permits fragments the project making it more difficult for 

jurisdictions to apply their regulations in a manner that ensures unified development from one unit of ownership to the next.

NoPre

Historic Trails, Cultural Sites and Viewsheds: Sweetwater County's Comprehensive Plan calls for the County to "Identify and protect the County's unique cultural, recreational and environmental resources", and to "Encourage a balance between resource development and environmental protection". With these goals in mind, Sweetwater County appreciates the BLM's efforts in inventorying and planning for impacts that may occur to historical and cultural resources and viewsheds. Sweetwater 

County supports these planning efforts and the protection of these important resources, but at the same time Sweetwater 

County strongly encourages the BLM to carefully consider and balance how the protection of Historic Trails, Cultural Sites and 

viewsheds will affect the ability the mineral and agricultural industries to develop and utilize their resources for economic 

purposes. Sweetwater County's economy depends on the mineral extraction and agriculture industries making it very important 

that the protection of Historic Trails, Cultural Sites and viewsheds occur in a balanced manner that also protects the economy 

of Sweetwater County.

Noare 3.3

Support of Preferred Route across Sweetwater County and the Support of Alternative 4a in Lincoln County: Sweetwater 

County supports Rocky Mountain Power's Preferred Alternative across Sweetwater County with the following caveats: 

• Sweetwater County joins Lincoln County, Wyoming in supporting Alternative 4a rather than the Preferred Alternative as the 

proposed the Gateway West Project leaves the western side of Sweetwater County and enters Lincoln County. Sweetwater 

County does not support the northern route of the Preferred Alternative as it enters Lincoln County since this route adversely impacts residents of both Sweetwater and Lincoln Counties. Sweetwater County believes this northern route into Lincoln 

County should be dropped from consideration. • Sweetwater County supports the Preferred Alternative Route across Sweetwater County to Alternative 4a as long as Rocky 

Mountain Power obtains the necessary Sweetwater County development permits as outlined in this letter.

YoProdes

...since the Gateway West Transmission Line Project will require a State of Wyoming Industrial Siting Administration (ISA) 

Permit and most Wyoming governments affected by this project will be parties to the ISA public hearings, Sweetwater County 

suggests that the BLM consider formatting the Socioeconomics Section on a jurisdictional basis that would parallel the ISA socioeconomic reporting requirements. This would make the socioeconomic information not only useful for the DEIS but also 

for the ISA permit application and public hearing process.

The 

...Sweetwater County encourages the project proponent, the BLM and the State of Wyoming to carefully inventory the socioeconomic impacts of all industrial projects that are planned to begin construction during the 2013 to 2018 construction 

phase of the Gateway West Transmission Line Project...Some of the potential projects that may begin during this time frame 

include projects not only similar to Gateway West such as the TransWest and Gateway South Transmissison Line Projects, but 

also projects like the Lost Creek In Situ Uranium Project and multiple oil and gas expansion projects like NPL, Moxa Arch, Hiawatha, Continental Divide, La Barge Platform and others.

Coand 

To make the Socioeconomics section of the DEIS more applicable to individual governmental units, Sweetwater County 

suggests that this Section be revised to address socioeconomic impacts more from the perspective of jurisdictional boundaries rather than EPC Analysis Area boundaries.

Reare 

EPC Analysis Area vs. Jurisdiction Boundaries (Section 3.4.2 of the DEIS): It is Sweetwater County's experience that counties, 

municipalities, and small towns generally are more experienced in understanding and managing the socioeconomic and land 

use impacts related to their communities on the basis ofjurisdictional boundaries such as city or town limits or county and state 

boundaries rather than on the basis of Engineering, Procurement and Construction (EPC) Analysis Areas, which the DEIS 

frequently utilizes to apply its economic analysis.

As by Se

As defined by the DEIS, an "Analysis Area is a 1000 foot wide area centered over the Proposed Route and Alternatives, as 

well as a 50 foot wide area centered over any access roads that extend outside of the 1,000 foot wide area." Sweetwater 

County understands how utilizing an EPC Analysis Area may be useful when addressing issues that relate directly to engineering, procurement and construction, but the County finds it difficult to utilize the EPC Analysis Area to apply the DEIS

socioeconomic statistics and demographics to individual cities and towns like Rock Springs or Wamsutter, especially when that 

EPC Analysis Area spans county and state boundaries.

ThiThe SwpreDE

100244 CASSIA COUNTY 

GATEWAY WEST TASK FORCE, POWER COUNTY TASK FORCE

requested ... a 30 day extension to submit comments No
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100245 DUANE & AILEEN 

HALVERSON 

I would like to protest the proposed route as shown across the top of Commisary Ridge and Slate Creek Ridge in western 

Wyoming.

Yosupcurfrom 

100246 JOHN TEETER The stated purpose and need, as stated below, are incompletely articulated. The "is principally necessary to serve future 

needs in Utah and Idaho, though other markets may also be served, ..." is purposely vague and pointedly incorrect.

No

100247 MERRI MELDE There is no suitable or relevant reason for the 9E or "9" powerline, because 9D is the obvious environmental, economical, and 

aesthetic choice. 9D will run along an existing road and near an existing power line and will cause the least damage to the 

area and the environment. According to expert biologists, it will have no adverse effects on raptors or on sage grouse habitat.

Please make the right decision and use the proposed 9D route for the new powerline.

YoAlte

 I help one resident put on horse endurance rides of 25 to 100 miles, (approximately 12 per year) in and around the Owyhee 

Front. These rides have been held annually for 10 years. People come from all over the country and all over the world to participate in these rides (Belgium, England, Scotland, Malaysia, the UAE, Australia, South Africa, Japan, Guatemala, 

Argentina, etc), because the area is renowned for its unspoiled beauty. If they had to ride around and under just another huge 

unsightly powerline blighting the landscape, there would be no need to come any more.

No

 The Owyhee Front is a recreation area used and appreciated by many forms of recreationalists: horseback riders, hikers, 

bikers, ATVers. They all come for the beauty of the area, to use their public lands for relaxation and recreation. These diverse 

groups of people support the Owyhee county economy. The proposed 9E powerline near the Owyhee mountains would defile 

this landscape and turn many of these outdoor enthusiasts away to other places less offensive. Once the Owyhee Front is 

ruined, its uniqueness is gone forever. We have so few of these pristine areas left in the country, with more disappearing every year.

Notab

 [confidential cultural resources information]. Desecrating this area would cause significant cultural conflicts. No 9E is completely inappropriate in numerous ways. Yo

100248 EDMUND V BRAND, 

CAROL BRAND 

Please follow your proposed route 9D. There are many reasons to keep the line on the Northeast side of the Snake River: It will be good for the birds of prey, according to many Biologists and it will not effect private land owners in that location.

Yo

 We are oppossed to any of the routes on the Southwest side of the Snake River No

100249 HELEN BONNER object to the proposed alternate route, 9E, for the Gateway West Transmission Line Project, and to say that it makes the most 

sense to follow the highway and already existing power line routes with this new project.

Yo

100250 ALMY (BUD) 

BARNES 

proposed route of segment 4 be abandoned and Alternative 4A be used instead. Yo

proconin C

 Segment 4 The segment from Fontenelle to Cokeville is some of the most rugged and unspoiled wilderness left in Wyoming. 

Construction would be difficult and expensive and have a short season due to the severe winters in that area. A transmission 

line is a transmission line and a road is a road. Mitigation or no, the area would be scarred forever.

The Rowe

 Instead of Proposal 4 please accept Alternate 4A. Or choose EIS Para. 2.3: No Action Alternative and scrap the entire plan No

in t

100251 PAUL NETTLETON support Alt. 9D that was developed by the Owyhee Task Force...This alternative would affect the least amount of private land 

and would not affect the aesthetics or environment adversely.

Yo

 disapprove of Alt. 9E ...This route runs further south into or very near prime sage grouse habitat causing adverse effects on 

that threatened species. Those same avian predators (especially Common Ravens) would be attracted to the large towers for 

nesting and hunting perches, causing irreparable harm to the sage grouse and its habitat.

Yo

100252 IDAHO 

DEPARTMENT OF PARKS AND RECREATION

both the proposed route and alternative routes pass within 1⁄2 mile of Bruneau Dunes State Park boundary. Going around the 

park avoids Land and Water Conservation Fund 6 (f) (3) property (36 CFR 59.1), but we predict the transmission line will 

impact the visual quality of the park. The visual quality analysis for the park is inadequate. A photo point and analysis was taken on the park roads (KOP 401 (Figure E.2-10)). This point is in part of the park where the towers would be less visible rather from the top of the big Bruneau 

Dune. The main dune structure is a very popular hike within the park. The top of the dune is much closer (within two miles) and at 

similar elevation where transmission line would be located. The FEIS needs to analyze the visual quality from the top of the 

dune, as well as the park roads.

Phvis

On Page 2-100, the DEIS makes a reference to “Bruneau Dunes County Park”. Bruneau Dunes is a State Park. The correct 

reference is “Bruneau Dunes State Park”

Info
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

On Page 2-101, the DEIS states “Consultation between representatives of the BLM, U.S. Air Force, Idaho Department of Parks 

and Recreation, and the Proponents has determined that the location of the Proposed Route within the restricted Military 

Operating Area and just to the south of Bruneau Dunes State Park is acceptable.” The IDPR was not consulted on this project, 

nor has our Board had any input on whether the proposed route or alternative routes is acceptable. The reference to our 

department should be removed from the DEIS.

The conthesiti

100254 WESTERN 

WATERSHEDS PROJECT

Overall, the Gateway DEIS is poor and incomplete. The opening sections of the EIS are confusing and do not present all relevant information. Agencies should provide baseline ecological information with areas of important habitat and an analysis 

of past habitat losses in the area. Sage-grouse and pygmy rabbit habitat information is particularly lacking. The EIS also fails 

to analyze a viable set of alternatives to the proposed route. More current information is needed on active leks in all four states 

based on baseline surveys within ten miles of all potential routes. The EIS lacks complete information and visuals necessary 

for a clear picture of project impacts and understanding of area vegetation communities. 

The altestuto uundinfoFE

The DEIS is missing ecological baseline and site-specific biological and other survey information needed for a full and valid comparison of route alternatives. Baseline information should include health data for all affected lands, and summarize all permitted and actual use over the past 20 years. The potential for a proliferation of roads is not fully analyzed and the issue of 

road impacts is left unresolved. The DEIS fails to consider an adequate range of alternatives for power provision; alternatives

that rely on local power generation, home energy production and conservation should be assessed. A supplemental EIS (SEIS) is needed to fully assess cumulative impacts of the proposed project in light of current adverse impacts from livestock 

grazing in and near potential line segments, for example the potential for increased invasive plant species and negative 

impacts on springs, seeps and riparian areas. Animal unit months (AUM) should be reduced as livestock are excluded from pastures crossed by Gateway. An SEIS is also needed to provide the public an opportunity to comment on final models used in the analysis, such as the Habitat Equivalency Analysis (HEA) or any other model still to be finalized by the agencies.

ChothCabeydevAdcomcumthe req

Maps provided in the DEIS are often confusing and lacking in sufficient detail to understand potential biological, cultural, and 

scenic view conflicts with route segments. Internal BLM maps that offer relevant wildlife habitat information should be made public, especially to help understand conflicts with sage-grouse and other biological conservation plans. The DEIS is missing avariety of relevant maps, including: 1) access roads and project construction disturbance areas, 2) overlay of Dark Night Sky 

areas with route and analysis of project lighting impacts, including possible future development, 3) current 

cheatgrass/medusahead and other weed presence, 4) portions of the route north of the Snake River that would affect slickspot 

peppergrass, 5) identification of pygmy rabbit habitat along all routes, 6) location of leks along the alternate routes (currently 

presented in Table 0-11-9), and 6) all Conservation Reserve Program (CRP) lands in the project area. The EIS directs a 

reader to Appendix E, and Figures 11-2 and 11.3 for Core Habitat; the Core Area concept leaves important lek areas out and the maps do not depict Nevada leks at all. The mapping of routes is difficult to understand, for example on map E.2.4, it is 

impossible to see where current transmission lines are. In several maps, it is impossible to understand where the WWEC runs.

1) MtheagereqinfolevweeThe avosagthethe fedof lbasEIS NevlineWW

WWP questions whether the proposed transmission line is needed, given recent economic shifts that reduce energy 

consumption (e.g. jobs moved overseas, housing collapse), and the DEIS does not provide sufficient data and analysis to make a determination. Even if Gateway is found to be needed, BLM should explain why the line cannot follow previously disturbed areas. A complete, life-cycle evaluation of the proposed line versus conservation and smart grid alternatives should 

be conducted to independently assess need for the project.

The proto buse scowhgenpup

If distance separation is needed between various energy projects – what is a minimal and reasonable separation? Ge

reqtow

The EIS should fully analyze and address potential light pollution impacts from the project, including how Dark Night Sky designated areas would be affected. WWP is also concerned that once a right-of-way is established, Idaho Power may sell the path to another party and there will be no way to appropriately minimize or mitigate impacts on wildlife species and habitat.

The in happvis
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100254 WESTERN 

WATERSHEDS PROJECT (cont.)

In many areas the proposed routes do not follow the DOE Corridor through degraded lands to avoid sensitive areas; less harmful alternatives through already degraded areas should be considered. Alternatives that cross significant lands for wildlife 

habitat and recreation should be denied. Further analysis is needed to understand if routes would lead to the eradication of sage-grouse, pygmy rabbit, Brewer’s sparrow, loggerhead shrike, sage sparrow, or other rare species populations. Of 

particular concern are routes along the Nevada-Utah border, the northern part of the South Hills, the Deep Creek Range, and 

the Owyhee Front. Only routes north of the Snake River should be considered, with a crossing near Melba to Hemingway, 

creating parallel lines along existing routes to the greatest extent possible. For separation of power lines, the EIS should 

discuss the specific distance required and why it is necessary. Objections from private landowners should not trump protection 

of valuable public lands.

The conporand lanWWtranFos

Transmission line wires must be marked to maximize visibility and reduce avian collisions, and visual analyses must be done 

using such marking. As night lights appear to draw migratory birds in and cause death from collisions, the design should “bundle” any such developments with other night sky light polluters.

The The polnot inte

The EIS should consider an alternative that maximizes paralleling existing lines, major roads, disturbed land areas of WWEC segments, and energizes Idaho Power existing lines and/or other operators’ existing lines. Shorter distance connecting lines 

can be built through disturbed areas to help facilitate such an alternative.

The corchaexiunddisrou

The EIS does not provide sufficient analysis to understand why the proposed route and alternatives are best able to enhance the capability of the power grid versus a broad range of other alternate locations, conservation, and increased local energy production.

As reqProbrodetnot inccap

BLM must seriously consider the No Action Alternative given significant negative impacts across the affected landscape. 

Adequate mitigation for alternate southern routes is not possible.

The 

as 

No transmission lines should be allowed in any Important Bird Areas (IBAs). Alternatives 7I, 7J, 7A, and 7H would all have 

significant adverse impacts on recognized important habitat, and none of these should be considered further. Gateway should avoid the Deep Creek range entirely. WWP opposes all segments outing in western Twin Falls County (Jarbidge BLM) and 

Owyhee County (segment 9 and alternatives 9A-H), especially alternative 9E as OHV use is already out of control and the transmission line will cause further serious habitat disturbance. 

Yobeealtecrotran

Overall, required mitigation actions are not adequate to address all of the deleterious effects of the project, and language leaves the strong possibility for agencies to waive mitigation measures in the future. An improved cumulative effects analysis is necessary to understand if mitigation will be effective or possible. Mitigation should require that project proponents purchase a significant amount of private land with important biological values, as well as purchase of public lands grazing permits in the 

region for retirement. The EIS should clearly state that mitigation of all the negative impacts is not possible for many segments of the line. In the case of any fires caused by the project, the owner of the right-of-way must be financially responsible for

rehabilitation of the land with native vegetation only. Fore herbicide use, a full and integrated IPM approach should be used. 

No crossing of Rock Creek-Tunp can be allowed. It is not sufficient mitigation for any part of this project to put flight diverters on a fence; significant reduction of fencing must be considered. The EIS should provide full and detailed analysis of the environmental effects and effectiveness of any mitigation.

Mitcorindwe

Without annual monitoring or other ecological evaluation data, it is impossible to fully understand the current condition of lands the Gateway project would impact. Such information is necessary to understand cumulative impacts or likelihood of successful rehabilitation, particularly given continued livestock grazing.

Promoact
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100254 WESTERN 

WATERSHEDS PROJECT (cont.)

The project routes will greatly blight scenic viewsheds. The EIS must fully examine the adverse effects to enjoyment of cultural 

and historic sites. Full analysis of adverse visual effects of roads and structures from all leks and important habitats must be 

undertaken. In the morning and evening, when light hits the metal uprights at a low angle, very bright reflections can occur that 

result in visual disturbance up to several miles from the line. Figure C40 shows highly intrusive and visually disruptive 

transmission structures. Portions of the route in Wyoming conflict with VRM II and I designations (Visual Resource 

Management); any RMP amendments must upgrade VRM protections to VRM II or I for all intact native vegetation habitats 

and important wild land areas.

The affedisthe 

incimp

The project will have severe impacts on sagebrush, shrub steppe, salt desert shrub, juniper and other arid habitats. Increased 

access points for livestock will intensify disturbances. The EIS should provide a full analysis of how rehabilitation of disturbed 

areas would occur, including if only native species will be used and how global warming could impair vegetation rehabilitation.Citations should be included for how long it takes to restore arid landscapes—decades to hundreds of years. A minimum of 

five to ten years of rest, recovery of microbiotic crusts and native shrubs must be required. It is important to assess the 

likelihood of invasive species dominance and altered fire regimes caused by Gateway; large disturbed areas at the base of each transmission line tower are especially vulnerable to invasive species, which is then exacerbated by livestock. The EIS should specify how much herbicide, and what type, will be applied in association with any part of this project, and if sprayed 

dead zones will be used around facilities.

The foreHEand incHEThewe

The DEIS assessment of rare or imperiled plant species is generally inadequate. Agencies should conduct a full analysis of 

near-, mid-, and long-term viability of all BLM sensitive species and all TES species, including site-specific surveys along the 

route options. Rare plants are likely to be greatly affected by invasive species increased by project disturbance; slickspot 

peppergrass in particular is at risk from portions of the route north of the Snake River.

Coall this sensen

The Gateway project is likely to cause an increase of invasive species and facilitate their spread around the region. The EIS 

should carefully assess the risks of weed infestations across the project area, including increased risk of wildfire (e.g. 

cheatgrass in Wyoming); current invasive plant species disturbance in the area should be mapped and analyzed as part of the 

ecological baseline. Livestock grazing exacerbates the impacts from project land clearing on spreading weeds. Vehicles 

driving in and out of the project area can also spread invasive plants. Any RMP amendments for the project should include 

Integrated Weed Management, and block grazing on disturbed sites until native vegetation is recovered. Land use plans 

should also require livestock moving from a weed infested site to a native vegetation area to be quarantined until the invasive

seeds pass through the animals.

The desmaand cleDEcroreq

WWP is generally unsatisfied with the extent of information and analysis provided for the protection of wildlife. The DEIS 

should include the risk of wildfire from the project over time as it would cause substantial loss of habitat, as well as a baseline 

map of fire history. Agencies should also assess the current extent of fencing and resulting negative impacts to wildlife. 

Mitigation included so far is likely to allow continued harm to wildlife. Analyses should be conducted as found in ICBEMP and other current science-based assessments (such as the ICBEMP Wisdom et aI. 2002 species examination and other ICBEMP 

documents, also the Nevada Wisdom et aI. 2003 assessment, and the Wyoming Basin Environmental Analysis) to examine 

the full range of ecological threats and habitat fragmentation that currently exists for sensitive species. Site-specific surveys 

for winter habitat are needed for the route, and any found winter habitat should be avoided. Precautions to pre-construction surveys should be applied to all migratory birds and raptors, and sensitive mammal species, not only sage-grouse. The EIS should include the March 2010 Federal Register Warranted But Precluded consideration of tall structures, road disturbance 

and many other adverse impacts, as well as discuss chapters in the Knick and Connelly 2009 Studies in Avian Biology. Further analysis of impacts from the transmission line wires is needed, such as what species have low frequency communication and how the lines could impact this.

The EnpolhowUtathis groimpsecfor surappSeRefreqWinresappSeRefreq

Habitats in the Gateway project area have already been altered and fragmented from many other land uses, particularly livestock grazing, fences, water developments, ranching, vegetation treatments, and desertification. The DEIS lacks baseline 

habitat fragmentation information that would provide a basis for evaluating impacts from the project on habitat connectivity. The potential for additional habitat fragmentation from future linked projects should be considered. Many of the DEIS photos 

(e.g. Figure E 3.19, E3-23, and 3-27 and 2-29) appear to show in-tact habitat that would be impacted by the transmission line. 

Impapp
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100254 WESTERN 

WATERSHEDS PROJECT (cont.)

The DEIS lacks sufficient attention to raptor species. All raptor nest sites should be avoided during sensitive nesting periods

(i.e. no project construction or road activity). Agencies should conduct site-specific surveys throughout a 10-mile range of the 

project routes. It is unclear how extensive any previous surveys have been, and not credible that only one known raptor nesting location exists in the area. Raptors are also at risk of colliding with transmission lines during migration, and such 

collisions can result in hazardous fire events.

All a firap

The DEIS must analyze how project routes may block or impede big game use and movement, including during periods of 

snow. Page 2 of Appendix 1 [sic, may refer to Appendix I] lists the Wells RMP antelope winter range, but has no further 

information. Fences are a known impediment to mule deer, elk, bighorn sheep, and antelope. It appears portions of segment 7 

are located near the Jim Sage bighorn sheep population, but clarification is needed. Agencies should examine all stresses that 

bighorn sheep populations may be under in the footprint of the Corridor, including disturbance by cattle grazing, and disease 

issues with domestic sheep.

Dis3.1or nsheProcon

Migration routes in the project region are poorly understood. As Gateway lines and subsequent development (e.g. industrial wind energy) could cause large numbers of collisions and other harmful impacts, detailed multi-year analysis of migration 

routes that cross the proposed transmission corridor should be required before proceeding. Lacking a basis in current on-site survey data and in-depth analysis, the DEIS conclusion that Gateway “would not have a measurable adverse effect on 

migratory bird populations, habitats ecological conditions and/or significant bird conservation sites" is invalid. Of particular 

concern is the continued viability of Brewer’s sparrow, loggerhead shrike, and sage sparrow populations in the area. Design of the transmission line and associated infrastructure should take all possible precautions to avoid migratory bird mortality. All

project activity must be prohibited during migratory bird nesting season; this should extend from March 1 through July 1 at a 

minimum, and longer in higher elevation areas. Project activity should avoid habitat for avian species of significant concern -

including pinyon jay, black-throated gray warbler, Virginia's warbler, juniper titmouse, and other migratory songbirds that mayinhabit sagebrush and pinyon-juniper systems. No guy wires should be allowed as they pose a collision risk for bats and avian species. Agencies should review the work by Chris Wood, Dr. Tom Cade and others on the Owyhee Front shrike populations 

that would be severely impacted by southern Section 9 alternative route segments.

The BreSevimpClepre

canprewe

can 

New road networks from the project will increase sedimentation and harm sensitive salmonid habitats. Pollution from hazardous substances (e.g. PCBs, utility industry chemicals, petroleum products, herbicides, etc.) can contaminate waters 

used by aquatic species. The EIS is inadequate in presenting information and analysis for rare Colorado river fish.

Proworedand outand proextRivRespeocc0.1 like
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100254 WESTERN 

WATERSHEDS PROJECT (cont.)

Overall, the DEIS lacks sufficient site-specific biological information to assess current health of and project effects on many

rare and sensitive species. Agencies should conduct a full analysis of near-, mid-, and long-term viability of all BLM sensitive species and all TES species, including site-specific surveys along the route options. Baseline data is needed for loggerhead shrike, sage sparrow, lek areas, sage-grouse, pygmy rabbits, migratory songbirds, and other rare species. The DEIS groups 

species according to habitat requirements or life history traits. This is unacceptable, as each species has specific habitat 

requirements. Sage-grouse are not a surrogate for sage sparrow, loggerhead shrike, Mojave collared lizard, and other lower elevation Wyoming big sagebrush species, including those that occur at interfaces with salt desert shrub. China Mountain and 

Gateway development, and potential linked future energy development, could result in a significant decline in pygmy rabbit and other wildlife. Sensitive wildlife species could be particularly harmed by new roads (including sedimentation) and pollution 

from hazardous substances that contaminate water sources. The EIS should include how many new roads and/or upgrades are expected and their locations. Baseline data is also needed for existing livestock facilities that degrade or fragment 

essential species habitat components across the Corridor. This includes livestock fences, water developments (spring “development” and de-watering projects, water pipelines and troughs, wells), salting sites, etc. – all of which may significantly 

impair ecological processes and habitat. Appendices - Table 0 11-1 and 0-11-2 do not provide enough information to 

understand how population viability will be affected for California bighorn sheep, black-tailed prairie dog, Brazilian free-tailed 

bat, American marten, and a host of other species. All management indicator species (MIS) for any forest impacted by any potential route must be considered. The route should not be allowed to cross northern goshawk habitat.

Suneeinfothe assuseare from preArescoconAppopNathe ForgosTarreq
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100254 WESTERN 

WATERSHEDS PROJECT (cont.)

The DEIS fails to provide adequate information, analysis, and protective measures for sage-grouse, a species whose habitat and viability would be severely impacted by the proposed project activity and alternatives. Informed public comment cannot occur until this is done. The EIS has no basis for its claim that the project would “not likely contribute to a trend toward federal 

listing or loss of viability for GSG". BLM must use the methodology and science in the Sage Grouse Conservation Assessment (Connelly et aI. 2004) and the recent Knick and Connelly (2009) Studies in Avian Biology to conduct a science based analysis of the direct, indirect and cumulative effects of the designation and/or development, and use this as the basis for developing 

alternatives. Reference to a series of incomplete and flawed HEA and other "models" is greatly inadequate, and cannot properly inform compensatory mitigation measures. Agencies should examine the effects on "Population Management Units", 

as described and defined in, for example, the Nevada Sage Grouse Plan, and apply the most current data as population trends 

are now shifting. Agencies should also examine the current effects of fragmentation and loss of habitats - including fire, 

livestock fences and other infrastructure, roads, existing and foreseeable energy development, power lines, etc. and project 

effects to sage-grouse populations over time with and without development of Gateway. Analysis for sage-grouse and other 

species should be done for an expanded range of route alternatives that focus on previously disturbed areas. 

The DEIS must examine conditions to at least 10 miles distance from leks, and fully consider that grouse may nest even 

further from leks and move over vast landscapes in the course of the year, requiring habitat that ensures connectivity (which 

core areas miss). The DEIS also lacks adequate DDC (density disturbance calculation) analysis. DDC in the EIS is tied to the Wyoming core area concept model. WWP believes this Core area concept is not adequate to conserve and protect sagegrouse in nearly all instances. A great flaw of the Core concept is that it focuses on leks and promotes loss of land areas andimportant wintering and other habitats if lek numbers and density are not as high as other areas. Sage-grouse are so imperiled 

that sacrificing small groups is unacceptable. An SEIS is needed to provide DDC analysis for the entire affected region, using 

methods that include specific information for each different form of disturbance. Placement of high tension lines in or near Wildlife Refuges or state WMAs, sage grouse leks, and habitats essential for connectivity may have significant adverse impacts. Power lines provide ample sage grouse avian predator and egg-predator 

perches where ravens can scan for nests. Additional roads and other disturbance also increases sage grouse nest predator 

travel corridors. Livestock grazing also increases raven predation; all components of livestock impacts must be mitigated. Sage-grouse brood rearing is tied to green vegetation on wet meadow and other areas. Many of these sites have already been 

greatly reduced and depleted, and agency use standards do not protect what remains from grazing and trampling impacts. 

Sage-grouse use breeding habitats with much greater shrub canopy cover than just 10-25%. This must be corrected, and 

areas with greater canopy cover included. All mature and old growth sagebrush communities must be identified and protected. 

The EIS should resolve understanding of all “uncertain” or “undetermined” sage-grouse leks. WWP objects to the DEIS characterization of the number of individuals in a species population as the “currency” of the Endangered Species Act (ESA). 

Idaho Power’s six Environmental Protective Measures (EPMs) are completely inadequate to protect sage-grouse. Sagegrouse and other wildlife need a complexity of connected habitat types, and areas with suitable conditions resulting from 

topography, vegetation, water sources, etc. that cannot be replicated. Mitigation models based on acreage replacement do 

not appropriately account for sage-grouse needs in time and space. Quality of habitat, not only quantity, must be considered. 

No project activity should be allowed within five miles of any lek in any habitat. Surface disturbance must be prohibited within 5 

miles of occupied leks. Idaho Power should not be released from protective requirements even if "agriculture, a highway, or line of sight barrier is present.” "Agriculture" could be a narrow dryland wheat field. “Highway" lacks clear definition. "Line of 

sight" does not include sound, blasting, helicopter use and other disturbance to sage-grouse. Each sage-grouse lek, wintering 

area, or other important use areas must be Key Observation Points. 

In Scoping, we asked that you use analyses as found in ICBEMP and other current science-based assessments such as the ICBEMP Wisdom et aI. 2002 species examination and other ICBEMP documents, also Nevada Wisdom et aI. 2003 assessment, and the Wyoming Basin Environmental Analysis (WBEA) to examine the full range of ecological threats and habitat fragmentation that currently exists for other sensitive species. This has not been done.

Th

hab

gredet

be (as HEspecomThare and mosimet atemAlt

al. 

Homoprointefeaass

fenpowtho

panThincThby PeonlGoPreproIt is 

SaTh

suppreageenvreleOnconthe in mBoin treleInteconFin
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100254 WESTERN 

WATERSHEDS PROJECT (cont.) 

Imppreand of tcovimpstaBLwildnumconProreqcomrevtheKOThe habby the 

The DEIS is inadequate in presenting information and analysis for black-footed ferret, Canada lynx, Columbia spotted frog, gray wolf, grizzly bear, mountain plover, northern leopard frog, whooping crane, yellow-billed cuckoo, several spring snails, rare Colorado river fish, and other habitats. 3-11-39. The OEIS proceeds to lump many sensitive species (BLM and Forest). This is greatly inadequate in addressing impacts, especially when Idaho Power hasn't bothered to conduct site specific surveys across all potential routes. Species are lumped due to habitat requirements or life history traits. This is nonsense. 

EACH of these species is a species of concern, and has specific habitat requirements. The gray wolf is still listed in Utah and 

Nevada and may be impacted by potential routes. This project must be routed to avoid Canada Lynx LADs and linkage areas. 

Agencies should develop alternatives that do this in a revised EIS. Project impacts are unclear for Columbia spotted frog or 

any aquatic species because adequate and detailed mapping of access roads and other disturbance has not been provided and overlaid. Alteration of hydrology and flow patterns, release of pollutants, increased predators, sedimentation, and many 

other adverse impacts are highly likely.

The and reqspeThe addproAccmitdiscrovegconweensappthe rele

The EIS should examine the full range of potential impacts to soils. There is significant potential for soil contamination, drift 

including on windblown eroded soils, and many other problems with herbicide use. A sound protocol for effective treatment 

including preventive actions and post-rehab controls grounded in Integrated Pest Management (IPM) must be established. 

There are no adequate protections provided in the DEIS for prevention of excessive soil erosion, loss of microbiotic crusts, and 

many other adverse impacts. Construction of the line and roads will result in altered hydrology, small depressions, ruts and 

puddles. Puddles that collect water will increase livestock concentration and their associated adverse impacts, especially 

harmful trampling impacts. Altered hydrological processes will also create additional sites for West Nile virus, especially when 

combined with cattle troughs, stock ponds, and other West Nile mosquito breeding areas.

The Painccomin WwaWa
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100254 WESTERN 

WATERSHEDS PROJECT (cont.)

The DEIS lacks detailed information the location and current condition of springs, seeps and other waters impacted by any 

part of the Gateway project. Ground and surface water is at risk of contamination from substances transported, used, spilled, 

or picked up as water is re-injected in association with geothermal or other development. New roads and development will also increase sedimentation in waterways, alter hydrological processes and flows, and deplete ground and surface water. Agencies 

should especially consider the effects on scarce spring sources in high desert regions. Springs are critical to a broad array of wildlife, and many have already suffered large-scale degradation, depletion and in some cases been eliminated entirely by the 

effects of livestock grazing and BLM and forest service "development" for livestock. See Sada et al. 2001, BLM Technical 

Bulletin. An SEIS must examine the current condition (including both water quantity and quality and any documented changes 

over time up to this point) of springs, seeps and riparian areas across the affected landscape. It must then determine the 

effects of all Gateway alternatives and associated, linked, or foreseeable development on critical riparian/watershed areas. 

Analysis of water resources must take impacts of global warming into account, as well as consider project impacts to municipal watersheds. 

Poteffealtethotheinc

The DEIS should improve its description of the type of transmission, gas pipeline, and other existing rights-of-way, as well asmining and other activities in or near all segments. An overlay of Conservation Reserve Program (CRP) lands and Gateway 

alternatives should also be provided, with an analysis of how secure CRP lands are from increasing transmission line and other disturbances, including grazing.

The Adwa

WWP opposes all land-degrading RMP and Forest Plan amendments. Any plan amendments should be done only to designate Areas of Critical Environmental Concern (ACEC) or otherwise increase biological value, visual resources, or other protections. The EIS should amend relevant Land Use Plans to authorize grazing permit retirement, and consider removal or 

reduction in livestock AUMs across the entire public lands corridor. The consequences of any amendment cannot be 

understood unless current and comprehensive wildlife information is provided, and all other parts of the Land Use Plan are 

complied with. Especially in the case of old land use plans, there have been many more miles of fence, sagebrush loss, 

energy or other adverse impacts than the plans examined. All adverse developments in excess of what the plan provided for must be examined before any Gateway amendments. Current MFPs, RMPs, and Forest Plans in the project area have 

inadequate measures to protect from OHV/roads, excessive grazing, overstocking, and grazing of weed-vulnerable lands. TES 

plans should not be amended to allow intrusion of northern goshawk habitat.

Yoand for Pro

The DEIS fails to provide a baseline of recreational uses. Construction of expanded roads or facilities will alter hydrologicalprocesses, and may affect human uses and enjoyment of wild land waters, including fishing opportunities. BLM should have already eliminated many route alternatives that have significant impacts to recreation activities. The EIS should examine how 

fencing inhibits recreational opportunities. Potential future liked geothermal energy development would also deplete, alter and

potentially destroy important recreational hot springs, or areas with important cultural importance to Native Americans.

Renot issimpcon3.3 

Increased vehicle/OHV use will greatly increase wild land fire danger. BLM often fails in controlling OHV use. Many Land Use Plans are outdated and cross-country use and road proliferation is allowed. Any Land Use Plan amendments must include 

road/OHV closures in any new or upgraded roads caused by the project. 

The use mitrecredsairoaincOH

The EIS should analyze impacts of the project to roadways and highways, including danger from increased tumbleweeds, concentration of livestock or big game, and exposure to herbicides.

ForThe tum

Will this project promote more global-warming gas producing coal-fired plant emissions? How much will dust pollute the air? The 

and genaffeaffethe DERe

Voltage build-ups, EMF health effects, low frequency and magnetic fields, stray voltage, and interference with electronic 

equipment are all concerning. It is difficult to understand what the effects would be from electric fields associated with lines as 

described in 3.21-11. 

No

and 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100254 WESTERN 

WATERSHEDS PROJECT (cont.)

There are a variety of dangers and risks posed by the Gateway project that should be further analyzed, discussed, and addressed with better protection measures. The project will increase risk of wildfire and associated safety risks, and included

fire prevention measures are inadequate. Guy wires pose a risk to public safety and should not be allowed. Additional adverse impacts to residents and potential health hazards include harmful effects of lines and transformer sites, herbicide use along disturbed corridors, toxic materials associated with energy facilities, pollutants associated with linked/facilitated coal plants and 

other development, spills or leakage of all manner of chemicals ranging from PCBs to chemical solvents, and ground and surface water contamination. DEIS section 3.21-11 describes electric fields associated with lines inducing small electric 

currents in metallic objects, and possible nuisance shocks -which can occur to electric fences, vehicles, irrigation systems. 

"Stray voltage" refers to a phenomenon in wet environments. Recreationists, scientists or others may be near the line under 

such conditions, in vehicles or hiking on foot. Hazards should be clarified, as hikers and cars can’t be grounded. The EIS 

should provide detailed analysis of the adverse effects on health and safety of motorists on federal, state, and local highwaysin the project area, including dangerous tumbleweeds and herbicides. Risks to small plane operations must also be analyzed and discussed. 

The On3.2theclaSeareProin S

High voltage lines produce an audible, often loud crackling noise. Analysis should be done that assesses how noise levels are 

impacted by different weather conditions and voltage loads, as well as which types of wildlife species are particularly vulnerable to noise. The EIS also mentions blasting, but leaves out any details of how much and where, making it impossible to understand impacts. 

Cowhimptrantheconfouwo

The DEIS does not adequately examine adverse cumulative impacts on sagebrush and other native ecosystems and wildlife 

from a potential plethora of new corridors/lines/energy development/ and disturbances (future or existing, such as grazing). 

The EIS should provide in-depth analysis of all threats and stressors to each affected habitat and population from a broad 

range of connected and foreseeable activities, including but not limited to industrial energy projects and mining. Such analysis 

should also include how global warming could increase all other threats and stressors, and how Gateway combined with 

previous and future projects may alter local weather and other patterns. In addition, this EIS must provide detailed analysis of the effects that the China Mountain wind development would have on wildlife so that the cumulative effects of the Gateway 

project can be understood. If BLM authorizes the potential southern route by the Nevada border east of Salmon Falls and then 

up into Shoshone Basin, combined effects are highly likely to cause great declines or loss altogether of the sage-grouse populations in the Idaho-Nevada borderlands east of Salmon Falls. Simplot is proposing a large wind farm by Rogerson. The 

Sawtooth Forest southern division has issued a series of Categorical Exclusions for wind MET towers in various sites north of the Nevada route. Gollaher Mountain and other Nevada areas have also been put forth as wind development sites. The EIS should identify and consider all current and proposed developments in the area, including rights-of-way in every state touched by the project and promotion of wind energy development on remote public lands in areas in and near the SWIP swaths. The 

EIS acknowledges: "If Alt 7H were selected for Gateway West other proposed transmission lines such as Zephyr and the Overland Intertie lines, would likely be built along Gateway's Proposed Route". The same would seem to apply to routes 7I, and 7J by the Nevada border and southern Cassia and Twin Falls Counties as well. All adverse impacts of linked future geothermal energy development or possible nuclear energy development must be considered. The EIS is also incorrect in 

saying that Wyoming EO effectively ends new wind development on state and private land in core areas, and it assumes that 

the EO remains when it could be changed politically.

The groHEthe comHEinfo

The Appendices are generally inadequate. Appendix 1 [sic, may refer to Appendix I] is missing Utah and Nevada information. Tables 0 11-2 and 0-11-2 only provide brief, simplistic information without noting where along individual line segments 

particular species may be found. 

The infoElkUtaexpage
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100254 WESTERN 

WATERSHEDS PROJECT (cont.)

All of the issues raised are of significant concern to the public. This includes voltage build-ups, EMF health effects -low frequency electric and magnetic fields, audible noise, stray voltage, and interference with electronic equipment. 

High voltage lines produce a very audible crackling noise, which at times is quite loud. How do different weather conditions, voltage loads, etc. - effect this as well as EMF and other hazards? The EIS downplays this by saying "the air breakdown, or 

small spark caused by corona t the surface of a transmission line conductor, is accompanied by a snapping sound. If there is 

sufficient corona activity on a high voltage line ... may be sufficient ... to produce discernible noise ... The use of the word may 

is not accurate. These lines are always audible and producing noise.

As whassAnby 

disratewemelevradwh

3.21-11 describes electric fields associated with lines inducing small electric currents in metallic objects, and possible nuisance 

shocks -which can occur to electric fences, vehicles, irrigation systems. "Stray voltage" refers to a phenomenon in wet environments. Recreationists, scientists or others may be near the line under 

such conditions, in vehicles or hiking on foot. What hazards does this pose - as hikers can't be grounded - and cars can't 

either. It is difficult to understand what the effects would be from this material.

The cla

line

Blasting is mentioned here. How much blasting is proposed, and where - for all segments of the line and access roads? Until full and detailed surveys in the noise Footprint of the line are conducted and detailed plans for this line produced, it will be 

impossible to understand impacts.

No wit

The entire cumulative effects analysis is greatly flawed. The EIS attempts to use a Table with a list of some projects listed to 

avoid full and detailed cumulative impacts analysis. It is impossible cumulative effects as there has been no adequate baseline. Now this simplistic approach how SEVERE the effects of the other projects will be, and the full array of threats and 

vulnerability of the habitats and populations impacted. The Table also omits many harmful activities occurring chronically in the 

Footprint of the line -like chronic livestock grazing disturbance.

Liv

The overall project footprint is poorly defined. Terms throughout the document need clarification and definition. WWP requests 

a meeting with BLM managers to discuss concerns about this EIS. 

Thi

staPro

BLM has thwarted full and informed public comment by failing to provide supporting documents including WEST and other 

consultant biological reports to the public. BLM excluded WWP from what it claimed was a collaborative process, and in which WWP repeatedly asked BLM Managers to be able to participate. BLM refused to extend the comment period, despite requests 

from many parties and much of the project area being inaccessible to the public throughout the wet spring weather. An SEIS 

must be completed in order to take a “hard look” required by NEPA. Including important new or supplemental information in a final EIS does not satisfy NEPA unless an SEIS is prepared with full public review. See 40 CFR § 1500.1(b): “NEPA 

procedures must insure that environmental information is available to public officials and citizens before decisions are made and before actions are taken.” The private land portion of the project cannot exist independently of the public land portion 

under all alternatives evaluated in the EIS. The relevant test in the Ninth Circuit is “whether ‘each [action]’ could exist without the other”. There should be anonymous review by scientific experts removed from political pressures. Consultants frequently 

used by the wind industry may have a vested interest as well; the EIS must be redone by qualified federal staff and not handed 

off to industry consultants. BLM has unlawfully segmented the analysis of the project in allowing incremental placement of MET towers. This has altered and destroyed the legitimacy of baseline wildlife habitat and population monitoring, especially for 

sage-grouse biological information. Jarbidge BLM will never require industry to abide by the list of “BMPs” and readily waived 

“stipulations” and other mitigation in the DEIS. Jarbidge has a long history of ignoring/stripping environmental protections. 

When selecting alternatives, an agency may consider an applicant’s desires, but is not limited by them. It is not appropriate for 

an agency to rely on the “self-serving statements of the project applicants.” Southern Utah Wilderness Alliance v. Norton, 237 F. Supp. 2d 48, 53 (D.D.C. 2002). Instead, the action agency must “to the fullest extent possible...study, develop and describe appropriate alternatives to recommended courses of action in any proposal which includes unresolved conflicts concerning alternative uses of available resources.” Id. at 54 (citing 42 U.S.C. § 4332(2)(E)). Moreover, “[o]ther factors to be developedduring the scoping process—comments received from the public, other government agencies and institutions, and development of the agency’s own environmental data—should certainly be incorporated into the decision of which alternatives 

to seriously evaluate in the EIS.” CEQ, Guidance Regarding NEPA Regulations, 48 Fed. Reg. 34,263, 34,267 (July 28, 1983).

ThistaProtow

The EIS is currently missing and must include maps for: 1) areas that have high fire potential, and 2) GIS viewshed analysis for 

entire project area.

Thista3.6occ3.2 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100255 WESTERN 

WATERSHEDS PROJECT (cont.)

BLM must not set such a narrow Purpose and Need. BLM enables the developer to discard alternative siting options, and 

artificially constrains the range of alternatives to the most harmful area sought by the energy developer.

ThistaProneethe 

The agencies must disclose meteorological information for the public to evaluate the claim that there is a “need” for the facility 

transmission line, and expansion of the road network.

Thistaund“ne

The project proposal represents a violation of and must be modified to bring it into conformance with existing law, regulations

and policy including recent Instruction Memos (IMs), and existing BLM land use plans, such as the: 1) February 2011 IM and a 

settlement with WWP for a new RMP emphasizing sage-grouse protections, 2) BLM’s sage-grouse and sagebrush conservation policies and conservation plan, 3) FLPMA balanced uses of public lands, 4) Instruction Memo ID-2010-039, 5) IM 

2010-077, LR2000 Data Standards for Renewable Energy Cases, under which BLM must collect detailed data on resource conflicts for transmission ROW related to renewable energy projects, 6) BMPs at 2A-4 (7,11) (for raptors), and 7) potential 

Wilderness Study Area status sites, including Black Canyon, Corral Creek, Salmon Falls, Player Canyon, and China Creek. 

How will BLM deal with protections in one RMP but not others? Where are all existing Revised Statute 2477 claims in and 

around the project area and what roads do they apply to? How are they being dealt with? The EIS also leaves out analysis of 

the Draft Jarbidge RMP Preferred Alternative, as well as discussion of the Sagebrush Sea and other ACECs (Area of Critical 

Environmental Concern) being considered under the Jarbidge RMP process. See Jarbidge DRMP Map 110, where the preferred alternative would result in all of this area of the Jarbidge foothills being designated an ACEC, as well as areas of the 

slickspot peppergrass habitat and the ACEC proposal in the area of the northern inbound Haul Route. 

Thistathe the pub3) Cproconand gov

A full and detailed description and analysis is needed for: 1) harm caused by delay of the new Jarbidge RMP, 2) new/more 

driven roads since the MET tower placement, 3) impacts from the proposed concrete batch plant, 4) impacts from the 

proposed rock quarry/crusher, 5) seismic conditions and earthquake potential, 6) proposed additional MET towers. An SEIS is 

needed for impacts from blasting.

ThiWe

The DEIS seeks to minimize understanding of impacts by referring to acreages bulldozed. For the transmission line, a 250 foot 

buffer area is greatly inadequate—disturbances will cover a far larger area.

ThiWe

The Nevada MET tower, as well as multiple towers on BLM lands in Idaho lack avian flight diverter markers for visibility. MET 

tower pieces are falling off, and on some towers the developer didn’t place markers on mooring wires so birds could see them 

and avoid being killed. 

ThiWe

An alternative to site all project components on private lands should be considered feasible. Thi

roupropriv

BLM must start with a new range of alternatives in an SEIS. Alternative siting is likely to be sustainable and less expensive to 

mitigate and to operate over the long run. The EIS also fails to analyze alternative conditions to be imposed on right of way grants.

ThiWe

BLM must require the immediate removal of the existing MET towers and restoration of damaged lands and revoke any 

ROWs. MET towers must also be removed so that a valid biological baseline can be established. 

ThiWe

BLM is not requiring and clearly specifying the level of mitigation that must be required for the loss of sage grouse, raptor and 

other regionally significant populations of wildlife including golden eagles, as well as the facility’s large-scale interference with 

an avian migration site, and the inevitable weed invasions and other habitat losses that will be caused. Mitigation here, if BLM 

allows this unmitigatable project to go forward, must be for total loss of the grouse population in the only high quality remaining 

habitat – as well as severe losses jeopardizing O’Neill Basin and Shoshone Basin birds as well. BLM should require the lands 

disturbed be rested for a minimum of 10 years to promote re-establishment of native species. Non-binding wording - like “will” 

or “would” are used. There is no NEPA analysis of the value or effectiveness of off-site mitigation. There is no certainty whatany conservation easement acquired for mitigation would entail. Easements will be bought for outlandish sums on lands with 

little development threat to “save” lands from non-existent Condo development threats. How enforceable will any easement 

be? Grazing would likely continue on “easements.” Please also provide a comparison between mitigation costs at the site, and 

for example, mitigation for an alternative marginal agricultural land site. Will the new/upgraded roads be returned to their 2011 

condition at the termination of the project? Will the same rehab standards apply to state and private lands as to BLM lands? If

so, how will they be enforced? BLM must assess the uncertainty associated with the issuance of “waivers.”

ThiWeAp
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100255 WESTERN 

WATERSHEDS PROJECT (cont.)

Monitoring wildlife fatalities for 5 or 7 years is insufficient. What specific thresholds will be established, with the ability to trigger 

shut downs and removal of turbines and the entire plant if specific mortality or adverse environmental changes occur? These should be clearly specified, and triggers put in place, as part of the “adaptive management” scheme, and with public notice formonitoring outcomes. An independent entity that reports directly to BLM, and provides rigorous daily mortality monitoring in all 

areas of the project site with information automatically displayed on a publicly available website, must be used. 

Thiwin

These values are regionally and even nationally significant. Visual simulations provided to date with this EIS are greatly inadequate; BLM has not complied with its own visual analysis requirements. BLM methodology used was from the 1980s and 

was not designed for the full light intrusions of 2011. DEIS photos are very inadequate in portraying the baseline condition of

all aspects of the project area. At night BLM forgot the bright erratically pulsing red lights, including in snow conditions where 

light reflections on snow look like carpet bombing. 

The in happvis

The Browns Bench area is a renowned obsidian quarry, there is extensive sign of lithic material, rock blinds and other features

– all of which must be protected and not degraded or destroyed with industrial development. What sites have already been 

nominated for the National Register? Is much of the area of the caliber of an Archaeological District? If so, BLM should use this 

process to deny a ROW and conduct analysis for National Register recommendations and an Archaeological District. If the 

choice comes down to destroying a cultural site or destroying wildlife habitats – what will be the basis for decision making?

AlthGaadd

Impacts to the historic Toano trail are of concern. No

Ad

What will the loss of revenue from outdoor activities be once the lands are blighted by industrial wind, and wildlife populations 

decimated? A fair accounting of the adverse economic impacts, and losses to the public and public resources including losses in jobs dependent on recreational activities, must be provided.

A dThe and The Se

The socioeconomic information included in the DEIS shows that this will be a typical boom and bust proposal. Low-paid or 

short-term workers will be present during construction. Please analyze such impacts/changes that are likely over the life of the 

project, including with technology foreseeable over the next 30 years. 

Potand 

Please provide detailed discussion, facts, figures and analysis of all federal, state, or other tax breaks, and subsidies the 

developer may plan to receive. The full burden of this project on taxpayers and rate payers under a range of foreseeable 

scenarios must be examined in detail in the EIS. One possible scenario should include the developer selling the ROW to 

another party, and taxpayers left paying the costs after the next owner causes further damages, goes bankrupt, or bonding proves inadequate. 

The ProNo 

Any recovery of low sagebrush communities may take 100-200 years or more. To avoid impacts, BLM must require use of helicopters, rather than roading, to the maximum extent possible. Vegetation that naturally sequesters carbon must be 

examined. BLM mapping only takes into account patches 20 acres in size or more – so it is not fine-scale enough to 

understand the complexity of the diverse vegetation communities. All of this further analysis must be provided in an SEIS. Is BLM proposing further livestock forage projects/fuelbreaks that destroy sagebrush? All direct, indirect and cumulative impacts of this added habitat destruction must be provided. The most current data on fire history should be used –including the 2010 fire in the China Creek area. 

As We

Full ESA consultation over impacts to slickspot peppergrass must occur. Thi

EISa c

There is no valid analysis of the feasibility of controlling invasive species, especially aggressive cheatgrass, bur buttercup,

weedy mustards, etc. across the project area. BLM is planning a large-scale fuelbreak project with aggressive, invasive forage kochia that is likely to infest areas at a considerable distance. The weed BMP doesn’t require that surveys occur for both noxious weeds and invasive plants. The word “or” is used, instead. The Proponent must not be allowed to spray weeds; instead, the Proponent should provide funds to BLM and any chemical use be conducted under federal oversight.

Thiproide

PFC (Proper Functioning Condition) is a subjective, minimal measure. It does not address habitat quality for aquatic biota, 

water quality and quantity including sustainable perennial flows, and many other attributes of wild land waters critical to full understanding of current conditions and direct, indirect and cumulative effects of the project. 

ThiWe
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100255 WESTERN 

WATERSHEDS PROJECT (cont.)

Vehicle mortality alone from 80 miles of new and “improved” roads will be a severe impact to wildlife. DEIS has failed to 

provide adequate migration radar studies critical for understanding bird and bat mortality, which will likely be much greater than 

predicted. It is not possible to adequately detect nesting birds by allowing 14 days to elapse between time of surveys and surface-disturbing activities. A full evaluation of the effectiveness (or lack thereof) of raptor anti-perching devices, and an 

analysis of the impacts of the project on promoting avian nest predators must be provided as well. How will this project 

increase West Nile killing of birds and bats that may consume mosquitoes? Reference is made to preparation of an ABPP 

[Avian and Bat Protection Plan]. Any such plan must be provided to the public for full comment in a SEIS.

Improuma

alloout from of l

ove

addWe

BLM would be in direct violation of the Migratory Bird Treaty Act and Bald and Golden Eagle Protection Act by placing facilities 

in an area where significant mortalities and/or displacement of eagles and other forms of “take” are highly likely to occur. BLM 

is in violation of this Act right now by allowing unmarked wire moored MET towers on BLM lands in both Idaho and Nevada. 

Please provide full raptors/eagles analysis in an SEIS.

The Go

Elk are dramatically increasing and now rely on the Project Area for winter habitat. Detailed baseline studies on deer, elk, 

antelope use and movement and population levels – as well as habitat concerns over the local and regional area must be 

conducted and provided in an SEIS. 

Elk big 

If a significant portion of a migratory bird species is killed, there will be impacts felt in other ecosystems. Mo

posSe

Have fisheries surveys been conducted for rare species on the blocks of private land in the project area? This must be done. Fis

age

Vesper sparrow (BLM sensitive species) and horned lark are abundant in the area. Pygmy rabbit, the golden eagle and many 

other rare species that inhabit these lands are likely to be listed under the ESA in the near future. Full ESA consultation must 

occur. Impacts to the white-tailed jackrabbit, a special status species in Oregon thought to be declining across its range, are

especially concerning. This jackrabbit lives in low sagebrush/mountain big sagebrush/bitterbrush/mountain shrub habitats. The short-horned lizard is sensitive in Nevada and will be adversely impacted by the project.

ThiEISCo

Any of the alternatives would propel sage-grouse to ESA listing. Sage-grouse are now a federal candidate species that has 

been found to Warrant ESA protection. Placement of MET towers has already caused avoidance of the site by wildlife like sage grouse –a species that avoids use of areas with tall vertical structures (Braun 1998, Manes 2002, USFWS March 2010 

Warranted but Precluded Finding for GSG, Knick and Connelly 2009 Studies in Avian Biology). Behavioral avoidance will skew 

results of any new research or data collection. In order to have a biologically valid baseline of sage-grouse use of the area, the MET towers must be removed and bird behavior studied for 3 to 5 years without them. Much of the entire high plateau is sagegrouse brood rearing, and must be avoided May 15-August 15. There are inconsistencies between states in treatment of sagegrouse. WWP is concerned there would be lesser protections applied in Nevada than in Idaho. Efforts are being made to 

expand the sharptail grouse population, so relegating use to winter is unacceptable. Much of the project area is recovery 

habitat for sharptail grouse, and links Idaho and Nevada populations of this species.

ThiEISProrecHEin tThe as Go

In many areas there is little to no topsoil – and that plants like low sagebrush growing amid talus have little to no topsoil but 

instead grow on small amounts of soil between platy rocks. The rocks may be essential in holding water on-site, and 

moderating growing conditions in a harsh environment. So without the rocks and once the soil is disturbed, the plants might not

be able to survive. 

Noresme
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100255 WESTERN 

WATERSHEDS PROJECT (cont.)

How will all aspects of this project affect aquifer percolation? How will the Critical Groundwater Management Area be affected by water uses, or watershed or aquifer flow disruptions caused by this project? Where will all water sources - including wells – 

be located? Have new wells already been drilled for this project? How much water will be used in all phases of construction and operations – ranging from the batch plant to keeping the dust down on roads? Where will all stream and wetland crossings be located? What impact could boring have on water resources? Will BLM protect intermittent and ephemeral drainages to the 

same degree as perennial ones? If not, what actual protections will be applied? How does climate change threaten perennial flows? BLM must conduct Level I (locate and provide reconnaissance level characterization of springs, delineate important 

species distribution and salient aspects of habitat, and unique circumstances/challenges) Level II (qualitatively sample riparian 

and aquatic communities to determine community structure quantitatively sample salient physiochemical elements to identify aquifer affinities), and Level III Surveys (quantitatively sample to determine aquifer dynamics, sample riparian and aquatic 

communities and habitats to determine spatial and temporal variation in environmental and biotic characteristics, and to 

quantitatively determine biotic and abiotic interactions). BLM still has no data on the ecological conditions of 50-60 springs and 

seeps in the Brackett Bench allotment alone. The mapped RHCAs only consider areas one acre or greater in size. This means 

that many smaller springs, seeps and intermittent/ephemeral drainages are not considered. The DEIS discusses many roading 

and other impacts to Rocky Canyon – a proposed Wild and Scenic River. It is impossible for a reader to determine where and 

how roading, turbines, etc. might impact this potential WSR or any other drainages in the Project area. 

EffSpwa

The analysis and proposed treatment of private lands is unclear. Will there be any controls on how the project unfolds across private or state lands in the project area? What will any differences be? What protections for drainage systems will be applied

to private lands? Lacking BLM surveys across the private lands, it is impossible to understand the severity of impacts. The EIS

must evaluate the ecological condition and degree of degradation of private land.

ThiWefed

Updated full and detailed VRM analysis must be conducted as part of this process. The Land Use Plans have seasonal avoidance criteria to prevent activities from harming wildlife. Where and when have these criteria been implemented? This is 

essential to understand so that an estimate can be made of their effectiveness, and of the consequences of stripping or gutting

these protections as is proposed. BLM must evaluate its progress, after 20 years, in meeting all RMP Objectives.

The Apexi

There is high recreational value for hiking, camping, sightseeing, photography, wildlife viewing and many other outdoor and 

aesthetic pursuits enjoyed by WWP members. Public access should not be restricted during any time of the project. All of the 

details, limits and bounds of planned site access control, fencing, and limited public supervision activities must be explained in 

great detail. Will there be armed guards with guns keeping the public from areas?

As Wefor 

thatrai

The entire project area must be permanently closed to livestock - as mitigation, and to promote effective rehabilitation of the

large areas of disturbed and destroyed soils. A federal court injunction is in place that prohibits cattle grazing these lands due to the significant FRH [BLM 1995 Fundamentals of Rangeland Health regulations] violations including degradation of sagegrouse and other wildlife habitats. 

Noaut

The full amount of pollution must be laid out. This includes pollution in mining rare earths and other turbine material, manufacturing steel and other material, transport of raw materials and manufacturing, transport of material to the site, - i. e. in 

all components of materials/development, construction and operation of the facility. There is already significant mercury and 

other pollution in Salmon Falls Reservoir – linked to air pollution where mercury then falls out with precipitation. Feedlots and 

dairies also contribute significantly to air quality degradation in the airshed to the north. How polluted is the air – and how much 

might that increase with more dairies/feedlots? There is no certainty that the “dust suppression” will “effectively” suppress dust in windy environments. Is prescribed burning planned? Winds often blow north from Nevada. So pollution from the Project 

activity is likely to impact the already poor air quality in the Magic Valley to the north.

No addthe botbeepiparewhare

A comprehensive fire risk assessment must be conducted, and there should be no construction during the period of fire danger, June-September. Psychological stresses from ongoing persistent noise may cause a physiological stress reaction that could result in impaired health.

Senum

White noise syndrome must be included in all assessments. A noise footprint analysis showing impacts on all area habitats 

and recreation sites must be presented in an SEIS. Analysis should include how atmospheric temperature and wind profiles may affect the way project noise travels. To present a complete picture, the EIS should also consider current and planned levels of civilian/military aircraft noise. The EIS must include robust seasonal avoidance criteria to protect nesting birds, wintering big game, and roosting bats from project noise. 

PotconpotconwaCacorpro
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100255 WESTERN 

WATERSHEDS PROJECT (cont.)

For sage-grouse, as well as many other values, the cumulative impacts analysis area is much too small, and appears arbitrarily drawn. The Times-News reported on the FERC process for a potential Corral Creek hydropower project in 2009. 

Could this project, strategically located along the Idaho-Nevada border, and where with the addition of a hydro project, also at some point be a steppingstone for water pipelines and water export? Perhaps of Salmon Falls Reservoir and/or Cedar Creek 

Reservoir water south to Las Vegas? An updated status of this project should be included.

The ava

WWP submitted more than 300 suggested references on CD to BLM. Additional key literature that should be reviewed 

includes: • IMPACTS OF FENCES ON GREATER SAGE-GROUSE IN IDAHO: COLLISION, MITIGATION, AND SPATIAL ECOLOGY. Master’s Thesis, University of Idaho, Bryan S. Stevens May 2011 • Manes et al. (2002) – adverse impacts of the wind development • Knick and Connelly (2009) for updated fire ecology information. • Merritt et al. 2008, paper on quantitative radar-based data with migrating bird presence verified through use of night vision

technology. • Dobkin and Sauder 2004, “Shrubsteppe Landscapes in Jeopardy: Distribution, abundances, and the uncertain future of birds 

and small mammals in the Intermountain West”, examined bird and small mammal species in the sagebrush biome. 

The

100256 GEORGE BILL & 

JOANN KELLEY 

It is important that individauls and communities affected by the proposed projects be able to be adequately compensated for 

the land being utilized in the development of the projects preferrably on an annual basis as opposed to a one time damage 

payment.

Nosta

 The proposed transmission project will be of value to the state and nation as the development of renewable energy moves 

forward. The additional transmission will be needed to meet the growing energy demand in addition will provide an opportunity and provide optional routing of the nations power in the event of a natural disaster. Currently our grid is aging and has not had 

significant upgrads in over 30 years. It is important that renewable energy be an important portion of the energy being developed thus reducing the reliance on fossel fuels which will eventually in the not to distant future be gone.

Nocum

100257 CONVERSE 

COUNTY COMMISSIONERS

The Converse County Commissioners adamantly oppose the proposed transmission line south of the Town of Glenrock and 

north of Interstate 25. Most of my constituents with whom I have spoken also oppose this proposed transmission line.

Yosup

conexitho

100258 CONNIE 

HOLLOWAY 

I do not support this project in anyway Yo

sup

 I am still not willing to let the Owyhee Mountains be sacrificed, and have their beauty and natural energy be polluted by huge

steel structures as proposed in segment 9 as one of the possible routes, that being 9E.

Yorevconin C

 these towers should follow already existing power corridors and not be making new ones No

Secomsumhou9 h

 I believe that by putting the transmission towers and lines there it would increase our chance for fires thus making it very 

dangerous for surrounding small communities.

No

100259 CONNIE 

HOLLOWAY 

I do not support the Project as proposed Yo

sup

 I am still not willing to let the beauty and natural energy of the Owyhee Mountains be sacrificed for the Gateway Projects plan 

to construct giant steel structures and transmission lines and run them across the lower Owyhee Mountain range, as proposed 

in Segment 9E of the project

Yorevconin C

 The cheapest, less risky and most efficient plan would be for the Companies to use existing power corridors whenever 

possible

NoSecomsumhou9 h
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100260 JENNIFER 

ROBINSON 

The land that these proposed lines would be placed on is a wildlife “preserve”. There are few places left in our over 

industrialized country that animals roam with few interruptions from people and this is one of them. This land is home to sage 

grouse (already on the extinction list), elk, deer, birds and so many other countless animals. Thus, building on this land is not “green” since it would destroy many animals and their patterns of life

NoAlteana

 the obvious choice would be to select 1E-C Yo

HoThe dro

100261 ANNE AGANON Of all the proposed alternatives, I understand that 9D would be the least disruptive Yo100262 PAUL MARTIN I am writing to advocate the Alternative 1E-B in the Gateway West EIS Yo

Seconpro

100263 ARCHIE ROYBAL I have observed the map project overview Figure A-1, the proposed "red route" and clearly support this route. Yo

 I do not believe that the feasible alternative is the route to take do to the following reasons. I clearly do not want to live under 

the 500-kv line, in addition to any and all health risks that may follow. I do fill that the transmission lines would not benefit going 

thru a community that has elderly residents and young families

The DEcomlan

 I do feel that the transmission lines would not benefit going thru a community that has elderly residents and young families. I 

believe that the preservation of human life is very important and route A-1 "red route" would keep the lines away from residents.

Notab

 I looked at the 2-A,and 2-B routes and did point out that the distance in these routes where not correct,this was at the Rawlins 

meeting held at the Jeffery Center. The transmission lines in these routes did go over residents that were in fact occupied, and was not a shed or abandon structure so stated by the spokes person.

If thHoof ARo

 I think the transmission lines would also effect the Fort Fred Steele Historical site. "Interest Party under the 106 of the National 

Historical preservation act ", devistate the land and its scenic values.

Nothis 

 The property values of homes and structures would be hurt No I would hope that the B.L.M, and the people placed in charge will help establish a energy cooridor that is south of the 

interstate. Thus for other transmission lines that will follow to remain away from residents. "

NoAlteis p

 The wildlife would be also effected in a negative way do to the route of the 2-A and 2-B going thru the Fort Steele area. Ne

list Ro

 The Bald Eagles, that nest along the route in this area would be effected. No

100264 AMY LANE For the purpose of preserving our land and a way of life, I ask you to reconsider using the existing route for this transmission 

line. This route is listed as Alternative 4A. I, like the Office of the Governor, believe this is the best route

YothacurPre

 I am writing to express my great concern regarding the purposed route for the Gateway West Transmission Line Project. In 

particular the section 4 that cuts across Lincoln County, Wyoming.

Yosup

100265 MARK & MELISSA 

MCKINNEY 

I prefer the alternate southern crossing proposal of highway 46, or at the very least locating the new line on the south of the

existing line location. However after your presentation in Twin Falls, I noticed a few other reasons for the southern alternate

route in Gooding county. 1. There seems to be a lot less development in my area of expertise (highway 46) on the southern alternative. 2. There seemed to be less wildlife conflicts on the southern alternative. 3. There is already a west wide energy corridor set up on the southern route. To have it and not use it for what it was created

for is not right in my opinion. Homeowners like myself could and have made decisions on where to live and invest based on the location of energy corridors and to not locate new construction along them is unfair to people who planned their lives 

accordingly and makes a mockery of the whole idea of having energy corridors in the first place.

The as incconin C
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100266 OREGONCALIFORNIA 

TRAILS ASSOCIATION

[DEIS Location - chapter 3.3] Issue: Impact to historic trails and their setting. The proposed route (4F) appears to have not been subjected to a detailed survey. At one point it is stated that a survey will be 

conducted if the route is selected. It can be concluded from this statement that the potential adverse impacts were not a primary aspect of the selection process (which they should be). It is insufficient to state that impacts are to be addressed 

through mitigation to be determined later.

No

use

wh

New lines should be placed in areas where other significant intrusions (roads, railroads, etc.) extist. The presence of a few old 

ranching buildings or similar low contrast intrusions does not just addition of a transmission line.

Lin

100267 JACK AND CELIA 

CORSON 

You do not compensate for loss of view-shed. That is forever lost to us. The 

 We are completely against Segment 1E. We do not want this transmission line, or any other transmission line, in our area. Yo

Seconpro

 Building transmission lines for wind energy, which is more expensive and less reliable to the consumer, is an incorrect 

principle.

No

 #2. Your current compensation formula does not take into account future values and income. We will not be fairly 

compensated for the loss of use of agriculture lands during construction, the loss of those lands from production due to roads 

and towers with pads, and the loss future values. #3. Your one time payments mean that we will lose the largest percentage of your payment in taxes.

NoSta

100268 RICHARD 

LLEWELLYN 

I support the NO ACTION alternative as I believe the construction of the transmission lines is no longer in the economic or 

environmental interest of Idaho.

Nosup

 However, if construction occurs regardless,... 9F and 9H are the best alternatives to no action. Yo

100269 IDAHO FOR 

WILDLIFE

We have discussed the diffrent proposed sites for your route and our 1,200 members locally in Pocatello, American Falls, Rockland, Burley, have voted unamiously against the East Fork of Rock Creek route. Our concerns lie with the well being of 

our struggling deer herds. Please reconsider and change this East Fork route for the Mule deers benifit. there are very few 

areas as large and as good of cover for the deer to protect theirselves.

Thi

Se

100271 WADE POVEY Stray voltage from large power lines. I have felt static charges on wheel lines that are under 340KV lines. 500KV lines will put 

off more static. Boots and gloves are required when work on lines under these conditions. GPS, who is to say what affect this 

does or will have on any future GPS equipment we that farm with now or in the futures. Technology has come along way and there is alot more to come. Do not hinder us because of stray voltage and magnetic fields. Precision farming is here and more to come.

Streleequitem hav

 5C alternate route should be used as to avoid going by Arbon Valley elementary school. Yo 7H alternate will avoid going through the town of Rockland and the Eastfork recreational area. This also make a viable fit with 

Cassia County and avoids there irrigated lands.

Yo

100272 DUCKS UNLIMITED, 

INC 

The Bruneau River Ranch (Figure 2) is located directly south of IPC’s Turner Ranch. DU is concerned and frustrated that IPC and the BLM have proposed a route (Segment 9-Proposed) that impacts a neighbor of an IPC property as opposed to 

maintaining their project impacts on their existing properties. The Bruneau River Ranch is currently enrolled in the Natural Resources Conservation Service’s Wetland Reserve Program and a conservation easement on the ranch is expected to close before the end of the year. 

Thi

 Spring Cove Ranch (Figure 4) already has an existing IPC right-of-way on the property. The landowner is concerned that 

contesting the existing siting of the proposed line (Segment 8-Propsed) may only result in realignment onto a neighbor’s 

property. DU proposes consideration of an alternative north of the existing proposed route out of the Clover Creek valley on 

BLM-owned upland lands 

Yo

 Concerning the Six S Ranch (Figure 3), DU met with IPC engineers on behalf of the ranch owners to discuss realignment of 

the proposed routes (Segments 7-Proposed and 7-Alternatives 7-D and 7-F) through the ranch. The owners are willing to have 

the line cross the property, but they are opposed to the existing location. Realignment was proposed and generally accepted 

by IPC with the exception of any necessary micrositing. The realignment agreed upon by IPC is presented in Figure 5. DU is opposed to the current location of the route and supports the realignment presented in Figure 5. 

No
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100272 DUCKS UNLIMITED, 

INC (cont.)

The EIS does not place adequate consideration to non-regulated natural resources. Wetland habitats have been evaluated 

from a regulatory standpoint, and as a vegetation community. However, federal and state laws do not recognize imperiled 

and/or rare habitat communities unless occupied by federally protected or recognized plants or animals that are associated 

with those respective habitats. DU argues that wetland habitats need to be considered as a limited and imperiled natural resource in the state of Idaho beyond the “no net loss” regulatory standard. And, from a regulatory standpoint, we expect the 

Bureau of Land Management (BLM) and Idaho Power Company (IPC) to honor Clean Water Act guidance that directs 

permittees to make all reasonable efforts to avoid and/or minimize wetland impacts.

SedisSe

DU is strongly opposed to the proposed siting of Segment 8-Proposed where it is in close proximity to Clover Creek north of 

Bliss, Idaho. Floodplain habitat of Clover Creek upstream from Pioneer Reservoir is unnecessarily impacted and an upland 

alternative needs to be considered. Thousands of migratory Sandhill Cranes, among other migratory waterfowl, are regularly observed on the Clover Creek floodplain.

Yosup

DU is strongly opposed to Segment 9-Proposed for its proposed impacts to floodplain and groundwater spring wetland habitat 

associated with the confluence area of the Bruneau and Snake Rivers.

Yosup

We propose Segment 9E as a more suitable alternative. YoThe Project also directly impacts three current DU wetland restoration projects (Figure 1). The three projects are on the Bruneau River Ranch in Owyhee County (Figure 2), Six S Ranch (Figure 3) in Cassia County, and Spring Cove Ranch (Figure 4) in Gooding County. Collectively, the three projects have private, state, and federal restoration funding totaling nearly 

$1,000,000. Project partners include private individuals and foundations, Southern Idaho Land Trust, Idaho Fish and Game, 

Idaho Department of Environmental Quality, Natural Resources Conservation Service, and the U.S. Fish and Wildlife Service. 

DU is strongly opposed to direct impacts to these properties as substantial public funding has been invested to the restoration

of wetland habitats on these properties totaling more than 500 acres.

Se

DU is generally opposed to any of the proposed routes and alternatives that are located within major valley floodplains and wetland features and prefer those that are situated in upland habitats.

No

In addition to the direct impact of the disturbance footprint, transmission lines pose additional indirect impacts to migratory

waterfowl by providing advantageous hunting perches for predatory raptors and disrupting typically free low elevation fly areas

above wetland habitats.

No

DU is opposed to Segment 4-Proposed and it’s crossing of the Bear River Valley. We are frustrated that no alternative is 

proposed for analysis. The Bear River Valley represents critical wetland and waterfowl habitat located within a major flyway. 

While we are encouraged with the existing route situated relatively well north of Bear River National Wildlife Refuge, a 

reasonable alternative with reduced wetland impact needs to be considered in the EIS.

Yosup

DU is strongly opposed to Segment 7-Proposed and 7-Alternative due to their proposed impacts and/or proximity to Marsh 

Creek and the Snake River and their associated wetland habitats.

Yosup

We propose Segment 7-H as a more suitable alternative. YoDU is strongly opposed to Segment 8A due to its proposed impacts to Billingsley Creek within the Hagerman Valley. The 

Hagerman Valley arguably provides Idaho’s most critical migratory waterfowl habitat and some of the most contiguous and substantial wetland habitat within south-central Idaho.

Yo

100273 RICHARD L 

CANNADY

While I have no objections to proposed route 1W(a), Yo

While I have no objections to proposed route 1W(a), I do have concerns with proposed route 1E. It would cross through 

Glenrock's Gateway addition.

YoSein tCh

I do have concerns with proposed route 1E... I feel that route 1E-A would be better for all parties. Yo

Securfrom 

100274 KATHY MCKENZIE The consideration of Alternate Route 8A clearly has "compliance" issues. According to the VRM the route is not in 

conformance. The interference and negative impact with many Historical sites(National Fossil Beds), Historical Trails(Oregon Trail & Toana Road) and Wildlife Management Areas(Billingsley Creek & State Park) has been defined in the draft. The impact 

to the number of residences(46 compared to the 14 on the Proposed route) also clearly defines another predominate reason to DISREGARD ALTERNATE ROUTE 8A as a consideration.

Yo

100275 TWIN FALLS 

CITIZENS IMPACT COMMITTEE

One of the negatives sited in the DEIS is that the proposed alternatives 7 I and 7 J and 9 D would not conform with the B.L.M. 

's land use plan. However the proposed segment 7 does not conform with the plans of individual home owners and farm 

operators that would be negatively impacted by this plan.

The the 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100275 TWIN FALLS 

CITIZENS IMPACT COMMITTEE (cont.)

In the 7J alternative, one of the objections to it was the proposed rogerson south substation. This is no longer an issue as Idaho power and Exergy corp have recently received permission to construct a substation in this location. Since Idaho power 

has intimate knowledge of these plans there should be no problem relocating the Cedar Hill proposed substation to the Rogerson South location........Since there is in fact going to be a substation located where the proposed Rogerson south 

substation would be located it would be redundant and an burdensome impact on the citizens of this county to have yet 

another substation located where the Cedar Hill substation is proposed. Therefore it makes absolute sense for the 7 J alternative to be selected.

The Alte

We believe that Idaho Power has been disingenuous to the point of lying about cumulative impact on the citizens of Idaho. 

They were aware of the fact that Exergy was planning in conjunction with them, the substation at Rogerson south.

No

Where is the study that supports the fact that Idaho would either need or be able to utilize wind power from Wyoming? This claim is the hook that was used to bring this project through the state of Idaho with an eminent domain right of way. In fact 

recent projections have lowered the estimate of the power requirement of Idaho power in the coming years. So where is the 

proof that this project is even necessary for the state of Idaho and her citizens. Before such a major project should be 

approved with the impacts that have been suggested that proof should be required other wise the transmission line should either be kept on public land or impacting minimally as we have suggested in lines such as on the state line and away from 

population centers.

The quethe rev

In conclusion, as citizens of Twin Falls Co. and the State of Idaho we feel that if in fact Gateway West is to be built, it should be 

built using alternatives 7 I, 7J and 9 D. to minimize the impact on the citizens of the area.

Yothe 

100276 LORI EGGLESTON I sincerely hope the BLM has started the coordination process which they are required to do...NEPA-National Environmental 

Policy Act also has a process that requires the BLM and Forest Service to coordinate with the local governments on the scoping, draft proposals and final EIS. NEPA requires that the analysis conducted be coordinated with local governments. The agencies are also required to work to resolve inconsistencies between the local government position and the federal agency’s position. Local governments that have asserted their coordinate authority cannot be ignored. This means each and every county in the State of Wyoming and State of Idaho that has the Gateway West line proposed should already be at the CO-ORDINATION table not designated as just cooperating agencies. The county commissioners of 

their respective counties have the right and the authority to question the line placement, the mitigation process and the end 

results of any mitigation upon the citizens of their counties.

All the Co

I am strongly opposed to the 1E route Yo

1E as 

As you can see the 1E segment proposes to cross at least 64 miles of private land. This is a very large amount of private land 

to deal with mitigation issues and hardships to cause private landowners. Private land is the largest percentage of land 

ownership that must be mitigated in order for the Gateway West line to be constructed. During construction 17,119 or 46.8% of 

the land is used and during operations 15,039 or 46.2% of private land is used. A major goal should be to cross or cause an 

impact to the least amount of private lands as possible.

Noconpro

I am strongly opposed to the 1E route and feel the 1E-C route alternative would be a much better option for another transmission line.

Yosupprotha

Gateway West line proposal 1E. It is being built to pick up transmission projects that might, could be, have not been developed

yet on the Laramie Plains. (speculation) These projects are very capable if and when they are built to build their own line to the 

Aeolus substation at Medicine Bow and/or could also hook up to the transmission line that is going from Wheatland/Chugwater 

area to Aeolus....I say the 1E line is speculative and a foot in the door to send power also to Colorado. There are currently no 

wind generating areas that NEED the 1E line now or in the very near future and all future development can tie into their own 

common line...Given the CEQ’s definition, electrical generating sources that might use the Gateway West Project to transmit 

their power are not connected actions’

Seconpro

The 1E-C line would be less costly to construct and; if I read the paper correctly; would carry the same “load” as the 1E line 

proposal.

NoAlteana

Water withdrawal for construction should not be taken from streams during irrigation periods. Farmers and ranchers should not 

have less irrigation water available due to construction of this project

The Ap

Also the concern over wildlife nests would be much less if construction and vegetation clearing was not allowed to start until July of any year and continue until April This would allow young wildlife and waterfowl nesting sites to not be disturbed.

WIseacon
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100276 LORI EGGLESTON 

(cont.)

Any new lines should avoid residences and farm lands period. If for some reason some farmland is to be affected then the farmer should receive annual compensation for loss of land use or for disruption of his land use. The one-time payment is not justified. Power lines do not just cause a disruption one time: annual compensation is a much fairer method.

The The neg

100276 DENISE LANGLEY All areas for line placement must have a noxious weed program in place. The weeds and unwanted vegetation must be treated 

during construction, and after completion of the line. The responsible parties that are in charge of maintenance of the power line and roads to the line must treat annually all weeds in their designated areas.

The by redthe spe

100277 LAVONNE GOOD My comments are regarding the proposed rout segment 9. I am against this proposal because it goes through, or too close to 

so many peoples homes/ businesses...Our home is one of those that would be very close to the proposed segment 9. Please consider that so many people have established farms in the area of segment 9 and should not have to have this danger so 

close to them.

Yosup

 I WOULD RATHER SEE ALTERNATIVE 9D be used because it affects so few people. Yo

100278 CHAD GOOD I am against proposed rout segment 9. I am for the alternative 9D. I do not want this close to my farm, or my home. Yo

inc

 I am against proposed rout segment 9. I am for the alternative 9D. I do not want this close to my farm, or my home Yo

inc

100279 JULIE BYERS I am against the proposed rout segment 9. I have close family that this would affect, and I don't want to be exposed to this 

when I come to visit. I would like to see alternative 9D be used.

Yoinc

 I am against the proposed rout segment 9. I have close family that this would affect, and I don't want to be exposed to this 

when I come to visit. I would like to see alternative 9D be used

Yoinc

100280 DEAN SCHULTZ Proposed rout segment 9 would run right over my head, and I don't want that. Yo

sup

 Proposed rout segment 9 would run right over my head, and I don't want that. Please use alternative 9D Yo

Plecro

100281 NATE GOOD Please put the blame stinking lectric poles on the alternate route 9D stead of route 9. Them things is ugly and we don't want to 

have to look at them every day.

Yo

100282 JUNE MILLER I do not like proposed rout segment 9. Yo

sup

 I want alternative 9D! Yo

100283 U.S. GEOLOGICAL 

SURVEY 

The analysis of impacts on wildlife is inadequate with respect to raptors. The DEIS does not discuss the beneficial effects of 

transmission lines on raptors and ravens. 

Adadd

 The analysis of impacts on wildlife is inadequate ... it does not discuss how increased opportunities for raptor and raven 

perching and nesting on new transmission lines could affect Greater Sage-grouse. 

The opppresub

 Nowhere in the DEIS did I see convincing evidence from Idaho Power or any other entity that two separate transmission lines 

are needed in southwestern Idaho. Currently there is one 500-kV transmission line from Midpoint to the Idaho-Oregon state line that has served well during the last 30 years. I do not believe that the Gateway transmission line was identified in Idaho

Power’s 10-year plan, and the need for the line appears to be based on projections that are outdated. To say we need to triple 

the transmission capacity in this stretch overnight does not seem logical. 

The 

 The BLM’s final analysis should consider an alternative with a single line between Cedar Hill and Hemmingway. Thi
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100283 U.S. GEOLOGICAL 

SURVEY (cont.) 

The Final Environmental Impact Statement (FEIS) needs to discuss the beneficial effects of transmission lines on raptors. Our work on the PacifiCorp (PP&L) 500-kV transmission line shows that transmission lines can benefit raptors species such as 

Golden Eagles, Ferruginous Hawks and Red-tailed Hawks by providing a stable and secure nesting substrate (Steenhof et al. 

1993). Pairs nesting on the transmission line had as good or better nesting success than those nesting in the surrounding 

natural substrates. We found that the new transmission line provided raptors and ravens nesting opportunities in areas where nest sites were previously unavailable. In some cases raptor pairs shifted from existing natural substrate nests and nested on 

towers. The FEIS also should recognize that the use of transmission towers by raptors depends on tower design, and not all lines have the same effect. However, adequately designed transmission lines can be compatible with raptors. I feel that the FEIS should discuss providing artificial nesting platforms on towers as a mitigation tool that was used the PacifiCorp (PP&L) 500-kV transmission line. The BLM may want to use another word than “impact” in the FEIS. The way the DEIS is written it implies that impacts of the line on raptors will be negative within a mile of proposed routes. As I mention above, the effects of transmission lines can bepositive. Also the FEIS needs to substantiate and justify the 1 mile buffer around known nests. The application of this buffer is 

unclear to me. 

DisIncinssenfor 

 I found the use of some terms dealing with raptors in the DEIS inconsistent and confusing. The FEIS needs to define terms 

and use them consistent with the definitions throughout the EIS. The DEIS refers “known”, “active”, and “occupied” nests, but no term is defined. The term “active” is used extensively throughout the DEIS but in different contexts. It is an archaic, 

ambiguous, and not a widely accepted term (see Steenhof and Newton 2007) that usually, but not always, refers to a nest with eggs or young during the nesting season. It is unclear whether that the data reported in Appendix D.10-2 actually represent 

historical nests that contained eggs or young at least once over certain time period. The FEIS should report the time period 

(beginning and ending years) represented by the databases used for the analysis. 

Re"kn

 The use of the term nest is confusing in the DEIS because I am not certain whether the counts of “nests” reported throughout 

the DEIS included multiple nests within individual territories. The FEIS needs to clarify this. I think the DEIS is actually referring 

to nesting pair. Assessment of just nests containing a nesting attempt is incomplete because most raptors do not lay eggs 

every year. Assessments of effects of the transmission line on raptors should be based on “nesting territories” and not individual nests because any effects will be on nesting pairs occupying territories rather than the nest. See Steenhof and Newton (2007) for definition of nesting territory. The FEIS must recognize that a nesting territory usually contains numerous 

nests (up to 19 for Golden Eagles). I question statements in the DEIS imply that all historical nesting territories have been identified. Appendix D.10-2 shows that 

no known historical Golden Eagle nesting areas occur within 1.0 mile of segment 8 and proposed alternates; however, I know 

of 16 historical Golden Eagle nesting territories within a mile of the proposed alternative routes for segment 8. Likewise 

Appendix D.10-2 shows only two “nests” occur within a mile of Segment 9 in alternative 9A. I know of 11 historical Golden 

Eagle nesting areas within 1 mile of segment 9 between Saylor Creek and Hemmingway. This makes me wonder if information is incomplete for the species and on the other segments. Locational data for the aforementioned Golden Eagle nesting areas is 

locted in the Boise District and Shoshone Field BLM offices and the USGS Snake River Field Station. Also the Idaho Fish and 

Game, under contract with the Idaho State Office BLM, conducted extensive Golden Eagle and other raptor inventories in 

south-central Idaho within the Project Area during 2011. The FEIS will need reassess the raptor data which includes checking 

the databases at the Boise District and Shoshone Field Office, BLM and incorporate the new information from the Idaho Fish and Game. I would be glad to advise on the matter. 

Bethe datdisnor mueverou

 It is good that the DEIS recognizes that construction activities could cause raptor nest failure or abandonment (page 3.10-34). 

However, the FEIS should define what is meant by “nesting” when it states “Raptors are particularly sensitive to disturbance 

during nesting and brooding...”. Does it mean during incubation or courtship and nest building or both? The FEIS should 

recognize that it is very important that the pair be protected from disturbance during courtship (prior to egglaying). In PRC-12 

the survey should focus on all nests in the nesting territory and an effort should be made to look for new nests. Some eagle 

pairs often build and use new nests. It would be good in PRC -14 to establish a cutoff date because in southwestern Idaho the duration between egglaying of the first and last pair can be up to two months. The FEIS should substantiate the 0.5 mile buffer. 

How does this differ from the 1 mile buffer described earlier? As a side note, the idea that construction roads will be closed and rehabbed after the line is in place is an admirable gesture, but could be unrealistic based on my experience with the PP&L 

500-kV transmission line. The roads were “closed” and rehabbed, but the public used them any way and they are well used after 30 years. 

EdPro

be eacthe 

 Segment 8 as proposed from I-84 to Hemmingway would require a new road for maintenance and construction resulting in 

additional habitat fragmentation within the NCA. The proposed crossing at Halverson Lake is counter to scenic, historical, 

archaeological, and recreation values in that part of the canyon. However, if the new line could be place closer to the existing 

PP&L 500-kV than a quarter of a mile and paralleling the PP&L 500-kV line completely out of the Birds of Prey NCA, like the blue line on the map, it would make a very desirable alternative. 

Lin
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100283 U.S. GEOLOGICAL 

SURVEY (cont.) 

Segment 8E is not desirable because it results in Segment 9D crossing at an environmentally sensitive area near the mouth of Sinker Creek (see comment of Segment 9 below). 

Yo

 Alternative 8B is perhaps the most desirable because it runs outside the NCA nearly eliminating any conflict with the legislation 

that established the NCA. 

Yo

 In reviewing the proposed route and the alternatives from C.J. Strike to Hemmingway, I find that Alternative 9D is the most 

desirable route with the least conflicts if it crosses the Snake River Canyon at its narrowest point, just upstream from Swan 

Falls and immediately adjacent to an existing 138-kV transmission line. 

Yo

100284 CRYSTAL GOOD I do not want the proposed rout segment 9!!! Yo

sup

I am voting for alternative rout 9D. Yo

100285 HAROLD A & 

MERRILAN SIMPER 

The proposed route, Segment 9, runs less than 200 feet from our home. Mic

wh

 The alternative route 9D makes more sense. There are less homes on alternative route 9 D and there is a road along that 

route. 

Yo

100286 HAROLD SIMPER My first concern is the closeness to the residence. The second concern is I don't want the Transmisson lines towers to limit the 

possibility of a pivot on my farm land next to route segment 9.

Yosup

100287 GAYLEN SMYER If this power line is to be constructed the state line route is only slightly longer than the route proposed by Idaho Power. The 

segment lengths are virtually the same if a Rogerson station is constructed rather than insisting upon Cedar Hill. The state line 

route would impact would directly impact fewer people and avoid prime agricultural areas. It would be impossible to quantify the impacts to private property along with the safety considerations for local inhabitants. 

Yo

 In summary, I do not believe this project would even be considered were it not for the federal incentives currently being offered 

through the federal government. I am opposed to the construction of the Gateway West transmission line. I am opposed to the construction of a power line that will negatively impact the farmers and ranchers who are capable stewards of the land. I am opposed to the restrictions that will be imposed area residents as they encounter towers and transmission lines in the area. 

Yoof t

 One aspect of the EIS is devoted to establishing the need for the transmission line. The proposed line is one of many being 

discussed to enhance and expand the power grid. The Gateway West project will eventually connect with a line being built 

from Las Vegas to Ely, Nevada near Cedar Hill. It occurs to me that it would be easier and cheaper to transport coal on existing railways from the coal fields in Wyoming to the power plant in Delta, Utah. Delta is just east of Ely and a connecting

transmission line could be built across less populated portions of both states. 

Anof t

 The EIS provides extensive and heavily weighted consideration for fish and wildlife. It appears the corresponding consideration 

for impacts to humans is under reported and under estimated. It is my position that estimated impacts to the public in general,

and to the private landowners in particular, are incomplete. The presence of one or more transmission lines will limit a landowner’s use of private property and restrict public access to ensure public safety.

Soto aThi

 There appears to be a bias toward placing the majority of the transmission line on private property rather than utilizing public 

lands. I would hope there is no aversion to placing a transmission line intended for public benefit primarily on public land. To 

the extent possible public power transmission lines should be placed on public land.

The issprivow

 The Draft EIS addresses the perceived need for additional electrical transmission capacity to serve areas of greater electrical 

power consumption in the western U.S. Even though Idahoans would benefit only minimally, much of the transmission line would be located within Idaho. I question the appropriateness of building a huge transmission line through one state to serve the interests of consumers in other states when, in my opinion, there are viable alternatives. 

Chinc
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100288 MEDICINE BOW 

CONSERVATION DISTRICT

The Medicine Bow Conservation District recommends that all owners of easements and/or rights-of-ways for power lines, above or below ground transmission lines, road ways, oil and gas exploration, pipeline and development sites, wind farms and mineral exploration and extraction sites shall be solely responsible for all control of noxious weeds until full establishment of 

perennial grass/shrub cover is established meeting the satisfaction of the private landowner, lessee or federal manager. Specifically, segments 2 and 3 are not in a "high fire danger due to Cheatgrass". Therefore we do not support the following 

recommendation within segments 2 and 3 for mitigation purposes or any other reclamation practices: "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..." We ask that all seed mixes be comprised of only local native grass, forb and shrub species. We would ask that all seed mixes 

be developed in cooperation with MBCD and/or the local private landowners for use on all private lands. 

MBCD stipulates that only certified hay or straw to be used as mulch on reclamation projects on any county road, state or 

federal highway project, or any reclamation project on lands owned or managed by the state of Wyoming or the Federal 

Government.

No

MBCD stipulates that within historic Greater Sage-grouse range that a minimum shrub reestablishment standard is met as part 

of all reclamation sites sufficient to restore/maintain adequate habitat. One of MBCD's greatest concerns with the GWT project and associated future power lines is the fragmentation of Greater Sage-grouse habitat. Though much of the line is associated 

with an existing power line corridor, we feel the drastically larger, 1500 foot ROW with two separate lines, is more obstacle 

than sage-grouse are willing to negotiate. With dissecting several sage-grouse core areas and important habitats we believe the impacts to Sage-grouse will be significant. Mitigation may not be adequate. We would ask that these areas be avoided whenever possible. MBCD asks that full compliance with the Governors Executive Order 2011-5 - Greater Sage-Grouse Core Area Protection. Exceptions should not be made for this project.

Muthe this 

MBCD will not support any action that results in a net loss of Animal Unit Months (AUM’s) on any allotment, permit or lease on 

lands owned or managed by the state of Wyoming or the Federal Government.

It wgra

MBCD asks that wetlands be avoided to the fullest extent possible and when not possible to avoid that complete mitigation be 

made when impacting any wetlands including prairie potholes, perennial and ephemeral streams, reservoirs, natural seeps and 

springs, etc.

We3.9

MBCD is not in support of route 1E. we ask that it be fully removed as an alternate route. Yo

Seconpro

The Medicine Bow Conservation District anticipates a significant Cumulative impact in regards to transmission lines 

construction in the near future. We do not feel this EIS adequately addresses this in the analysis. We ask that a more details 

consideration be made of cumulative impacts associated with this project, including impacts to wildlife, socio-economics, viewsheds, etc.

Chwit

MBCD supports that all mitigation funding go through the Wyoming Wildlife and Natural resource Trust Fund (WWNRTF) this 

is the most responsible and responsive means of getting mitigation on the ground. If this is not possible we would propose that

the funds be distributed through local conservation districts. MBCD asks that mitigation funds be made available for alterations to Carbon County, Wyoming Road 121 near Medicine Bow, which will serve as the access to the Aeolus Substation, including the bridge 

across the Medicine Bow River. The cost of these changes should not be exclusively on the backs of local tax payers.

Mit

we are generally in support of the Gateway West Transmission Line Project as far as it is constructed responsibly. No

100289 EDWARD KAUFMAN I support the proposed rout of segment 8, Midway Point to Hemingway Yo

sup

100290 CALVIN LOW Please encourage them to move this power line to alternative route #9D on the north side of the snake river where it won't 

impact us or any of our neighbors.

Yo

100291 SHARON HARDYMILLS because these transmission lines are to be used by the public the line should be on public land The 

line Ap

 State line which is away from the majority of people would be best. Yo The proposed corridors are already working with BLM through Wyoming so would already have the forms and paperwork 

required to cross that land and it could and should carry through Idaho on State line which is BLM managed public lands

Yo
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100292 PLANNING AND 

ZONING COMMISSIONER, CITY OF MELBA

I favor all transmission lines in the Gateway West Project to follow the current built transmission lines and go through the Birds 

of Prey areas and BLM land.

NoThe me

On Segment 8, I strongly oppose alternative 8B. Yo

100293 GORDON AND 

KARON BEST 

The congressional act that mandates new powerlines are to be placed in existing corridors is the most commanding reason 

that the BLM should comply

We in ewh

 Running the lines on the north side of the snake river where the existing corridors now are would comply to the law. The 9D 

proposal is our choice. We do not want noisy, ugly, property devaluing high power lines over our land and houses. Would you?

Yo

100295 SHARON HARDYMILLS I am in favor of segment 8 because it has less impact on farmland and the city of Kuna Property. It is shorter and therefore less expensive. Yo

sup

 In the event alternative segment 8B is chosen I strongly oppose the proposed route in mile 21.3 to 23.5. This is an unnessary 

jog into my field. A tower would be in a forty acre field I farm and has wheel lines used for irrigation.

Notab

100296 STEVE MCCOY At the meeting in Douglas. we were shown the two proposes routes through Glenrock... 

You have other options: 1 - run the power lines through the unpopulated parts of Wyoming or next to existing power lines. This would save you money 

because you would't have to wast taxpayer money on all your studies. The studies were already performed for the existing 

power lines. 2 - run the power lines under the ground. They do that for natural gas and oil, why not electricity? 

3 - comprise. If you still must run the power lines near a town, run that particular portion of the power lines near the town 

underground. You can run the rest of the power lines above ground between towns.

Noconpro

 We have already had our electricity prices raised to support your current "infrastructure improvements", which you recently 

defined to mean that the residents of each state must share the costs of new power lines running through that state. 

You are going to ruin our views of the mountains and the prairies, our property values, and then increase our electricity costs. 

Why?

Noconpro

 Most of the information handed out at the meeting emphasizes the overall scope of the project and the town of Glenrock 

seemed to be just a speck on the map. without the resolution to examine either the proposed routes or the alternate routes. I understand the complexity of the project. and the desire to focus on the "big picture", but I have my focus on the local community and the long term affects of your proposals. The people of Glenrock were initially told that the two options were either route 1E OR route lW(a). This seemed to spark some 

controversy between Glenrock residents living on the north side of town versus those living on the south side of town. There 

are NO residents of Glenrock that want their property values affected by surrounding Glenrock with power lines used only to supply the west coast and Nevada with power. I have contacted the local elected officials and were told that they were lead to believe that the transmission lines would be located next to the existing power lines far south of Glenrock. I was also told that no elected officials have been included in the 

selection of the various routes. This is very troubling that we as citizens have no input to the decisions affecting our future. 

When Rocky Mountain Power gets to choose a route that is cheapest, and the BLM is along for the ride to "grease the skids", I 

am shocked and appalled.

No

conpro

100297 FERN LINTON I have read the Draft EIS for the Gateway West Transmission Line Project. I am particularly concerned with impacts to 

historic/cultural trails and sites along the entire project area. Wyoming and Idaho have some of the most well preserved Class 1 and 2 trails throughout the whole Historic trail System. Viewshed at this time in many areas, is typical 1840-1850 viewshed. Very pristine/no modern invasion this transmission line will severly impact trail setting. There are many locations of trail crossings along the transmission line corridor. Even if crossings are at 90 degrees to trail there will be impact to the NSO guidelines set in BLM District RMP's for historic trails

No

 In the Rock Springs and Kememmer BLM District there are several alternatives and it appears that the proposed/preferred 

alternative may not best fit the needs of Trail preservation. I have studied your tables and charts and although impact will occur 

to historic trails and sites in all your alternatives the best restrictive alternatives appear to be Section 4, Alternatives BCDE

NoThe Alteis p

 mitigation issues must be addressed in your PA process. 

Avoidance - Reduction, Compensation, and modification all appear to be important issues to address with the least ammount of impact to the historic trail system.

No

 KOP's with initial monitoring need to be established and consistently revisited - not only for multiple view shed issues from 

KOP's but for individual view shed issues at each KOP.

MoAp
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100297 FERN LINTON 

(cont.) 

The Powerline impacts graves, campsites river crossings and up to 7 different trails a huge damage to Preservation of our historic culture and History.

No

100298 ALMY BARNES I recommend that the proposed route of Gateway West transmission line segment 4 be abandoned and alternative 4A be used 

instead. As proposed and according to the EIS table 2.8-4 segment 4A would be less than half as long and disturb less than half the 

construction and operations areas as segement 4. In almost all the features compared in the table, segment 4A is superior. Segment 4 looks good on the map, but someone needs to put boots on the ground and go look at the route. The segment (over) from Fontenelle to Cokeville is some of the most rugged unspoiled wilderness left in Wyoming. Construction would be 

difficult and expensive and have a short season due to the severe winters in that area. A transmission line is a transmission 

line and a road is a road. Mitigation or no, the area would be scarred forever.

NoThe Alteana

 I recommend that the proposed route of Gateway West transmission line segment 4 be abandoned and alternative 4A be used 

instead. As proposed and according to the EIS table 2.8-4 segment 4A would be less than half as long and disturb less than half the construction and operations areas as segement 4. In almost all the features compared in the table, segment 4A is superior. Segment 4 looks good on the map, but someone needs to put boots on the ground and go look at the route. The segment (over) from Fontenelle to Cokeville is some of the most rugged unspoiled wilderness left in Wyoming. Construction would be 

difficult and expensive and have a short season due to the severe winters in that area. A transmission line is a transmission 

line and a road is a road. Mitigation or no, the area would be scarred forever.

YoProconCh

 Instead of proposal 4, please accept alternative 4A. Or choose EIS para 2.3: "no action" and scrap the plan. No

The Alteana

100299 BOB SCHEIDT, 

KARIN SCHEIDT 

Please find and alternative routhe whereby we don't have to see the transmission lines from the back of our home No

conpro

100300 THOMAS DIGRAZIA Each of these pastures have fences that would carry an electric current from close proximity to power lines. I cannot afford to 

have any of my foals endangered and I need all three pastures to house them. I had my own lines buried 12 years ago in anticipation of this breeding program

No

100301 INA DIGRAZIA Since 2001 I have owned a restaurant in Albion, Idaho. We have invested over $1 million into a new building. We are located 

on the back-country-byway and draw alot of tourists to our little town. We are almost entirely dependent on out-of-towners. Many people have a fear, whether rational or not, that traveling under or near power lines will adversely affect their health. Our 

business has been so bad because of the economy; we could not survive one more reason to turn people away from our area.

NoAlbthe 

100303 JAMES A 

BRUNETTE, TIMOTHY H PARKER 

The preferred route of the State of Wyoming is Alternate 1W-A. Alternate 1W-A was the initial route of the project, and 

continues to show clear advantages over the proposed route 1W(a) as evidenced in the draft EIS. We would support the use of 

this preferred route - Alternate 1W-A.

YoSebeeconpro

 Further, interference with irrigation can have important consequences for our water rights. Wyoming law requires us to 

beneficially use our water rights, or we can forfeit them. Our business depends on those water rights; we cannot afford to lose

them and will not allow anything that could jeopardize them.

Se

 We strongly oppose the proposed route 1W(a) of the Gateway West transmission line project. Yo

suplonfollas 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100303 JAMES A 

BRUNETTE, TIMOTHY H PARKER (cont.) 

This proposed route would cut across our river-bottom irrigated farm ground and pasture area, which is some of our most productive, important, and valuable land. By using route 1W(a), a new transmission line would severely negatively impact our 

ranching and farming operations. Our headquarters is located in the NW/4 of Section 2 and we have full time employees 

residing there. We have pivot in the NE/4 of Section 2, which irrigates a large, productive alfalfa hay meadow. We have 2 other

pivots located in the NW/4 of Section 2 and the NE/4 of Section 3. We have ordered and have commenced dirtwork for a large 

pivot in the NW/4 of Section 3. Overhead power lines are inherently inconsistent with these circle pivots, and thus siting a new 

line in a way that would interfere with their operation would be extraordinarily detrimental. In addition, we have other pipe and 

flood irrigated land in these and adjacent sections. For these reasons, we take exception to the statements made and 

information presented in the draft EIS that show no dryland farming or irrigated agriculture acreage being impacted by the proposed route. [Table 3.18-7 (Agricultural Land Disturbed during Construction - Segment 1W) and Table 3.18-8 (Agricultural 

Land Disturbed during Operations - Segment 1W)]. We believe that depicting and describing only rangeland and pasture acreage, and stating under Crop Production: "Segments 1W(a) and 1W(c) would cross less than 0.1 acre of irrigated 

farmland." is incorrect and inaccurate. In fact, a portion of the landowner map from the Gateway website showing the 2-mile 

study corridor clearly shows a field under pivot irrigation.

The corThe Pre

 Our family and the ranch also own mineral interests in these areas, which interests are in the process of being developed by 

the oil and gas operator. An overhead transmission line could present conflicts with that development.

The cor

The Pre

 There are approximately a dozen existing residences located in and around Sections 1 and 2. Consistent with that land use 

pattern, over the next number of years we plan to subdivide for residential purposes portions of our deeded acreage between 

the North Platte River and the Glenrock Highway. My brother and I plan to construct residences on parcels in the NW/NW of Section 1 and in the NE/NE of Section 2. Those parcels were selected because they have river frontage, are easily accessible, and are east of our farming operations. We have begun the process of applying for a family subdivision through the County. 

Some of the infrastructure (roads and power) has already been constructed and we have received some governmental approvals for additional infrastructure (pipelines and access permits off the highway). This land is extremely valuable and a new high-voltage transmission line would be inappropriate anywhere near residential properties and would substantially 

diminish the value and long term potential.

The curPre

 Additionally, for many years we have operated a commercial bird farm for release of pheasant, chukkar, and quail to hunting 

clients. We have plans to install facilities, including a lodge on the river, to develop that business. A large overhead power line 

would be inconsistent with our bird farm operation for both firearm safety and aesthetic reasons. The game bird farm draws in 

raptors, eagles and other protected avian species. Installing additional perching areas by way of a transmission line across this 

area will increase mortality of these species. Attached as EXHIBIT 1 is a letter from an avian biologist describing these negative impacts.

Imp

100304 MUDDY MINERAL 

EXPLORATION, LLC

[business] is a small Wyoming oil and gas operator, and it owns and operates the South Glenrock Block C Unit, located 

immediately south of Linc Energy's East Big Muddy Unit and west of Linc's South Glenrock B Unit. The rough outline of the 

South Glenrock Block C Unit is shown as a yellow transparent polygon on the attached map, through which the proposed lines, 

1W(a) and 1E, run.

Nobeeconpro

business] objects to proposed routes 1W(a) and 1E, as it appears they will be constructed directly through our field. No

beeconpro

[business] is developing this field and it intends to drill 60-70 new wells in the near future to produce the recoverable oil 

reserves, which are estimated at 5 million barrels. [business] has spent significant sums on engineering and geology to develop its water-flood and CO2 programs in the South Glenrock Block C field. The development will require not only space for 

new wells and drilling rigs, but many pipelines, powerlines, and other facilities to undertake this extensive type of program. A new high voltage powerline and the right of way to accommodate it that runs through the middle of this field will severely 

impede development of this mineral resource.

YosupAlteana

[business] supports expansion of 1W(c) and construction of lines parallel to it (1E-A). This corridor is least intrusive to the area 

in general and will not impact the development of the significant oil and gas resource at the South Glenrock Block C Unit.

Yosup

lineBL
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100305 NOH SHEEP 

COMPANY

Scott Flinders, Tetra Tech, was most helpful at the Twin Falls open house in responding to our concerns that we had been 

unable to obtain or view maps adequate to determine the impact of various route proposals upon our private lands and grazing 

permits. He created a fine map and mailed it to us in good time. The maps on the CDs are inadequate. Neither the Twin Falls BLM office nor the Twin Falls County Commissioners had appropriate maps. Idaho Power did provide an internet site which 

was better, but still inadequate, and no maps with sufficient detail were available at the open house. I have talked with several 

other land owners and permit holders who experienced the same frustrations. Having worked with NEPA processes for many 

years in several capacities, I doubt that this lack of critical information meets the requirements of the law.

The in AApprolev

Our greatest concern is with private lands in the immediate vicinity of Big Creek, some of which are committed to two, relatively 

small, fenced pastures used for summer grazing for all of our rams and thus are critical for our entire operation of 2,500 breeding ewes. One of the these parcels is directly on Big Creek as it enters a small canyon, and is also the location of our 

major sorting corrals and facilities for loading trucks. These ram pastures and facilities have unique properties, cannot be 

replicated elsewhere and are bisected by the midline.

Alteconpro

Big Creek, at this location, runs through a small canyon with vertical walls, with considerable rocky areas on either side. This 

reach of Big Creek has extensive, healthy riparian areas and is inhabited by an extensive beaver colony. Big Creek is also a 

major tributary of Shoshone Creek, an important component of maintaining water quality in Salmon Falls Creek and Reservoir. 

These physical circumstances will likely lead to increased construction of roads for access and higher costs.

Alteconpro

At this same site is another unique, historical feature which would have to be protected. At the time these lands were 

homesteaded, or possibly before. With great effort, a ditch was constructed to convey water diverted from Big Creek above the 

canyon, west along the canyon rim to irrigate hay ground some distance downstream. It is a remarkable testimony to the energy and hardships of that era, and should be preserved.

NoAlteana

The recent court settlement of Earth Guardians v. Salazar moves the Endangered Species act and sage-grouse to center 

stage. The Shoshone Basin Sage-grouse Local Working Group, which has not been contacted by the proponents, has listed 

infrastructure development as the second greatest threat to sage-grouse in the area. Data in Appendix D makes it clear that 

Alternative Segments 7I and 7J are likely to have much greater adverse impacts upon sage-grouse than other alternatives. 

Adverse impacts upon this unique, successful sage-grouse population caused by Gateway or other major infrastructure developments could significantly reduce values of private lands and permits. These costs are not addressed in the Draft.

NoAlteana

Because the alternative route along the Nevada-Idaho border, including segments 7I and 7J, traverse dry, often remote rangelands as compared with the proposed route, the possibility of invasion and spread of invasive weeds is much greater. Major travel routes into Shoshone basin from Jackpot and Rogerson are predictable routes 

for invasion. Vacant lots in Jackpot are filled with knap weed. Vehicle and ORV traffic from there is increasing. Some private and BLM lands in the vicinity of Rogerson are also likely sources for invasion. Any activity in this type of terrain which 

increases roads invites increased use by ORVs. Risk analysis involves an estimate of the probability of an event occurring times the cost. In spite of the best intentions and short term efforts portrayed in the Draft, the long term costs of an occurrence 

to all private land owners and other dependent interests are enormous. This is reason enough to reject the southern route.

Alteconpro

My reading of the draft found no reference or role for the Twin Falls Weed Bureau, the most professional, aggressive, effective

defense against invasive weeds in this project area. We do appreciate the enormous efforts which have gone into this effort by 

the Bureau of Land Management, and appreciate the assistance given to us and to the public.

Noreg

Any time roads of any kind are added the growing problems of gates left open, vandalism, irresponsible ORV use and other 

complications increase.

NoAlteana

Segments 7I and 7J are likely to have much greater adverse impact.... Yo

tabconpro

100306 OFFICE OF THE 

GOVERNOR, STATE OF WYOMING 

Alternative 1E-A is inconsistent with my Executive Order 2011-5 and could result in adverse impacts to sage-grouse 

populations. There is no information presented in the DEIS suggesting measures that could be implemented to ensure that Alternative 1E-A is consistent with the Executive Order. In addition, landowner concerns with this alternative are the same as 

those for the applicant's proposed route, 

Sepro

bee

 most of the "likely" wind projects are clustered a relatively short distance from the Aeolus Substation and those entities were 

unable to identify current or active plans for projects near the eastern portion of 1E-B. 

Seprobee

 should a wind project be proposed east of the alignment for Alternative IE-C in the future, a radial line could be constructed 

between the wind project and the Aeolus Substation rather than adversely affecting the many landowners along the path of the 

applicant's proposed route who, based on discussions with my staff, have no interest in either wind development or 

transmission. 

Seprobee
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100306 OFFICE OF THE 

GOVERNOR, STATE OF WYOMING (cont.) 

consider a new alternative that avoids landowner concerns in northern Albany County associated with 1E-B and sage-grouse concerns with Alternative 1E-A. If a new alternative can be developed in cooperation with the state and local cooperators and landowners, I recommend that BLM incorporate the alternative into the Final Environmental Impact Statement (FEIS). 

Seprotha

 Alternative 2A would result in an unacceptable and unnecessary impact to the residents and private property owners of Fort 

Steele and this alternative should be rejected in the Record of Decision 

Yo

 Alternative 4A is the only current common-sense alignment for this segment. Executive Order 2011-5 establishes a 2-mile wide 

corridor through the Sage and Seedskadee Core Areas centered on the existing transmission lines to facilitate east to west 

routing of new transmission lines in this portion of the state. Alternative 4A is consistent with Executive Order 2011-5 

Yo

 Executive Order 2011-5 - the applicant's proposed route and all other alternatives for Segment 4 (except 4A) in the DEIS are 

inconsistent with the Executive Order 

Thi

 I request that BLM adopt Alternative 4A in the Record of Decision and that BLM, SHPO and the applicant begin discussions 

concerning appropriate mitigation to offset incremental visual impacts to the historic trail. 

Yo

 The DEIS does not provide a consistent area for study of socio-economic statistics suitable for the Industrial Siting process, 

rather it chooses different geographic areas to report different statistics. The Industrial Siting process requires a consistent 

geographic area and data indexes for different socio-economic features for that consistent geographic area - e.g., 

student/teacher ratios, crime rates, doctors or hospital beds per capita, water system capacity per capita, etc. The specific 

geographic area to be used in the Industrial Siting process will be identified with the project proponent during the jurisdictional 

meeting with the Industrial Siting Division. 

The are2). samAre

 1E-C, is available that clearly reduces impacts to both natural resources and private landowners and would be substantially 

constructed in an existing transmission corridor 

Yo1E Alteana

 I was concerned to see BLM conclude in the Executive Summary, at p. ES-7, that Alternative 1E-C would not meet the 

applicant's need to provide 230 kV infrastructure farther east where wind energy resources are planned. This statement is 

erroneous and is based on information which has changed significantly since the applicant's proposed route was developed. As you are well aware, a large portion of the area north, east and southeast of the Aeolus Substation (the termination of 

Segment 1E) has been designated core area for sage-grouse. As such it is unlikely that wind development will occur in areas 

previously considered by the applicant. 

 Securfrom 

 I request that BLM implement standard state/federal protective stipulations, utilizing existing waiver procedures. The 

estaut

 The proposed project should comply with the Record of Decision and Approved Casper Resource Management Plan (Dec. 

2007), Decision #4051, which provides: "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." 

The The und

 The applicant should implement measures to control weeds resulting from any new surface disturbance throughout the state. 

Among all the potential invasive plant species which may occur along Segments 1W and 1E, cheatgrass represents the most significant concern, particularly if it establishes in relatively intact sagebrush communities, such as in upper Bates Hole. 

Cheatgrass can proliferate rapidly in arid and semi-arid sagebrush grasslands and can pose an eventual fire hazard in 

sagebrush communities. Avoiding impacts from cheatgrass should be specifically addressed in the FEIS. 

The surredche

 To prevent the spread of AIS, the following provision should be added and required: 

"When work will occur in or near water, all equipment must be decontaminated. Decontamination should first occur before 

arrival at a project site, so AIS are not transferred from previous work sites. Decontamination should again occur before 

leaving a work site, so AIS are not transferred to the next work site. Decontamination may consist of either: I) drain all water 

from equipment and compartments, clean equipment of all mud, plants, debris, or animals, and dry equipment for five days in 

summer (June, July and August); 18 days in spring (March, April and May) and Fall (September, October and November); or 

three days in winter (December, January and February) when temperatures are at or below freezing; or 2) use a high pressure (2500 psi) hot water (140°F) pressure washer to thoroughly wash equipment and flush all compartments that may hold water." 

VEdea

 I recommend that AIS stipulations also be required for the disinfection of water trucks between waterbodies. These trucks 

could easily harbor and move A1S. 

WEme

devme
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100306 OFFICE OF THE 

GOVERNOR, STATE OF WYOMING (cont.) 

Regarding Appendix C, SPC-4, contaminated soils should be stored 500 feet from any wetland or waterbody, consistent with 

other hazardous materials. And as for Appendix C, C-1, it should address reporting requirements for spills. 

Nomesoiand pro

 Concerning p. 2-163, Table 2.7-1, Midget Faded Rattlesnakes, there is no mitigation measure stated for midget faded 

rattlesnakes, if they are found. Midget faded rattlesnakes appear to be a relatively rare species and WGFD believes steps are 

prudent to protect the species and avoid potential listing of the species as federally endangered or threatened. I recommend 

the BLM incorporate the following in the Record of Decision to address potential impacts to this rare species: 

"Prior to the start of construction, the applicant shall conduct surveys for midget faded rattlesnakes and prepare a plan 

identifying measures to reduce impacts for approval by BLM and the WGFD." 

The Se

 The Bates Creek Reservoir Lek and the Upper Bates Creek Lek combine to form (along with two other smaller leks) one of the 

most substantial sage-grouse lek complexes known in the state. For example, on May 7, 2006, a total of 465 males and 9 

females were observed attending these two leks. Bisecting the high quality sagebrush/sage-grouse habitat to the east of these leks with two parallel transmission lines separated by 1,500 feet may impact a significant number of sage-grouse within the Natrona Core Area if east-west movements are impeded. I concur with WGFD's recommendation that BLM reduce the 

separation between all the alternatives and the existing line to the maximum extent possible in this area. It is my understanding 

that separation of 800 feet between 230 kV lines is acceptable to the Western Electric Coordinating Council. 

SeTheand 

we

 At p. 2-154, Table 2.7-1, Fish-4; the DEIS states: "If an aquatic invasive species is discovered during surveys for wetlands and 

waters of the U.S. conducted for USACE and state permitting prior to construction, the waterbody will be flagged and noted on the construction drawings. After work is complete in that waterbody, any equipment involved in construction in that waterbody must be washed to remove any propagules of aquatic invasive species and to prevent the spread of those species to other 

waterbodies in the Analysis Area." The above provision assumes that surveys conducted by the proponent are going to detect 

aquatic invasive species (AIS), which is not necessarily the case. Instead of the language quoted above, the measure should 

be worded as follows: "All wetlands and waters in the project area are assumed to contain aquatic invasive species and all 

equipment contacting water will be properly disinfected. After work is complete in a waterbody, any equipment involved in construction in that waterbody must be washed to remove any propagules of aquatic invasive species and to prevent the 

spread of those species to other waterbodies." 

Ch

 Alternatives 1W-A and 1W(a) for 1W and Alternative 1E-C for 1E. These routes are consistent with my Executive Order 2011-5 

(Greater Sage-Grouse Core Area Protection) and consistent with the comments you received from the Albany County 

Commissioners and members of the Wyoming Legislature. For reasons stated below, the BLM should adopt these routes in the Record of Decision and reject the applicant's proposed route 1E-B and Alternative 1E-A. 

YotabAlteana

100308 Clint Rodeman Any wind development projects can be served by collector lines routed to the Rocky Mountain Power substation at Aeolus. 

Collector line construction would be at the expense of the developer and not at the expense of rate payers. Developers would also be required to negotiate fair rates with landowners for collector lines and landowners would not be subject to eminent 

domain.

Sethe Ch

The proposed route [1E] crosses a large section of private land and landowners overwhelmingly oppose this line and do not 

plan to develop wind energy on their property.

YoSeconpro

The Wyoming Governor’s executive order states that all new lines should follow existing corridors. This proposed line is in an 

unindustrialized area with no existing transmission lines.

ThiThe 

dro

Alternatives exist that will not encroach on unindustrialized areas, critical elk range, sage grouse core areas and that are 

favorable to landowners. This line can be routed south of the core sage grouse area in to the area where landowners are favorable to wind development and transmission. See attached map with purple line showing alternative.

ThiThe dro

I am writing to express my concerns over the proposed Gateway to the West project, specifically segment 1E-A. This segment is unnecessary, intrusive and opposed by the majority of landowners

Thiincactbee

Section 1E-A is being promoted by Rocky Mountain Power to provide redundancy. This is the only section of “so called” 

redundant line in the proposed route across Wyoming. This clearly an attempt to provide a transmission line to an area Rocky Mountain Power plans to develop in the future and designating it as a transmission line will avoid the moratorium on collector line construction.

Seconpro
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100309 BLAINE COUNTY, 

BOARD OF COMMISSIONERS

1) In the southern tip or "tail" of Blaine County a 345KV powerline currently exists (See Segment 6). Pursuant to Chapter 34 of

the Blaine County Code (attached), this is the appropriate location in Blaine County for such a high voltage powerline. The Board has no objection to energizing this line from 345KV to 500 KV on the existing route identified in Segment 6.

Yo

3) On the other hand, it may be reasonable to contemplate Segment S(o). Blaine County agrees that this segment does not merit further study for the reasons given in the draft EIS, but in light of the suggestions by our neighbors to the south, this

board understands identifying it for limited consideration . The suggestion by "[a] combination of Power County, Bannock 

County, and Cassia County residents" that a line "be routed directly north from the Populus Substation in order to avoid Power 

and Cassia Counties altogether" might justify a limited examination of Segment 5(o).

Nobee

100310 GREAT BASIN 

TRANSMISSION, LLC, LS POWER GROUP, LLC

The Draft EIS indicates in Table 4.2-12 on page 4-41, and in the text of the last paragraph of Section 4.4.19 on page 4-94 that

the SWIP-North project is "presently on hold." The SWIP-North project is not on hold. SWIP-North has received major project permits including a BLM notice-to-proceed and construction is pending completion of satisfactory commercial arrangements. 

GBT requests that the referenced table and Draft EIS text be updated to reflect the correct status of the SWIP-North project.

Thi

the Gateway West Project is analyzing transmission alignments and substation locations that are in close proximity to the rightof- way of SWIP-North. GBT requests that the location of the SWIP-North right-of-way be considered when determining the 

location of the Gateway West Project elements. a. Any proposed substations, interconnections, or transmission alignments that cross the right-of-way for SWIP-North need to 

be coordinated in advance with [business].

CoBL

b. For those areas where proposed alignments of the Gateway West Project will parallel the SWIP-North right-of-way (such as 

Segment 10 from Midpoint Substation to the proposed Cedar Hill Substation), [business] requests that BLM consult with and obtain the concurrence of [business] regarding the separation distance between parallel alignments before issuing any land 

use decisions.

Nosta

3. [business] requests that any land use decisions that are issued as a result of the proposed Gateway West Project be subject 

to the SWIP-North right-of-way.

Noaut

100311 UNION PACIFIC 

LAND RESOURCES (ANADARKO)

To reduce the impact to Anadarko's interest we respectfully request: 1. BLM fully consider requiring shared infrastructure, where feasible, resulting in co-locating transmission lines on common towers/structures. This consideration should include the proposed Gateway South and TransWest Express Transmission Lines. 2. That the Project parallel existing transmission line corridors through the Checkerboard lands. 3. That construction of two parallel single-circuit lines should not be authorized due to a 25% to 30% increase of additional 

disturbance. A single structure should be used for these lines. 4. BLM address the steps it will take to preserve Anadarko's ability to access to its trona, coal, oil and natural gas resources 

and other surface and mineral resources. This should include requirements to relocate transmission lines and towers and/or 

subside the surface if necessary. 5. That BLM not issue ROWs until such time that there is resolution of private property mineral and access agreements within 

the Checkerboard lands. 6. That the Project follows established energy corridors. 7. BLM address, and provide the opportunity for public comment on draft language for the analysis regarding the 

circumstances private lands would be condemned, and what the effect would be. 

8. That economic impact to federal, state and local taxes (ad valorem and severance) that results from loss of fee trona, coal,

oil and natural gas production due to the Project be disclosed. 9. That mitigation measure MN-2 is made a condition of approval for the ROW and that the language is expanded to include all 

potentially recoverable minerals on federal, state and fee mineral resources. 

10. BLM to require resolution of private property mineral and access agreements prior to authorizing BLM ROWs. Alternatively, 

the ROW grant should be conditioned to require the resolution of private property mineral and access agreements prior to 

initiation of construction activities.

1) Gdoureq2) Atranand 3) S4) TThe and 5) Tpropro6) S7) C

law und8) Tres9) T10) procon
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100311 UNION PACIFIC 

LAND RESOURCES (ANADARKO) (cont.)

Within the Checkerboard lands, the Gateway West Project area encompasses, among others, portions of the Rock Springs 

Uplift, Great Divide Basin, Kindt Basin as well as the Hanna Basin. These areas are highly prospective for, among other 

minerals, coal. Anadarko has coal projects in the Hanna Basin including Freezeout, Cyprus-Shoshone, Rosebud, Vanguard 

and Hanna coal regions. These projects contain several million tons of coal resources. West of there, Anadarko coal projects 

include Continental Divide, Red Rim, Bolten Ranch, Creston, Cherokee, Bitter Creek and Salt Wells. Within these areas are several hundred million tons of additional coal resources. Further west are the active underground trona mines near Green 

River. Each of these mines contains multiple millions of tons of trona. A transmission line across these mines could sterilize the 

trona beneath the line thus negatively impacting the mine operator as well as the mineral owner. Anadarko's status as a fee 

mineral and surface owner and affected properties are noted because management decisions made on federal lands can and 

do impact current and future activities on fee lands.

CoSe

BLM's authorization, should it occur prior to completion of fee mineral and surface owner access agreements, will directly 

affect those entities in a disadvantaged manner. In this instance, Proponent negotiations with fee interest owners may be negatively influenced by virtue of the BLM granting ROW authorization. BLM states that it will analyze the circumstances under which private lands would be condemned, and what the effects would be (Footnote 3). However, we are unable to find this 

discussion in the document. Clearly, the specter that BLM would issue ROWs prior to completion of access agreements for 

private interests may exacerbate the need for condemnations. This very important aspect of authorizing the Project must be 

discussed in the document as well as providing an opportunity for public comment on that language in draft form.

Co

Additional information is needed regarding the economic impact resulting from the loss of opportunity to develop fee minerals caused by the Project. The document aims at resolving the document's lack of economic analysis on the impact to mineral resources by suggesting that the Proponents incorporate mitigation measure MN-2 into their Environmental Protection Measures (EPMs) and apply it Project-wide (Footnote 4). MN-2 states that, "An accounting of damages will be conducted by the Proponents to current operators to determine the potential loss of mineral resources. There may be mining claims under 

the 1872 Mining Law that would have precedence over the Project. Similarly, federal and state mineral lease agreements provide rights to lessees that could interfere with the Gateway West Project. The Proponents will resolve mineral claim and lease agreements prior to Project initiation, as with site access agreements on private property." Anadarko requests MN-2 be made a condition of approval for the ROW and furthermore, it should clearly state the "accounting of damages" should apply to all potentially recoverable minerals on federal, state and fee mineral resources and not just current mine operators. Resolution 

of private property mineral and access agreements should also be completed prior to authorizing BLM ROWs. Alternatively, 

the ROW grant should be conditioned to require the resolution of private property mineral and access agreements prior to 

initiation of construction activities.

No

Due to safety reasons, there could be no mining directly beneath the lands covered by the transmission lines and on those lands within a certain distance of the ROW, sterilizing even more coal. Oftentimes, blasting activities are required to produce

coal and other minerals. However, blasting would not be able to occur under or near the transmission lines further severing 

Anadarko's access to its coal resources. If the ROW cuts through the middle of a mine site, it may sever mine operations thus increasing mining costs. For underground mines, the Project would sterilize the coal directly beneath the towers as well as a 

distance laterally. Therefore, an un-mined column must be left in place that is larger than the actual footprint of the tower. If 

mining were to occur via longwall methods, mine operators would probably be unable to leave columns beneath all of the 

towers. Additionally, due to the nature of longwall mining, the ground would most likely experience subsidence. Given this, 

longwall mining, a sometimes more cost effective mining method, would probably be impossible in the vicinity of the Project. BLM must fully take into consideration the economic loss the Project will have on the fee mineral holdings within the 

checkerboard given the likelihood that these holdings would be used for energy projects during the life of the Project.

Co

100312 WYOMING 

WILDLIFE FEDERATION

•The stipulations intended to protect wildlife need to be strictly enforced. Se

•Incorporate the most current and relevant scientific data that analyzes wildlife and fisheries impacts related to development. The 

refl

•Follow WGFD Wind Recommendations. The •Establish an action plan for the potential loss of existing big game migration corridors. No

com

•Provide an environmental compliance plan that clearly states how the BLM will enforce monitoring, environmental compliance 

and remediation on wildlife and fisheries affected by wind development in the project area. The environmental compliance plan 

should be developed on a landscape scale to determine management options for wildlife and aquatic species.

Noeac

covwin

•Vegetation monitoring should be part of the development and production phase. BLM must effectively protect habitats at risk from impacts associated with the proposed development.

No
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100312 WYOMING 

WILDLIFE FEDERATION (cont.)

All monitoring must be done by qualified personnel according to rigorous and standardized science-based protocols. Wildlife 

data collected during monitoring make up a large proportion of the decision-making information used by the agency and the project proponent for designing and adjusting mitigation measures and it is therefore essential that these data are accurate, reliable, complete, and developed according to rigorous protocols. Inappropriate study designs, insufficient or poorly timed data collection, or poorly skilled field personnel may result in skewed, biased, and unreliable findings. This is especially 

problematic in light of the weakening population trends for greater sage-grouse, mule deer, pronghorn, and golden eagles 

across multiple regions, trends which dictate close assessment of population viability and conservation measure success. It is 

also paramount that there is full disclosure of mortality and other negative impacts to the BLM and other cooperating agencies.

We suggest the development of a monitoring and mitigation matrix for wildlife, wildlife habitat, fisheries, aquatic habitat, and 

stream changes with thresholds and indicators. Further, we suggest the development of an action plan to guide efforts once the thresholds are met. One example of such is found in the Record of Decision & Final Supplemental Environmental Impact Statement for the Pinedale Anticline Oil and Gas Exploration and Development Project, Appendix B. Some framework for defining impacts is necessary.

Sefor by 

A baseline water quality monitoring and analysis plan must be developed. It should include a schedule for baseline surveys and data gathering prior to construction, during and after.

On req(se

Limiting human disturbance and activity during critical big game seasons will help mitigate impacts, but if and only if they are 

enforced and no exceptions are allowed.

Se

All roads and project activities should be located as far from riparian and wetland communities as possible. SeReclaim vegetation sites by using re-seeding techniques that promote non-invasive vegetation production. Thi

Se3.8

In order to address the concerns associated with this large work force we recommend the following actions. 

Any man camps that are created should be fenced to exclude livestock and wildlife. These fences will minimize conflict and help to protect wildlife and livestock.

Wopriv

In order to address the concerns associated with this large work force we recommend the following actions. 

Employees should be required to participate in an Environmental Awareness Training Program. Trespass laws, laws on public lands, and current Wyoming Game and Fish regulations should be covered for the benefit of employees new to the area.

COnoxtrai

In order to address the concerns associated with this large work force we recommend the following actions. •Mandatory 

reprimand should be used in cases of employees convicted of poaching or harassing wildlife while employed by the company, its contractors, or subcontractors

The 

In order to address the concerns associated with this large work force we recommend the following actions. •Guns should be 

prohibited on any job site to prevent harassment or poaching of wildlife.

The 

In order to address the concerns associated with this large work force we recommend the following actions. •Efforts should be 

made to bus construction crews to the work site to reduce overall vehicular traffic. This effort will reduce disturbance of wildlife in the area and reduce the risk of vehicle collisions with wildlife.

Se

In order to address the concerns associated with this large work force we recommend the following actions. •Dogs should be 

prohibited on any job site to prevent harassment of wildlife.

The 

When considering the siting of GWW environmental and social impacts should be avoided to the greatest extent possible. The 

transmission line should be developed within existing corridors and co-located with other transmission lines when possible. 

Additionally transmission lines should be sited in areas where disturbance has already occurred and avoid construction in 

“green spaces.” Areas that should be avoided include crucial big game winter ranges/severe winter ranges, migration 

corridors, Greater Sage-grouse core areas, National Wild, Scenic, and Recreational Rivers, wetlands, National Historic and National Scenic trails, and cutthroat trout habitat. Damages should be minimized and mitigated using best management practices, cooperation with landowners, and innovative technologies.

Thethe 

Wyoming Wildlife Federation’s siting preference follows: •Segment 1 – 1E-C

YoSeconpro

Wyoming Wildlife Federation’s siting preference follows: •Segment 2 – Proposed

Yosup

Wyoming Wildlife Federation’s siting preference follows: •Segment 3 – Proposed •Segment 4 – 4F/4A

Yosup
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100312 WYOMING 

WILDLIFE FEDERATION (cont.)

Appendix C: Revised Environmental Protection Measured Plans outlines the Proponent’s protection measures to minimize traffic and transportation impacts. TR-14 calls for “(r)oads 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.” To minimize the mitigation needed for these temporary roads, reduce reclamation costs and to minimize the impact of 

the temporary road WWF would like to encourage the proponent to implement disappearing roads technology for all temporary roads. In 2008 a team of University of Wyoming students won the “Disappearing Roads Competition” for their layered mat, roll-out 

road system (Wyoming 2008). The roll-out road is designed with synthetic boards and developed by Heartland Biocomposites. 

The mats can reduce ground and habitat disruption by up to 88 percent. If these mats are unavailable WWF would like to 

encourage the Proponent to take advantage of other temporary road mats. These temporary roads can be laid down on top of the sagebrush steppe and removed when the road is no longer needed. As opposed to creating temporary gravel roads which require the removal of vegetation, road creation, and then reclamation these new roads technology do not disturb the root 

system of the sagebrush allowing for quicker recovery of the sagebrush steppe.

Temespfor In asecgenin u

WWF encourages the Proponent and Agencies to consider sportsmen and the sporting heritage by avoiding blasting in areas 

when they are open to hunting as well as during the first week prior to the hunting season. Wyoming sportsmen and women value the hunting opportunity provided throughout the state and these values are at risk when noise from blasting temporarily 

relocates big game. In order to protect the rights of sportsmen who hunt in these areas WWF recommends halting construction on public lands during hunting season within affected hunt areas. The disturbance caused by construction will negatively affect sportsmen’s hunting experience and could possibly lead to lower success rates.

Givclohun

In order to address the concerns associated with this large work force we recommend the following actions. •Reclamation of 

roads associated strictly with construction should begin immediately after completion of construction; reclamation being complete within five years.

A rsubMo

In order to address the concerns associated with this large work force we recommend the following actions. •Decontamination 

of equipment should occur before work begins around or near water, as well as when construction equipment leaves the area.

No

In order to address the concerns associated with this large work force we recommend the following actions. •Areas disturbed 

during construction that contribute sediment to surface waters should be re-vegetated as quickly as possible to ensure water quality.

Nopla

In order to address the concerns associated with this large work force we recommend the following actions. •Riparian vegetation should be protected by leaving a 200 foot buffer on each side of streams and water courses. The buffer should be expanded to 500 feet in the case of waterways with sensitive aquatic species.

Norela

In order to address the concerns associated with this large work force we recommend the following actions. •Equipment should be serviced and fueled away from riparian areas.

Se

In order to address the concerns associated with this large work force we recommend the following actions. •All lines should 

be constructed in a raptor proof manner, ensuring the safety of raptors throughout the area.

Nome

Appendix C-2 Framework Reclamation Plan for Construction Activities outlines the proponent’s outline their plan to reduce 

erosion, sedimentation, dust control, and prevention of noxious or invasive weeds. Within that plan the proponent calls for certified weed free straw or hay to be used as a BMP to control erosion, dust, and control establishment of noxious or invasive

weeds. WWF would encourage the Agencies and Proponents to consider using new straw technologies, SuperStraw. This 

innovative product is produced from beetle kill pine and spruce as well as Sudden Aspen Decline aspen; free of seeds, chemicals, and dust (Sleeping Giant Industries 2011).

Thi

In order to address the concerns associated with this large work force we recommend the following actions. •Shuttles/busses 

should be used whenever possible to reduce vehicle traffic in the area. Vehicle traffic and increased human interaction can 

result in increased movement in mule deer and increased physiological stress (Group 2007). Interactions should be minimized whenever possible.

A t

In order to address the concerns associated with this large work force we recommend the following actions. •No construction 

activity should take place from November 15 – April 30 in big game crucial winter range to minimize impacts to wintering wildlife.

No

In order to address the concerns associated with this large work force we recommend the following actions. 

•Construction activity should not take place during hunting season and one week prior to hunting season to avoid altering the 

recreation opportunity.

Givclohun

According to the BLM’s Wyoming National Environmental Policy Act Hotsheet several wind energy facilities are being 

proposed for BLM lands along the GWW route and were not disclosed in the Draft EIS. In the Final EIS WWF would 

recommend adding the Sand Creek wind project in Wyoming’s Shirley Basin, which is to be tied into the GWW transmission line. (BLM 2011)

Tha
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100312 WYOMING 

WILDLIFE FEDERATION (cont.)

As part of mitigation efforts the proponents are proposing an in-lieu fee payment for unavoidable impacts to waters. Additionally, the proponents are considering a combination of in-lieu fee and permittee-responsible mitigation including 

preservation, restoration, creation of new/existing wetlands. WWF has been recognized as a suitable sponsor for an in-lieu 

free program and would like to be considered as a partner in this endeavor.

No

GWW’s proposed routes include important Greater sage-grouse habitat in Wyoming. WWF is concerned that the GWW 

transmission line will cause adverse impacts to sage-grouse if improperly sited and should avoid leks, nearby nesting and brood-rearing habitats, and winter habitat. The FEIS should take into account current sage-grouse habitats not just active leks

as the DEIS considers. •Transmission line design should bury lines if possible and when not possible lines should run a minimum of 0.6 miles from the 

perimeter of occupied Greater(?) Sage Grouse leks. •Timing stipulations should be extended from the proposed March 1 to May 15 – to allow for nesting and early brood rearing. •Reclamation should reestablish grasses, forbs, and shrubs during the interim and final reclamation for the benefit of sage 

grouse.

Reinforesin s

100313 HENRY & ROSE 

HORNBACHER 

My comments pertain to Idaho Power's powerline across my irrigated farm in Power County, segment 5. A transmission line across my farm will have a huge negative impact on our operation. Is Idaho Power willing to compensate us and make us whole on all these issues? (1) Aerial applications cannot operate around power lines. (2) GPS systems on our equipment and pivot electronics will malfunction. (3) Market value of the whole farm will be negatively impacted. (4) Farm ground underneath the power line will be permanently out of production.

Noat tthis 

 cross elsewhere besides on our irrigation farm. No

sup

100314 THE NATURE 

CONSERVANCY

Segment 4 (southern-most route, Feasible Alternative – 4B,C & 4C,E) crosses through the Bear River and Green River Basins 

Wyoming Bird Conservation Partnership priority wetland areas, two of only nine in Wyoming. The Conservancy recommends that this route be avoided.

Yosup

Segment 1EB crosses through the Shirley Basin Wyoming Bird Conservation Partnership priority wetland area, one of only 

nine in Wyoming. The Conservancy recommends that this route be avoided.

Nocurfrom 

Segment 4 (Feasible Alternative – 4B,D & 4D,E) crosses through the Bear River and Green River Basins Wyoming Bird 

Conservation Partnership priority wetland areas, two of only nine in Wyoming. The Conservancy recommends that this route 

be avoided.

Yosup

Alternative 9E in Owyhee County crosses through a 75% breeding density area. The Conservancy recommends that this route be rejected.

Yo

Alternative 7H, outside of Oakley, crosses through the center of a 50% breeding density area. Given the significant importance 

of this habitat to the long-term survival of sage-grouse, the Conservancy recommends this route be rejected.

Yoaltethe Ch

Alternative 7I, east of Rogerson, crosses through the center of a large 25% breeding density area, which represents the “best 

of the best “ of sage-grouse breeding habitat. The Conservancy strongly recommends this route be rejected.

No

the conconpro

As best as we can determine, the Sage-Grouse Breeding Bird Density Map (Doherty et al 2010) and data were not 

incorporated into the DEIS route analysis, several of the alternate routes would impact 25%, 50% and 75% breeding density 

areas. These alternative routes include: Alternative 5B crosses through a 75% breeding density area. The Conservancy 

recommends that this route be rejected.

The the an be 

We support routes, such as Segment 2, which follow the Governor’s designated Executive Order two-mile wide transmission 

line corridor. Concentrating transmission lines through this specific portion of Core Population Areas will help to minimize 

impacts to Core Population Areas and other natural resources.

Yo
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100314 THE NATURE 

CONSERVANCY (cont.)

The Density Disturbance Calculator appears to drive development toward pristine or undisturbed landscapes. The Density Disturbance Calculator (DDC) discussed in Appendix J is described as “a tool designed to measure habitat loss within the Key Habitat/Core Area. “ The concept appears to be focused on whether the amount of disturbance within the project footprint (defined 

by a 4 mile buffer around the right of way) would disturb greater or less than 5% of the "suitable habitat" within the project footprint. 

Our primary concern with this approach is that it seems to drive the siting of infrastructure development towards pristine landscapes 

and penalizes development that piggybacks with existing infrastructure, such as co-locating transmission lines in a highway corridor. 

Furthermore, it appears that projects with a larger impact and footprint in sage-grouse habitat could be viewed favorably over projects with a smaller footprint based on this calculator. As an example, this approach would penalize a project that impacted only 10 acres if there were only 20 acres of suitable habitat, as that would be 50% of available habitat, but a project that impacted 100 acres out of 2000 acres of suitable habitat would be acceptable, because that would represent 5% of suitable habitat. This would 

result in more acres disturbed, even though it results in a lower “density of disturbance.“ The DDC appears to encourage development in undeveloped habitat just to stay below the 5% density disturbance threshold.

Thi

sagthe 

I. The Mitigation Hierarchy Provides a Sound Framework for Analyzing the Project. For the most part, the proposed route for the Project in Idaho follows a path that would minimize impacts to the most important sagegrouse habitats; this is not the case in Wyoming, where the proposed route crosses 184 miles of core sage grouse habitat. That is 

also not the case with several of the Alternative alignments proposed in Idaho which cross through highly sensitive sage-grouse

habitat (see our specific comments on route selection at the end of this document). It is clear that significant, unavoidable adverse impacts to sage-grouse will occur from the proposed project, yet no mitigation measures compensating for these impacts are 

proposed in the DEIS. Thus, our primary focus with these comments is requesting additional opportunity for public comment on 

compensatory mitigation measures prior to the final EIS, and to provide guidance on key elements that should be incorporated into a 

successful compensatory mitigation plan. To be clear, our goal is a clear explanation of the technical analyses and policies that will guide how compensatory mitigation will be used to offset Project impacts.

A dand 

The DEIS Omits Essential Sage-Grouse Habitat Impact Analyses and Compensatory Mitigation Measures. Despite the central 

importance that the DEIS accords to compensatory mitigation, the DEIS was released to the public with no compensatory mitigation measures and without disclosure of the key technical analyses that the BLM intends to rely upon in determining the appropriate scale of such mitigation. To be clear, we are not requesting that a final compensatory mitigation plan be made available for public comment prior to the FEIS. Rather, we seek a clear explanation of the technical analyses and policies that will guide how compensatory mitigation will be used to offset Project impacts.

A dpub3.1

BLM Should Provide Opportunity for Additional Public Comment on Compensatory Mitigation Prior to the Preparation of a Final EIS. The The EIS should address the major policies that will guide the development of compensatory mitigation measures. The 

and mitsou(a wadeencclomitvalaffe

Determine which focal species, natural communities, or representative biological targets will be the subject of compensatory 

mitigation measures. The EIS should expressly address BLM’s rationale for selecting the particular species or targets for which

compensatory mitigation measures are developed. For instance, if compensatory mitigation is limited to sage-grouse, the 

document should explain why the BLM did not develop mitigation alternatives for other species and values.

The neecomfram

Establish clear and measureable objectives for compensatory mitigation. It is imperative that the EIS state clear objectives for 

compensatory mitigation, including but not limited to describing the extent to which Project impacts will be offset by mitigation actions.

A dpub3.1

Provide a common currency and accounting methodology. A common unit of measurement would be established for describing and tracking both the project impacts and the benefits of any compensatory mitigation actions. This unit of measurement can be a physical unit such as “acres impacted “ or more specifically “acres of summer brood rearing habitat impacted “ or “habitat units “ lost.

An pub

Base the scope of compensatory mitigation on a full evaluation of project impacts. First, given the status of sage-grouse, 

impacts to all sage-grouse habitat – including R1-R3 habitat in Idaho – should be mitigated. Second, the EIS should address 

the full range of effects in setting the objectives for mitigation.

A dpuband 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100314 THE NATURE 

CONSERVANCY (cont.)

Use landscape-scale conservation planning to target mitigation actions. An 

pub

Identify mitigation methods. The EIS should identify the categories of mitigation projects or strategies that will be included in 

the mitigation plan for the Project, and specifically the compensatory mitigation elements. We recommend that the BLM 

consider a portfolio of sage-grouse habitat protection, enhancement, and restoration that provide long-term habitat benefits for 

sage-grouse.

A dpub3.1

Address offset duration, monitoring, and management. The EIS should include provisions for the continued monitoring, operations and maintenance of all mitigation undertaken to address project impacts.

Reana

Address factors affecting Sage-grouse mitigation effectiveness. Consider probability of success (likelihood that a mitigation 

action will deliver the expected conservation benefits). Consider time lag to conservation maturity. This is evaluated as the 

length of time for a mitigation action to deliver conservation at maturity level (or ecological state) similar to that lost at the 

impact site. (Footnote 46)

A dpuband 

Project routes should avoid areas of high biological importance. Route selection is the most important factor in determining the 

impact of the Project on sage-grouse. The Conservancy recommends avoidance of areas that have high biological value or are 

considered priority habitat when determining the final route selection. Of particular concern, we note that several of the 

alternative routes would pass through crucial breeding areas, or breeding density areas as defined by Doherty et al (2010). 

The Sage-Grouse Breeding Bird Density Map (Doherty et al 2010), which was coordinated and funded by BLM, provides a 

spatially explicit map of identifiable population concentrations, or priority habitat, for sage-grouse. These breeding density areas are highly important to the conservation of sage-grouse populations range-wide. We note that this important analysis was not referenced in the DEIS and recommend it as crucial information for inclusion in the final DEIS.

The basSadefDeBLhas 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100315 MARGENE TOMKINSON 

ANDERSON, BONNIE ANDERSON, AM (), CHARLIE BARNARD, LINDA BARNARD, JACKIE BRADY, JERRY W BRADY, HILL BRODERICK, ELIZABETH FILLMORE, LAWRENCE J FILLMORE, EDDY HANSEN, REBECCA HANSEN, LYNN HEYETER, CARL JONES, JANIS JONES, J. KINLY, GAYLE KNASS, KRESS, ANITA KRESS, EUGENE & GAYLE KRESS, DEBRA LEI, R SCOTT LISH, JANET LISH, KIRSTEN LOWA, SAMANTHA LOWDER, WILL LOWER, LUCAS MCCARGUE, BRITTANY MCCARGUE, LORRAINE MCHARGUE, SUSAN MONK, MELVIN MORRIS, KAILA MORRIS, KINDRA MUNK, CURTIS MUNK, ARTHUR GENE NELSON, RONALD NELSON, RONALD NELSON, LORI NELSON, R K NELSON, VERN NELSON, KATIE NELSON, JILL NELSON, JOLENE NELSON, LESLIE NELSON, BRAD R., SHONEL RADFORD, DAN E. RALPHS, DORIS RALPLNE, BART RALPLNE, ROBERT ROCKFORD, STAN SCHMIDT, JANICE SCHMIDT, RON SPILLETT, LYNN SPILLETT, CAROL SPILLETT, JUAN SPILLETT, JAMES SPILLETT, JOAN STEIDLEY, PERRY STEIDLEY JR, STANFORD H. TAYSOM, MONA TAYSOM, JASON TOMKINSON, LORI TOMKINSON, JANET TURLEY, ARTHUR AUSTIN TURLEY, JIM WOODRICH + Several Illegible names 

This letter concerns the Idaho Power/Rocky Mountain Gateway West Project which intends (as their preferred route) to bring two 500 KV power lines from Wyoming down through the Rockland East Fork Canyon (Deep Creek Mountain Range) and the campgrounds at the head of that canyon. The lines would then intersect the Rockland Valley going both North-South and East-West. We the following persons strongly object to these routes and feel that because of their locations, size, and numbers, they will have an extremely detrimental environmental, economic and aesthetic impact on our community. We feel it is an unfair burden for the town and citizens of the Rockland area to bear. It will greatly affect the recreational value and experience of East Fork Canyon and the campground enjoyed by ourselves and others from all over this side of the state.

YoThsprtha
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100316 KELLY BLUE, BRIAN 

BURG, JAMES BURNETT, NATASIA DIERS, ZEM HOPKINS, ROBERT REETZ, ERIC RUDY, TONY TOMASSI 

This letter is to ask that the Gateway West Transmission Line Project be constructed through the existing Corridor in section 4, north of the City of Kemmerer.

YoPro

100318 JAMES RICHARD 

WARD 

My preferred route between Populus & Midpoint is segment #6 because: 

1. High voltage lines already exist there & could be upgraded to accommodate 500 KV lines. 2. if this route were used there would be relatively few new impacts to private holdings or to new environmental concerns. 3. It seems to be the shortest & most direct route 4. Since it is the shortest & most direct route it seems like it would be most economical for the power companies to upgrade 

existing facilities to move the power. 5. This route #6 would have the least impacts to private property investments - i.e. farming, pivot irrigation dairies, feedlots, viewsheds, public health.

YoSeand 

 If segment 6 cannot be utilized my second preferred route is segment 7i (the southern route through Cassia County. for the 

following reasons: 1 - This route is mostly on Federal lands with few impacts to private land or private land investments. 2 - Even though this route is a little longer it crosses a lot of gentle terrain. for cheaper construction costs., private land

mitigation costs would be small. 3 - There is not a lot of public opposition to this route. The power companies could buy a lot of "good will" with the public if they chose this route, or even more if the chose route #6.

Yo

100319 BONNIE ANDERSON As a resident and landowner in the East Fork area of the Rockland Valley, I would prefer that the line was run to the south with 

the alternate sub station at Rogerson, instead of Cedar Hill or through the Fort Hall Indian Reservation to Borah.

Yo

100320 LINDA LEE 

BARNARD 

Our farm is 100% against this project since it has no benefit to us. We think it is destructive to our land and our Rockland 

Valley overall.

NoPre

100321 ROBERT LADEAN 

BARNARD 

Our farm is in Segment 7 on your maps between East Fork and Sand Hollow Roads. We will be in line to get multiple towers 

on our farm land on the "MILE RADIUS" projection. We bluntly do not want to towers on our land nor do we want anything to do with this project.

Yokno

100322 KAREN STEENHOF The rationale for disallowing all new transmission lines in the Birds of Prey Resource Management Plan (RMP) was unclear 

and was not based on the data we had collected for BLM. It is important to remember that the NCA was never intended to be managed as a wilderness area. Legislation that established the NCA identified the main goal as enhancing raptor nesting 

populations. A properly routed transmission line would be consistent with that goal, particularly when it averts an alternativethat could have devastating effects on another wildlife resource. I support amending the Birds of Prey RMP to allow new transmission lines as long as they follow existing roads and power line rights of ways.

The Alteis p

The DEIS did not accurately show the route between Node 9P and Node 9w that was proposed by the Owyhee Task Force and submitted by the Owyhee County Commissioners at the end of the scoping period in 2009. This portion of 9D should have 

been at least a half mile east of the private homes in Eagle View Estates

Adrouas 

In 2010, the BLM developed additional alternatives for Segment 8 that overlapped other portions of Route 9D. This occurred 

after the scoping process and after we had been told there had to be a different route for each alternative. During the process

of developing Alternative 9D, the BLM never informed us about serious conflicts with the non-motorized area near the Cove Recreation site.

Me

The proposed route is within a few meters of recently used Golden Eagle nests in the San Sebastian nesting territory. In addition, the mouth of Sinker Creek has some of the most important riparian habitat within the Morley Nelson Snake River 

Birds of Prey National Conservation Area (NCA). There are high densities of nesting Long-eared Owls, and there has been at least one sighting of Bighorn Sheep near the mouth of Sinker Creek in recent years.

Rasurlim

Areon 

und

The overriding question is whether Idaho Power has adequately justified the need for this project. The Gateway transmission line was not identified in Idaho Power’s 10-year plan. The need for the line appears to be based on projections that are outdated.

Ad

The FEIS should analyze whether the Gateway West Project will facilitate access to clean domestic energy that will reduce 

greenhouse gas emissions and whether there are simpler, alternatives to meet this goal with fewer environmental impacts.

AnSe
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100322 KAREN STEENHOF 

(cont.)

Any analysis of impacts on raptors should be based on “nesting territories” rather than individual nests because any impacts 

will be on nesting pairs occupying territories rather than nest structures. ...Eagles and most other raptors typically use morethan one nest within a nesting territory. It is unclear whether the counts of “nests” reported throughout the DEIS included multiple nests within individual territories. If they did, the tally is erroneous and misleading.

Althimpdetpaifor 

Our research showed that transmission line towers provided both new and alternative nesting substrate for raptors and ravens. The DEIS makes no mention of providing artificial nesting platforms on towers as a mitigation tool.

Usrapthe Avi

Table 3.10-1 refers to both “known” nests and “active” nests, but neither term is defined anywhere in the DEIS. The term 

“active”(which is used extensively throughout the DEIS but in different contexts) is an ambiguous and inappropriate term (see 

Steenhof and Newton 2007) that usually but not always refers to a nest with eggs or young during a particular breeding season (Postupalsky 1974). Technically, a nest cannot be “active” outside a breeding season. Thus, it is likely that the data reported in Appendix D.10-2 actually represent historical nests that contained eggs or young at least once over an unspecified 

time period. The FEIS should report the time period (beginning and ending years) represented by the databases used for the analysis. The BLM and Idaho Department of Fish and Game conducted extensive raptor inventories within the Project Area 

during 2011, so the FEIS will need to incorporate this new information.

Declelocact

The analysis of impacts on raptors in the DEIS is based mainly on the number of “active” nests within 1 mile of proposed 

routes, and the DEIS implies that impacts on raptors will be negative. Using 1 mile as a metric to evaluate effects is arbitrary 

and meaningless. Whether a transmission line will adversely affect a nesting raptor depends on the species of raptor and the 

topography surrounding the nest. The concluding paragraphs on raptors in Section 3.10.2.3 are very misleading in comparing 

the number of raptor “nests” that would be “impacted” by the various alternative routes. For example, the wording on pages 

3.10-89 and 3.10-95 states that all known nests near alternatives for Segments 8 and 9 will be “impacted.” The implication is 

that any “impacts” will be negative is also misleading. The wording about Segments 8 and 9 in Tables 3.10-37 and 3.10-42 is 

more accurate in that it merely reports the number of “currently documented raptor nests” within one mile of each alternative 

and does not imply any impacts (or that surveys were complete).

ChrapbenwildgroBeindtheto massare wit

The DEIS correctly recognizes that “construction activities could cause [raptor] nest failure or abandonment (page 3.10-34).” Timing restrictions on construction near raptor nests should apply to the complete nesting season (courtship through postfledging). The post-fledging period is one of the most critical for raptors. It would be inappropriate to lift protection as soon as young fledge. Guidelines PRC-13 and PRC-19 (page 3.10-35) should be modified to include the post-fledging season (page 

3.10-35). It is also important to avoid construction in occupied territories just prior to egg-laying, when raptors are especially 

sensitive to disturbance. Technically it will be impossible to find an “active” nest before eggs are laid. PRC- 14 and PRC-20 

need to be clarified: pre-construction surveys prior to the nesting season may not be conclusive depending on their timing. References to “appropriate nesting time periods” (p. 3.10-36) in the DEIS are ambiguous. The FEIS should include information on the nesting chronology (earliest nest initiation dates and latest fledging dates) of all raptor species throughout the project 

area to ensure that adequate protection occurs.

Apanaor r

Page 3.11-57 cites research by Coates and Delehanty that increased raven numbers could result in increased predation on 

prey species of black-footed ferrets, but the DEIS fails to cite findings (Coates et al. 2008) that documented ravens as the most common nest predator of Greater sage-grouse in northeastern Nevada. Coates et al. (2008) found that ravens appear to cue in on the movements of grouse to and from nests. Female sage-grouse are able to escape direct predation but are unable 

to defend nests successfully, especially when confronted with more than one raven. The presence of ravens may inhibit female grouse from leaving their nests to forage. Nest failure is thought to be an important factor in sage-grouse population declines, and nest predation appears to be the primary cause of nest failure for Greater Sage-grouse. The FEIS should 

incorporate these data in the analysis.

Rebee

The DEIS notes concerns about “consolidation” of raptors and ravens, but it does not address the fact that populations 

associated with transmission lines will not only concentrate on transmission line towers but will increase over time, as offspring 

of productive pairs colonize transmission towers (see Table 1 and Figure 3 in Steenhof et al. 1993). Increases will be 

associated not only with an increase in potential perch sites (page 3.11-68) but also an increase in nesting opportunities.

A calodatonl
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100322 KAREN STEENHOF 

(cont.)

Pages 3.11-57 and 3.11-69 cite secondary literature (Boarman and Heinrich 1999—misspelled as Heinrick on both pages) on 

distances moved by ravens. The DEIS should report the primary sources of these data: Bruggers 1988 for Minnesota, Mahringer 1970 for Michigan, Linz et al. 1992 for California, and most importantly Engel and Young 1992 for southwestern 

Idaho. Engel and Young’s radio telemetry studies revealed that ravens moved an average of 7 km (about 4 and a half miles) and as far as 65 km (about 40 miles) from transmission line roosts in each day. Given that ravens forage several miles from their nests and roosts, sage-grouse nests within 15 miles of new transmission lines will be vulnerable to ravens that roost on transmission lines. Small buffers around leks will be inadequate to protect sage-grouse.

The inddoenumthe En

Page 3.11-58 mentions that anti-perch devices will be used on some structures to reduce raven and raptor use. Most perch 

deterrents tried to date have had limited effectiveness. The FEIS should specify the types of devices that will be used, and it

should provide evidence for how effective they will be.

Texmindev

The DEIS has not provided convincing evidence that two separated transmission lines are needed in southwestern Idaho. AdThe DEIS should have considered an alternative with a single route in southwestern Idaho. Furthermore, the process of 

developing alternatives in southwestern Idaho during the scoping process was flawed.

Nomerou

I support the Owyhee Task Force’s new proposed modifications to 9D that will avoid that non-motorized area.... The DEIS did not accurately show the route between Node 9P and Node 9w that was proposed by the Owyhee Task Force and submitted by the Owyhee County Commissioners at the end of the scoping period in 2009. This portion of 9D should have been at least 

a half mile east of the private homes in Eagle View Estates. However, my preference is to have 9D follow the Task Force’s 

original proposed route from node 9r5, through nodes 8r5, 9t, and 9v to node 11 (now shown in the DEIS as part of Alternative 8).

Adbot

Alternative 9E, which runs south of Highway 78, is unacceptable YoAlternative 9G which crosses the Snake River at the Mouth of Sinker Creek is unacceptable YoAlternative 9 is unacceptable YoThe DEIS failed to incorporate important published and unpublished data about raptors, habitat, and prey species in the NCA. We 

pro

Unfortunately the proposed alternatives for Segment 8 that run through the NCA do not follow existing roads or power line 

rights of way. Parts of Alternative 8 and 8E run parallel to the existing 500-kV transmission line, but we have been told that 

there must be a 1500-foot separation between 500-kV lines. This would require construction of a new road approximately 0.25 

miles from the existing road. The DEIS recognizes (page 3.10-41) that “the transmission line and Project roads (8 feet wide 

during operations) would fragment habitat.” As stated on pages 3.10-36-37 of the DEIS, “Edge effects brought about by 

vegetation removal could lead to a change in plant species composition, potentially lowering the quality of habitat for raptors or their prey.” Additional habitat fragmentation in a Conservation Area that has suffered from extensive fragmentation over the last 30 years cannot be allowed. Fragmentation will affect more nesting raptors than those that nest within a mile of the transmission line.

Nowo

The raptor analysis in the DEIS refers to specific areas in Wyoming (page 3.10-48), but references to the Morley Nelson NCA are conspicuously absent. Chapter 3.10 even fails to mention the two most important prey species of raptors in the Morley 

Nelson NCA: Piute ground squirrels (Spermophilus mollis) and blacktailed jackrabbits (Lepus californicus). The DEIS mentions the possibility of revegetation on page 3.10-22, but it does not acknowledge the difficulties that have been experienced in 

revegetating areas in a very low precipitation zone where the NCA occurs.

The NCgroundothsursuc

The only alternative identified in the DEIS for Segment 8 that is compatible with the legislation is the original one that runsoutside the NCA (Alternative 8B).

Yo

Page 3.10-34. “Brooding” is a nesting behavior not a life history stage. The Page 3.10-35. The term “occupied” nest appears here for the first time; it is not clear how this differs from an “active” nest. Ch

Su

Pages 3.11-54 through 3.11-58. It is unclear why “impacts that would occur to all species” are under the Black-Footed Ferret 

heading.

Thioccthe wo

Pages 3.11-57 and 3.11-69. No reference is provided for the Golden Eagle hunting ranges reported. RePage 7-12. The citation for Engel et al. 1992 is listed twice. InfoPage 7-40. The link for the reference TetraTech 2009a appears to be broken. Info
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100322 KAREN STEENHOF 

(cont.)

An even bigger concern about routing Segment 8 through the NCA is the proposed crossing near Halverson Bar. The 

transmission line would cross the Snake River at a wide spot in the canyon; towers would be constructed within the canyon 

itself, and wires would run between the canyon walls instead of above them. The crossing, in my opinion, would be 

incompatible with scenic, historical, archaeological, and recreation values in that part of the canyon. The stretch of canyon where the crossing is proposed is the heart of the non-motorized “natural” area and gets extensive recreation use for fishing, 

hiking, horseback riding, and nature appreciation. The scenic impacts would be huge for people who come to come to see and 

photograph the historical cabins and ancient petroglyphs in this stretch of canyon. More importantly, this crossing bisects a 

section of the canyon with one of the highest Prairie Falcon densities in the NCA. Although collision with wires has not been aproblem for raptors on the NCA benchlands, it could be a bigger threat when wires are close to cliff-nesting sites. Young birds

learning to fly and adults engaged in territorial defense and courtship could be far more susceptible to collision—especially when wires are below the cliff face

Nowo

100323 ANDREA ERICKSON 

QUIROZ, LAURA HUBBARD, WILL WHELAN

Contrary to what is stated in the draft, only the Conservation Reserve Program (CRP) is administered by the USDA-Farm 

Services Agency (FSA). The Grassland Reserve Program (GRP) and the Wetland Reserve Program (WRP) are administered 

by the USDA – Natural Resources Conservation Service (NRCS). The Grassland Reserve Program and the Wetland Reserve Program often involve permanent conservation easements. I have attached a copy of the NRCS-CPA-255 for 2009 as an example of a Conservation Easement deed for the Grassland Reserve 

Program.

Ch

100323 RAYMA CATES This comment concerns clarification of the visual impacts to the Public Campground located on State of Idaho land on the East 

Fork of Rock Creek. Recommend including recognizable features from the East Fork Campground in the photograph and 

photographic simulation for KOP 242. A Photographic Simulation is given from Key Observation Point 242 Segment 5 Figure E.2-21b. Key observation point 242 is 

very close to the public campground on the East Fork of Rock Creek. However, the general public is not likely to recognize 

this. It would be more informative if the Key Observation Point and Photographic Simulation showed the visual changes as observed from the East Fork Campground or from the East Fork of Rock Creek. Including the creek in the photo would be 

helpful in documenting the existing visual resource of the stream.

Thi

 Segment 5 Populus to Borah, Figure A-7 and Figure E. 2-6 have an incorrectly labeled road. The road labeled Cutoff Rd. is 

known to the locals as Deeg Road. I checked a topographic map and a Big Sky map of Power County and both label the road 

as Deeg Road

De

 Visual KOP Locations, Segment 5 – IDAHO, Figure E.2-6 shows an enlargement with KOP 241, 242 and 257. It would be 

much easier to recognize the location of these KOPs if streams in the area were shown. There is plenty of room on this enlargement to show these additional features

We and are 

 Figures E.3 -12 (page74) to Figure E.3 -50 (page 112) show Cultural Key Observation Points. It is very hard to determine the 

location of these KOPs. These 38 pages do not have a reference to the route segment they are associated with. They are also 

not in numerical order according to their Key Observation Point. The small map on each page does not usually include any information that would give the general population an idea of the KOP location. There are 10 maps on page 63 (Figure E. 3-1) to 73 (Figure E. 3-11) with very fine print that would have to be closely examined to determine the location of the Cultural 

KOPs.

The fiel2.2 pre

 I am in agreement with Power County that the proponents anticipated need for the Gateway West transmission line was based 

on predictions that have not come true and that this transmission line is thus likely not needed at this time.

No

 Segment 5E to Borah. This route will have the least negative impact because it is shorter than the proposed route and there 

are currently transmission lines already in this area. I agree with Power County that Segement 5E should be the preferred 

route.

Yo

 I am in favor of alternative 5C. Yo I am very concerned about the Proposed route 5. Yo I am also very concerned about alternative 5D Yo I am concerned about Alternative 5A Yo I am concerned about Alternative 5B Yo I endorse the Power and Cassia Counties preferred “Stateline Route” for Segment 7. Yo I prefer Alternative 7B Yo I prefer Alternative 7B to Alternative 7A and the Proposed Segment 7 Yo

tab
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100323 RAYMA CATES 

(cont;d) 

Appendix A, Project Maps are difficult to read. Also, Route Detail Maps are not labeled with route and segment numbers 

adding to public difficulty in understanding the maps and routes. The project maps are printed too small to use efficiently. In order to read the segment numbers and tell the difference between segment 5j and 5i, for example, I have to increase the size on my computer to 200%. When I do this and then try to navigate to other parts of the map, my computer severely slows 

down and has crashed several times. I have been unable to look at the draft on my fairly new lap top due to constant crashes. I have heard similar complaints from other task force members who have tried to use lap tops. 

It is impossible to read many of the details on the printed versions of the draft. This makes the printed version almost useless 

and discriminates against the portion of the public which doesn’t have access to a computer that can handle this disk. 

Even with the ability to increase the size of the print on my computer, some of the routes aren’t clear. For example, even in the 

enlarged area of Appendix A, Figure A-7 Segment 5, Populus to Borah, it is impossible to tell what 5i and 5j refer to. The Route Detail maps are also not labeled with the Segments. Labeling these segments would increase the usability of the 

Route Detail maps greatly. Solution: Divide all maps and figures up or include enlargements so that the printed version is a font size that is usable for the 

public. Divide the project up into more than one disk and ensure that standard computers are able to utilize the disks. Label all 

routes and segments on Route Detail Maps.

AdHopropub

 Many previously undocumented grouse leks were identified and documented in Power County and surrounding areas in the 

spring of 2011 by the Idaho Department of Fish and Game. I was given a copy of the new lek layer for the Arbon Valley area by Fish and Game. In the Power County portion of Arbon Valley I count only 2 leks that were documented prior to 2010. I now count 29 leks in this same area. Many of the new leks are near the proposed segment 5 route between mile 21 and mile 28. 

(In the Pauline area.) Many of the new leks are also near the proposed segment 7 route between mile 21 and mile 28. 

Solution: Include the new lek information in the analysis for the EIS as it is likely to greatly change the current analysis of the 

impact of the proposed segment 5 and proposed segment 7 and perhaps of other alternatives on the grouse population. Also update Figure E. 11-3 in Appendix E with the additional leks [see communication 100302 for referenced lek map]

Lekthe 

 This comment concerns the Grassland Reserve Program (GRP), the Wetland Reserve Program (WRP) and the Conservation 

Reserve Program (CRP) being erroneously grouped together as CRP in 3.18-4...Change the wording of the draft so GRP and WRP are addressed separately from CRP. I also recommend contacting the affected state and/or county USDA Natural 

Resources Conservation Service offices to determine ground in the GRP and WRP program and then analyzing any ground in 

GRP or WRP on a case by case basis.

Ad3.1

 Figure E.2-34a and E.2-34b are both labeled existing landscape of the Rockland and Arbon Valleys. Because the Rockland 

Valley and Arbon Valley are separated by the Deep Creek Mountains the photos of them should be labeled so the viewer can 

identify which valley they are observing. There is currently a transmission line in the Arbon Valley. However, there is not a 

transmission line in the Rockland Valley. Figure E. 2-34a and E. 2034b as labeled could give the erroneous impression that 

there are currently transmission lines in both valleys. Solution: Label existing landscape so the viewer can identify which valley they are viewing

Capho

100324 MILITARY AFFAIRS 

COMMITTEE OF MOUNTAIN HOME, IDAHO

We strongly support the military in Idaho and oppose any impact that might encroach upon the bases or the military training in Idaho. The Mountain Home Training Range that includes airspace in Idaho Oregon and Nevada referred to as the Military 

Operating Area and two drop ranges Sailor Creek and Juniper Butte Ranges are considered some of the best training airspace 

and capability in the United States....The areas around the two training ranges used for dropping training ordinance are extremely vital for military training and therefore vital to our national security. It is imperative that these areas be preserved for 

that purpose and no vertical obstruction impose any limitations on that capability. We are aware that BLM and the Gateway 

West project have worked closely with Mountain Home Air Force Base and the Idaho National Guard to try to adhere to their 

request of their desire to protect their training areas. We strongly support their request

Me

would oppose any changes that would cause an encroachment issue to either of the bases or military training areas in Idaho. Your support of the military and our position is greatly appreciated.

Nored

100325 EUGENE & GAYLE 

KRESS

I wish to express my great concern for the plans to cut through our valley with high voltage power lines, endangering our East 

Fork and South Fork water sources, habitat for deer, elk, fowl, fishing, farming and camping. The proposed route would certianly do this and ruin the irrigation systems, both wheel lines and flooding.

The Ea

It is our desire that the current plans be abandoned and use one of the alternate routes (state line or Fort Hall). As I observe 

the construction of roadways to the new windmills, I can see the damage potential to the terrain. I have seen sharp-tails, pheasants, bald eages and deer as we walk and ride and plead that you would not do this to our beautiful valley. The worth of 

our land would be diminished and farm work hindered. It would be TOO CLOSE to our town and populated area.

Yo

It is our desire that the current plans be abandoned and use one of the alternate routes (state line or Fort Hall). Yo
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100326 WILL BILLINGTON, 

DANIEL BILLINGTON

Alternatives 7I and 7J would result in greater amounts of ground disturbance during construction, operations and maintenance 

that the comparison portions of the Proposed Route. They would also have a greater visual impact to sensitive federal lands. 

Alternatives 7I and 7J would have the potential to impact visitors to the City of Rocks National Reserve as well as local sensitive viewing areas. In addition Alternative Routes 7I and 7J are the only two feasible alternatives to cross into the State of 

Nevada. Most importantly Alternative Routes 7I and 7J would cross more sage-grouse key habitat and cross more nesting 

raptor buffers that the comparison portion of the Proposed Route.

Yotab

As stated in Chapter 2 - Alternatives, page 2-90 and 2-91, Alternatives " 7I and 7J would neither be in conformance with the management direction provided in the Cassia and Wells RMPs and Twin Falls MFP, nor would it be consistent with the 

Sawtooth Forest Plan." These management plan included extensive analysis and public input over many years. To now 

circumvent the findings of these public lands management plans would be an enormous waste of the public/taxpayers' time, effort and financial resources.

AlteHocondro

On page 2-91 first paragraph regarding Alternative 7J..."Local landowners opposed the Proposed Route between Populus and 

Cedar Hill..." I would like to clarify that not all local landowners are opposed to this route. It appears the Twin Falls County 

Commissioners were reacting to a very small, vocal and select constituency.

No

Chapter 3 -- Affected Environment and Environmental Consequences, page 3.11-63 Both Alternative 7I and 7J cross sage 

grouse leks on property my family owns. Initial construction of the proposed line, permanent placement and continued routine 

maintenance of the line would increase detrimental impacts to the greater sage-grouse through collision/electrocutions, consolidation of predatory birds along powerlines, lower recruitment rates newar lines, habitat fragmentation, degradation of habitat due to spread of invasive plant species, impacts resulting from the line's electromagnetic fields and direct loss of habitat.

AlteHocondro

Most importantly Alternative Routes 7I and 7J would cross more sage-grouse key habitat and cross more nesting raptor 

buffers that the comparison portion of the Proposed Route.

AlteHocondro

Alternatives 7I and 7J would result in greater amounts of ground disturbance during construction, operations and maintenance 

that the comparison portions of the Proposed Route. They would also have a greater visual impact to sensitive federal lands. 

Alternatives 7I and 7J would have the potential to impact visitors to the City of Rocks National Reserve as well as local sensitive viewing areas

AlteHocondro

There are an enormous number of sage-grouse leks located within the Alternative Routes 7I and 7J. With the currently proposed wind power generators located on China Mountain, four separate sites near Rogerson (Jack's Ranch), and the proposed wind generators on Gollher mountain in Nevada located approximately 10 miles from the southern point of Alternative Route 7J we will be whittling away at significant habitats of TES. It becomes cumulative and the end result will bedevastating.

AlteHocondro

I support the Proposed Route and thank you for providing the informative public meetings. Yo

sup

100327 VICTORIA 

HOLLOWAY BERGLUND 

I am writing in support of the proposed Segment 8 and in absolute opposition to proposed 8 alt 8A. Yo

bee

 I am writing in support of the proposed Segment 8 Yo

100328 POWER COMPANY 

OF WYOMING LLC

the BLM should disclose in the Final Environmental Impact Statement (“FEIS”) its plans to coordinate amongst the various 

applicants and existing right-of-way grantees so as to meet BLM’s multiple use mission.

BLaddthe Tra
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100328 POWER COMPANY 

OF WYOMING LLC (cont.)

Segments of the proposed GWW Project cross land owned by [Affiliate], upon which [Business] owns the wind development 

rights or the right to site facilities and infrastructure related to wind energy development. The Segments are within the I-80 corridor from approximately Fort Steele to the Sage Creek Road (GWW Project Segments 2, 2A and 2B). [Business] supports 

these route Segments because they are within an existing utility corridor in an area already impacted by development. However, BLM should be aware that there are a number of other projects underway within this corridor including the 

TransWest Express Transmission Project under development by [Business]’s affiliate TransWest Express LLC, [Business]’s 

CCSM Wind Project, and the Energy Gateway South Project, which is also being developed by Rocky Mountain Power. Union Pacific is also discussing a new rail distribution facility planned within this area on land owned by [Affiliate]. The proposed

GWW Project must be planned and sited so as to avoid interfering with the siting, construction and operation of the TransWest Express Transmission Project as well as the CCSM Wind Project. The BLM should consider these existing and future projects in its decision making process. Siting of the GWW Project transmission line through this area will require careful consideration of and coordination with other

project developers. In particular, the GWW Project transmission line must be sited so as to avoid wind energy development 

areas and facilities planned to support the CCSM Wind Project such as substations, transmission and collector lines, haul roads, laydown yards and the previously mentioned rail distribution facility. If the GWW Project interferes with the siting, construction and/or operation of [Business]’s CCSM Wind Project, in general, or the wind energy development areas and 

facilities planned to support the CCSM Wind Project, such entry and activities would cause not only physical injury to the 

property, but would substantially interfere with [Business]’s possession and use of the property, would substantially interfere

and damage [Business]’s CCSM Wind Project, and would impair the use of other property within the CCSM Wind Project area.

Thi

Proposed mitigation measure LU-4 (page 3.17-74) which would require coordination with the Chokecherry and Sierra Madre 

Wind Farm and the TransWest Express Transmission Project developers along the GWW Project Segment 2 to ensure 

mutually compatible siting of transmission lines and wind energy facilities would address a number of the issues raised above and we encourage BLM to include this mitigation measure in its Record of Decision for the GWW Project and right-of-way 

grants.

LUMa

there is an incorrect statement on page 4-45 describing the CCSM Wind Project. As discussed above, the CCSM Wind Project is a proposed 2,000 - 3,000 megawatt wind energy project (the DEIS erroneously lists the production capacity at about 2,000 

MW total). The DEIS also incorrectly describes the CCSM Wind Project as being within mapped sage-grouse core area. The 

project is not within sage-grouse core area as established by Wyoming Executive Order 2011-5. This error should be 

corrected in the FEIS. The DEIS correctly notes that the proposal is still current. In fact, as stated above, the BLM published

the Notice of Availability of the draft EIS on July 22, 2011 and a Record of Decision is expected in 2012.

Texwininfo

The BLM should maintain flexibility in its record of decision and issuance of right-of-way grants for the GWW Project 

Proponents to work with local landowners and other project developers to site the GWW Project facilities so as to avoid and 

minimize impacts to present and reasonably foreseeable future land uses and activities, including the CCSM Project.

The Re

100329 ROBERT (BOB) 

BILLINGTON, KAY BILLINGTON 

I strongly oppose Alternative Routes 7I and 7J. Yo

tab

 As stated in Chapter 2 -Alternatives, page 2-90 and 2-91, Alternatives" 7I and 71 would neither be in conformance with the 

management direction provided in the Cassia and Wells RMPs and Twin Falls MFP, nor would it be consistent with the Sawtooth Forest Plan." These management plans included extensive analysis and public input over many years. To now 

circumvent the findings of these public lands management plans would be an enormous waste of the public/taxpayers' time, effort and financial resources.

Nocomallo

 On page 2-91 first paragraph regarding Alternative 71 ... "Local landowners opposed the Proposed Route between Populus 

and Cedar Hill ... " I would like to clarify that not all local landowners opposed this route. It appears the Twin Falls CountyCommissioners were reacting to a very small, vocal and select constituency.

Chlan

 Chapter 3 -Affected Environment and Environmental Consequences, page 3.11-63 Both Alternative 7I and 7J cross sage leks 

on property my family owns. Initial construction of the proposed line, permanent placement and continued routine maintenance 

of the line would increase the detrimental impacts to the greater sage-grouse through collision/ electrocutions, consolidation of 

predatory birds along powerlines, lower recruitment rates near lines, habitat fragmentation, degradation of habitat due to spread of invasive plant species, impacts resulting from the line's electromagnetic fields and direct loss of habitat

Nopla

 I support the Proposed Route and thank you for providing the informative public meetings. Yo

100330 BRUCE BOTHWELL Re: ALT 8A 

This is not the location for this transmission line. It would affect the senic values of this area and introduce an unwanted health hazzard to our valley. What the hell is wrong with out in the desert & farm land! Keep these lines away from populated areas.

Yo
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100331 KENT SEARLE noticed the administrative draft map failed to show a landing strip on our property for crop dusters. I advised the BLM that it 

was missing. It is now on the map included in the draft EIS, however, the proposed route continues directly over the landing 

strip. Why was the route not altered to avoid the landing strip or some other type of mitigation offered?

No

 Those concerns have either been ignored or the response is with data that is not on point. One example is the electrical 

shocks that are experienced when sprinkler equipment is near high voltage transmission lines. The fact is several technicians who work on the sprinkler equipment near these lines repeatedly told of serious shocks. Idaho Power's response is unacceptable as they offer studies that are not on point and have not been able to explain the shocks the technicians receive. I 

am aware that the recordings of those public meetings in Cassia County are being submitted for the record and should be 

carefully reviewed.

Trathe 

 am hopeful that several newly proposed alternate routes that were discovered during the public open houses and sent with 

Cassia County's response would carefully be considered.

Nosupwe

100332 WYOMING 

OUTDOOR COUNCIL, HAWKWATCH INTERNATIONAL

We also question whether it is proper to amend an RMP in response to a single right-of-way request. The 

We are very concerned about how present projects like GW and CCSM and future projects are allowed to force resource management plan (RMP) and forest plan amendments, especially when many of these plans were recently finalized after 

many years of significant public involvement. (Footnote 12) These amendments, combined with the forthcoming Wyoming 

sage-grouse RMP amendments and the numerous BLM (Footnote 13) and Forest Service (Footnote 14) plan amendments for the West-Wide energy corridors (WWEC) cause us to question the value of land use planning.

The staam

In the instant case, the land use plan amendments suggested are at odds with the vision and constraints of various RMPs, 

especially the Kemmerer RMP. Both the Kemmerer RMP and the WWECs chose to only allow transmission through the 

Kemmerer field office along Interstate 80. Allowing RP's right-of-way request to force an amendment to the Kemmerer RMP would undermine that plan's vision and cohesiveness. Numerous stakeholders helped create a balanced management 

approach in the Kemmerer RMP. This balance will be upset if the BLM fails to keep its promise to site transmission along Interstate 80 in the Kemmerer field office. If BLM insists upon pursuing a route through the northern portion of the Kemmerer filed office, we believe that BLM must initiate a revision, instead of amending, the Kemmerer RMP.

The RMrou

A plan revision may be necessary for other BLM and Forest Service planning areas as well. Pro

DE

Piecemeal right-of-way grants that require endless NEPA processes and RMP amendments are not a good way to guide wind energy and transmission development in Wyoming or elsewhere. BLM can and should take the lead role and proactively address this critical issue before resources are committed. We suggest that BLM begin a comprehensive and interdisciplinary planning process for wind energy and transmission infrastructure on BLM lands in southern and eastern Wyoming. Through 

this process, BLM and stakeholders would determine where and how wind energy and transmission infrastructure would be built. The results of this process would be final, binding, and not subject to amendment. Such a planning effort would make thehard decisions, now, about which areas would be developed for wind energy and which areas would be managed for other resource values.

De

beyma

we believe that BLM should fully analyze additional, reasonable, alternative route segments – such segments in Wyoming 

include: a route going east from the Aeolus substation to the east slope of the Laramie Range and a route that would follow I80 into Utah.

No1E Raas 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100332 WYOMING 

OUTDOOR COUNCIL, HAWKWATCH INTERNATIONAL (cont.)

Section 3 of the GW DEIS analyzes impacts that are directly attributable to the GW line, but because it is reasonably 

foreseeable that GW will induce growth of wind energy generation along its length we believe that Section 3 should fully analyze these indirect impacts. In addition, BLM should amend section 4, cumulative impacts, to include wind energy 

generation that is induced by GW as well as other proposed transmission lines and the wind energy generation that those lines 

would induce. Section 4.3 very briefly summarizes the various activities with potential for cumulative impacts with GW. Table 

4.3-1 lists “Construction of new wind facilities” and briefly notes that “[v]isual, cultural, socioeconomic, vegetation, specialstatus plants and animals, weeds, wetlands, wildlife, paleontologic resources, geologic hazards, soils, water, land use, 

agriculture, transportation, air quality, noise” could be affected. The subsequent cumulative impacts analysis on section 4.4 

fails to properly analyze cumulative impacts. For example, section 4.4.3 attempts to analyze cumulative impacts to visual 

resources and notes that “[n]ew activities that would add to the industrial character of the landscape prevalent in Wyoming include the establishment of new energy and mineral extraction sites as well as construction of new transmission lines, pipeline, and other linear facilities.” Section 4.4.3 also states that “[m]ost prominent of the new energy facilities would be the proposed wind energy parks, given the strong vertical contrast of the turbines and blades (300 to 400 feet) against the generally flat to rolling terrain of the area. Nowhere in section 4.4 does the DEIS give the reader any clear idea about where or 

how many wind energy structures might be enabled by Gateway West or other proposed transmission lines. One small wind energy facility, the Pioneer Wind Park is briefly mentioned. All that a reader learns from this section is that some new wind energy parks might be built somewhere in Wyoming.

AdtexCh

Because the capacity of GW will substantially increase at the Aeolus substation, we can guess that significant new wind generation might occur near Aeolus. The purposes of NEPA are not served by asking readers to speculate when the agency 

can provide more detailed information.

AdtexCh

The remainder of section 4.4 provides little or no information about specific impacts to specific places or resources. For example, Section 4.4.11.3 gives just three paragraphs of discussion to migratory birds and concludes that “additional 

transmission lines and addition wind farms will add to migratory bird deaths from collision” and that “the cumulative impact on

migratory bird habitat and ecological conditions would be substantial.”

Impsum

Table 4.4-2 hints that specific wind projects might occur in conjunction with GW, in this case within core sage-grouse habitat,

but no details about the scope or location of the “[w]ind lease” and “two proposed” are provided.

UpwinTab

4.4.12.17 only mentions impacts from the GW line and concludes that “cumulative effects of the Gateway West Project on 

habitat for both species of prairie dog when considered together with the effects of past, present, and reasonably foreseeable future projects would be substantial.”

Impsum

No specific treatment was given to cumulative impacts to golden eagle populations, which are likely to be impacted by wind 

energy facilities induced by GW and other proposed transmission lines. Significant golden eagle population declines could well determine the fate of GW as well as other transmission projects. Thus, a well-developed cumulative impacts analysis for 

golden eagles should be a primary consideration before BLM commits additional resources toward this or other transmission line proposals.

Impimp

Of the seven proposed wind energy projects listed in table 4.2-15, only one project, the 100 MW Pioneer Wind Farm, could be 

expected to tie into routes proposed for segment 1 of GW. We wonder where and how much wind energy generation is 

planned for GW. The presence of the Heward substation and the increased capacity beginning at the Aeolus substation indicates that a significant source of generation must be planned for the greater Medicine Bow area. According to its NEPA 

Hotsheet,(Footnote 4) BLM is already aware of potential plans to develop 1,351 MW of wind energy in the Shirley Basin in the 

area adjacent to the planned Heward substation. Unfortunately, these and other projects within BLM's sphere on knowledge 

were not mentioned in section 4. These projects, and especially the Dry Creek Wind Project,5 are reasonably foreseeable.

TabE, in t

Because substations are expensive components, a prudent person would consider it sufficiently likely, without viewing the 

BLM Hotsheet, that a significant amount of infrastructure would be connected to GW at the Heward and Aeolus substations. Generation infrastructure, noted in the Hotsheet or otherwise, that would connect to GW must certainly be considered interdependent, otherwise it would be irrational for Rocky Mountain Power to construct this line. The growth of interdependent 

generation infrastructure induced by GW must be considered if the public is to have a true sense of the cumulative and indirect

impacts from this project.

AdtexCh
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100332 WYOMING 

OUTDOOR COUNCIL, HAWKWATCH INTERNATIONAL (cont.)

A proper indirect and cumulative effects analysis for each resource would begin with a discussion of the scope and location of 

reasonably foreseeable development activities, especially wind generation. BLM should be able to deduce how many wind energy facilities the GW and other transmission lines will enable given the expected capacity rating of each transmission line.

Only once this initial projection is made, can BLM adequately address cumulative impacts to the various resources mentioned in table 4.3-1. We expect a relatively specific and thorough analysis that quantifies impacts to specific resources in specific

areas. For example, how would golden eagle populations be affected by individual golden eagles killed by the infrastructure 

needed to power each of the proposed lines? We believe that BLM's duty to inform the public will not be met unless cumulative impacts are analyzed in a much more robust manner that will convey how the future of places and resources will be affected by GW.

AdtexCh

The Department of Interior's NEPA handbook explains that the “purpose and need statement for an externally generated action must describe the BLM purpose and need, not an applicant’s or external proponent’s purpose and need.” Department of Interior, Bureau of Land Management, National Environmental Policy Act Handbook 35, (citing 40 C.F.R. § 1502.13) 

(emphasis added), available at http://www.blm.gov/pgdata/etc/medialib/blm/wo 

/Information_Resources_Management/policy/blm_handbook.Par.24487.File.dat/h1790-1-2008-1.pdf (citing 40 C.F.R. § 1502.13) (emphasis added). Furthermore, “[t]he applicant's purpose and need may provide useful background information, but this description must not be confused with the BLM purpose and need for action . . . It is the BLM purpose and need for action that will dictate the range of alternatives. . .” Id. As courts have cautioned, “One obvious way for an agency to slip past the

structures of NEPA is to contrive a purpose so slender as to define competing „reasonable alternatives? out of consideration 

(and even out of existence.)” Davis v. Mineta, 302 F.3d 1104, 1119 (10th Cir. 2002) (quoting Simmons v. United States Army 

Corps of Eng’rs, 120 F.3d 664, 669 (7th Cir. 1997). BLM's purpose and need statement for this project narrowly constrains the inquiry to approval or non-approval of the right-ofway application that the proponent has submitted. In addition to determining whether a right-of-way should be approved, we ask that BLM expand the statement and need to include a determination of whether the public interest, balanced resource use, and the mandates of the Federal Land Policy Management Act (FLPMA)(Footnote 1) and the National Forest Management Act (NFMA)(Footnote 2) will be met. An expanded purpose and need would help determine whether Rocky Mountain Power (RP) 

could accomplish its objectives by other means such as a less transmission, generation closer to load, conservation, or 

distributed generation - relevant in this context is RP's ability to comply with FERC orders 890 and 1000. From an expanded 

purpose and need, BLM could frame alternatives that would help it determine whether this transmission line is in the public 

interest and whether it would cause “unnecessary or undue and unnecessary degradation” (Footnote 3) of public lands.

The 

purdisThe buiROeffe

We do not consider the analysis in the 2004 Wind Energy programmatic environmental impact statement (WEIS)(Footnote 6) 

to be an adequate analysis of cumulative impacts because it is outdated and lacks site-specific information at a spatial scale 

relevant to GW.

No

we believe that approval of this line without discussing the nature and extent of reasonably foreseeable development on BLM 

land would be an “irreversible and irretrievable commitment of resources” (Footnote 7) because construction of GW will induce development and force BLM to allocate subsequent resources and land.

AdtexChbecon env

As BLM is aware, golden eagles are protected under the Migratory Bird Treaty Act (MBTA)(Footnote 8) and the Bald and 

Golden Eagle Protection Act (BGEPA)(Footnote 9). We are very concerned that wind energy generation induced by GW as well as other planned transmission lines could act in concert to cause significant golden eagle mortality in the proportion 

expected to occur at the Chokecherry and Sierra Madre Wind Energy Project (CCSM).10

AdtexCh
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100332 WYOMING 

OUTDOOR COUNCIL, HAWKWATCH INTERNATIONAL (cont.)

The wide breadth of effects that will be induced by GW and other planned transmission projects would best be addressed by a 

legally-binding master plan for wind and transmission infrastructure in southern and eastern Wyoming. Haphazard oil and gas 

development, prompted by the nomination leasing system and hobbled by resource location uncertainty, has had far-reaching 

consequences for open spaces, air, water, and wildlife. To ensure a balance of resource uses, BLM should assume a 

leadership role and craft a future for wind development on our public lands that does not discount the value of our open 

spaces and wildlife. In October of 2010 we became aware, through Tom Lahti, that BLM hoped to embark upon a master planning effort for wind 

development in Wyoming. We were hopeful and optimistic that this planning effort would chart a wise course for wind energy 

and transmission development in Wyoming – one that would allow renewable generation yet protect Wyoming's priceless 

landscapes and wildlife populations. To our knowledge, this Wyoming planning effort was prompted by and would have 

averted many of the problems BLM encountered with industrial-scale solar projects in the Mojave desert. We are aware of the 

Wyoming Wind and Transmission Study and are hopeful that it will yield a better understanding of where to site wind and transmission infrastructure. Unfortunately, the fact that it is a “study” implies that this effort will not produce a legally-binding 

plan. Moreover, it is our understanding that this effort will not be completed for another two years. Meanwhile, BLM is moving 

forward with GW and other large transmission NEPA processes and associated land use plan amendments.

Cothis 

100333 SNAKE RIVER 

ALLIANCE

we believe DEIS Section 1.3 (Proponents’ Purpose and Need for the Project) as currently construed fails to sufficiently justify

this project.

Ad

The lack of information about whether this line will facilitate additional clean energy development or expanded fossil fuel 

generation makes it difficult to support this project at this stage. It is possible that the project proponents can better explain in 

the FEIS the kinds of energy that will access this project, and if so we urge them to do so.

Thecoa

We do not question that the existing east-west transmission system across southern Idaho and Wyoming has known 

constraints during certain times of the year. We also agree with the proponent utilities that the existing transmission 

infrastructure must be improved to resolve grid reliability and stability issues. We simply question whether Gateway West is the solution to that problem. The DEIS states at 1-1 that: The proposed transmission line is needed to supplement existing transmission lines in order to relieve operating limitations, 

increase capacity, and improve reliability in the existing transmission grid, allowing for the delivery of up to 3,000 megawatts of additional energy for the Proponents’ larger service areas and to other interconnected systems. The Project is principally 

necessary to serve future needs in Utah and Idaho, though other markets may also be served, including Wyoming’s oil and 

gas field electricity needs. Idaho Power’s current average firm load is less than 2,000 average megawatts, which is served primarily by Idaho Power’s 

total nameplate generation of 3,276MW, much of which serves its major load centers from the Hells Canyon hydropower 

complex to the west of the main load centers. Furthermore, Idaho Power’s 2011 IRP does not envision significant east side 

market purchases or plant development during the 20 years covered by the IRP. The IRP also does not include Gateway West 

as a committed resource, although it did model one IRP portfolio that was based largely on Gateway West being built in 2022 and allowing Idaho Power to access an additional 500MW of transmission capacity for market purchases from the east side of Idaho Power’s service area (2011 IRP at P. 96). The Idaho Power 2011 IRP, while not agnostic on the issue of Gateway West, is as vague as is the Purpose and Need section 

in this DEIS. From Page 54 of the IRP: The project cost and capacity is expected to be shared between Idaho Power and Rocky Mountain Power based on load service requirements and third-party transmission service request obligations. Significant renewable resource development potential exists in Wyoming and southern and eastern Idaho. Idaho Power’s 

transmission system is currently limited in its ability to transmit energy from new resources from the east to the major load 

centers in Idaho. Gateway West will provide new transmission capacity to integrate and deliver any such selected resources in addition to meeting third-party transmission service requests under Idaho Power’s OATT (open access transmission tariff). 

While we stipulate that some improvements are needed on the existing southern Idaho and Wyoming transmission 

infrastructure, there are serious questions whether a project of this magnitude and all of its associated economic, 

environmental and other risks can be justified at this time. For these and other reasons, we are struggling to understand the 

value of a share of a 3,000MW transmission line to Idaho Power and its customers. We do not question the need for 

improvements to the transmission infrastructure, particularly in southern Idaho. Rather, we question whether a project as largeas Gateway West as identified and justified in the DEIS is the solution to addressing these needs.

Ad

Given that this project has a direct connection to existing coal operations, we believe the Purpose and Need section in the 

FEIS must include potential environmental implications of facilitating the transmission of coal-fired generation.

An 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100333 SNAKE RIVER 

ALLIANCE (cont.)

Proponents and the DEIS note at P. 1-1 that the Federal Energy Regulatory Commission (FERC) requires that utilities “must 

plan, design, construct, operate, and maintain an adequate electric transmission system that meets not only the customers’ energy demands (measured in megawatt-hours) but also meet the customers’ peak load demands (measured in megawatts). 

Both are important in determining the need for the project.” We agree, but we would also point out that Section 1.3.4 of the 

DEIS notes: As of June 2011, all of the generators requesting transportation on Gateway West were wind energy (PacifiCorp 2011). The sizeable amount of wind that proponents say would be accommodated by Gateway West, while valuable as an energy 

resource, is of dubious capacity value for meeting peak demand needs due to what both utilities describe as the variability of 

the resource. A more appropriate response to meeting peak demand challenges is to aggressively expand utility demand 

response programs that serve to reduce peak at critical times. We believe the FEIS should more fully examine the value that 

expanded demand response and other mitigating measures such as distributed generation might have in determining the need for this project.

AdChwinwinsoustucou

we note that the Northwest Power and Conservation Council’s 6th Power Plan for the four-state Pacific Northwest region 

downplays the need for significant amounts of new nonrenewable energy development. In fact, the 6th Plan, which serves as the region’s electricity roadmap, notes that the region can satisfy fully 85 percent of its new load growth through energy efficiency and conservation, with the balance coming mostly from renewables such as wind.

Whpow

The DEIS cites at P. 1-9 in 1.3.3.1 (Existing Transmission System Constraints; General Studies) a 2006 Department of Energy 

study that says in part: This area is rich in coal and wind resources that, if developed, could provide important sources of low-cost energy and fuel diversity while improving domestic energy self-sufficiency and enhancing the economic development in the resource areas. 

This resource development scenario has been thoroughly explored in analysis sponsored by the Western Governors 

Association. Missing in this section, however, is the fact that, since the 2006 DOE study was released, two of the largest non-proponent 

possible destinations for power carried by Gateway West (Oregon and Washington) have adopted renewable portfolio 

standards that make the importation of coal-fired generation that would be carried by Gateway West nearly impossible. Other potential target states for the power, Montana, Nevada, and California, have increased the requirements in their RPS’s. In 

short, the markets for much of the power that the proponents say would be carried by Gateway West are disappearing, while 

the demand for distributed generation resources closer to utility load centers is increasing, further reducing the need for large 

transmission projects such as this

No

Based on the information contained in the DEIS, it is unclear whether the amount of new generation that would fill a new 

3,000MW transmission line (or lines) will occur in the foreseeable future.

The to b

We also note that the most recent assessment by the Resource Adequacy Forum 

(http://www.nwcouncil.org/library/2007/2007-9.htm) and the Northwest Power and Conservation Council and the Bonneville 

Power Administration indicates that the Pacific Northwest is adequately positioned to meet expected load growth for the short term and midterm future. While the Pacific Northwest Adequacy Assessment does not project resource adequacy at the utility level, and while the Council is in the process of adopting a new standard, it appears clear that the region identified as a 

possible target for power that would be delivered by Gateway West is already well positioned to meet its anticipated new load 

with existing and forecasted resources.

No

We recommend that the FEIS more fully examine the issue of regional adequacy and in particular the analysis contained in the 

Power Council’s 6th Power Plan.

Anand 

we question the need for two separate 500KV lines between the Populus substation in southeast Idaho and the Hemingway 

substation in southwest Idaho, through the existing Midpoint substation and the proposed Cedar Hill substation in Idaho’s Magic Valley.

Noneelan

We recommend that the FEIS undertake a much more thorough analysis not only of the benefits of a second line, but equally 

important the economics of such a line and whether the risk mitigation from such a line justifies the added expense.

NoAs thethe 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100333 SNAKE RIVER 

ALLIANCE (cont.)

While we agree with the suggestion in the DEIS that no single generation or transmission project alone would “trigger” the need for this project, we take issue with section 1.7.3.3 on Pages 1-27 and 1-28 that: 2. Gateway West has sufficient justification to be built in the absence of the other proposed transmission lines. It does not require the construction of another transmission line to be put into service. Therefore, it can and would proceed without other

actions taken previously or simultaneously, failing the second test for connected action. 

As stated above, proponents and the DEIS state that “other markets may also be served” by Gateway West. In fact, this is a 

primary driver for Idaho Power’s proposed 500kV Boardman to Hemingway transmission line that would link the Hemingway 

substation which is at the western terminus of the proposed Gateway West line with markets in the Pacific Northwest. Current 

transmission from Idaho Power’s western service territory to those markets is frequently constrained and in our view could not 

accommodate additional demand from the power that Gateway West would provide to the Hemingway substation. There 

clearly is a nexus between the two proposed projects.

As demline

we urge BLM and the proponents to carefully assess whether this project is truly necessary, and just as important whether 

more modest enhancements to the existing transmission systems would accomplish the same goals as Gateway West but 

without the enormous cost to utility customers and without the myriad permanent environmental and land management 

challenges posed by this project.

Se

100334 NORTHERN 

LARAMIE RANGE ALLIANCE

The Alliance strongly supports the route designated in the Draft Environmental Impact Statement (“DEIS”) as “1EC”. Yo

Sein tCh

Pacificorp/Rocky Mountain Power says it needs “redundancy” – i.e., a backup corridor in the event that the main corridor has 

to be shut down for some reason. But there are many stretches of the Gateway West line that are being built within the 

existing corridor, and Alternative 1E-C – along the existing corridor – would meet all the linespacing criteria established by the Western Electricity Coordinating Council (WECC) that oversees these issues.

YoSe

in tCh

Pacificorp/Rocky Mountain Power also says it may want to service wind development in in the northwest part of Albany 

County. But this development is unlikely: Those are core sage grouse areas, where wind and transmission development would 

violate State policy. And even if such development occurs, it easily can be served by spur lines from the Aeolus Substation. A new corridor is not needed.

ThiThe dro

We strongly oppose the two other routes currently under consideration (Routes 1E-A and 1E-B), both of which would traverse 

western foothills of the Northern Laramie Range.

YosupAlteana

100335 LINC ENERGY [business] purchased the fields near Glenrock from [business] in March, 2011. Since that time the company has been actively 

pursuing the redevelopment of the producing properties. It is also the company’s intent to initiate a CO2 Enhanced Oil 

Recovery (EOR) program in both the South Glenrock field and the Big Muddy field. The attached map shows the locations of [business]’s assets in the Glenrock Area. From West to East, [business] operates the Big Muddy River Unit (Frontier) in 

Purple, East Big Muddy Unit (Dakota) in Blue, South Glenrock A Unit in Red, and the South Glenrock B Unit in Green. Both the South Glenrock and Big Muddy Units have been evaluated for CO2 EOR and it is the company’s intent to pursue this potential. The route that works for [business] is shown in green on the above map. The eastern route is the existing 1W(c), and

would also represent the 1W-A or 1E-A of the proposed expansion. The western route, 1W(a) cuts across the eastern area of the Big Muddy Unit and the Glenrock Unit. As shown on the map, the eastern routes skirt the South Glenrock B unit and will not impact [business]’s oil field operations. For this reason we would favor this route. The greatest impact to our oil field operations is that we cannot raise a rig, either drilling or work-over, near overhead power lines. Therefore we will have to make sure that when and where the transmission is routed we will not expect to have wells located near there in any of our future plans. The fact that there is a transmission corridor near our fields will hopefully allow us 

to more easily work with Rocky Mountain Power to supply electricity for our EOR projects.

SebeeAlteana

Proposed route 1W (a) that goes west along the north side of the town of Glenrock then heads south should be moved farther west to avoid crossing Linc Energy’s units to make sure that our present and future oil field operations are not affected.

The exia d

It is our understanding that the existing transmission from the Dave Johnston Power Plant at Glenrock follows the route shown 

in red as 1W(c) on the map shown above. [business] fully supports an expansion of this route to meet the additional 

transmission requirements out of the area, either 1E-A or 1W-A shown in green. To [business] this route creates the least 

disturbance to the area and achieves the goals at increasing transmission.

Yo1E as 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100336 RUSSELL V AND 

LISA PATTERSON 

Our farm is located at [address] of Burley in Cassia County and the power line would go along the northern boundary of our farm as well as cut directly through a farm we rent at [address]. We have hand lines in these fields and we are concerned about the workers moving hand lines under these high powered lines. We are also concerned about pivot Repairmen who are working on pivot towers which are even closer to the line, especially on hot days as when the lines naturally expand. Tractor 

operators and their electronic equipment are also affected by the stray electrical current from the power line, as well as interference to radio signals which are used many times daily. Our last point of concern is for the aerial spray applicators who 

spray our potatoes and barley. They need to get close to the pivot edges and the liability of them getting into the power line 

would be tremendous. Any of these stated concerns would make it more difficult and cause a significant hardship on our ability to farm due to the loss of timeliness, efficiency, safety, and added costs; not to mention the loss of production on farmable 

ground.

AdSe

 A suggested route we would like to recommend is to follow the Utah line route to the 110 location on the 7I, J Route. (See 

attached Map) We then suggest it turn northwest into the Goose Creek Drainage towards the west side of the Oakley Reservoir. As indicated by Walt George to us, this area contains a smaller population of Sage Grouse habitat than the more populated route located further west (7I). If this new route were used, it would eliminate the extra distance and costs 

associated with the other 7I and 7J routes to Rogerson, (Alternative to Cedar Hill) and avoid more major populated Sage Grouse habitat and other game route areas. This suggested route along the East side of the foothills is also in a "storm shadow" which would increase the ease of accessibility. It is located in more of the desert areas and less likely to be impacted by adverse weather because it covers 

significant areas of very low precipitation. Last of all, I think there would be less resistance from landowners on this route, as most of it is cattle rangeland and not highly valued, irrigated row crop land. A route with the least amount of impact on private property owners would be a much more 

agreeable situation for everyone.

A nThe Pre

100337 CASSIA COUNTY 

FEDERAL LANDS ADVISORY GROUP

although the 7I routes crossed more public lands, the nature of these public lands lends itself more to this types of use. For 

example, from the point were 7H and 7K separate and continuing south and west up the Raft River Valley, there already exists 

a high voltage transmission line belonging to Raft River Rural Electric. It made sense to route additional lines where current 

lines exist, rather than to impact new areas. The public lands in these areas are somewhat more arid in terms of winter wildlife 

habitat and are dissected by roads connecting the communities of Bridge, Naf, Yose and Almo.

Yolonas 

7I was routes through an area south of what is locally known as "Spark's Basin." Spark's Basin lies in between the Stateline 

and Emigrant Canyon, all south of the Reserve. Mr. Keck indicated to us that day that if the line was routed south of Spark's 

Basin that it would be hidden from view within the Reserve.

Altein tCh

Alternative 7I, while it may consist of more public land that the proponents preferred route, represents the right balance of public and private land resources and is most ideally suited to this type of use

YoAltein tCh

the DEIS indicates on page 2-79 that this route was identified by the proponent "in response to the stateline (7I) route". Thisstatement is erroneous. 7H existed before the stateline route--but the proponent would not consider it until talk began to 

surface of a stateline route. It seems as if this route was arbitrarily drawn to provide an alternative, without any real 

consideration to the environmental impacts.

Texof Adet

Granite Pass--the location where the California Cutoff from the Oregon Trail enteres the Goose Creek valley...route here was 

located below and to the north of Granite Pass in order to enable visitors to the City of Rocks to have an uninterrupted line of sight from the Twin Sisters lookpoint point to Granite Pass. From this point the route continues west circumventing Forest Service Roadless areas until in leaves the county.

The in t

every person who visits our county via the Interstate Highway system will have significant portions of our public lands resources obstructed by the presence of this 500kV powerline. Alternative 7H may represent the most significant impact to our 

public lands resource in the county--crossing some of the most pristine valleys and vistas

YoAlteconpro

We feel that Cassia County provides one of the best visual resources for the Interstate Highway traveler for its entire length along I-86 in Cassia County and continuing along I-84 west of the I-84/I-86 junction. When considering visual resources, you 

need to more carefully consider the number of people who use of the visual resources will be negatively impacted. Too much consideration may be given to the proponents concerns of mileage, expense, etc.

No

in the fertile Goose Creek valley and then reach the public land area near Cottonwood Creek, Buckhorn Canyon and Dry Creek. One reason why we preferred the Stateline or 7I alternative to this area was becuase of the winter wildlife habitat that

exists here.

YoAltein tCh
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100338 BARRY GUY 

NEILSEN 

Route 07 would still be closer than we would like but is much more acceptable than 05. We understand the desire to avoid the forest and roadless areas and moving Rt 07 north to avoid them is not a big problem for us.

Nopro

 route 05 is the most troubling for the residents in the Basin as it goes over or very near to most the homes in the valley. Yo

sup

100339 CRAIG SEARLE I feel that the proposed Gateway transmission line is a public utility and therefore should be put on public land. The southernmost route that is suggested crosses the most public land. Why should my occupation as a farmer be disrupted because of 

these lines going through my fields and I don't even get to use the electricity? Let the public decide if they want electricity or sage grouse.

The line Ap

100340 BEVERLY SEARLE *We use 2-way radios and GPS in our farming operations. The interference caused by these power lines could disrupt the 

frequencies. Will Gateway be responsible for the interference? *And how in the world are we supposed to farm around the towers? If we have to leave access to the right-of-way, it will cut up our fields into pieces and make the irrigateion systems unusable. *We currently have a landing strip for crop dusting planes on our property. The proposed route of the Gate-way transmission line goes right over that landing strip. How will that be handled?

Nosup

 I feel that using the southern proposed alternate route would disrupt lives and occupations the least. Yo *Gateway states that there should not be any problem with stray voltage. However, those who live and work around these high 

voltage lines claim there is an unusually high number of dead animals and injury from electricity. The local companies who install and repair aluminum irrigations systems, such as center pivots, have said they will refuse to work on these systems if 

this powerline goes in. How are we to continue farming?

AdSe

100341 MITCHELL SEARLE Gateway West transmission line should be constructed along the most southern proposed route. That route would disrupt the 

economy of area the least.I think Gateway should put more consideration of human impact than how this construction will 

affect the grouse. The southern proposed route is the best choice.

Yo

 The proposed northern route would force landowners to make costly changes to be able to continute to live and farm around 

and under the lines.

Yosup

100342 MARLON L 

BARNARD 

Our farm exists in SEGMENT 7 within the MILE RADIUS. We will be affected either way. We in no way, want any of these electric line towers on our farm ground.

Yosup

 Besides being an eyesore on anyones property, it also hard to farm around and is usually not worth what is paid for by the 

power company, if any compensation is given at all.

AdSe

 This is a farming valley and this project does nothing to support this. In reality, it hampers it by putting towers in our fields and 

de-valuing our land.

Imp

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER

DEIS mischaracterizes the Companies’ efforts by stating that a "substantial segment of public that have not had a chance to 

express their opinion..." (2nd paragraph, pg 2-203, Section 2.9) In fact, there has been an extraordinary amount of opportunity 

for the public to express their opinion far beyond what is typically required under the National Environmental Policy Act (NEPA) 

process, including numerous public meetings initiated by the Companies. Later in the document, the DEIS notes that the BLM 

will “reserve its identification of a preferred alternative until it has received input on the routes from all sectors of the public.” 

(4th paragraph page 2-203 Section 2.9.1)

The NEpot

The Companies encourage the BLM to identify a preferred alternative soon after the close of the public comment period in order to more productively move the NEPA process forward and further identify issues and concerns that can be resolved.

The 

Section 2.2.1 of the DEIS should provide additional detail regarding the methodology of the Companies’ siting efforts. 

However, the several alternative routes in the DEIS reflect years of proactive steps taken by the Companies to avoid and 

minimize potential Project impacts. Details of the routing and siting process are provided in the following documents and are 

summarized below: • Idaho Power Company and Rocky Mountain Power. September 2008. Siting Study. Gateway West Transmission Line 

Project. • Idaho Power Company and Rocky Mountain Power. October 23, 2008. Letter to Walt George, BLM Project Manager. Revised Routing in response to Concerns Raised by BLM and Cooperating Agencies 

• Idaho Power Company and Rocky Mountain Power. December 30, 2009. Letter to Walt George, BLM Project Manager. Analysis of revised Gateway West Transmission Line Project routing: new and revised routes submitted in response to 

September 4, 2009 deadline.

Re
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Currently, the Companies are refining the indicative layout as part of the engineering design. This is a significantly more intensive effort that incorporates site-specific field data (e.g., species-specific surveys, wetland delineations, results of 

geotechnical studies, field visits by engineers, etc.) and addresses agency-identified concerns and mitigation measures in the 

DEIS. The Companies are therefore concerned about future applications of mitigation measures which require further rerouting. Such measures should only be done in finite circumstances after careful consideration of the full suite of potential 

resource impacts and when not contrary to prior adjustments made in response to concerns of the public, stakeholders, 

regulatory agencies and landowners. This is especially concerning because the DEIS appears to misrepresent that changing the route or location of a structure or associated facility is an isolated event. In fact, every re-route and adjustment necessarily 

initiates an iterative design process that must account for many factors and can have a ripple effect that impacts multiple Project features. For example, moving one structure may require several other structures and access roads up and down the 

line to be moved in order to meet standard transmission line design principles. This is especially unfavorable when the suggested changes require replacing a tangent structure with an angle structure (or multiple angle structures). Angle structures not only significantly increase project costs, but they also require more materials, larger foundations and more 

permanent ground disturbance. The Companies respectfully request that the BLM include additional routing and siting details as presented above and recognize that any route adjustments moving forward need to be evaluated carefully and in concert with the Companies.

The 

Just as the BLM must abide by Section 7 of the ESA, the Companies must abide by WECC’s bylaws, standards, decisions and 

enforcement provisions. When the BLM is planning for new projects, they must consider the affects the ESA has on their projects just as the Companies must consider the affects existing electrical pathways have on new project’s performance and 

ratings. Just as violations of Section 7 of the ESA may result in penalties, violations of WECC’s bylaws, standards and 

decisions may likewise result in penalties. When planning for bulk electric facilities, such as the Gateway West Project, the Companies must follow the System Performance Criteria as stated in TPL-(001 thru 004)-WECC-1-CR. To obtain the performance required this Project cannot be located within a “Common Corridor” of certain existing electrical transmission facilities. The “Common Corridor” is defined by WECC as “Contiguous right-of-way or two parallel right-of-ways with structure centerline separation less than the longest span length of the two transmission circuits at the point of separation or 500 feet, whichever is greater, between the transmission circuits.

The 

The Companies’ obligation to follow WECC’s bylaws and standards is not removed because some of the Project stakeholders perceive these bylaws and standards as contrary to their goals or simply do not agree with them. While the Companies 

recognize that this typical 1,500 feet minimum separation requirement is not clearly understood nor accepted by all 

stakeholders, it is a fundamental Project requirement supported by explicit direction from the regulatory body governing the 

Companies’ planning for this Project. By not following WECC’s bylaws and performance criteria, the Project will not meet its purpose and need as discussed below.

The 

in the DEIS’ description of the No Action alternative which states “If the Gateway West Project, or is not permitted [sic], the

demand for transmission services to which its purpose and need refers would not be met with this Project and the area would have to turn to other proposals to meet the transmission demand. According to McBride et al. (2008), the lack of construction 

of transmission lines could result in substantial adverse impacts on the economic growth, including loss of jobs, in the Pacific 

Northwest region....While that statement is accurate, the significance of the Project extends far beyond the Pacific Northwest

Thisayin C

The Companies recommend that Alternative 1Ec be removed from detailed analysis. This alternative does not meet the 

Project’s purpose to responsibly access future areas of wind generation (See Table 1.3-3) nor does it meet the BLM’s broad policy to “facilitate environmentally responsible development of solar and wind energy projects on public lands” as described in 

Secretarial Order 3285A1 (March 11, 2009).

SeAlteana

The alternative routes for Segment 7 are all higher in mileage than the original proposed route and pass through undeveloped 

areas with rich natural and cultural resources. We have particular concerns regarding alternative routes 7i and 7j due to their

substantially higher mileages and impacts to natural, cultural and recreational resources. These include impacts to the City ofRocks National Reserve, as well as large blocks of undisturbed greater sage grouse habitat.

Yoinc

The Rogerson substation alternative described in the DEIS (developed as an alternative to the Cedar Hill substation) does not 

meet the Companies’ purpose and need as there would still need to be a switching station required at the Cedar Hill location where the load is located. This is a fundamental element of the Companies’ project description and is not subject to change. It

is also an extremely costly endeavor that would increase the Project’s physical footprint and overall disturbance with little to no benefit to the overall electrical system. As such, the Rogerson substation alternative should be eliminated because it does not

meet the Project’s purpose and need.

Yo
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Overall, the DEIS should be improved such that a consistent rationale is applied for alternatives considered for detailed 

analysis versus alternatives eliminated from further consideration. For example, the DEIS should indicate in detail the BLM’s 

rationale such as a) not resolving resource conflicts (citing which resource conflicts) compared to the Proposed Action, b) being substantially similar to another alternative already being considered in detail (noting which alternative and explaining the 

similarities), c) being technically or economically infeasible (describing why the Proponent’s would not or could not construct

the Project should that alternative be selected) and/or d) not meeting the purpose of and need for the Project. The DEIS should model each of the alternative’s narrative similar to that done for the East of Laramie Mountains alternative (5th 

paragraph page 2-47 Section 2.4.1.3) which effectively compares it to the Proposed Action and provides distinct points regarding the BLM’s rationale as to why it was eliminated from further consideration. The DEIS should not pre-judge impacts such as the description of the Proposed Route between Aeolus and Creston (4th paragraph page 2-55 Section 2.4.3.1) which states that the Proposed Route “would have the least impact...” Rather, the DEIS’ description of alternatives should rely on the analysis in Chapter 3 to determine and disclose impacts. This is particularly important to remove unsubstantiated opinion from 

the DEIS that is confusing to the reader, such as the statement from Power County that “the Proposed Route would have extremely detrimental impacts...” (2nd paragraph page 2-206 Section 2.9.3).

NoSe

The DEIS also should improve the rationale used regarding its conclusions about the benefits of different alternatives. For 

example, it is not clearly stated in the document why paralleling an existing line is beneficial (multiple locations including page 54 Section 2.4.2.4) nor is the use of helicopter-assisted construction techniques explained in terms of its limitations, criteria for 

its application, or its impacts (access and/or service roads may still be required). (2nd paragraph page 2-14 Section 2.1.2). 

The DEIS also commonly describes mileages of an alternative within certain habitats as a justification of its decision without a 

clear comparison to the Proposed Route; it is left to the reader to assume the basis of the comparison (multiple locations including Section 2.4.1.3).

NoWy

the DEIS should refrain from statements such as “the Proponents have stated they cannot support this alternative”(last paragraph page 2-67 Section 2.4.5.3) or “considered as an alternative by the Proponents” (page 2-54 Section 2.4.2.4) because not only is the BLM the primary entity required to consider all the alternatives, but the BLM is also required to verify 

the accuracy of the Proponents’ assertions and present information in the DEIS that does not undermine the NEPA process by appearing to be prejudicial or biased.

No

the presentation of alternatives in the DEIS is very challenging to understand and follow. For example, it is difficult to discern 

which alternatives have been eliminated because the labels in the maps do not correspond to the text. Overall, more clarity is 

needed between the table comparing alternatives, the maps and the text. (Table 2.4.1 page 2-42-45 Section 2.4).

The in dcorrevalte

Section 3.3.1.3(page 2): The DEIS states "The final determination of impacts and resolution of adverse effects, through the Section 106 consultation process, will not be complete until surveys of all lands crossed by the Project have been completed." 

This and all similar statements in the DEIS should be revised to indicate that a large percentage of the Project occurs on or 

near private lands and detailed survey work on those lands (including Class III cultural surveys) will be dependent upon 

landowners allowing access. The Final EIS also should incorporate the requirements of the Programmatic Agreement that describes in more detail how cultural resources will be addressed.

Whstathrobe 

Section 3.3.2.4(pages 17-19): When considering whether the Project will have an adverse effect on the setting of cultural sites, 

the DEIS should consider the current setting of the area, including the presence of existing modern infrastructure that has 

already affected that setting. For example, does the introduction of a transmission line into a setting that already contains numerous modern intrusions really diminish a significant historic feature if it no longer exists? Is attracting the attention of a 

casual observer away from a housing tract, farm, interstate highway, or other intrusion that already dominates the landscape an adverse effect?

No 

Section 3.3.3.3: Prior to this text, Section 3.3.2.4 outlines what is needed for a finding of No Historic Properties Affected and 

Historic Properties Adversely Affected based on the approved agency protocol. It states that what is needed for moderate or strong contrast constituting an adverse effect is that the “...proposed Project elements tend to dominate the setting.” The 

analyses listed here actually state that the elements would not dominate the setting, yet state there is an adverse effect, which is contrary to the previous explanations. Additionally, these analyses also do not discuss whether or not the setting is truly a significant historic feature of the site or trail segment. As an indication of how confusing this analysis is to the reader, Section 

3.3.3.2, page 208 states that the Project has “...potential for the elements to blend into the backdrop in some areas. . .”

AphisSeveleres

Section 3.4.2.2 (pages 39-40): The DEIS states “These costs appear to be averages of estimates provided by six farmers but the overall estimates do not track with the supporting information by the Task Force." Accordingly, we recommend that the discussion of the farmers’ results should be omitted as they do not “track with the supporting information.” Furthermore, the farmers’ estimates come from a very small sample size that has the potential to provide subjective information.

Coagrcon
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

• Section 3.4.2.3(page 71): The City of Rockland and Power County have made assumptions that the powerline will negatively impact future growth but provide no supporting information, particularly for conclusions that 25 households that would 

otherwise move to Rockland would move somewhere else as a result of the transmission line. The DEIS should provide 

supporting rationale and documentation for concluding that these impacts would occur.

The estDE

Section 3.7.1.1: The Final EIS should be revised to disclose the rationale and literature citations that support a five mile 

analysis area and clearly identify the species this was applied to.

NocenroaspesomNasurana

Section 3.7.2.3: The Final EIS should be revised to indicate that the BLM, not the Proponent, is consulting with the U.S. Fish 

and Wildlife Service. Section 7 consultation is appropriate for federal agency decisions actions affecting federally listed 

species.

InfoUS

• Section 3.10.1.1: The Final EIS should be revised to provide supporting rationale and documentation for the assumption that 

the half mile buffer on either side of the centerline is appropriate to capture and analyze indirect effects of the Project on wildlife. It would seem that this indirect impacts analysis area would vary by species and/or habitat type.

The inte

Section 3.10.1.4: The conclusions of Engel et al (1992) are misrepresented in the DEIS. Engel et al (1992) did not find an 

increase in ravens along a transmission line. Rather, they determined that ravens already present in the area started roosting in large numbers on a newly built transmission line. The DEIS should be revised to clarify this.

Ch

Section 3.10.2.2: The DEIS should be revised to provide rationale and documentation for all assumptions, methodology and 

conclusions cited in the habitat fragmentation analysis.

Ass3.1des

Section 3.10.2.3: The DEIS should clarify between what is existing habitat fragmentation and what would be additional habitat 

fragmentation caused by the Project.

ThiD.1

The DEIS expands the Analysis Area simply because data are available and not because there is information that would 

support the assertion that the Project could have an impact on a species at a certain distance. The DEIS should be revised to 

provide an analysis area appropriate to the type and level of impacts of the Project and not based on the area for which data 

are available.

No the 

Section 3.11.1.1: The DEIS should provide rationale and documentation as to why an 8-mile buffer was used for assessing fragmentation impacts, particularly since Pruett et al. (2008) estimate edge effects from newly fragmented habitats would 

extend only approximately 330 feet into habitat patches for prairie chickens.

The AreProoveworeastaexc

Section 3.11.1.5: By omitting the full definition of R1 through R3 habitats, the DEIS is implying that these areas currently support, or are capable of supporting, greater sage-grouse despite definitions contained in the July 2006 Idaho Sage-grouse 

Conservation Plan which explicitly states the contrary. The DEIS should be revised to include the full definition of the areas so 

readers can have the correct context to evaluate potential Project impacts.

The 

Section 3.11.2.2: The DEIS makes unsubstantiated broad statements that need to be reconsidered and verified by referencing 

appropriate literature citations. For example, the DEIS should provide rationale and documentation for the conclusion that building this Project adjacent to existing lines “...would cumulatively add to the numbers of raptors and ravens that are already

utilizing transmission lines in the general area.” This logic implies that raptors and ravens are perch limited in the project area. Is there evidence that the existing lines are fully-utilized by nesting raptors and ravens? Are new resources becoming available 

that can be exploited by new colonizers? Also, as stated in the DEIS, ravens and golden eagles (but also other nesting raptors such as red-tailed hawks and ferruginous hawks) have large home ranges and already exploit areas miles from the existing 

power lines. Would a new line adjacent to an existing line provide additional areas to be exploited by nesting ravens and 

raptors?

Thiterm 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Section 3.11.2.2: The DEIS states “The USFWS’s 12-Month Findings for Petitions to List the greater sage grouse as Threatened or Endangered (2010e) listed the following as potential impacts to the greater sage-grouse resulting from power lines: 1) collisions/electrocutions, 2) consolidation of predatory birds along power lines, 3) lower recruitment rates near lines, 4) 

habitat fragmentation, 5) degradation of habitat due to spread of invasive plant species, 6) impacts resulting from the line’s 

electromagnetic fields, and 7) direct loss of habitat.” However, the DEIS should also disclose the level of uncertainty in the 

USFWS’s findings.

The Adby 

Section 3.11.2.2: The DEIS over-generalizes the conclusion of Stevens (2011). Stevens (2011) determined that sage grouse collisions with fences was highest near leks and rapidly dropped off with distance to leks. Furthermore, Stevens (2011) study 

indicated that collisions were influenced by technical attributes of the fences. Fences built with steel post showed higher 

collisions than those built with wooden posts and wider spacing between posts. Broad-scale modeling suggested probability of collision was influenced by region, topography and fence density. Thus, if fence removal or modification is considered as a 

mitigation measure, only those fences should be modified or removed that have the highest probability of causing mortality to 

sage grouse. These fences are those closest to leks, are exposed on higher terrain and are less visible due to their 

construction.

Ad201

Section 3.11.2.2: The DEIS indicates that indirect effects to the greater sage grouse from the Project operations include “... a potential avoidance of tall transmission structures that could result in an increase in habitat loss and fragmentation ....” However, the UDNR 2010 literature review found “...that there were no peer-reviewed, experimental studies designed specifically to evaluate the landscape effects of tall structures on sage grouse.” They found “...no ‘peer-reviewed’ manuscripts that reported results from experimental studies to document sage-grouse avoidance of tall structures, increased predation 

related to avian predators using tall structures as perches, increased mortality attributed to collisions, or habitat degradation and/or fragmentation attributed to tall structures.”

Thistru

pot

Section 3.11.2.2: The DEIS should provide rationale and documentation to support conclusions regarding the impacts of 

electromagnetic fields on sage grouse.

Do

by et a

Section 3.11.2.2: The DEIS should be revised to provide rationale and documentation for its conclusions regarding potential 

impacts from electrocution and fragmentation of habitat by roads.

The linecur"low 

Section 3.13.1.3: The DEIS should define “significant paleontological resources”. ThiSection 4.1.2, Table 4.1-1: Ten miles seems excessive for a cumulative impacts analysis area for eagles. For example, USFWS uses a 6 mile buffer for determining disturbance impacts to golden eagles. All cumulative impacts analysis areas for 

wildlife species should include a rationale for why they were chosen, including specific references to support that rationale.

The 50 knoof a 

Section 4.1.2, Table 4.1-1: It is confusing why the DEIS uses multiple cumulative impacts analysis areas for sage grouse. The 

Final EIS should be revised to disclose the most appropriate distance to capture cumulative impacts, provide the rationale for that distance and use that area to assess cumulative effects.

The direrefl

Section 4.1.3 (page 8, paragraph 1): The DEIS should say that implementation of the Proposed Action and alternatives would include land use plan amendments instead of saying they would be “incompatible” with existing land use plans. The Proposed Action and alternatives includes proposals to amend existing land use plans as necessary to ensure that they are in compliance with those plans in the event one is chosen in the Record of Decision.

LanProForsig

Section 4.1.3 (page 8, paragraph 2): The assumption that the land use plan allocation is a cumulative effect is incorrect. Changes in the land use plan allocation are required specifically for this Project to occur and are therefore “connected actions” to the Project, not “cumulative actions”. As such, the impacts of these land use plan amendments should be disclosed as 

direct effects and should be assessed using appropriate broad programmatic analysis indicating the consequences of the 

change in management of this land (in contrast to vague references to future projects that could occur there because of the 

change). Secondly, the cumulative effects section should describe the impacts of site-specific impacts of “reasonablyforeseeable future actions” on the same resources that this Project would affect. The term “reasonably-foreseeable” implies those actions are either planned or proposed. Future actions that may or may not occur as a result of a land use allocation 

change in the land use plan is speculative at best and is not appropriate for cumulative impacts analysis. All “cumulative effects” described in Section 4.1.3 for land use plan amendments should be moved to the appropriate direct/indirect impacts sections of the DEIS.

ImpChsepcum
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Section 4.1.3.5 (page 11): The DEIS states “Changes in the VRM designation and the possible designation of a utility corridor 

along either Alternative 4B or 4D, if they are chosen and constructed, would have the effect of encouraging further 

transmission development to be sited in this corridor. Two proposed transmission lines; a 500-kV DC (TransCanada’s Zephyr line) and a 500-kV DC or AC line (Jade Energy’s Overland Intertie) were originally proposed to follow the Gateway West 

alignment. Both projects are on hold as of June 2011. If either moves forward in the future, they would likely be built along this 

alignment and in the designated utility corridor if this Project were approved and constructed in this location.” It is our 

understanding that both these projects have been placed on indefinite hold; therefore, they should not be considered reasonably-foreseeable. Additionally, it is speculative to assume they would be built along the Project alignment unless they 

are actually proposed to be built there.

Ovupdhas 4Das 

Section 4.2.1.4 (page 34): There are no existing or proposed solar facilities that would be impacting the same resources as the

Project. Accordingly, the DEIS should be revised to remove the descriptions of the potential impacts to solar facilities.

Socou

Section 4.2.2.5 (page 46): The DEIS states “In 2010, ICF International published a report conducted for the Wyoming 

Infrastructure Authority called the Wyoming Collector and Transmission System Conceptual Design (ICF 2010a). This report considered two wind resource development scenarios—one that included wind resources west of the Laramie Range and one that included wind resources primarily on the east side of the Laramie Range. The intent was to provide a conceptual design 

for up to 12 gigawatts (GW) of renewable capacity. The report concluded that it was conceptually feasible to provide for this 

capacity under both resource scenarios...” This verbiage does not describe reasonably foreseeable future actions that are 

either actively proposed or planned and therefore is speculative at this time and should not be considered as a cumulative 

effect.

It is prodevimpdis

Section 4.2.2.5 (page 48): The DEIS states “Wind projects are still in development in Wyoming, but many appear to be on hold 

(see Table 4.2-15). According to AWEA, an industry association, there are 1,412 MW of installed capacity in Wyoming, of 

which 310 MW were added in 2010. Several projects were located in areas with good wind resources but also in areas listed by the State of Wyoming as Core Habitat for sage grouse, where the Governor of Wyoming has stated (EO 2011-5) that wind 

development is inappropriate. It is therefore not clear how much wind energy will be developed in Wyoming, or where that 

development will occur...” As above, this verbiage does not describe reasonably-foreseeable future actions that are either 

actively proposed or planned and therefore is speculative at this time and should not be considered as a cumulative effect.

Chsomleacandev

Section 4.2.2.5, Table 4.2-16: All six pumping projects referred to at the start of the section should be included in this table for 

clarity.

Tex

Section 4.4.3 (pages 55- 59): This section does not include an assessment of the visual impacts when considered with existing 

development and how that has affected the current visual conditions. Accordingly, it does not have an adequate baseline for 

comparison to defensibly say that Project impacts would be “substantial”.

Sedevcom

Section 4.4.5 (pages 60-62): This section of the DEIS does not estimate the cumulative numbers of new workers and 

revenues from reasonably-foreseeable future projects. This information is necessary to disclose the cumulative socioeconomic impacts on housing, infrastructure and tax revenues. As it is now, the DEIS has no basis for saying there would be housing 

shortages.

The and 

the DEIS is not consistent when disclosing plan amendments required for the Project. The best example, however, is for the Kuna MFP which should serve as a template for other plan amendment descriptions. In particular, the Kuna MFP description 

correctly identifies that several plan amendments would be needed to make the Proposed Route conform with BLM land use 

plans in effect: 1) an amendment to allow the transmission line outside of existing corridors, 2) amendments to the SRBOP 

RMP’s VRM classes to permit surface-disturbing activity within 0.5 mile of sensitive plant habitat, and 3) to allow a utility corridor outside the two utility corridors identified in the plan. The one part of this description that could be improved relates to its explanation that an amendment would be needed to allow the Proposed Route to be constructed within a non-motorized area, but the Boise District BLM office has stated that such an 

amendment would not meet the RMP’s objectives and therefore is not implementable. Other examples of similar scenarios occur where implementation of a given alternative is precluded from occurring. If indeed a given alternative cannot be implemented, then it should not be carried forward for detailed analysis in the Final EIS.

AlteproProare 

The DEIS does not adequately describe nor cite the Wyoming Governor’s Executive Order 2011-5 (EO 2011-5, which replaces 2010-4). At a minimum, the DEIS should disclose which alternatives are consistent with EO 2011-5, including its provision that new transmission lines built within 1⁄2 mile of existing 115kV or greater facilities would be acceptable and discussion regarding

agreement/ disagreement between agencies’ current management plans and the EO. The DEIS would benefit greatly by 

including a map specifically depicting greater sage- grouse Core Population Areas and alternatives that traverse them rather than Figure E 11.2 which shows these areas but not the Project’s alternatives.

A dcomwe
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

The DEIS frequently refers to access roads and infrequently refers to service roads. The Companies’ definition of access and 

service roads has been provided to the BLM and is included in Appendix C-4, Section 4.1. Generally, access roads are roads 

that provide direct or indirect access to the transmission line or associated facilities but that is not their primary purpose; these roads may be used by the public or other permit holders. The sole purpose of service roads is to provide access to the 

transmission line or associated facilities by the Companies. It is important to make this distinction since access and service roads will have different levels of use, different users and the mitigation measures in the DEIS cannot and should not be applied universally to access and service roads. For example, there is a requirement to gate all access roads. Since access 

roads are used by others, it may not be appropriate to install a gate or otherwise limit their use. Another example is LU-1 that 

would require the Companies to monitor OHV use on access roads. Since these roads are open to other uses, monitoring increased OHV use should not be the responsibility of the Companies; rather, it is the responsibility of the land managing agency. The DEIS (page 95 Section 3.2.2.3) states that any new roads would be closed. The Companies will work with all landowners to determine if new service or access roads should be closed to the general public. Not all new roads may be closed based on such agreements. Moreover, new access roads are likely to be left open since by definition they are open to use by others.

All necserbot

the DEIS states “The Proponents have proposed to supply monitors to determine seasonal occupancy of various big game restricted areas. The Agencies reject the monitoring proposal...” (Page 26 Section 3.10.2.2). However, the DEIS fails to explain why the Company-proposed EPMs will not result in protection that is equivalent to what is in existing resource plans; 

rather, the DEIS implies they were rejected solely because there is an exception process in place. The DEIS further confuses 

the matter because

The the

it presents Company-proposed EPMs as if they will be implemented as stated on page 4 Section 3.1.3.7. Several of the Company-proposed EPMs are tied to the monitoring proposal that has been rejected such as PGC-33 through PGC-36 regarding monitoring within mule deer critical winter range

Nomitlan

The DEIS also does not identify which currently existing RMPs do not address sensitive species; in these cases, the 

Company-proposed EPMs would be more protective since there are no other protections in place. For example, the current 

Four River Field Office RMP provides no specific information for slickspot peppergrass; the Shoshone Field Office has no 

specific information for burrowing owl; and the Caribou-Targhee National Forest has no specific information for northern goshawk.

It is The 

In terms of agency-proposed mitigation, each resource within the DEIS has a set of agency-derived mitigation measures some of which conflict with mitigations proposed for other resources. For example, OM-10 and OM-20, Company-proposed measures that the BLM has accepted, state that low growing vegetation and small trees may be left in the right-of-way (ROW) 

and VIS-12 requires minimization of tree removal. However, VEG-5 requires brush clearing in the ROW to minimize fires. 

Obviously both sets of mitigations cannot be applied as they are mutually incompatible. The DEIS should remedy such cases 

and ensure that the analysis correctly captures what mitigations would be applied.

The foll

the DEIS includes several mitigation measures that require report submittal and agency approval prior to the start of construction activities. For example, TESPL-3 states that “Qualified botanists shall conduct pre-construction surveys during a season when target species are readily identifiable for special status or globally rare species...Survey reports documenting the 

surveys, their results and recommendations must be provided to land management agency for approval prior to construction... Documentation of the evaluation of avoidance of impacts to sensitive and globally rare plants must be provided to the 

Agencies prior to construction.” The Companies encourage the BLM to delegate such approvals through an agency-approved contractor dedicated to the Project as a representative of the agencies. This process would protect resources and facilitate construction in a reasonable and timely fashion.

No
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 2 - Alternative Development -- 2.2.1 -- 23 -- All -- In developing the Proposed Route, the Proponents have reported that they considered a number of options, collected data, identified major features on the ground, coordinated with land 

management agencies and landowners, and tried to minimize issues and effects related to implementing the proposal. The process used in evaluating alternatives while developing the Proposed Route is documented in the Gateway West 

Transmission Line Project Siting Study (IPC and RMP 2008, 2009). Alternative routes, substation sites, and structures 

considered by the Proponents, but not evaluated in detail, are summarized further in the EIS, along with the BLM Interdisciplinary Team (IDT) rationale for not considering them. The Proponents must meet the WECC minimum separation 

distance (1,500 feet or greater for longer spans) between transmission lines to prevent the loss of multiple circuits from a 

single event such as a wildland fire. This was a major constraint on what alternatives the Proponents could consider in detail.

See Chapter 1, Section 1.3.3.3, for more detail regarding reliability requirements of the regional and national electrical grid.The Proponents’ overall Project siting approach was to use the WWE corridor and other designated ROW corridors and existing utility corridors, if feasible, unless there was a compelling reason not to. In many cases the proposed routing closely follows

the WWE corridor; however, the WWE corridor is only mapped for federal land, and about half of the lands along the route are 

privately owned. In some locations, the WWE corridor is too narrow to allow for the minimum separation requirement from 

existing transmission lines already in the corridor (see discussion above), or no WWE corridor has been designated between 

required substation interconnections. Reasons for not using the WWE corridors are listed by each segment for the Proposed Route or Route Alternatives. Section 2.4.13 and Table 2.4-2 describe use of the WWE corridor by alternative. Appendix A, Figures A-2 through A-12 show the WWE corridor as determined in the Final PEIS, published November 2008 (DOE and BLM 2008). -- The EIS should expand upon the description regarding siting and routing using the information provided in the 

Companies' comment letter. Additional information can be provided upon request. Referencing the siting study is not 

adequate.

Ad

Chapter 2 - Alternative Development -- 2.2.2 -- 23 -- -- Rationale for Alternatives Developed by BLM -- The EIS should explain 

how the BLM prioritized which resource was more important than another when evaluating if an alternative would be carried 

forward, including the criteria and rationale that were used to determine which resource(s) were more important for a given 

alternative.

The rou

Chapter 2 - No Action Alternative -- 2.3 -- 24 -- 1 -- The action triggering this environmental review is described in the 

Proponents’ applications to BLM and the Forest Service for a ROW grant and a Special Use Permit for the portion of the 

Project on federal lands. The agencies may deny the respective applications or approve the Project with or without conditions. 

Therefore, the No Action Alternative analyzed in the EIS is the predicted result of the denial of the applications. Under the No 

Action Alternative, the Gateway West Project would not be constructed (no construction of the new substations, substation 

expansion, or the transmission line). The objectives of the Project, which include providing increased transmission capacity 

and a more reliable transmission line system for transport of primarily wind energy to meet existing and future needs (as described in Section 1. 3, Purpose and Need), would not be met. The cumulative effects of the No Action Alternative are found Chapter 4 and summarized in Section 2.10. -- The last sentence should be changed to read: "...transport of generation including wind energy to meet..."

Info

Chapter 2 - Route Action Alternatives -- 2.4 -- Overall -- [blank] -- Using the phrases "considered by proponents" vs. "considered by BLM" is prejudicial. The EIS should be explicit when describing BLM's role as lead permitting agency to consider all alternatives and provide impartial evaluation of those suggested by the Proponents either for detailed analysis and/or elimination from detailed analysis.

Whit m

Chapter 2 - Route Action Alternatives -- 2.4 -- 41 -- 5 -- Because the Project connects a series of three proposed, one planned, and eight existing substations, alternatives proposed by the IDT or suggested by the public and those not considered in detail 

are described by segment between substations. Table 2.4-1 lists the alternatives considered by segment. The reference points 

are illustrated in Appendix A, Figures A-2 through A-12 by segment. -- Correct last paragraph to give correct substation 

quantities as follows: Existing: Jim Bridger (tie to Anticline); Expanded: Windstar, Populus, Borah, Midpoint, Hemingway; New: Heward, Aeolus, Creston, Anticline, Cedar Hill (total 11 not 12)

Info

Chapter 2 - Route Action Alternatives -- 2.4 -- 42 -- T2.4.1 -- All -- The EIS needs provide better clarity between this table, the 

maps and the text. E.g.. Alt 2A, Alt 2B, Alt 2C. Segment 2. For example, use small thumbnail maps in line with the text to focus 

the reader's attention geographically. In addition, the EIS needs to assist the reader better in its depiction of alternatives 

eliminated from consideration because they are not currently labeled in the maps to correspond with the text. This applies to all alternative descriptions.

Thu5 in locdis

add
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 2 - Route Action Alternatives -- 2.4.1.1. -- 46 -- 2 -- Eastern routes between Windstar and Aeolus were considered. In 

the northern portion of Segment 1E, routes were identified to avoid multiple transmissions lines across landowners located along the existing Dave Johnston – Rock Springs transmission line corridor. The southern end of the Proposed Route was 

routed by the Proponents to more easily access the wind energy resources north of Medicine Bow. Several routes including routes across as well as mostly east of the Laramie Mountains were considered and eliminated by the Proponents resulting 

from scenic concerns and public opposition to development of a new Greenfield route4. Among the key factors considered in routing this segment were visual resources, wildlife resources (sage-grouse, big game winter range, and nesting raptors), and 

geologic features (an ice cave). -- Sentence 4 in paragraph 2 needs to be clarified to help make the map understandable.

Noact

Chapter 2 - Route Action Alternatives -- 2.4.1.2 -- 47 -- 3 -- At MP 95.8 (point 1Ek) the route would pass just north of the 

Medicine Bow River and into Aeolus Substation. Between MPs 31.3 and 100.5, a new Greenfield route would be developed. 

The Proposed Route would be Greenfield for 86.5 miles and parallel an existing transmission line for 9.5 miles. -- 1E is considered a "greenfield" route between MPs 31.3 and 100.5 based on definition of "greenfield" in the footnote on 

page 2-46. However, according to definition in the Glossary, all of 1E would be "greenfield". The EIS 'greenfield' definition and application in route descriptions should be consistent throughout the document.

The 

Chapter 2 - Route Action Alternatives -- 2.4.1.3 -- Overall -- (Alternatives Eliminated from Detailed Study) -- Reasons for 

eliminating an alternative (bulleted lists) should be related to the Proposed Route similar to what was done for the East of 

Laramie Mountains alternative. Simply stating the mileage of the alternative within certain habitats is not sufficient justification. 

In some cases, there is no comparison to the Proposed Route and it is left to the reader to make the assumption that a given alternative has a greater impact or challenge than the Proposed Route.

Ad

Chapter 2 - Route Action Alternatives -- 2.4.1.4, 2.4.2.1 -- 51 -- Fig A-2 -- "...After crossing the Carbon/Converse County line, the alternative would proceed parallel to the existing 230-kV line across the west fork of Duck Creek and over the Deer Creek 

Range. At approximately MP 10, the alternative crosses Ice Cave Mountain, the “Ice Cave,” a local historical site that was a 

July 4th gathering spot for the community where they would meet to celebrate and cut ice to take home to their ice boxes. The alternative then proceeds generally south, passing east of Bates Creek Reservoir before crossing SR 487. The alternative 

would parallel the west side of SR 487 for about 14 miles to MP 59.5 (of Proposed Route 1W[c]) where the alternative would turn southwest and proceed along the northwest side of the Freezeout Mountains before terminating at the planned Aeolus 

Substation. During final design, the alignment may need to be modified to avoid the ice caves. The one area where BLM has not designated the existing corridor as a ROW corridor is..." -- The EIS should not discuss activities at the Ice Cave as part of 

its alternatives description for 1E-C unless it treats all alternatives in a similar manner.

Thi

Chapter 2 - Route Action Alternatives -- 2.4.2.2 -- 52 (53) -- 4 -- Alternatives for this segment focused on the feasibility offollowing the existing utility corridor that is also partially a WWE corridor in portions and BLM- and Forest Service-designated 

ROW corridor in other portions (BLM 2007a, 2008a). They also cross the Bates Hole MA. -- The EIS needs to clarify what is meant by "this switch"

Ch

Chapter 2 - Route Action Alternatives -- 2.4.2.2 -- 53 -- 2 -- "...At reference points 1Wc and 1x.1, the Proposed Routes for Segments 1W(a) and 1W(c) would each shift alignment approximately 1,500 feet to the southeast. For about 9 miles, 1W(a) would follow the existing Dave Johnston – Rock Springs alignment to before turning southwest at MP 39. From approximately 

MP 24, Segment 1W(c) would shift 1,500 feet east of the existing Dave Johnston – Rock Springs line before rejoining it at MP 

34. This 9-mile shift in alignment was precipitated by landowner comments about potential impacts to an historic ice cave located west of 1W(a) at MP 37.5. The modified alignment avoids the ice cave by approximately 1,500 to 3,000 feet. Upon 

resuming their original alignments, 1W(a) and 1W(c), along with Alternative 1E-C, proceed generally south passing east of 

Bates Creek Reservoir before crossing SR 487...." -- The EIS should more accurately depict the distance that the modified 

alternative would avoid the Ice Cave (currently stated as between 1,500 and 3,000 feet).

At tcom

Chapter 2 - Route Action Alternatives -- 2.4.2.3 -- 53 -- 2 -- The Shirley Basin Alternative was developed in an attempt to avoid 

crossing the Bates Hole MA with a new 230-kV transmission line; however, avoidance of Bates Hole could not be achieved 

without substantially affecting several other environmental resources. This alternative includes a 230-kV line on steel H-frame

structures that would substitute. for Segment 1W(a), described above. The proposed 230-kV route would exit the Windstar Substation heading generally west, running north of the North Platte River and the I-25 corridor. The alternative passes north 

of Glenrock, Casper, and the Natrona County International Airport, and then begins to head southwest, crossing U.S. Highway 

20/26 and traversing Emigrant Gap Ridge. This alternative would continue southwest for approximately 27 miles until meeting 

U.S. Highway 220 just north of the Pathfinder NWR. This alternative would then turn south and parallel the Pathfinder 

Reservoir and NWR about 6 to 7 miles to the west. Next, the alternative would loop east, passing south of the Seminoe Mountains, crossing Seminoe Reservoir and State Park, passing south of the Shirley Mountains, and terminating at the Aeolus Substation near the Medicine Bow River. -- As stated in the comment letter, the rationale for eliminating an alternative should

state "does not resolve resource conflicts' or similar statement that maintains consistency with NEPA guidance to eliminate 

alternatives.

As couthis 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 2 - Route Action Alternatives -- 2.4.2.3 -- 54 -- bullets -- This alternative was eliminated from detailed study because, 

as of the date it was originally proposed, it: • Is 72 miles longer than the Proposed Route; • Traverses historic trail buffers, whereas the Proposed Route avoids them; • Passes through Seminoe State Park, whereas the Proposed Route would avoid this area; 

• Crosses portions of the Natrona, Greater South Pass, and Hanna sage-grouse core areas; and 

• Encroaches upon two sage-grouse lek 0.65-mile buffers. Chapter 2 - Route Action Alternatives -- 2.4.2.4 -- All bullets used to describe alternatives eliminated from detailed study 

should be more explicit regarding the rationale used, e.g.. "Does not resolve sage grouse resource conflicts because..."

The 

Chapter 2 - Route Action Alternatives -- 2.4.3.1 -- 55 -- 4 -- Alternatives focused on an existing 230-kV utility corridor that is 

also a WWE corridor and a BLM-designated ROW corridor, as well as a relatively direct route. The proposed route location for the Gateway South Project6 was also considered. Among the key factors considered in routing this segment were visual resources visible from the Fort Fred Steele State Historic Site and nearby residences, sage-grouse and big game winter range, mining leases, and SRMAs. The current Proposed Route would have the least impact on Fort Fred Steele and 

residences among the Route Alternatives. -- The alternative's description should not pre-judge impacts of an alternative. The description should show the rationale but let the analysis in Chapter 3 determine impacts.

The app

Chapter 2 - Route Action Alternatives -- 2.4.3.2 -- 55 -- 1st footnote -- A double-circuit 500-kV transmission line is composed of 

six electrical phases (two independent circuits of three phases each) and two lightning protection shield wires. One of the 

lighting protection shield wires is a steel OHGW, and the other is an OPGW. The OPGW contains glass fibers used for 

communication along the fiber path for data transfer between the Proponents’ facilities. The data transferred are required for system control and monitoring. -- This description should be introduced earlier in the document.

Ch

Chapter 2 - Route Action Alternatives -- 2.4.3.2 -- 55 -- 2nd footnote -- PacifiCorp initiated siting studies for the Gateway South 

Project, which is a proposed transmission line from Aeolus to Mona in Utah, then from Mona to Crystal in southern Nevada. 

While part of PacifiCorp’s overall expansion of its portion of the western grid, Gateway South is an independent project from 

Gateway West. See Chapter 4 – Cumulative Effects, for more information on the Gateway South Project -- Footnote 

inaccurately portrays Gateway South as continuing to Nevada which is no longer the case.

Infopoi

Chapter 2 - Route Action Alternatives -- 2.4.3.2 -- 56 -- 2 -- Proceeding west, the Proposed Route passes north of Jefferson Flats, south of the Greenville Dome and a Wyoming penitentiary before crossing SR 71 about 2.4 miles south of Rawlins. Just 

west of SR 71, the route traverses Coal Creek and Coal Mine Ridge south and parallel to an existing 230-kV line. The route 

continues at varying distances from the existing line to the proposed Creston Substation. In this last 40-mile segment, the 

route crosses Hogback Ridge, Red Rim, and SR 789 before reaching the planned Creston Substation south of Wamsutter. 

The proposed 230-kV circuit would enter and exit this proposed substation and the 500-kV circuit would bypass the substation 

on single-circuit steel lattice structures. They resume in a double-circuit 500-kV configuration to the Anticline Substation. -- 

"The route continues at varying distances from the existing line to the proposed Creston substation." The EIS should state the 

minimum separation that was maintained. This statement can be interpreted as separation was not maintained.

Infoma

Chapter 2 - Route Action Alternatives -- 2.4.3.3 -- 57 -- 2 -- Rawlins Alternative (2h, 2g, 2i) 

The Rawlins Alternative was initially considered in order to avoid sage-grouse lek buffers by at least 0.65 mile. It would begin 

at point 2h, diverging south of the Proposed Route (which follows the existing utility corridor and the WWE corridor) by up to 2 

miles (at point 2g) on new ROW before rejoining the Proposed Route at point 2i. The alternative would avoid one sage-grouse lek 0.65-mile buffer, but would be 0.5 mile longer than the Proposed Route. However, the BLM, the State of Wyoming, and the 

WGFD indicated they would prefer that the Project follow the existing utility corridor and the WWE corridor, in lieu of creating 

Greenfield routes in order to avoid every sage-grouse lek 0.65-mile buffer. The BLM IDT therefore eliminated this alternative from detailed study because, as of the date it was originally proposed, it: • Does not follow existing utility corridor or the WWE corridor. -- Rawlins Alternative: rationale for elimination should be related 

to not resolving resource conflicts vs. not being in compliance.

The foll

Chapter 2 - Route Action Alternatives -- 2.4.3.4 -- 58 -- 2C - all -- Alternative 2C was developed in response to the Wyoming 

Governor’s EO 2011-5, which lays out a series of measures for greater sage-grouse core area protection. Stipulation 16 of the EO establishes a transmission line corridor through core population areas. This 2-mile-wide corridor is the State of Wyoming’s 

preferred alternative for routing transmission lines across the southern portion of the state. The EO provides that new 

transmission lines within this corridor would be considered consistent with the EO. Therefore, BLM has identified an alignment for Alternative 2C that is within the established corridor as an alternative to the Proposed Route and a portion of Alternative2A, which are outside the corridor but in the same general area. This alternative is approximately 24.4 miles long, compared to28.4 miles for the corresponding portion of the Proposed Route. Alternative 2C would originate at point 2a.1 and extend 

southwest through point 2d.1 to a connection with the Proposed Route at point 2e.4. No land use plan amendment would be 

required for this alternative. -- The description of this alternative should describe and/or provide a footnote of the Wyoming Governor's Executive Order (EO) and explain that this alternative would be in compliance with the EO if implemented.

The Se
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 2 - Route Action Alternatives -- 2.4.3.4 -- 57-58 -- 2A - 2nd paragraph -- "...At this point, this alternative would depart 

from the existing transmission line and head generally southwest, crossing to the south side of I-80 and U.S. Highway 287/30 

at MP 25.8, and continuing another 2.5 miles to a location just southeast of Grenville Dome and approximately 2 miles southeast of Sinclair. This alternative would be substantially more visible from the Fort Fred Steele State Historic site than the 

Proposed Route would be. This alternative would parallel existing transmission lines for 26 miles." Alt 2B: "Alternative 2B was

originally the Proposed Route; however, concerns by rural residents as well as issues related to visual impacts to a historic 

site resulted in the Proponents changing this route segment from proposed to a feasible alternative. This alternative is approximately 6.2 miles long, compared to 7.0 miles of the corresponding portion for the Proposed Route. This alternative consists of the original proposed alignment in the vicinity of Fort Fred Steele State Historic site. It would cross 

immediately south of the historic site main compound. This alternative would make maximum use of following an existing 

corridor and the designated WWE corridor. No land use plan amendment would be required for this alternative" -- The rationale for Alternate 2A and 2B is confusing and almost sounds like rationale that would be used for elimination. Was it initially considered for following the existing corridor but 

no longer considered for that reason?

As theclo

Chapter 2 - Route Action Alternatives -- 2.4.4.3 -- 60 -- 1 -- This alternative was eliminated from detailed study because as of 

the date it was originally proposed: • The WWE corridor along this route contains extensive development including existing roads, railroads, mining, and oil and gas operations, which present substantial constraints to the design and operation of the Gateway West transmission facilities -- Tipton Alternative: Bullet should be based on not meeting P&N or technical infeasibility not "substation constraints".

If th

Chapter 2 - Route Action Alternatives -- 2.4.5.1 -- 61 -- 3rd bullet from bottom of page -- The Rock Springs Subsegment 

extends approximately 52 miles to the west of the Anticline Substation. It is the only subsegment where a designated WWE corridor exists. It is approximately 52 miles west from the proposed Anticline Substation (from point 4 to 4b along the Proposed 

Route). The most important constraint in this subsegment is the Seedskadee NWR along the Green River. Other constraints 

include trona and coal mining, sage-grouse leks and buffers and core area, proximity to the Spring Canyon Subdivision, VRM 

Class II lands, and raptor nests and buffers. The primary routing opportunities are the existing transmission corridor and the WWE corridor. -- Rock Springs Subsegment: Is it appropriate to label a restraint as "most important", in this case the 

Seedskadee NWR. The term "most important" is a value-based judgment and should be deleted.

Infoma

Chapter 2 - Route Action Alternatives -- 2.4.5.2 -- 63 -- 1,2,3 -- The Proposed Route remains parallel and offset about 1,500 

feet northeast of the existing 345-kV corridor crossing Bear Lake Valley, U.S. Highway 89, and the Bear River before 

proceeding to the eastern boundary of the Caribou-Targhee NF at MP 160. The Proposed Route crosses about 9.2 miles 

within the NF boundary on a new ROW north of, but offset from, the existing 345-kV line as proposed by the Forest Service. 

The route then rejoins the existing corridor on the west side of SR 34 crossing Mound Valley and the Bear River again. At MP 176, the Proposed Route leaves the existing 345-kV corridor and proceeds west passing along the north side of Dry Hollow Mountain and angling northwest toward the community of Downey. About 2 miles south of Downey, the Proposed 

Route crosses U.S. Highway 91 and the Marsh Valley. It then continues northwest to the Populus Substation located about 1.3 miles west of Downey. The Proposed Route would be within the Greater South Pass Sage-Grouse Core Area adjacent to the 

existing 345-kV transmission lines. It would then cross the Seedskadee Sage-Grouse Core Area (Seedskadee Core Area) from approximately MPs 58 to 70, adjacent to existing 345-kV lines and Greenfield route from MPs 70 to 71. The route would then cross approximately 14 miles of the Fontenelle Sage-Grouse Core Area (Fontenelle Core Area) and 4 miles of the Sage 

Sage-Grouse Core Area (Sage Core Area) on a Greenfield route. Of its 203.0-mile length, 80.4 miles would be parallel to existing transmission lines. The Proposed Route would neither be in conformance with the management direction provided in the Kemmerer Green River 

RMPs nor would it be consistent with the Caribou Forest Plan. Table 2.2-1 describes the management direction, the proposed 

amendment, and the sections of the Draft EIS where the effects are analyzed. Appendix F provides the proposed amendment 

and Appendix G provides the analysis and rationale for visual resources amendments. -- In general, the EIS needs to better describe the EO . In this case, the EIS needs to clarify that passing through core areas adjacent to existing lines is consistent with the EO. Throughout the EIS, the description of alternatives should state if a given alternative is or is not consistent with 

the EO, if applicable.

Infosee 

Chapter 2 - Route Action Alternatives -- 2.4.5.2 -- 63 -- 3 -- The Proposed Route would neither be in conformance with the 

management direction provided in the Kemmerer Green River RMPs nor would it be consistent with the Caribou Forest Plan. 

Table 2.2-1 describes the management direction, the proposed amendment, and the sections of the Draft EIS where the effects are analyzed. Appendix F provides the proposed amendment and Appendix G provides the analysis and rationale for 

visual resources amendments. -- The EIS text should be changed from "neither in conformance" to "would require a land use plan amendment" An alternative would not be out of conformance until a decision was made and a necessary plan amendment was not approved. This applies for wherever "Not in conformance" appears in document.

The 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 2 - Route Action Alternatives -- 2.4.5.2 -- 63 -- 2 -- At MP 176, the Proposed Route leaves the existing 345-kV corridor 

and proceeds west passing along the north side of Dry Hollow Mountain and angling northwest toward the community of Downey. About 2 miles south of Downey, the Proposed Route crosses U.S. Highway 91 and the Marsh Valley. It then continues northwest to the Populus Substation located about 1.3 miles west of Downey. The Proposed Route would be within 

the Greater South Pass Sage-Grouse Core Area adjacent to the existing 345-kV transmission lines. It would then cross the 

Seedskadee Sage-Grouse Core Area (Seedskadee Core Area) from approximately MPs 58 to 70, adjacent to existing 345-kV lines and Greenfield route from MPs 70 to 71. The route would then cross approximately 14 miles of the Fontenelle SageGrouse Core Area (Fontenelle Core Area) and 4 miles of the Sage Sage-Grouse Core Area (Sage Core Area) on a Greenfield 

route. Of its 203.0-mile length, 80.4 miles would be parallel to existing transmission lines. -- South Pass at Seedskadee are in 

Wyoming not near Downey, ID. This paragraph implies that sage grouse areas are near Downey and Marsh Valley. Need to correct descriptions of locations in FEIS.

Ch

Chapter 2 - Route Action Alternatives -- 2.4.5.3 -- 64 -- last -- Figure 2.4-1 shows an area in southwestern Wyoming in the 

Kemmerer BLM FO that contains important historic, visual, and natural resources. To date, the Proponents and the BLM have 

proposed a total of seven alternatives in this area. Each alternative was designed to reduce impact on one suite of resources; however, each of these alternatives would result in unavoidable impacts on important resources. These alternatives and their 

resulting impacts are discussed in the following text. -- The sentence should be re-written to eliminate opinion regarding whatis 'important' and cite the analysis instead.

Ch

Chapter 2 - Route Action Alternatives -- 2.4.5.3 -- 66 -- 2 and 4 -- The Gateway West Project proposes to carry up to 3,000 MW on a double-circuit 500-kV structure through this area. When combined with energy carried on the three 345-kV 

structures, the total is about 5,400 MW. While it would be technically feasible to carry this load on one set of double-circuit

765-kV structures through this area, it would be prohibitively expensive for the following reasons: -- "prohibitively expensive" 

and "out of proportion" are not good reasons to eliminate an alternative from detailed analysis. See previous comment regarding improving the description of the rationale that was used to eliminate alternatives.

The con

Chapter 2 - Route Action Alternatives -- 2.4.5.3 -- 66 -- bullets at top of page -- * The Western Interconnection does not include 

765-kV systems, and there are no substations or transformers in the Western grid that could interconnect with this voltage; • Therefore, to allow for this possibility, new substations would need to be constructed, or existing substations expanded, to 

accommodate very large new transformers just for this one line. If such a substation or expansion were created near the Jim Bridger Power Plant, then the new 765-kV line would have to be over 150 miles long, from Bridger to Cokeville; and 

• A large new substation would have to be built at Cokeville to allow for the 345-kV line that turns north near Cokeville to 

continue to supply power to the Three Mile Knoll Substation. -- The EIS could combine the 1st and 2nd bullets.

The FE

Chapter 2 - Route Action Alternatives -- 2.4.5.3 -- 67 -- last -- The Proponents have stated that they cannot support this alternative. System studies have not been conducted on this alternative but it is reasonable to assume that the reliability 

requirements for common corridor outages would not be met and that... -- The EIS should eliminate statements such as "the Proponents have stated they cannot support this alternative". In this case, the rationale that this alternative does not meet the 

Purpose and Need relative to reliability should be cited as the rationale. See previous comment. .

The FE

Chapter 2 - Route Action Alternatives -- 2.4.5.3 -- 68 -- 2 -- Based on the reliability concerns raised by the Proponents, this

alternative was eliminated from detailed analysis. -- The EIS should eliminate the statement "Based on the reliability concernsraised by the Proponents, this alternative was eliminated from detailed analysis." This needs to be directed more to not meeting the Purpose and Need. See previous comment.

The FE

Chapter 2 - Route Action Alternatives -- 2.4.5.3 -- 69 -- 2B - all -- Kemmerer Alternative B (4b.2, 4b.9, 4b.10, 4b.11, 4b.12) In January 2008, the BLM Kemmerer FO proposed a route alternative to the south of the Proposed Route in order to avoid 

environmental constraints along the existing 345-kV transmission lines. The Kemmerer Alternative B incorporates segments 

proposed by both the Proponents and the Kemmerer FO. This alternative departs from the feasible alternatives just west of Route 189 and trends west, crossing active trona mines owned by FMC, to the area just west of the Chevron coal mine south of the community of Kemmerer (point 4b.2). From this point, the Kemmerer Alternative B would proceed to the Wyoming-Utah 

border south of the Cokeville Meadows NWR through 20.2 miles of Sage Core Area. At the state line, the alternative would turn north to point 4b.12. This area is less disturbed than areas to the north, is within sage-grouse core area, and is big game 

crucial winter range. This alternative was eliminated from detailed study because, it: • Crosses through sage-grouse core areas; • Crosses through big game crucial winter range; and • The WGFD expressed concerned that this route alternative would cross high quality habitat with a new ROW. -- The 

description of Kemmerer Alternative B should expand all elimination reasons in similar fashion to those used for Kemmerer Alternative A. Also, the EIS should clarify the last bullet as to what habitat is high quality.

The FE
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 2 - Route Action Alternatives -- 2.4.5.3 -- 70 -- 5th bullet: mid-page -- * Results in more environmental effects than the 

Proposed Route. -- For the Populus alternative, the statement "more environmental effects than proposed action" is too vague. 

What are the exact effects?

The FE

Chapter 2 - Route Action Alternatives -- 2.4.6.3 -- 75 -- 6th bullet -- * Because topographic constraints do not allow adequate

space to accommodate two transmission lines in this area, it would not allow for co-location with Segment 7. -- Deep Creek Alternative A: 6th bullet should discuss that this alternative doesn't meet the purpose and need to provide safe and reliable 

energy.

The FE

Chapter 2 - Route Action Alternatives -- 2.4.8.4 -- 89 -- 3 -- This alternative is studied in detail although it would cross the 

Sawtooth NF for 12.1 miles, in multiple locations, most of which is high-quality habitat, and the alternative would be all 

Greenfield. Also, this alternative would result in substantially more impacts to raptors and sage-grouse compared to the 

Proposed Route. Overall, this alternative would result in measurably more environmental effects than the Proposed Route. However, the Proponents consider this alternative as superior to Alternative 7I. Of its 127.5-mile length, 116.5 miles would be

Greenfield and 11.0 miles would parallel. existing transmission lines. -- Alternative 7H: Makes several references to the 

impacts this alternative would have. Those should be reserved for the impacts analysis section.

Alte

Chapter 2 - Route Action Alternatives -- 2.4.92 -- 92 -- last -- Several plan amendments would be needed to make the 

Proposed Route conform with BLM land use plans in effect. The Kuna MFP would need an amendment to allow the transmission line outside of existing corridors. The SRBOP RMP would need amendments to VRM classes, to permit surfacedisturbing activity within 0.5 mile of sensitive plant habitat, and to allow a utility corridor outside the two utility corridors 

identified in the plan. In addition, the Proposed Route would not be in conformance with the management direction provided in 

the Bennett Hills/Timmerman and SRBOP RMPs and the Kuna MFP. An amendment would be needed to allow the Proposed Route to be constructed within this non-motorized area; however, the Boise District BLM office has stated that the RMP could 

not be amended in this way to meet objectives. Alternative 8E would avoid this area. Table 2.2-1 describes the management direction, the proposed amendment, and the sections of the Draft EIS where the effects are analyzed. Appendix F provides the 

proposed amendment and Appendix G provides the analysis and rationale for visual resources. -- This description is a good example of language for alternatives that would require a land use plan amendment and should serve as a template for other such descriptions.

Nonee

Chapter 2 - Route Action Alternatives -- 2.4.9.3 -- 95 -- 1st bullet -- Gooding North Alternative: Is 1.8 miles more VRM Class I 

and II land than the Proposed Route; -- Gooding North Alternative: "is 1.8 miles more" should be changed to "Crosses 1.8 miles more"

Info

Chapter 2 - Route Action Alternatives -- 2.4.9.3 -- 96 -- 5th bullet -- Cross 32.4 miles more of steep slope areas than the 

Proposed Route. -- The EIS needs to define steep slopes.

The 

Chapter 2 - Route Action Alternatives -- 2.4.10.3 -- 102 -- 4th bullet -- The Proposed Route was agreed upon through agency consultation as a means to avoid conflicts with the Air Force Range and the State Park, whereas this alternate was not; and -- 

For the Saylor Creek Alternative, the statement that the "Proposed Action was agreed upon to avoid conflicts, whereas this 

alternative was not agreed upon" is a poor qualification. The EIS should be reworded to state this alternative has potentially 

more conflicts or proximity to the Range and State Park. Is it not clear what conflicts it presents that require it to be eliminated.

The FE

Chapter 2 - Route Action Alternatives -- 2.4.X.3 -- 47-109 -- Alts Eliminated -- All -- If an alternative is eliminated because it 

doesn't resolve resource conflict compared to proposed action, the EIS' explanation should explicitly state what impacts apply and be clear that the comparison is to the proposed action.

The FE

Chapter 2 - Route Action Alternatives -- 2.4.X.3 -- 47-109 -- Alts Eliminated -- All -- If an alternative is eliminated because it is 

substantially similar to another alternative already being considered in detail, the EIS should note which alternative it is and 

explain how it is the same.

We det

Chapter 2 - Route Action Alternatives -- 2.4.X.3 -- 47-109 -- Alts Eliminated -- All -- If an alternative is eliminated because it 

would not ensure/provide safe and viable energy, the EIS' explanation/rationale should state that the alternative would not 

meet the purpose and need.

We det

Chapter 2 - Route Action Alternatives -- 2.4.X.3 -- 47-109 -- Alts Eliminated -- All -- If an alternative is eliminated because it 

would be technically or economically infeasible, the rationale should reflect that the Proponent would not/could not do the 

project if the alternative were selected.

The FE

Chapter 2 - Substation Alternatives -- 2.5 -- General -- General -- Descriptions of equipment that will be put in substations 

should be more general; it currently is too prescriptive and may not be what really is necessary.

InfoPla

Chapter 2 - Substation Alternatives -- 2.5 -- General -- General -- In general Section 2.5 needs to correct substations description: Proposed should be Creston, Anticline, Cedar Hill, Aeolus and Heward; and Existing should be Windstar, Populus, 

Borah, Midpoint, Jim Bridger and Hemingway.

InfoPla
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 2 - Substation Alternatives -- 2.5.1.2 -- 115 -- 1 -- The proposed Anticline Substation is located about 2.5 miles 

southeast of the Jim Bridger Power Plant, along the east side of Deadman Draw, approximately 30 miles east of Rock Springs, 

Wyoming, as shown on Appendix A, Figure A-14. The proposed substation would consist of a new 500-kV yard constructed 

southeast of the power plant occupying a fenced area of about 125 acres on private land (Appendix A, Figure A-4). Equipment 

to be installed within the fenced area would include 500-kV and 345-kV circuit breaker bays and associated equipment, bus 

supports, high-voltage switches, transmission line termination structures, 500-kV transformers, 345-kV phase shifting transformer, 500-kV reactors, 500-kV series capacitors, and a new control building to house communications and control 

equipment. Access to the new 500-kV yard would require improving about 0.3-mile of existing dirt road to a 20- to 24-foot allweather surface road between the existing Jim Bridger Power Plant access road and proposed Anticline Substation fenceline, improved highway access approaches, and a UPRR crossing. Within the substation site, approximately 0.4 mile of intermittent 

stream channel would be realigned to provide site drainage. -- Revise "Jim Bridger Power Plant Access Road" to "Highway 377".

InfoPla

Chapter 2 - Substation Alternatives -- 2.5.1.2 -- 115 -- 3 -- The existing Jim Bridger Power Plant has separate 230-kV and 345-kV substation yards located east and west of the plant, respectively (Appendix A, Figure A-15). Each substation would require modifications and interconnecting transmission lines as part of Gateway West. -- This paragraph states that JB Power Plant 

has separate 230kV and 345kV yards. They are not separate and they are not east and west. They are more southwest per 

Figure A-15 in Appendix A.

InfoPla

Chapter 2 - Substation Alternatives -- 2.5.1.2 -- 115-116 -- last bullet -- 8 A 5.5-mile interconnecting 345-kV transmission line 

between the new Anticline Substation 500-kV yard and the existing Jim Bridger Substation 345-kV yard (Segment 3A) would 

be required to electrically connect the two substations. The Jim Bridger 345-kV yard would be expanded by about 10 acres to 

accommodate the line termination position. -- The sentence should be re-written as "Expanded by about 10 acres to accommodate the line termination position and relocate existing shunt capacitor banks."

InfoPla

Chapter 2 - Substation Alternatives -- 2.5.1.2 -- 116 -- 2nd -- In first full paragraph, structure description doesn't match Table 

2.1.2 (pg 2-6). Should be steel H-frame or correct Table 2.1.6. Which of these is right? -- Lattice steel towers are not being considered for the 230kV and 345kV tie lines to Jim Bridger. These will be steel H-frame structures.

InfoPla

Chapter 2 - Substation Alternatives -- 2.5.2.1 -- 117 -- last -- The Aeolus Substation site is located in Carbon County approximately 10 miles west of Medicine Bow, Wyoming, on private land as shown in Appendix A, Figure A-17. The substation would be the southern terminus of Segment 1. The Aeolus Substation would be expanded to electrically terminate the two new 

230-kV lines (1W[a] and 1E), the reconstructed portion of the Dave Johnston – Rock Springs 230-kV line between the Dave Johnston Power Plant and the planned Aeolus Substation, and the two new transmission lines that would extend west to the 

Creston and Anticline Substations (Segment 2 and 3). One of the new westerly lines to Creston and Anticline would be initially 

energized at 230 kV and the other line would be energized at 500 kV. The addition of these new facilities would increase the 

size of the Aeolus Substation fenced area by about 90 acres (Appendix A, Figure A-17). -- For clarity, the EIS should indicate that the reconstructed portion of the Dave Johnston - Rock Springs 230kV line is Segment 1W[c]. This is not specifically 

defined in the paragraph.

InfoPla

Chapter 2 - Substation Alternatives -- 2.5.2.1 -- 119 -- 2 -- Existing Conditions: CR 121 is currently a single-lane road, about 20 feet wide and about 11 miles long, from SR 30 to the Aeolus Substation. It is in poor condition with a thin layer of gravel over a 

clay base and without turnouts. It includes a single-lane bridge over the Medicine Bow River built in 1914 and refurbished with

a metal deck around 1972 (see Figure 2.5-2). The bridge was recently inspected by the Wyoming Department of Transportation and found to be in poor structural condition. Its current weight limitations include a 10-ton weight limit for single 

axle trucks and 13-ton limit for multiple axle trucks, which would not accommodate the heavy haul transporters. -- Revise "SR30" to "Highway 30" (2 places)

InfoPla

Chapter 2 - Substation Alternatives -- 2.5.3 -- 120 -- All -- The substations described in this section are already operational. Alternative locations for these substations were not considered. Expansion of the 345-kV Jim Bridger Substation is described 

in conjunction with the proposed Anticline Substation (Section 2.5.1.2). The following describes their locations and the modifications proposed as part of the Gateway West project. -- Substation at Dave Johnston power plant should be added to the Existing Substations section (2.5.3) as Segment 1W[c] connects to it.

InfoPla

Chapter 2 - Substation Alternatives -- 2.5.3.1 -- 120 -- 3 -- The control house would be expanded and/or added to 

accommodate the necessary system communications and control equipment. The existing access road would be used to 

reach the site. -- Add after the 2nd sentence in the 2nd paragraph as follows: Each bay will contain the high-voltage breakers 

and switches, bus supports and control equipment. Revise the 3rd paragraph as follows: A new control house will be added to 

house the communications and control equipment for the proposed Gateway transmission lines.

InfoPla
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 2 - Substation Alternatives -- 2.5.3.2 -- 120 -- last -- The Heward Substation would be an expansion of the existing 

Difficulty Substation, which is located about 45 miles from Bessemer Bend and approximately 34 miles north of Medicine Bow, 

Wyoming, as shown on Appendix A, Figure A-19. The Heward expansion would add a new 230-kV yard to the west and immediately adjacent to the existing substation fenced area. The substation expansion would be required because the existing 

230-kV bus and other equipment within the Difficulty Substation is under-rated for accommodating the additional electrical capacity that would be added by rebuilding and reconductoring a portion of the existing Dave Johnston – Rock Springs 230-kV 

line between the Dave Johnston Power Plant and the planned Aeolus Substation (Proposed Route 1W(c)). Adding the new 230-kV yard would increase the flow through capacity of the Difficulty 230-kV bus and also facilitate maintaining power to 

Difficulty Substation customers during construction -- Heward Substation: "...would be an expansion of the existing Difficulty 

Substation" Change to "a new substation adjacent to the existing Difficulty Substation" then correct remaining section as 

needed. See previous comment.

InfoPla

Revised to include the information contained in the Plan of Development submitted in December 2012 (see Appendix B of the 

FEIS).

ReDe

Chapter 2 - Design Alternatives -- 2.6.2.1 -- 123 -- T2.6.1 -- Table -- Segments 3A and 3B should be added to Table 2.6-1: 

3A - New Single-Circuit 345kV, Steel H-frame 3B - New Single-Circuit 230kV, Steel H-frame Add segments 3A and 3B to the table. 3A- 345kV -steel H frames:3B -230kV-steel H frames. Comment: Identify all tie lines in 

document as an example.

ReDe

Chapter 2 - Design Alternatives -- 2.6.2.1 -- 124 -- last 3 paragraphs -- Vertical Steel Lattice 

The proposed double-circuit 500-kV structures use a horizontal delta configuration to reduce height. For the vertical steel 

lattice tower, one circuit of three phases is installed on each side of the tower in a vertical configuration. While the vertical 

configuration is lower in cost for some projects, the average height of the vertical configuration tower would have to be over 

200 feet for the Gateway West Project to satisfy the Proponents required phase to phase spacing for live-line maintenance 

activities. Federal Aviation Administration regulations require structures over 200 feet in height to be lighted (USDOT 2000). ...

Tubular H-Frame The double-circuit 500-kV tubular H-frame horizontal configurations represent the highest unit costs and have higher 

construction impacts than those of lattice towers. While the lattice structures are designed with four widely-spaced feet to 

provide lateral stability against the weight of the conductor and adverse environmental conditions, including high winds and ice 

storms, tubular H-frame structures have deeper and wider diameter foundations, which require more concrete per structure to provide the same lateral stability. The structures also weigh more than the lattice structures, requiring larger cranes for their installation and wider roads with greater surface stability. -- What is listed under the heading are 2 structure types NOT carried 

forward for detailed analysis. This is confusing. Add "Design Structures Eliminated From Detailed Analysis" as subsection of 

Section 2.6 for clarity.

ReDe

Chapter 2 - Design Alternatives -- 2.6.2.2 -- 126 -- all -- Lattice The Proponents considered steel lattice towers where 230-kV line configurations are needed. Unlike the 500-kV configuration, 

lattice towers do not offer the same advantages over the H-frame configuration at the 230-kV voltage level. Smaller towers can 

be used at 230 kV than at 500 kV due to the reduced conductor to tower and conductor to ground spacing requirements. 

Because of the smaller size of the structures, it is feasible to design and construct H-frame structures at a lower cost than for 

lattice towers. Further, the H-frame structures provide advantages in controlling perching opportunities for raptors, crows, and 

ravens and were therefore proposed by the Proponents. Because there is no economic or environmental advantage to using lattice towers, only the H-frame structure was carried forward for detailed analysis. -- The EIS should discuss why an H frame 

is a better perch discourager and provide a defensible justification of why H frames have less impacts than lattice.

Thi

Chapter 2 - Design Alternatives -- 2.6.2.3 -- 126 -- 1 -- Tubular single-pole tangent structures are self-supporting but angles

and corners typically require guyed structures. While H-frames can achieve lateral stability against the weight of the conductor 

and ice and wind conditions by virtue of the braced H-frame design, single-pole structures require deeper foundations and 

heavier steel poles to provide the same lateral stability, because each pole must be designed to independently withstand operational and ice and wind loads. Single-pole structures are more expensive to purchase and install, offer no technical or 

operational advantage over the proposed H-frame structure and were therefore not carried into detailed analysis. -- Single Circuit Tubular H frame: Alternative was carried forward if lattice towers present adverse impacts. What impact? The EIS should be specific and cite defensible rationale. .

Ch

Chapter 2 - Design Alternatives -- 2.6.3 -- 127 -- T 2.6.3 -- Table (ROW Width 250 feet) -- Long Term Ground Disturbance: 

Remove "ROW width" because the entire ROW width is not equivalent to long term ground disturbance.

Ch
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 2 - Design Alternatives -- 2.6.3.1 -- 128 -- overall -- All -- The EIS should cite safety and reliability as well as increased 

impacts caused by extensive operational maintenance as the primary criteria to eliminate painting.

Info

Chapter 2 - Design Alternatives -- 2.6.4 -- 129 -- T2.6.3 -- Table -- This is only a partial replication of data in Table 2.6.2 with 

extra items. The EIS should use one comprehensive table of advantages/disadvantages of all types and remove extraneous tables to simplify and remove opportunity for inconsistency.

Tab

Chapter 2 - Design Alternatives -- 2.6.4 -- 130 -- 1st bullet -- * Cost—One major reason that utilities do not normally install

extra high voltage transmission lines underground is that the construction costs are increased by 12 to 17 times over an 

overhead counterpart (National Grid 2009). These additional costs must be approved by the public utilities commission and 

are passed on to all the ratepayers, not just those near the area of underground installation. -- Cost is not the primary factor 

and shouldn't be shown as the first bullet. Greater impacts than other alternatives is the main reason it would be eliminated 

from detailed analysis.

Ch

Chapter 2 - Design Alternatives -- 2.6.4.2 -- 134 -- 3 -- For both the 230-kV and 500-kV voltage levels, the installation of 

underground transmission lines uses similar techniques. Large open trench installation or the more costly trenchless technologies are utilized to place the cables underground. Construction includes, but may not be limited to clearing of the ROW, trenching, installation of duct banks or pipe networks, installation of vaults, cable splicing and terminating, and termination structure construction. -- The extensive impacts caused by the construction process should go to the forefront of why underground was eliminated.

No

Chapter 2 - Components Common to All Actions Alts -- 2.7.5 -- 144 -- T2.7.1 -- The proposed 230-kV transmission lines between Windstar and Aeolus would use a steel H-frame structure configuration similar to the existing 230-kV in the same 

general location. The steel pole H-frame would utilize self weathering steel. Weathering steel is manufactured from a group of steel alloys that were developed to eliminate the need for painting. This type of steel alloy forms a stable rust-like appearance 

if exposed to the weather for several years -- The EIS should explain how long it takes for weathered steel to take on a rust 

appearance and in the interim, there may be short-term impacts. For example, they arrive oxidized and continue to darken 

over several months.

A d

Chapter 2 - Components Common to All Actions Alts -- 2.7.5 -- 144 -- T2.7.1 -- [blank] -- As per previous comment, the proponents are still considering dull galvanized steel for all H-frame structures. This should be updated throughout the document.

ReDe

Chapter 2 - Components Common to All Actions Alts -- 2.7.5 -- 145 -- T2.7-1 (Vis-12) -- Where the route would be visible on 

timbered slopes, limit tree removal to areas required for safety rather than from the entire ROW in order to prevent a linear 

feature on the landscape from clear-cutting trees. Vegetation removal requirements will consider Appendix A, “Standards and 

Practices for Electric system reliability" -- The "area required for safety" is the entire ROW. A requirement that we not remove 

trees in the ROW will force us to prune to such an extent as to leave large numbers of tree remnants in the right of way. This 

practice would be unsightly, adversely affect system reliability, severely damage or kill existing trees, promote infestations of 

bark beetles, produce an unnecessary fire risk, and impose an unreasonable long-term management burden on the company 

and our rate payers. If land managers want to prevent linear features we can feather the right of way, as outlined in the last paragraph of Section 

3.6.2.2, page 21 for the Medicine Bow-Routt and Caribou-Targhee NFs.

Thi(se

Chapter 2 - Components Common to All Actions Alts -- 2.7.5 -- 146 -- T2.7.1 -- Table -- CR in Acronyms/Abbreviations says county route but that is not what CR means in this table. Need consistency. All acronyms/abbreviations in this table are 

missing from list.

The 

Chapter 2 - Components Common to All Actions Alts -- 2.7.5 -- 149 -- T2.7-1 (Veg-14) -- Where the route would be visible on 

timbered slopes on lands managed by the Kemmerer FO, allow tree removal only at structure locations and where required for 

safety rather than from the entire ROW in order to prevent a linear feature on the landscape from clear-cutting trees. 

Vegetation removal requirements will consider Appendix A, Key Standards Relating to Electric System Reliability and Safety, of the MOU with the Edison Electric Institute (2006). -- This is completely unacceptable as a mitigation measure and is a direct contradiction to the intent of the MOU cited. The MOU's intent is to perform cover type conversion away from vegetation communities that could interfere with the conductors at some time in their life-cycle toward plant communities that will not. A

requirement that we not remove trees except at structure locations will force us to prune to such an extent as to leave large numbers of tree remnants in the right of way. This practice would be unsightly, severely damage or kill existing trees, promote

infestations of bark beetles, produce an unnecessary fire risk, and impose an unreasonable long-term management burden on 

the company and our rate payers. If land managers want to prevent linear features we can feather the right of way, as outlined in the last paragraph of Section 

3.6.2.2, page 21 for the Medicine Bow-Routt and Caribou-Targhee NFs.

Thi
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 2 - Summary Comparison of Effects -- 2.8.1 -- 179 -- 3 -- Alternative 2B was originally considered by the Proponents 

as the Proposed Route. Due to local landowner concerns and visual impacts to visitors to the Fort Fred Steele State Historic 

Site located on the North Platte River as well as several eagle nests in the area, the Proponents relocated the Proposed Route 

several miles to the south and BLM left the original Proposed Route as an alternative to be analyzed in detail. This alternative 

would not impact sage-grouse core area and would affect slightly less big game winter range than the comparison portion of the Proposed Route (10.4 miles vs. 16.8). Alternative 2B would affect fewer acres of mineral leases (34 acres vs. 54). 

Alternative 2B would cross the Continental Divide SRMA whereas the corresponding portion of the Proposed Route would 

cross the Continental Divide SRMA and the North Platte River SRMA. Alternative 2B would be less visible from the Fort Fred Steele State Historic Site than the comparison portion of the Proposed Route. -- States Alternative 2B would be less visible from Fort Steele. It is MORE visible so statement needs to be corrected.

InfovisSR

Chapter 2 - Summary Comparison of Effects -- 2.8.5 -- 185 -- 4 -- Alternative 5D was the Proponents’ original Proposed Route, but issues were raised by local landowners about impacts to agricultural land. The Proponents agreed to move their Proposed 

Route several miles to the east and keep the original Proposed Route as an alternative to be analyzed in detail (Alternative 

5D). Alternative 5D would affect more agricultural land than would be impacted by the comparison portion of the Proposed 

Route. Additionally, Alternative 5D would be more visible from residences in the Rockland Valley compared to the Proposed 

Route, which takes better advantage of topography to minimize visual impacts from the valley. However, it would cross within 1,000 feet of an elementary school (the only alternative to do so) and 24 residences, compared to 10 for the comparison 

portion of the Proposed Route. -- 5D does not come within 1000 feet of an elementary school; 5A does (Arbon Elementary) so this needs to be corrected. Also states that 5D is the only alternative to do so. Alternative 7A follows the same route as 5A 

near the same elementary.

Info

Chapter 2 - Summary Comparison of Effects -- 2.8.7 -- 195 -- 2 -- Alternative 8A was developed to maximize use of the WWE corridor. This alternative would cross 6.2 miles of VRM Class I (but no Class II) land whereas the comparison portion of the Proposed Route would cross 3.2 miles of class I and 8.1 miles of Class II. The comparison portion of the Proposed Route 

would be close to the communities of Hagerman and Glenns Ferry, the Hagerman Fossil Beds, and the Billingsley Creek 

Wildlife MA. This alternative would impact more cultural resources than its comparison portion of the Proposed Route (84 vs. 

33). It would cross within 1,000 feet of 46 residences compared to 14 for the comparison portion of the Proposed Route. It would affect slightly less agricultural land (182 vs. 188 acres). -- Misstates the comparison portion of proposed route as close 

to Hagerman, etc. Should state Alternative 8A: Proposed route is not close to Hagerman, etc.

Info

Chapter 2 - Preferred Alternatives -- 2.9 -- 203 -- 2 -- There is no impact-free route choice for a large transmission line. In

some segments of the Gateway West Project, where there are multiple resource conflicts, alternative routes often show dramatically different impacts on certain resources, and some alternatives were put forward to emphasize protection of one resource or land value over another. There are substantial segments of the public than have not had a chance to express their opinions on the issues and alternatives so far proposed. It is reasonable to expect those entities to propose additional alternatives or perhaps to present new information on alternatives currently considered. -- Statement "substantial segment of 

public that have not had a chance to express their opinion..." should be better described so as to not misrepresent the 

extensive efforts conducted by the agencies and BLM to engage stakeholders and public at large.

The proeffe
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 2 - Preferred Alternatives -- 2.9.1 -- 203 -- 2 -- The BLM has typically identified preferred alternatives in most of the 

Draft EISs it has prepared. The BLM portion of the Project approval covers only the federal lands it administers, between 40 and 50 percent of the total length. It does not extend to state-managed or private lands. The BLM recognizes that any route it 

proposes to approve influences that route’s location on adjacent private lands. Faced with this multiple use management situation, it is prudent for the BLM to reserve its identification of a preferred alternative until it has received input on the routes 

from all sectors of the public. Therefore, the BLM will defer identification of its preferred alternative until the Final EIS for the 

above reasons. Following the public comment period on the Draft EIS, the BLM pledges to work collaboratively with 

cooperating agencies and the public to reach a consensus on the preferred route for the Gateway West Project. In the 

absence of a consensus, the BLM will identify in the Final EIS its preferred alternative based on its multiple-use mandate in the FLPMA. In consideration of the potential changes to the environmental analysis between the draft and final document, the BLM will hold a sufficient public comment period on the Final EIS. -- “pledges to work collaboratively with cooperating agencies 

and the public to reach consensus.” Should be deleted as consensus is not possible nor is it required. Can change to address concerns to the extent practical 

within FLPMA requirements. Suggest re-wording as: "FLPMA encourages the BLM to collaborate with agencies, stakeholders, and the public during the NEPA process and to use that information to inform the range of alternatives considered and the scope of the analysis in the 

NEPA document. Additionally, it encourages the BLM to be as consistent as possible with local land use plans within the 

confines of their FLPMA responsibilities. Neither FLPMA nor any other BLM regulation requires that the BLM’s decision be 

based on consensus. The BLM’s decision has to be based on their requirements under FLPMA, including the requirement to meet the project purpose and need while managing for the long-term sustainability of project area resources. We request that this section be revised accordingly. The pledge to reach consensus for this project decision is not based on BLM’s regulatory 

mandate and will foster an expectation with the public that cannot be met by the BLM."

Thithe

Chapter 2 - Preferred Alternatives -- 2.9.1 -- 203 -- 4 -- The BLM has typically identified preferred alternatives in most of the 

Draft EISs it has prepared. The BLM portion of the Project approval covers only the federal lands it administers, between 40 and 50 percent of the total length. It does not extend to state-managed or private lands. The BLM recognizes that any route it 

proposes to approve influences that route’s location on adjacent private lands. Faced with this multiple use management situation, it is prudent for the BLM to reserve its identification of a preferred alternative until it has received input on the routes 

from all sectors of the public. Therefore, the BLM will defer identification of its preferred alternative until the Final EIS for the 

above reasons. Following the public comment period on the Draft EIS, the BLM pledges to work collaboratively with 

cooperating agencies and the public to reach a consensus on the preferred route for the Gateway West Project. In the 

absence of a consensus, the BLM will identify in the Final EIS its preferred alternative based on its multiple-use mandate in the FLPMA. In consideration of the potential changes to the environmental analysis between the draft and final document, the BLM will hold a sufficient public comment period on the Final EIS. -- Decision for BLM to ID preferred alternative is predicated 

upon false assumption that FEIS will generate input from "all" sectors of the public. The sentence should be re-written to clarify 

that the BLM decision will be made after it has solicited input from the public, not necessarily received input from all sectors of the public.

Merou

Chapter 2 - Preferred Alternatives -- 2.9.2 -- 204 -- overall -- All -- The EIS should add maps showing the designated sage grouse core area in relationship to routes in this section.

MaAp

Chapter 2 - Preferred Alternatives -- 2.9.2.4 -- 205 -- 1 -- Numerous conflicts exist with transmission routing along this segment 

and a number of alternatives have been developed to address these concerns. However, to date it has not been possible to 

identify a single alternative that minimizes to acceptable levels impacts to all the resources that occur along this segment --

Define "it" as State of Wyoming

“It” 

Chapter 2 - Preferred Alternatives -- 2.9.2.4 -- 205 -- 3 -- This alternative may, however, result in higher impacts to historic 

trails and therefore mitigation should be developed, with input from the SHPO, to adequately compensate for impacts to the 

trails. -- Change "compensate" to mitigate.

Info

Chapter 2 - Preferred Alternatives -- 2.9.3 -- 206 -- 1 -- Power County, a cooperating agency, passed ordinance No. 2010-03 

on November 23, 2009, designating two alternatives as preferred for those portions of Segments 5 and 7 in Power County 

(Power County 2009a). The County states that the Proposed Route would have extremely detrimental impacts on the health, 

safety, welfare, and economic viability of the County, particularly irrigated agriculture and future economic development within 

the County. -- This statement should be deleted because it is not defensible unless scientific studies can be appended to the document regarding how the "proposed route would have extremely detrimental impacts to health, safety, welfare and economic viability in the county." As it reads, it is an opinion which should not be included in the EIS.

Thitran
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 2 - Preferred Alternatives -- 2.9.6 -- 207 -- 2 -- Owyhee County, a cooperating agency, identified two preferred 

alternatives to the Proposed Route in Segment 9 by letter dated September 1, 2009 (Owyhee County, 2009). Of these routes, 

the Northern Route (9D) is strongly preferred and the Southern Route (9E) is considered as only a marginal improvement over 

the Proposed Route. The County states that the Proposed Route would have significant detrimental effect on the County’s landowners, farmers, economy, future development, and tax base. -- For Owyhee County, the text is confusing to read because it inserts opinion regarding who "strongly prefers" and a 'determination' that the Southern Route is only a "marginal improvement" County or BLM. As it reads, it is an opinion which should not be included in the EIS.

No 

Chapter 2 - Preferred Alternatives -- 2.9.7.1 -- 207 -- 5 -- IDANG believes Segment 8 of the Proposed Route could adversely 

affect ground maneuver and aerial combat training operations within the Orchard Training Area. It could adversely affect approximately 3,500 acres of lands in the northern portion of the Orchard Training Area by limiting or restricting training near 

tower and line safety buffers. The Proposed Route could also negatively affect cultural sites and known populations of 

slickspot peppergrass (Lepidium papilliferum), a federally listed plant species. -- IDANG believes proposed route Segment 8 

would impact training operations. Then says it would impact slickspot peppergrass which is a listed species. Whose opinion is 

that? IDANG or BLM?

The 

Chapter 2 - Cumulative Effects -- 2.10 -- General -- General -- The EIS summary should discuss all alternatives in the 

cumulative discussion, not just the No Action and Proposed Action.

Suas 

Chapter 2 - Cumulative Effects -- 2.10.1 -- 208 -- all -- i.e.: "...For many resources, the effects of Gateway West, when combined with the effects of other known projects, are not cumulatively substantial...." and "...The Gateway West Project 

would not have a measurable adverse effect on migratory bird populations or significant bird conservation sites..." -- The EIS should describe the difference between "significant" vs. "substantial".

Sigbe broimp

Chapter 2 - Cumulative Effects -- 2.10.1 -- 208 -- 1 & 2 -- The effects of the proposed Gateway West Project, when taken together with past, present, and reasonably foreseeable future actions, constitute the cumulative effects of the Project and are 

fully analyzed in Chapter 4. Chapter 4 also discusses the cumulative effects of land use plan amendments needed to allow for the Proposed or Alternative Routes when the amendment would change one or more land classifications. For many resources, the effects of Gateway West, when combined with the effects of other known projects, are not cumulatively substantial. In other cases, although the effects of Gateway West are minor, when taken together with effects of other past, present, and 

proposed future actions, many of which collectively already present a substantial cumulative effect, the cumulative impact may 

be considerable. Finally, there are some effects of Gateway West that are by themselves large, and when considered with other effects, are also cumulatively substantial. Resources for which Gateway West effects are minor and even when considered together with other projects remain less than 

cumulatively substantial include socioeconomics, environmental justice, weeds, wetlands, federally listed invertebrate species,

lynx, wolf, yellow-billed cuckoo, bald eagle, minerals, paleontological resources, geologic hazards, transportation, air quality, 

electrical environment, public safety, and noise. Additional details are found in Chapter 4. -- The Elis needs to describe 

'substantial' and 'minor.' In general, this section should just quantify impacts and not use value-based terminology. E.g.. Use

the term 'measurably-adverse' vs. 'small adverse'.

Sigbe broimp

Chapter 2 - Cumulative Effects -- 2.10.1 -- 208 -- 1 -- The effects of the proposed Gateway West Project, when taken together with past, present, and reasonably foreseeable future actions, constitute the cumulative effects of the Project and are fully 

analyzed in Chapter 4. Chapter 4 also discusses the cumulative effects of land use plan amendments needed to allow for the 

Proposed or Alternative Routes when the amendment would change one or more land classifications. For many resources, the effects of Gateway West, when combined with the effects of other known projects, are not cumulatively substantial. In other 

cases, although the effects of Gateway West are minor, when taken together with effects of other past, present, and proposed 

future actions, many of which collectively already present a substantial cumulative effect, the cumulative impact may be 

considerable. Finally, there are some effects of Gateway West that are by themselves large, and when considered with other 

effects, are also cumulatively substantial -- The phrase "possibly allowing for other projects" is speculative. The EIS should deal with reasonable foreseeable future actions (proposed or planned not associated with this project).

The 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 2 - Cumulative Effects -- 2.10.2 -- 209 -- 1 -- Under the No Action Alternative, the BLM would not issue a ROW grant 

to the Proponents of the Gateway West Transmission Line Project and the Project would not be constructed across federal 

lands. No land management plans would be amended to allow for the construction of this Project. Other projects would 

continue, including wind farms, oil and gas extraction, and coal, trona, phosphate mines. The demand for electricity, especially 

for renewable energy, would continue to grow in the Proponents’ service territories. If the Gateway West Project, or is not 

permitted, the demand for transmission services to which its purpose and need refers would not be met with this Project and the area would have to turn to other proposals to meet the transmission demand. According to McBride et al. (2008), the lack of construction of transmission lines could result in substantial adverse impacts on the economic growth, including loss of jobs, 

in the Pacific Northwest region, which includes Idaho as well as Washington, Oregon, Montana, and several Canadian provinces. -- The Companies appreciate that the BLM recognizes the regional significance of the Gateway West Project as 

indicated in the DEIS’ description of the No Action alternative which states “If the Gateway West Project, or is not permitted 

[sic], the demand for transmission services to which its purpose and need refers would not be met with this Project and the 

area would have to turn to other proposals to meet the transmission demand. According to McBride et al. (2008), the lack of 

construction of transmission lines could result in substantial adverse impacts on the economic growth, including loss of jobs, in 

the Pacific Northwest region, which includes Idaho as well as Washington, Oregon, Montana and several Canadian 

provinces.” While that statement is accurate, the significance of the Project extends far beyond the Pacific Northwest. Without

additional capacity available on the existing electrical grid, new generation including abundant wind development resources 

would be stranded and largely inaccessible. This scenario would therefore extend outside the Pacific Northwest to other regions, such as Wyoming, where new wind farms that provide economic growth and job opportunities would not be feasible without increased transmission capacity out of Wyoming.

The 

Chapter 2 - Irreversible Commitments of Resources -- 2.11 -- 210 -- 2 -- Resources committed to the proposed Project would 

be material and nonmaterial. Irreversible commitment of resources for the purposes of this section has been interpreted to 

mean that those resources, once committed to the proposed Project, would continue to be committed throughout the 50-year life of the Project. Irretrievable commitment of resources has been interpreted to mean that those resources used, consumed, 

destroyed, or degraded during construction, operation, maintenance, and abandonment of the proposed Project could not be 

retrieved or replaced for the life of the Project or beyond. -- The EIS reverses terms and should be corrected. "Irreversible" are impacts that can't be resolved and "irretrievable" is lost during life of project.

The Glo

Chapter 2 - Irreversible Commitments of Resources -- 2.11 -- 211 -- T2.11.1 -- Removal or disturbance of habitat could create irreversible and irretrievable impacts. Aquatic habitat could be irreversibly affected Removal or disturbance of habitat could create irreversible and irretrievable impacts. Aquatic habitat could be irreversibly affected. -- The EIS needs to explain why this 

is irreversible.

Infoadd

Chapter 2 - Irreversible Commitments of Resources -- 2.11 -- 211 -- T2.11.1 -- Removal or disturbance of vegetation could 

create irreversible and irretrievable impacts. -- The EIS needs to explain why this is irreversible.

Infoadd

Chapter 3 - Introduction -- 3.1.2.1 -- 2 -- 1 -- The Proposed Action is to construct and operate approximately 1,103 miles of 

new 230-kV and 500-kV electric transmission system consisting of 10 segments between the Windstar Substation at Glenrock, 

Wyoming, to the Hemingway Substation approximately 30 miles southwest of Boise, Idaho. Segments 1 to 3 and most of 4 would cross Wyoming while the western part of Segment 4 and Segments 5 through 10 would cross Idaho -- The mileage figure in this paragraph should be changed to 1,100 miles.

1,1pro

Chapter 3 - Introduction -- 3.1.4 -- 4 -- last -- Chapter 2 and Appendix B describe the components of the Project contributing to 

construction ground disturbance and operations site occupancy and use that would be constructed for any Route Alternative chosen. These components include transmission support structures; their associated construction pads; pulling sites for 

tensioning conductors; access roads to each structure, regeneration station, and substation; staging areas; fly yards where 

helicopter construction would be used; regeneration sites; and substations. As part of the conceptual design and to aid 

quantification of effects, preliminary indicative locations were assigned for all components of the Proposed Action and each Action Alternative. At each location the change in existing conditions was measured based on the size requirements, existing vegetation, and land use. Figures 3.1- -- The Draft EIS should include clear definitions and rationale for what it considers 

"temporary disturbance" and "permanent disturbance"

Thedur

will defvarillu

Chapter 3 - Introduction -- 3.1.4 -- 6 -- Fig 3.1.2 -- (Refer to figure) -- The Heward and Aoelus are new substations and should 

be included under "new" in permanent facilities.

Thi
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 3 - Visual Resources -- 3.2.1.1 -- 1 -- 1 -- The Analysis Area for visual resources was established through a combination of field reconnaissance and in consideration of the BLM and Forest Service distance zones including foreground, 

middleground, background, and seldom seen (landscape areas screened by topographic features). These distance zones are 

described in more detail in the Key Observation Point (KOP) descriptions (Section 3.2.1.4). The visual resources Analysis Area generally is between 5 miles and 15 miles from either side of the centerline of the Proposed Route and Route Alternatives. Five miles was chosen as the minimum extent because it was assumed that beyond that viewing threshold, terrain and atmospheric conditions would absorb the transmission line. The background distance zone used by the BLM is 

defined as up to 15 miles. This distance was considered for certain sensitive viewing locations; however, due to the nature of 

lattice structures it was determined that, beyond the 5-mile distance zone (middleground to background), a lattice structure would not be visible in this landscape. In most instances, middleground and background distance zone views are broad open 

views of valleys and mountainous terrain that would absorb the visual alterations. -- As stated in the Draft EIS, the transmission line can not be seen beyond 5 miles dues terrain and atmospheric conditions. Accordingly, we recommend that 

the visual impact analysis, area be confined to five miles from the centerline of the proposed transmission line.

WhForincthe 

Chapter 3 - Introduction -- 3.1.4 -- 7 -- Fig 3.1.3 -- (Refer to figure) -- The road width is 20 feet at corners. RoChapter 3 - Visual Resources -- 3.2.1.5 -- General -- e.g. KOP C6 (Figure 3.2-2). Views from this point are from the Opal Wagon Road. -- It is unclear why some KOP's use the letter "C" designation and some do not. The Draft EIS should be revised to clearly explain this.

KOhas 

Chapter 3 - Visual Resources -- 3.2.1.5 -- 34 -- last -- Alternative 4A, the shortest of all the Segment 4 alternatives, would cross approximately 42.9 miles of BLM-administered land, including 13.5 miles managed with VRM Class II objectives in Wyoming and 10.5 managed with VRM Class III objectives in Wyoming and Idaho. Alternative 4A would also cross 4.5 miles of Wyoming state land and 34.3 miles of private land in Wyoming and Idaho. The following 10 KOP locations were selected to represent the most sensitive or most typical views for Alternative 4A. The first six KOPs exhibit both cultural and visual 

resource concerns and are described in the Section 3.3 – Cultural Resources. -- We recommend revising the Draft EIS to indicate that Alternative 4A is proposed in a corridor containing 3 existing 345 KV lines. This is important relevant information 

for establishing the baseline for the comparison of project impacts.

Thi

Chapter 3 - Visual Resources -- 3.2.1.5 -- 35 -- starts with 3 -- KOP C6 (Figure 3.2-2). Views from this point are from the Opal 

Wagon Road. KOP C110 (Figure 3.2-2). Views from this point are from the White Hill Historic Monument on the Oregon NHT. 

KOP C7 (Figure 3.2-2). Views from this point are from the Alfred Corum Grave on the Oregon NHT. KOP C8 (Figure 3.2-2). 

Views from this point are from the Nancy Hill Grave on the Oregon NHT. KOP C9 (Figure 3.2-2). Views from this point are from 

Emigrant Springs on the Oregon NHT. -- Alternative 4A:KOP C6, C110, C7, C8, C9, C10: All of the previous subsequent KOPs descriptions disclose the type of viewer as well as the level of sensitivity impact. We recommend the Draft EIS be revised to disclose similar information for these KOPs.

The vie

Chapter 3 - Visual Resources -- 3.2.1.5 -- 56 -- 5 -- Alternative 7I would deviate from the Segment 7 Proposed Route east of 

Bradley Mountain and travel southeast along the Alternative 7B route, diverging from it north of Buist, Idaho. The alternative would travel west across the Sawtooth NF and Raft River Valley following the Alternative 7H route before diverging farther to the south, east of the Jim Sage Mountains. The Route 

Alternative would travel south of the City of Rocks National Reserve along the Nevada state line before turning northwest toward Amsterdam, Idaho, where it would follow an existing transmission alignment and WWE corridor to the Cedar Hill Substation from the west. Alternative Route 7I would cross approximately 0.6 mile of BLM-administered land with VRM Class II objectives (Burley FO) and 24.1 miles of BLM-administered land with VRM Class III objectives (Burley and Pocatello FO) as 

well as 65.3 miles of private land in the states of Idaho and Nevada. -- The Alternative 7I route description references the 

WWE corridor. The Draft EIS should be revised so that all segments that will follow the WWE corridor include a similar disclosure.

Thi

Chapter 3 - Visual Resources -- 3.2.2.3 -- 91 -- Table 3.2.2 -- 2/ RES – A single resident. REC – A recreational viewer. HIST –A site identified as having historic value. CULT – A site identified as a sensitive viewing location for cultural resources yet not discussed in the Cultural Resources section. -- Cultural footnote: why are there cultural sites that are not discussed in cultural 

section?

CUtribimp
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 3 - Visual Resources -- 3.2.2.3 -- 95 -- 2nd full -- The construction and operations of a transmission line along Segment 1E would not be consistent with the Medicine Bow Forest Plan management objectives in all areas of the Forest 

crossed. Segment 1E would cross NFS lands designated as MA 3.31, Backcountry Recreation, Year-round Motorized. MA 

3.31 has an SIO of Moderate. Impacts would be moderate due to screening offered by vegetation and landforms, distance of 

viewers, and lack of densely populated areas in this intact landscape. The area is not visible from any developed recreation 

area or travel way. Existing roads are closed to the public. Any new roads would also be closed. The borders of the cleared 

ROW would be feathered to create a more natural-appearing line, as required by the Forest Plan. Also, the towers would be 

made of material that, over time, becomes nonreflective. New towers would be similar to the existing towers to reduce 

contrast. A plan amendment would be needed (see Appendices F-2 and G-2). -- The Draft EIS states that for Segment 1E: 

"New towers would be similar to existing towers to reduce contrast." This is not correct. Existing towers are wood, whereas 

proposed structures would be steel. Additionally, existing towers on 1Wc would be replaced. The Draft EIS needs to be 

revised to correct these errors.

Se

Chapter 3 - Visual Resources -- 3.2.2.3 -- 95 -- 2nd full -- The construction and operations of a transmission line along 

Segment 1E would not be consistent with the Medicine Bow Forest Plan management objectives in all areas of the Forest 

crossed. Segment 1E would cross NFS lands designated as MA 3.31, Backcountry Recreation, Year-round Motorized. MA 

3.31 has an SIO of Moderate. Impacts would be moderate due to screening offered by vegetation and landforms, distance of 

viewers, and lack of densely populated areas in this intact landscape. The area is not visible from any developed recreation 

area or travel way. Existing roads are closed to the public. Any new roads would also be closed. The borders of the cleared 

ROW would be feathered to create a more natural-appearing line, as required by the Forest Plan. Also, the towers would be 

made of material that, over time, becomes nonreflective. New towers would be similar to the existing towers to reduce 

contrast. A plan amendment would be needed (see Appendices F-2 and G-2). -- The Conformance with BLM VRM Classes and USFS VQOs section of the Draft EIS states: "Any new roads would be closed also." The Draft EIS needs to be revised to clarify that these roads would be gated or blocked to prohibit public use but would be deemed administrative use roads and, therefore, not reclaimed.

The thethe 

Chapter 3 - Visual Resources -- 3.2.2.3 -- 97 -- Table 3.2.5-1st footnote -- 1/ Viewers at KOP would have views of Segment 

1W(c) with lower anticipated visual impacts and Alternative 1E-C with higher impacts -- The referenced statement from the 

Draft EIS does not make sense and should be revised accordingly.

Foo

Chapter 3 - Visual Resources -- 3.2.2.3 -- 108 -- [blank] -- There are three Route Alternatives for a portion of the Proposed 

Route: Alternatives 2A, 2B, and 2C. alternative 2A shares many of the same KOPs that have been described above for Alternative 2B. The shared KOPs are all within close proximity to Fort Fred Steele. Alternative 2B is approximately 1.5 miles 

farther from Fort Fred Steele and closer to local residences than Alternative 2A. Overall, the Proposed Route would have less 

visual impact than Alternatives 2A or 2B due to the increased viewing distance between Fort Fred Steele and residences 

located to the north of I-80. With increased view distance the facilities lack scale and spatial dominance and in some views are 

partially to totally screened by the foothills of the Hogback, resulting in overall low visual impacts, with a few isolated incidences of moderate to high impacts resulting from the residence and recreational access area located south of I-80. If 

Alternatives 2A or 2B were selected, steel pole H-frame structures would be used where noted due to the adjacent H-frame 

structures in the area of impact. Alternative 2C shares KOP 836-West with Alternative 2A. At this location Alternative 2C would

be closer and the visual impact would be moderate to high compared to the moderate impact from Alternative 2A. However, 

farther east Alternative 2A would be close to KOPs 838, C2, C3, and C4, as well as the community of Hanna. The overall visual impacts would be much greater from Alternative 2A compared to Alternative 2C. -- For the Segment 2 Conclusion and Figure A-3 in the Draft EIS, we request that the BLM verify the accuracy of Alternative 2C on maps with respect to the 

Wyoming governor's designated corridor through sage grouse core areas.

The hav

Chapter 3 - Visual Resources -- 3.2.2.3 -- 129 -- Table 3.2.23 -- (Refer to Table) -- The Draft EIS needs to be revised to disclose why BIA reservation is listed as RES in some cases and Cult in others.

The 

Chapter 3 - Visual Resources -- 3.2.2.3 -- 156 -- 5 -- If any of Alternatives 7H, 7I, or 7I were to be constructed, H-frame single circuit structures would be required in the Sawtooth NF. -- Visual 19: 7I is listed twice.

Info
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 3 - Visual Resources -- 3.2.2.3 -- 163 -- 3 -- The three southern alternatives, 7H, 7I, and 7J, would connect the 

alignment reference point 7a2, from Alternative 7B, to the Cedar Hill Substation. These three alternatives would share a 

portion of their alignment south of the Sublette Range until crossing I-84. Alternative 7H would travel north of Elba, through the 

Albion District of the Sawtooth NF, and south of Oakley, Idaho, before rejoining the Proposed Route south of Artesian City. 

Alternatives 7I and 7J would continue on a shared alignment farther south of the Jim Sage Mountains as well as south of Almo and the City of Rocks National Reserve while following the Nevada state line before turning north around the western boundary of the Sawtooth NF. Where Alternative 7I would turn northwest, to continue a route through the Cassia Division of 

the Sawtooth NF, 7J would turn west through mostly private lands. Alternative 7I would continue northwest and then turn east 

back to the Cedar Hill Substation. Alternative 7J would continue northwest through private land for approximately 16 miles to a

point where, if this alternative were selected, the Rogerson Substation (as an alternative to the Cedar Hill Substation) would be located. From this point, the alternative would split into two routes; one would head northeast to join with the Proposed Route

Segment 7, while the other would head northeast to join with Proposed Route Segment 9. It is anticipated that Alternatives 7H, 7I, and 7J would be located in more pristine viewing conditions and closer to numerous sensitive viewing areas where contrast 

and impacts to viewers would be higher than comparison portions of the Proposed Route. -- The Draft EIS needs to be revised 

to disclose that the "Rogerson substation (as an alternative to the Cedar Hill substation) ..." does not meet project purpose 

and need. There would still a need for a switching station at the Cedar Hill location, as this is a load location. Accordingly, this 

alternative should be dropped from detailed analysis or revised as previously noted

Thi

Chapter 3 - Visual Resources -- 3.2.2.3 -- 190 -- 1 & 2 -- Alternative 9A – Alternative 9A would cross 5.5 miles of BLMadministered VRM Class IV land designated by the Jarbidge RMP. Alternative 9A is anticipated to conform with VRM Class IV 

objectives (see KOP 440). Alternative 9B – Alternative 9B would cross over 1.6 miles of BLM-administered VRM Class I lands designated by the Jarbidge RMP between MPs 36.8 and 38.4 partially paralleling an existing 138-kV transmission line. It 

would not conform with the Jarbidge RMP because the objective of VRM Class I is to preserve the existing character of the 

landscape. Only natural ecological changes can occur on lands managed as VRM Class I and the level of change to the characteristic landscape must not attract attention (see KOPs 801 and 810). If this route were selected, amendments would be 

needed to change the VRM Class to VRM Class III where it would no longer conform with VRM Class II objectives. See 

Appendix F-1 for proposed amendment language and Appendix G-1 for visual analyses. Alternative 9B would also cross BLMadministered VRM Class IV lands designated by the Jarbidge RMP in numerous separate areas between MPs 0.0 and 53.2, 

paralleling an existing ROW, which allows for change in the landscape setting (see KOP 798). Impact areas along Alternative 9B are anticipated to conform to VRM Class IV objectives. Effects discussed in this chapter for KOP 810 would be dependent upon land use plan amendments to visual requirements. -- The Draft EIS should be revised to delete the term "would cross over X.X miles" and replace it with "would cross X.X miles". The term cross over is confusing in that the reader does not know if "over" refers to above or on top of, or if it refers to cross more than X.X. miles. Additionally, the Draft EIS should be revised to use rounding to the nearest whole number when referring to "approximate" miles or acres. It is inappropriate to use the term

"approximately" with numbers with decimal places out to the tens, hundreds, or thousandths.

The exc

Chapter 3 - Cultural Resources -- 3.3 -- 1 -- 1 -- For non-historic properties, BLM Manual 8100.03.F (BLM 2004a) states that 

“[c]cultural resources need not be determined eligible for the National Register of Historic Places (as in the National Historic 

Preservation Act) to receive consideration under the National Environmental Policy Act.” Cultural resources that are of 

traditional religious and cultural importance, or TCPs, are places that “are valued by the human community” and play an 

important role in that community’s “historically rooted beliefs, customs, and practices” (Parker and King 1992). Walker (2009) indicates that TCPs should be defined so as not to limit the identification of tribal “traditions, beliefs, practices, lifeways, arts, 

crafts, and social institutions.” TCPs could also embrace a “rural community whose organization, buildings, and structures, or patterns of land use reflect the cultural traditions valued by its long-term residents” (Parker and King 1992). This section also presents a suite of mitigation measures to be considered where impacts are unavoidable. As described in this document, mitigation under NEPA does not limit or prescribe the outcome of consultation required under Section 106 of the NHPA and implementing regulations found at 36 CFR Part 800. -- While it is true that the BLM manual states that cultural resources need 

not be determined eligible, the section further states that the goal is to “preserve important historic, cultural, and natural aspects of our national heritage.” What better measure of importance than meeting the National Register criteria? For the 

purposes of this project, we recommend that National Register eligibility be the yardstick for importance. This is especially 

important since there does not seem to be any effort to evaluate sites according to the BLM’s cultural resource manual section 

8130, and we cannot expend the resources necessary for protecting or mitigating sites that are not on, or eligible for, the National Register. Additionally, the Draft EIS introduces the acronym TCP without any definition. While it is true that the term 

TCP is introduced and discussed by Parker and King, the bulletin is advisory and the term has no regulatory definition or legal

standing. IPC prefers that the legal term “properties of traditional religious and cultural importance” as defined in 36 CFR 8100, 

and requests that it be used in lieu of TCP throughout the document. The Draft EIS should be revised to address these inaccuracies.

TexCu
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 3 - Cultural Resources -- 3.3.1.2 -- 2 -- 2 -- The protohistoric overviews provide a general description of the types of 

resources known in the region and reflect changes observed in cultural resource types and assemblages that occur between 

pre- and post-European contact. Historic resources are segregated into broad socioeconomic themes, such as transportation routes, including trails (further subdivided into trails that have been congressionally designated as NHT and other trails and 

routes), railroads, roads, and bridges; settlements including homesteads, ranches, and camps; irrigation works, including canals and ditches; and electric transmission lines. Other sites that are associated with trails, such as important emigrant graves, are treated with those trails. -- This is the first time the acronym NHT is used in this section. The Draft EIS should be 

revised to spell it out and provide a definition the first time it is referenced.

Info

Chapter 3 - Cultural Resources -- 3.3.1.2 -- 2 -- 1 -- Prehistoric resources are divided into site categories that reflect the 

purpose and intensity of aboriginal occupation at specific locations: lithic (chipped stone) scatters, landscapes, and quarries; 

open and sheltered camps, with or without evidence of specialized activities; rock art (petroglyphs and pictographs); and mortuary sites that might include human burials. The protohistoric overviews provide a general description of the types of resources known in the region and reflect changes observed in cultural resource types and assemblages that occur between 

pre- and post-European contact. Historic resources are segregated into broad socioeconomic themes, such as transportation routes, including trails (further subdivided into trails that have been congressionally designated as NHT and other trails and 

routes), railroads, roads, and bridges; settlements including homesteads, ranches, and camps; irrigation works, including canals and ditches; and electric transmission lines. Other sites that are associated with trails, such as important emigrant graves, are treated with those trails. -- The Draft EIS needs to be revised to disclose exactly what each state (Idaho & Wyoming) considers a "site".

Re

Chapter 3 - Cultural Resources -- 3.3.1.3 -- 3 -- 1 -- Adverse weather conditions precluded completion of the sample surveys 

for the Nevada portion of Alternative 7I/7J, survey of which is planned for the 2011 field season. At the request of the BLM 

Kemmerer FO, no sample surveys of Segment 4 alternatives were conducted. Instead, known site data were used in place of 

sample surveys to assess site likelihood along the alternatives (see Section 3.3.2.4). -- This inventory was completed and that

fact stated as such on page 3.3-241. Data from the inventory needs to be included in the final draft. Please adjust text 

accordingly, including the other sections of the document where discussion of the delay of the Nevada inventory occurs.

The as 

sur

Chapter 3 - Cultural Resources -- 3.3.1.3 -- 3 -- Table 3.3-1 -- NHPA column, definition of Federal Undertaking -- Only part of

the definition was included. Please use the entire definition from 36 CFR 8100.16(y)

Infound

Chapter 3 - Cultural Resources -- 3.3.1.3 -- 3 -- Table 3.3-1 -- NHPA column, definition of APE -- Please use the entire 

definition of APE from 36 CFR 8100.16(d) Chapter 3 - Cultural Resources -- 3.3.1.3 -- 3 -- Table 3.3-1 -- NHPA column, definition of Effects -- Only a partial definition of 

an adverse effect is presented. Chapter 3 - Cultural Resources -- 3.3.1.3 -- 3 -- Table 3.3-1 -- NEPA column, definition of Adverse Impact -- An opinion was rendered, not a definition of an adverse impact. Chapter 3 - Cultural Resources -- 3.3.1.3 -- 3 -- Table 3.3-1 -- NHPA column, definition of Adverse Effect -- Please use the 

entire definition of adverse effect from 36 CFR 800.5(a)(1) Chapter 3 - Cultural Resources -- 3.3.1.3 -- 4 -- Table 3.3-1 -- NEPA column, definition of Eligible. “In the professional opinion 

of the EIS preparers, unevaluated resources may be eligible for inclusion in the NRHP.” -- This is an opinion. Sites are just as 

likely to be found ineligible. State instead that “unevaluated sites will be treated as eligible until a final determination has been 

made.” Chapter 3 - Cultural Resources -- 3.3.1.3 -- 4 -- Table 3.3-1 -- NHPA column, definition of Consultation -- Please use the 

definition of consultation from 36 CFR 800.16(f) Chapter 3 - Cultural Resources -- 3.3.1.3 -- 4 -- Table 3.3-1 -- NHPA column, ACHP -- The role of the State Historic Preservation Office was omitted. They are the first line of review on how agencies’ decisions affect historic properties.

Tex

Chapter 3 - Cultural Resources -- 3.3.2.1 -- 4 -- 2 -- Literature Review: The Analysis Area includes those cadastral sections crossed by a 1-mile buffer on Proposed Route and Route Alternatives for a file search in each state, and the ecoregions 

crossed by the Project for published and unpublished literature on the area. -- Insert “. . . from the centerline of . . .” between 

buffer and on.

Info

Chapter 3 - Cultural Resources -- 3.3.2.3 -- 15 -- 2 -- 1. The BLM’s VRM system, which uses a specific inventory system to determine visual impact and to determine whether that impact is consistent with visual land management objectives assigned in the area’s RMP; -- This is the first time that the acronyms VRM and RMP are introduced in this chapter. The Draft EIS needs 

to be revised to spell out and define those acronyms the first time they are referenced.

The it is calacrhavof tAb
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 3 - Cultural Resources -- 3.3.2.4 -- 18 -- 2 -- The viewshed analysis used GIS to evaluate whether transmission line 

towers might be visible by viewers along historic trails and generated two types of viewsheds: a multiple viewshed and an 

individual viewshed. A multiple viewshed analysis combines the viewable areas from several observation points into a single visibility surface. The fieldwork analysis used transmission towers, spaced at 300 feet or 100 meters, as viewpoints. This 

method created a visibility surface 5 miles on either side of the transmission line where the towers would most likely be visible. 

Historic trails/routes were overlaid in GIS on the visibility surface to identify any intersecting trail sections or portions of the trail that needed to be visited in the field. In contrast to multiple viewshed analysis, individual viewshed analysis results in a 

visibility surface that relates to a single observation point. Several KOPs along historic trails were established in the field and 

an individual viewshed was created for each KOP. The individual viewsheds identified the Project segments and alternatives 

that were visible from each KOP. Both viewshed analysis methods assume an average observer eye level of 5.5 feet. Tower height was assumed to be 190 feet for the field viewshed analysis and 180 feet for the KOP analysis. In addition to identifying

each visible Project segment and alternative, the shortest distance from a KOP to the Project segment and alternative was 

calculated in GIS using a straight line, or perpendicular, distance. If a Project segment or alternative did not intersect the viewshed at the shortest distance, then the distance was calculated at an angle from the KOP to the nearest point of 

Project/viewshed intersection. -- The Draft EIS needs to be revised to clearly disclose the rationale for the height assumptions 

given in this paragraph.

The becwavishig

the indbet

and prothe ave

vie

Chapter 3 - Cultural Resources -- 3.3.2.4 -- 19 -- 1 -- Assessment of impacts on cultural resources within the Project’s viewshed assumed a worst-case scenario, in which all viewers would have views toward the proposed Project on a highvisibility day (recommended to be up to 5 miles and beyond) and the KOP chosen for that resource would best represent the 

disparate viewing conditions and viewing opportunities. In September 2009, Idaho and Wyoming BLM authorized use of the following procedure for visual analysis of cultural resources within the Project area -- (No) The Draft EIS needs to be revised to 

delete the phrase “and beyond" and just provide a specific number of miles.

” ...on 

Chapter 3 - Cultural Resources -- 3.3.2.5 -- 20 -- 1 -- The 1,103-mile-long Gateway West Transmission Line can be considered an environmental transect, inasmuch as it crosses several environmental zones from its beginning in east-central Wyoming to its terminus in southwestern Idaho, with one alternative crossing through a portion of northern Nevada. For discussion purposes, it is useful to distinguish the project environmental setting by ecoregion. Ecoregions are defined as “areas of general 

similarity in ecosystems and in the type, quality, and quantity of environmental resources” (USEPA 2007). This is relevant to an understanding of human settlement and subsistence in the Project area, because each ecoregion is characterized to by a distinctive landscape that, to a greater or lesser extent, influenced human settlement and by a complement of essential resources (e.g., potable water, plants, animals, and useful raw materials) upon which the prehistoric and historic inhabitants 

relied for subsistence. Therefore, modern environmental parameters are used to interpret past patterns of human settlement and subsistence. The regional climate has fluctuated dramatically in the 12,000-plus years that humans have occupied these areas of Idaho and Wyoming. A general description of these ecoregions serves as a natural baseline against which the representative cultural resources are compared, with the ultimate purpose of deciding which Project segments (proposed or 

alternative) are least likely to impact significant cultural resources. -- The Draft EIS should be revised to delete "can be considered an environmental transect, inasmuch as it" so the sentence reads "..Transmission Line crosses several environmental zones..."

Info

Chapter 3 - Cultural Resources -- 3.3.2.5 -- 25 -- 1 -- Segment 10 crosses the Snake River Plain. It has no prehistoric 

resources, indicating that its natural resources were sparse. It did, however, support several historic settlements, emigrant 

trails and railroads, and irrigation waterworks, reflecting again the historic growth of settlement in the area. Irrigated farmland is present along the Snake River and near reservoirs -- Is it Segment 10, or the Snake River Plain, that has no prehistoric 

resources? The Draft EIS needs to be revised to clarify this.

The 

Chapter 3 - Cultural Resources -- 3.3.2.5 -- 25 -- 4 -- The Shoshone, Paiute, and Bannock occupied portions of southern 

Idaho, western Wyoming, and northern Utah. As mentioned above, an ethnographic study requested by the Shoshone-Paiute 

and Shoshone-Bannock Tribes is currently underway. In addition to his own reassessment of the Shoshone-Bannock, Walker 

(1993) cites Lowie (1924), Stewart (1939), and Fowler and Liljeblad (1986) as the principal ethnographic sources for the Northern Paiute (Walker 2009). Traditional ethnographies of the Northern Shoshone and Bannock Tribes are Lowie (1909), Steward (1938), Murphy and Murphy (1960, 1986), and Walker (1973, 1978, 1993). -- The Draft EIS needs to be revised to disclose that the ethnographic study requested by the Shoshone-Paiute has been completed.

Tex

Chapter 3 - Cultural Resources -- 3.3.2.5 -- 27 -- 4 -- Previously Recorded Cultural Resources The inventories resulted in the identification of over 200 cultural resources located within the Analysis Area (extending 0.5 mile 

south from the Idaho-Nevada border). Identified sites are all prehistoric in origin and consist of lithic scatters and quarrying areas, many with stone tools, related to locally occurring obsidian and ignimbrite sources. -- The earlier discussion on page 

3.3-27 states that over 200 sites associated with obsidian quarrying were identified, but the last paragraph on page 3.3-34 

states that only seven sites were identified. The Draft EIS needs to be revised to address these inconsistencies.

The from 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 3 - Cultural Resources -- 3.3.2.5 -- 29 -- Tab 3.3.-3 -- (Refer to Table) -- The Draft EIS needs to be revised to disclose 

which of the sites in this table are considered eligible sites and which are considered in-eligible.

The eligsur3.3

stu

Chapter 3 - Cultural Resources -- 3.3.2.5 -- 40 -- 2 -- Power Transmission sites are locations, features, or structures involved 

with the movement of energy from one place to another. Until recently, transmission lines have not been widely recorded as historic sites. The historic context statement written for the Bonneville Power Administration (BPA) (Kramer 2009), and a report 

prepared for the Western Area Power Administration that was submitted to the Colorado and Wyoming SHPOs (Schweigert 1998), will be used to help guide resource evaluation during the Phase II survey. Both documents contain a detailed historic 

context on the design and construction of electrical transmission systems in the western U.S -- This paragraph is inconsistent 

with the Wyoming SHPO/BLM protocol Appendix D, which categorically excludes most power lines, from consideration as 

historic sites. Nevada has a context for transmission lines prepared by Erika Johnson in 2006, the Draft EIS needs to be 

revised to reference and consider this information.

Tru

lineThe resformthetheexhReForackjudeva

Chapter 3 - Cultural Resources -- 3.3.2.5 -- 40 -- last bullet -- Rural sites include buildings, structures, objects, sites, or districts 

associated with human settlement in the non-urban setting. -- The Draft EIS should be revised to provide clear examples of 

what might fall into this category, and how they might not fit into other categories of sites in a rural setting.

The encthe con

Chapter 3 - Cultural Resources -- 3.3.2.5 -- 65 -- 5 -- The cultural files search identified several canal sites within the Idaho Project area. These include water conveyances known as the Twin Falls Main Canal, Milner Gooding Canal, A Coulee Canal, 

High Line Canal, X Canal, Portneuf Marsh Valley Canal, and Bear Lake Outlet Canal. The Proposed Route in Segments 8, 9, and 10 would cross several other unnamed or unidentified canals. -- The Draft EIS needs to be revised to provide a 

description of the Y-Canal, which parallels the X-Canal and has been determined eligible for listing on the NRHP.

Y C

Chapter 3 - Cultural Resources -- 3.3.2.5 -- 68 -- 2 -- Pedestrian cultural resources inventories (a 15 percent sample) were attempted for the Nevada portion of Alternative 7I/7J but the attempt was abandoned due to snow. Surveys are planned for the 

2011 field season (prior to completion of the Final EIS). One site was documented along the Nevada portion of Alternative 

7I/7J. -- This section indicates that the Nevada sample survey was not yet complete, but page 3.3-241 indicates that the survey was completed in July 2011.The Draft EIS needs to be revised to correct or clarify this inconsistency.

Nedro

Chapter 3 - Cultural Resources -- 3.3.3.2 -- 70 -- CUL-3 -- CUL-3 The Cultural Resource and Paleontological Monitoring and Mitigation Plan will include provisions for the preparation 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 -- This stipulation is 

for paleontological resources. We recommend that the Draft EIS be revised to move it to the paleontological section of the EIS.

Ch

Chapter 3 - Cultural Resources -- 3.3.3.2 -- 70 -- CUL-8 -- CUL-8 If human remains are discovered, construction will be halted and the county 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 NAGPRA will 

be followed. -- The Draft EIS should be revised to indicate that there is a completed programmatic agreement (PA) to address 

this issue. The Draft EIS should also be revised to reference appropriate mitigation measures described in the PA.

Tex

Chapter 3 - Cultural Resources -- 3.3.3.2 -- 72 -- 6th bullet -- CR-3, 6th bullet - Acquire or trade land with willing seller(s). -- 

The Draft EIS needs to be revised to indicate the purpose of any land tenurement adjustments and what values that land will 

be managed for.

TheThe 

Chapter 3 - Cultural Resources -- 3.3.3.2 -- 72 -- 7th bullet -- CR-3, 7th bullet - Preserve landscapes from a cultural landscape 

perspective. -- How is this to be done? There is already discussion on preserving

Se

Chapter 3 - Cultural Resources -- 3.3.3.2 -- 72 -- 8th bullet -- CR-3, 8th bullet - Bury elsewhere other (non-Project) lower kilovolt transmission or distribution lines. -- This is a very expensive proposal which will make future maintenance of the line(s) 

extremely difficult and expensive. As a consequence, transmission reliability would suffer. As the Proponent, we would prefer 

The Draft EIS be revised to remove this stipulation, as it does not allow the project to meet purpose and need .

The 

Chapter 3 - Cultural Resources -- 3.3.3.2 -- 72 -- 10th bullet -- CR-3, 10th bullet - Re-vegetate disturbed areas to protect or

restore viewsheds. -- Re-vegetation is covered under other sections of this document. Is it really necessary here?

The 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 3 - Cultural Resources -- 3.3.3.2 -- 73 -- CR-5 -- On NFS lands, a management plan should be developed for each 

historic property nominated to the NRHP. The plan should be drafted during the nomination process. The National Heritage 

Strategy should be used to guide decisions on issues related to the Heritage Program -- The PA, which was developed with Forest Service participation, does not include a stipulation for management plans for each historic property. The Draft EIS 

needs to be revised to remove this stipulation, thereby ensuring consistency with this PA. Additionally, the Draft EIS should be 

revised to clearly disclose that the project proponent's are required to address impacts to cultural resources within the APE, 

not within all NFS lands.

The proas 

Chapter 3 - Cultural Resources -- 3.3.3.3 -- 88,94,109,116,117,122,129,132,134,136,137,138,139,141,146,154,155,200,220,232,234,325 -- Various -- 3.3.3.3 Visual 

Impacts of the Proposed Route and Alternatives by Segment: KOP C43; KOP C45; KOP C51; KOP C15; KOP C12; KOP C27; KOP C110; KOP C42; KOP C7; KOP C8; KOP C11; KOP C28; KOP C29; KOP C30; KOP C121; KOP C10; KOP C41; KOP 

C61; KOP C60; KOP C116; KOP C120; KOP C104 -- This section appears to be inappropriately applied, especially in that it is 

linked to the Wyoming BLM/SHPO Protocol. Section 3.3.2.4 indicates that proposed project elements need "tend to dominate 

the setting" to create the moderate or strong contrast constituting an adverse effect. However, the Draft EIS states that the 

elements would not dominate the setting, yet concludes, contrary to the previous rationale, that there is an adverse effect. The 

Draft EIS needs to be revised to address this inconsistency. Additionally, the Draft EIS needs to be revised to better explain if 

and how the setting is truly a significant historic feature of the site or trail segment.

AphisSeveleres

Chapter 3 - Cultural Resources -- 3.3.3.3 -- 126,127,164,168,169,170;177,178,182,183,184,186,187,188,189,191;209,238 -- 

Various -- 3.3.3.3 Visual Impacts of the Proposed Route and Alternatives by Segment: KOP C38; KOP C39; KOP C24; KOP C22; KOP C23; KOP C65; KOP C23; KOP C66; KOP C67; KOP C78; KOP C73, KOP C74; KOP C75; KOP C76; KOP C77; 

KOP C83; KOP C84; KOP C85; KOP C108; KOP C99 -- This section appears to be inappropriately applied, especially in that it is linked to the Wyoming BLM/SHPO Protocol. Section 3.3.2.4 indicates that proposed project elements need "tend to 

dominate the setting" to create the moderate or strong contrast constituting an adverse effect. However, the Draft EIS states 

that the elements would not dominate the setting, yet concludes, contrary to the previous rationale, that there is an adverse effect. The Draft EIS needs to be revised to address this inconsistency. Additionally, the Draft EIS needs to be revised to 

better explain if and how the setting is truly a significant historic feature of the site or trail segment.

No 

Chapter 3 - Cultural Resources -- 3.3.3.3 -- 144 - 145 -- KOP 57 -- KOP C57 (Figure 3.3-71) is located on a segment of the California NHT – Dempsey-Hockaday Cutoff, 0.5 mile south of Sullivan Hollow. Fontenelle Creek is 2 miles to the north and Willow Creek is 0.75 mile to the south. The Proposed Route in Segment 4 of the Project is 1.4 miles to the north. The KOP is situated on a broad east-to-west trending ridge on a two-track road that bisects the trail. Photographic simulations depicting indirect (visual) impacts to the resource have been generated for this KOP (Appendix E, Figures E.3-23 and E.3-24). -- The analysis states that the project elements would “. . . blend in with the landscape, decreasing their prominence within the view. . .” If that is the case, it seems odd that the Draft EIS concludes they would dominate the setting. The Draft EIS needs to be 

revised to clarify the rationale between these two conclusions.

The disthe 

Chapter 3 - Cultural Resources -- 3.3.3.2 -- 172 -- KOP 70 -- KOP C70 (Figure 3.3-107) is located on a segment of the California NHT – Hudspeth Cutoff, in the canyon for South Fork Sublette Creek, between Eyrie Canyon to the north and Park Canyon to the south. KOP C70 is located approximately 0.8 mile south of Alternatives 7H and 7I/7J. The resource at this location is a bladed road. There are no modern intrusions to the setting at this location. Views of the Project route near this KOP are intermittent and screened in most areas by topography. Due to the KOP’s proximity to the Route Alternatives, the VCR for this KOP is assessed as strong for Alternatives 7H and 7I/7J. The proposed Project elements would dominate the setting; therefore, there would be an adverse impact to the resource at this location -- How can the Proposed project elements dominate the setting when the views of the Project route near the KOP are 

intermittent and screened in most areas by topography? The Draft EIS needs to be revised to clarify the rationale for this conclusion.

Eveparele

Chapter 3 - Cultural Resources -- 3.3.3.2 -- 239 -- KOP C99 -- KOP C99, Figure 3.3-191. “View northwest toward the 

Proposed Route in Segment 10 from Minidoka National Historic Site.” -- The Minidoka National Historic Site (MNHS) is on the 

north side of the North Side Main Canal. Is that the canal visible in the photo, and if so, is the direction indicated correct? The 

view to the northwest includes a number of modern structures, developed agricultural fields, and relocated MNHS structures. 

In the KOP description, it states that the MNHS is northeast of the proposed route. Shouldn’t the photo have been directed to 

the southwest? The analysis states that the project has similarity of design and the potential to blend in with the backdrop. If 

so, why is this considered an adverse effect? What is the property’s significant historic feature, and is it impacted by a change in the setting? If it is the harsh desert environment when the camp was first built, hasn’t that already been diminished by the

number of modern farms that surround the MNHS, and the number of transmission lines in the vicinity leading to the substation to the south? The Draft EIS needs to be revised to address these questions and how this affects the conclusion that 

the project would have an adverse affect.

The The has is cattethis E.3The 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 3 - Cultural Resources -- 3.3.3.4 -- 240 -- 3 -- Historic Value – defined as an ordinal scale with values ranging from 1 

to 4, possibly encompassing two or more criteria of NRHP eligibility. Sites that have standing structures and archaeological 

potential were assigned a value of 4. Intact historic trail ruts might have been placed in this category but direct impacts to such resources are less likely because the trail segments would be spanned by the transmission line. Indirect (visual) impacts to historic trails are much more likely but those impacts are captured by the Overall Visual Impacts variable (see below). Sites 

with standing structures but without archaeological potential were assigned a value of 3. Sites that have archaeological 

potential but no standing structures are slightly less valuable than those with standing structures and were accorded a value of 

2. Finally, historic debris scatters have limited importance and were given a value of 1. For each route, these values were 

summed and divided by the number of resources to achieve a “score” that reflects the Historic Value of resources within that route. More historic resources and higher measures of Historic Value per segment equate to greater impacts -- The Draft EIS 

needs to be revised to insert “unassociated” in front of “historic debris scatters.”

Ch

Chapter 3 - Cultural Resources -- 3.3.3.4 -- 240 -- 3 -- Historic Value – defined as an ordinal scale with values ranging from 1 

to 4, possibly encompassing two or more criteria of NRHP eligibility. Sites that have standing structures and archaeological 

potential were assigned a value of 4. Intact historic trail ruts might have been placed in this category but direct impacts to such resources are less likely because the trail segments would be spanned by the transmission line. Indirect (visual) impacts to historic trails are much more likely but those impacts are captured by the Overall Visual Impacts variable (see below). Sites 

with standing structures but without archaeological potential were assigned a value of 3. Sites that have archaeological 

potential but no standing structures are slightly less valuable than those with standing structures and were accorded a value of 

2. Finally, historic debris scatters have limited importance and were given a value of 1. For each route, these values were 

summed and divided by the number of resources to achieve a “score” that reflects the Historic Value of resources within that route. More historic resources and higher measures of Historic Value per segment equate to greater impacts -- Literature 

Review: Historic Value: Terms: "slightly less value", "limited importance" were used to determine "score" but these terms are 

very vague and could mean different things to different readers. The Draft EIS needs to be revised to provide a better 

description or criteria for these terms.

The Potbut thaelesim

Chapter 3 - Cultural Resources -- 3.3.3.4 -- 241 -- 1 -- Preliminary results of a 15 percent survey along 7I and 7J in Nevada, 

conducted July 2011, were used in evaluating these alternatives. Full survey results will be reported in the Final EIS. Overall, 

the 15 percent survey results are statistically less reliable for comparing routes, given the manner in which the sample was drawn (i.e., confined to Tribal and public lands, from previously unsurveyed areas, on shallower slopes, and in undisturbed areas), but they have modest 

interpretive value and provide valuable insights into the distribution of cultural resources in each segment. Because the magnitude of the 15 percent survey is 

probably influenced by the size of the investigated areas and thereby inflates the assessment of impacts, the raw frequency in each segment has been “normalized” by dividing that number by the segment’s total length. -- (yes) 15% Survey Results: "Full 

survey results will be reported in the FIS.": The Draft EIS needs to revise this sentence so readers understand that full survey results means full 15% survey results.

Tex

Chapter 3 - Cultural Resources -- 3.3.3.4 -- 248 -- Fig 3.3-192 -- (Refer to figure) -- This figure has numerous inaccuracies, including incorrect labeling and the reversal of proposed and alternative routes. The Draft EIS needs to be revised to correct 

these inaccuracies.

Tex

Chapter 3 - Cultural Resources -- 3.3.3.4 -- 262 -- Fig,. 3.3-206 -- (Refer to Figure) -- Page 3-262 and page 3.3-263 are 

duplicates but with different results. Which is correct? The Draft EIS needs to be revised to address this inconsistency.

Gra

Chapter 3 - Cultural Resources -- 3.3.3.5 -- 264 -- Overall -- All -- Based on inaccuracies in route labeling in Section 3.3.3.4, 

how do we know that this section is addressing the maps as shown in Figure A-2?

Ro

Chapter 3 - Cultural Resources -- 3.3.3.5 -- 265 -- 3 -- Table 3.3-9 summarizes historic trail crossings in Segment 1W. As summarized in this table, impacts to significant trail segments would be greatest for the Proposed Route 1W(a), and less so 

with Alternative 1W-A and Proposed Route 1W(c) -- Segment 1W Heading: States Alternative 1W-A would have fewer impacts 

than Proposed Route 1W but Table 3.3-7 (pg 243) states otherwise. The Draft EIS needs to be revised to address this 

inconsistency.

Tab

foc
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 3 - Cultural Resources -- 3.3.3.5 -- 270 -- 1 & 2 -- The Proposed Route in Segment 5 is 54.6 miles long and has a low number of prehistoric (n=21) and historic (n=8) sites, for a ratio of approximately 0.5 site/mile. Previous surveys in this area 

have been limited, which may partially account for the low site density. Intensive agricultural activity in this area may also have 

destroyed many sites. Relative to the five Route Alternatives, the impacts of the Proposed Route are considered to be low. The comparison portions of the Proposed Route would have fewer impacts than alternative routes 5A, 5B, 5C, and 5D, but 

Alternative 5E would have more impacts than the comparison portion of the Proposed Route. 

Table 3.3-14 summarizes historic trail crossings in Segment 5. Impacts to significant trail segments would be greatest for the Proposed Route, followed by Alternatives 5D and 5E and then by Alternatives 5A and 5B. No historic trails would cross Alternative 5C -- Segment 5: Impact comparison for 5B and 5E are inconsistent with Table 3.3.-7 (pg 243). The Draft EIS 

needs to be revised to address this inconsistency.

Tab

foc

Chapter 3 - Socioeconomics -- 3.4.1.4 -- 15-16 -- Tab 3.4-11 -- (Refer to Table) -- The Draft EIS needs to be revised to updatethe information regarding the data referenced in this table. For example, the description of the 2009 data should be changed 

from "estimated" to "actual data. Additionally, all data estimates in this section be updated or replaced with actual data as appropriate.

No 

Chapter 3 - Socioeconomics -- 3.4.1.4 -- 19 -- Tab 3.4-12 -- (Refer to Table) -- If data is available, the Draft EIS should be 

revised to replace the 2005/2006 stats with something more recent.

The 

Chapter 3 - Socioeconomics -- 3.4.2.1 -- 28 -- 2 & 3 -- Under the No Action Alternative, the Proposed Action would not be 

constructed, operated, or decommissioned. There would be no Project-related impacts to socioeconomics. As discussed in 

Chapter 1 of this EIS, the Gateway West Project is needed to supplement existing transmission lines in order to relieve 

operating limitations, increase capacity, and improve reliability in the existing electric transmission grid, allowing for the delivery of up to 3,000 MW of additional energy for the Proponents’ larger service areas, primarily in Utah and Idaho. The 

purpose and need of the proposed Project would not be met under the No Action Alternative and existing constraints coupled with projected increases in demand in the Proponents’ service areas could result in insufficient supply to meet energy demand 

and an increase in the potential for supply outages. These potential impacts could have detrimental socioeconomic impacts, 

with negative impacts to existing businesses and economic activities, as well as businesses and economic activities that might 

otherwise consider locating in the affected service areas. -- The Draft EIS needs to revise this section as necessary to ensureit is consistent with Chapter 1 of the EIS.

Nothe 

Chapter 3 - Socioeconomics -- 3.4.2.2, 3.4.2.6 -- 28, 74 -- 4th full, 3rd -- Estimated construction workforce requirements are 

summarized by EPC contract in Figures 3.4-1 through 3.4-4. These projections were developed for the various Project 

components by the Proponents’ transmission engineering contractor using project planning computer software. Overall, Project construction is expected to occur between June 2013 and December 2018, depending on permitting. The Proponents’ proposed schedule identifies general construction time frames by segment and substation, generally 4 to 5 years (see Table 

2.1-3). Construction times by segment are, however, expected to range from about 8 months to 27 months; similarly, substation construction times would range from 2 to 9 months. This construction would take place within the broader time frames identified in Table 2.1-3 but the exact timing is unknown. In addition, the start of construction could be delayed based

on permitting. This could affect the years identified in the following section, but would not be expected to substantially change the estimated impacts. -- Population: Verify substation construction durations. Maximum of 9 months seems short. Referenced 

in both places.

The info

Chapter 3 - Socioeconomics -- 3.4.2.2 -- 34 -- Fig 3.4-5 -- (Refer to figure) -- The Draft EIS needs to be revised so this figure discloses that substation EPCs and transmission line EPCs would be separate.

Figthe tranideimp

Chapter 3 - Socioeconomics -- 3.4.2.2 -- 42 -- 2 -- Adjusted to 2009 dollars, the HydroSolutions and Fehringer estimates for irrigated fields ranged from $16 per structure for a single pole located along the edge of a field to $300 per structure for an Hframe structure located in the interior of the field. The Power County Task Force’s (2009e) estimated that duplication of 

processes (seeding, fertilization, chemical/pesticide application, cultivation, and harvest) on irrigated cropland would result in 

annual costs of $2,740 per mile, assuming four transmission structures per mile, or $685 per structure. -- Power County 

estimates losses due to loss of development within 60 feet of the easement. Companies do not preclude development outside of the easement and compensation cannot be based on future speculative land use, only on current use and zoning.

Coas Se
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 3 - Socioeconomics -- 3.4.2.3 -- 71 -- 1 -- The City of Rockland in Power County, Idaho, has expressed concern that 

construction of Segment 7 of the proposed Project would hinder potential future growth of the city because this segment of the proposed transmission line would pass approximately 0.5 mile south of the city and cross an area where the City believes 

future growth would be likely to occur. Rockland, which had a total estimated population of 312 in 2009, estimates that this 

would result in foregone revenue from federal highway dollars paid per capita, and from local liquor taxes and property taxes 

(Power County Task Force 2009c, 2009f). These estimates are based on the assumption that 25 households that would 

otherwise move to Rockland over the next 40 years would, as a result of the proposed transmission line, move elsewhere. The 

City of Rockland has also indicated that Alternative 5D, which passes almost 3 miles east of the city at its closest point, would 

have similar impacts, but provided no supporting discussion (Power County Task Force 2010). -- City of Rockland and Power County have made assumptions that the powerline will impact future growth but provide no supporting information. This discussion appears biased towards Power County.

No 

Chapter 3 - Environmental Justice -- 3.5.1.5 -- 5 -- Tab 3.5-2 -- (Refer to Table) -- This Table Header says "Percent of Total Population 2000": The rest of the table says the data is from 2010. The Draft EIS needs to be revised to clarify this or correct 

the inconsistency.

Tab

Chapter 3 - Environmental Justice -- 3.5.1.5 -- 2 -- 2 -- The CEQ and USEPA guidelines indicate that low income populations 

should be identified based on the annual statistical poverty thresholds established by the U.S. Census Bureau. Like minority populations, low income communities may consist of individuals living in geographic proximity to one another, or a 

geographically dispersed set of individuals who would be similarly affected by the proposed action or program. The U.S. 

Census Bureau defines a poverty area as a census tract or other area where at least 20 percent of residents are below the 

poverty level (U.S. Census Bureau 2008b). -- "below the poverty level in Idaho in 2008 was very..." This is referring to Table 

3.5-3 which presents 2009 data. Need to correct 2008 to 2009.

The pub

Chapter 3 - Environmental Justice -- 3.5.2.2 -- 9 -- 2 -- Operation of the proposed Project is not expected to have high and 

adverse human health or environmental effects on nearby communities. Long-term visual impacts would result from the longterm presence of the transmission line structures and overhead conductors. Other long-term visual impacts could include land 

scarring from grading and other construction activities in semi-arid environments where vegetation recruitment and growth are slow. Vegetation would also remain cleared or partially cleared along some portions of the ROW for the operational life of the Project (see Section 3.2 – Visual Resources). -- "vegetation would also remain cleared or partially cleared along some portions..." The use of the term "cleared" gives the impression that the areas are denuded of vegetation. Tall growing 

vegetation may be cleared as needed but low growing vegetation is preferred and reclamation activities will take place. 

Change to "tall growing vegetation..."

The texto g

Chapter 3 - Vegetation Communities -- 3.6.1.4 -- 5 -- 1st bullet -- Digital ortho quarter quad tiles of the Project were 

downloaded from the USDA Farm Service Agency’s National Agriculture Imagery Program (NAIP). This program acquires 1-meter resolution digital ortho imagery for agricultural regions in the United States during the summer crop growing season. The program updates their datasets annually by rotating among states or over regions within larger states; therefore, only a 

portion of the United States is flown each year. NAIP imagery is acquired at a 1-meter ground sample distance with a horizontal accuracy that matches within 6 meters of reference aerial control points, which are used during image inspection. Latest imagery available for Idaho had been flown in 2004 and for Wyoming and Nevada in 2006. This imagery was used for the purposes of initial segmentation. -- This paragraph is unclear regarding the vegetation management requirements for 

construction vs. operations. Add more clarity to the description as to why the area is greater during operations than during 

construction.

Nodurcon

Chapter 3 - Vegetation Communities -- 3.6.1.4 -- 5 -- 1st bullet -- Analysis of ROW clearing and maintenance impact was 

assessed by GIS by overlaying the vegetation with the ROW width. -- Please clarify if this analysis considered the Companyproposed EPMs when evaluating potential impacts. In other words, did the DEIS use only GIS data and not take into account 

how impacts to vegetation would be avoided and/or minimized by EPMs?

Infoconmin

Chapter 3 - Vegetation Communities -- 3.6.1.4 -- 5 -- 2 -- The values reported for operations impacts due to ROW maintenance/clearing may be larger than those reported for construction ROW clearing in some instances (e.g., see Tables 

D.6-2 and D.6-3). This is because the disturbance footprint necessary to construct tower pads and access roads is larger during construction, compared to the permanent footprint of these same tower pads and access roads during operations. In 

addition, some disturbances (e.g., fly-yards) would only occur during construction, and these same areas may be later classified as ROW maintenance disturbances during operations if they occurred within the forested ROW. As a result, the areas classified as “ROW disturbances” compared to the areas classified as “project facility disturbances” can be smaller during construction than during operations. For example, as shown in Figure 3.6-1, the total area disturbed during construction

and operations is identical within this hypothetical forested area; however, the area that would be classified as ROW 

maintenance/clearing is smaller during construction than during operations -- These two sentences seem to contradict each 

other. If the disturbance footprint is larger during construction, how can the operations impacts be greater?

Infocomare paropetha
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.) 

Chapter 3 - Vegetation Communities -- 3.6.1.4 -- 5 -- Figure 3.6-1 -- (Refer to figure) -- We recommend the Draft EIS be revised to include labels and/or a legend of key project features on this figure. Additionally, it is not clear why the figure shows 

operation impacts occurring only on two sides of the structure and not on all four sides since maintenance activities would 

typically require access to all sides of the structure although the majority of work may occur on one side. The narrow strip that is marked “maintained clear for line maintenance” is not correct. Low growing vegetation will occur within and adjacent to the 

structures and would be removed on a periodic basis. Moreover, the Companies are not intending to maintain a cleared area 

to the edge of the ROW. The Draft EIS needs to be revised to correct these errors.

Thialtetex

Chapter 3 - Vegetation Communities -- 3.6.2.2 -- 14 -- 1 -- After construction, the portions of the structure pad not needed for 

normal transmission line maintenance, including fire and personnel safety clearance zones, would be restored to approximate their pre-construction conditions and would be reseeded with a weed-free seed mix. The recovery of vegetation following 

reclamation would vary by plant community type desired following construction (i.e., low-growing vegetation maintained in the ROW for safety). Grasslands and herbaceous wetlands would generally recover within 5 to 7 years. Shrublands may require 

30 to 50 years, and forested and woodland areas could take 50 to 100 years to reach mature conditions. Sites with naturally 

sparse vegetation, saline or alkaline soils, high erosion potential, or shallow soils may be difficult to restore and may require 

special techniques or repeated revegetation efforts. The vegetative communities that reestablish after construction may differ 

from pre-construction conditions if soils are modified during construction due to compaction or by breaking up of hardpans. -- 

"After construction, the portions of the structure pad not needed for normal transmission line maintenance...would be restored...and would be reseeded..." This gives the false impression that the portion of the pad used during maintenance would remain bare ground which is untrue. It will be reclaimed and reseeded as well. The Draft EIS needs to be revised to 

correct this error.

InfoEIS extafte

Chapter 3 - Vegetation Communities -- 3.6.2.2 -- 15 -- last -- Given the dry climate, that construction would occur during the 

summer when the weather is hot and dry, and the vegetation present in the vicinity of the ROW, the potential for fire is 

relatively high. To minimize the potential for wildfires, state and federal fire prevention requirements would be followed. Fire 

prevention measures would include enforcing red flag warnings, providing "fire behavior" training to all pertinent personnel, 

keeping vehicles on or within designated roads or work areas, and providing fire suppression equipment and emergency 

notification numbers. All construction personnel would also be trained in wildfire risk and prevention and adequate fire suppression equipment would be maintained with each construction crew. Fire prevention measures have been developed (refer to Table 2.7-1), which outline the responsibilities of Project personnel for prevention and suppression of fires and define 

minimum fire prevention and suppression measures that would be used during Project... -- The DEIS fails to identify what is 

meant by adequate. We recommend this text in the Draft EIS should be revised as follows: "All construction personnel would also be trained in wildfire risk and prevention and fire suppression equipment consisting of shovels, rakes, and/or Pulaski’s, a 16-20 lb fire extinguisher, and 20-50 gallons of water with a way to effectively spray the 

water (i.e. backpack pumps, water sprayer, etc.) would be maintained with each construction crew. When performing O&M or emergency repair activities during the “closed” fire season in Idaho (May 10 – October 20 each year as set by Idaho State Law, Title 38-115), crews will have the fire suppression equipment as specified in Appendix C-4, p. 16."

The fire Pro

Chapter 3 - Vegetation Communities -- 3.6.2.2 -- 17 -- Fig 3.6-2 -- (Refer to figure) -- We recommend that the Wire zone/border

zone illustration be revised to insert the correct 500kV str. type with delta conductor configuration.

Thi

Chapter 3 - Vegetation Communities -- 3.6.2.2 -- 19 -- VEG-14 -- VEG-14 Where the route would be visible on timbered slopes on lands managed by the Kemmerer FO, allow tree removal only at structure locations and where required for safety rather than from the entire ROW in order to prevent a linear feature on the landscape from clear-cutting trees. Vegetation removal 

requirements will consider Appendix A, Key Standards Relating to Electric System Reliability and Safety, of the MOU with the Edison Electric Institute (2006). -- This is not feasible as a mitigation measure and is a direct contradiction to the intent of the 

MOU cited. The MOU's intent is to perform cover type conversion away from vegetation communities that could interfere with 

the conductors at some time in their life-cycle toward plant communities that will not. A requirement that we not remove trees 

except at structure locations will force us to prune to such an extent as to leave large numbers of tree remnants in the right of 

way. This practice would be unsightly, severely damage or kill existing trees, promote infestations of bark beetles, produce an

unnecessary fire risk, and impose an unreasonable long-term management burden on the company and our rate payers. The 

Draft EIS needs to be revised to remove this mitigation measure. We recommend it be replaced with a mitigation that requires us to feather the right of way, as outlined in the last paragraph of page 21 for the Medicine Bow-Routt and Caribou-Targhee NFs.

Thi
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.) 

Chapter 3 - Special Status Plants -- 3.7.1.1 -- 1 -- 2 -- The Analysis Area for the TES plant species and their habitat was set as 

a 1-mile-wide area centered on the Proposed Route and its Alternatives (a half mile on either side of the centerline of each route), and a 0.5-mile-wide area centered on any access roads that extended outside of the 1-mile-wide route buffer (0.25 mile 

on either side of the access road’s centerline). The Analysis Area, as designed, encompasses all Project components 

including the entire Project ROW, all access roads and ancillary facilities, as well as all staging areas and fly yards. While most 

of the Analysis Area would not be impacted by the proposed Project, information gathered for this larger area allows for an 

understanding of the context in which the impacts would occur and permits an assessment of indirect effects. Potential direct impacts to plants species that are living in the immediate vicinity of construction are limited to the actual footprint of disturbance during construction. Chapter 2 and Appendix B of this EIS provide additional details regarding the disturbance 

footprint that would occur during construction. However, indirect impacts to habitat and to species occupying them would 

extend beyond the footprint during construction. -- Definition of indirect impacts is not only vague (but is better defined 

somewhat later in 3.7.2.2) but potentially incorrect. Indirect effects are defined as impacts removed in either time or space. For 

example, there can be indirect effects that occur within the construction footprint but are removed in time. The Draft EIS needs 

to be revised to provide a clear and correct definition of indirect effects.

No

Chapter 3 - Special Status Plants -- 3.7.1.1 -- 2 -- 3 -- Natural heritage program databases of occurrences within 5 miles of the Proposed Route and Route Alternatives (Idaho Conservation Data Center [CDC] Wyoming Natural Diversity Database [WYNDD], and Nevada Natural Heritage Program). -- The Draft EIS needs to be revised to provide rationale and literature 

citations that support a 5-mile analysis area and clearly identify the species this was applied to.

NocenroaspesomNasurana

Chapter 3 - Special Status Plants -- 3.7-3 -- 11 -- Table 3.7-3 -- (Refer to table) -- The Draft EIS needs to be revised to disclose 

what a blank cell in the table means. For example, does it mean that the particular species and/or its habitat does not occur within the 0.5 or 5-mile analysis area?

Taband

Chapter 3 - Special Status Plants -- 3.7.2.2 -- 23 -- 3 -- TESPL-4 Environmental monitors shall be used to identify and mark aboveground populations of slickspot peppergrass and higher-quality microsites within 50 feet of the construction area, 

including access roads, so that they are avoided by construction equipment and vehicles. Full field clearances shall be 

conducted that meet USFWS protocols prior to construction. No construction shall occur within 50 feet of any slickspot 

peppergrass plant or habitat, including known occurrences of slickspot peppergrass (based on Idaho CDC data) even if 

aboveground plants are not observed during the surveys. Seeding during reclamation must use methods that minimize soil 

disturbance such as no-till drills or rangeland drills with depth bands, in areas of suitable habitat. Reclamation must use certified weed-free native seed. Excess soils will not be stored or spread on slickspots. -- Slickpot Peppergrass: TESPL-4: text 

should be added that surveys would occur only in suitable habitat. As stated it sounds like they would occur on all federal 

lands. 

As 

hab

Chapter 3 - Special Status Plants -- 3.7.2.2 -- 26 -- 3 -- General mitigation measures for vegetation as identified in Section 3.6.1.2 would reduce these impacts to some extent; however, these measures alone do not ensure consistency with Forest 

Service (FSM 2670.32) and conformance with BLM (BLM Manual 6840) policies, which require that impacts to sensitive 

species be avoided or minimized. Measure TESPL-3, as identified by the Agencies and described above, applies to all TES plant species and would require that pre-construction surveys be conducted for other special status plant species that have 

been documented within the analysis area or have the potential to occur in the Analysis Area (Table 3.7-3 above). Therefore, with the implementation of TESPL-3, construction impacts to all TES plants species or populations that are located on lands 

managed by the BLM and/or the Forest Service would be avoided or minimized. Where avoidance is not possible, the Project would apply EPM OM-29, which applies to the relocation of plants. -- TESPL 3 appears to be applicable to all TES plants on 

federal lands. Additionally, the referenced surveys should only be conducted where potential habitat is identified. The Draft EIS 

needs to be revised to clarify this.

TEtha

Chapter 3 -- ESA-listed and Candidate Species -- [blank] -- These sections in the DEIS make determinations regarding the particular species that should be made as part of the BA/BO process. Since the BA has not been provided to the public (and may not be completed) and there is no BO, how can the DEIS make these conclusions? The Draft EIS needs to be revised to 

provide detail on the consultation process that has been conducted to date and in particular, support for the conclusions the 

DEIS makes.

The list
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.) 

Chapter 3 - invasive Plant Species -- 3.8.2.2 -- 9 -- 2 -- Existing invasive plant species may be treated prior to the onset of

construction activities. Because various landowners and land management agencies have differing requirements regarding invasive species, whether an invasive plant species would be treated at a specific location and how it would be treated would 

depend on its status (e.g., is it a noxious weed or not), requests/requirements of the landowner or land management agency, 

the nature and extent of the infestation, and the surrounding conditions (e.g., predominance of invasive species near the 

Project). The following EPMs proposed by the Proponents would be followed during pre-construction treatments, as well as 

during construction activities, to limit the potential spread or introduction of invasive plant species: -- This statement makes it 

seem that measures REC-1 through REC-15 would be implemented during pre-construction and construction activities when 

this is not the case. Furthermore, the DEIS leaves out important clarifying language from the Proponents measures (Appendix c-2, p. 4). The Appendix states “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.” The Appendix also states that measures REC-1 through REC-7 are for pre-construction 

activities. REC-8 through REC-15 are to be implemented during construction activities. The Draft EIS needs to be revised to 

be consistent with the referenced appendix..

Thi

Chapter 3 - invasive Plant Species -- 3.8.2.2 -- 11 -- 1 -- Revegetation of disturbed areas with native species is essential to

limit the spread or establishment of invasive plant species. Therefore, disturbed areas would be revegetated with native plant species adapted to local site conditions to establish long-term, productive, self-maintaining plant communities that are 

compatible with existing land uses. The final Reclamation Plan would include success criteria for determining whether 

revegetation efforts have been successful and what remediation requirements would be implemented if the success criteria 

are not met. The Framework Reclamation Plan for Construction Activities in Appendix C-2 provides details of the proposed revegetation activities -- The Draft EIS erroneously states that disturbed areas will be reseeded with native species. While native species may be used in certain locations, nonnative species will also be used as appropriate (e.g., when reseeding is conducted as a stabilization measure or to keep out invasive species such as cheatgrass or to meet specific landowner 

requests). The Draft EIS needs to be revised to disclose this.

Info

Chapter 3 - invasive Plant Species -- 3.8.2.2 -- 13 -- 4 -- Revegetating disturbed areas with “desired vegetation” promptly after 

the initial disturbance (as outlined in the Proponents’ EPM OM-17) is an essential component needed to limit the spread and establishment of invasive plant species; however, “significantly disturbed areas” are not explicitly defined within the Revised

Plan for Operations, Maintenance, and Emergency Response Activities. The Proponents would need to clearly define this term, in order to ensure that they (the Proponents or construction contractor) would adhere to the commitment to revegetate all

disturbed areas that are not permanently occupied by Project facilities. In addition, measures would be needed to stabilize any

areas that cannot be revegetated within a reasonable time after initial disturbance (potentially due to unforeseen environmental conditions). -- PacifiCorp will submit a revised plan of operations addressing the concerns expressed in the 

Draft EIS. We recommend the Draft EIS be revised to disclose this. Send to Brian for re-write.

The 

Chapter 3 - invasive Plant Species -- 3.8.2.2 -- 13 -- Weed-5 -- During operations, access roads and maintenance areas shall 

be surveyed annually between May 1 and September 30 (or as determined by Agency staff) for the presence of new weed 

introductions and existing invasive plant species. Coordinate with Agency specialists to identify the most appropriate time for

survey. A weed control program would be implemented if new weeds were found, which would define how and when these invasive plants would be treated. Weeds shall be treated before their seed heads have become viable, or if heads will become viable, whole plant removal of all weeds shall occur before seed drop occurs. -- Committing to hand pulling of weeds will be a labor-intensive and expensive control measure. If properly monitored, weed infestations can more easily be controlled with herbicides. We recommend the Draft EIS be revised to delete the last sentence of this mitigation measure.

The me
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 3 - Wetlands and Riparian Areas -- 3.9.1.3 -- 3 -- 2 -- There are no specific laws protecting riparian areas; however, the land management plans of federal agencies provide protections for riparian areas including BLM’s no net loss of 

wetland/riparian habitat policy. Federal agency management goals are to maintain, restore, and improve riparian areas to 

protect water quality, improve water retention and groundwater recharge, provide wildlife habitat, support biodiversity, and 

other goals. The BLM and Forest Service evaluate the functional condition of riparian areas using a qualitative method called 

assessment of proper functioning condition (Pritchard 1998). “Properly functioning” means the hydrological, vegetation, and 

soil erosion/deposition components on a stream system are in working condition, are resilient to disturbance, and provide 

adequate vegetation, landform, or debris to protect water resources, habitat, and biodiversity. Proper functioning condition can 

be applied for both lotic (streams) and lentic (ponds, wetlands) systems. The evaluation procedures for delineating the 

condition of these areas are different for each system and are more clearly defined in the BLM technical documents (Burton et al. 2008; Smith 2008). The assessment of proper functioning condition should be used in conjunction with more quantitative 

methods; it is not a substitute for monitoring but a tool for identifying smaller scale areas (step-down process) -- We 

recommend that the Draft EIS be revised to provide a citation for this policy.

The DeAct 

Chapter 3 - General Wildlife & Fish -- 3.10.1.1 -- 2 -- 2 -- The Analysis Area, for the purposes of terrestrial wildlife habitat, was 

set as a 1-mile-wide area centered on the Proposed Route, the Route Alternatives, and access roads (0.5-mile on either side of the centerline of each route or road), and a 0.5-mile buffer around all fly yards, laydown yards, staging areas, and 

tensioning/splicing sites (see Section 3.1 – Introduction). This distance was chosen so that indirect effects to wildlife would be 

captured. While ground clearing and the transmission line itself would take up only a small percentage of the Analysis Area (approximately 40,300 acres of the 16,082,500-acre Analysis Area cleared during construction, or 0.3 percent), it is necessary 

to utilize an Analysis Area that extends beyond the limits of direct impacts in order to capture the areas that may experience indirect impacts. Direct impacts to habitat and to species living in the immediate area of construction would occur at the actual footprint of disturbance during construction, which includes the clearing of vegetation and other activities at construction areas 

for each transmission structure, access roads, laydown yards, fly yards, and tensioning and splicing areas. Indirect impacts 

would extend beyond the location of construction and operations activities and include noise and edge effects (see Construction under Section 3.10.2.2 for a discussion of edge effects). Construction- and operations-related noise, including from helicopters, is expected to attenuate below annoyance levels in less than 0.5 mile (see Section 3.23 – Noise). This bufferwould also include edge effects caused by vegetation removal. Therefore, the Analysis Area would encompass most indirect 

effects to wildlife -- There is a lack of supporting documentation in this section for the 1 mile analysis area (0.5 miles either 

side of centerline). The Draft EIS needs to be revised to provide the supporting data and rationale upon which this assumption 

is based.

NobelThisom

Chapter 3 - General Wildlife & Fish -- 3.10.1.3 -- 5 -- last -- ...The USFWS has since released some documents providing 

interim guidance for external partners on how to avoid violating the Eagle Act, including a document specifically for golden eagles (Pagel et al. 2010; USFWS 2010a). These documents describe suggestions for consultation with agencies, what analyses to conduct and include in documents, and survey protocols. -- Pagel et al. (2010) describes general protocols to 

conduct surveys for golden eagles. However, the USFWS 2010a reference is a region 8 document and it is not clear why it is included in this DEIS. While region 8 include Nevada, which does include a short segment of an alternative route, it is incorrect 

to imply that the document applies to the entire project. Idaho is part of the USFWS’s region 1 and Wyoming is part of region 

6. The text acknowledges that the USFWS documents are “suggestions” for analyses and survey protocols, but then require 

that all are adhered to. The DEIS incorrectly cites Smith 2010 (a HawkWatch raptor migration study). IPC believe they meant to cite Pagel et al. 2010. Both the Pagel et al. 2010 and the USFWS 2010a documents are interim documents and are therefore subject to change. IPC needs more specific information and or guidance than “All suggestions for analyses and survey protocols issued by the USFWS”.

Adabo
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 3 - General Wildlife & Fish -- 3.10.1.4 -- 9 -- 1 -- ...in portions of the Twin Falls, Pocatello, Kemmerer, Rock Springs, 

and Rawlins BLM FOs from April 1 through April 28, 2008. Raptor species present in the Analysis Area are analyzed in this 

section regardless of whether they are sensitive or have special status. Special status raptors are also addressed in Section 

3.11 – Special Status Wildlife and Fish Species. Ravens (Corvus corax) are included in the raptor discussion because of their importance as predators to many species and their tendency to increase along transmission lines (Engel et al. 1992). Seven 

previously unrecorded active raptor nests were identified: two active bald eagle nests, one golden eagle nest, one red-tailed 

hawk nest, one unidentified raptor nest, and two raven nests (Tetra Tech 2009a). Ground surveys for raptor nests were 

conducted along a portion of Segment 2 in the Rawlins FO on June 4 and 5, 2008. No active nests were discovered during the 

ground surveys, while one inactive golden eagle nest was observed. Field searches for northern goshawks (Accipiter gentilis) 

and flammulated owls (Otus flammeolus) were also carried out in June 2009 on the Caribou-Targhee NF, in accordance with the Caribou Forest Plan. Surveys for northern goshawks were also carried out in July 2010 on the Medicine Bow-Routt NFs, in 

accordance with the Medicine Bow Forest Plan. Neither of these surveys found any territorial birds or active nests -- Engel et al (1992) did not find an increase in ravens along a transmission line. Rather, they determined that ravens already present in 

the area started roosting in large numbers on a newly built transmission line. Please see Attachment A for additional comments on predation and greater sage-grouse.

Ch

Chapter 3 - General Wildlife & Fish -- 3.10.1.4 -- 9 -- last -- To assess the impact of fragmentation on habitat, the current level of fragmentation was compared to the expected level that would occur following construction. Fragmentation caused by roads, transmission lines, and both roads and transmission lines was analyzed. Fragmentation from transmission lines was analyzed 

separately to account for species that will readily pass under or over them. Some species, however, may avoid areas containing transmission lines, so these structures would contribute to fragmentation of their habitat. The levels of fragmentation (current and expected) were assessed within an 8-mile buffer centered along the Project’s route. Because 

Project-specific remote sensing was not conducted out to this distance, regional GAP data were used for habitat types and 

locations. The current conditions were first assessed via GIS analysis, using existing developments (excluding transmission lines) and natural breaks in habitat types. Existing roads were shown on the ESRI “Streetmap” data layer, and other developed 

areas were retrieved using GAP data. These data were used to calculate road densities within the 8-mile-wide buffer. The data 

baselayer used to assess existing transmission lines was the ESRI “Powermap” data layer. Expected levels of fragmentation were assessed by adding the proposed roads to the existing road fragmentation data, and the expected transmission route to 

the existing transmission fragmentation data. All these data sets were then combined into one data layer, which represented the expected level of fragmentation from existing roads, developments, and transmission lines, plus the addition of the proposed roads and transmission lines. These data allowed the assessment of the number of fragments and the average... -- The DEIS needs to provide the specific species and literature citations to support these statements.

By tranis d

Chapter 3 - General Wildlife & Fish -- 3.10.2.2 -- 20 -- 1 -- The Proponents have attempted to minimize fragmentation resulting

from the Project by avoiding routing the line through large blocks of contiguous habitat. The primary way in which the Project would affect the degree of fragmentation is through the clearing of vegetation for the ROW and access roads. For some species, the generally 8-foot-wide permanent access roads (14 to 16 feet wide during construction) could serve as a barrier to 

movement, thereby isolating subpopulations and increasing the risk of local extirpation. (This would be predominantly 

experienced by smaller species or those less likely to move through open areas devoid of vegetation such as the pygmy rabbit, discussed in Section 3.11 – Special Status Wildlife and Fish Species). Although roads may not serve as a barrier to 

movement for all species, roads can reduce habitat quality by creating edge effects (discussed below). As the effects of fragmentation differ depending on the species considered, specific effects of fragmentation on individual species groups will not be addressed within this general habitat fragmentation discussion, and will instead be addressed within the speciesspecific discussions in this section and in Section 3.11. -- The DEIS needs to provide the specific species and literature 

citations to support these statements.

Ad
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 3 - General Wildlife & Fish -- 3.10.2.2 -- 22 -- 2 -- Temporary (occurring during the construction period only) impacts

on habitat would include the clearing/use of laydown yards or fly yards for storage and assembly of equipment and structures 

during construction. Areas that contained native vegetation prior to construction would be restored in accordance with the 

Proponents’ Reclamation, Revegetation, and Weed Management Plan (mitigation measures WEED-1 through WEED-6 in Section 3.8 – Invasive Plant Species). Areas not containing native vegetation prior to construction would be successfully 

reseeded with native vegetation, but there would be no ongoing effort to keep surrounding non-native species from encroaching onto the disturbed area, except on federal land. This would be in accordance with EO 13112, which requires 

federal agencies to prevent the introduction of invasive species and to not cause or promote the introduction or spread of 

invasive species (see Section 3.8.1.3). All revegetation efforts would be conducted in accordance with landowners’ or land 

management agencies’ requirements. Seed mixtures for use on private lands would be prearranged with the landowner (WEED-1, OM-17). Therefore, the spread of noxious weeds due to construction of the Project is not expected to have an appreciable impact on wildlife habitat. In addition, the Proponents have proposed to reduce the construction-related impacts on habitat through dust control during construction (EPM AR-2, Appendix C-1). -- "Areas not containing native vegetation prior to construction would be successfully reseeded with native vegetation, but there would be no ongoing effort to keep surrounding non-native species from encroaching onto the disturbed area, except on federal land." It is not practicable to 

manage a narrow stretch of land to reintroduce native vegetation when it intersects large populations/infestations of nonnative/noxious weeds without the adjacent lands being managed as well.

A nwepriocon

Chapter 3 - General Wildlife & Fish -- 3.10.2.2 -- 22 -- WILD-12 -- Any areas that may require blasting will be identified and a 

blasting plan will be submitted to the appropriate agency for approval. Blasting within 0.25 mile of a known sensitive wildlife

resource will require review and approval by the appropriate agency. -- "WILD-12 Any areas that may require blasting will be 

identified and a blasting plan will be submitted to the appropriate agency for approval. Blasting within 0.25 mile of a known 

sensitive wildlife resource will require review and approval by the appropriate agency." What is the procedure and timeframe in

which the appropriate agency will provide review and approval?

The pro

Chapter 3 - General Wildlife & Fish -- 3.10.2.2 -- 23 -- 2 -- Indirect effects on habitat during the construction period would 

include fugitive dust dispersing from the immediate construction area and air pollution from the diesel motors used by the construction equipment. Impacts from fugitive dust and air pollution would last longer than the construction timeline. High levels of fugitive dust can impact the growth of some organisms, especially mosses and lichens, and impact drinking water. 

The effects of air pollution could include an increase in the acidity of rain, which could harm plants and amphibians, and 

contribute to global climate change. Most impacts from fugitive dust would last only until the next rain event, when the dust is 

washed away and diluted. The immediate impacts from air pollution caused by vehicles would decrease in a matter of hours 

as particles dilute in the air and settle out; however, the exhaust could combine with other effects of air pollution and cumulatively have a more lasting effect. -- The Draft EIS needs to be revised to clearly disclose what the specific “other effects 

of air pollution” would be and which species found in the project area would be affected.

Air rev

Chapter 3 - General Wildlife & Fish -- 3.10.2.2 -- 26 -- 1 -- The Proponents have proposed to supply monitors to determine seasonal occupancy of various big game restricted areas. The Agencies reject the monitoring proposal and require that only 

appropriate Agency personnel may determine presence or likely presence of big game species in restricted areas. Therefore, 

the Agencies have identified the following measure to reduce impacts to big game: -- This paragraph states that the agencies 

may be the only ones to determine presence of big game in restricted areas yet the Proponents EPM (including monitoring) is still included. If this monitoring is acceptable, occupancy decisions by monitors should be acceptable as well. We recommend 

the Draft EIS be revised to correct this inconsistency.

Se

Chapter 3 - General Wildlife & Fish -- 3.10.2.2 -- 33 -- WILD-8, Tab 3.10-3, -- Flight diverters will be installed and maintained 

where the transmission line crosses rivers at the locations identified in Table Chapter 3 - General Wildlife & Fish -- 3.10-3. The 

flight diverters will be placed on at least one of the higher conductors or ground wires at each river crossing in order to reduce avian collisions. Additional locations may be identified by the Agencies. -- MM states that diverters must be installed, however, 

no guidance as to how often (one per span). Need to make sure this is clarified in EPC Specs and POD 

ThidireMBPow
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 3 - General Wildlife & Fish -- 3.10.2.2 -- 34 -- 1 (under Raptors heading) -- Direct impacts on raptors during 

construction could include collision with Project structures, electrocution, disturbance due to construction noise, fugitive dust, 

and visual disturbance. Raptors are particularly sensitive to disturbance during nesting and brooding, and some construction activities could cause nest failure or abandonment. In order to minimize the risk of this, the Proponents would follow timing restrictions and monitoring requirements enforced by the Agencies to reduce disturbance to nesting raptors (see Appendix I). All suggestions for analyses and survey protocols issued by USFWS (Smith 2010; USFWS 2010a) would also be adhered to. Federal, state, and local jurisdictions have requested minor changes to the Project’s design and additional changes will also 

likely occur prior to the Final EIS. Therefore, the BLM and cooperating agencies have identified the following mitigation measure: -- "Direct impacts on raptors during construction could include collision with Project structures, electrocution, 

disturbance due to construction noise, fugitive dust, and visual disturbance." Also on page 36 (3rd paragraph from bottom) it states: "The Proponents’ Avian Protection Plan states that if mortalities due to electrocution are documented, changes to the 

distribution lines would be made in order to avoid future mortalities (such as by changing the arrangement of the power lines or by excluding birds from certain areas). Therefore the potential for raptor electrocution would be minimal." The Proponents will

construct distribution lines in accordance to avian safe standards, thereby effectively eliminating or greatly reducing the risk of electrocution even further than what is inferred in the DEIS. 

Pa

Chapter 3 - General Wildlife & Fish -- 3.10.2.2 -- 36 -- WILD-6 -- As part of their annual aerial flight line maintenance activities, 

the Proponents would document nesting activity (by species) on any towers constructed as a result of this Project. This would 

occur after the first year of construction until year 10 of operations. Results would be provided to the applicable land management agency. -- "WILD-6 As part of their annual aerial flight line maintenance activities, the Proponents would 

document nesting activity (by species) on any towers constructed as a result of this Project. This would occur after the first 

year of construction until year 10 of operations. Results would be provided to the applicable land management agency." What 

is the purpose of such a survey and data? The Companies do not see an appreciable benefit to raptor species by conducting such an annual survey for ten years. Justification for such a requirement must be provided.

The 

Chapter 3 - General Wildlife & Fish -- 3.10.2.2 -- 40 -- last -- The Proposed Route would affect 5,022 acres during operations from ROW maintenance tower bases, permanent access roads, and areas encompassed by substations (Appendix D, Table D.6-3).... -- The DEIS implies that this is a new impact and appears to double count impacts. Tower bases, permanent roads, 

and substation impacts are permanent and have been accounted for in the construction impacts. The Draft EIS needs to be 

revised to clearly differentiate between temporary and permanent impacts.

Rebegcon

Chapter 3 - General Wildlife & Fish -- 3.10.2.2 -- 40 -- 1 from bottom -- Outside of the permanent ROW, vegetation would be 

allowed to regrow. Although this is classified as a “temporary” impact, in the case of sagebrush, for example, it would affect 

several generations of wildlife that depend on this habitat type, such as sage sparrows, until vegetation could grow back and 

regain its wildlife habitat function. Vegetation removed within the permanent ROW would be maintained every 3 to 10 years 

(annually in some places where vegetation grows quickly) so that only grasses, forbs, and other low-growing plants would be 

present during the life of the Project. -- "Outside of the permanent ROW, vegetation would be allowed to regrow. Although this is classified as a “temporary” impact, in the case of sagebrush, for example, it would affect several generations of wildlife that 

depend on this habitat type, such as sage sparrows, until vegetation could grow back and regain its wildlife habitat function. Vegetation removed within the permanent ROW would be maintained every 3 to 10 years (annually in some places where 

vegetation grows quickly) so that only grasses, forbs, and other low-growing plants would be present during the life of the 

Project." Vegetation would be allowed to grow within the permanent ROW. The above quotes are somewhat misleading. It 

should be clarified that "tall-growing" species that are not compatible with power lines are removed and low growing species encouraged.

Thi
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 3 - General Wildlife & Fish -- 3.10.2.2 -- 41 -- 3 -- Existing road densities on the Proposed Route vary from 1.3 to 2.2 

miles of road per square mile. Resulting road densities after the Project is completed would vary from 2.1 to 2.7 miles of road

per square mile. The impacts of fragmentation from roads would vary by species. While big game species can easily cross 

roads, for example, smaller or less mobile animals could experience some habitat fragmentation from the presence of roads. 

(See the discussion of fragmentation effects found in the previous Construction section, because these effects would continue 

through Project operations.) Trees adjacent to roads and the transmission line would also be trimmed to keep branches from blocking roads or coming into contact with the transmission line. This could increase the effects of fragmentation and edges somewhat. Fragmentation could also be caused by the transmission line itself. Although transmission lines are not typically 

considered contributors to habitat fragmentation except in forests, there is concern that some sagebrush-associated wildlife 

species, such as the greater sage-grouse, avoid tall structures (see grouse discussion in Section 3.11.2). Therefore, the transmission poles and line may contribute to habitat fragmentation in the sagebrush habitat type by inducing some wildlife 

species to avoid the area. Tables D.10-3a and b in Appendix D list the number and average patch size of fragments resulting 

from existing roads and compare this to the post-construction conditions along each segment and alternative. Tables D.10-4a and b in Appendix D make the same comparisons as Tables D.10-3a and b; however, they consider only transmission lines as 

the source of fragmentation. Tables D.10-5a and b in Appendix D compare the pre- and post-construction levels of fragmentation when roads and transmission lines are considered jointly. -- These statements imply that other species will avoid transmission lines but does not provide the specific species or literature to support the statement. The Draft EIS needs to be revised to provide rationale and supporting data for such statements.

Avoadd

tha

Chapter 3 - General Wildlife & Fish -- 3.10.2.2 -- 41 -- last -- Disturbance from maintenance activities associated with the 

Proposed Route may cause wildlife to avoid certain areas. In habitat types similar to those in the Analysis Area, deer and elk have been shown to avoid areas within 650 feet of roads, including roads used only by four-wheelers (Rost and Bailey 1979). 

Therefore, although the presence of a road in itself may not cause habitat fragmentation for large species such as deer and elk

due to breakup of contiguous habitat, roads may fragment habitat by disturbing animals and keeping them away from roads. In 

a study on roads’ effects on elk, Lyon (1983) reported that with a road density of 1 mile per square mile, habitat effectiveness 

for elk declined by at least 25 percent. In a study in southwest Wyoming, densities of sagebrush obligates, particularly 

Brewer’s and sage sparrows, were reduced by 39 to 60 percent within a 330-foot buffer around four unimproved, dirt roads 

with traffic volumes of 10 to 700 vehicles/day associated with natural gas exploration (Ingelfinger and Anderson 2004). Studies

elsewhere have shown no effect to grassland birds (bobolinks and meadowlarks) at traffic volumes of 3,000 to 8,000 vehicles/day on a small local street; however, effects were detectable up to 3,940 feet away from the road when traffic 

volumes rose to 30,000 vehicles/day on a multilane highway (Forman et al. 2002). Most access roads would be used 

approximately once per year by Proponents’ staff, though substations would be accessed approximately once per month. Only 

minimal vegetation management would be necessary over most of the route, as the naturally occurring vegetation is lowgrowing. Annual post-construction surveys would be carried out by the Proponents for a minimum of 3 years to ensure that 

reclamation is successful, or as decided by the land-managing agency (Appendix C-2). -- "Disturbance from maintenance 

activities associated with the Proposed Route may cause wildlife to avoid certain areas." Should read: "Disturbance from 

maintenance activities associated with the Proposed Route and Route Alternatives may cause wildlife to avoid certain areas."

Ch

Chapter 3 - General Wildlife & Fish -- 3.10.2.2 -- 44 -- last -- An operations impact that could impact big game is increased 

human presence in the Analysis Area. Project-related operations activities include biannual helicopter flights over the line and 

approximately annual access by truck, all-terrain vehicle, and foot. See Appendix C-4 for more details on operations and 

maintenance activities. Vehicle, helicopter, and human presence could impact big game animals by disturbing them and 

displacing them temporarily from preferred habitat areas, including from winter range and parturition areas. This displacement 

could cause animals to move to areas containing less quantity or quality of forage, increase exposure to predation, or affect 

reproductive activities. On winter range, disturbance could affect winter survival by causing animals to mobilize energy 

reserves that are needed to survive the winter. A decrease of energy reserves in females during the winter could also cause decreased reproductive success, by preventing pregnancy, causing fetal loss, or resulting in less fit offspring. Disturbance byhumans and vehicles in the Analysis Area could also impact reproductive success if females are sufficiently disturbed to not provide adequate care for young. The Proponents would not conduct operations and maintenance activities on winter range 

during closure periods (see Appendix C-4). Unauthorized use of the ROW could also increase harvest of big game animals. To reduce an increase in big game harvest due to unauthorized use of Project-related roads, the Proponents would install gates or other barriers. -- "Project-related operations activities include biannual helicopter flights over the line and approximately 

annual access by truck, all-terrain vehicle, and foot." This reads as though there is annual access by truck, ATV and foot. The

Draft EIS should be revised to read "Project-related operations activities include biannual helicopter flights over the line, 

approximately annual access on-the-ground using trucks or all-terrain vehicles, as well as periodic foot traffic as needed."

Ch
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 3 - General Wildlife & Fish -- 3.10.2.2 -- 46 -- last -- Project operation is expected to have only minor impacts to most 

migratory bird and game bird individuals, including Species of Conservation Concern and Game Birds Below Desired Condition, because the presence of the transmission line, structures, and access roads do not present barriers to movement through fragmentation, create... -- The Draft EIS needs to be revised to disclose the species that comprise “Species of 

Conservation Concern and Game Birds Below Desired Condition”.

Ad

Chapter 3 - General Wildlife & Fish -- 3.10.2.3 -- 60 -- Conclusions -- Habitat Fragmentation The habitat type that would see the greatest number of additional patches created by the Proposed Route would be grasslands, with 369. The habitat type that would experience the greatest drop in average patch size by construction of the 

Proposed Route, Segment 1E is forest/woodlands, with a decrease of 416 acres. The habitat types that would be least affected by fragmentation by construction of the Proposed Route along Segment 1E are riparian/wetland and agriculture/disturbed. Alternative 1E-A would result in a similar number of patches as the comparison portion of the Proposed Route in all habitat types, but would decrease the average size of remaining patches over the Proposed Route in shrublands, 

grasslands, and riparian/wetland. Average patch size would be bigger than along the comparison portion of the Proposed Route under Alternative 1E-A in forest/woodlands, and agriculture/disturbed. Alternative 1E-B would result in smaller average 

patch size than the comparison portion of the Proposed Route only in agriculture/disturbed. It would create more patches than 

the comparison portion of the Proposed Route would in forest/woodland, grassland, and agriculture/disturbed. Alternative 1EC would cause less fragmentation than the comparison portion of the Proposed Route in all five habitat types except for 

grasslands. Alternative 1E-B would result in the smallest decrease in average remaining patch size as compared to the 

comparison portion of the Proposed Route, while Alternative 1E-A would result in the smallest increase in patch counts. -- 

Habitat Fragmentation: Sentence dealing with 1Wc discusses increase on fragmentation acres/patches. The Draft EIS should 

clearly disclose the rationale for this conclusion considering that 1Wc would be located in habitat already fragmented by an existing line with an existing road access system.

HasegconconMeHa

Chapter 3 - General Wildlife & Fish -- 3.10.2.3 -- 65 -- Fish -- There are two stream crossings proposed for Segment 3 (three on BLM-managed land and three on private land), and a total of 8 acres of riparian vegetation would be cleared for construction. Of these 8 acres, 1 are on federal land, administered by the BLM. During operations, 1 acre of riparian 

vegetation would remain cleared (Tables D.9-1 and D.9-2 in Appendix D). -- Clarify stream crossing sentence. The sentence 

starts by stating 2 crossings but in the parenthesis, it discusses 3 on BLM and 3 on private lands.

Thi

Chapter 3 - General Wildlife & Fish -- 3.10.2.3 -- 77 -- Top -- Alternative 7J, which is a variant of the State Line Route also

proposed by local landowners, would not terminate at the Cedar Hill Substation. This alternative, referred to as the Rogerson Alternative, would require a different substation be constructed near a 345-kV existing transmission line (approximately 24 miles southwest of the Cedar Hill Substation; see Appendix A, Figure A-9). The tables and discussion in this document 

compare 7J (202 miles) with the corresponding portion of Segment 7/9 (118.1 miles of Segment 7 and 25.8 miles of Segment 9, for a total of 143.9 miles). All other Segment 7 alternatives are compared to Segment 7 of the Proposed Route (118.1 miles) 

only. -- Segment 7: Reference to Rogerson Alternative states that it would not terminate at Cedar Hill but rather 24 miles 

southwest. However, the Draft EIS needs to be revised to disclose that there would still be the need for a station of some sort

at Cedar Hill to meet the project purpose and need to provide safe and reliable power.

Thi

Chapter 3 - General Wildlife & Fish -- 3.10.2.3 -- 80 -- Fish -- A total of 18 stream crossings are proposed for the Proposed Route of Segment 7. Of those on federal land, 7 of the 11 along Alternative 7I would be on NFS land. There would be 5 acres 

of riparian vegetation cleared during construction of the Proposed Route, less than 1 acre of which would be kept clear during 

operations. Of the riparian vegetation removed that is on federal land, there is 1 acre along Alternative 71 and less than 1 acre 

along Alternatives 7I and 7J that lie on NFS land. Table 3.10-32 compares the Proposed Route of Segment 7 with Alternatives 

7A through 7J in regard to construction impacts to fish resources. -- 5th sentence states "there is one acre along Alternative 71 and less than one acre along 7I and 7J..." The Draft EIS needs to be revised to clearly disclose what Alternative 71 is. If this is 

a typo, it needs to be corrected.

Typ
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 3 - General Wildlife & Fish -- 3.10.3 -- 101 -- 2 -- WILD-7 On federal lands, guy wires should be marked with bird 

deterrent devices to avoid avian collisions with structures on public lands (I.M. 2010-022). -- I.M. 2010-022 is misapplied and is 

specific to Wind Energy structures including turbines and MET tower supports. I.M.2010-022 states: Wind Energy Associated Structures • To reduce the risk of collisions, avoid the use of guy wires for turbine or MET tower supports. All existing guy wires should be 

marked with recommended bird deterrent devices. • The siting of new temporary MET towers must be avoided within 2 miles of active sage-grouse leks, unless they are out of the direct line of sight of the active lek. Comments of the U.S. Fish and Wildlife Service to the FCC on 47 CFR Parts 1 and 17, WT Docket No. 03-187, FCC 06-164, Notice of Proposed Rulemaking, “Effects of Communication Towers on Migratory Birds” http://www.wirelessestimator.com/t_content.cfm?pagename=FWS%20Response FCC NPRM Request: “We seek comment on the effectiveness of [guy] wire markings in mitigating migratory bird collisions with 

communication towers.” (p. 67514)

Re

Chapter 3 - Special Status Wildlife & Fish -- 3.11.1.1 -- 2 -- 1 -- ...In addition, data on some TES wildlife and fish species are 

currently available for broad areas adjacent to, but outside of the original Analysis Area; therefore, the Analysis Area for some TES species was expanded to include this known information. Table 3.11-1 summarizes these known data, as well as their 

spatial extent and the extent that they added to the original Analysis Area. Gray wolf (Canis lupus) Known locations of wolf 

packs -- It appears that the DEIS is expanding the Analysis Area simply because data are available and not because there is information that would support the assertion that the project could have an impact on a species at a certain distance. It is inappropriate to define an Analysis Area based on data without consideration of the impacts you are trying to assess.

No 

Chapter 3 - Special Status Wildlife & Fish -- 3.11.1.1 -- 4 -- 1 -- The Analysis Area used to assess the effects of habitat 

fragmentation was set as an 8- mile-wide buffer around the Project’s centerline (see Section 3.10.1.1). An 8-mile-wide buffer 

was chosen to assess a large enough area to capture the current and existing level of fragmentation, without assessing too 

large of an area, which would mask the effects of the Project’s contribution to the area’s fragmentation. -- The DEIS provides no information or literature citations to support the selection of an 8-mile buffer. Exactly how did the BLM decide 8-miles wasjust right? Furthermore, p. 3.11-70 states “If the response of the greater sage-grouse to transmission lines is similar to those recorded by 

Pruett et al. (2008) for the lesser and greater prairie-chickens, then edge effects resulting from newly fragmented habitats 

could extend approximately 330 feet into habitat patches.” This is significantly less than 8 miles.

The out numextoveof ffraginscon

Chapter 3 - Special Status Wildlife & Fish -- 3.11.1.3 -- 5 -- 1 -- Regulations that address and govern impacts to TES species 

include the ESA and various land-management plans from the BLM, Forest Service, and state agencies. Following is a discussion of the relevant regulations -- This section fails to identify and describe one of the key regulations affecting project 

routing in Wyoming – the Governor of Wyoming’s Executive Order regarding greater sage-grouse. The Wyoming Executive Order 2011-5 is a critical document that has informed the routing and siting of the transmission line in order for the Project to 

be incompliance with this order. Additional detail regarding the EO and influence the EO may have on routes and alternative routes should be disclosed and described in this section to inform the reader. The following or similar should be added: 

"Wyoming Executive Order 2011-5: Wyoming has developed the Core Area Strategy in attempt to "weave" the many on-going 

efforts to conserve the Greater Sage-Grouse in Wyoming into a statewide strategy and maintain a management mechanism to 

address threats to the grouse. This EO restricts development within the Core Areas. Transmission development within the 

Core Areas is allowable through meeting certain criteria or if it is developed within designated corridors. In order maximize use 

of the designated corridors and to be consistent with the EO, an additional route (Alternative 2C) was developed and follows 

the designated corridor through the Hanna Core Area. The designated corridors through core area where developed as utility 

corridors. Wyoming State Office and the Wyoming Game and Fish Department do not require additional mitigation for the 

portions of the project that utilize the corridors as they view the EO as mitigation in itself and therefore being consistent with 

the EO is mitigation."

Infoimpthe 

Chapter 3 - Special Status Wildlife & Fish -- 3.11.1.3 -- 8 -- 3 -- Only the Jarbidge and Owyhee Working Group have released their Conservation Plans;... In areas in Idaho where the Local Working Groups have not finalized their plan, the Conservation Plan for the Greater Sagegrouse in Idaho would apply. -- The Draft EIS should be revised to provide the citations for these documents. The Draft EIS 

should also be revised to clearly identify the boundaries of the local working groups so it is clear which portion(s) of the project 

they are concerned and/or involved in.

Tex
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 3 - Special Status Wildlife & Fish -- 3.11.1.4 -- 12 -- last -- The Project has been proposed for an area with substantial 

public lands managed with the intent of conserving and improving wildlife populations and stopping or reversing population 

declines of sensitive species. -- Management of public lands in the project area is not solely for the purposes identified in this 

statement. It is misleading to imply this. The Draft EIS should be revised to identify the multiple-use mandate that BLM and 

USFS is required to adhere to for the public lands crossed by the proposed project. This multiple-use mandate includes the provisions of right-of-way corridors for utilities infrastructure.

Tex

Chapter 3 - Special Status Wildlife & Fish -- 3.11.1.4 -- 16 -- 5 -- Habitat for the greater sage-grouse was originally included in 

the remote sensing analysis. The original intent of this effort was to use this Project-specific remote sensing analysis to determine the quantitative impacts (i.e., acres of impacts) that would occur to greater sage-grouse habitats. However, an interagency group consisting of the BLM, USFWS, IDFG, and WGFD decided that the remote sensing data was insufficient to address direct and indirect project-related impacts -- The Draft EIS needs to be revised to provide the specific criteria that 

were considered when determining that the analysis was insufficient and the rationale supporting that conclusion.

Re

Chapter 3 - Special Status Wildlife & Fish -- 3.11.1.4 -- 16 - 20 -- Beginning with Paragraph 5 -- The group developed a four 

component Analysis Framework of Interstate Transmission Lines that could be used to analyze potential impacts to greater sage-grouse in this Draft EIS (found in its entirety in Appendix J). -- The Framework does not appear to have measures that 

remove areas that are within an existing corridor from the DDC. Please explain how the BLM will address the apparent conflict 

between the project-wide analysis and resulting mitigation requirements with the Wyoming Governor’s order that does not require mitigation if a project is located within an existing corridor. In other words, under what authority can the BLM require 

mitigation for impacts on private or non-federal lands when this is not required by the State of Wyoming and not addressed by the State of Idaho?

The lan

Chapter 3 - Special Status Wildlife & Fish -- 3.11.1.5 -- 27 -- 2 -- R1 habitats are defined as perennial native and non-native

grasslands with high restoration potential. R2 habitats are defined as annual grass dominated areas (either shrubland or 

grassland) with low restoration potential. R3 habitats are defined as conifer encroachment areas with high restoration 

potential. -- By omitting the full definition of R1 through R3 habitats, the DEIS is implying that these areas currently support, or 

are capable of supporting, greater sage-grouse. The July 2006 Idaho Sage-grouse Conservation Plan further defines R1 as “...that should provide suitable potential nesting habitat in the future, once sufficient sagebrush cover is re-established (at least 

10% canopy cover). R2 is defined as “Areas dominated or strongly influenced by invasive annuals such as cheatgrass 

(Bromus tectorum) or medusahead rye (Taeniatherum caput-medusae) or similar species. Areas with sagebrush may be present, but, in general, understories are not suitable for sage-grouse.” R3 is defined as “Areas where junipers (Juniperus spp.) and/or other conifer species are encroaching into sage-grouse habitat areas.” The Draft EIS needs to be revised to include the full definition of the areas so readers can have the correct context to evaluate potential impacts.

The 

Chapter 3 - Special Status Wildlife & Fish -- 3.11.1.5 -- 27 - 28 -- last & first -- For the sake of this analysis, all leks in Nevada 

will be considered as occupied due to the limited length that Alternative 7I would cross this state -- The DEIS should not 

assume that all leks are occupied because of the length of the segment. The DEIS should clearly identify if the leks are 

occupied or if data are not available. Just because it is convenient is not a supportable rationale for the assumption and 

resulting analysis.

The inte

Chapter 3 - Special Status Wildlife & Fish -- 3.11.1.5 -- 29 -- 1 -- Based on the preliminary analysis (i.e., the results of the HEA 

are still pending), suitable greater sage-grouse habitat occurs along all segments, and the Proposed Route would cross through approximately 677.3 miles of suitable sage-grouse habitat (see Appendix D, Table D.11-3). -- It is not clear from the text or the table if suitable sage-grouse habitat includes areas identified as R1-R3 in Idaho. It is also not clear what vegetation 

categories are considered suitable habitat and the basis for their inclusion. The Draft EIS needs to be revised to disclose this 

information.

Tex

Chapter 3 - Special Status Wildlife & Fish -- 3.11.2.2 -- 57 -- last -- Approximately 36 percent (394.1 miles) of the Proposed 

Route is located adjacent to (within 1 mile of) existing transmission lines, which already serve as nesting and perching habitats for raptors and ravens. In these areas, the Project would cumulatively add to the numbers of raptors and ravens that are 

already utilizing existing transmission lines in the general area. In the remaining areas where the Project would not be colocated with existing lines or other tall structures (such as portions of the line that cross through forested habitats), it would 

create new nesting and perching opportunities. -- The Draft EIS should be revised to disclose the specific rationale supporting

the conclusion that the Proposed Project would add to the numbers of raptors using the existing lines. The presence of 

another transmission line does not automatically mean the populations of raptors and ravens using existing lines will increase.

Appropriate references and data supporting this conclusion needs to be disclosed to the public.

Selite
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 3 - Special Status Wildlife & Fish -- 3.11.2.2 -- 58 -- TESWL-2 -- TESWL-2 The Proponents shall work with the 

applicable land-management agencies to develop a survey protocol that would be conducted in conjunction with annual operations and maintenance surveys (as outlined in the Proponents’ Avian Protection Plans). The goal of these raptor-raven 

surveys shall be to identify whether populations of raptors and ravens are consolidating along the Project, and will be done during the appropriate time of year. These surveys shall be conducted, at a minimum, along portions of the line that are 

located within 1 mile of identified concentrations of sensitive raptor and raven prey species (including the black-footed ferret, 

burrowing owl, grouse species, mountain plover, prairie dogs, and pygmy rabbit). The Proponents and applicable landmanagement agencies shall work together to identify measures to limit predation rates on sensitive species within areas where 

raptor and raven populations are considered to be consolidating (limited to areas near sensitive species). -- Black-footed 

ferrets spend much of their time underground pursuing their prey. Is there any information in the literature that black-footed 

ferrets are prone to predation by nesting ravens and raptors, given their fossorial habits? Furthermore, placement of anti-perch 

deterrents (TESWL-3) is expansive and should be carefully considered. If black-footed ferrets are unlikely to be predated because of their fossorial habitats, anti-perch devices are not likely to be useful in protecting the species and should not be

required.

TE

Chapter 3 - Special Status Wildlife & Fish -- 3.11.2.2 -- 58 -- 1 -- Of the 708.8 miles of the Proposed Route that are not located 

within 1 mile of an existing line, about 485.8 miles are located within non-forested habitats (or 44 percent of the Proposed 

Route’s length). It is in these areas that the effects of potential consolidation of raptor and raven populations on prey species 

would be most substantial (the risk of increased predation pressures by raptors and ravens would be applicable to all raptor/raven prey species that occur in open shrubland and grassland habitats) -- The DEIS states that other developments 

exist along the proposed route and alternatives to the proposed route. No information has been provided if these structures 

already harbor nesting ravens and raptors. The GW transmission line is not constructed in an area that is devoid of human 

activities and impacts. In fact much of the non-forested habitats are in grassland, according to the DEIS. It is unclear what the 

cumulative effect the construction of the GW transmission line will have with respect to predation given the current habitat 

conditions. Rather than making a sweeping statement that that “the effects of potential consolidation of raptor and raven 

populations on prey species would be most substantial” a more detailed analysis where such predation would most likely to 

take place in non-forested habitats would better inform the lead agencies decision. As it is, "most substantial" means virtually 

nothing. Also, it is unclear what is considered “a consolidation of raptor and raven populations”. Is this the colonization of the transmission line by nesting raptors and ravens? Apparently, there is a population of ravens and raptors present. Are these 

birds nesting on existing structures and is there concern that this population will all be “consolidated” on the newly built 

transmission line? The Draft EIS needs to be revised to provide an analysis of these impacts that is based on scientificallydefensible information and sound rationale.

The staimp

Chapter 3 - Special Status Wildlife & Fish -- 3.11.2.2 -- 61 -- 3 -- There is a very low possibility that the transmission linestructures would be placed in riparian habitat; instead, it is common engineering practice to span riparian habitat with the 

conductors and place the towers outside riparian habitat. However, the Proponents may propose one or more access roads 

that cross riparian habitat. Disturbances within these areas could result in direct mortality of frogs during the clearing and 

construction of the stream/waterbody crossing. In addition, increased sedimentation could result, which if at high enough levels 

could impact tadpoles and eggs present at both at the crossing location itself and immediately downstream. Sedimentation could bury frog eggs and/or damage tadpole gills, resulting in mortality. Sedimentation would be controlled through 

implementation of the Proponents’ SPCC Plan (Appendix C-1, Attachment C). In addition, the possibility of a spill of toxic materials into waterbodies would be limited due to the implementation of the Proponents’ SWPPP (Appendix C-1, Attachment 

B; these measures would be applicable to all species that inhabit wetlands or waterbodies). Even with the implementation of 

these preventive and protective measures, the crossing of waterbodies by access roads should be avoided to the extent 

feasible; in addition, all necessary crossing should occur outside of forested riparian areas to reduce the amount of riparian vegetation that would need to be cleared -- "Sedimentation would be controlled through implementation of the Proponents’ 

SPCC Plan (Appendix C-1, Attachment C). In addition, the possibility of a spill of toxic materials into water bodies would be limited due to the implementation of the Proponents’ SWPPP (Appendix C-1, Attachment B; these measures would be 

applicable to all species that inhabit wetlands or water bodies)." It would be more appropriate to state that sediment would becontrolled through implementation of the SWPPP rather than the SPCC and that spills would be minimized due to the 

implementation of both the SWPPP and SPCC. That Draft EIS should be revised to clarify this.

Tex
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 3 - Special Status Wildlife & Fish -- 3.11.2.2 -- 63- 64 -- 4 -- The USFWS’s 12-Month Findings for Petitions to List the 

Greater Sage-Grouse as Threatened or Endangered (2010e) listed the following as potential impacts to the greater sagegrouse resulting from powerlines: 1) collisions/electrocutions, 2) consolidation of predatory birds along powerlines, 3) lower 

recruitment rates near lines, 4) habitat fragmentation, 5) degradation of habitat due to spread of invasive plant species, 6) 

impacts resulting from the line’s electromagnetic fields, and 7) direct loss of habitat. -- Knick et al (2010) state that “The underlying cause for population declines in this western species [greater sage grouse] is loss of suitable sagebrush habitat tomeet seasonal requirements for food, cover, and nesting". Powerlines may have impacts on sage grouse as listed in the DEIS. 

However, only anecdotal information is available on collisions of sage grouse with distribution lines or telephone wires (UWIN 

2010). Increased predation of sage-grouse due to nesting ravens and raptors is largely unsubstantiated. In fact, much of the literature on sage grouse predation in relation to transmission or distribution lines is anecdotal, limiting inferences from these studies (Ellis 1984, 1985b, 1987, 1989). Only one long-term study has been conducted to determine the effect of transmission 

lines on sage grouse recruitment rates (Blomberg et al 2010). This study showed no effects on sage grouse vital rates were found after 7 years of study of the Falcon-Gondor 345 kV line. Lastly, effects of habitat fragmentation on sage grouse due to 

powerlines has not been established (UWIN 2010). Wisdom et al (2011) found that distance to transmission lines [and 

distance to cellular towers], have unknown relations with sage-grouse population dynamics at regional extents. Sage grouse 

researchers agree that habitat degradation plays a major role in declining sage grouse populations in the western US. The 

Draft EIS should be revised to include the most recent information on sage grouse ecology and management in this analysis. For example, the publication by Knick et al (2010) should be referenced in the DEIS. See Attachment A for additional 

information.

ThimoEnnew 

Chapter 3 - Special Status Wildlife & Fish -- 3.11.2.2 -- 63- 64 -- last -- To limit the potential disturbance to this species, one of 

the Proponents’ primary goals while routing the Project was to avoid all leks by at least 0.25 mile (in accordance the BLM RMP requirements for “no surface occupancy,” which was in place at the time of initial Project design in 2008). -- To correctly 

portray what the Proponents did, we recommend that the Draft EIS be revised so the referenced text reads as follows: "To limit 

the potential disturbance to this species, the Proponent's routed the proposed transmission line to avoid all leks by at least 0.25 mile (in accordance the BLM RMP requirements for “no surface occupancy,” which was in place at the time of initial 

Project design in 2008).

Tex

Chapter 3 - Special Status Wildlife & Fish -- 3.11.2.2 -- 64 -- 1 -- surface occupancy,” which was in place at the time of initial 

Project design in 2008). However, the centerline of the Project would come within 0.25 mile of a lek with an “undetermined” management status along Segment 10 and within 0.25 mile of a lek with an “occupied” management status along Segment 5 (see Table 3.11-4). In addition, the Proponents attempted to avoid leks by 0.6 mile to the extent possible, based on the 

assumption made at the time of initial Project design (2008) that the “no surface occupancy” requirement would increase from 0.25 mile to 0.6 mile (as of this date, the BLM “no surface occupancy” restriction has been increased to 0.6 mile). However, not all leks could be avoided by this distance (see Table 3.11-4) due to the need to avoid other sensitive resources (e.g., highaltitude mountain habitats that contain species listed under the ESA, or sensitive cultural resources that are protected by thevarious SHPOs). -- "In addition, the Proponents attempted to avoid leks by 0.6 mile to the extent possible, based on the assumption made at the time of initial Project design (2008) that the “no surface occupancy” requirement would increase from 0.25 mile to 0.6 mile..." Should read: "In addition, the Proponents attempted to avoid leks by 0.65mile to the extent possible, 

based on the assumption made at the time of initial Project design (2008) that the “no surface occupancy” requirement would 

increase from 0.25 mile to 0.65 mile..." (this comment also applies to 3.11-91, last paragraph)

Tex

Chapter 3 - Special Status Wildlife & Fish -- 3.11.2.2 -- 68 -- 2 -- Fences located in sage-brush habitats have been identified as a major cause of mortality for greater sage-grouse, due to these low-flying birds colliding with and becoming entangled within these fences (Stevens 2011) -- The Draft EIS needs to be revised to fully disclose the context of the Stevens (2011) study. Stevens (2011) determined that sage grouse collisions with fences was highest near leks and rapidly dropped off with distance to leks. Furthermore, Stevens (2011) study indicated that collisions were influenced by technical attributes of the fences. 

Fences built with steel post showed higher collisions than those built with wooden posts and wider spacing between posts. 

Broad-scale modeling suggested probability of collision was influenced by region, topography, and fence density. Thus, if fence removal or modification is considered as a mitigation measure, only those fences should be modified or removed that have the highest probability of causing mortality to sage grouse. These are fences closest to leks, are exposed on higher terrain, and are less visible due to their construction.

Ad201
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 3 - Special Status Wildlife & Fish -- 3.11.2.2 -- 68 -- 4 -- The Agencies have also identified the following mitigation

measures, which are required as part of recent published BLM Instructional Memorandums. TESWL-14 Surface disturbance 

shall be avoided within 0.6 to 4 miles of occupied or undetermined greater sage-grouse leks from March 15 to July 15 in all portions of the Project except for Nevada. In Nevada, surface disturbance shall be avoided within view of or within 0.3 mile ofall leks from March 1 to May 15; and within areas designated by Nevada as greater sage-grouse brood rearing areas from 

May 15 to August 15. -- No Instructional Memorandums are listed. Please include which IM states no surface disturbance 

within 4 miles of occupied or undetermined leks. IPC is not aware of any BLM instructional memorandums limiting surface 

disturbance within 4 miles of leks.

The 

Chapter 3 - Special Status Wildlife & Fish -- 3.11.2.2 -- 68 -- 4 -- Indirect effects to the greater sage-grouse from the Project operations include ... potential avoidance of tall transmission structures that could result in an increase in habitat loss and fragmentation .... -- The UDNR 2010 literature review found “...that there were no peer-reviewed, experimental studies 

designed specifically to evaluate the landscape effects of tall structures on sage-grouse.” They found “...no ‘peer-reviewed’ manuscripts that reported results from experimental studies to document sage-grouse avoidance of tall structures, increased predation related to avian predators using tall structures as perches, increased mortality attributed to collisions, or habitat

degradation and/or fragmentation attributed to tall structures.” The literature synthesis “...did find professional opinions, 

personal observations, unpublished data, anecdotal references, and models that implicated tall structures as potential causal 

agents of the above effects on sage-grouse, and peer reviewed studies on the cumulative effects of oil and gas development 

and associated infrastructures on sage-grouse. The latter studies did not isolate tall structures, as defined by this project, as a 

specific mechanism affecting sage-grouse.” The Draft EIS should be revised to disclose this relevant information related to 

transmission line impacts on sage-grouse.

The revthe of e

diffcomlac

Chapter 3 - Special Status Wildlife & Fish -- 3.11.2.2 -- 68 -- last -- The distance that these effects could extend from the transmission lines (if they are used as roosting habitat by predatory avian species) depends on the hunting range the predatory avian species. For example, non-breeding pairs of ravens have been documented to travel an average of 4.3 miles (6.9 kilometers) (up to 38.8 miles [62.5 kilometers]) in Idaho from roost sites to food sources and 16.8 miles (27 kilometers) in Michigan (ranging from 0.5 to 91.3 miles [0.8 to 147.0 kilometers]), with breeding pairs often traveling up to 0.8 mile (1.3 kilometer) while hunting (Boarman and Heinrick 1999). -- The Boarman and Heinrick (1999) citation is cited out of context. The Draft EIS needs to be revised to also note that the non-breeding pairs referenced in the study were travelling from roost to landfills – not hunting. In the Mojave Desert of California, breeding pairs hunted live food an average of 0.35 mile (0.57 

kilometer) from their nests (Boarman and Heinrick 1999). Additionally, Sherman (1993) found that nesting ravens in the. 

Mojave Desert of California spent 75% of foraging time within 400 m of the nest, but at least once per day individuals flew 

several kilometers out of sight, probably to obtain water (Sherman 1993).

Info

Chapter 3 - Special Status Wildlife & Fish -- 3.11.2.2 -- 68 -- 4 -- Potential direct impacts from Project operations include the 

effects of the electromagnetic field on sage-grouse and collisions with Project structures. -- The Draft EIS needs to be revised to provide the necessary citations to support this statement.

Cit

Chapter 3 - Special Status Wildlife & Fish -- 3.11.2.2 -- 69 - 70 -- last & first -- However, the distribution lines that serve the 

substations could provide an electrocution hazard to the greater sage-grouse, although this hazard would be minimal due to the limited number of places where new distribution lines would be constructed (at the Creston, Bridger, and Cedar Hill 

Substations), the short distances that these distribution lines would travel (between200 to 500 feet), and the fact that these 

distribution lines would be constructed in accordance with APLIC guidelines (i.e., designed to prevent avian electrocutions). -- In order for a greater sage-grouse to be electrocuted they must first attempt to land on the power pole. Greater sage-grouse 

do not use power poles for perches. It should be sufficient to say neither transmission nor distribution lines are an electrocution 

hazard.

Lanthrocon

Chapter 3 - Special Status Wildlife & Fish -- 3.11.2.2 -- 70 -- last -- Peer reviewed science that demonstrates an avoidance or

non-avoidance of tall structures by the greater sage-grouse is either limited, or nonexistent in the current literature. This lack of 

evidence is related to a lack of peer-reviewed and controlled studies that can differentiate between the impacts related to tall 

structures and those related to other components of human developments (e.g., noise, human presence), as opposed to a true lack of evidence (UDNR 2010). -- To say the lack of evidence in not really a true lack of evidence is confusing to say the least. There is a true lack of evidence that sage-grouse avoid tall structures. That does not mean they do or do not, it just means there is a lack of evidence to establish that relationship. To try and paint that as not really a true lack of evidence because we 

cannot show a clear connection smacks of bias. The Draft EIS should be revised to delete the sentence "This lack of evidence is related to a lack of peer-reviewed and controlled studies that can differentiate between the impacts related to tall structures 

and those related to other components of human developments (e.g., noise, human presence), as opposed to a true lack of 

evidence" as this statement makes absolutely no sense.

Thiappthis occ
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 3 - Special Status Wildlife & Fish -- 3.11.2.2 -- 71 -- 4 -- Compensatory mitigation for impacts to greater sage-grouse

and their habitats will likely be necessary due to the current declines in their population rates range-wide, the current concerns 

regarding their status, the magnitude of potential impacts that the Project could have on their habitats, and the impact that their 

potential ESA listing could have on the economic stability of Wyoming’s oil and gas industry. -- The only valid reason for 

requiring mitigation is due to impacts from the Gateway West project. The Companies are not responsible for mitigating impacts that resulted from previous BLM decisions nor are we responsible for the economic stability of Wyoming.

As pro

Chapter 3 - Special Status Wildlife & Fish -- 3.11.2.2 -- 82 -- last -- The Proponents would conduct construction and 

decommissioning of culverts under a Construction General Permit required for stormwater operations, which includes the 

development of BMPs to protect surface water from stormwater runoff. -- Generally, Construction General Permits are only required for disturbances of one acre or more; therefore, the statement should be revised as follows: 

If disturbance is one acre or more, the Proponents would conduct construction and decommissioning of culverts under a Construction General Permit required for stormwater operations, which includes the development of BMPs to protect surface water from stormwater runoff.

Tex

Chapter 3 - Special Status Wildlife & Fish -- 3.11.2.2 -- 91 -- 3 -- However, roads could potentially serve as a barrier, and could fragment populations and habitat. -- The Draft EIS needs to be revised to provide data, rationale, and analysis to support this

conclusion

Tex

Chapter 3 - Special Status Wildlife & Fish -- 3.11.2.2 -- 93 -- 3 -- The Agencies have identified TESWL-11 to limit the potential impact of the Projects construction of sharp-tailed grouse leks. TESWL-11 In areas where sharp-tailed grouse leks occur in proximity to greater sage-grouse leks, surface disturbance shall be avoided within 4 miles of occupied or undetermined greater 

sage-grouse leks from March 1 to July 15. In areas where sharp-tailed grouse leks occur in isolation from greater sage-grouse leks, surface disturbance shall be avoided within 1.2 miles of occupied or undetermined sharp-tailed grouse leks from March 15 to July 15. -- The Draft EIS needs to be revised to provide rationale for the timeframes and distances used in TESWL-11.

Se

Chapter 3 - Special Status Wildlife & Fish -- 3.11.2.2 -- 158 -- last -- TESWL-3 H-frame structures shall be equipped with antiperch devices to reduce raven and raptor use, and limit predation opportunities on special status prey species. -- Deterrent 

devices would be most appropriate in perch-limited areas or to reduce use of specific pole perches in close proximity to a sage

grouse lek or the presence of other special status species (Slater and Smith 20010). The Draft EIS should be revised to 

propose perch deterrents only where nesting ravens and raptors overlap with special status prey species.

TEspe

Chapter 3 - Special Status Wildlife & Fish -- 3.11.2.2 -- 158 -- last -- TEWSL-3 H-frame structures shall be equipped with antiperch devices to reduce raven and raptor use, and limit predation opportunities on special status prey species. -- Bui et al. 

(2010) studied raven activity in relation to land use in Wyoming. They found that raven occupancy near sage-grouse nests and 

broods was more highly correlated with sage-grouse success than were raven density and behavior, suggesting that the majority of nest predation by ravens is most likely carried out by resident territorial individuals. They concluded that managers 

attempting to reduce the potential effects of ravens on grouse reproduction should first reduce occupancy of important sagegrouse nesting habitat by ravens. Bui et al. (2010) noted that anthropogenic nest sites should be managed to reduce raven use through retrofitting or the installation of deterrent fixtures (i.e., strips, netting, screening) on old structures, covering well 

heads, modifying future engineering of structures to avoid providing suitable nesting platforms, egg removal, nest destruction,

and harassment of nesting pairs.

Ad

However, perch deterrents are not effective for precluding nesting and in fact can facilitate the accumulation and support of nesting material. Two studies conducted to study the effectiveness of perch deterrents reported ravens using perch deterrents 

to facilitate nesting. Lammers and Collopy (2007) found 3 common raven nests built using perch deterrents to support the 

nest. Likewise, Slater and Smith (2010) reported that a raven pair built a nest between the crossarm spikes installed to prevent 

perching. They noted that surveyors regularly observed adults and nestlings using crossarm deterrent devices and nearby conductors as perching substrates. Therefore, the Proponents support the use of steel H-frame structures with no anti-perch devices in habitat that supports special status prey species. Steel H-frame structures do not provide nesting substrate.

Ad

Studies of the effectiveness of perch deterrents for excluding or reducing perching have reported varying results depending on 

the bird species and type of perch deterrent used. Lammers and Collopy (2007) observed avian predators perching on 345-kV 

towers retrofitted with perch deterrents during 50% of the 77 surveys conducted. Corvids and raptors overcame the deterrents 

by perching directly on them or on deterrent-free parts of the towers (e.g., on conductors [before electric current] or wire) and 

nesting on them. Of the avian predators Lammers and Collopy (2007) observed during surveys, 77% (n = 18) were perched on the horizontal arm of the towers, 19% (n = 5) on the tower wires, and the remainder on the crossarms and transposition 

towers. Lammers and Collopy (2007) found that perch deterrents did not appear to have an effect on the observed numbers of 

avian predators of concern to greater sage-grouse. However, they did report a reduction in avian predator use of overhead 

transmission line towers via shorter perching duration on the deterrents versus other available perching substrates.

Ad
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Likewise, Prather and Messmer (2010) studied raptor and corvid response to perch deterrents in Utah and did not detect any 

difference in perching events by perch deterrent and controls. However, they did note that the perch deterrents had inherent 

design and placement flaws. Slater and Smith (2010) studied the effectiveness of spike perch deterrents on H-frame structures in Wyoming. They found that raven and raptor activity was significantly lower on the deterrent line compared with the control line, when comparing only 

those birds perching on the cross-arms or pole-tops that were subject to application of deterrent devices (i.e., they did not include observations of birds perched on conductors or cross-braces). When including all birds perched on the structures, 

golden eagles were sighted 268 times on the control line, whereas they were observed only 54 times on the deterrent line. Rough-legged hawks were observed more frequently on the deterrent line (171 observations) than the control line (53 

observations) and used the static wire as a perch. Common ravens were sighted 68 times on the control line versus 50 times 

on the deterrent line. The authors noted that they filtered out all observations associated with the raven nesting on the 

deterrent line (i.e., raven sighting on the deterrent line would have been higher if those observations had been included) . Ravens were most frequently sighted using the static wire and crossbraces of the deterrent line, but were also observed using the cross-arms and pole tops with deterrents.

Bot

Slater and Smith (2010) noted that in contrast to the pilot study conducted 2 years earlier on the same structures (Oles 2007),

they did not find that deterrent devices completely excluded raptors and ravens. They suggested that deterrent devices may 

lose some effectiveness as their initial novelty wears off. They conclude that deterrent use may be most appropriate in areas 

with few tall perches (both natural and man-made) or to reduce use of specific poles. The Draft EIS needs to be revised to incorporate this data into the analysis of the potential environmental effects of the proposed project.

The 

Chapter 3 - Paleontological Resources -- 3.13.1.3 -- 5 & 6 -- last & first -- Federal protection for significant paleontological 

resources applies to federally owned or managed lands. Federal legislative protection for paleontological resources began with 

the Antiquities Act of 1906 (P.L. 59-209; 16 U.S.C. § 431 et seq.; 34 Stat. 225), which requires protection of historic landmarks, historic and prehistoric structures, and other objects of historic or scientific interest on federal land. The Antiquities Act of 1906 forbids disturbance of any object of antiquity on federal land without a permit issued by the responsible managing 

agency. This act also establishes criminal sanctions for unauthorized appropriation or destruction of antiquities. The Federal 

Highways Act of 1958 clarified that the Antiquities Act applied to paleontological resources and authorized the use of funds 

appropriated under the Federal-Aid Highways Act of 1956 to be used for paleontological salvage in compliance with the 

Antiquities Act and any applicable state laws. In addition to the Antiquities Act, other federal statutes protect fossils. The Historic Sites Act of 1935 (P.L. 74-292; 49 Stat. 

666; 16 U.S.C. § 461 et seq.) declares it national policy to preserve objects of historical significance for public use and gives 

the Secretary of the Interior broad powers to execute this policy, including criminal sanctions. NEPA (P.L. 91-190; 31 Stat. 

852; 42 U.S.C. §§ 4321-4327) requires that important natural aspects of the nation’s heritage be considered in assessing the 

environmental consequences of any proposed project. The FLPMA (P.L. 94-579; 90 Stat. 2743; U.S.C. § 1701-1782) requires that public lands be managed in a manner that protects the quality of their scientific values. The most explicit protection for

paleontological resources was enacted in 2009. The Paleontological Resources Preservation Act of 2009 regulates who may 

collect fossils on public lands and where such fossils must be curated -- The Draft EIS needs to provide a clear definition of what is a “significant paleontological resource.” All of the listed laws and regulations have exemptions for common 

invertebrates and plant resources, which are typically not seen as significant paleontological resources.

Co

Chapter 3 - Paleontological Resources -- 3.13.1.3 -- 6 -- 2 - last sentence -- In addition to the Antiquities Act, other federal 

statutes protect fossils. The Historic Sites Act of 1935 (P.L. 74-292; 49 Stat. 666; 16 U.S.C. § 461 et seq.) declares it national 

policy to preserve objects of historical significance for public use and gives the Secretary of the Interior broad powers to execute this policy, including criminal sanctions. NEPA (P.L. 91-190; 31 Stat. 852; 42 U.S.C. §§ 4321-4327) requires that important natural aspects of the nation’s heritage be considered in assessing the environmental consequences of any proposed project. The FLPMA (P.L. 94-579; 90 Stat. 2743; U.S.C. § 1701-1782) requires that public lands be managed in a manner that protects the quality of their scientific values. The most explicit protection for paleontological resources was 

enacted in 2009. The Paleontological Resources Preservation Act of 2009 regulates who may collect fossils on public lands 

and where such fossils must be curated. -- The Paleontological Resources Protection Act was passed as part of Public Law 111-011, Title VI, Subtitle D. Currently, no agencies have promulgated regulations for this legislation, which makes the law 

difficult to enforce

Infodis
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 3 - Paleontological Resources -- 3.13.2.2 -- 12 -- PALEO-1 -- The Proponents shall prepare a Paleontological 

Monitoring Plan for the Project, focusing on Segments 4, 7, 8, and 9 where the potential for adverse impacts is the greatest. This plan shall be submitted to appropriate agencies for review and approval prior to commencing construction. The plan will specify that: • Monitoring of excavation and grading in sensitive sediments, especially access roads and tower sites, must occur when 

construction is near or in those geologic formations. • Monitoring of excavations in sensitive sediments, screening the excavated spoils, and processing of bulk sediment samples 

for microvertebrate fossils must occur where there is a significant potential for data recovery from those spoils. • Monitoring must be performed by a qualified paleontologist and in consultation with a designated paleontologist in each state, 

NF, or BLM district. The Authorized Officer will designate the appropriate paleontologist depending on project location. -- The

Draft EIS needs to be revised to provide more specific and enforceable criteria for when monitoring should occur. The terms "significant potential for data recovery of these spoils" is vague and can mean different things to different readers. Additionally, 

what constitutes sensitive soils should be clearly defined (class 4 or 5, etc).

Ne

Chapter 3 - Paleontological Resources -- 3.13.2.2 -- 12 -- PALEO-1 -- The Proponents shall prepare a Paleontological Monitoring Plan for the Project, focusing on Segments 4, 7, 8, and 9 where the potential for adverse impacts is the greatest. This plan shall be submitted to appropriate agencies for review and approval prior to commencing construction. The plan will specify that: • Monitoring of excavation and grading in sensitive sediments, especially access roads and tower sites, must occur when 

construction is near or in those geologic formations. • Monitoring of excavations in sensitive sediments, screening the excavated spoils, and processing of bulk sediment samples 

for microvertebrate fossils must occur where there is a significant potential for data recovery from those spoils. • Monitoring must be performed by a qualified paleontologist and in consultation with a designated paleontologist in each state, 

NF, or BLM district. The Authorized Officer will designate the appropriate paleontologist depending on project location. -- The

Draft EIS should be revised to require that the proponent survey in Class 3, 4 and 5 areas to eliminate or more readily identify 

areas that would require monitoring instead of automatically requiring monitoring in all those areas. The Draft EIS also needs 

to be revised to specifically disclose how much sediment constitutes a "bulk sediment sample, as well as disclosing why 

screening is necessary if you are already taking a bulk sample.

The 

IM 

Chapter 3 - Paleontological Resources -- 3.13.2.2 -- 12 -- PALEO-3 -- Areas with Fossil Potential Classification sensitivity rankings of 3, 4, or 5 on NFS lands will be surveyed and posted. -- "PALEO-3 Areas with Fossil Potential Classification 

sensitivity rankings of 3, 4, or 5 on NFS lands will be surveyed and posted." The required monitoring should be sufficient. If 

there are surveys conducted, it diminishes the need for active monitoring.

Thibee

Chapter 3 - Geologic Hazards -- 3.14.1.4 -- 4 -- 4 -- The damage to structures caused by earthquakes is highly variable and based on many features including, but not limited to, types of building materials and quality of construction, distance from 

epicenter, earthquake magnitude, and the susceptibility to ground shaking of underlying soil and rock at the site of the structure. Therefore, any relationship between structure damage 

and distance from earthquake epicenter is only an estimate. However, certain areas are subject to more earthquakes than 

others and the geographic distribution of earthquakes was considered. -- All utilities governed by the National Electric Safety

Code are required to apply various weather-related structural loading cases while designing transmission lines. We do apply 

all those required as well as some additional cases we feel are important to the integrity of the lines. A short note in section 

250.A.4 indicates that by following the required loading cases, nothing further is required to resist earthquake loads. It states, 

“The structural capacity provided by meeting the loading and strength requirements of Sections 25 (Loadings for Grades B and 

C) and 26 (Strength Requirements) provides sufficient capability to resist earthquake ground motions.” For this reason we do 

not perform any additional design efforts specific to earthquakes.

Info3.1

Chapter 3 - Geologic Hazards -- 3.14.2.3 -- 19 -- 2 -- Segment 1W is composed of two parts, Segment 1W(a) and 1W(c), both 

of which would consist of a new 230-kV line for part of their length and a reconstruction of an existing 230-kV line for the remaining part. Segment 1W(a) would be about 76.5 miles long, and would extend from the Windstar Substation to the Aeolus 

Substation. Segment 1W(c) would be about 70.6 miles long, and would extend from the Dave Johnston Power Plant to the 

Aeolus Substation. Alternative 1W-A is a 16.2-mile alternative located near the town of Glenrock, which was the Proponents’ initial proposal before moving the Proposed Route at the suggestion of local landowners in order to avoid the more settled 

area around Glenrock. Twenty acres of the proposed expansion at the Windstar and Aeolus Substations are attributed to 

Segment 1W(a) and 3 acres of the expansion at the Heward Substation and 17 acres of the expansion at the Windstar and 

Aeolus Substations are attributed to Segment 1W(c). There are no Route Alternatives proposed south of that point (see 

Appendix A, Figure A-2). -- Segment 1W: Modify earthquake sentence per above.

Info
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 3 - Soils -- 3.15.2.2 -- 13 -- 2 -- Project construction activities that would affect soils include clearing, grubbing, and 

grading along the ROW and at additional temporary workspaces; trenching; backfilling; excavating; and construction of permanent structures, such as transmission line towers, access and service roads, co-generation sites, and substations. The 

total Project construction disturbance area consists of approximately 16,000 acres, which is approximately one percent of the 

Analysis Area. The construction disturbance area was calculated by establishing an assumed construction disturbance area around all Project features, such as transmission line towers, regeneration sites, substations, staging areas, laydown yards, 

and access roads. This predicted area was entered into a GIS database and compared to the areas of the various soil factors 

used for the soils analyses using the methods described in Section 3.15.1.4. The estimated soil effects within the construction

disturbance area are presented in Table D.15-1 in Appendix D. Ground clearing during construction would increase the 

potential for erosion. Certain soils within the Project area would be more sensitive to soil impacts, including soils with a low soil 

loss tolerance, and soils qualifying as prime farmland. Removal of protective vegetation would expose soil to potential wind 

and water erosion. The construction acreage is larger than the operations area due to the need for tower erection areas at 

each structure, laydown yards, staging areas, and tensioning sites. The areas used only for construction would be reclaimed 

as soon as possible, which may include re-grading to original land contours, topsoil replacement, and revegetation. -- The 

Draft EIS should be revised to disclose that service roads used for construction and operations would also be reclaimed to 

minimize erosion potential.

Info

Chapter 3 - Soils -- 3.15.2.2 -- 13 -- 4 -- Prior to construction, wetland delineations would be necessary in areas crossing oradjacent to assumed wetlands. At that time, the amount of hydric soils/wetlands would be re-evaluated and measures would be implemented to preserve or reclaim those acreages during construction and operation. The procedures presented in the Reclamation Plan (Appendix C-2), EPMs included in Appendix C-1, and the mitigation measures contained in Section 3.9 – Wetlands and Riparian Areas would be used to minimize effects to hydric soils and wetlands. FSH 2509.22, Soil and Water 

Conservation Practices, contains mitigation measures for hydric soils to be used on NFS land. -- "FSH 2509.22, Soil and 

Water Conservation Practices, contains mitigation measures for hydric soils to be used on NFS land." The Draft EIS should be revised to specifically describe the required mitigation measures from the referenced document. Additionally, we recommend 

the Draft EIS be revised to specifically describe those measures required by the U.S. Forest Service, the BLM, and the 

Proponent to allow a direct comparison of respective mitigation measures and their effectiveness.

FSpra

Chapter 3 - Soils -- 3.15.2.2 -- 17 -- SOIL-5 -- Disturbed soil will not be allowed to support the growth of noxious weeds, or 

invasive weedy species. Prevention of noxious weeds will apply to all phases of the Project. -- This condition is too broad for

effective implementation and is essentially meaningless and we recommend that it be deleted from the Draft EIS. The 

reclamation plan and other weed management measures will be implemented to minimize the spread of noxious weeds.

Thi

Chapter 3 - Soils -- 3.15.2.2 -- 17 -- SOIL-7 -- The Proponents are responsible for monitoring to ensure soil protection is achieved and providing monitoring reports on reseeding success or other methods to stabilize soils to the Forest Service by the end of each growing season for areas on NFS lands. -- The Draft EIS needs to be revised to specifically disclose of criteria 

and/or a timeframe for the monitoring of reseeded areas.

No

Chapter 3 - Soils -- 3.15.2.2 -- 17 -- SOIL-8 -- Reclamation of all temporary disturbances on NFS lands (such as road cuts) should include replacement of material to original contours. Recompaction to pre-existing compaction percentage (which 

should be identified before disturbance) should be included in the plan. Guidelines for streambank re-compaction to maximize 

vegetative regrowth and mechanical stability are covered in USACE publication ERDC TNEMRRP-SR-26 (Goldsmith et al. 2001). -- The Draft EIS should be revised to include similar language as in AGRI-12 with regards to reclamation. This would include the requirement 

that compaction would be tested in areas identified as a concern during reclamation activities.

AG

Chapter 3 - Water Resources -- 3.16.1.3 -- 6 -- 5 -- WDEQ maintains similar water quality standards (Water Quality Rules and Regulations, Chapter 1) that also contain priority and non-priority pollutants, and water quality standards for Wyoming surface

water. -- The Draft EIS should be revised to provide the complete citation for the referenced standards.

A c

Chapter 3 - Water Resources -- 3.16.1.4 -- 7 -- 3 -- In order to identify water resources within the Analysis Area, estimates of stream flow along the transmission line were made using USGS regression models created using data gathered from established stream gages. -- The Draft EIS should be revised to provide a complete citation for the model(s) and specific 

stream gages that were used. Were the models calibrated and validated for this Project? If yes, please provide the information.

If no, please explain why the BLM did not feel this was necessary.

Citme

Chapter 3 - Water Resources -- 3.16.1.4 -- 7 -- 4 -- After the estimated flows were calculated for the terminal stream order 

within each HUC, determinations were made on the likelihood of encountering active flow at proposed crossings within that HUC. -- The Draft EIS should include a description of the time of the year when flow estimates were calculated and should 

include a description of the seasonal and annual flow fluctuations.

Ad
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 3 - Water Resources -- 3.16.1.4 -- 11 -- 3 -- For TMDL and 303(d) listed temperature-impaired streams, the effects 

from removal of shading vegetation on temperature degradation were analyzed. ...Acres of woody vegetation removed within 

500 feet of the temperature impaired stream were calculated. The 500-foot distance was selected to be consistent with RMP buffers used to protect water quality. -- The Draft EIS needs to be revised to provide citations that support that vegetation 

removal 500-feet from the edge of a waterbody will adversely affect water temperatures.

Ad3.1

Chapter 3 - Water Resources -- 3.16.1.4 -- 12 -- 2 -- Shallow bedrock within the Project area could require the use of blasting

to set Project foundations. Blasting in shallow bedrock is more fully described in Section 3.14 – Geologic Hazards. Blasting in

shallow bedrock could damage nearby structures, including wells. Wells within 200 feet of the blasting areas could be especially susceptible to damage. To assess the number of water wells within 200 of the blasting zones, the GIS file of the 

Analysis Area was overlaid on the GIS file from the Idaho and Wyoming water entities. The number of total wells within 200 

feet of the Project centerline was determined by segment. To compare the number of wells within 200 feet of centerline 

between the Proposed Route and Route Alternatives, the number of total wells within 200 feet of centerline was counted by 

alternative -- The Draft EIS needs to be revised as follows: "To assess the number of water wells within 200 of the blasting zones, the GIS file of the Analysis Area was overlaid on the GIS file from the Idaho and Wyoming water entities." Should read "To assess the number of water wells within 200 feet of the blasting zones, the GIS file of the Analysis Area was overlaid on 

the GIS file from the Idaho and Wyoming water entities."

The 

Chapter 3 - Water Resources -- 3.16.2.2 -- 18 -- 5 -- In addition, the Agencies have identified BIO-3 (in Section 3.6 – 

Vegetation Communities), which requires that access roads be constructed and sited in such a way as to minimize the number 

of trees that would need to be removed. -- This requirement may not be practicable or feasible given the other mitigation measures and requirements of the agencies to avoid numerous sensitive resources (e.g., plant and wildlife species, 

viewsheds, cultural resources, etc.). Moreover, the Proponents have avoided sensitive resources as much as possible during 

routing. Accordingly, we recommend this requirement be removed from the Draft EIS.

TheDEaccnew ovesencul

Chapter 3 - Water Resources -- 3.16.2.2 -- 18 -- last -- The Proponents would conduct construction and decommissioning of 

culverts under a CGP required for stormwater operations ... -- Generally, Construction General Permits are only required for 

disturbances of one acre or more. If an individual culvert is decommissioned, then it is not likely that a Construction General

Permit would be required.

Infowill 

Chapter 3 - Land Use and Recreation -- 3.17.2.2 -- 50 -- 1 -- For reliability reasons, the Proponents have proposed to site thefacilities an average of 1,500 feet from existing transmission lines 230 kV or higher (see Section 1.3.3.3 of Chapter 1). During 

final design the separation distance could be greater if the distance between the tower of the existing line is greater than 1,500 feet. ROWs typically are wide enough only to accommodate the existing facility safely, and none of the Proposed Route and 

Route Alternatives would occupy any existing 230-kV or higher utility transmission ROW except as they approach substations. 

An exception is the 5.3-mile long Alternative 5E proposed by Power County, which would be located adjacent to an existing 

345-kV line and would, therefore, not be consistent with the 1,500-foot separation criteria established for the Project -- "For

reliability reasons, the Proponents have proposed to site the facilities an average of 1,500 feet from existing transmission lines 

230 kV or higher (see Section 1.3.3.3 of Chapter 1). During final design the separation distance could be greater if the 

distance between the tower of the existing line is greater than 1,500 feet." Separation is based on set criteria. Accordingly we recommend the Draft EIS be revised to the first sentence is as follow: "For reliability and public safety reasons and based on regulatory guidance, the minimum separation for preliminary siting of the line adjacent to existing lines is 1,500 feet." To more accurately portray the rationale behind greater separation distances correctly we also suggest the second sentence be revised as follows: "During final design, the separation distance could be greater as separation criteria includes the length of the 

longest span."

Thi

Chapter 3 - Land Use and Recreation -- 3.17.2.2 -- 54 -- 1 -- The easement would also specify that the ROW be kept clear of 

trees and buildings or structures, and prohibit storage of flammable material of any kind within the boundaries of the ROW or 

bringing equipment or vehicles to the ROW that would exceed 14 feet in height. The ROW may be used for roads, agricultural crops, other purposes not inconsistent with the above limitations, and special circumstances in mining and agricultural areas 

where necessary to maintain existing practices, as negotiated with the landowner. -- Height limit should state 12 feet.

Info

Chapter 3 - Land Use and Recreation -- 3.17.2.2 -- 54 -- 2 -- In some locations, the presence of a 230- or 500-kV transmission 

line ROW could be considered a corridor. -- The Draft EIS should be revised to provide specific locations of these locations 

and why they, in particular would be considered a corridor.

Ad

Chapter 3 - Land Use and Recreation -- 3.17.2.2 -- 57 -- LU-1 -- "LU-1 To assist agency and county law enforcement in minimizing unauthorized OHV use on public and private lands, monitor OHV use and post signs along access roads where OHV activity has increased ..." -- The Draft EIS should be revised to eliminate the requirement that the Proponent monitor 

OHV use. This is a difficult and time-consuming task that we do not have the personnel to implement effectively.

No 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 3 -3.21.1.4 -- 12 -- 3 -- In the Gateway West study area, wet environments may include dairy barns or feedlots. Stray 

voltage issues may occur when an animal makes contact with a metal object that is at a different potential from another point 

in contact with the animal (i.e., the nearby ground or earth potential). This may occur when there is poor grounding or bonding

of the metal object to the earth and the electrical ground. For example, faulty or improperly wired motorized appliances, 

portable electric heaters, and fluorescent lights can lead to stray voltage issues. Metallic fences or large metallic object that 

are adjacent to, run parallel, or pass under the proposed Gateway West transmission lines may develop a different potential 

than the surrounding ground if not properly grounded; however, this is easily resolved by grounding the object. -- Delete this 

paragraph because, as stated in the first paragraph on stray voltage, stray voltage is a distribution phenomenon and does not pertain to transmission lines. It is fine to maintain the first and third paragraphs of this section.

Ed

Chapter 3 - 3.21.2.2 -- 37 -- 1 -- Stray Voltage – Stray voltage or current is a problem whereby currents or potentials on conductive objects and metal work can come in contact and flow through humans or animals. Stray voltage is often a concern involving the farm electrical system and the local utility distribution system where a potential is developed on the grounded neutral system of the farm or utility. If an animal or human comes in contact with metal equipment that is at a different potential 

than the ground on which they are standing, a current may flow through the animal, or person, to ground and the potential be 

detected. Usually if this potential difference exists, it is too small to generate any physical or behavioral changes. In the case of 

nearby transmission lines, fences or piping that pass under or near the transmission line and connect back to a farm can be the source of currents and potentials on the farm. Stray voltage may be the result of corrosion or broken ground connections. 

Good grounding practices would reduce or eliminate this concern. The Proponents maintain programs for on-site investigation 

of stray voltage concerns. -- The summary should be specific that stray voltage is a distribution problem and this transmissionproject will not impact the local distribution systems or create a change in the occurrence of stray voltage.

Ad

Chapter 3 - Land Use and Recreation -- 3.21.2.2 -- General -- General Comment -- The Draft EIS needs to be revised to disclose that the Proponent may have to ignore restrictions in the case of emergency that requires immediate repair. In those cases, public health and safety will receive first priority.

The acc

Chapter 4 - Basis for Assessment -- Entire Section -- All -- Overall the section does an excellent job listing the reasonablyforeseeable future actions, referring to the Affected Environment sections for details on the cumulative impacts of past actions, 

and providing rationale for the cumulative impacts analysis areas for each discipline. The section does need to improve its 

quantification of those impacts to take advantage of all the excellent preliminary work done in this section. We recommend the 

Draft EIS be revised to address this.

No

Chapter 4 - Basis for Assessment -- 4.1.2 -- 3 -- Table 4.1-1 -- Known locations of eagle nests and suitable winter roosting habitat within 10 miles of the DICIAA. -- Bald Eagle: 10 miles seems excessive for a cumulative impacts analysis area for eagles. Doesn't the FWS use a 6 mile buffer for golden eagles? A reference for the 10 mile buffer similar to what has been done for greater sage grouse would be helpful.

The the knoa g

Chapter 4 - Basis for Assessment -- 4.1.2 -- 4 -- 1 -- For the purposes of this analysis, the temporal extent of the projects to be considered is the expected physical operational service life of this Project (50 years), plus the estimated 10 years needed for

substantial site rehabilitation after decommissioning is completed. -- There needs to be more description regarding the life of

the project stating that although 50 years is chosen for purposes of analysis, that this line may be in service much longer so 

that the reader understands it may not be decommissioned after 50 years. The Draft EIS needs to be revised to address this.

Chtran

ser

Chapter 4 - Basis for Assessment -- 4.1.2 -- 5 -- Table 4.1-1 -- Table -- Greater Sage grouse: it is confusing why the Draft EIS 

uses multiple cumulative impacts analysis areas for sage grouse. It is not clear what the value of doing this is for assessing cumulative impacts. The Draft EIS should be revised to use the most appropriate distance to capture cumulative impacts, 

provide that rationale, and use that area to assess cumulative effects.

The direrefl

Chapter 4 - Basis for Assessment -- 4.1.3 -- 8 -- 1 -- In several cases, the Proposed Route or Route Alternatives would be 

incompatible with land allocation classifications (frequently but not exclusively VRM classifications) assigned to the federal 

lands they would cross. Chapter 2 summarizes all plan amendments, Appendix F-1 contains details and analysis of each proposed amendment to BLM land management plans, Appendix F-2 contains details and analysis of each proposed amendment to Forest Service land management plans, and Appendix G contains maps and visual analysis documentation, 

including photographs and simulations, in support of the amendments analyses. -- The Draft EIS should be revised to reword 

the first sentence to say that the Proposed Action and alternatives would require land use plan amendments instead of saying 

they would be “incompatible” with existing land use plans.

LanProForsig
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 4 - Basis for Assessment -- 4.1.3 -- 8 -- 2 -- In most cases, the amendments to the land management plans are designed to allow the Project to be constructed and operated without changing the underlying land allocations. Where that is 

the case, there are no cumulative effects of the plan amendment that are not fully captured in the cumulative effects of the 

Project itself. Those amendments are considered in detail by resource, below, but not addressed further in this section. Where that is not the case, the resultant plan amendment could have cumulative effects in addition to the cumulative effects of the 

proposed Project itself. For land use plan amendments, in addition to considering the cumulative effects of the Project itself,

the impact of the underlying land use allocation revision is analyzed in this section across the extent of the polygon proposed

for revision. For example, if a polygon mapped as VRM Class II is proposed to be changed to VRM Class III, the impact of that 

change is taken into consideration as part of the cumulative effects. -- The assumption that the land use plan allocation is a cumulative effect is flawed. Changes in the land use plan allocation are required specifically for this project to occur and are 

therefore “connected actions” to the project, not “cumulative actions”. As such, the impacts of these land use plan amendments should be disclosed as direct effects of this project and should be assessed as using appropriate broad programmatic analysis indicating the consequences of the change in management of this land (in contrast to vague references to future projects that could occur there because of the change). Secondly, the cumulative effects section should describe the 

impacts of site-specific impacts of “reasonably-foreseeable future actions” on the same resources that this project affects. The 

term “reasonably-foreseeable” implies those actions are either planned or proposed not future actions that may or may not occur as a result of a land use allocation change. Such speculation is not appropriate for cumulative impacts analysis. All such direct/indirect effects described as “cumulative effects” in Section 4.1.3 for land use plan amendments should be moved to the 

appropriate direct/indirect impacts sections of the Draft EIS and the impacts of the land use plan amendments should be revised to provide appropriate broad scale programmatic analysis of the impacts of changing the land use 

designation/allocation. The Draft EIS needs to be revised to incorporate these changes.

ImpChsepcum

Chapter 4 - Basis for Assessment -- 4.1.3.5 -- 11 -- last -- Changes in the VRM designation and the possible designation of a utility corridor along either Alternative 4B or 4D, if they are chosen and constructed, would have the effect of encouraging 

further transmission development to be sited in this corridor. Two proposed transmission lines, a 500-kV DC (TransCanada’s Zephyr line) and a 500-kV DC or AC line (Jade Energy’s Overland Intertie) were originally proposed to follow the Gateway West alignment. Both projects are on hold as of June 2011. If either moves forward in the future, they would likely be built 

along this alignment and in the designated utility corridor if this Project were approved and constructed in this location. The

change in designation would not affect currently authorized coal mining taking place in the area. No other reasonably 

foreseeable projects would be located within the area proposed for VRM amendment. Therefore, the impact of the change 

would largely be to encourage future transmission development, if any, to follow the Gateway West alignment through the Kemmerer FO. Cumulative impact of additional transmission line construction is analyzed by resource in Section 4.4, below. -- If these two projects were put on hold then they would not be considered reasonably-foreseeable. Additional explanation is 

necessary to indicate why they are still seen as reasonably-foreseeable

Ov

a ppro

Chapter 4 - Basis for Assessment -- 4.1.3.7 -- 12 -- last -- Segment 5 would also cross a VRM II parcel adjacent to the Snake 

River. If it is selected, the VRM Class II designation for the 35-acre parcel containing the pipeline recreation site (3 miles 

southwest of American Falls on the Snake River) would be changed to VRM Class IV (AOI M-2). A pipeline crossing of the Snake River is visible from that campground now. Reasonably foreseeable projects proposed include two proposed transmission lines, a 500-kV DC (TransCanada’s Zephyr line) and a 500-kV DC or 500-kV AC line (Jade Energy’s Overland Intertie), which were originally proposed to follow the Gateway West alignment. Both projects are on hold as of June 2011. If either moves forward in the future, they would likely be built along the approved Project alignment. The 35-acre designation change to VRM Class IV would not affect the approval process for these lines, because they would each need one or more land use plan amendments to be approved. Therefore, the cumulative impacts of the plan amendment that changes the VRM 

classification of the 35-acre parcel would be essentially identical to the cumulative effects of the Project itself -- The statement 

“Therefore, the cumulative impacts of the plan amendment that changes the VRM classification of the 35-acre parcel would be 

essentially identical to the cumulative effects of the Project itself” illustrates how this section confuses the cumulative impacts 

analysis. What this statement is referring to are the direct and indirect impacts of the project. Cumulative impacts are the 

incremental addition of project direct and indirect impacts onto the impacts of past, present, and reasonably-foreseeable future 

actions not associated with the project but affecting the same resources. The Draft EIS needs to be revised to address this.

ImpChsepcum

Chapter 4 - Projects or Actions w/Potential for Cum -- 4.2.1.4 -- 27 -- Table 4.2-4 -- Table -- The Draft EIS needs to be revised 

to include FMC Green River and Pocatello in this table.

Tab
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 4 - Projects or Actions w/Potential for Cum 4.2.1.4 -- 34 -- 1st after table -- Solar power generation is the process of 

converting solar energy into electricity. Multiple methods are used at existing solar facilities to convert solar energy to 

electricity, including photovoltaics (using semiconductors that exhibit the photovoltaic effect) and concentrated solar thermal

(focusing solar energy to produce steam). Most utility-scale solar facilities in the U.S. are located in the southern portion of the 

country where solar light is more intense and the light regime is more predictable. Solar facilities have low impacts on air 

quality compared to conventional fossil fuel-power plants; however, due to the large area of ground disturbance associated 

with utility-scale solar facilities, they contribute to habitat loss and fragmentation. In addition, there is some concern regarding 

the impact that these facilities could have on avian species (due to burns or collisions with project mirrors); however, very little post-construction data are available regarding this potential effect. There are no existing solar facilities in Idaho or Wyoming. -- Existing Solar facilities: If there are no existing solar facilities in the 

area, why are does the DEIS describe potential impacts of those facilities? This sub-section should be revised or deleted from the Draft EIS.

Tex

Chapter 4 - Projects or Actions w/Potential for Cum 4.2.2.5 -- 46 -- last -- In 2010, ICF International published a report 

conducted for the Wyoming Infrastructure Authority called the Wyoming Collector and Transmission System Conceptual Design (ICF 2010a). This report considered two wind resource development scenarios—one that included wind resources 

west of the Laramie Range, and one that included wind resources primarily on the east side of the Laramie Range. The intent 

was to provide a conceptual design for up to 12 gigawatts (GW) of renewable capacity. The report concluded that it was conceptually feasible to provide for this capacity under both resource scenarios... -- Transmission for Proposed Wind Energy Facilities: This section does not appear to describe reasonably foreseeable future actions that are proposed. Implementation of any of this transmission appears speculative at this time and should not be considered under cumulative impacts as per earlier comments stating that reasonably foreseeable actions were those that were actively proposed or previously proposed 

and not withdrawn.

It is prodevimpdis

Chapter 4 - Projects or Actions w/Potential for Cum 4.2.2.5 -- 48 -- last -- Wind projects are still in development in Wyoming,

but many appear to be on hold (see Table 4.2-15, above). According to AWEA, an industry association, there are 1,412 MW of 

installed capacity in Wyoming, of which 310 MW were added in 20106. Several projects were located in areas with good wind resources but also in areas listed by the State of Wyoming as Core Habitat for sage-grouse, where the Governor of Wyoming 

has stated (EO 2011-5) that wind development is inappropriate7. It is therefore not clear how much wind energy will be 

developed in Wyoming, or where that development will occur... -- Backup Energy for Firming Intermittency in Wind Generation: 

Same comment as above; this section does not describe any reasonably foreseeable future actions and should be deleted.

Tex

Chapter 4 - Projects or Actions w/Potential for Cum 4.2.2.5 -- 50 -- Table 4.2-16 -- Table -- All six pumping projects referred to 

at the start of the section should be included in this table for clarity. The Draft EIS should be revised to address this.

Tex

Chapter 4 - Projects or Actions w/Potential for Cum 4.2.2.5 -- 51 -- 2 -- Biomass feasibility studies are currently being conducted in the western states (including Idaho and Wyoming), and multiple biomass and cogeneration projects are currently 

being considered. However, at this time, formally proposed projects are limited due to current economic feasibility. No projects have been formally proposed in Wyoming; however, eight projects have been proposed in Idaho, with estimated power production ranging from 1.2 to 13 MW. Only two projects are currently proposed that would generate at least 10 MW of energy: the Adams County Electrical Biomass Facility that would generate 10 to 13 MW of energy, and the Yellowstone Tower Combined Heat and Power Plant that would generate 10 MW of energy (Crockett 2010; Huffman 2010). -- Proposed Biomass 

and Cogeneration Facilities: the proposed footprint (acreage) of the biomass/cogen facilities should be provided to set the 

stage for impacts analysis. The Draft EIS should be revised to address this.

It is futucumtha

Chapter 4 - Projects or Actions w/Potential for Cum 4.2.2.6 -- Entire section -- There are many thousands of acres of oil and 

gas leases that have not yet been fully developed. Oil and gas exploration, extraction, and development are likely to continue 

throughout the life of Gateway West. The intensity of development and the degree to which less productive fields are exploited 

are dependent on the international and domestic market for petroleum products as well as any government incentives (e.g., 

depletion allowance) or disincentives (e.g., carbon tax). Although the leases are in place and development could technically take place at any time, the market drivers to exploit them are unknown now. Therefore, it is not possible to quantify the 

additional amount of environmental impact due to future oil and gas development. The existence of a robust electric grid will 

continue to support oil and gas extraction by providing the power for the extraction pumps. The Creston Substation is proposed in part to serve a future load from oil and gas extraction both north and south of the proposed Gateway West transmission line in the areas of Segments 2 and 3... -- This section does not discuss reasonably foreseeable future development at a level to allow for cumulative impacts analysis. It is possible that RFDs for these types of development could 

be taken from existing RMPs to provide a robust cumulative impacts analysis. The Draft EIS should be revised to address this.

It is futucumtha
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 4 - Projects or Actions w/Potential for Cum 4.2.2.8 -- Entire section -- It is reasonable to expect that the Forest Service 

and the BLM will continue their programs of vegetation management for fire control, salvage timber harvest, and road maintenance and decommissioning. However, no site-specific information on activities scheduled more than 2 years in the 

future was either found on the SOPA for the Medicine Bow-Routt, Caribou-Targhee, or Sawtooth NFs or available for the 

Kemmerer or Pocatello FOs. -- The Draft EIS should be revised to delete this statement, it provides no actual reasonably 

foreseeable future actions.

It is are cha

Chapter 4 - Activities & Potential Shared Resource Impacts -- 4.3 -- 53 -- Table 4.3-1 -- Table -- This table would be more 

informative to the reader if it included a column with overall disturbance acreages for each broad category of action. A footnote 

referencing the qualitative descriptions for each resource in the table would allow the reader to easily see both the detailed 

qualitative descriptions of cumulative impacts and the quantification of those impacts. The Draft EIS should be revised to address this.

It is futucumtha

Chapter 4 - Cumulative Impact -- 4.4.3 -- 55-59 -- Entire section -- The 10-mile-wide CIAA for visual resources includes a 

variety of landscapes such as mountainous areas, broad agricultural valleys, expanses of shrub steppe that have been or are 

still used for livestock grazing, areas of intensive mining, coal and gas development extraction and, for most of the Proposed Route and Route Alternatives, one or more existing transmission lines that occur within a half mile. Section 3.2 – Visual 

Resources discusses the direct and indirect effects of the Proposed Route and Route Alternatives on visual resources. The Proposed Route was designed to take advantage of existing utility corridors to minimize the introduction of a new transmission facility into a previously undisturbed landscape and reduce the visual impact on the landscape. Segment 9 is the longest exception to this general rule and the Proposed Route crosses areas without other major existing transmission lines for most 

of the its length. Segment 1E also crosses landscapes without existing high-voltage transmission lines for 88 miles. However, even with careful siting and the implementation of additional mitigation measures required or recommended by the Agencies, 

the Proposed Route and Route Alternatives are expected to have a substantial adverse visual impact on the landscape in 

certain locations... -- This section does not include an assessment of the visual impacts when considered with existing VRM and development so it doesn’t have a substantive basis for saying impacts would be “substantial”. While this section includes a

good qualitative description, its lack of quantification needs to be improved (e.g. it could quantify acres of disturbance and 

miles of power line within visually sensitive areas for example). The Draft EIS should be revised to address this.

Sedevcom

Chapter 4 - Cumulative Impact -- 4.4.4 -- 59-60 -- Entire section -- In some areas, the construction of the Gateway West transmission line could lead to the establishment of a corridor in which other lines may be installed in the future. There is a

potential that cumulative impacts to the visual settings for some cultural resources would occur due to the establishment of a 

corridor and the subsequent construction of additional transmission lines.... -- This section should quantify total cumulative 

disturbance, particularly in areas where there is a high likelihood of finding cultural resources. Again, this section lacks 

quantification and at a minimum it should provide cumulative acres of disturbance. See comment above regarding Table 4.3-1. 

The Draft EIS should be revised to address this.

Defrom quawa

Chapter 4 - Cumulative Impact -- 4.4.5 -- 60-62 -- Entire section -- that could combine with the Gateway West Project and result in cumulative effects to the socioeconomic environment include projects with the potential to affect population, the economy and employment, housing, property values, education, public services, and tax revenues. The effects from past and 

present activities are generally accounted for in the baseline socioeconomic environment characterized in Section 3.4.1. 

These past and present activities generally include construction and operation of existing transmission line and other linear 

projects, development and operation of energy generation projects, past and present oil and gas operations, and other residential and commercial development (see Section 4.2.1). Ongoing and reasonably foreseeable projects with the greatest potential to combine with the proposed Gateway West Project and result in cumulative impacts include 1) current construction projects that would continue through 2011 and beyond, or 2) reasonably foreseeable actions that would be in construction 

between September 2011 and December 2018, when the majority of construction activities would occur on Gateway West. 

Cumulative effects on socioeconomic resources do not differ substantially by alternative.... -- This section could make an 

estimate of cumulative numbers of new workers and revenues from reasonably-foreseeable future projects to better quantify 

cumulative socioeconomic impacts on housing, infrastructure, and tax revenues. As it is now, there is not a basis for saying there would be housing shortages for example. Also, if the DEIS can do a general estimate for the project's tax revenues, then 

it should be estimating roughly the revenues for reasonably-foreseeable future actions. The Draft EIS should be revised to incorporate these suggestions.

It is 

futucumtha
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 4 - Cumulative Impact -- 4.4.6 -- 62 -- Entire section -- Data compiled by the U.S. Census at the block group level 

indicate the potential presence of minority and low income communities in the vicinity of the Project. The Project is not 

expected to generate high or adverse human health or environmental effects on nearby communities. The Project would, 

however, have high, long-term visual impacts in some locations where the structures and overhead conductors would be visible from private residences, including parts of the Census Block Groups that have potential minority and low income 

communities. While these potential impacts exist, overall, the proposed Project does not appear to exhibit systematic bias 

toward placing the Project in minority or low income communities (see Section 3.5 – Environmental Justice). Cumulative effects on visual resources are discussed above in Section 4.4.3. Local construction expenditures for materials and supplies 

and spending by workers directly employed by the Project are expected to benefit local economies. -- This section does not 

address cumulative impacts to environmental justice communities which would be appropriate if there were none from this 

project. The Draft EIS should provide the rationale for this assessment such that it does not show “systematic bias” towards 

low income or minority communities and therefore does not have disproportionate impacts on these communities. The Draft 

EIS should be revised to address this.

The 

this imp

Chapter 4 - Cumulative Impact -- 4.4.7 - 4.4.12 -- 63-84 -- Entire sections -- The major ecological changes to vegetation that have occurred, and that continue to occur, in the CIAA due to past and present actions include changes in vegetation 

composition and conditions due to fire, grazing, mining, oil and gas development, agriculture, infrastructure development, and other forms of development. Of particular concern is the continuing degradation of shrub-steppe habitat, primarily due to increased abundance and dominance of non-native species. Planned activities, including construction of infrastructure, mining, and expansion of residential development, would contribute to this overall loss of native vegetation, increase habitat for 

noxious weeds, and result in the potential loss of rare plant occurrences and habitat (see Sections 3.7 and 3.8 discussion). Grazing, which is prevalent along Gateway West in Wyoming and parts of Idaho, may also affect vegetation by increasing 

habitat and distribution of noxious weeds and other non-native plants and by causing shifts in native species composition because of differential selection of food plants. These processes will continue into the foreseeable future.... -- These sections 

should provide the acreage of cumulative disturbance to these habitats and vegetation cover types. As it is now, there is no basis for the many claims of “substantial” cumulative impacts. In most cases these sections just reiterate the numbers from the

Proposed Action without disclosing the cumulative disturbance of all the other reasonably-foreseeable future projects. 

Additionally, the analysis also doesn’t match the point of establishing the cumulative impacts analysis areas defined at the 

start of this section. Without quantification, those analysis areas (particularly for wildlife) are of minimal value.

De

incdevnotThe condev

Chapter 4 - Cumulative Impact -- 4.4.14 -- 85 -- Entire section -- There are several concentrations of known fossil-bearing formations close to or at the surface in the CIAA for Gateway West. Based on the indices reported in Section 3.13, which discusses paleontological resources for the Project, the most sensitive of these areas are found along Alternative Routes 4B 

through 4E, near Fossil Butte National Monument, and near Alternatives 8A and 9A, which pass near to the boundary of Hagerman Fossil Beds National Monument. In the area of high fossil sensitivity, the additional ground-disturbing activities with 

potential to degrade fossil-bearing formations include the two proposed transmission lines, Zephyr and Overland Intertie; no 

other projects are proposed in this area. These projects have the potential to uncover fossils of potential scientific importance. 

However, the relatively small footprint of the several projects when compared with the large extent of the fossil-bearing 

formations indicates that the cumulative impact of Gateway West would be minor. -- This analysis should at a minimum disclose the cumulative total of potential disturbance in formations with a high likelihood of encountering vertebrate fossils.

Right now it doesn’t quantify cumulative impacts to paleontological resources. The Draft EIS should be revised to address this.

It is futucumtha
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 4 - Cumulative Impact -- 4.4.15 -- 85-86 -- Entire section -- Some of the Projects listed in Section 4.3 have the 

potential to create geologic hazards (e.g., mining activities creating subsistence, leaving unstable walls, and sinkholes). In addition, multiple crossings of earthquake zones and areas of high landslide potential by various proposed transmission lines could contribute to the possibility of catastrophic failure of several lines at once. The Proposed Route and all Route 

Alternatives for Segments 4, 5, and 7 would cross areas of high earthquake risk (see Section 3.14 – Geologic Hazards, for details). Project structures could be damaged or collapse in the event of fault rupture beneath or adjacent to a tower due to 

inaccurate fault location during project design. Collapse of Project structures would potentially result in power outages, 

damage to nearby roads or structures, and injury or death to people. In addition to Gateway West, three existing 345-kV 

transmission lines and the proposed Overland Intertie and Zephyr transmission line projects would cross high earthquake risk areas in Segments 4, 5, and 7, as well as crossing areas of high landslide potential in the western end of Segment 4. BLM 

would require proponents of all new transmission lines to conduct geotechnical exploration and avoid locating any project facilities on earthquake traces or in areas of active land movement. Prudent engineering design and compliance with national building standards would reduce the risk for each of the transmission lines to a minor level. Taken together, the risks to each

line and to the existing 345-kV lines would raise the chances that at least one of them might fail in an earthquake or landslide 

event. However, the cumulative risk would still be low provided that standard engineering practices for design and 

construction, and the proposed operations and maintenance activities for Gateway West were also practiced by other 

proponents. -- There is no quantification of reasonably-foreseeable disturbance acreages in high erodibility soils or areas of high geologic instability. The Draft EIS should be revised to address this.

It is futucumtha

Chapter 4 - Cumulative Impact -- 4.4.16 -- 86 -- Entire section -- Effects on soils from Gateway West that would contribute cumulative effects include soil loss due to wind erosion, soil mixing, soil compaction, and soil contamination. Soils in the CIAA 

have been affected by past activities such as pipelines, transmission lines, roads, oil and gas development, OHV use, and 

grazing. During construction of any of the current or reasonably foreseeable projects, vegetation would be removed exposing 

the soil to erosional forces, soil compaction could occur from vehicle traffic, and soil excavation would cause soil mixing, 

although BMPs (minimizing bare soil exposed to wind, water, and steep slopes, and stockpiling topsoil for use during reclamation) are or would be used to minimize the extent of effects. Soil contamination could occur from chemical or petroleum 

spills, although the risk is not great. Soil disturbance will remain during the life of the projects. These effects are short-term, 

occurring during the construction period, as disturbed areas are required to be reclaimed. Loss of production due to sites occupied by facilities (transmission line structures energy generation facilities, commercial development, and the access roadsto all of these) would remain during the life of the projects. Effects on soils could occur from unauthorized off-road vehicle use 

from construction on projects with inadequate access control. Decommissioning and reclamation can recover some of the soil 

productivity, but is not 100 percent effective. Large construction projects, mining, roads, and pipelines are the projects that

have the most of these types of effects on soils. The implementation of BMPs and reclamation on all projects would minimize 

soil impacts. The cumulative impact of Gateway West, when taken together with the already substantial impact of past and 

present activities and proposed future action on some sensitive soils, could be substantial even with expected erosion control 

measures fully effective -- There is no quantification of reasonably-foreseeable disturbance acreages in high erodibility soils or areas of high geologic instability. The Draft EIS should be revised to include this.

It is 

futucumtha

Chapter 4 - Cumulative Impact -- 4.4.17 -- 86-87 -- Entire section -- The impacts to surface waters from the Gateway West Project include potential for sedimentation and temperature increases due to road crossing construction and ROW clearing. These impacts would be minimized but not entirely eliminated by the conditions of the SWPPP and additional mitigation 

measures. It is reasonable to assume that other construction projects would also minimize but not eliminate their impact. However, when taken together with the substantial degradation to surface water resources from grazing, fires, and invasive 

species, the additional minor impacts of Gateway West and other proposed projects would contribute to a substantial 

cumulatively impact. Construction of Gateway West and any other project could affect groundwater if an accidental chemical 

spill occurred near an open excavation for a foundation on any of the planned projects that occur in the same area of shallow 

groundwater found in Segments 4, 5, and 7. The risk is relatively small because these types of spills rarely occur and because 

the Proponents have committed to enforce the terms of their SPCC Plan. Water usage would also occur for most facility construction projects in the CIAA, mostly for dust control and mixing concrete for other transmission line facilities, energy generation facilities, commercial developments, and roads. This water usage is 

important because of federally listed threatened and endangered fish and plants in these watershed and the cumulative effects 

are discussed in Section 4.4.8. Because Gateway West would not require any water rights, there would be no cumulative 

effects on water right -- The Draft EIS should include quantification of cumulative numbers of water crossings and/or cumulative disturbance in 100 year floodplains and/or within 1⁄4 mile of perennial water bodies from reasonably-foreseeable future actions.

It is futucumtha
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 4 - Cumulative Impact -- 4.4.18 -- 87-92 -- Entire section -- The WWE Corridor PEIS (DOE and BLM 2008) designates 

corridors on federal lands within 11 western states (Arizona, California, Colorado, Idaho, Montana, Nevada, New Mexico, 

Oregon, Utah, Washington, and Wyoming) for oil, gas, and hydrogen pipelines, as well as electricity transmission and distribution facilities. However, it does not take into account the current federal land use plans (such as the Forest Service 

Forest Plans or the BLM RMPs) that still exclude those uses along many parts of the corridor. As a result, the siting of these 

types of facilities within the WWE corridor may still require amendments to existing federal land management plans (Forest Plans, RMPs, and MFPs) that could change existing land use allocations for the affected lands. In addition, the Gateway West Project is only partially located within this designated corridor. The Gateway West Project would cumulatively add to the 

changes made to these federal land use plans by the past, present, and reasonably foreseeable future projects. The Route 

Alternatives (such as Alternatives1E-C and 7I) that cross more public lands or would impact more sensitive resources on 

federal lands would have a greater contribution to this cumulative effect on public land use plans than the Proposed Route.... -- 

The Draft EIS should include total acreage of land use changes or even land use category changes associated with amendments and reasonably-foreseeable future actions. The Draft EIS needs to be revised to address this.

LanAp

Chapter 4 - Cumulative Impact -- 4.4.19 -- 92-94 -- Entire section -- Within the Agriculture CIAA, past, present, and reasonably 

foreseeable activities that could combine with the Gateway West Project and result in cumulative effects to agriculture includeprojects with the potential to affect prime farmland, livestock grazing, crop production, CRP lands, and dairy farms. The effects 

from past and present activities that have shaped current patterns of agricultural use are generally accounted for in the 

existing conditions overview presented in Section 3.18.1.5. The analysis area used for the direct and indirect effects analysis is the same area as the Agriculture CIAA... -- The Draft EIS needs to disclose the quantification of total acreage of prime farm 

land impacted by reasonably-foreseeable future actions. This section restates the project impacts. The Draft EIS should be 

revised to address this.

It is futucumtha

Chapter 4 - Cumulative Impact -- 4.4.20 -- 94 -- Entire section -- Linear facilities invariably need to cross other linear features 

such as highways and railroads. These crossings can interfere with use of the roads and railroads during project construction, sometimes including needing to reroute or delay traffic. However, these impacts would be temporary in nature and only last as long as construction activities occurred within the area. If other reasonably foreseeable projects are construction at the same

time and location as the Gateway West Project, or immediately before or after this project, then there could be a minor temporary cumulative effect on traffic volumes on local roads, which would be mitigated by traffic controls required by both county and federal regulations. Cumulative impacts on transportation do not differ substantially by alternative, because the 

measures in place to protect the public during both construction and operations would apply both for Gateway West and other 

projects -- Based upon the statements in this Draft EIS, this section shows the project has no impact on transportation and as 

such should be eliminated from the cumulative impacts analysis with the associated rationale for doing so. The Draft EIS 

should be revised to address this.

Evethe concum

Chapter 4 - Cumulative Impact -- 4.4.21 -- 95 -- 1st-2nd -- Total estimated CO2 equivalent emissions (total emissions of all 

greenhouse gases converted to equivalent of CO2) from construction of the Project is 232,268 tons over the construction 

period. Approximately 54 percent of these emissions or 125,425 tons CO2 equivalent is allocated to Wyoming, and 46 percent of these emissions, or 106,843 tons CO2 equivalent, is allocated to Idaho. On an annual basis, the project construction CO2 

equivalent emissions for Wyoming and Idaho are 24,593 and 20,950 tons CO2 equivalent per year respectively. 

Predicted CO2 equivalent emissions for 2010 in each state are 66,330,000 tons CO2 equivalent for Wyoming, and 43,560,000 

tons CO2 equivalent for Idaho (CCS 2007, 2008). The construction CO2 equivalent emissions from the Project represent 

approximately 0.037 percent of the annual total for Wyoming, and 0.048 percent of the annual total for Idaho. GHG emissions from operations activities would be on the order of less than 3 tons CO2 equivalent per year. Therefore, construction and 

operations of the Gateway West Project would not add substantially to the cumulative effects of past, present, and reasonably 

foreseeable future projects in terms of greenhouse gas emissions. -- It is unclear if these emissions are the cumulative 

emissions from reasonably-foreseeable future actions or are the emissions from this project? Also, estimated potential 

emissions from the reasonably-foreseeable power projects described previously should be provided. The Draft EIS should be revised to incorporate these suggestions.

Texguebeebe pro

Chapter 4 - Cumulative Impact -- 4.4.22 -- 95 -- Entire section -- The analysis of electrical effects determined that the Gateway West Project would have no effects on health or safety; therefore, there would be no cumulative effects to other past, present,

or reasonably foreseeable future projects. This is the case across all alternatives. Cumulative effects of noise due to corona 

effects are treated in Section 4.4.24. -- It is unclear why the cumulative impacts analysis for electrical environment centers on 

health and safety. which is covered in the next section. This section should discuss the cumulative impacts of all the 

reasonably-foreseeable future actions and this project on electrical capacity, reliability, public needs, peak usage, etc. The Draft EIS should be revised to incorporate these suggestions.

The apprevbey
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 4 - Cumulative Impact -- 4.4.24 -- 96 -- Entire section -- Cumulative impacts due to construction noise could occur 

within 1,000 feet of the Project area or ancillary facilities as other projects or activities add to the noise from the time of

Gateway West construction. In some cases, other construction projects could be using the same roads as Gateway West and 

additional construction-related traffic noise could occur, though it is very unlikely that these projects would be constructed 

concurrently. No substantial long-term changes in the volume of traffic and resulting potential transportation noise impacts are 

expected. Therefore, Gateway West would not contribute substantially to adverse cumulative noise impacts during construction. Operations noise from the Gateway West Project is limited to corona noise. Corona noise is not audible outside the ROW. Cumulative impacts on noise do not differ substantially by alternative because the measures in place to reduce noise of both 

construction and operations would apply both for Gateway West and other projects. With the exception of limited areas where the Gateway West Project crosses other transmission lines, there would be no cumulative effect when taken together with 

other transmission lines because of the separation distances and lack of sensitive receptors. -- The Draft EIS should be 

revised to provide the quantification of cumulative impacts of construction noise of reasonably-foreseeable future actions 

within 1,000 feet of the sensitive receptors so that the Draft EIS discloses what is being impacted by the project during the 

same time period.

It is futucumtha

Appendix A -- Figure A-2 -- Refer to figure -- Show and label Dave Johnston substation location. ChAppendix A -- Figure A-7 -- Refer to figure -- Kinport substation is incorrectly shown as Ben Lomond substation ChAppendix A -- Figure A-12 -- Refer to figure -- Needs to depict route to Rogerson substation and comparison of alternate 

should be included in analysis.

Thi

Appendix A -- Figure A-2-A12 -- Refer to figure -- Add ID labels for all eliminated routes to help readers locate them easily ElimAppendix A -- Figure A-2-A12 -- Refer to figure -- Increase node ID labels so they are readable We Appendix B - TL & SS Components - Types of Transmission Line .... -- 1.1.1 -- B-1 -- 2 -- In addition to the more typical 

tangent structure configurations, specialized structures are designed where the line must turn an angle. Each structure type is

individually designed, depending on the line angle and the underlying soil and rock conditions, to withstand the pull of the wires in different directions. Angle structures are heavier and have deeper foundations. Figure B-7 illustrates structure typesconsidered during preliminary Project design but not carried forward as proposed by the Proponents. Table 2.6-2 and Section 2.6.2, Chapter 2, provide a comparison with proposed structures and a rationale for the selection of the proposed structures. -- The second paragraph should be separated into two paragraphs, starting with the sentence "Figure B-7 illustrates ...". This 

part of the paragraph is a new thought detailing what structures were considered but not carried forward. The first portion of 

this paragraph deals with angle and deadend structures that are being carried forward.

Apis p

Appendix B - TL & SS Components - Types of Transmission Line .... -- 1.1.1 -- B-4 -- Fig. B-3 -- [blank] -- Add note "Detail of Conductor Bundle" to arrow in lower left portion of the figure (see similar note on Fig. B-2)

Apis p

Appendix B - TL & SS Components - Types of Transmission Line .... -- 1.1.1 -- B-5 -- Fig. B-4 -- [blank] -- On the 230-kV 

Proposed Design sketch, revise 19'-6" to 21'-6" and move the dimension line for the 60'-90' height to the top of the shield wire. 

This sketch will then match Fig. B-1. Also, add a sketch for the single circuit 345-kV ROW.

Apis p

Appendix B - TL & SS Components - Types of Transmission Line .... -- 1.1.1 -- B-8 -- New -- N/A -- Insert new figure of typical 

tangent 345kV structure

Apis p

Appendix B - TL & SS Components - Types of Transmission Line .... -- 1.1.1 -- B-9 -- 2nd -- [blank] -- Add "Structure heights 

would vary depending on terrain and the requirement to maintain minimum conductor clearances from ground" after the 

sentence describing the average distance between 230-kV h-frame structures. This will make the discussion similar to that of the 500-kV structures in the next paragraph.

Apis p

Appendix B - TL & SS Components - Types of Transmission Line .... -- 1.1.1 -- B-9 -- Table B-1 -- Footnote: 2/ Includes 230-kV and 345-kV interconnections with existing Jim Bridger Substation, which will be constructed using tubular steel singlecircuit structures. Note that for estimating purposes, the larger disturbance footprint of the 500-kV double-circuit tower type

was used. Actual disturbance will be less -- Add 345kV row for segment 3A; could then delete footnote 2

Apis p

Appendix B - TL & SS Components - Types of Transmission Line .... -- 1.1.1 -- B-9 -- Tbl B-1 -- [blank] -- Temporary and 

Permanent Disturbance Area: Remove "ROW width" because this is not the ROW width.

Apis p

Appendix B - TL & SS Components - Types of Transmission Line .... -- 1.1.1 -- B-9 -- Tbl B-1 -- [blank] -- Revise title of last 

two columns to Temporary and Permanent Disturbance Area (matches the paragraph describing the table and the 

continuation of the table on page B-10).

Apis p

Appendix B - TL & SS Components - Types of Transmission Line .... -- 1.1.3 -- B-10 -- 1st -- [blank] -- Change the second sentence to state "foundation diameter and depth ... are dependent on the structure type and type of soil ..."

Apis p

Appendix B - TL & SS Components - Types of Transmission Line .... -- 1.1.3 -- B-10 and B-11 -- 1st -- [blank] -- Revise singlecircuit tangent structure foundation depth from 15 to 22, double-circuit tangent structure diameter from 6 to 5 and depth from 

20 to 26 (all to match Table B-2).

Apis p
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Appendix B - TL & SS Components - Types of Transmission Line .... -- 1.1.1 -- B-11 -- Table B-1 -- N/A -- Add 345kV 

foundation row for segment 3A

Apis p

Appendix B - TL & SS Components - Conductors -- 1.2 -- B-12 -- New -- N/A -- Add 345kV paragraph describing conductor Ap

is p

Appendix B - TL & SS Components - Conductors -- 1.2 -- B-12 -- 3 -- Where multiple conductors are utilized in a bundle for each phase, the bundle spacing would be maintained through the use of conductor spacers at intermediate points along the 

conductor bundle between each structure. The spacers serve a dual purpose: in addition to maintaining the correct bundle configuration and spacing, the spacers are also designed to damp out wind-induced vibration in the conductors. The number 

of spacers required in each span between towers would be determined during the final design of the transmission line. -- 

Correct paragraph. Vertical double bundle does not use spacers; just stockbridge dampers. The only place where spacers are required is in the last span into a substation where the bundle rolls from vertical to horizontal.

Ap

is p

Appendix B - TL & SS Components - Insulators -- 1.3.1 -- B-12 -- 1 -- As shown in Figure B-1, insulator assemblies for 230-kV H-frame tangent structures would consist of one insulator string hung vertically from the cross arm in the form of an “I.” As 

shown in Figures B-2 and B-3, insulator assemblies for 500-kV tangent structures would consist of two strings of insulators normally in the form of a “V.” These strings are used to suspend each conductor bundle (phase) from the structure, maintaining the appropriate electrical clearance between the conductors, the ground, and the structure. The V-shaped 

configuration of the 500-kV insulators also restrains the conductor so that it would not swing into the structure in high winds. Dead-end insulator assemblies for both 230-kV and 500-kV lines would use an I-shaped configuration, which consists of insulators connected horizontally from either a tower dead-end arm or a dead-end pole in the form of an “I.” Insulators would 

be composed of grey porcelain or green-tinted toughened glass or single unit polymer (no ceramic insulators) -- Add sentence discussing tangent 345kV insulator assembly configuration.

Apis p

Appendix B - TL & SS Components - Insulators -- 1.3.1 -- B-12 -- 1 -- As shown in Figure B-1, insulator assemblies for 230-kV H-frame tangent structures would consist of one insulator string hung vertically from the cross arm in the form of an “I.” As 

shown in Figures B-2 and B-3, insulator assemblies for 500-kV tangent structures would consist of two strings of insulators normally in the form of a “V.” These strings are used to suspend each conductor bundle (phase) from the structure, maintaining the appropriate electrical clearance between the conductors, the ground, and the structure. The V-shaped 

configuration of the 500-kV insulators also restrains the conductor so that it would not swing into the structure in high winds. Dead-end insulator assemblies for both 230-kV and 500-kV lines would use an I-shaped configuration, which consists of insulators connected horizontally from either a tower dead-end arm or a dead-end pole in the form of an “I.” Insulators would 

be composed of grey porcelain or green-tinted toughened glass or single unit polymer (no ceramic insulators) -- Add 345kV to 

"I-string" dead-end sentence

Apis p

Appendix B - TL & SS Components - Insulators -- 1.3.1 -- B-12 -- 1st -- [blank] -- Change no to non in last sentence (in parentheses, non-ceramic insulators).

Apis p

Appendix B - TL & SS Components - Grounding Systems -- 1.3.2 -- B-13 -- 2 -- The methods and equipment needed to mitigate these conditions would be determined through electrical studies of the specific situation. As standard practice and as

part of the design of the Project, electrical equipment and fencing at the substation would be grounded. All fences, metal gates, pipelines, metal buildings, and other metal structures adjacent to the ROW that cross or are within the transmission line 

ROW would be grounded. If applicable, grounding of metallic objects outside of the ROW may also occur, depending on the 

distance from the transmission line as determined through the electrical studies. These actions take care of the majority of 

induced current effects on metallic facilities adjacent to the line by shunting the induced currents to ground through ground rods, ground mats, and other grounding systems, thus reducing the effect that a person may experience when touching a 

metallic object near the line (i.e., reduce electric shock potential). In the case of a longer parallel facility, such as a pipeline 

parallel to the Project over many miles, additional electrical studies would be undertaken to identify any additional mitigation 

measures (more than the standard grounding practices) that would need to be implemented to prevent damaging currents from flowing onto the parallel facility, and to prevent electrical shock to a person that may come in contact with the parallelfacility. Some of the typical measures that could be considered for implementation, depending on the degree of mitigation 

needed, could include (NACE International 2003): -- Correct paragraph. Typically for 230 and 345kV lines, fences, metal gates, etc are not grounded. At 500kV they will be. Refer to PAC transmission standard TD310.

Ap

is p
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Appendix B - TL & SS Components - Optical Ground Wire -- 1.4.1 -- B-14 -- 1 -- Reliable and secure communications for system control and monitoring of Gateway West is very important to maintain the operational integrity of the Project and of the

overall interconnected system. Primary communications for relaying and control would be provided via the OPGW that would be installed on the transmission lines. For the 500-kV transmission lines, a secondary communications path would be provided 

by the Proponents’ existing microwave system, which is currently installed from the Central Wyoming area near the Windstar 

Substation west to existing substations near Boise, Idaho. A secondary communication path may also be developed using a powerline carrier. No new microwave sites are anticipated for the Project. Updated microwave equipment may be installed at 

existing sites and at the substations -- Add discussion of 2 communication systems from Anticline to Bridger. Must be diverse 

paths. Insert somewhere in section.

Apis p

Appendix B - TL & SS Components - Optical Ground Wire -- 1.4.1 -- B-15 -- 2 -- Each structure would have two lightning 

protection shield wires installed on the peaks of each of the 500-kV single- or double-circuit lattice steel structures (see 

Figures B-2 and B-3). On the 230-kV H-frame structures (see Figure B-1) these lightning protection shield wires would be 

installed near the top of each pole. On both the 500-kV and 230- kV lines where communication is required, one of the shield wires would be composed of extra high strength steel wire with a diameter of 0.495 inch and a weight of 0.517 pound per foot. 

The second shield wire would be an OPGW constructed of aluminum and steel, which carries 48 glass fibers within its core. On the 500-kV lines, the OPGW would have a diameter of 0.637 inch and a weight of 0.375 pound per foot; on the 230- kV 

lines, the OPGW would have a diameter of 0.465 inch. The glass fibers inside the OPGW shield wire would provide optical 

data transfer capability among the Proponents’ facilities along the fiber path. The data transferred are required for system control and monitoring. On lines where communication is not required, both of the shield wires would be composed of extra 

high strength steel wires with a diameter of 0.495 inch and a weight of 0.517 pound per foot For the Gateway Project, all 500-

kV line segments would be designed to carry an OPGW. For the 230-kV lines, Segments 1W(a) and 1E would be designed to carry an OPGW, although the OPGW shield wire on Segment 1E would not immediately be connected to the communication 

system and would be left dark. Between the new Anticline Substation and the existing Jim Bridger Substation, two 

communication paths (underground or aerial) would be required for redundancy. -- Add 345kV as appropriate in paragraph.

Apis p

Appendix B - TL & SS Components - Access Roads -- 1.5 -- B-16 & B-24 -- 2 -- Access and service roads are an essential part of the construction and operation of the Gateway West transmission line. Large foundation auger equipment, heavily loaded trucks, cranes, and specialized line construction equipment will be required for construction, maintenance, and emergency 

restoration activities. Annual ground based inspections require vehicular access using 4x4 trucks or 4x4 all-terrain vehicles (ATVs) to each structure site. Section 3 of this appendix describes in detail operational requirements... -- Two sections 1.5 -

Correct numbering

Apis p

Appendix B - TL & SS Components - Access Roads -- 1.5 -- B-17 -- 2nd -- [blank] -- Change require to required in the first 

sentence.

Apis p

Appendix B - TL & SS Components - Access Roads -- 1.5 -- B-17 -- 4th -- [blank] -- Change second sentence to read 

"reliability of steel h-frame and lattice structures ..."

Ap

is p

Appendix B - TL & SS Components - Substations -- 1.5 -- B-24 -- 1st -- [blank] -- Change sentence to read "... includes four 

proposed substations and expansion at one planned and six existing substations"

Apis p

Appendix B - TL & SS Components - Right-of-Way Width -- 2.1.1 -- B-27 -- 1st -- [blank] -- Add 345kV ROW width (150'). Ap

is p

Appendix B - TL & SS Components - Right-of-Way Width -- 2.1.2 -- B-27 -- last -- [blank] -- Document states "...landowners would be contacted to obtain right-of-entry for surveys and for geotechnical drilling...". Surveys and geotechnical drilling have

already been performed at select locations, and field activities will continue through permitting, ROW acquisition, and up 

through construction.

Apis p

Appendix B - TL & SS Components - Right-of-Way Width -- 2.1.1 -- B-27 -- last -- Table B-5 provides a breakdown of the 

amount of land needed temporarily for construction and for operation over the life of the Project. During construction, temporary permission would be required from landowners and land management agencies for off-ROW access, staging areas, helicopter fly yards, and material storage. During operation, Project land requirements would be restricted to the ROW, 

including access roads, substations, and communication facilities. Access to the ROW would be in accordance with the land rights obtained as part of the easement acquisition process. As further details of the final Project design are engineered, the

amount of land required may change. -- Clarify paragraph so that readers are aware that project access roads that go outside 

the ROW will be used if permitted with original access plan for operations.

Apis p

Appendix B - TL & SS Components - Right-of-Way Acquisition -- 2.1.2 -- B-28 -- Table B-5 -- (Refer to table) -- Add table for 

Segment 3A, Anticline - Bridger.

Apis p
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Appendix B - TL & SS Components - Right-of-Way Acquisition -- 2.1.2 -- B-30 -- Table B-5 -- 5. For 500 kV, wiring 

pulling/splicing sites would be the ROW width x 600 feet located approximately every 3 miles; for 230 kV, ROW width x 400 feet located every 9,300 feet. Typically, only sites that would be off of the ROW would be at large angle dead-ends. It is 

estimated that one in four sites would be off of the ROW. -- Footnote 5; we want to revise distance between wire pulling/splicing sites to one reel length (approx. 9,250'). The pulling and tensioning also need to be the ROW width X 700' long.

Apis p

Appendix B - TL & SS Components - Right-of-Way Acquisition -- 2.1.2 -- B-31 -- 2nd -- -- For clarification, minimum separation 

required from existing lines is not 1500 ft per WECC reliability standards. Separation required per WECC is the largest of the spans between the two lines, but at least 500 ft. 1500 ft separation is used in routing and design as the longest span is 

generally shorter than 1500 ft. In some instances, the longest span is greater than 1500 ft for which separation would be increased between the two lines.

Apis p

Appendix B - TL & SS Components - Transmission Line Construction -- 2.2 -- B-32 -- Table B-6 -- (Refer to table) -- 1) please clarify that the acreages are for multiple pads in each segment and 2) please explain difference between construction and operations tower pad acreages and 3) please consider that the final pad left for operations will be reseeded but not 

recontoured

Apis p

Appendix B - TL & SS Components - Transmission Line Construction -- 2.2 -- B-32 -- Table B-6 -- (Refer to table) -- Add table for Segment 3A, Anticline - Bridger.

Apis p

Appendix B - TL & SS Components - Transmission Line Construction -- 2.2 -- B-32 to B34 -- Tbl B-6 -- -- Regeneration station disturbance areas do not match (see Table B-3 for quantities). Disturbance areas should be: 0 (Segment 1E), 0.5 (Segment 1Wa Operation acres), 0 (Segment 1Wc), 11 (Project Totals, Construction acres). Also, what is the "additional substation 

disturbance in Segment 6? Verify Project Total quantities for Substations.

Apis p

Appendix B - TL & SS Components - Transmission Line System Roads -- 2.2.1 -- B-35 -- 2 -- Transmission line ROW access would be a combination of new access roads, improvements to existing roads, and use of existing roads as is. New access 

roads or improvements to existing access roads would be constructed using a bulldozer or grader, followed by a roller to 

compact and smooth the ground. Front-end loaders would be used to move the soil locally or off site. Typically, access to the transmission line ROW and tower sites requires a 14-foot-wide travel way for straight sections of road and a 16- to 20-footwide travel way at corners to facilitate safe movement of equipment and vehicles. Wherever possible, new access roads would 

be constructed within the proposed transmission line ROW, or existing roads would be used. In other cases, access roads 

would be required between the proposed transmission line and existing roads. Erosion control and sedimentation measures 

such as at-grade water bars, culverts, sediment basins, or perimeter control would be installed as required to minimize erosionduring and subsequent to construction of the Project. -- Add discussion of lower impact overland travel. Refer to PAC 

Transmission Standards TD501

Apis p

Appendix B - TL & SS Components - Site Preparation -- 2.2.4 -- B-37 -- 1 -- Individual structure sites would be cleared to install the transmission line support structures and facilitate access for future transmission line and structure maintenance. Clearing of individual structure sites would be required to install the structures. Clearing individual structure sites would be 

done using a bulldozer to blade the required area. At each single-circuit 500-kV structure location, an area approximately 250 

feet by 250 feet would be needed for construction laydown, tower assembly, and erection at each tower site. An area of 

approximately 300 feet by 250 would be needed for each 500-kV double-circuit tower site. An area approximately 150 feet by 125 feet would be required for 230-kV structure locations. This area would provide a safe working space for placing equipment, vehicles, and materials. The work area would be cleared of vegetation only to the extent necessary. After line construction, all areas not needed for normal transmission line maintenance, including fire and personnel safety clearance 

areas, would be graded to blend as near as possible with the natural contours, then revegetated as required -- Add sentence 

for 345kV work area.

Ap

is p

Appendix B - TL & SS Components - Staging Areas -- 2.2.3 -- B-37 -- Tbl B-8 -- [blank] -- Paragraph 1 states that fly yards 

would be used on Segments 2, 3, and 4 if the phased single-circuit or two single-circuit design options are used. If fly yards are indeed needed, there would be approximately 20, 12, and 41 fly yards for Segments 2, 3, and 4, respectively. This is not 

indicated in Table B-8 or anywhere else in this section.

Apis p
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Appendix B - TL & SS Components - String Conductors, Shield Wires ... -- 2.2.7 -- B-40 -- last -- Pulling and tensioning sites for 500-kV construction would be required approximately every 3 miles along the ROW and would require approximately 5 

acres each to accommodate required equipment. Pulling and tensioning sites for 230-kV construction would be required approximately every 2 miles along the ROW and would require approximately 1.2 acres each to accommodate required equipment. Equipment at sites required for pulling and tensioning activities would include tractors and trailers with spooled 

reels that hold the conductors and trucks with the tensioning equipment. To the extent practicable, pulling and tensioning sites 

would be located within the ROW. Depending on topography, minor grading may be required at some sites to create level 

pads for equipment. Finally, the tension and sag of conductors and wires would be fine-tuned, stringing sheaves would be 

removed, and the conductors would be permanently attached to the insulators at the support structure -- Revise distance between wire pulling/splicing sites to one reel length (approx. 9,250'). The pulling and tensioning also need to be the ROW 

width X 700' long.

Apis p

Appendix B - TL & SS Components - Communication Sys - Access Rds -- 2.3.2 -- B-42 -- 1 -- Regeneration station roads 

would be constructed using a bulldozer or grader, followed by a roller to compact and smooth the ground. Front-end loaders would be used to move the soil locally or off site. Either gravel or asphalt would be applied to the prepared base layer. -- 

Revise paragraph to mention need for a gravel road into all regen stations.

Apis p

Appendix B - TL & SS Components - Substation Construction -- 2.4 -- B-42 -- 1st -- -- 1st sentence states "construction 

activities at 12 locations". Are the 230-kV and 345-kV yards at Bridger counted as separate locations? In the last sentence, 

Heward is listed as an existing substation when in fact it is a new substation.

Apis p

Appendix B - TL & SS Components - Foundation Installation -- 2.4.7 -- B-44 -- 2nd -- -- In 2nd and 5th sentences, change "reinforced steel" to "reinforcing steel".

Apis p

Appendix B - TL & SS Components - Control Building Construction -- 2.4.10 -- B-45 -- 1 -- One or more control buildings are 

required at each substation to house protective relays, control devices, battery banks for primary control power, and remote monitoring equipment. The size and construction of the building depends on individual substation requirements. Typically, the control building would be constructed of concrete block, pre-engineered metal sheathed, or composite surfaced materials. 

Once the control house is erected, equipment is mounted and wired inside. In some cases an emergency generator may be located just outside the control house within the substation fenced area -- Confirm last sentence; I think all stations will have 

an emergency generator; not just some.

Ap

is p

Appendix B - TL & SS Components - Helicopter Use -- 2.5.2 -- B-47 -- 2 -- The size and weight of the 500-kV double-circuit 

lattice steel structures preclude the use of helicopter erection methods7. These structures would be erected on site using 

appropriately sized cranes to assemble and erect the towers. The single-circuit 500-kV towers weigh less and in some cases it 

may be desirable to employ heavy lift helicopters in the tower erection process. To allow the construction contractor flexibility 

in what construction methods can be used, the construction specification would be written to allow the contractor the option of

using ground-based or helicopter construction methods, or a combination thereof. Use of a helicopter for structure erection 

may be driven by various factors, including access to the structure locations, construction schedule, and/or construction 

economics. -- Need to discuss conventional construction of foundations and tower leg erection.

Apis p

Appendix B - TL & SS Components - Water Use -- 2.5.3 -- B-49 -- Table B-10 -- -- Reference to footnote 2 on 4th column under substations (Gallons for grading/site work/dust control) should reference footnote 3.

Apis p

Appendix B - TL & SS Components - Construction Workforce -- 2.6.1 -- B-50 -- 2 -- The Proponents’ proposed schedule identifies general construction timeframes by segment and substation, generally 4 to 5 years (see Table B-17). Construction times by segment are, however, expected to range from about 8 months to 27 months; similarly, substation construction times 

would range from 2 to 9 months. This construction would take place within the broader timeframes identified in Table B-17, but 

the exact timing is unknown. The combined labor requirements by EPC shown in Figure B-15 are, therefore, based on a 

representative Project schedule that is used in the EIS for the purposes of analysis -- Confirm substation construction 

durations; nine months seems short for Aeolus and Anticline.

Apass

Appendix B - TL & SS Components - Construction Workforce -- 2.6.1 -- B-51 -- Fig B-15 -- [blank] -- Need definition of EPC #1, #2, and #3 that is indicated in the legend below the figure. Otherwise, show total workforce without defining different EPC 

contracts.

Apass

Appendix B - TL & SS Components - Construction Equipment and Traffic -- 2.6.2 -- B-59 -- last -- [blank] -- Change "... soil not be suitable ..." in second sentence to "... soil not suitable ...". Change "... transformer bank required .." in next to last sentence 

to "transformer bank delivered ...".

Info
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Appendix B - TL & SS Components - Construction Schedule -- 2.6.4 -- B-61 -- 3 -- Transmission line construction commences 

with contractor mobilization. The contractor would mobilize equipment and personnel to the construction site at various stages 

in the Project schedule depending on operational requirements. This would cumulatively require approximately 6 weeks throughout the schedule for each segment. Construction management, engineering support, inspection, materials handling, and administration are required throughout the Project. First, surveyors would start at one end of the segment and stake the 

locations of access roads. Road construction can start 1 to 2 weeks after the surveyors begin, which may require clearing in higher elevations where tree removal is required prior to road construction. After a couple of weeks of road construction another survey crew can begin staking the structure locations. A week or two after the survey crew starts staking structure locations, excavation of holes for foundations for 500-kV towers, or for directly embedded poles for 230-kV structures, can 

begin. For 500-kV construction, the installation of the concrete pier foundations would begin within the next couple of weeks. 

The foundations need time to cure and develop to full structural strength (i.e., compression capacity) before lattice towers can 

be installed. Five to six weeks after foundation installation has begun, lattice tower assembly and erection can begin. For 230-

kV construction, structure assembly and setting can begin immediately after the excavation of holes has begun. For 230-kV 

and 500-kV construction, the wire installation crews would start approximately 8 to 12 weeks after assembly and erection/setting begins. This would be followed by final cleanup, reclamation, and restoration -- Last 1/2 of paragraph; add discussion of 345kV construction

Ap

is p

Appendix B - TL & SS Components - Hardware Mtc and Repairs -- 3.1.3 -- B-66 -- 2 -- The Proponents plan to conduct maintenance on the critical 500-kV and 230-kV system using live line maintenance techniques. Maintenance on the 

transmission lines can be completed safely using live line techniques thereby avoiding an outage to the critical transmission line infrastructure. High reach bucket trucks along with other equipment are used to conduct these activities. For the 500-kV 

lattice tower structures, this requires that adequate space be available at each structure site so that the high reach bucket 

truck can be positioned to one side or the other of the structure and reach up and over the lower phases to access the upper center phase for live line maintenance procedures. For the 230-kV H-frame structures, this requires that adequate space be 

available at each structure site so that a bucket truck can be positioned to access the outside phases. To allow room at each 

structure for these activities, in low slope areas a pad area is required with the structure in the center of 300 feet (ROW width) 

by 100 feet longitudinal for the double-circuit 500-kV structure, 250 feet by 100 feet for the single-circuit 500-kV structure, and 

125 feet by 50 feet for the 230-kV H-frame structure. Figures B-16 through B-18 depict the space requirements for live-line maintenance. The size and location of these required pads near the structures may vary depending on the side slope and access road at each site. The work areas and pads would be cleared to the extent needed to safely complete the work. These 

pads would remain in place after construction, but would be revegetated after the initial construction is completed. -- Add 

345kV to live line maintenance sentence

Apis p

Appendix F -- General -- All -- For the sake of consistency and to minimize future potential impacts to visual resources, the Draft EIS should be revised to indicate that all land use plan amendments related to visual resources for this project be amended to a one-time allowance for the GW project without changing the VRM class for areas affected by the route. This allows for project implementation without opening the door for long-term development that could have potential adverse 

impacts on resources in the project area.

The proapp

Appendix F -- 2.1.1 -- General -- The issues identified through public scoping and used to develop alternatives are as follows:• Objection to location on private lands (“If the project is for the general public good, it should be on public lands.”); 

• Reliability and proposed separation distances of transmission lines; • Avoiding sensitive areas such as National Monuments and Wildlife Refuges, military operating areas, National Conservation Areas, Areas of Critical Environmental Concern (ACECs), and State Parks; 

• Effects to Native American traditional cultural properties and respected places; • Effects to paleontological resources; • Effects on wildlife habitat, plants, and animals including threatened, endangered, and sensitive species; 

• Effects to visual resources and existing viewsheds; • Effects to National Historic Trails (NHTs) and their viewsheds; • Land use conflicts and consistency with land use plans; • Effects to soils and water from surface-disturbing activities; • Effects to agriculture lands; • Effect on local and regional socioeconomic conditions; and • Management of invasive plant species and effective reclamation -- Planning issues do not just include resource issues/impacts. They also should include management needs such as providing for transmission line corridors and/or exceptions to land use planning documents. This section of the Draft EIS should be revised to provide the missing key management needs addressed by amendments and/or exceptions.

As 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Appendix F -- 2.1.1 -- 2 -- 1st bullet -- • Objection to location on private lands (“If the project is for the general public good, it 

should be on public lands.”); -- It is not clear what parenthetical statement "(If the project is for the general public good, it 

should be on public lands.)" is for or what it means or how it is addressed through this EIS process. The Draft EIS should be 

revised to clarify this.

Thi

Appendix F -- 2.1.2 -- General -- The following general planning criteria are being considered in the development of the proposed plan amendment: • National Environmental Policy Act (NEPA); • Existing laws, regulations, and BLM policies; • Plans, programs and policies of other federal, state and local governments, and Indian Tribes; • Public input; • Future needs and demands for existing or potential resource commodities and values; • Past and present use of public and adjacent lands; • Environmental impacts; • Social and economic values; • Public welfare and safety; and • President’s National Energy Policy. -- Planning Criteria typically include the legal and regulatory constraints under which the project and/or its analysis would be 

operating (See BLM Land Use Planning Handbook ). Several of these bullets are not planning criteria (public input, future 

needs, environmental impacts, etc.). The Draft EIS should be revised to delete them from this section.

We 

Appendix F --3 -- 4 -- 1 -- Effects on visual resources were determined through the use of computer modeling, field visits, and

site-specific knowledge by local BLM staff. The analysis and effects determinations on visual resources are documented in 

Appendix G-1 for the Casper, Rawlins, Green River, Kemmerer, Cassia, Jarbidge, SRBOP, and Wells RMPs and the Malad, 

Bennett Hills/Timmerman Hills, Twin Falls, and Bruneau MFPs. These proposed amendments reference the analysis, maps of the locations (referred to as the areas of inconsistency [AOIs]), photographs, and simulations included in Appendix G-1. The 

visual analysis pertains only to the public lands, as the BLM does not establish visual management objectives for lands it does

not administer. -- It is unclear why this section goes into detail on the methodology for visual analysis. The Draft EIS should be 

revised to move this to the Visual Resources section of the Environmental Consequences section.

Approvis

Appendix F -- 3.2.4 -- 10 -- 3 -- The Record of Decision (ROD) for the Rawlins RMP states: “Avoidance Areas: Areas to be avoided which may be available for location of ROWs and Section 302 permits, leases, and easements with special 

stipulations or mitigation measures. For such authorizations, the area’s environmental sensitivity and other feasible 

alternatives will be strongly considered.” The Proposed Route was identified because it would have less effect on sage-grouse 

habitat. The Draft EIS considers an alternative to the Segment 1E Proposed Route (Alternative 1E-C) that would not cross 

areas mapped as VRM Class II; however it would have a higher impact on other resource. Mitigation measures were developed to reduce impacts to visual and other resources (refer to Table 2.7-1 in Chapter 2 of the Draft EIS) -- Effects: Rawlins FO: The land use plan exceptions for the Rawlins FO is specific to this project and would not open the door for other 

projects. However, the Draft EIS discusses impacts from other projects that would apparently result from allowing this project.

This is an incorrect assumption and the Draft EIS impacts analysis should be revised to disclose only the impacts from this project when it discusses impacts within the Rawlins FO.

The 

Appendix F -- 3.3.1 -- 11,12 -- last -- The Project’s Proposed Route along Segments 3 and 4, as well as Alternatives 4B, 4C, 4D, and 4E, would cross through the Green River Management Area. Approximately 24 miles of Segment 3 are within the 

Planning Area, 10.5 of which cross BLM-managed land. Approximately 65 miles of Segment 4 are within the Planning Area, 

approximately 30 of which cross BLM-managed land. Alternatives 4B, 4C, 4D, and 4E follow the same route within the Green 

River Planning Area, 3.5 miles of which cross BLM-managed land... -- The proposed Green River amendment allows a one time exception for this project only and therefore wouldn't allow other uses. See proposed amendment language on page 1-14.

The inte

Appendix F -- 3.4.3 -- 20 -- last -- The following amendment would be needed if one of these alternatives is approved: 

Proposed Route: Permit a one-time allowance for Gateway West Project to cross the Dempsey Hockaday NHT in section 32, 

T 24 N, R 117 W Alternative 4A: Permit a one-time allowance for Gateway West Project to cross the Sublette NHT in section 11, T 23 N, R 118 W -- It is confusing as to why the Kemmerer RMP proposes a one-time exception when the situation in this FO is much more appropriate for designation of a new utility corridor than other BLM FOs crossed by the proposed project. 

There is an existing corridor with existing transmission lines along the proposed power line alignment which would allow for this project to occur in an area that currently has transmission line development. The Draft EIS demonstrates a deficiency in 

the existing Kemmerer FO RMP, and the Draft EIS should be revised to address this clear planning issue- the need for 

designation of a utility corridor in the Kemmerer FO to address current and future transmission line development.

The Dis
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Appendix F -- 3.4.3 -- 21-22 -- last 2 on 21, 2nd on 22 -- Alternative 4A: Permit a one-time allowance for Gateway West Project

without changing the VRM class for areas affected by the route...........Alternative routes 4C, 4E: Reclassify the VRM Class 

designation to VRM Class III in the portion of the planning area south and west of U.S. highway 30 (the highway) beginning on a north-south line along the high ridgeline approximately 1⁄4 mile west of the current active coal leases (west of the town of 

Kemmerer); south along the high ridgeline to the ridgeline behind the active coal leases in T21N, R117W, Sec 25; then west following the high points of the topography approximately 3 miles south of the highway to T21N, R118W, Sec 28; then northwest following the high points of the topography within approximately 3 miles of the highway to T21N, R118 W, Sec 18; then 

north-west following the high points to within approximately 1⁄2 mile of the highway in T21N, R118W, Sec 12; then west to the junction of U.S. Highway 30/State Highway 89. For routing north and east of highway 30/State Highway 89, permit a one-time 

allowance for Gateway West Project without changing the VRM class for areas affected by the route. Alternatives 4B, 4D: 

Reclassify the VRM Class designation to VRM Class III in the portion of the planning area south and west of U.S. highway 30 (the highway) beginning on a north-south line along the high ridgeline approximately 1⁄4 mile west of the current active coal leases (west of the town of Kemmerer); -- It is unclear why the Draft EIS suggests changes to the VRM designations for Alternative 4B,4C, 4D and 4E versus allowing for one-time exceptions. The Draft EIS should be revised to allow for one time exceptions for VRM rather than amending the land use plan to change VRM class. This will minimize the risk of future longterm impacts to public lands ( See general comment above).

The det

Appendix F -- 3.4.3 -- 22 -- P3 Mitigation -- Mitigation: Where the route would be visible on timbered slopes, limit tree to those 

portions of the right-of-way where it is required for safety rather in order to avoid creating a linear feature on the landscape. Vegetation removal requirements will consider Appendix A, Key Standards Relating to Electric System Reliability and Safety, of the Memorandum of Understanding with the Edison Electric Institute (2006) -- This proposed mitigation measure is not 

feasible and is a direct contradiction to the intent of the cited MOU. The MOU's intent is to perform cover type conversion away from vegetation communities that could interfere with the conductors at some time in their life-cycle toward plant communities 

that will not. A requirement that we not remove trees except at structure locations will force us to prune to such an extent as to 

leave large numbers of tree remnants in the right of way. This practice would be unsightly, severely damage or kill existing trees, promote infestations of bark beetles, produce an unnecessary fire risk, and impose an unreasonable long-term management burden on the company and our rate payers. We recommend the Draft EIS be revised to remove this mitigation 

measure. If land managers want to prevent linear features, the right-of-way could be treated as outlined in the last paragraph 

of page 21 (3.6.2.2) for the Medicine Bow-Routt and Caribou-Targhee NFs.

Thi

Appendix F -- 3.4.3 -- 22-23 -- -- Mitigation for NHT crossings will be determined through the 106 process. These measures may include micrositing to place the line behind topographic features, replacing insulators with new ones made of nonreflective materials, and replacing conductors using non-specular wire to reduce visibility from Key Observation Points (KOPs) in highly visible places. This mitigation measure would be implemented once the Gateway West lines are operational. These 

mitigation measures would be especially pertinent where the new transmission line is visible from NHTs in the locations listed 

below (depending on the selected route).... -- It is unclear why an amendment would be needed to amend NHT for Kemmerer RMP. Decision 5010 says it would be allowed on a case by case basis. Decision 6008 doesn't require an amendment.

The 21)

Appendix F -- 3.5.4 -- 30 -- 2nd full -- These amendments may impact the ability to meet management objectives. Allowing 

additional utility corridors would result in impacts to the resources outside of those designated areas. These include impacts to 

wildlife, vegetation, soils, water, and cultural and visual resources. -- Effects: Malad MFP: "Allowing additional utility corridors 

would impact..." is incorrect. The proposed amendment would allow only this project not new projects in the corridor. The Draft EIS needs to be revised to correct this.

If thline 

Appendix F -- 3.6.3 -- 32-33 -- 4th down on 32 and 1st on 33 -- “The area classified as VRM Class II in the Goose Creek Travel Zone (within one-half mile of the Goose Creek Road between Wilson Pass and the Utah border), will be reclassified as VRM Class III.”...........“VRM classes are designated as shown in the Cassia RMP; however areas associated with the Gateway West Transmission Line Project will be reclassified as follows: the area north of the ROW (122 acres) in the Jim Sage area ( AOICA-1 in Appendix G-1), and 806 acres Cottonwood Creek area (AOI CA-2 in Appendix G-1) from VRM III to VRM IV. -- As stated in previous comments, we recommend that the Draft EIS be revised to allow exceptions for VRM in the Goose Creek travel zone instead of requiring that the VRM be changed. This also applies to Spring Canyon Area, Jim Sage 

and Cottonwood Creek. These are very small parcels that are not appropriate for large-scale allocation changes such as VRM 

class, particularly for a single project (See general comment 1 above).

The Disthis 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Appendix F -- 3.9.1 -- 45 -- 8 -- Alternatives 9D and 9G would pass through Cove, a non-motorized area within the C.J. Strike 

SRMA. This use is not in conformance with the SRMA designation based on “recreational, scenic or cultural values.” (Note: 

The following amendment is presented to document the degree of change that would occur if this route were approved; 

however, the BLM Boise District has stated that they would not approve an amendment for a route through the Cove area.) 

The designation of the C.J. Strike SRMA is defined as: “C.J. Strike SRMA: This SRMA consists of 20,000 acres surrounding 

C.J. Strike Reservoir along the Snake River. The purpose of the SRMA is to provide enhanced recreation management associated with the reservoir, and protection of the Oregon Trail adjacent to the reservoir.” (2.14 Recreation 2-20) -- Because

the BLM won't approve an amendment to allow for the route through the Cove area as indicated in the Draft EIS, then it is disingenuous to the public to retain this route for detailed analysis. Accordingly, the Draft EIS should revised to either allow an amendment for this route, or to eliminate it from detailed analysis.

An 

Appendix F -- 3.9.3 -- 48 -- 2 -- “Retain all public lands in the 43,000-acre ROW avoidance area to protect the visual corridor

along the historic Oregon Trail and the resources along the Snake River canyon. Permit the Gateway West Transmission Line 

Project as a one-time allowance with significant mitigation required to maintain the cultural resources and traditional cultural 

properties of the area.” -- The statement "Permit the Gateway West Transmission Line Project as a one-time allowance with 

significant mitigation required to maintain the cultural resources" does not provide adequate information for the reader to 

understand what the consequences of this allowance are. For example, what is meant by "significant mitigation"? We recommend that the Draft EIS be revised to state "Allow GW a one-time exception with mitigation as appropriate based upon 

Section 106 consultation."

Thi

Appendix F --3.9.3 -- 48 -- last 1/2 of page -- For Proposed Route 8: “Manage the areas along the Oregon Trail and the Snake River Canyon as VRM Class II, the OTA as Class IV and remaining 

areas as Class III. Approximately 6,400 acres of Class II areas associated with the Oregon Trail and scenic values associated with the Oregon Trail and scenic values associated with the Snake River Canyon would be designated as Class III to 

accommodate a major powerline R/W.” For Alternatives 8E, 9D, and 9F: “Manage the areas along the Oregon Trail and the Snake River Canyon as VRM Class II, the 

OTA as Class IV and remaining areas as Class III. Approximately 3,100 acres of Class II areas associated with the Oregon 

Trail and scenic values associated with the Snake River Canyon is designated as Class III to accommodate a major powerline 

R/W.” For Alternative 9G/9H: “VRM Class II areas within 250 of the Route centerline would be reclassified to VRM Class III, taking into account the need for

a 0.5 mile buffer from NHTs. Mitigation will include adjusting the alignment to ensure a 0.5 mile buffer from NHTs is 

maintained.” -- For Routes 8, 8E, 9D, 9F, 9G and 9H we recommend that the Draft EIS be revised to make proposed land use plan amendments for one-time exceptions to VRM rather than wholesale changes in VRM management (See general comment 1).

As up 

Appendix F -- 3.9.3 -- 49 -- 2 and 4 -- “This SRMA consists of 15,900 acres in the Snake River Canyon downstream from Grandview, Idaho that is managed for the protection of cultural and scenic values. The SRMA designation has been reduced by approximately 6,400 acres to accommodate a major powerline..........“C.J. Strike SRMA: This SRMA consists of 16, 900 

acres surrounding C.J. Strike Reservoir along the Snake River. The purpose of the SRMA is to provide enhanced recreation management associated with the reservoir, and protection of the Oregon Trail adjacent to the reservoir. The SRMA 

designation has been reduced by approximately 3,100 acres to accommodate a major powerline R/W.” -- It is not clear how 

the project is not in conformance with Slickspot Peppergrass CA page 4 or A-67 of SRPOB RMP. See also paragraph 4 and quote on F1-50, paragraph 5. We recommend the Draft EIS be revised to indicate this conformance or provide additional 

rationale to justify the conclusion that the project is not in conformance.

No Ad3.7

Appendix F -- 3.9.3 -- 50 -- 5 -- “b) If direct or indirect negative impacts to the species or its habitat are anticipated as a result 

of new BLM actions, the activity will be modified to avoid or minimize negative impacts and, where feasible, promote species 

conservation.” -- It is not clear how the project is not in conformance with Slickspot Peppergrass CA page 4 or A-67 of SRPOB RMP. See also paragraph 4 and quote on F1-50, paragraph 5. We recommend the Draft EIS be revised to indicate this 

conformance or provide additional rationale to justify the conclusion that the project is not in conformance.

As the 

Appendix F -- 3.9.4 -- 51 -- 2 -- Allowing construction in the Utility Avoidance Area and in areas of high cultural importance such as the Guffey Butte-Black Butte Archaeological District could impact the ability to meet management objectives of 

protecting these areas and maintaining the cultural landscape. Potential impacts could include loss of historic artifacts, loss of 

historic character of the landscape, and diminished traditional cultural properties and resources. “Significant mitigation” would 

be required to limit these impacts as described in the SRBOP ROD 2-1; which could involve extensive cultural surveys, micrositing, data recovery, and on-site mitigation. -- If you require "significant mitigation" then one would expect 

correspondingly significant decreases in project impacts to cultural resources. We request that the Draft EIS be revised to 

provide specific information regarding this "significant mitigation". The Draft EIS also needs to be revised to disclose the 

effectiveness of this mitigation and how it would decrease impacts to cultural resources.

The mit
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Appendix F -- 3.10.2 -- 52 -- 6 -- “Prohibit all land disturbing developments and uses on archeological sites.” -- Based on the

mitigation proposed for cultural resources, the proposed project would not build on an archaeological site. Accordingly, the 

Draft EIS should be revised to remove this requirement.

Avothe set

Chapter 1 - P&N -- 1.3.2 -- 9 -- 1 -- As regulated utilities, both Idaho Power and Rocky Mountain Power are required to 

produce and periodically update an Integrated Resource Plan (IRP). The Public Utilities Commissions of the states where 

these utilities operate review and acknowledge these IRPs and their updates. Part of the planning process includes addressing conservation and other means of reducing or controlling the growth of the demand for electricity among the utilities’ customers. 

When the Public Utilities Commission for a given state acknowledges the IRP, it is agreeing that the balance of demand-side 

measures and development of additional generation resources, including associated transmission, is appropriate to meet the needs of the customers of its state while complying with the various laws and regulations on renewable energy requirements, 

carbon emissions, and other energy-related issues. The Proponents have detailed their demand-side management in their 

respective IRPs, which have been acknowledged by the Public Utilities Commissions for which they were written, and have 

shown to the satisfaction of the Public Utilities Commissions that additional transmission capacity is needed to meet their 

customers’ needs (RMP 2009; IPC 2009). -- The following statement is of concern: “... and have shown to the satisfaction of the Public Utilities Commissions that additional transmission capacity is needed to meet their customers’ needs ...” 

The PUC’s only acknowledge the IRP and make the following statement about the IRP: “Our acceptance of the Company 2009 IRP should not be interpreted as an endorsement of any particular element of the Plan, nor does it constitute approval of 

any resource acquisition or proposed action contained in the Plan.”

TexMa

Chapter 1 - P&N -- 1.3.2 -- 9 -- 2nd; 2nd sentence -- ...The Public Utilities Commissions of the states where these utilities operate review and acknowledge these IRPs and their updates. ... -- Change sentence to reflect that Wyoming does not 

acknowledge the IRP: ...With the exception of Wyoming, the Public Utilities Commissions of the states where these utilities 

operate review and acknowledge these IRPs and their updates. ...

TexMa

Chapter 1 - P&N -- 1.3.2 -- 9 -- 4 -- ...The Proponents have detailed their demand-side management in their respective IRPs, 

which have been acknowledged by the Public Utilities Commissions for which they were written, and have shown to the 

satisfaction of the Public Utilities Commissions that additional transmission capacity is needed to meet their customers’ needs

(RMP 2009; IPC 2009). -- (RMP, 2009; IPC, 2009): Should be 2011..

TexMa

Chapter 1 - P&N -- 1.3.3.2 -- 10 -- 1 -- (see Section 1.3.2.3 below for further information). -- Incorrect citation. Should say see Section 1.3.3.3. Chapter 1 - P&N -- 1.3.3.3 -- 11 -- T 1.3.1 -- Table 1.3-1. Rating and Capacity of Paths with and without the Gateway West Project -- Tot 4A-proposed Gateway parallel segments- should include 1Wc.

Tex"W

Chapter 1 - P&N -- 1.3.3.3 -- 11 -- T 1.3.1 -- Table 1.3-1. Rating and Capacity of Paths with and without the Gateway West Project -- Section should be expanded to discuss the public safety aspects of reliability as public safety is a criteria for 

significant impact (40CFR 1508.27 (6)(2)). The Draft EIS should evaluate reliability for each alternative.

Ad

Chapter 1 - P&N -- 1.3.3.3 -- 11 -- T1.3.1 Row 5 -- Column 2: 2,757, Column 6 5,757 -- We have not increased the rating for Borah West from 2,557 to 2,757. The column values should be 2,575 and 5,557.

Thi

Chapter 1 - P&N -- 1.3.3.3 -- 11 -- T1.3.1 Row 6 -- Column 2: 2,287, Column 6 5,287 -- The Midpoint West path is now rated at 2,527. The column values should be 2,527 and 5527, respectively

Thi

Chapter 1 - P&N -- 1.3.3.3 -- 11 -- Table 1.3-1, footnote 2 -- According to the Proponents, “Idaho Power and PacifiCorp will beincreasing the rating of the Bridger West and Borah West transmission paths by 200 MW (from 2,200 MW to 2,400 MW for 

Bridger West and from 2,557 MW to 2,757 MW for Borah West). This increase in transfer capability on the two paths will utilize 

existing and/or future equipment that will be in-service prior to the addition of the Gateway West project.” Also, according tothe Proponents, “With the addition of Segment 2 and 3 facilities (Aeolus – Creston – Bridger) plus anticipated resources at 

Windstar and Aeolus, the West of Bridger transfers would increase by about 3,000 MW. It is anticipated that transfers west of 

Aeolus (including 500 kV and 230 kV facilities) would be as high as 2,200 MW. Each of the paths listed in Table 1.3-1 are part of the Gateway West Project and are dependent on each other to move power from east to west (Wyoming to Idaho).” -- As stated previously, we have not increased the rating for Borah West from 2557 to 2757. So these values should be 2575 and 

5557. The footnote should be written as "According to the Proponents, “Idaho Power and PacifiCorp will be increasing the rating of 

the Bridger West transmission path by 200 MW (from 2,200 MW to 2,400 MW). ..."

Thi

Chapter 1 - P&N -- 1.3.3.3 -- 12 -- 2 -- Due to the high megawattage load requirements necessary for the Gateway West Project, multiple high-capacity lines on separate corridors are required in key segments of the Project. -- The text in the EISshould be corrected as follows: Due to the high transfer capacity requirements necessary for the Gateway West Project, multiple high-capacity lines on separate corridors are required in key segments of the Project.

Thi
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 1 - P&N -- 1.3.4 -- 13 -- 1 -- This Project is designed to provide for the delivery of up to 3,000 MW to the service areas 

of the Proponents and possibly other markets. Idaho Power forecasts a peakhour load growth of 57 MW per year over the next 

10 years. PacifiCorp forecasts the megawatt-hour growth between 2010 and 2019 for Utah, Wyoming, and Oregon will be 6.8 million, 3.7 million, and 1.1 million megawatt-hours, respectively. These forecasts are based on the IRPs prepared by each company as required to fulfill the regulatory requirements and guidelines established by the public utilities commissions of the 

states served by the Proponents (PacifiCorp 2011; Idaho Power 2009). Each IRP addresses the obligations of each company 

pursuant to its OATT to plan for and expand its respective transmission systems in a non-discriminatory manner based on the needs of its native load customers, network customers, and all eligible customers that agree to expand their transmission systems. This includes entities that generate or plan to generate electricity, including coal-fired, natural-gas-fired, and 

renewable energy sources (biogas, wind, and geothermal). As of June 2011, all of the generators requesting transportation on Gateway West were wind energy (PacifiCorp 2011). -- The text in the EIS should be corrected as follows: Idaho Power 

forecasts a peakhour load growth of 69 MW per year over the next 10 years.............(PacifiCorp 2011; Idaho Power 2011).

Thi

Chapter 1 - P&N -- 1.3.4.1 -- 14 -- T1.3.2 -- Table -- Should Dave Johnston substation be listed here? TabChapter 1 - P&N -- 1.3.4.2 -- 15-16 -- T 1.3.3 -- Table 1.3-3. Gateway West Transmission Line Segments -- Rephrase "other 

projects" to state "area of high wind potential"

The 

Chapter 1 - P&N -- 1.3.4.2 -- 15-16 -- T 1.3.3 -- Table 1.3-3. Gateway West Transmission Line Segments -- Add Segment 1Wc - Delete comment, after further review, this is a summary description of segments and not specific to either 1Wa or 1Wc.

The 

Chapter 1 - P&N -- 1.6 -- 24 -- 1 -- The Proponents would negotiate details regarding needed land acquisition across privately owned lands, either in fee or as an easement, for the transmission line and associated facilities (substations, etc.) with each

landowner. In exchange for the right to operate the transmission line and facilities, the Proponents would compensate the 

landowner for the use of the land. The negotiations between the Proponents and the individual landowner could include compensation for loss of use during construction, loss of nonrenewable or other resources, and the restoration of unavoidable 

damage to property during construction. BLM does not have the legal authority to impose stipulations on private lands. Private 

landowners may negotiate stipulations as part of their agreements. -- Additional clarifiaction should be added so sentence 

reads "BLM does not have the right to enforce stipulations on private land but have the obligation to recommend stipulations to

reduce impacts as part of the NEPA process."

The 

Chapter 1 - P&N -- 1.7.2 -- 25 -- 1 -- The analysis will address the effects of the Proposed Action, No Action Alternative, or 

Route Alternatives, including construction (short-term), operations and maintenance (long-term), and decommissioning and abandonment (long-term). Construction would occur between 2013 and 2018. Therefore, short-term effects occur within that 5-

year time frame. Typically, transmission lines of this size are designed for a working life of 50 years although, in practice, the 

useful life is often much longer. Therefore, 50 years is considered long term. -- The working life of a transmission line is not the 

same as the length of time of impacts. How long impacts last depends upon the resource affected. The EIS should be revised to disclose, by resource, the duration of long-term impacts. and disclose details regarding the timing and effectiveness of 

reclamation to support the rationale for the determination of the duration of long-term impacts.

Thi

Chapter 1 - P&N -- 1.9.2 -- 30 -- 3 -- Route Alternatives were identified that could reduce the impacts suggested for each 

issue. The feasibility of each Route Alternative was then considered, such as physical ability to construct the Project in that

location and other resource impacts. If it was determined that an Alternative was not feasible, it is described as an Alternative Considered but Eliminated from Detailed Analysis in Chapter 2. Alternative development issues and the alternatives that were considered in detail in the EIS are described in Table 1.9-1. -- Feasibility is not the only reason to eliminate an alternative from detailed analysis. It would also be eliminated if it does not reduce resource impacts/conflicts or is out of the scope of the 

federal decision.

The 

Chapter 1 - P&N -- 1.9.3 -- 31 -- Bullet 2 -- Could the transmission line be located where it is not visible from residences? -- 

Bullet 2 is not an analysis issue but an alternatives issue.

The is a

Chapter 1 - P&N -- 1.9.3 -- 38 -- Bullet 8 -- How would the Proponents protect against potential vandalism or acts of terrorism

to Project structures? -- This should go under Section 1.9.4

Thiof t

Chapter 2 - Alternatives -- 2 -- General -- General -- There is no clear description of why paralleling an existing line is beneficial 

for an alternative. The EIS should provide an explanation for why this is beneficial and include why it may also not be beneficial.

As reqthe 

Chapter 2 - Alternatives -- 2 -- General -- General -- Table 2.1-2: Transmission Line Features Common to all 230kV Segments: Bittern conductor diameter equals 1.345" (not 1.196").

Info

Chapter 2 - Alternatives -- 2 -- General -- General -- It would be easier to follow if the plan amendment table occurred after the 

alternatives description

We rea

Chapter 2 - Alternatives -- 2 -- General -- General -- Recommend an up-front statement that all mileage is approximate or an 

estimate. Then delete approximate throughout document and do not use overly precise figures.

Thi
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 2 - Alternatives -- 2 -- General -- General -- The EIS needs definitions of 'planned', 'proposed' and 'existing'. 

Additionally, the EIS should clarify that reasonable foreseeable actions are not connected to the proposed action (planned).

“Plava

Chapter 2 - Overall Project -- 2.1 -- 3 -- 1 -- Description of various ROW widths -- Omits 350' ROW for 2 single circuit option InfoChapter 2 - Overall Project -- 2.1.1 -- 2 -- 2nd, 2nd sentence -- It then proceeds as a double-circuit 500-kV line from Aeolus to Populus (though in Segments 2 and 3 with one of the circuits initially energized at 230 kV between the Aeolus and Anticline 

Substations). At Populus, the Gateway West Project splits into two single-circuit 500-kV roughly parallel paths. -- Change 

sentence as follows: "...from Aeolus to Populus (through in Segments 2, 3,and 4 ..."

Info

Chapter 2 - Overall Project -- 2.1.1 -- Overall -- All -- Refers to 1103 mileage but elsewhere says 1100-should be consistent 

across document - see comment above re: approximating mileages.

The 

Chapter 2 - Overall Project -- 2.1.1 -- 4 -- T2.1.2 -- Table -- T line features common to all proposed segments: "One OPGW 

wire diameter 0.637 inches"-delete "One" so that sentence structure is consistent with others in the section.

Info

Chapter 2 - Overall Project -- 2.1.1 -- 8 -- T2.1.2 -- Project Facility Description Substation Facilities Windstar Substation •

Expansion of existing substation. • Developed acreage: increase the fenced area of the 230-kV substation by approximately 10 acre• Existing access road is gravel and would not need extension for Gateway West. • 230-kV circuit breakers and related switching equipment, bus and support structures, potential an transformers, 230-kV shunt capacitor banks. • 230-kV line termination structures approximately 70 feet in height. • Control, protection, and communications equipment. • Addition of new 

control building within the substation fenced area. • See Figure A-18. Heward Substation • Expansion of existing substation. • 

Developed acreage: increase the fenced area by approximately 3 acres. • 230-kV circuit breakers and related switching 

equipment, bus, and support structures. • 230-kV line termination structures approximately 70 feet in height. • Control, protection, and communications equipment. • Addition of new control building within substation fenced area. • See Figure A19. Aeolus Substation • Expansion of planned substation. • Developed acreage: increase the fenced area by approximately 90 

acres. • Expansion of the Aeolus Substation will require upgrading County Route 121. This upgrade will r64 acres of 

construction disturbance and 33 acres of new permanent roadway. • 500-kV and 230-kV circuit breakers and related switching 

equipment, bus and support structures, transformer bank, 500-kV shunt reactor bank on bus and on Anticline line, potential 

and current tr• Control, protection, and communications equipment. • 500-kV line termination structures approximately 135 feet 

in height. • 230-kV line termination structures approximately 70 feet in height. • New control buildings for the 230-kV and 500-

kV substation yards. • New Static Var Compensator that will occupy about 10 to 15 acres in the substation fenced area aa 

building that contains power electronic equipment and associated cooling equipment. • See Figure A-17. Creston Substation • Proposed new substation. • Developed acreage: Approximately 13 acres fenced with access road. • A gravel access road of approximately 500 feet long would connect to an existing road. • 230-kV circuit breakers and related switching equipment. -- 

Table 2.1-2: Substation at Dave Johnston power plant should be added to the list of substations.

Thi

Chapter 2 - Overall Project -- 2.1.1 -- 8 -- T2.1.2 -- Table -- T line features common to all proposed 230kV line segments. *One 

OPGW Wire diameter: 0.637 inch. Delete "One" to be consistent and correct diameter is 0.465

Info

Chapter 2 - Overall Project -- 2.1.1 -- 8 -- T2.1.2 -- Table -- Table 2.1-2: Revise each bullet listing equipment to state: Breakers 

and related switching equipment, bus and support structures, potential and current transformers, shunt and/or series capacitors and shunt reactors (as required based on system requirements at the time of construction). Leave references to 

transformer banks, control, protection and communications systems and control buildings. Eliminate all other equipment references.

The

Chapter 2 - Overall Project -- 2.1.2 -- 8 -- 1st bullet -- Expansion of existing substation -- This is inaccurate. Heward is a new substation adjacent to the existing Difficulty substation

Info

Chapter 2 - Overall Project -- 2.1.2 -- 14 -- 2 -- The alternative of two single-circuit lines in place of one double-circuit line 

presents some potential advantages for construction schedule, maintainability, and operational availability. For example, as 

opposed to the heavier double-circuit tower, the lower structure weight and configuration of the single-circuit structure would

allow helicopter-aided construction techniques, providing the Proponents with the option of taking less time to construct. 

Separating the two 500-kV circuits onto two separate structures would allow energized maintenance procedures to proceed more easily than when both circuits are on the same structure. During a structure failure event, if a double-circuit tower fails, 

both circuits would be out of service. With two single-circuit lines, it is less likely that both circuits would be affected to the 

same degree during the same event. Thus, the two single-circuit structure alternative would have a higher operational 

availability during a tower failure event. However, in the isolated situation where spans between structures would exceed 

1,800 feet as compared to the average span of 1,200 to 1,300 feet, a parallel circuit separation distance of greater than 175 

feet would be required for protection in the unlikely event of towers tipping into the adjacent line because tower heights would need to be increased to allow for greater span lengths. Longitudinal offsets of tall towers may also be required. -- The EIS needs to better explain what is meant by helicopter construction, including its inherent limitations as well as impacts. The EIS 

should also explain when (and with what criteria) would it be used?

The 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 2 - Overall Project -- 2.1.3 -- 17 -- [blank] -- In addition to the proposed self-supporting single-circuit steel lattice 500-

kV structure, the Proponents wish to consider an alternative single-circuit 500-kV guyed structure for use where terrain, land cover, and land use allow. During final design, the Proponents would identify specific locations where this structure would be 

proposed for review and approval. Figure B-6 in Appendix B shows the ROW configuration for the guyed “Delta” and guyed “V” 

structures. Table 2.1-6 compares the self-supporting and guyed “Delta” structures for several factors. -- The EIS should describe what criteria determines when guyed structures would be used instead of conditions when they "can" be used.

Seobl

Chapter 2 - Overall Project -- 2.1.3 -- 18 -- T2.1.6 -- Table -- The long-term disturbance for guyed structures should be different than other structures and the EIS should disclose the use of disk anchors in addition to screw anchors. Also, for either type of anchors, maintenance must be performed periodically to ensure integrity of system so the Proponent will be driving to them (leaving the access road) at least once every ten years.

The 

Chapter 2 - Overall Project -- 2.1.3 -- 18 -- T2.1.6 -- Table -- Guyed weights are stated as approximate at 29679 and 25113 

pounds. This should be rounded up to 25000 and 30000 pounds. See previous comment.

Thi

Chapter 2 - Overall Project -- 2.1.3 -- 18 -- T2.1.6 -- Table -- Maintenance activities are listed as similar. Similar to what? All 

comparatives in this table should be clarified.

The 

Chapter 2 - Overall Project -- 2.1.3 -- 20 -- 2 -- The guyed tower takes up more operational space than the self-supporting structure due to the guy wires but would generally be accommodated within a 250-foot ROW where only a single circuit is 

planned. Guy wires may extend outside the ROW on the downhill side on steep slopes to maintain an appropriate slope for the guy. For the Design Variation in which two single circuits would be constructed on the same ROW, the guyed structures would 

be guyed delta towers and would require a ROW 375 feet wide. The extra ROW would be required only where the structure 

locations the guy anchors and wires would extend beyond the ROW. -- This phrase should be re-written to state that guy wires 

may extend beyond 250' and the ROW would be expanded accordingly.

Thi

Chapter 2 - Alternative Development -- 2.2.1 -- 23 -- 4 -- (Add as new 4th paragraph) -- WECC language should be inserted as 

a new paragraph including: a) (WECC Criteria TPL – (001 thru 004) – WECC – 1 – CR _ System Performance Criteria 

Definitions, b) Common Corridor: Contiguous right-of-way or two parallel right-of-ways with structure centerline separation less 

than the longest span length of the two transmission circuits at the point of separation or 500 feet, whichever is greater, between the transmission circuits. This separation requirement does not apply to the last five spans of the transmission circuits 

entering into a substation and c) Adjacent Transmission Circuits: Transmission circuits within a Common Corridor with no other 

transmission circuits between them. Transmission Lines that cross but are otherwise on separate corridors are not Adjacent Transmission Circuits.

Thi

Chapter 2 - Overall Project -- 2.1.2 -- 16 -- T2.1.5 -- Table -- Long-term disturbance differs by resource (see previous comment).

Se

G-1 -- Resource Management Plan (as amended) design criteria, Best Management Practices (BMPs) and mitigation requirements will apply on BLM-managed lands. -- D -- The Proponents propose the following revision: "Resource Management Plan (as of 2011) design criteria, Best Management Practices (BMPs) and mitigation measures that are 

consistent across Field Office boundaries and with acquired permits will be applied on BLM-managed lands to the extent feasible within engineering and design limitations." [RMPs in effect at time of ROW grant]

No 

G-2 -- Forest Plan Standards and Guidelines (as amended) will apply on National Forest System (NFS) lands. Ground 

disturbing and vegetation management activities will comply with all Agency wide, Regional, and State BMPs. -- D -- The 

Proponents propose the following revision: "Forest Plan Standards and Guidelines (as of 2011) will apply on National Forest System (NFS) lands to the extent feasible within engineering and design limitations and as consistent with acquired permits. 

Vegetation management activities will comply with the memorandum of understanding among Edison Electric Institute member 

utilities and federal agencies, as well as the best management practices from the International Society of Arboriculture (Miller, 

2007)." [RMPs in effect at time of ROW grant]

No am

VIS-2 -- To minimize ground disturbance and/or reduce scarring (visual contrast) of the landscape, the alignment of any new access roads or cross-country routes will follow the landform contours in designated areas where practicable, providing that such alignment does not impact resource values additionally. -- D -- The Proponents propose the following revision: To minimize ground disturbance and/or reduce scarring (visual contrast) of the landscape, the alignment of any new 

access/service roads or cross-country routes will follow the landform contours in designated areas where practicable, providing that such alignment does not impact resource values additionally or result in new impacts to resources that were 

previously avoided.The DEIS also needs to identify/define “designated areas”.

VISredor csucres
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

VIS-3 -- To minimize sensitive feature disturbance and/or visual contrast, in designated areas structures will be placed so as to 

avoid sensitive features such as, but not limited to, riparian areas, water courses and cultural sites and/or to allow conductors 

to clearly span the features, within the limits of standard tower design. – D -- The Proponents propose the following revision:"To minimize sensitive feature disturbance and/or visual contrast, in designated areas on federal lands, structures will be placed so as to avoid sensitive features such as, but not limited to, riparian areas, water courses and cultural sites and/or to allow conductors to clearly span the features, within the limits of standard tower design and only if other sensitive or important (e.g., identified by stakeholders) resources are not affected." 

VISandto aculstama

VIS-4 -- To reduce visual impacts on federal land, including potential impacts on recreation values and safety, towers are to be 

placed at the maximum feasible distance from the highway, canyon and trail crossings within limits of standard design and to 

the extent practical. – C -- This measure requires clarification. it is assumed that it applies to tangent structures however it is 

unclear. As written it could lead to more angle structures and significant cost increase. The BLM should identify sensitive trail 

and canyon crossings (for example, specific trails crossings where the trail meets specific criteria [i.e. with intact ruts] and 

specific canyons) using similar format as presented in VIS-8. Additional information on how a canyon is defined and specific 

criteria that would be used for identifying canyons (and trail crossings) where this measure could be applicable? Are these key

crossings at the Snake River or just any canyon-like feature that is cross? This measure is also covered in VIS-8 and could be 

removed or combined to avoid redundancy. 

VISincmasta

VIS-5 -- Crossings of rivers shall be at approximately right angles where practical. Strategic placement of structures shall be

done both as a means to screen views of the transmission line and rights-ofway and to minimize the need for vegetative 

clearing. – C -- The term "river" should be clarified, i.e., what order of river? This is accomplished during design and spotting of 

towers. This will be accomplished to the extent feasible and within general engineering constraints and common practices. Refer to the Siting Study (Sept 2008). This is not a measure that may be implemented after design has been accomplished.

No 

VIS-6 -- All insulators shall be made of materials that have reduced potential to reflect and refract light. Glass insulators shall be avoided when there is an alternative insulator type available with lower refractive characteristics. – C -- Glass has a distinct 

advantage over porcelain because they do not fail catastrophically and they are much easier to inspect, although porcelain will

have an almost identical insulator length. There are problems with brittle fracture, as well as inspection problems with polymers. There is no way to do an inspection on polymers to determine if you have an insulator that will protect workers doing

live-line work. If polymers are selected, you have essentially eliminated the option of performing live-line maintenance for the 

life of the line. Polymer insulators have to be longer than glass insulators to get the same insulation properties. The increased 

length will increase the dimensions of the structure windows and the tower height; this requires more steel and increases 

structure costs. Polymer insulators are not a direct replacement for porcelain/glass in terms of dimensions.

The (norednot 

VIS-1 -- No paint or permanent discoloring agents would be applied to rocks or vegetation to indicate limits of survey or 

construction activity. -- A -- [blank]

Thi

VIS-7 -- For segments of the line 1) within the 0- to 0.5-mile zone of Interstate highways where existing lines of the same 

voltage are paralleled and 2) within the 0- to 0.5-mile zone of residences where existing lines of the same voltage are paralleled, locate new towers to be adjacent to existing towers, within the limits of standard transmission line design and 

considering the ruling span length of adjacent proposed and existing lines. -- B – [blank]

VIS

VIS-8 -- Site-specific “micrositing” will be required near certain sensitive areas, as identified by the agencies, where proposed 

transmission facilities would be present and could impact visual quality; these situations include: -- D -- The Proponents propose the following revision: "Site-specific “micrositing” (moving a structure in-line with the centerline or within the limits of standard engineering design as to not require additional tangent or angle structures) will be implemented to the extent practicable near certain sensitive areas, as identified by the agencies, where proposed transmission facilities would be present 

and could impact visual quality; these situations include:" Additional comment: This measure is also covered in VIS-4 and could be removed or combined to avoid redundancy. Micrositing should be defined throughout all measures where it is used. 

This is accomplished during tower spotting. Crossings over major highways; Crossings of high quality historic trails; Crossings over the North Platte Snake Rivers; Crossing the Albion Mountains in the Sawtooth NF; Sensitive travelways, use areas, residential areas, recreational facilities as identified by the agencies (including national 

recreation and scenic trails, campgrounds, recreation areas, and trailheads), and other areas identified by management plans; and Along Forest Service roads in forested areas.

VISlimidequa• C• C• C• Sthe are• TThe tran
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

VIS-9 -- In specific areas identified by the applicable federal land manager (such as VRM Class II, erosive soils, steep slopes, 

areas near NHT Trails) the access road used for construction will be restored and an alternative access route for operations will be designated. -- C -- Implementation of this measure would result in new and currently unknown impacts that would need to be assessed through the current NEPA process.

Thi

VIS-10 -- In areas in proximity to existing residential developments with an urban or suburban character, such as in the Kuna 

area, steel pole H-frame tubular steel poles may be specified to provide tower structures that are visually more appealing. 

Lattice steel towers will need to be specified at turning tower locations and at long spans because tubular steel poles do not 

have the strength to withstand the forces exerted by the conductors at these locations. -- C -- The BLM does not have the 

regulatory authority to require certain structures on non-federal lands.

Thi

VIS-11 -- The lighting specified for the marshaling yards shall be the minimum required to meet safety and security standards. All light fixtures within 1,000 feet of a residence shall be hooded to eliminate any potential for glare and to prevent light from spilling off the site or up into the sky. Additionally, the fixtures shall have sensors and switches to permit the lighting to be turned off at times when it is not required. -- A – [blank]

VISminof a spisw

VIS-12 -- Where the route would be visible on timbered slopes, limit tree removal to areas required for safety rather than from

the entire ROW in order to prevent a linear feature on the landscape from clear-cutting trees. Vegetation removal requirements will consider Appendix A, “Standards and Practices for Electric System Reliability.” -- C -- This section is inconsistent with the 

MOU between EEI member utilities and Federal Agencies, and is therefore, unacceptable. The linear nature of the right of way 

can be mitigated using the wire border zone technique as described in Appendix C. Note that wires at many of the structures 

will be more than 50 feet off the ground, meaning those areas would be "Region B" as described in Figure 2 of Appendix C. That means border zone species may be allowed over the entire width of the right-of-way near to structures provided the vegetation does not encroach on the structures themselves. The "area required for safety" is the entire ROW. A requirement 

that we not remove trees in the ROW will force us to prune to such an extent as to leave large numbers of tree remnants in the 

right of way. This practice would be unsightly, adversely affect system reliability, severely damage or kill existing trees, 

promote infestations of bark beetles, produce an unnecessary fire risk, and impose an unreasonable long-term management burden on the company and our rate payers. Secondly, feathering may be accomplished by thinning trees from the right-ofway edge out with agency approvals in some areas. However, trees with a mature height over 25 feet may only be allowed to 

grow in the ROW where the line is over 100 feet off the ground (considering maximum designed sag). Should specify what 

document Appendix A is located in as it may be confused with Appendix A of the DEIS.

Thi

VIS-13 -- To reduce visual contrast in areas where overstory vegetation is removed for access, tower pads, or conductor 

clearance, specific sections of the clearing edges on federal land will be feathered to give a natural appearance, where not in

conflict with regulatory requirements (e.g., NERC, WECC, and Occupational Safety and Health Administration requirements). -- D -- The Proponents propose the following revision: "To reduce visual contrast in areas where overstory vegetation is 

removed for access, tower pads, or conductor clearance, specific sections of the clearing edges on federal land will be feathered (trees thinned/removed from the edge of the rightof- way out or away from the right-of-way boundary) to give a 

natural appearance, where not in conflict with regulatory requirements (e.g., NERC, WECC, and Occupational Safety and 

Health Administration requirements). This would be a onetime application and conducted with agency approval." 

VIS

vegthe edgappOcapp

VIS-14 -- Crossing federal land along a transmission corridor shall require the preparation of a vegetation management plan for the utility corridor to minimize scenic impacts and plan for rehabilitation of existing impacts. This plan will be approved by 

the landmanagement agency prior to vegetation clearing. – C -- This should only be required where there are adverse impacts to visual resources, otherwise the reclamation plan will be followed and the Proponents' respective vegetation management 

plans will be followed. In the event additional plans are required, such plans should be consistent with ANSI A300 Part 7 and 

Best Practices: Integrated Vegetation Management (2007, Miller, R.H. from the International Society of Arboriculture). "Scenic 

impacts" should be defined.

Thipre

VIS-15 -- To mitigate potential visual impacts on federal land, the construction and maintenance plan to be developed by the Proponents shall include measures to reduce ROW scarring and enhance restoration. The plan will be approved by the land 

management agency prior to ground clearing and construction. -- A -- Pertaining to this and all measures that require agency 

approval (i.e. approval of a plan or process), the BLM should identify and describe the approval process, responsible parties, 

and timelines within the EIS.

No

VIS-16 -- Realignment of a portion of Alternative 1E-B, adjacent to the Rock Creek and Fort Fetterman Road (KOP 993), to 

follow the rugged terrain and foothills of Smith Mountain should be evaluated to determine absorption effectiveness. -- C -- This should be conducted as a new route alternative and analyzed between DEIS and FEIS based upon addressing resource 

conflicts. Visual simulations shall be performed to provide justification for structure selection.

Se
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

VIS-17 -- Single-circuit H-frame structures shall be used to reduce visual impact to Fort Fred Steele between MP 38.0 to MP 

43.0 for Alternative 2B and MP 18.0 to MP 24.0 for Alternative 2A to match the existing structures. -- D -- The Proponents 

propose the following revision: "Single-circuit H-frame structures shall be used to reduce visual impact to Fort Fred Steele 

between MP 38.0 to MP 43.0 for Alternative 2B and MP 18.0 to MP 24.0 for Alternative 2A to match the existing structures. 

Lattice steel towers will need to be specified at angle and dead-end locations and at long spans because tubular steel poles 

are cost prohibitive, potentially have more disturbance area and may result in less visual absorption."

Thi

VIS-18 -- If Alternative 7I were to be constructed, H-frame single-circuit structures would be required in the Nevada portion of 

the alternative as requested by the Wells FO. -- C -- Table 2.6-3 compares the single-circuit lattice steel tower and singlecircuit steel pole H-frame ROW configurations for several factors. While the H-frame 500-kV tangent structure is feasible with 

significant cost increase, this measure fails to assess and acknowledge that tubular structures would have greater disturbance 

(more structures per mile) and would likely result in less visual absorption, thereby not satisfying the intent of this measure

(addressing visual resources). Use of H-frames at 500kV will likely result in less visual absorption as the H-frames are much bigger than the existing lines and the large dark steel poles that comprise the H-frames are likely to be more visible than the

lattice at a medium distance. In addition, Lattice steel towers would need to be specified at turning tower locations, dead-ends and at long spans because tubular steel poles are cost prohibitive, potentially have more disturbance area and may result in 

less visual absorption.

Alte

VIS-19 -- If any of Alternatives 7H, 7I, or 7J were to be constructed, Hframe single-circuit structures would be required in the 

Sawtooth NF. -- C -- Table 2.6-3 compares the single-circuit lattice steel tower and single-circuit steel pole H-frame ROW configurations for several factors. While the H-frame 500-kV tangent structure is feasible with significant cost increase, this

measure fails to assess and acknowledge that tubular structures would have greater disturbance (more structures per mile) 

and would likely result in less visual absorption, thereby not satisfying the intent of this measure (addressing visual resources). 

Use of H-frames at 500kV will likely result in less visual absorption as the H-frames are much bigger than the existing lines 

and the large dark steel poles that comprise the H-frames are likely to be more visible than the lattice at a medium distance. In 

addition, Lattice steel towers would need to be specified at turning tower locations, dead-ends and at long spans because tubular steel poles are cost prohibitive, potentially have more disturbance area and may result in less visual absorption.

The

CR-1 -- (for historic properties in all segments): Avoid direct impacts by designing the route so that no Project facilities, including access roads, are placed within the boundaries of historic properties. Assess magnitude and location of adverse effects, should avoidance of historic properties not be feasible. – D -- In order to 

fully adhere to this measure, the Proponents require the results of cultural surveys that have been conducted and will be 

conducted. The Proponents cannot avoid resources without knowing where they are. The Proponents may more effectively and cost-efficiently avoid and minimize impact to cultural resources/historic properties by knowing their location. The 

Proponents request this information be provided to the Proponents as these surveys are completed. In addition, the 

Proponents propose the following revision: "The Proponents will evaluate the possibility of avoiding cultural resources that are 

eligible for listing or are listed on the NRHP once the BLM provides this data. Relocating structures and associated facilities to avoid or minimize impacts will be evaluated on a case-by-case basis. Changes in structure and associated facility location will

be implemented only if it does not result in the relocation of project features to an area outside of the analysis area (e.g., no 

new surveys or analysis are required); does not result in increased costs; and does not result in new or additional impacts to other sensitive resources."

Thi
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

CR-2 -- (for historic trails and other linear routes in all segments): Design the transmission line to cross where existing modern 

development occurs. – D -- The Proponents propose the following revisions: "(for historic trails and linear routes [linear routes 

should be defined] in all segments where there is an adverse effect determination):" "Design the transmission line to cross 

where existing modern development occurs to the extent feasible within common engineering design limitations and where 

permissible." The term "linear routes" needs to be defined to fully assess this proposed measure. The measures proposed here should be clarified to be utilized only if there is an adverse effect on the resource. Routing the transmission line to cross 

linear routes "where there is existing development" is largely dictated by local codes and ordinances. Dog-legs or S-curves in a 

transmission line would require several bulky towers and associated hardware. The author of this measure needs to consider the visual impact of multiple dead-end and angle structures, (with associated insulators and jumpers) on views around historic 

trail crossings. These tower structure types would be required to build dog-legs or S-curves, and are much more bulky and 

eye-catching than the inline tangent structures. The dead-end and angle structures are larger due to the added forces induced from pulling the towers in different directions. These design criteria would require more structures compared to straight 

alignments. Clarification regarding "paralleling" needs to be provided. Avoid paralleling by what distance? 

CR-2 -- (for historic trails and other linear routes in all segments):Cross the resource as close to a 90-degree angle as possible 

using a dog-leg or S curve. --C – The Proponents propose the following revisions: "(for historic trails and linear routes [linear routes should be defined] in all segments where there is an adverse effect determination):" "Design the transmission line to 

cross where existing modern development occurs to the extent feasible within common engineering design limitations and where permissible." The term "linear routes" needs to be defined to fully assess this proposed measure. The measures 

proposed here should be clarified to be utilized only if there is an adverse effect on the resource. Routing the transmission line 

to cross linear routes "where there is existing development" is largely dictated by local codes and ordinances. Dog-legs or Scurves in a transmission line would require several bulky towers and associated hardware. The author of this measure needs 

to consider the visual impact of multiple dead-end and angle structures, (with associated insulators and jumpers) on views 

around historic trail crossings. These tower structure types would be required to build dog-legs or S-curves, and are much 

more bulky and eye-catching than the inline tangent structures. The dead-end and angle structures are larger due to the 

added forces induced from pulling the towers in different directions. These design criteria would require more structures compared to straight alignments. Clarification regarding "paralleling" needs to be provided. Avoid paralleling by what distance?

CR-2 -- (for historic trails and other linear routes in all segments): Adjust tower placement to use the maximum span distance to achieve maximum tower distance from the linear resource. – B – The Proponents propose the following revisions: "(for historic trails and linear routes [linear routes should be defined] in all segments where there is an adverse effect 

determination):" "Design the transmission line to cross where existing modern development occurs to the extent feasible within 

common engineering design limitations and where permissible." The term "linear routes" needs to be defined to fully assess this proposed measure. The measures proposed here should be clarified to be utilized only if there is an adverse effect on the resource. Routing the transmission line to cross linear routes "where there is existing development" is largely dictated by local 

codes and ordinances. Dog-legs or S-curves in a transmission line would require several bulky towers and associated 

hardware. The author of this measure needs to consider the visual impact of multiple dead-end and angle structures, (with associated insulators and jumpers) on views around historic trail crossings. These tower structure types would be required to 

build dog-legs or S-curves, and are much more bulky and eye-catching than the inline tangent structures. The dead-end and angle structures are larger due to the added forces induced from pulling the towers in different directions. These design criteria 

would require more structures compared to straight alignments. Clarification regarding "paralleling" needs to be provided. Avoid paralleling by what distance? CR-2 -- (for historic trails and other linear routes in all segments): Avoid paralleling the linear resource as much as possible 

and obtain maximum tower distance by shifting alignment and maximize topographic screening with lower structures, such as the two single-circuit steel-lattice design alternative.. – C – The Proponents propose the following revisions: "(for historic trails 

and linear routes [linear routes should be defined] in all segments where there is an adverse effect determination):" "Design the transmission line to cross where existing modern development occurs to the extent feasible within common engineering design limitations and where permissible." The term "linear routes" needs to be defined to fully assess this proposed measure. The measures proposed here should be clarified to be utilized only if there is an adverse effect on the resource. Routing the 

transmission line to cross linear routes "where there is existing development" is largely dictated by local codes and ordinances. 

Dog-legs or S-curves in a transmission line would require several bulky towers and associated hardware. The author of this measure needs to consider the visual impact of multiple dead-end and angle structures, (with associated insulators and jumpers) on views around historic trail crossings. These tower structure types would be required to build dog-legs or S-curves,

and are much more bulky and eye-catching than the inline tangent structures. The dead-end and angle structures are larger due to the added forces induced from pulling the towers in different directions. These design criteria would require more structures compared to straight alignments. Clarification regarding "paralleling" needs to be provided. Avoid paralleling by what 

distance?

Thides
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

CR-3 -- Compensatory Mitigation Measures – The BLM, in consultation with the Wyoming, Nevada, and Idaho SHPOs, and consulting parties is developing a PA and a Historic Properties Treatment Plan. Compensatory mitigation measures may be developed as appropriate for specific historic resources. The following example measures may be considered for adversely affected 

properties, or other measures required: Fund or provide interpretive, educational exhibits placed in museums or nearby interpretive centers. 

Develop an illustrated guide to the regional archaeology and history, which would present the results of the Project’s archaeology/history in layperson’s terms for the general public. Provide new markers for the BLM and other public groups to position along historic trails, highways, and other linear resources. 

Fund or provide outdoor, interpretive wayside exhibits along access points to trails, highways, and other linear resources Fund or provide educational films or curriculum for area school districts about the history and significance of the linear resources. Acquire or trade land with willing seller(s). Preserve landscapes from a cultural landscape perspective. Bury elsewhere other (non-Project) lower kilovolt transmission or distribution lines. Commission studies of associated historic sites along the corridor to support a regional context. Re-vegetate disturbed areas to protect or restore viewsheds. Provide monetary support to historic trail-related state parks.-- C -- Burying non-Project related lines may have adverse environmental impact and O&M complications. The cost and complications of implementing such a measure is not commensurate with the perceived impact to the cultural resource. The Proponents may also not own the lines and thus the Owner may not want them buried due to O&M issues. Measures such as this should not be suggested without knowing the feasibility of accomplishing the measure. Appropriate mitigation will be addressed in the HPTP. These measures should be clearly presented as potential measures

and not limited to. Mitigation within the HPTP should not be dictated here.

Thi

CR-4 -- Conservation Easements – Where feasible and appropriate, conservation easements will be considered to preserve important archaeological and historic sites, and high integrity linear resource segments, or to preserve viewsheds. A 

conservation easement (sometimes called a conservation covenant) creates a legally enforceable land preservation 

agreement between a landowner and a government agency (federal, state, county, or municipality) or a qualified land protection organization ("land trust") for the purposes of conservation. It restricts real estate development, commercial and 

industrial uses, and certain other activities on a property to a mutually agreed upon level. The property remains the private 

property of the landowner. – B -- Appropriate mitigation will be addressed in the HPTP.

Thi

CR-5 -- On NFS lands, a management plan should be developed for each historic property nominated to the NRHP. The plan should be drafted during the nomination process. The National Heritage Strategy should be used to guide decisions on issues 

related to the Heritage Program. – C -- Appropriate mitigation will be addressed in the HPTP.

No 

SOC-1 -- Housing Plan: Contract with local motels and hotels for temporary accommodation within daily commuting distance of the Project site. Temporary accommodations will be selected based on value, cleanliness, and proximity to the Project site. Contract with local RV parks for rental spaces to accommodate workers who have access to RVs. 

If temporary accommodation is not available within the Project area, seek motel and hotel accommodations outside the Project area. In this event, the Proponents would provide transportation to the Project site in the form of buses or vans, depending on

workforce numbers, to ensure workers arrive at the Project site safely. If sufficient temporary accommodation is not available, depending on the location and the number of workers involved, the Proponents would explore other temporary housing options, including the use of temporary housing facilities established for other projects, establishing temporary RV lots on public lands, and developing Project-specific temporary housing camps. The Proponents would provide bus or other transportation to the Project site if these facilities were located outside the Project area. 

– C -- This will be accomplished by the EPC contractor as per the requirements imposed by the WISC permit. An analysis was conducted by a number of EPC vendors that indicate sufficient housing. Appropriate measures will be taken by the EPC contractor to ensure adequate housing and transportation to and from the Project site.

Thi

VEG-1 -- The Proponents shall consult with each appropriate local land management agency (Forest Service and BLM) office or land owner to determine appropriate seed mix for revegetation. Also see WEED-1. – A – [blank]

The

VEG-2 During construction, blading of native plant communities should be minimized, consistent with safe construction 

practices. Where feasible, shrubs should be cut at or near ground level to facilitate re-growth after construction. The footprint 

of construction and operations facilities should be kept to the minimum necessary. – A – [blank]

Thi

VEG-3 Where feasible, locate new access roads to minimize the number of trees to be removed during construction. -- D -- 

The Proponents propose the following revision: "Where feasible, locate new access and service roads to minimize the number of trees removed during construction. Roads will not be relocated if the change would result in an increase in the overall 

disturbance (acres); additional cut and fill activities, or impact other sensitive resources (e.g., sagebrush plant community, 

sensitive species habitat, and/or cultural resource or viewshed)."

Thi
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

VEG-4 In areas where revegetation would be completed, topsoil salvage and replacement should be used for areas larger 

than 1 acre where soils would be disturbed during construction. In areas where revegetation would be completed, topsoil 

salvage will be used in all areas of cut or fill in order to facilitate revegetation. -- D -- Clarification is needed regarding the 1 acre threshold in order to assess this measure and reduce confusion regarding implementation. Is this applicable to improved 

access roads and service roads? Because of existing site conditions (e.g., areas with noxious weeds) it may not be 

appropriate to salvage topsoil. Also, this measure appears to conflict with the first bullet on p.3.6-14 and the Proponents proposed measure in Appendix C-2 (page 6). As such, the Proponents propose the following revision: “In areas where 

revegetation with the intent to restore habitat would be completed, topsoil salvage and replacement may be used where soils 

would be disturbed during construction. Generally, topsoil salvage will be used where negotiated with private landowners (e.g.,

agricultural soils) and where healthy native plant communities occur. The Proponents will also reseed disturbed areas as a BMP (e.g., roads); topsoil will not be salvaged in these areas.”

No

VEG-5 -- The Proponents’ employees and contractors will employ typical practices to prevent fire during construction and 

operations including brush clearing prior to work, stationing a water truck at the job site to keep the ground and vegetation 

moist in extreme fire conditions, enforcing red flag warnings, providing training to all pertinent personnel, keeping vehicles on 

designated roads and within work areas, and providing fire suppression and emergency notification numbers at each construction site. Brush clearing will be limited to the construction ROW. -- D -- By removing discussion of stationing water 

trucks it allows flexibility and leaves it up to the EPC contractor how this will be accomplished. This measure also appears toconflict with other measures that require minimizing brush clearing. This conflict needs to be addressed to ensure application 

of intent of such measures is achievable. The Proponents propose the following revision: "The Proponents’ employees and contractors will employ typical practices to prevent fire during construction and operations including brush clearing prior to 

work, enforcing red flag warnings, providing training to all pertinent personnel, keeping vehicles on designated roads and 

within work areas, and providing fire suppression and emergency notification numbers at each construction site. Brush 

clearing will be limited to the construction ROW."

Thi

VEG-6 -- The Reclamation, Revegetation, and Weed Management Plan must provide a site-specific plan for access road and ROW vegetation management in areas where removal of trees is proposed. The site-specific plan must include tree removal, slash disposal plans, and BMPs to avoid erosion or sedimentation of watercourses or wetlands. This plan will be submitted to 

each applicable land management agency for approval prior to clearing. -- C -- Clarification is needed regarding access roads. 

Is this referring to service roads? Trees removal on USFS land will adhere with the conditions of the timber sale and USFS requirements. Through discussion with the USFS for the Caribou, Medicine Bow and Sawtooth NFs, they all had said that additional site specific plans would not be required and that the Proponents vegetation management guidelines in conjunction 

with the timber sale requirements would be sufficient.

Thi

VEG-7 -- Herbicide use must conform to the existing types and application methods approved by those land managing agencies. The Reclamation, Revegetation, and Weed Management Plan must specify where herbicides would be used, what types would be used, and what application methods would be used. The plan must be in conformance with regulations regarding herbicide use from the land-managing agency or county in which herbicide use is proposed. -- D -- This measure is very similar to REC-5, REC-6 and OM-14. The agency proposed measures could be combined into one measure. Rocky 

Mountain Power follows IVM Best Management practices, Miller, R.H. from the International Society of Arboriculture - Champaign, IL 2007 regarding application of herbicide. Also, Pesticide Use Proposals are required, which would seem to cover this measure, however, the Proponents propose the following revision: "Herbicide use must conform to the existing 

types and application methods approved by those land managing agencies. The Reclamation, Revegetation, and Weed 

Management Plan must specify where herbicides would be used, what types would be used, and what application methods 

would be used. The plan must be in conformance with regulations regarding herbicide use from the land-managing agency or county in which herbicide use is proposed.

The
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

VEG-8 -- Prior to the start of construction and maintenance activities, all contractor vehicles and equipment (including personal 

protective equipment) shall be cleaned of soil and debris capable of transporting invasive plant seeds or other propagates. Allvehicles and equipment shall be inspected by Agency-approved inspectors and certified as weed free by agency approved personnel, in order to ensure they have been cleaned properly. The final Reclamation, Revegetation, and Weed Management 

Plan will include the location of all cleaning stations, how materials cleaned from vehicles at these stations would be either 

captured or treated so that cleaning station locations would not also become infected, and who would confirm/certify that 

vehicles leaving cleaning stations and/or entering construction sites are free of invasive plant materials. -- D -- Additional 

clarification is required to assess this measure. How will inspection be accomplished of all vehicles and equipment by the inspector? The Proponents propose the following revision: "Prior to the start of construction and maintenance activities, all contractor vehicles and equipment shall be cleaned of soil and debris capable of transporting invasive plant seeds or other 

propagates. Vehicles and equipment used on site shall be randomly inspected and certified as weed free by agency approved 

personnel, in order to ensure they have been cleaned properly. The final Reclamation, Revegetation, and Weed Management Plan will include the location of all cleaning stations, how materials cleaned from vehicles at these stations would be either 

captured or treated so that cleaning station locations would not also become infected. "

Thiins

VEG-9 -- Agency staff will approve weed-free straw or other erosion control on federal lands prior to application. -- C -- This

measure is vague. How is this accomplished? Paperwork approval or physical inspection? Clarification is needed in order to assess and potentially implement this measure. The DEIS needs to clearly identify the criteria, process, and timelines the 

agencies will use to approve weed-free straw and other erosion control materials.

ThiCocon

VEG-10 Agency staff will approve tree seedlings planted in decommissioned roadbeds and other temporarily disturbed areas on federal lands to assure seedlings are matched to site conditions. -- D -- The DEIS needs to clearly identify the criteria, 

process, and timelines the agencies will use to approve seedlings. The Proponents propose the following revision: "The Proponents will consult with Agency staff to determine tree seedlings to be planted in decommissioned roadbeds and other temporarily disturbed areas on federal lands (where tree stands were removed) to assure seedlings are matched to site conditions."

Thiappdeclan

VEG-11 -- The Proponents will consult with appropriate Forest Service staff to identify the top soil layer on NFS lands. -- C -- 

The DEIS needs to clearly identify the criteria, process, and timelines the agencies will use to indentify the top soil layer.

Thiope

VEG-12 -- Post-construction monitoring and treatment of invasive plants on closed roads and fly yards shall continue for at least 3 years. If after 3 years post-construction conditions are not equivalent or better than pre-construction conditions, 

monitoring and treatment will continue until these conditions are met.-- D -- The Proponents propose the following revision: "Postconstruction monitoring and treatment of invasive plants on closed service roads (roads dedicated for use by Proponents only) and fly yards shall continue for 3 years. If after 3 years post-construction conditions are not equivalent or similar to preconstruction conditions (in accordance with applicable permit), monitoring and treatment will continue until these conditions are 

met."

Thion fly infeconaccconperPro

VEG-13 -- The Proponents will meet Wyoming State Forest Practices Act requirements and apply Region 4 BMPs for timber 

removal operations on the Medicine Bow NF and meet Idaho State Forest Practices Act requirements and apply Region 2 BMPs for timber removal operations on the Caribou-Targhee and Sawtooth NFs. -- D -- Proponents propose the following revision based on discussions with NFs: "The Proponents will meet the terms and stipulations within the timber sale contracts 

for timber removal operations on the Medicine Bow, Caribou-Targhee and Sawtooth NFs."

Thi

VEG-14 -- Where the route would be visible on timbered slopes on lands managed by the Kemmerer FO, allow tree removal 

only at structure locations and where required for safety rather than from the entire ROW in order to prevent a linear feature on 

the landscape from clear-cutting trees. Vegetation removal requirements will consider Appendix A, Key Standards Relating to 

Electric System Reliability and Safety, of the MOU with the Edison Electric Institute (2006). -- C -- This is completely 

unacceptable as a mitigation measure and is a direct contradiction to the intent of the MOU cited. The MOU's intent is to 

perform cover type conversion away from vegetation communities that could interfere with the conductors at some time in their life-cycle toward plant communities that will not. A requirement that we not remove trees except at structure locations will force 

us to prune to such an extent as to leave large numbers of tree remnants in the right of way. This practice would be unsightly,severely damage or kill existing trees, promote infestations of bark beetles, produce an unnecessary fire risk, and impose an 

unreasonable long-term management burden on the company and our rate payers. If land managers want to prevent linear features we can feather the right of way, as outlined in the last paragraph of Section 3.6.2.2, page 21 for the Medicine BowRoutt and Caribou-Targhee NFs.

Thi
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

TESPL-3 -- Qualified botanists shall conduct pre-construction surveys during a season when target species are readily 

identifiable for special status or globally rare species. Where feasible, micrositing of project facilities shall avoid direct impacts 

to identified populations. Survey reports documenting the surveys, their results, and recommendations must be provided to land management agency for approval prior to construction. Agency botanists may evaluate individual sites based on sitespecific conditions. Documentation of the evaluation of avoidance of impacts to sensitive and globally rare plants must be 

provided to the agencies prior to construction. -- C -- The Proponents will address this measure when the Proponents submit revised proponent-proposed environmental protection measures at a later date.

The 

TESPL-4 -- Environmental monitors shall be used to identify and mark aboveground populations of slickspot peppergrass and 

higherquality microsites within 50 feet of the construction area, including access roads, so that they are avoided by construction equipment and vehicles. Full field clearances shall be conducted that meet USFWS protocols prior to 

construction. No construction shall occur within 50 feet of any slickspot peppergrass plant or habitat, including known 

occurrences of slickspot peppergrass (based on Idaho CDC data) even if aboveground plants are not observed during the 

surveys. Seeding during reclamation must use methods that minimize soil disturbance such as no-till drills or rangeland drills with depth bands, in areas of suitable habitat. Reclamation must use certified weed-free native seed. Excess soils will not be 

stored or spread on slickspots. -- C -- The Proponents will address this measure when the Proponents submit revised proponent-proposed environmental protection measures at a later date.

The 

TESPL-1 -- Surface disturbance will be allowed in suitable habitat for Goose Creek milkvetch where species-specific surveys 

have determined that no populations are present. The species-specific surveys will be conducted the year prior to 

construction, and the proposed disturbance areas will be redesigned to avoid direct impacts to populations. -- D -- The Proponents propose the following revision: "Surface disturbance will be allowed in suitable habitat where speciesspecific surveys have determined that no populations are present. The species-specific surveys will be conducted prior to construction 

during the appropriate season, and the proposed disturbance areas will be designed or modified within engineering limitations and standards to avoid direct impact to populations to the maximum extent practicable."

The 

TESPL-2 -- Pre-construction surveys for the Ute ladies’ tresses shall be conducted by qualified botanists in all areas of 

potential habitat, in accordance with federal land management agency and USFWS requirements. These pre-construction 

surveys shall be conducted during the appropriate survey window, for a total of 3 years. – D -- Proponents propose the 

following revision: "Pre-construction surveys for the Ute ladies’ tresses shall be conducted by qualified botanists in all areas of 

potential habitat, in accordance with federal land management agency and USFWS requirements. These pre-construction 

surveys shall be conducted during the appropriate survey window, for a total of 3 years; where right of entry and landowner 

permissions are obtained."

Thi

TESPL-3 -- Qualified botanists shall conduct pre-construction surveys during a season when target species are readily 

identifiable for special status or globally rare species. Where feasible, micrositing of project facilities shall avoid direct impacts 

to identified populations. Survey reports documenting the surveys, their results, and recommendations must be provided to land management agency for approval prior to construction. Agency botanists may evaluate individual sites based on sitespecific conditions. Documentation of the evaluation of avoidance of impacts to sensitive and globally rare plants must be 

provided to the Agencies prior to construction. -- D -- The Proponents propose the following revision: "Qualified botanists shall conduct pre-construction surveys during a season when target species are readily identifiable for special status or globally rare species. Where feasible, micrositing (moving a structure in-line with the centerline or within the limits of standard engineering 

design as to not require additional tangent or angle structures) of project facilities shall avoid direct impacts to identified

populations. Survey reports documenting the surveys, their results, and recommendations shall be provided to land management agency prior to construction. Agency botanists may evaluate individual sites based on site-specific conditions 

within 20 days of receiving the report. Documentation of avoidance of impacts to sensitive and globally rare plants must be provided to the agencies prior to construction. Such plants may be impacted if the USFWS authorizes take in the BO."

Thi

TESPL-5 -- If a whitebark pine or limber pine (a similar species that can be difficult to distinguish from whitebark pine) stand 

cannot be avoided, off-site mitigation in the form of appropriate silvicultural treatments of adjacent stands, collection of seed, 

identification of “plus” trees or other acceptable mitigations will be done to offset the loss of the stand in addition to replanting whitebark pine on reclaimed areas. -- D -- The Proponents propose the following revision: "If a whitebark pine or limber pine (a 

similar species that can be difficult to distinguish from whitebark pine) stand cannot be avoided, off-site mitigation in the form 

of appropriate silvicultural treatments of adjacent stands, collection of seeds from agency identified "plus" trees, or other 

acceptable mitigations will be done to offset the loss of the stand."

ThiCodro
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

WEED-1 -- The Proponents shall consult with each appropriate local land management agency (Forest Service and BLM) 

office or landowner to determine appropriate seed mix and commercial seed source for revegetation. The Reclamation, Revegetation, and Weed Management Plan must specify the approved seed mixes for each area (also see VEG-1). -- D -- The Proponents propose the following revision: "The Proponents shall consult with each appropriate local land management agency (Forest Service and BLM) office or landowner to determine appropriate seed mix and commercial seed source for 

revegetation. The Reclamation, Revegetation, and Weed Management Plan shall specify the approved seed mixes for federal 

lands and be updated with seed mixes for use on private lands as they are identified through landowner negotiations and 

discussions (also see VEG-1)."

WEconoffiThe seenoxpha

WEED-3 -- Gravel and other materials used for road construction on federal lands shall come from certified weed-free sources. 

-- C -- The feasibility of acquiring all materials used in road construction as certified weed-free is not known. This will be implemented to the extent feasible and practicable.

No 

WEED-4 -- Annual post-construction monitoring and treatment of invasive plants shall continue for at least 3 years. If after 3 years postconstruction conditions are not equivalent or better than preconstruction conditions, monitoring and treatment will 

continue until these conditions are met (also see VEG-12). -- D -- The Proponents propose the following revision "Annual 

postconstruction monitoring and treatment of invasive plants shall continue for 3 years in areas where infestations or large population of noxious weeds have been identified. If after 3 years post-construction conditions are not equivalent or similar to 

pre-construction conditions (in accordance with applicable permit), monitoring and treatment will continue until these 

conditions are met (also see VEG-12). If adjacent land uses are contributing to the introduction and/or persistence of invasiveplant species within areas disturbed by the project, then Proponents will not be required to treat noxious weeds for more than 

three years."

The 

WEED-5 -- During operations, access roads and maintenance areas shall be surveyed annually between May 1 and September 30 (or as determined by Agency staff) for the presence of new weed introductions and existing invasive plant 

species. Coordinate with Agency specialists to identify the most appropriate time for survey. A weed control program would be implemented if new weeds were found, which would define how and when these invasive plants would be treated. Weeds shall 

be treated before their seed heads have become viable, or if heads will become viable, whole plant removal of all weeds shall 

occur before seed drop occurs. -- C -- WEED-4 with Proponents revisions satisfy this. Annual survey and weed control of 

access roads (which are utilized by other entities in addition to the Proponents) is something the Proponents are not willing to undertake as issues (weed infestations) could arise due to other entities actions. Cost is greater than benefit. This measure is 

open ended.

The 

WEED-6 -- Soil stockpiles in areas containing invasive plants shall be reseeded or revegetated as soon as feasible, or the soil

replaced in or near the original excavation. If requested by the applicable land-management agency, soil stockpiles shall be 

covered with plastic during the time prior to reseeding or replacement; however, plastic coverings will not be used on lands 

where the managing agency or landowner have requested that these piles not be covered with plastic (e.g., the Forest 

Service). -- D -- Because reseeding or covering soil stockpiles may not be practicable or appropriate in all cases, the Proponents propose the following revision: "Soil stockpiles in areas containing noxious weeds and invasive plant species shall be kept separate from soil removed from areas that are free of noxious weed and invasive plant species, and the soil will be 

replaced in or near the original excavation. If requested by the applicable land-management agency, soil stockpiles shall be 

covered with plastic if the soil stockpile will be in place for two weeks or more and is not being actively used. On lands managed by the Forest Service or per private landowner request, stockpiles will not be covered with plastic."

Thiinvnoxorigstomopriv

WET-1 -- Impacts on wetland and riparian areas shall be avoided unless physically or economically infeasible. Land 

management agencies’ plans (RMPs and Forest Plans) that have standards, guidelines, stipulations, or avoidance buffers will 

be adhered to. Where these do not exist, Inland Fish Strategy (INFISH) buffers for fish-bearing and nonfish-bearing waters and wetlands will be followed. -- C -- In order to fully assess this measure, the INFISH buffers must be provided to the Proponents. Proponents intend to have permanent access to every structure (Appendix B, page B- 22). This measure may conflict with this need and therefore would not be feasible.

Info

WET-4 -- To meet USACE requirements for CWA 404 permitting, the Proponents must submit a plan for mitigation and full 

compensation for all losses of waters of the United States. This plan must be approved by the USACE. The framework for this plan is included in the Draft EIS (see Appendix C-6) and must be fully detailed for the Final EIS. -- D -- The Proponents 

propose the following revision: "To meet USACE requirements for CWA 404 permitting, the Proponents will submit a mitigation plan that is accepted by the USACE. The framework for this plan is included in the Draft EIS (see Appendix C-6)."

WEProfor 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

WET-3 Where impacts on wetlands are not avoidable, site-specific crossing plans and measures to mitigate impacts shall be 

submitted to the appropriate regulatory agency, as well as the land managing agency. The Proponent shall apply directly to 

the appropriate permitting agency (USACE and/or State agency) for approval. -- D -- The Proponents propose the following 

revision: "Where impacts on wetlands are not avoidable, site-specific crossing plans and measures to mitigate impacts shall be submitted to the appropriate regulatory agency, as well as the land managing agency. The Proponent shall obtain all necessary permits prior to discharging dredged or fill material to waters of the U.S. and state."

WEplaageper

FISH-1 -- On BLM-managed land, all culverts, whether temporary or permanent, must be designed to meet BLM Manual 9113 

standards. Culverts should be located, designed, constructed, and maintained according to standards that preserve or improve 

streambed gradients and velocities to allow fish passage and that minimize erosion and sediment damage. On federal lands, unless the applicable management plan has specific requirements for stream crossings, use the following for culverts in channels with less than 3 percent slope: The minimum culvert width shall be equal to or greater than 1.5 times the active channel width. 

The culvert shall be placed level (zero percent slope). The bottom of the culvert shall be buried into the streambed at not less than 20 percent of the culvert height at the outlet, and 

not more than 40 percent of the culvert height at the inlet. Embedment does not apply to bottomless culverts. At sites where the channel slope is greater than 3 percent, additional consideration should be given to alternate design options such as bottomless arch culverts or fords (low-water crossings). This is because of the difficulty of providing for the passage of aquatic species through culverts installed at these sites. Also, the culvert would be installed so that its slope would match the average 

grade of the stream immediately up- and down-stream of the culvert site. Follow RMP guidelines where specific requirements 

are included. On NFS lands, Forest Plan standards and guidelines shall apply. – C -- In order for the Proponents to determine 

the feasibility of this measure, the Proponents request the BLM to provide a list of measures within manual 9113 that apply. In

the event that the measures within manual 9113 are identified in this measure, the measure should be revised to clearly state 

this.

FISperStaFor

FISH-2 -- All in-stream construction actions will be conducted when critical fish life stages can be avoided as designated by the 

appropriate state and federal agencies. All culverts placed in fish habitat will be suitable, as determined by the federal or state 

agency, for passage by all life stages present or potentially present within the stream reach. Riparian vegetation removal 

should be kept to the minimum along fish bearing streams. Blasting in or adjacent to fish-bearing streams will require the state 

fish agency approval prior to blasting. Channel morphology data (e.g., streambank composition, bank slope, stream substrate characteristics, stream slope, riparian vegetation characteristics) will be obtained anywhere a road will cross a stream prior to construction and be used to restore the site of the crossing to pre-Project conditions when temporary roads are decommissioned. -- C -- The DEIS should clearly identify in-stream construction periods by waterbody. How will the agencies 

determine “suitable”? Also, rationale as to why blasting adjacent to fishbearing streams is an impact should be included in the

EIS. Collecting morphology data for all road crossings is not warranted (i.e. for permanent crossings). The Proponents will not

collect morphology data as suggested in this measure.

Thi

FISH-3 -- When taking water from TES fish-bearing streams for road and facility construction and maintenance activities, 

intake hoses shall be screened with the most appropriate mesh size (generally 3/32 of an inch), or as determined through coordination with NMFS and/or USFWS. -- A – [blank]

Thi

FISH-4 -- If an aquatic invasive species is discovered during surveys for wetlands and waters of the U.S. conducted for USACE and 

state permitting prior to construction, the waterbody will be flagged and noted on the construction drawings. After work is complete in 

that waterbody, any equipment involved in construction in that waterbody must be washed to remove any propagules of aquatic invasive species and to prevent the spread of those species to other waterbodies in the Analysis Area. -- A – [blank]

Thi

WILD-1 -- Requests for exceptions from closure periods and areas must be submitted by the Proponents to the appropriate land management agency office in which the exception is requested. Established exception processes on federally-managed lands must be followed. The appropriate agency, or a contractor chosen by the Proponents and approved by the agency, shall 

conduct any surveys and coordinate with any other agencies as necessary. Factors considered in granting the exception 

include animal conditions, climate and weather conditions, habitat conditions and availability, spatial considerations (e.g., travel routes and landscape connectivity), breeding activity levels, incubation or nestling stage, and timing, intensity, and 

duration of the Proposed action. Requests must be submitted in writing no more than 2 weeks prior to the proposed 

commencement of the construction period, to ensure that conditions during construction are consistent with those evaluated. The authorized officer, on a case-by-case basis, may grant exceptions to seasonal stipulations, and has the authority to cancel

this exception at any time. -- D -- The Proponents shall submit a revised plan addressing Proponent proposed EPMs including 

exceptions and monitoring. A proposed rewrite of this measure will be included at that time.

The cha

WILD-12 -- Any areas that may require blasting will be identified and a blasting plan will be submitted to the appropriate agency for approval. Blasting within 0.25 mile of a known sensitive wildlife resource will require review and approval by the 

appropriate agency. -- C -- DEIS needs to clearly identify process, criteria for a decision, timeline.

Thi
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

WILD-5 -- Surveys will be conducted within 0.5 mile of the route prior to construction for caves, abandoned mines, and adits. If 

suitable bat roosts are identified, the Proponents will consult with the applicable land management agency to determine 

appropriate protective measures. -- C -- This is onerous and costly in comparison to the benefit. Also, the DEIS provides no 

justification for the 0.5 mile area. Please provide a discussion of potential impacts and literature citations that support this 

requirement.

Thi

WILD-4 -- On federal lands, accurate monitoring, including identifying nest occupancy, shall be conducted in order to ensure 

that raptor nests are located in advance of any construction activities. This would be needed to ensure that all construction 

activities would cease in areas near active nests. Biological monitor on site would perform these surveys ahead of construction. If an occupied nest is found, the appropriate restrictions and closures would be adhered to. All encounters of nesting raptors in the Analysis Area must be reported to the biological monitor and to appropriate agencies. -- D -- The 

Proponents propose the following revision: "Preconstruction nest surveys will be conducted in suitable habitat to identify raptor 

nest locations and status of previously identified raptor nests. Appropriate buffers will be applied to active nests during 

construction and the Proponent-proposed EPMs would be followed." On federal lands, pre-construction surveys would be conducted in suitable habitat to identify raptor nests. If an occupied nest

is found, the Company-proposed EPMs would be followed.

WIbe idenesencmo

WILD-6 -- As part of their annual aerial flight line maintenance activities, the Proponents will document perching and nesting activity (by species) on any towers constructed as a result of this Project. This would occur after the first year of construction 

until year 10 of operations. Results would be provided to the applicable landmanagement agency. -- C -- This is onerous and cost is not commensurate with any benefit. The reason for doing this is not clear in the DEIS.

Thi

WILD-7 -- On federal lands, guy wires should be marked with bird deterrent devices to avoid avian collisions with structures on

public lands (I.M. 2010-022). -- C -- IM 2010-022 addresses guy wires associated with fences and wind energy structures (MET towers and turbines). Implying that it applies to transmission towers is disingenuous. Moreover, the BLM has provided no evidence that guy wires associated with transmission towers present a significant risk to SAGR. Marking all guy wires is unlikely to be efficient and an unnecessary expense. We suggest that areas where species are present that may be impacted by the presence of guy wires should be prioritized. Where such species are not present marking of guy wires should not be required. The DEIS identifies some areas where marking of guy wires would be useful, such as 

river crossings. The BLM should carefully evaluate and determine which areas require marking of guy wires, rather than applying this requirement universally to all towers.

WIon ma

WILD-8 -- Flight diverters will be installed and maintained where the transmission line crosses rivers at the locations identified 

in Table 3.10-3. The flight diverters will be placed on at least one of the higher conductors or ground wires at each crossing in order to reduce avian collisions. Additional locations may be identified by the Agencies. -- D -- The Proponents propose the 

following revision: "Flight diverters will be installed and maintained where the transmission line crosses rivers at the locations 

identified in Table 3.10-3. The flight diverters will be placed on at least one of the higher static wires at each crossing in order 

to reduce avian collisions. Flight diverters will be installed on no more than one span either side of the span that crosses the 

river. Additional locations may be identified by the Proponents in accordance with their respective Avian Protection Plans and USFWS agreements."

WIwhAdwill conma

WILD-9 -- Pre-construction pedestrian or aerial surveys will be completed during the appropriate nesting time periods needed 

to identify each raptor species. The Proponent will provide survey results to the authorized officer for approval (see WILD-1). -- 

D -- This measure is similar to WILD-4 and could be combined with that measure, however, the Proponents propose the following revision: "Pre-construction pedestrian or aerial surveys will be completed during the appropriate nesting time periods 

needed to identify active raptor nests. The Proponent will provide survey results to the authorized officer."

No 

WILD-10 -- To the extent feasible, all vegetation clearing would be conducted prior to the onset of the avian breeding season (generally April 15 through July 31, depending on local conditions and federal land management plan requirements), in order to limit the potential impact of clearing on nesting birds. In addition, pre-construction surveys within the disturbed portion of the 

ROW and extending a minimum of 30 feet on either side of the ROW shall be conducted. If an active nest is found during preconstruction surveys, the nest will be identified to species, flagged and avoided until any young have fledged. Avoidance 

distances are species-specific and must be approved by a USFWS-approved biologist. -- D -- This measure significantly 

lessens the feasibility of constructing the Project given the temporal and spatial restrictions. The Proponents conduct annual 

MBTA internal training addressing concerns raised in this measure and in order to ensure compliance with MBTA. The Idaho State BLM has recently found this training (Idaho Power training) acceptable as providing a mechanism for compliance with 

MBTA. Also, the BLM must provide avoidance distances in the DEIS in order for the Proponents to evaluate and comment on 

them. The Proponents propose the following revision: "The Proponents shall ensure that all field personnel receive MBTA training including training regarding nesting habitats (i.e. identifying cavities that may support nesting birds) which will describe 

requirements such as halting activities adjacent to nesting birds and mark/flag the area until the young have fledged."

WIreq
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

WILD-11 -- Snags shall be maintained to the extent practical along the outer portions of the Project’s ROW in order to reduce 

the impacts to habitat for cavity nesters. -- D -- The Proponents propose the following revision: "Snags shall be maintained to

the extent practical and where it does not conflict with the Proponents vegetation management specifications along the outer 

portions of the Project’s ROW in order to reduce the impacts to habitat for cavity nesters."

WInot por

TESWL-1 -- For the protection of aquatic and riparian/wetland dependent species, surface disturbing and disruptive activities 

should be avoided in the following areas: 1) identified 100-year floodplains; 2) areas within 500 feet of perennial waters, 

springs, wells, and wetlands; and 3) areas within 100 feet of the inner gorge of ephemeral channels on federally managed 

lands. Where it is not possible to avoid wetland and riparian habitat, crossing-specific plans must be developed. These plans shall: 1) demonstrate that vegetation removal is minimized; 2) show how sediment would be controlled during construction and 

operation within wetland and riparian areas; 3) attempt to intersect the wetland or riparian habitat at its edge; and 4) provide measures to restore habitat and ensure conservation of riparian microclimates. This plan must be submitted to the appropriate land management agency and approved prior to construction of any portion of the Project within sensitive riparian habitat. -- C-- In order to fully assess this measure, citations for the 500 foot and 100 foot "buffers" need to be provided and justified. In 

order to maximize tower distance from such areas, the conductor sag will be greatest and thereby require more intensive vegetation clearing than otherwise in order to maintain clearances. The Companies have avoided to the extent practicable 

impacts to aquatic and riparian/wetland dependent species. Please see the response regarding indicative and engineering 

design for more details. The information required to comply with 1-4 will be provided in the POD; application(s) to the U.S. Army Corps of Engineers, 

and/or construction storm water plans. It is not clear how a Proponent can preserve microclimate.

The info

TESWL-2 -- The Proponents shall work with the applicable land-management agencies to develop a survey protocol that 

would be conducted in conjunction with annual operations and maintenance surveys (as outlined in the Proponent’s Avian 

Protection Plans). The goal of these raptor-raven surveys shall be to identify whether populations of raptors and ravens are consolidating along the Project, and will be done during the appropriate time of year. These surveys shall be conducted, at a minimum, along portions of the line that are located within 1 mile of identified concentrations of sensitive raptor and raven prey 

species (including the black-footed ferret, mountain plover, burrowing owl, grouse species, as well as white- and black-tailed prairie dogs). The Proponents and applicable land-management agencies shall work together to identify measures to limit 

predation rates on sensitive species within areas where raptor and raven populations are considered to be consolidating 

(limited to areas near sensitive species). -- C -- Considering prudent use of rate payers money, this is an onerous and 

unwarranted measure. This would require the Proponents to hire a consultant to conduct annual surveys for hundreds of miles 

of transmission line. The perceived benefit does not clearly outweigh the cost of implementing such a measure. There appears 

to be a fundamental misunderstanding of the Proponents' APPs as annual surveys of lines are not conducted for this purpose. 

The transmission line would not be surveyed annually under the provisions of the APPs; such surveys are beyond the scope of 

an APP (refer to the APP Guidelines). Regarding sagegrouse predation, there are no scientific correlations to tall structures 

which justify the use of anti-perching devices (see the UWIN literature review regarding tall structures and sagegrouse).

Info

TESWL-3 -- H-frame structures shall be equipped with anti-perch devices to reduce raven and raptor use, and limit predation 

opportunities on special status prey species. -- C -- Considering prudent use of rate payers money, this is an onerous and 

unwarranted measure. H-frame in comparison to lattice structures inherently reduce and minimize raptor perching and nesting 

opportunities. Rocky Mountain Power currently has agreements with the FWS (Office of Law Enforcement) to not use antiperch devices as they have been shown to be ineffective and increase potential for electrocution and nesting. This 

requirement conflicts with the working agreements with the FWS. Also, anti-perching devices when used at high voltages 

specifically pose maintenance and safety risks as they would require to be maintained "hot". Regarding sage-grouse 

predation, there are no scientific correlations to tall structures which justify the use of anti-perching devices (see the UWIN

literature review regarding tall structures and sage-grouse).

Thi

TESWL-4 -- In the event that an ESA listed species is discovered during surveys, construction would cease, the USFWS 

would be notified, and Section 7 consultation would be initiated. In addition, the transmission line or structures would be relocated to minimize direct impacts to newly discovered ESA species, to the extent practical. -- C -- Since the BLM is already

doing section 7 consultation it is not clear what this measure is trying to accomplish. Is this measure intended to address 

previously unknown species? Moreover, if the BO provides for take, this measure may not be consistent with what is in the 

BO. This should be worked out with FWS now. There should be an agreement and procedures in place.

Thicov
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

TESWL-5 -- Pre-construction surveys must be conducted for the black-tailed prairie dog (in addition to those already proposed 

for the whitetailed prairie dog and the black-footed ferret) in Segments 1E and 1W. If prairie dogs or their habitat are documented, then surveys for black-footed ferrets must occur. If black-footed ferrets are found, construction in that area must

halt and consultation with the USFWS be initiated. If black-tailed prairie dogs are discovered during construction, all 

construction activities must cease and a survey for the blackfooted ferret shall be conducted. If black-footed ferrets are found, 

construction in that area must halt and consultation with the USFWS would be re-initiated. – C -- Since the BLM is already doing section 7 consultation it is not clear what this measure is trying to accomplish. Is this measure intended to address 

previously unknown species? Moreover, if the BO provides for take, this measure may not be consistent with what is in the 

BO. This should be worked out with FWS now. There should be an agreement and procedures in place.

TE

for pra

TESWL-6 -- Requests for exceptions from bald eagle closure periods and areas must be submitted by the Proponents to the 

appropriate land-management agency office in which the exception is requested. Established exception processes on federally 

managed lands must be followed (see WILD-1). – D -- The Proponents shall submit a revised plan addressing Proponent 

proposed EPMs including exceptions and monitoring. A proposed rewrite of this measure will be included at that time.

No

TESWL-20 -- Requests for exceptions from ferruginous hawk closure periods and areas must be submitted by the Proponents 

to the appropriate land-management agency office in which the exception is requested. Established exception processes on 

federally managed lands must be followed (see WILD-1). – D -- The Proponents shall submit a revised plan addressing Proponent proposed EPMs including exceptions and monitoring. A proposed rewrite of this measure will be included at that time.

No

TESWL-21 -- Requests for exceptions from northern goshawk closure periods and areas must be submitted by the Proponents 

to the appropriate land-management agency office in which the exception is requested. Established exception processes on 

federally managed lands must be followed (see WILD-1). – D -- The Proponents shall submit a revised plan addressing Proponent proposed EPMs including exceptions and monitoring. A proposed rewrite of this measure will be included at that time.

No

TESWL-7 -- Requests for exceptions from burrowing owl closure periods and areas must be submitted by the Proponents to 

the appropriate land-management agency office in which the exception is requested. Established exception processes on federally managed lands must be followed (see WILD-1). -- D -- The Proponents shall submit a revised plan addressing Proponent proposed EPMs including exceptions and monitoring. A proposed rewrite of this measure will be included at that 

time.

No

TESWL-8 -- A wildlife biologist will accompany site engineers during the final engineering design, in order to verify and flag the location of any known occupied structures (e.g., nests, burrows, colonies) utilized by sensitive species. This will include, but 

not be limited to, known burrowing owl burrows (including artificial burrows that have been constructed as part of research/restoration efforts), prairie dog colonies, and raptor nests, which could be impacted by the Project based on the indicative engineering design. The final engineering design will be routed to avoid direct impact to these occupied structures to 

the extent practical. -- C -- This is onerous. Pre-construction surveys will be conducted by a qualified wildlife biologist, areas 

will be avoided during design phase and monitoring of resources will be conducted during construction.

TEInsCogrostrubut resimpdes

the 

TESWL-9 -- Requests for exceptions from Columbia sharp-tailed grouse closure periods and areas must be submitted by the 

Proponents to the appropriate land-management agency office in which the exception is requested. Established exception 

processes on federally managed lands must be followed (see WILD-1). -- D -- The Proponents shall submit a revised plan 

addressing Proponent proposed EPMs including exceptions and monitoring. A proposed rewrite of this measure will be 

included at that time.

Ad

TESWL-11 -- In areas where sharp-tailed grouse leks occur in proximity to greater sage-grouse leks, surface disturbance shall 

be avoided within 4 miles of occupied or undetermined greater sage-grouse leks from March 1 to July 15. In areas where sharp-tailed grouse leks occur in isolation from greater sage-grouse leks, surface disturbance shall be avoided within 1.2 miles of occupied or undetermined sharp-tailed grouse leks from March 15 to July 15. -- C -- The BLM should clarify “proximity” and provide rationale for 1.2 miles and 4 miles. This measure in inconsistent with resource management plans that allow for construction to take place (within distances proposed in this measure) with the exception of early morning and early evening 

hours; typically allow construction to take place from 9am to 4pm.

BL201

TESWL-12 -- Requests for exceptions from mountain plover closure periods and areas must be submitted by the Proponents 

to the appropriate land management agency office in which the exception is requested. Established exception processes on 

federally-managed lands must be followed (See WILD-1). – D -- The Proponents shall submit a revised plan addressing Proponent proposed EPMs including exceptions and monitoring. A proposed rewrite of this measure will be included at that time.

The 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

TESWL-13 -- A pre-construction survey for the yellow-billed cuckoo must be conducted at any proposed crossing of suitable 

habitat. If these birds are detected within 1 mile of the centerline (within existing habitat), construction must not occur until the young have fledged or the nest is abandoned. The crossing-specific plan must contain proposed monitoring measures to assure compliance with this measure. – C -- According to the DEIS, there is less than 0.1 mile of suitable yellow-billed cuckoohabitat within the entire Project (p. 3.11- 34). The proposed mitigation measures and requirements are ludicrous for the level of 

potential impact for the species. The yellow-billed cuckoo’s tendency to collide with transmission structures is uncertain. 

However, it is likely limited due to their preference for dense riparian habitats, which indicates that they are adapted to negotiating around obstacles while in flight, and would not typically fly into open areas where conductors or transmission 

towers would be located.

Thirev

TESWL-18 -- Pre-construction surveys for occupied or potential midget faded rattlesnake hibernacula (i.e., rock outcrops with south to east aspect) will be conducted. – C -- This measure is vague and requires clarification as to why surveys would be conducted. Additional description in the DEIS is needed regarding range of the species. The BLM should provide protocol for 

identifying hibernacula.

Thirev

TESWL-14 -- Surface disturbance shall be avoided within 0.6 to 4 miles of occupied or undetermined greater sage-grouse leks from March 15 to July 15 in all portions of the Project except for Nevada. In Nevada, surface disturbance shall be avoided within view of or within 0.3 mile of all leks from March 1 to May 15; and within areas designated by Nevada as greater sagegrouse brood rearing areas from May 15 to August 15.. C The Proponents do not need to be consistent with the Wyoming EO 

in Idaho. It is not possible to construct the project the project with such restrictions. Also, the Proponents must consider not 

applying/following distance stipulation on non-federal lands in order to construct the project when factoring in all of the 

restrictions.

TEbe perCoIM her

Othappaffe

TESWL-15 There shall be no surface occupancy (NSO) within 0.6 mile of the perimeter of occupied greater sage-grouse leks. 

“No surface occupancy,” as used here, means no surface facilities, including roads, shall be placed within the NSO area. 

Other activities may be authorized with the application of appropriate seasonal stipulations, provided the resource’s protected

area is not adversely affected. C This measure is not possible to comply with. See text on p. 3.11-64. “However, not all leks could be avoided by this distance (see Table 3.11-4) due to the need to avoid other sensitive resources (e.g., high-altitude 

mountain habitats that contain species listed under the ESA, or sensitive cultural resources that are protected by the various 

SHPOs).”

TEdisgrocasProfrom tran

TESWL-16 Requests for exceptions from greater sage-grouse closure periods and areas must be submitted by the 

Proponents to the appropriate land management agency office in which the exception is requested. Established exception 

processes on federally-managed lands must be followed (See WILD-1). D The Proponents shall submit a revised plan 

addressing Proponent proposed EPMs including exceptions and monitoring. A proposed rewrite of this measure will be 

included at that time.

The info

TESWL-19 There shall be no surface disturbances within areas designated as Winter Concentration Areas for the greater sage-grouse from November 1 through March 15. C The DEIS should clearly identify known winter concentration areas in order to assess this measure. Currently known concentration areas could only be considered and additional survey should not 

be required of the Proponents.

Win

(noArewit

TESWL-22 No structures that require guy wires would be used in occupied sagebrush obligate habitats within the area managed under the Kemmerer RMP. C This measure eliminates the use of several optional structure types (guyed vee, tubular h-frame other than at tangent structures, etc.). There may be distribution lines that use guys, (i.e. a distribution line that 

goes to a regeneration site).

Thibee

TESWL-23 If the Kemmerer RMP is amended to allow Alternatives 4A, 4C, 4E, or 4F to be selected, existing fences within 1 mile of the portion of the Gateway West Project located on lands managed by the Kemmerer RMP shall be modified with FireFly Grouse Flight diverters (or a similar product) in order to prevent greater sage-grouse mortalities. Additional site-specific 

reclamation, such as transplanting sagebrush seedlings within previous disturbed habitats, may also be required to off-set the net loss of sagebrush habitats within the Rock Creek/Tunp management area. C Appropriate mitigations for impacts to sagegrouse will be implemented an identified through negotiations during the NEPA process.

Thi
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

MN-1 -- A geotechnical investigation will be conducted by the Proponents in areas where abandoned underground mines are known to occur to determine the presence of methane and the likelihood of subsidence. -- C -- The recommendation from 

engineering is that a field investigation should not be done. Finding anomalies that result in methane or subsidence is like trying to find a needle in a haystack. Trying to find these by punching holes with an eight inch auger is not recommended. 

Engineering recommends that the geotechnical investigation be a desktop survey to identify and document the areas where abandon mines exist.It would ultimately be up to the EPC contractor to mediate these conditions if they are discovered during 

construction. This desk top survey would help identify those areas that the contractor may want to do additional analysis as part of final design and construction.

Thi

MN-2 -- An accounting of damages will be conducted by the Proponents to current operators to determine the potential loss of mineral resources. There may be mining claims under the 1872 Mining Law that would have precedence over the Project. 

Similarly, federal and state mineral lease agreements provide rights to lessees that could interfere with the Gateway West 

Project. The Proponents will resolve mineral claim and lease agreements prior to Project initiation, as with site access agreements on private property. -- C -- Stipulation or requirement: does not seem to be a mitigation measure; covered in easement agreements (we relocate at our own expense or purchase the right). This is not a mitigation measure as RMP does 

identify mining activity and rights during the title search done prior to ROW acquisition. RMP investigates each one and 

resolves any concerns at that time. This process includes analysis of risk, and potentially, condemnation if resolution is not possible.

Thi

PALEO-1 -- The Proponents shall prepare a Paleontological Monitoring Plan for the Project, focusing on Segments 4, 7, 8, and 9 where the potential for adverse impacts is the greatest. This plan shall be submitted to appropriate agencies for review and approval prior to commencing construction. The plan should specify that: Monitoring of excavation and grading in sensitive sediments, especially access roads and tower sites, must occur when construction is near or in those geologic formations. Monitoring of excavations in sensitive sediments, screening the excavated spoils, and processing of bulk sediment samples for microvertebrate fossils must occur where there is a significant potential for data recovery from those spoils. 

Monitoring must be performed by a qualified paleontologist and in consultation with a designated paleontologist in each state, NF, or 

BLM district. The Authorized Officer will designate the appropriate paleontologist depending on project location. -- D -- The phrase "Significant Potential" should be defined. The Proponents propose the following revision: "The Proponents shall prepare a Paleontological Monitoring Plan (Discovery Plan) for the Project, for areas within Segments 4, 7, 8, and 9 where the potential for 

adverse impacts is the greatest (based on the known current potential fossil yield classification [class 3, 4, or 5] for formations within 

these segments). This plan shall be submitted to appropriate agencies for review and approval prior to commencing construction.The plan shall include discussion regarding implementation of monitoring (visual monitoring and inspection) at site specific locations in sensitive geologic formations with known high potential to contain significant paleontological resources (rare fossils)."

ThiPufedexpuse reg

PALEO-3 -- Areas with Fossil Potential Classification sensitivity rankings of 3, 4, or 5 on NFS lands will be surveyed and posted. – C -- Clarification on NFS lands is needed as well. Similar to BLM lands, only PFYC 3, 4, or 5 shall be surveyed. See proposed revisions for PALEO-1.

Thi

PALEO-2 -- Where fossil-bearing sediments are exposed by construction, the sediments must be covered with a 4-inch layer 

of soil where feasible to reduce unauthorized removal or disturbance of resources. -- B – [blank]

Thi

GEO-1 -- A site-specific landslide mitigation plan that addresses measures to be taken in the design, construction, and operation to minimize failure due to landslides must be prepared and submitted by the Proponents with the construction POD prior to issuance of a ROW grant on federally managed lands. -- D -- Contractor will likely conduct additional geotechnical 

investigations. Specific engineering mitigation plans will likely not be developed prior to the issuance of the ROW grant. As 

written, if this measure is not completed, no ROW grant will be issued. The geotechnical contractor is locating the areas where

there is landslide risk in their evaluation. In areas where they are located, mitigation will be done. Rewrite stating that this would be accomplished but not prior to ROW grant issuance. Proponents propose the following revision: "A site-specific 

landslide mitigation plan that addresses measures to be taken in the design, construction, and operation to minimize failure 

due to landslides must be prepared and submitted by the Proponents as the information becomes available during design and construction on federally managed lands.

Thi

GEO-3 -- On-site slope stability examinations will be performed on NFS lands for slopes over 40 percent prior to designing project features that require the removal of forest. -- C -- The geotechnical contractor is locating the areas where there is landslide risk in their evaluation. In areas where they are located, mitigation will be done.

Thi
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

GEO-4 -- A site-specific soil analysis shall be conducted prior to construction to verify any areas identified as unstable or marginally unstable in the Caribou National Forest Soil Resource Inventory. -- C -- The geotechnical contractor is locating the

areas where there is landslide risk in their evaluation. In areas where they are located, mitigation will be done.

Thibe unsfedareapp

GEO-2 -- Review the final location of the preferred alternative with affected mine operators and lessees to ensure all measuresare taken to protect against subsidence. -- A – [blank]

No

SOIL-1 -- Efforts will be made to preserve topsoil and minimize mixing with subsoil. In agricultural areas, the landowner or land 

management agency will be asked to provide input on placement of removed topsoil. The Wyoming State Reclamation Policy 

and applicable Agency management plan requirements for soil management will be followed. Soil disturbances in agricultural areas will be developed to minimize impacts to existing agricultural activities where possible. Unless the landowner or land 

management agency specifically approves otherwise, the Proponents will prevent the mixing of topsoil with subsoil by stripping topsoil from the portion of the construction work area that will be restored (construction pad, storage yards, and fly yards) in actively cultivated or rotated croplands and pastures and other areas at the landowner's or land-managing agency’s request. Where topsoil segregation is required, the Proponents will maintain separation of salvaged topsoil and subsoil throughout all 

construction activities. Immediately after construction, topsoil will be restored to the areas not dedicated to operational 

requirements and revegetated as specified in the EPMs. -- C -- The content of this measure is contained within other 

measures and Proponent proposed measures. Content of this measure would be addressed with private landowners during 

negotiations with private landowners.

Thiand foll

SOIL-5 -- Disturbed soil will not be allowed to support the growth of noxious weeds, or invasive weedy species. Prevention of noxious weeds will apply to all phases of the Project. -- C -- Other WEED measures satisfy the intent of this.

Thi

SOIL-7 -- The Proponents are responsible for monitoring to ensure soil protection is achieved, and providing monitoring reports on reseeding success or other methods to stabilize soils to the Forest Service by the end of each growing season for 

areas on NFS lands. -- C -- This measure is unclear as to what is being required regarding monitoring "soil protection".

Thi

SOIL-8 -- Reclamation of all temporary disturbances on NFS lands (such as road cuts) should include replacement of material to original contours. Re-compaction to pre-existing compaction percentage (which should be identified before disturbance) should be 

included in the plan. Guidelines for streambank re-compaction to maximize vegetative regrowth and mechanical stability are covered 

in USACE publication ERDC TN-EMRRP-SR-26 (Goldsmith et al. 2001). -- D -- The Proponents propose the following revision: "Reclamation of all temporary disturbances on NFS lands (such as road cuts) should include replacement of material to original 

contours and re-compaction to pre-disturbance compaction percentage (which shall be identified during reclamation at adjacent 

locations to the disturbance). Guidelines for streambank re-compaction to maximize vegetative regrowth and mechanical stability are 

covered in USACE publication ERDC TN-EMRRP-SR-26 (Goldsmith et al. 2001)."

Thi

SOIL-9 -- On federal land, follow land management plan requirements on the location of waste material (silt, sand, gravel, soil, 

slash, debris, chemical, etc.) -- C -- This measure appears to be incomplete and requires clarification and additional 

information. The location of waste materials is identified in various plans, such as the SPCC, SWPPP, Construction POD, etc.

Thi

SOIL-10 -- On NFS lands, soil resources will be inventoried to National Cooperative Soil Survey Standards, and volumes and suitability of soil resources for reclamation will be determined prior to disturbance. -- C -- This is beyond standard practices. Benefit does not outweigh cost. The reclamation contractor shall assess conditions and develop appropriate prescriptions. 

ThiNF

top

SOIL-11 -- In specific sensitive areas (such as erosive soils, steep slopes) on lands managed by the Kemmerer FO, the access road used for construction will be restored and an alternative access route for operations designated. -- C -- Implementation of this measure would result in new and currently unknown impacts that would need to be assessed through 

the current NEPA process.

Thi

SOIL-4 -- Reclamation will include revegetation unless pre-existing conditions were not vegetated (rocky areas, agricultural 

fields). On public land the appropriate agency will provide input on the extent of reclamation, the type of vegetation to be 

planted, and the monitoring necessary to ensure reclamation success. -- C -- This measure is addressed in other measures 

(for example VEG-12). Also, the BLM will have input through approving the final seed mix to be used on BLM lands and the 

final reclamation plan.

Thi
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

SOIL-6 -- Detrimental soil disturbance such as compaction, erosion, puddling, and displacement will be limited or mitigated to meet long-term soil productivity goals on NFS lands. Treatment should include road ripping, frequent waterbars, cross-ditching 

(e.g., rolling-dips) or other methods to reduce compaction while preventing gully formation. Ripping pattern should be altered to a crossing, diagonal, or undulating pattern of tine paths to avoid concentrated runoff patterns that can lead to gullies. -- D -- 

Preconstruction conditions may not be able to meet long-term soil goals. The Proponents will reclaim to pre-disturbance conditions to the extent feasible. As such, the Proponents propose the following revision: "Detrimental soil disturbance such as 

compaction, erosion, puddling, and displacement will be minimized through implementing measures identified in the SWPPP. 

Measures may include road ripping, frequent waterbars, cross-ditching (e.g., rolling-dips) or other methods to reduce compaction while preventing gully formation. Ripping pattern should be altered to a crossing, diagonal, or undulating pattern of 

tine paths to avoid concentrated runoff patterns that can lead to gullies."

Thi

WQA-1 -- Avoid placement of road bed material in channels (perennial, intermittent or ephemeral). Road bed material contains 

considerable fines that would create sedimentation in coarse cobble dominated stream channels. Even in seasonally dry reaches those fines could be transported during flow periods and negatively impact fish spawning reaches below. -- A -- This is an accepted measure to be implemented during design and spotting of access roads, however, there will be crossings as 

total avoidance is not feasible.

As 

WQA-5 -- On non-federal lands, culvert placement should comply with state BMPs. The minimum size culvert will be 12 inches in diameter. If a channel width exceeds 3 feet, additional pipes may be used until the cross sectional area of the pipes is 

greater than 60 percent of the cross sectional area of the existing channel. Filter cloth should be placed on the streambed and

banks prior to placement of the pipe, and the culvert should be covered with a minimum of 1 foot of aggregate. -- D -- The 

BMPs should be listed/provided so that Proponent has an understanding of them. The Proponents propose the following 

revision: "On non-federal lands, culvert placement should comply with state BMPs."

Ch

WQA-3 -- All culverts on NFS lands, both permanent and temporary, shall be designed and installed to meet desired conditions for riparian and aquatic species as identified in the applicable Forest Plan. Culverts should not be hydraulically 

controlled. Hydraulically controlled culverts create passage problems for aquatic organisms. Culvert slope should not exceed stream gradient and should be designed and implemented (typically by partial burial in the streambed) to maintain streambed material in the culvert -- C -- There are other measures for culverts that cover this.

No

WQA-4 -- Culvert sizing on NFS lands should also comply with Guidance for Aquatic Species Passage Design, Forest Service 

Northern Region & Intermountain Region (Forest Service 2003f), and culvert sizing on BLM-administered land shall comply with BLM Manual 9113. -- C -- There are other measures for culverts that cover this.

ThishoNo

LU-1 -- To assist agency and county law enforcement in minimizing unauthorized OHV use on public and private lands, 

monitor OHV use and post signs along access roads where OHV activity has increased in areas on public lands where OHVs are regulated by a land use plan, and on private, state, and Tribal lands at the request of the landowner, agency, or Tribal 

government. Signs shall indicate the restriction or regulation, location, penalty for violation, and appropriate contact information 

for reporting violations. Signage shall be maintained and replaced as part of the routine maintenance. Consult with appropriateAgencies on additional measures to block unauthorized OHV use. – D -- The Proponents propose the following revision: 

"Signs shall be posted at access points to service roads where public access is restricted by a land use plan, and on private, 

state, and Tribal lands at the request of the landowner, agency, or Tribal government. Signs shall indicate the restriction or 

regulation, location, penalty for violation, and appropriate contact information for reporting violations. Signage shall be 

maintained and replaced as part of the routine maintenance. "

LUaccreqresfor ma
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

LU-2 -- Coordinate with the Foxley Airstrip owner to realign the location of Alternative 1E-C to eliminate the impact to the airstrip or in 

compensate for any loss of use. -- C -- LU-2 through LU-10: The Companies are doing all of this as part of the NEPA process and ob

Issues will be resolved with landowners during negotiations. It is not clear as to why these specific landowner issues have been eleva

other landowner issues and identified within the DEIS. These are not MMs that should be in the FEIS as these will be addressed dur

landowner discussions. the Proponents propose the following revision by replacing these measures with one: "The Proponents shall 

landowners to minimize impact and address substantiated concerns." LU-3 -- Work with the private landowner of the ice cave along Alternative 1E-C and microsite the facilities during final design to reduc

- LU-2 through LU-10: The Companies are doing all of this as part of the NEPA process and obtaining ROW. Issues will be resolved 

landowners during negotiations. It is not clear as to why these specific landowner issues have been elevated above all other landown

identified within the DEIS. These are not MMs that should be in the FEIS as these will be addressed during routing and landowner diProponents propose the following revision by replacing these measures with one: "The Proponents shall work with landowners to min

and address substantiated concerns." LU-4 -- Coordinate with the Chokecherry-Sierra Madre Wind Farm and TransWest Express Project developers and BLM along the SProposed Route to ensure mutually compatible siting of transmission lines and wind energy facilities. -- C -- LU-2 through LU-10: The are doing all of this as part of the NEPA process and obtaining ROW. Issues will be resolved with landowners during negotiations. It 

to why these specific landowner issues have been elevated above all other landowner issues and identified within the DEIS. These a

that should be in the FEIS as these will be addressed during routing and landowner discussions. the Proponents propose the followinreplacing these measures with one: "The Proponents shall work with landowners to minimize impact and address substantiated conc

LU-5 -- Work with the owners of potentially affected industrial buildings and microsite the transmission line during final design to avoi

these structures. -- C -- LU-2 through LU-10: The Companies are doing all of this as part of the NEPA process and obtaining ROW. I

resolved with landowners during negotiations. It is not clear as to why these specific landowner issues have been elevated above all landowner issues and identified within the DEIS. These are not MMs that should be in the FEIS as these will be addressed during ro

landowner discussions. the Proponents propose the following revision by replacing these measures with one: "The Proponents shall landowners to minimize impact and address substantiated concerns." LU-6 -- Review the final location of the Segment 3 Proposed Route with any affected oil/gas well operators to ensure measures are t

against any impacts to wells. This measure also applies to any segment where the Proposed Route would be near oil/gas wells. -- C 

LU-10: The Companies are doing all of this as part of the NEPA process and obtaining ROW. Issues will be resolved with landowner

negotiations. It is not clear as to why these specific landowner issues have been elevated above all other landowner issues and idenDEIS. These are not MMs that should be in the FEIS as these will be addressed during routing and landowner discussions. the Prop

the following revision by replacing these measures with one: "The Proponents shall work with landowners to minimize impact and ad

substantiated concerns." LU-7 -- Once the final locations of towers where crossings of the MTR would occur are known, IDANG should be consulted to ensure information is made available for proper warnings. -- C -- LU-2 through LU-10: The Companies are doing all of this as part of the NEPobtaining ROW. Issues will be resolved with landowners during negotiations. It is not clear as to why these specific landowner issues elevated above all other landowner issues and identified within the DEIS. These are not MMs that should be in the FEIS as these wilduring routing and landowner discussions. the Proponents propose the following revision by replacing these measures with one: "Thshall work with landowners to minimize impact and address substantiated concerns." LU-8 -- Coordinate with the owner of the planned Dry Creek Sky Ranches airstrip to realign the Segment 7 Proposed Route or airstri

way compensate for loss of use. -- C -- LU-2 through LU-10: The Companies are doing all of this as part of the NEPA process and obIssues will be resolved with landowners during negotiations. It is not clear as to why these specific landowner issues have been eleva

other landowner issues and identified within the DEIS. These are not MMs that should be in the FEIS as these will be addressed durlandowner discussions. the Proponents propose the following revision by replacing these measures with one: "The Proponents shall landowners to minimize impact and address substantiated concerns." LU-9 -- Alternative 8C along Segment 8 should be realigned in the vicinity of the Mayfield Springs subdivision during final design to re

on the planned Mayfield Springs community. -- C -- LU-2 through LU-10: The Companies are doing all of this as part of the NEPA proobtaining ROW. Issues will be resolved with landowners during negotiations. It is not clear as to why these specific landowner issues 

elevated above all other landowner issues and identified within the DEIS. These are not MMs that should be in the FEIS as these wilduring routing and landowner discussions. the Proponents propose the following revision by replacing these measures with one: "Thshall work with landowners to minimize impact and address substantiated concerns." LU-10 -- Consult with the IDANG to determine if the Segment 8 Proposed Route can be sited in such a way as to not compromise thmission in the Alpha Maneuver Sector of the Orchard Training Area, thereby avoiding relocation of the existing transmission line if po

LU-2 through LU-10: The Companies are doing all of this as part of the NEPA process and obtaining ROW. Issues will be resolved wduring negotiations. It is not clear as to why these specific landowner issues have been elevated above all other landowner issues anwithin the DEIS. These are not MMs that should be in the FEIS as these will be addressed during routing and landowner discussions

Proponents propose the following revision by replacing these measures with one: "The Proponents shall work with landowners to min

and address substantiated concerns."
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

LU-11 -- Consult with the BLM to determine how best to construct and maintain the Proposed Route transmission line through the area closed to motorized vehicles along the Snake River to ensure no impacts to existing natural, cultural, and historic resources. -- C -- This is not a mitigation measure as it is conducted during the NEPA process.

Thi

AGRI-1 -- Provide for a qualified Agricultural Specialist to assist construction planning, construction, restoration, postconstruction monitoring, and follow-up restoration. -- C -- Measures would be identified and agreed to during landowner 

negotiations. Depending upon landowner circumstances and individual property characteristics, all of these measures would 

not be applied. We should not dictate in the DEIS or through such default measures how the Companies shall interact with all 

landowners as some measures will not apply or be desirable in all situation. The landowners will know what they want to take 

place and how they want it to take place on their lands. Landowners may take offense that the BLM appears to be making decisions for them on their lands. AGRI-2 Maintain an active program of liaison with landowners and tenants, including specific points of contact whose responsibilities shall include pre-construction inventory, notices, complaint resolution, damage assessment, and negotiation 

and compensation. -- A – [See AGRI-1] AGRI-3 -- Establish procedures for determining ingress and egress routes with landowners and tenants, protection methods for off-ROW roads over agricultural lands and on ROW pads, including methods such as geotextile matting to segregate temporary rock fill. -- C -- [See AGRI-1] AGRI-4 -- Establish the location of temporary roads to be used for construction purposes through negotiation with the landowner, with existing farm lanes or two tracks as preferred temporary access roads, restoring temporary access roads to 

preconstruction condition and leaving temporary access roads intact through mutual agreement with the landowner and tenant unless located in flood areas or drainage hazard areas, or otherwise restricted by federal, state, or local regulations. -- C -- [See AGRI-1] AGRI-5 -- Maintain landowner and tenant access across construction areas for farm equipment and livestock to fields isolated by construction activities and install temporary fences and gates across the construction area, as necessary, to facilitate 

agricultural operations. -- C -- [See AGRI-1] AGRI-6 -- Protect topsoil by stripping and segregating topsoil in the disturbance area on agricultural lands unless negotiated 

differently with the landowner or tenant. They shall prevent segregated topsoil from being mixed with cut-and-fill materials, 

rock, construction debris, excavated materials, or other subsoil. -- C -- [See AGRI-1] AGRI-7 -- Restrict the operation of vehicles and heavy equipment, or take other appropriate action, so that deep rutting does 

not result in mixing of topsoil and subsoil on excessively wet soils on the portion of the construction work area in agricultural 

land where the topsoil is not stripped. – C -- [See AGRI-1] AGRI-8 -- Protect irrigation operations and drain tiles by 1) contacting landowners and tenants to identify the location of irrigation systems and wells, identified underground irrigation water pipes, well systems, and drain tiles that intersect the construction area; 2) repairing disrupted irrigation and drain tile systems as soon as possible; 3) maintaining the flow of 

irrigation water during construction or coordinating a temporary shut-off with affected parties; and 4) compensating affected parties for crop losses that result from irrigation and drain tile system interruptions due to construction. -- C -- [See AGRI-1] 

AGRI-9 Protect agricultural lands from dewatering activities by pumping into a constructed energy-dissipating structure that 

shall minimize damage to adjacent agricultural land, drainage systems, and crops. -- C -- [See AGRI-1] AGRI-10 -- Restore the land to the pre-construction condition or provide compensation. -- C -- [See AGRI-1] 

AGRI-11 -- Decompaction of exposed subsoil before topsoil replacement shall be accomplished utilizing an agricultural subsoil 

or other appropriate implement. After decompaction and prior to topsoil replacement, a disc or harrow shall be utilized, as 

necessary, to smooth the subsoil surface. -- C -- [See AGRI-1] 

AGRI-12 -- Following final grading and topsoil replacement in agricultural lands, deep tillage shall be used to relieve soil compaction in construction areas or the Proponents shall test soils for compaction at regular intervals. Where soil compaction 

is tested, construction areas shall be compared to adjacent areas not disturbed by construction. -- C -- [See AGRI-1] 

AGRI-13 -- Decompact agricultural lands where topsoil has not been removed by using a non-inversion, deep-tillage 

agricultural subsoiler specifically designed for soil decompaction and designed to minimize surface disturbance and the mixing of subsoil with topsoil. -- C -- [See AGRI-1] AGRI-14 -- Existing range improvements that are damaged or modified during construction shall be repaired. Additionally, 

temporary fences and gates shall be removed after construction if requested by landowner or land-management agency. -- C -- [See AGRI-1]

Thi

AGRI-15 -- If a dairy farm reports problems with stray voltage, complete a free, on-site investigation and determine the level of 

voltage and fix any problems resulting from their transmission line to less than 1 volt. -- C -- Stray voltage is not likely with transmission construction and operation.

Thi
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

AGRI-16 -- Align the transmission line to avoid the CAFO approximately 14.5 miles east of the proposed Cedar Hill Substation 

if this route is approved. -- C -- During routing and siting the Companies are taking all constraints in to consideration to 

minimize impact as part of the NEPA process and obtaining ROW. Issues will be resolved with landowners during 

negotiations. It is not clear as to why this specific landowner issues has been elevated above all other landowner issues and identified within the DEIS. This is not a mitigation measure that should be in the FEIS as this will be addressed during routing and landowner discussions. The Proponents propose the following revision by replacing these measures with one: "The Proponents shall work with landowners to minimize impact and address substantiated concerns."

Thi

AGRI-17 -- Realign the transmission line route during final design to avoid affecting any CAFOs. – C -- Measures would be identified and agreed to during landowner negotiations. This would be accomplished to the extent practicable during final 

design.

Thi

AGRI-18 -- Consult with the Farm Service Agency and landowners to determine if construction would affect the CRP status of 

the land currently enrolled in CRP or if special construction or revegetation techniques would be necessary. -- D -- Proponentspropose the following revision: "Consult with the Farm Service Agency and landowners to determine how construction may 

affect the CRP status of land currently enrolled in CRP." TRANSPORTATION

Thi

TRANS-1 -- The Proponents will attempt to identify existing two-track trails as preferred temporary access roads for 

construction. – D -- The Proponents propose the following revision: "The Proponents will attempt to identify existing two-track

trails as preferred access roads for construction."

Ch

TRANS-2 -- Temporary roads will be designed so proper drainage is not impaired and will be built to minimize soil erosion on or near the temporary roads. Consult with appropriate Agencies on additional design measures. -- D -- The Proponents 

propose the following revision: "Roads will be designed so proper drainage is not impaired and will be built to minimize soil 

erosion."

Thiprowit

TRANS-3 -- Permanent and temporary roads on NFS lands and BLMadministered lands will be consistent with appropriate National Forest and BLM Transportation Management Plans, as amended, and other applicable rules. Permanent roads built for the Project on NFS lands and BLM-administered lands shall be closed to the public. Signs shall indicate the restriction or 

regulation, location, penalty for violation, and appropriate contact information for reporting violations. Signage shall be maintained and replaced as part of the routine maintenance. Proponents will monitor permanent roads on NFS land and BLMadministered lands yearly, and the applicable land-managing agency shall be provided with annual monitoring reports. Roads 

will be maintained as required by the Special Use Permit. -- D -- Clarification as to what the following really means is needed

as it is not clear: "Permanent and temporary roads on NFS lands and BLM-administered lands will be consistent with appropriate National Forest and BLM Transportation Management Plans, as amended, and other applicable rules." There is no 

justifiable reason to "monitor" roads annually and there is no description as what is to be monitored. Service roads will be 

maintained as needed. The Proponents propose the following revision: "Service roads built for the Project on NFS lands and BLM-administered lands shall be closed to the public unless otherwise agreed upon with the landowner/manager. Signs shall indicate the restriction or regulation, location, penalty for violation, and appropriate contact information for reporting violations. 

Signage shall be maintained and replaced as part of the routine maintenance. Service roads will be maintained by the 

Proponents as needed for Proponent use."

ThiProthe penand repfor use 

TRANS-4 -- Upon abandonment, temporary access roads may be left intact through mutual agreement of the land 

management agency, landowner, the tenant, and the Proponents, unless located in flood areas or drainage hazard areas or 

otherwise restricted by federal, state, or local regulations. -- D -- The Proponents propose the following revision: "Roads to be 

abandoned may be left intact through mutual agreement of the land management agency, landowner, the tenant, and the 

Proponents, unless located in flood areas or drainage hazard areas or otherwise restricted by federal, state, or local 

regulations."

Thibe tenoth

FIRE-4 -- Clear equipment parking areas, the ROW, staging areas, and designated vehicle-parking areas of all flammable 

material. -- C -- These will be addressed in the Fire Management Plan that will be developed. This conflicts with minimizing vegetation removal in other MMs.

Thi

FIRE-10 -- Restrict or cease operations on federal lands during periods of high fire danger at the direction of the responsible

land-managing agency representative. -- D -- The Proponents propose the following revision: "The Proponents shall comply with fire restrictions and/or waivers as applicable."

Ch
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

ENV-1 -- After a route has been selected and before construction, the route would be reviewed for areas within 0.5 mile of petroleum or gas pipelines, oil or gas wells, municipal solid waste landfills, service stations, railroads, municipal landfills, 

caves, and active and abandoned mines. The locations intersected by the route and these facilities would be compared 

against state Department of Environmental Quality databases which contain the locations of contaminated facilities and sites 

undergoing remediation. If contaminated sites are identified, further information would be obtained from Department of Environmental Quality personnel, and the authorized officer would be notified. -- C -- This is basically conducting a Phase 1 environmental site assessment for a large portion of the route. This is not a common construction practice but rather 

conducted when there is an apparent need or when properties are purchased due to ownership transfer. During construction, if 

contamination is encountered, the contamination will be managed appropriately in compliance with all applicable laws. What is the process if there is a likelihood of contamination? What would the authorized officer do? The cost for doing such an analysis greatly outweighs the benefit and is not justifiable. ENV-2 covers this issue appropriately. Contractor preconstruction training 

may include identification of site contamination.

Thi

ENV-2 -- Construction crews would be trained to look for pre-existing environmental contamination. Indications of contamination could include mine waste rock stockpiles, drums or containers of unknown products, discolored soil, or unusual 

soil odors. Should indications of contamination be encountered, all surface disturbing activities in the vicinity of the 

contamination would cease. The location would be marked and project access restricted to eliminate the spread of 

contamination by construction equipment. The authorized officer would be notified, and the applicable Department of 

Environmental Quality personnel, and property owner or land management agency informed. To protect site workers, and 

minimize environmental effects, no work would occur at this location until the environmental conditions have been resolved. The Proponents would not assume responsibility for discovery of pre-existing contamination. -- C -- It is inappropriate to 

involve contractors with safety issues specifically to look for and identify contamination. The Proponents advise their 

contractors to inform the foreman in the event suspicious materials are encountered so that appropriate measures can be implemented.

Thitraiconcre

NOISE-1 -- Provide notice by mail prior to construction to all sensitive receptors and residences within 300 feet of construction 

sites, staging areas, and access roads. The announcement will state specifically where and when construction will occur in the 

area. -- D -- The Proponents propose the following revision: "Provide notice by mail, prior to construction to all businesses and 

residences within 300 feet of construction sites, staging areas, and access roads. No more than one notice by mail is required 

during the course of construction. The announcement will state the proposed start time for construction activities in the area 

acknowledging that schedules may change and identify the general area of construction activities."

Thi

Chapter 1 - P&N -- 1.2 -- 3 -- 1 -- The purpose of the federal action on federally managed lands is to determine if providing for 

the use of those lands for portions of the Gateway West Transmission line is in the public interest. The need for the action is

established by the federal agencies’ responsibility under the Federal Land Policy and Management Act (FLPMA2) to respond 

to an application for a ROW. In addition, the USACE must respond under the Clean Water Act (CWA3) to an application for a permit to dredge or fill waters of the United States, including wetlands. The purpose and need for major federal authorizing actions requested for the proposed Project to proceed are further described below. -- The purpose of the federal action is 

incorrect: It's not to determine if it is in the public interest, but rather to provide access to those lands.

Co

Chapter 1 - P&N -- 1.2.1 -- 4 -- 1st bullet -- Decide if a ROW grant should be issued for the transmission line; -- BLM's decision 

should also include issuing a ROW grant for access roads and ancillary facilities.

Thi

Chapter 1 - P&N -- 1.3 -- 15 -- T1.3.3 -- Table -- Heward sub is not existing-to be built adjacent to Difficulty Sub-looks like the 

Difficulty description was kept and just changed the name to Heward. Also issue in T2.1.2

Thi

Chapter 1 - P&N -- 1.3.1 -- 11 -- T1.3.1 -- Table -- Bridger West line: Parallel Segment should be Anticline not JB: Note 2: 

change JB to Anticline

Info
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

Chapter 1 - P&N -- 1.3.1.1 -- 7 -- 1 -- The number of customers in Idaho Power’s service area is expected to increase from 

around 490,000 in 2009 to over 680,000 by 2029. Firm peak-hour load (the peak hourly electricity that the system must supply when demand is at its highest) has increased from 2,052 MW in 1990 to over 3,000 MW in 2006, 2007, 2008, and 2009. In June 2008, the peak-hour load reached 3,214 MW, which was a new system peak-hour record. Average firm load (the average annual demand from customers) has increased from 10,500,000 megawatt hours (MWh) in 1990 to 15,800 MWh in 

2008 (excluding Astaris/FMC) (IPC 2009). While the economic downturn is expected to depress customer demand for 

electricity in the near term, Idaho Power forecasts that on average their load will continue to grow at about 0.7 percent per year 

to approximately 17,500,000 MWh in 2019. During the same period, the peak-hour load is expected to increase at a rate of 57 MW per year, adding an additional 570 MW of peak-hour demand by 2019 (IPC 2009). -- In June 2011, Idaho Power filed our 2011 Integrated Resource Plan (IRP) with the public utilities commissions in Idaho and Oregon. The IRP is available at: 

http://www.idahopower.com/AboutUs/PlanningForFuture/irp/2011/default.cfm 

The text within the DEIS needs to be updated to reflect the current IRP. Replacement text for the DEIS is provided below. The number of customers in Idaho Power’s service area is expected to increase from around 490,000 in 2010 to over 650,000 

by 2030 (IPC IRP 2011). Firm peak-hour load (the peak hourly electricity that the system must supply when demand is at its 

highest) has increased from 2,052 MW in 1990 to an annual average of 3,090 MW for the years 2006 to 2010. In June 2008, the peak-hour load reached 3,214 MW, which was a new system peak-hour record. Average firm load (the average annual 

demand from customers) has increased from 10,500,000 megawatt hours (MWh) in 1990 to 15,200,000 MWh in 2010 

(excluding Astaris/FMC) (IPC IRP 2011). While the economic downturn is expected to depress customer demand for electricity 

in the near term, Idaho Power forecasts that on average their long term load growth rate will be about 1.4 percent per year and

that load will grow to approximately 18,300,0000 MWh in 2020. During the same period, the peak-hour load is expected to 

increase at a rate of 69 MW per year, adding an additional 690 MW of peak-hour demand by 2020 (IPC IRP 2011).

The 

Chapter 1 - P&N -- 1.3.1.1 -- 7 -- last -- Idaho Power is a regulated public utility under the laws of the State of Idaho whose

mission is to provide reliable, responsible, fair-priced energy. Idaho Power operates under the oversight and regulatory controls of the Idaho Public Utility Commission... -- Change Utility to Utilities

Info

Chapter 1 - P&N -- 1.3.1.1 -- 8 -- 2 -- Idaho Power is also a public utility under the jurisdiction of the FERC. Idaho Power isobligated to expand its transmission system to provide requested firm transmission service, and to construct and place in 

service sufficient capacity to reliably deliver resources to network and native load customers as provided in their Open Access

Transmission Tariff (OATT) under Sections 15.4 and 28.3 (FERC 2008). Idaho Power’s Attachment K of the OATT requires 

planning for the expansion of the system to ensure that its transmission system meets industry, regulatory, and reliability 

standards. -- The obligation to plan is described in the OATT under section III Network Integration Transmission Service: “The Transmission Provider will plan, construct, operate and maintain its Transmission System in accordance with Good Utility 

Practice and its planning obligations in Attachment K in order to provide the Network Customer with Network Integration Transmission Service over the Transmission Provider’s Transmission System.” Replace existing text with the following: Idaho Power’s OATT requires planning for the expansion of the transmission system in order to provide network integration 

transmission service that complies with regulatory reliability standards.

Thi

Chapter 1 - P&N -- 1.3.1.2 -- 8 -- 4 -- [blank] -- The last sentence in paragraph 4 page 1-8 should be changed to state "The 

growth rate is reflective of all customer loads."

Thi

Chapter 1 - P&N -- 1.3.1.2 -- 8 -- last -- Rocky Mountain Power operates under oversight and regulatory controls of the public 

utility commissions of Wyoming, Utah, and Idaho. The Wyoming Public Service Commission (PSC) regulates rates, integrated 

resource plans, construction of large electric facilities, and transactions between utilities. The Wyoming PSC’s primary regulatory responsibility is rates. The Wyoming PSC does not regulate environmental impacts from facilities or siting (other 

than how siting influences rates). The IPUC regulates investor-owner or privately-owned utilities that provide gas, water, 

electricity, or telephone service for profit. The primary responsibility of the Utah PSC is to ensure safe, reliable, adequate, and 

responsibly priced utility service. -- Replace with: "PacifiCorp is an electric utility that transmits electricity via a grid of transmission lines located throughout a six-state region and a distribution system that serves more than 1.7 million retail customers. Rocky Mountain Power delivers electricity to approximately 1 million customers in Utah, Wyoming, and Idaho. As 

an essential service provider, Rocky Mountain Power is required to operate under the oversight and regulatory controls of the 

Public Service Commission of Utah, the Wyoming Public Service Commission, and the Idaho Public Utility Commission. Pacific Power, another business unit of PacifiCorp, provides service to approximately 730,000 customers in Oregon, Washington, and California, and is subject to the regulatory oversight of the Oregon Public Utility Commission, the Washington Utilities and Transportation Commission, and the California Public Utilities Commission. Although the objectives of these 

multiple commissions vary somewhat, they do share a common goal of ensuring utilities such as Rocky Mountain Power 

provide safe, reliable, adequate, and efficient delivery of electricity."

Thi
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100343 IDAHO POWER AND 

ROCKY MOUNTAIN POWER (cont.)

While Section 5.1.2 of the DEIS, “Stakeholder Outreach” provides a discussion of the meetings organized by the Companies 

to collaborate with interested parties on the Project, a large number of other outreach activities should be included in the Final 

EIS to document the extensive efforts the Companies have conducted to address stakeholder concerns. Through April 2011, the Companies have hosted and attended over 150 meetings in addition to those cited in the DEIS. Table 1 starting on page 

15 lists these additional outreach efforts.

Infoout

100345 U.S. FISH AND 

WILDLIFE 

[page]2-20 -- [para]1-3 -- [line]All -- [commenter]Julie Proell -- Guyed towers have been shown have a significant impact on 

migratory birds compared to the proposed self-supporting lattice structures. We recommend the use of SSL towers in all areas where moderate to high bird use has been documented. 

Nolanlan

 [page]3.6-10 -- [para]Vegetation Types of Concern -- [blank] -- [commenter]Jeri Wood -- The DEIS states that “Limber pine 

and whitebark pine, which have recently been added to the BLM sensitive species list in Wyoming, are addressed in Section 

3.7.” As this species has recently been identified by the FWS as a candidate for listing under the ESA, be aware that Idaho 

BLM has also added the whitebark pine to their BLM sensitive species list. 

Infoadd

 [page]3.7-9 -- [para]ESA-Listed & Candidate Plant Species -- [blank] -- [commenter]Jeri Wood -- Whitebark pine. The 

whitebark pine was identified as a candidate for listing under the ESA by FWS on July 18, 2011. The final EIS (as well as 

section 7 conference on candidate species, if requested by BLM) should address this change in status for the whitebark pine. 

Infowh

 [page]3.7-19 -- [para]Plan amendments -- [blank] -- [commenter]Jeri Wood -- Plan Amendments. The DEIS indicates that the 

Morley Nelson Snake River Birds of Prey National Conservation Area (SRBOP) Resource Management Plan will require an 

amendment as the Gateway West project as proposed would be located within 0.5 miles of sensitive plant habitat along Segment 8. We recommend that Segment 8 be reevaluated to avoid impacts to sensitive plant species and their habitats, including the slickspot peppergrass. 

Corec

prebeeAreavolocpos

 [page]3.7-22 and 23 -- [para]4 and 1 -- [line]All -- [commenter]Julie Proell -- TESPL-2 and TESPL-3 state that there will be 3 

years of preconstruction surveys performed in suitable habitat for Ute ladies’-tresses and that micrositing will be used to avoid identified populations. I recommend that these measures be implemented throughout all suitable habitat within the Analysis Area, and not just on public lands. Otherwise, impacts to this species may be MALAA and require formal conferencing. 

Nolan

spe

 [page]3.7-23 -- [para]Slickspot peppergrass (Threatened) -- [blank] -- [blank] -- Slickspot peppergrass. We anticipate that the 

Gateway West Transmission Line Project may result in some unavoidable adverse effects to proposed, listed, and/or 

candidate species, including the slickspot peppergrass (Lepidium papilliferum). Despite mitigation measures, it is anticipated 

that impacts to some slickspot peppergrass plants or seeds and its habitat may not be avoided by the Project. In addition, some segments of the Project bisect proposed critical habitat for the slickspot peppergrass. Impacts that may occur to the primary constituent elements for slickspot peppergrass critical habitat may include damage or loss of slickspot microsites or removal of sagebrush shrubs and native forbs during construction and/or maintenance activities. As described in the DEIS, transmission line construction, maintenance, and operations may also ignite wildfires, which would adversely impact both the slickspot peppergrass and its critical habitat. In addition, construction, operations, and maintenance of transmission lines may increase the risk of invasive nonnative plant introduction and spread on a localized level, potentially resulting in impacts to

both the species and primary constituent elements of critical habitat. Through section 7 effects analyses, the Federal action 

agency examines the effect of their action on the species at the level of an individual plant or animal. While the FWS 

acknowledges that BLM has incorporated conservation measures into the proposal to avoid or minimize effects to slickspot 

peppergrass and its habitat as per BLM's 2009 Conservation Agreement with the FWS and the State of Idaho's 2006 Candidate Conservation Agreement, we anticipate that it will not be possible to avoid all localized adverse effects to the species and its critical habitat. Therefore, we recommend that the final EIS be updated to address these potential adverse 

impacts to the species and its critical habitat, and that the BLM request formal conferencing on the species and its critical habitat prior to signing the Record of Decision for this project. In addition, the DEIS indicates that the slickspot peppergrass is known to occur within 0.5 miles of Proposed Route and other Route Alternatives (8A, 8B, 8C) in Segment 8, and within 5 miles 

of Alternative 8E. We recommend the final EIS implements the Project routes that minimize overlap with slickspot peppergrass 

EOs and proposed critical habitat to the greatest extent possible. We further recommend that, within the conferencing for this 

project, specific EO numbers and critical habitat units be identified to allow for an adequate analysis of effects for this species. 

In addition, we recommend that potential habitat and slickspot peppergrass habitat as defined by Idaho BLM be included the 

analysis of effects of the Project on the slickspot peppergrass in the final EIS and associated section 7 conferencing. 

The pepper 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100345 U.S. FISH AND 

WILDLIFE (cont.)

3.7-23 -- Slickspot peppergrass -- [blank] -- Jeri Wood -- Slickspot peppergrass. We agree with the DEIS that the Proponentproposed Environmental Protection Measures (EPMs) are insufficient to protect the slickspot peppergrass due to its annual or 

biennial life history and its persistent seed bank. The agency mitigation measure within the DEIS appears to provide improved 

conservation for the species. However, we recommend that the term “higher-quality microsites”, which we interpret as slickspot microsites, be further defined or clarified in the final EIS. We also suggest that any slickspot known to support slickspot peppergrass plants (whether meeting the criteria for a “quality microsite” or not) be avoided by construction equipment and vehicles. In addition, we encourage use of BLM data regarding the location of slickspot microsites and slickspot peppergrass to supplement slickspot peppergrass location information currently entered into the Idaho Natural Heritage Data Program (INHP). It is likely that BLM has some information that has not yet been entered into the INHP. Finally, as described in the 2009 Conservation Agreement between BLM and FWS, we recommend that disturbed areas in slickspot peppergrass habitat be reseeded to establish 50 percent perennial cover following all ground disturbing activities, unless ecological site conditions 

preclude that level of cover. If a native species component existed prior to the ground disturbance, then the native species 

component should be restored.

SeCu

and for app

[page]3.7-24 -- [para]2 -- [line]6 -- [comments]Julie Proell -- TESPL-5 states that any whitebark or limber pine stands will be

mitigated through off-site mitigation and replanting in reclaimed areas. I recommend the inclusion of “approved biologist” in this 

mitigation measure to ensure that trees are properly identified, planted, etc.

Thi

[page]3.10-16 -- [para]2 -- [blank] -- [commenter]Amy Defreese -- This section should identify how the following sources of 

management direction influenced the development of the NEPA document and the analysis of project effects to migratory 

birds: Executive Order 13186; IM 2008-050 MBTA; and, the BLM MOU with USFWS regarding migratory birds. There are 

measures included in each that specify management direction relative to a) the analysis of direct and indirect impacts to 

nesting habitat, fragmentation of habitat, and reduction in habitat patch size; b) identification of the amount of affected habitat 

and relative abundance of the habitats over the landscape; and c) bird habitat protection and conservation

All All 

[page]3.10-16 -- [para]2 -- [blank] -- [commenter]Amy Defreese -- This section should reference the following sources of 

information for region-specific migratory bird information: USFWS Birds of Conservation Concern (2008) and Utah Partners in 

Flight Avian Conservation Strategy. The former can be referenced for information regarding Bird Conservation Regions in 

which the proposed project falls (BCRs 9, 10 and 16). The document lists those birds of conservation concern found within in each region.

InfoCo

[page]3.10-17 -- [para]Raptors -- [blank] -- [commenter]Julie Proell -- Eagle Take Under 50 CFR 22.26 states that, on transmission projects if construction is within 3⁄4 miles of a Golden Eagle or Bald Eagle Nest and disturbance is anticipated, 

then the Project Proponent may wish to pursue an Eagle Take Permit. Disturbance would most likely occur during the 

construction phase of the Project.

A t

[page]3.10-17 -- [para]Raptors -- [blank] -- [commenter]Jeri Wood -- Raptors. Environmental Protection Measures (EPAs) in the DEIS indicate that preconstruction raptor nest activity surveys and associated construction prohibitions within 0.5 miles of 

the transmission line centerline during the appropriate seasonal timeframe to avoid impacts to nesting raptors from 

construction activities. However, FWS draft “Guidelines for Raptor Conservation in the Western United States” (Whittington 

and Allen 2008) recommend a spatial buffer of 1 mile from ferruginous hawk nests during the breeding/nesting season 

(February 1 through July 31). This guideline can be modified based on local conditions or nest activity in any given year. We recommend that this more conservative raptor nest buffer be used in the final EIS for ferruginous hawk nests located in the vicinity of this project.

EPproSe

[page]3.10-17 -- [para]Raptors -- [blank] -- [commenters]Jeri Wood -- Raptors. The DEIS states that “the Proposed Route for 

Segment 8 lies within 1 mile of the highest number of raptor nests, 256, of any of the segments. This segment runs through 

the SRBOP, home to the largest concentration of nesting raptors in North America, which explains the high number of nests.” 

The FWS recommends that an alternative be chosen for implementation that is located outside the SRBOP to the greatest extent possible to avoid or minimize impacts to this congressionally designated raptor conservation area.

The 

[page]3.10-32 -- [para]3 -- [line]1-9 -- [commenter]Julie Proell -- “There would be some direct impacts on migratory birds...” implies that some level of take is anticipated. The MBTA does not allow for take of migratory birds. How will project proponentaccount for this?

The con

[page]3.10-32 -- [para]4 -- [blank] -- [commenter]Amy Defreese -- Recommend that the BLM identify acres of migratory bird 

habitat indirectly affected by project construction, operation and maintenance. Also recommend that the project proponent and 

BLM identify compensatory mitigation that will offset this loss of habitat.

AdArebe 

spe

[page]3.10-34 -- [para]4 -- [blank] -- [commenter]Amy Defreese -- In order to ensure compliance with Utah-specific federal 

guidelines for raptors, we recommend that BLM cross-reference proposed mitigation measures with the Utah Field Office Guidelines for Raptor Protection from Human and Land Use Disturbances (2002).

Thi
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100345 U.S. FISH AND 

WILDLIFE (cont.)

[page]3.10-35 -- [para]Raptors -- [blank] -- [commenter]Jeri Wood -- Raptors. The FWS recommends that all bald and golden 

eagle nest sites within 2 miles of the transmission line centerline are surveyed within 2 weeks of initiating construction 

activities during the nesting season to avoid construction-related impacts to reproduction of bald and golden eagles. The FWS also recommends that if there is a potential for take of either of these species, the project proponents should apply for an 

Eagle Take Permit.

The eaghabBA1 m

[page]3.10-33 and 10-100 -- [para]Mitigation Measures -- [blank] -- [comment]Jeri Wood -- Mitigation Measures. WILD-8 should include wetlands for installation of flight diverters (see general comment about Segments and Segment 9 regarding 

Partners for Wildlife projects).

WIide

[page]3.10-39 -- 3 -- All -- [commenter]Julie Proell -- Water draw-down (if not all purchased from existing water rights) totaling 13,702,747 cubic feet exceeds the de minimis limit of 4,356,000 cubic feet per year, and so formal conference with the USFWS is required.

The 

[page]3.10-100 -- [para]Mitigation Measures -- [blank] -- [commenter]Jeri Wood -- Mitigation Measures. WILD-7 should include 

non-Federal lands, especially on Partners for Wildlife projects (see general comment about Segments and Segment 9 

regarding Partners for Wildlife projects).

The 

[page]3.11-8 -- [para]2 -- [blank] -- [commenter]Amy Defreese -- The document should reference Sage-grouse local working groups in Utah as this species (in Utah) may be indirectly affected if alternative routes are chosen over the proposed.

Ap

[page]3.11-12 -- [para]1 -- [line]1-17 -- [commenter]Julie Proell -- List of species for surveys the year prior to project should 

also include Preble’s MJM, Yellow-billed cuckoo, Gold eagle, Prairie falcon, Red tailed hawk, and Swainson’s hawk as those 

species are either now listed or have been documented in the project area with impacts anticipated to the species as a result 

of the project.

Texcon

[page]3.11-26 -- [blank] -- [blank] -- [commenter]Amy Defreese -- There is a potential for indirect effects to greater sage-grouse 

in Utah if Alternatives 7I or 4B are chosen. These alternative routes abut the Utah/Idaho and Utah/Wyoming borders at a point 

where greater sage-grouse occupied, brooding habitat exists in Utah. We recommend that the BLM expand the Affected 

Environment – Existing Conditions section for greater sage-grouse to include Utah-specific information (Section 3.11.1.5).

Pobee

[page]3.11-27 -- [para]3 -- [line]1 -- [commenter]Amy Defreese -- There is a potential for indirect effects to greater sage-grouse 

leks in Utah if Alternatives 7I or 4B are chosen. These alternatives abut the Utah/Idaho and Utah/Wyoming borders at a point where greater sage-grouse occupied, brooding habitat exists in Utah. We recommend that the BLM expand the Affected 

Environment – Existing Conditions section for greater sage-grouse to identify the number of leks in Utah.

Lekare 

[page]3.11-35 -- [para]Bliss Rapids Snail (Threatened) -- [blank] -- [commenter]Jeri Wood -- Bliss Rapids Snail (Threatened). We recommend updating the final EIS to state that “The Bliss Rapids snail (Taylorconcha serpenticola) was listed as threatened [DEIS indicates the species was listed as endangered] under the ESA on December 14, 1992.” In addition, the final 

EIS should be updated to indicate that the FWS determined in September 2009 that the Bliss Rapids snail is likely to become endangered within the foreseeable future (i.e., the species remains threatened, as defined by the ESA). Therefore, The FWS 

determined that removing the Bliss Rapids snail from the list of endangered species is not warranted at this time.

Info
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100345 U.S. FISH AND 

WILDLIFE (cont.)

[page]3.11-36 -- [para]Snake River Physa Snail (Endangered) -- [blank] -- [commenter]Jeri Wood -- Snake River Physa Snail 

(Endangered). The text insert below represents the most recent information on the distribution of the Snake River Physa snail. 

This information should be used in both the final EIS as well as in effects analyses associated with any ESA section 7 

conferencing efforts regarding this species. In addition, the effects of any Snake River crossings located within this updated 

species range area should be addressed in both the final EIS and effects analyses associated with section 7 conferencing efforts once the preferred alternative for the Project is identified. “The Snake River physa snail is only known from the Snake River in south-southwest Idaho, with limited specimens recorded 

from a single major tributary. The Service (1995, pg. 8) reported that the Snake River physa’s “modern” range extended from 

Grandview (RM 487, Rkm 784) to the Hagerman Reach (RM 573, Rkm 922). Recently identified specimens collected by the 

Bureau of Reclamation (Gates and Kerans 2010, pg. 20, 48-51) and Idaho Power Company from 1995 to 2003 (Keebaugh 

2009, pgs. 1-124) confirm its distribution to as far upstream as Minidoka Dam (RM 675, Rkm 1086.1) and as far downstream as Ontario (RM 368, Rkm 592.1), Oregon, some 128 miles (206 km) downstream of its previously recognized downstream 

range (Grandview). Two specimens were recovered from the Bruneau River arm (RM 4, Rkm 6.4) of C.J. Strike Reservoir 

(Keebaugh 2009, pg. 123) representing the only tributary of the Snake River from which the species has been recorded. 

While the species is more widespread than previously thought, currently recorded from an estimated 307 river miles (494 river 

km), it has not been found at high densities within much of its current, known range and is likely absent from portions of the 

river. The most extensive surveys conducted to date are from the 12-mile reach below Minidoka Dam (RM 663-675, Rkm 

1066.8-1086.1) (Gates and Kerans 2010, pg. 10), in which live Snake River physa were recovered from 29 (8%) of 365 samples collected. In plots where they were found, densities were typically =32 per square meter, but live animals reached 

relatively high densities in a few of these samples, estimated at 40 to 64 individuals per square meter. Elsewhere in the SnakeRiver, surveys have been much less intensive and not specific to Snake River physa. Of 758 samples reexamined by Keebaugh (2009) between river miles 200 and 589.2, 4.5% (34) contained Snake River physa. Of those, 67% (23) contained a single animal (0.25/m2) and one sample near Marsing, Idaho (RM 421, Rkm 677.4) contained a high of 7 individuals, extrapolating to a density of 28 per square meter. Hence, in habitats sampled in the lower Snake River, the species would probably not be regarded as ubiquitous nor abundant, and being patchily distributed. River reaches upstream of the Hagerman 

area (est. RM 590, Rkm 949.3) through Milner Reservoir (est. RM 663, Rkm 1066.8) have not received systematic surveys or 

reexamination of previously collected materials. “

Info

[page]3.11-37 -- [para]Utah Valvata Snail (Endangered) -- [blank] -- [commenter]Jeri Wood -- Utah Valvata Snail (Endangered). Be aware that the FWS removed the Utah valvata snail from the Federal List of Endangered and Threatened Wildlife effective September 24, 2010. The final EIS should be updated to reflect this information.

Info

[page]3.11-43 -- 3 -- [blank] -- [commenter]Lynn Gemlo -- Preble’s meadow jumping mouse must be analyzed as a threatened 

species. Move to Sec 3.11-20.

Info

[page]3.11-44 -- [para]2 -- [blank] -- [commenter]Lynn Gemlo -- Should be added-Preble’s meadow jumping mouse are found, 

as far as current distribution, in 5 counties in WY. Laramie, Goshen, Platte, Albany and Converse. Fed. Reg. 2008. Segment 

1E and 1W occur in Converse and Albany. Should be added-Habitat of jumping mouse in riparian is 100 meters beyond the 

100 year floodplain.

Info

[page]3.11-59 -- [para]1 -- Conclusion -- [commenter]Julie Proell -- BFF: You determined MANLAA because potential for 

impacts, implementation of EPMs, mitigation measures. I believe this is the appropriate determination for this species for this

project in WY

Yo

[page]3.11-60 -- [para]5 -- Conclusion -- [commenter]Julie Proell -- Canada lynx: You determined MANLAA because loss of 

some LAU habitat, cross 2 linkage, but no impact to prey base or impede movement. I believe this is the appropriate 

determination for this species for this project in WY.

Yo

[page]3.11-63 -- [para]4 -- Conclusion -- [commenter]Julie Proell -- Grey wolf: You determined MANLAA because no specific 

habitat type required, and wolves would move from area during construction. I believe this is the appropriate determination for

this species for this project in WY.

Yo

[page]3.11-64 -- [para]1 -- [blank] -- [comments]Lynn Gemlo -- Not avoiding leks and core areas is not sufficient to protect 

nesting birds with these distances.

The origreq

[page]3.11-64 -- [para]2 -- [blank] -- [commenter]Lynn Gemlo -- Need to meet WY Core Area Strategy-General Stipulations for 

vegetation removal: Limited to minimum disturbance required by the project. All removal will occur between July 1 and March 

14 within 4.0 miles of an occupied lek.

No

[page]3.11-65 -- [para]PAC-10 -- [blank] -- [commenter]Lynn Gemlo -- 0.25 mile arbitrary, not based on literature. Not enough 

to minimize disturbance for sage-grouse.

The req
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100345 U.S. FISH AND 

WILDLIFE (cont.)

[page]3.11-65 -- [para]Federal ESA Wildlife Species -- [blank] -- [commenter]Jeri Wood -- Federal ESA Wildlife Species. 

Please explain the justification for the survey zone of 1 mile for PAC-7 and the .25 mile no surface disturbance buffer for PAC10. Ruby Pipeline used a 2 mile survey buffer (FEIS, page 4-141) and the 0.6 mile no surface disturbance buffer (FEIS, page 

4-141). See also general comment above regarding consistency of buffer zones, etc.

Theprosupdire

bas

[page]3.11-67 -- [para]Federal ESA Wildlife Species -- [blank] -- [commenter]Jeri Wood -- Federal ESA Wildlife Species. 

TESWL-23 should be applied across the entire line to provide for consistency across the project area

The USsag

[page]3.11-68 -- [para]Federal ESA Wildlife Species -- [blank] -- [comment]Jeri Wood -- Federal ESA Wildlife Species. It is 

unclear that poaching of sage grouse poses a significant adverse effect on sage grouse. Please provide a citation for this 

statement.

Poposlow

3.11-69 -- Federal ESA Wildlife Species -- [blank] -- Jeri Wood -- Federal ESA Wildlife Species. Please provide a citation for the statement “Golden eagles hunting ranges ...very large”. Also TESWL-22 should be applied across the entire line to provide for consistency across the project area.

Citmiton 

[page]3.11-70 -- [para]2 -- [blank] -- [commenter]Lynn Gemlo -- Why would the avoidance distance based on literature not be 

used? Should use the science to base this on to minimize impacts.

At tand Se

[page]3.11-71 -- [para]2 -- [blank] -- [comment]Lynn Gemlo -- Kestrels, falcons, tree swallows and chickens have been shown 

to be highly sensitive to electromagnetic fields.

Info

[page]3.11-72 -- [para]3 -- [blank] -- [comment]Lynn Gemlo -- Explain “replacement of any lost birds”? Tex[page]3.11-72 -- [para]5 -- Conclusion -- [commenter]Julie Proell -- G. sage-grouse: You determined MAA individuals (take) 

because going through core and key areas, avoiding most leks w/in 0.25 to 0.6 miles, compensatory mitigation plan, PAC-7 thru 12, TESWL-10, TESWL-14 thru 16, TESWL-19, TESWL-23, TESWL-22. If compensatory mitigation plan not complete, 

MAA and trend to listing would be result of project.

No

[page]3.11-73 -- [para]1 -- [blank] -- [commenter]Lynn Gemlo -- Cannot assume the final plan would say this, this is a 

presumptive statement not based on any information that would lead you to be confident in this statement. Suggest deleting it.

Tex

[page]3.11-73 -- [para]4 -- Conclusion -- [commenter]Julie Proell -- Grizzly bear: You determined MANLAA because will avoid 

area, will avoid whitebark pine to extent practicable. I believe this is the appropriate determination for this species for this 

project in WY.

Yo

[page]3.11-78, 3.11-85 -- [para]2,1 -- Conclusion, Conclusion -- [commenter]Julie Proell -- Platte River Sp: You determined MALAA because depletions if not able to purchase enough water. I believe this is the appropriate determination for these 

species for this project in WY. You will need to initiate formal conferencing under the programmatic BO for Platte River depletions.

Yo

[page]3.11-78 -- [para]4 -- Conclusion -- [commenter]Julie Proell -- Wyoming Toad: You determined NE because no suitable 

habitat within area

Thi

[page]3.11-80 -- [para]2 -- Conclusion -- [commenter]Julie Proell -- Yellow-billed cuckoo: You determined MAA individuals 

(take) because span riparian areas, implement EPMs to avoid riparian areas to extent practicable. I believe this is the appropriate determination for this species for this project in WY.

Yo

[page]3.11-80 -- [para]Federal ESA Invertebrate Species -- [blank] -- [commenter]Jeri Wood -- Federal ESA Invertebrate 

Species. Update the final EIS to state: “There are four [DEIS says five] federally listed and two [DEIS says one] recently delisted aquatic invertebrate species found within the Analysis Area that could be affected by the Project’s construction and 

operations: the Utah valvata snail (delisted) [DEIS says Endangered]; Bliss Rapids snail (Threatened); Jackson Lake springsnail (delisted); Banbury Springs limpet (Endangered); Snake River physa snail (Endangered); and Bruneau hot springsnail (Endangered).”

Tex
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100345 U.S. FISH AND 

WILDLIFE (cont.)

[page]3.11-81 -- [para]Federal ESA Invertebrate Species -- [blank] -- [commenter]Jeri Wood -- Federal ESA Invertebrate 

Species. The DEIS describes some potential effects to listed Snake River snails as being water temperature increases due to vegetation loss along the Snake River and streams as well as impacts from potential access road crossings of springs and 

rivers. Listed Snake River snails are found in cold water river habitats and associated cold water springs and spring creeks. 

Removal of vegetation along the Snake River is not expected to impact water temperatures to the degree that these snail species would be adversely affected, particularly at RM 573.5. RM 573.5 is located over the reservoir associated with the Salmon Falls Dam. In addition, the IFWO is not aware of documented records of the Bliss Rapids snail in the reservoir, and we do not expect Snake River Physa snail to occur in the reservoir. In contrast, the removal of vegetation along cold water springs and spring creeks may impact water temperatures to the 

degree that listed Snake River snail species, if present, could be adversely affected. Similarly, road crossings of cold water 

springs or their spring creeks could impact listed Snake River snails. We strongly recommend that the placement of any potential road crossings through cold water springs and their associated spring creeks that contain listed Snake River snails or 

contribute to listed Snake River snail habitat in adjacent river habitats be avoided as these springs represent high value habitats that are extremely limited in southern Idaho. In addition, we agree that sediment generated by the project through vegetation removal or access road construction or use could affect listed Snake River snails within the Snake River as well as 

associated habitats, and should continue to be discussed in the DEIS. The Proposed Route and Route Alternatives for the Project between Jerome and Glenns Ferry, Idaho (east to west) and 

between King Hill Creek ACEC and Castleford, Idaho (north to south) are of particular importance to the conservation of listed aquatic invertebrates in Idaho. The Idaho Fish and Wildlife Office (IFWO) is available to provide detailed technical assistanceregarding avoidance and minimization of potential effects of the Project on listed aquatic invertebrates in Idaho. We request 

that a zoomed in map detailing the locations of all Proposed Route and Route Alternatives for the Project between Jerome and Glenns Ferry, Idaho (east to west) and between King Hill Creek ACEC and Castleford, Idaho (north to south) be provided to the IFWO to assist us in developing technical assistance recommendations for the Project prior to the release of the final EIS.

In addition, a map that zooms in on the proposed location of the Bruneau River crossing by the Project would also assist the 

IFWO in providing technical assistance on measures that will avoid or minimize Project impacts on the Bruneau hot springsnail 

as well as potential impacts on designated bull trout critical habitat.

Tex

reqneemin

[page]3.11-84 -- [para]4 -- Conclusion -- [commenter]Julie Proell -- Colorado River Fish: You determined MALAA because 

depletions if not able to purchase enough water. I believe this is the appropriate determination for these species for this project 

in WY. We will need to undergo formal conferencing under the programmatic BO for Colorado River depletions.

Yo

[page]3.11-85 -- [para]Federal ESA Fisheries Species -- [blank] -- [commenter]Jeri Wood -- Federal ESA Fisheries Species. Critical habitat for bull trout has been finalized. Please update this discussion.

Info

[page]3.11-88 -- [para]3 -- Conclusion -- [comment]Julie Proell -- Bald eagle: You determined MAA individuals because 

impacts habitats near nests and roosting habitats, implement EPMs and mitigation measures. Will have to apply for an eagle take permit, once they become available.

Info

[page]3.11-89 -- [parap]2 -- Conclusion -- [commenter]Julie Proell -- Black- and White-Tailed Prairie Dogs: You determined 

MAA individuals because increased predation, disturbance, loss or modification of habitat, implement mitigation measures TESWL-2, TESWL-3. I believe this is the appropriate determination for this species for this project in WY.

Yo

[page]3.11-91 -- [para]4 -- Conclusion -- [commenter]Julie Proell -- Burrowing owls: You determined MAA individuals because 

impact habitat, increased predation, PRC-5 mitigation measure. Determine MALAA because depletions if not able to purchase enough water. I believe this is the appropriate determination for this species for this project in WY.

Yo

[page]3.7-28-31 -- [para]Table -- [line]Table -- [commenter]Julie Proell -- Desert yellowhead: You determined NE because only found over 50 miles away from the project site in Fremont County, which is not included in the Analsysis Area. I believe this is the appropriate determination for this species for this project in WY.

Yo

[page]3.7-39 -- [para]Segment 4,ESA-listed and Candidate Species -- [blank] -- [commenter] Jeri Wood -- Segment 4, ESAlisted and Candidate Species. The DEIS states that “Given that pre-construction surveys for Ute ladies-tresses would be 

conducted in areas of suitable habitat, and that loss of wetland habitat would be adequately mitigated, construction and 

operations of the Project along the Proposed Route and Route Alternatives may affect, but are not likely to adversely affect, 

this species.” However, this species is extremely difficult to survey for, so all plants may not be avoided by construction 

activities. In addition, mitigation of wetland habitat loss is not expected to avoid the loss of individual plants on that may be present on lost wetland areas. BLM may wish to consider a “likely to adversely affect” determination for the Ute ladies’-tresses in section 7 conferencing associated with the final EIS.

Dislad
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100345 U.S. FISH AND 

WILDLIFE (cont.)

[page]3.7-45 -- [para]Segment 8, ESA-listed and Candidate Species -- [blank] -- [commenter]Jeri Wood -- Segment 8, ESAlisted and Candidate Species. The DEIS states that “The Project would directly impact a total of 7 acres of known slickspot 

peppergrass occurrences along the Proposed Route for Segment 8 during construction and approximately 1 acre during 

operations.” We recommend that an alternative that avoids known slickspot peppergrass occurrences be chosen for 

implementation in Segment 8 to avoid impacts to both the slickspot peppergrass and its proposed critical habitat.

The 

[page]Sections 3.10 and 3.11 -- [blank] -- [blank] -- [commenter]Amy Defreese -- In general, it appears that BLM omitted an 

inventory and analysis for Utah wildlife resources where alternative routes abut the Utah/Idaho and Utah/Wyoming borders. 

We recommend that BLM identify and analyze Utah wildlife resources that fall within the various Areas of Analysis for 

Alternatives 7I and 4B. Resources and species to consider include those protected under the Endangered Species Act, migratory birds, raptors including bald and golden eagles, greater sage-grouse, and pygmy rabbit.

Uta

[page]3.7-28-31 -- [para]Table -- [line]Table -- [commenter]Julie Proell -- Colorado Butterfly Plant: You determined NE becauseno portions of Analysis Area occur in counties where species occurs. I believe this is the appropriate determination for this species for this project in WY.

Yo

[page]3.7-28-31 -- [para]Table -- [line]Table -- [commenter]Julie Proell -- Blowout Penstemon: You determined that Segment 4 MANLAA, the rest of segments have NE. No sand dune habitat occurs in Analysis Area, though all portions are in potential 

range. PPC-1 through PPC-4 allow surface disturbance where surveys the year prior to construction suggest no populations 

are present. I believe this is the appropriate determination for this species for this project in WY.

Yo

[page]3.7-28-31 -- [para]Table -- [line]Table -- [commenter]Julie Proell -- Western prairie fringed orchid: You determined that

Segments 1E, 1W, and 2 MALAA, the rest of segments are NE. Adverse effect from depletions of N. Platte River watershed that occurs in Segments 1E, 1W, and 2. I believe this is the appropriate determination for this species for this project in WY.

Formal conferencing should be initiated.

Yo

[page]3.7-28-31 -- [para]Table -- [line]Table -- [commetner} Julie Proell -- Whitebark pine: You determined that Segment 4 MALAA, rest of segments NE. Likely present along alignment of Segment 4 in WY and individuals will be removed. TESPL-5 

states if a stand cannot be avoided, silvicultural treatments of adjacent stands, collection of seed, identification of “plus” trees, or other acceptable mitigations will be done to offset the loos of the stand in addition to replanting whitebark pine on reclaimed areas.” Recommend defining silvicultural treatments and other acceptable mitigations. I believe this is the appropriate 

determination for this species for this project in WY.

TE

tha

[page]3.7-28-31 -- [para]Table -- [line]Table -- [commenter]Julie Proell -- Ute ladies’-tresses: You determined MANLAA for 

Segments 1W, 1W, 2, 3, and 4, the rest are NE. Potential habitat occurs within Analysis Area, and limited surveying was not 

appropriate to disqualify this species from being considered for potential impacts. I anticipate seeing results of surveys from

2011 from each site within the analysis area that contains suitable habitat for this species.

The 

[page]3.10-4 -- 2 -- [blank] -- [comment]Amy Defreese -- Recommend that BLM reference the Utah Field Office Guidelines for 

Raptor Protection from Human and Land Use Disturbances (2002)

Re

[page]3.10-8 and 9 -- [para]4 and 1 -- [line]Field Surveys -- [commenter]Julie Proell -- “Aerial raptor nest surveys were 

conducted in portions of...FOs from April 1 through April 28, 2008.” Surveys in 2008 regarding active/inactive nests are likely no longer the best available data. Recommend newer data be used for micrositing towers.

The cho

[page]3.11-96 -- [para]3 -- [blank] -- [comments]Lynn Gemlo -- Based on your statements, riparian areas within the Preble’s 

meadow jumping mouse habitats cannot be avoided. You expect adverse effects to occur which should be clearly stated here. Current language as written is not appropriate.

Thr

[page]3.11-96 -- [para]4 -- Conclusion -- [commenter]Julie Proell -- Preble’s Meadow Jumping Mouse: You determined MAA 

individuals because within riparian and wetlands, implementation of EPMs to minimize. This is an incorrect determination, as this species is currently federally listed as threatened in WY. I recommend that the project proponent amend the project so that 

a determination of MANLAA can be achieved.

The and MAagema

[page]3.11-97 -- [para]7 -- Conclusion -- [commenter]Julie Proell -- Pygmy rabbit: You determined MAA individuals because 

impact habitat, increased predation, EPMs and mitigation measures would limit potential impacts. I believe this is the appropriate determination for this species for this project in WY.

Yo

[page]3.11-98 -- [para]9 -- Conclusion -- [comments]Julie Proell -- Wyoming Pocket Gopher: You determined MAA individuals, individuals because impact habitat, increased predation, EPMs and mitigation measures would limit potential impacts. I believe 

this is the appropriate determination for this species for this project in WY.

Yo

[page]3.11-121 -- [para]1-2 -- All -- [commenter]Julie Proell -- EPMs PRC-15, PRC-16, PRC-17. Birds may be impacted even if their nests are within 0. 5 miles of construction.

The req
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100345 U.S. FISH AND 

WILDLIFE (cont.)

[page]3.11-157 -- [para]5 -- 3.11.2.5 entire -- [commenter]Julie Proell -- The proposed Structure Variation with guy wires could 

increase the impact on migratory birds. Additionally, you state that mortality at a given site will cause flight diverters be installed locally. We recommend the use of guyed towers only be used in areas where a lack of avian use has been demonstrated through surveys throughout the year leading up to construction.

The insnot 

[page]3.11-159 -- [para]TESWL-11 -- [blank] -- [commenter]Lynn Gemlo -- What is the source of the information to apply 4 miles and 1.2 miles?

ThiBu

[page]3.11-159 -- [para]TESWL-14 -- [blank] -- [commenter]Lynn Gemlo -- You should be consistent and use the most 

conservative information.

The(e.g(e.galtesta

[page]3.11-160 -- Mitigation Measures on Federal Lands -- [blank] -- [commenter]Jeri Wood -- Mitigation Measures on Federal Lands. TESWL should be applied on all landownership as guy wires have been shown to be detrimental to migratory birds and the restrictions of the Migratory Bird Treaty Act apply regardless of landownership.

The autaut

OthCW

4-64 -- Cumulative Effects -- [blank] -- Jeri Wood -- Cumulative Effects. We agree with the DEIS conclusion that this project 

would have an overall substantial cumulative impact on native vegetation types, including shrub habitat required by sagebrush 

obligate species such as sage grouse.

Yo

[page]4-71 -- [para]Cumulative Effects -- [blank] -- [commenter]Jeri Wood -- Cumulative Effects. The DEIS states that Avian Protection Plan would reduce the potential for mortality for migratory birds and raptors. Development of an Avian Protection 

Plan, with participation by the FWS, should be a requirement by the BLM prior to submittal of a Notice to Proceed. Additional, 

we agree with the statement that the proposed project would have a substantial cumulative impact on migratory birds and raptors, especially if segment 8 is approved in the Snake River Birds of Prey area.

Botcom

[page]4-81 -- [paa]Cumulative Effects -- [blank] -- [commenter]Jeri Wood -- Cumulative Effects. While the project proponents 

have made efforts to establish the line outside the 0.25 mile buffer zone (see general comment above regarding buffer zones), the cumulative effects of this line plus all past, present and future projects proposed across the landscape are substantial. This 

project and all other project will lead to increased habitat fragmentation and regardless of the activity; sage grouse have been documented to be adversely affected by anthropomorphic disturbances on the landscape. This will be especially evident if the proposed segment 7 is approved (see above general comment).

No

[page]C-2, p 2-10 -- [para]Noxious and Invasive Weed Control -- [blank] -- [commenter]Julie Proell -- Noxious and Invasive 

Weed Control. We appreciate the inclusion of this section into the reclamation plan. For how many years will the annual spraying occur?

Noreqfed

[page]C-2, p. 8 -- [para]4.1.2 Seed Mixes -- [line]6 -- [commenter]Julie Proell -- Seed Mixes. What will this sentence say when

completed?

The rev

[page]C-2, p. 9 -- [para]Post-construction monitoring and reporting -- [blank] -- [commenter]Julie Proell -- Post-construction monitoring and reporting. A 3-year period is not long enough to determine whether weed control and seeding measures were 

adequate to mitigate for ground-disturbing activities. Additionally, we recommend the project proponent monitor the density of reseeded areas to ensure the densities are comparable to adjacent communities.

Approcon

[page]C-3, p4-7 -- [para]Table 1 -- [blank] -- [commenter]Julie Proell -- Species Protected in the Gateway West Species 

Conservation Plan. This table should be updated to include the current status of T&E species, i.e. Preble’s meadow jumping 

mouse, Wolverine.

Appro

[page]C-3, p16-20 -- [para]Birds -- [blank] -- [commenter]Julie Proell -- Proposed Plant and Wildlife Conservation Plans. The 

phrase “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,” is 

subjective. The disturbance from a highway is very different from the disturbance from the installation of transmission line towers. You cannot expect that birds will not be harassed by the proposed construction if they are within the recommended spatial buffer area.

Appro

[page]C-4, p. 14 -- [para]OM-25 -- [blank] -- [commenter]Julie Proell -- “If 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.” I recommend including the phrase “Proponents will contact a USFWS biologist.” Whenever a T&E 

species is located within the vicinity of the project area, a biologist from the USFWS should be notified.

ApidechaPOact

[page]C-5, p 2, 1.1.1.1 -- # 1 -- [blank] -- [commenter]Lynn Gemlo -- Should mark those guy wires to minimize impacts Ap

pro
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100345 U.S. FISH AND 

WILDLIFE (cont.)

[page]C-5 p 2, 1.1.1.1 -- # 2 -- [blank] -- [commenter]Lynn Gemlo -- Consider burying these smaller lines because they can cause negative impacts. Can you retrofit existing lines?

Appro

[page]C-5, p 3 -- #4 -- [blank] -- [commenter]Lynn Gemlo -- 0.25 miles is not based on any published literature, is arbitrary. 

Average of 4 mile from a lek was shown in studies in WY to protect 98% of nesting hens. Should consider this information also.

Approcon

[page]C-5, p 5, 1.1.1.2 -- # 1 and # 2 -- [blank] -- [commenter]Lynn Gemlo -- These guidelines replaced by the Core Area Strategy for WY.

Approcon

[page]C-5, p 5, 1.1.1.2 -- [blank] -- [blank] -- [commenter]Lynn Gemlo -- Bates Hole/Shirley Basin Plan-We recommend the use 

of perch deterrents. What “other methods of mitigation” are you referring to?

Appro

[page]C-5, p 6 -- 2 -- [blank] -- [commenter]Lynn Gemlo -- Where in the scientific literature does it support you only addressing impacts within 1km? Impacts can occur and it is recognized there is literature that discusses negative impacts from power lies.

Appro

[page]C-5, p 7, 1.1.2 -- [blank] -- [blank] -- [commenter]Lynn Gemlo -- We recommend you adopt the most conservative restrictions.

Appro

[page]C-5, p 7, 11 1.1.3 -- [blank] -- [blank] -- [commenter]Lynn Gemlo -- As stated in Core Area Strategy, new transmission 

infrastructure must demonstrate that it will not cause declines in sage-grouse populations. How will you demonstrate this?

Appro

[page]C-5 p 8, 9, 10, 1.2 -- [blank] -- [blank] -- [commenter]Lynn Gemlo -- You acknowledge that this data in the draft EIS 3.11-

71 is not peer reviewed and does not provide enough evidence that lek abandonment or decrease in lek attendance will not 

occur due to the transmission lines. Why use this data and base your conclusion on it to say a lek more than 0.65 mile from the powerline will be minimally affected? Sage-grouse have high fidelity to nest sites, you did not consider length of line and

the effect from lines could have already occurred. You need good temporal information to discuss impacts adequately.

Appro

[page]C-5 p 10, 2.1 -- [blank] -- [blank] -- [commenter]Lynn Gemlo -- When did Tetra Tech do their surveys? How many surveys were completed? Locating leks are highly dependent on time of year. This data is now 3 years old. Need have updated lek information to 2011 to be accurate.

Appro

[page]C-5 p 10, 2.1 -- 2 -- [blank] -- [commenter]Lynn Gemlo -- Again, 0.25 mile buffer is not based on any published literature and is arbitrary.

Appro

[page]C-5 p 13, 2.4 -- [blank] -- [blank] -- [commenter]Lynn Gemlo -- “no construction activities......” is not consistent with the

WY Core Area Strategy.

Appro

[page]C-5 p 14, 2.4 -- Top of page -- [blank] -- [commenter]Lynn Gemlo -- Include restrictions for Nevada also. Ap

pro

[page]C-5, p14, 3.0 -- 2 -- [blank] -- [commenter]Lynn Gemlo -- How will impacts be successfully restored? Develop a plan for this specifically. When will the entities be contacted and what if their participation is not secured? Re: in-lieu of payments see 

Naugle et al. Ch4. P. 55 in Energy Development and Wildlife Conservation in Western North America, 2011: should look at 

a.... “biologically based currency for estimating efficiency of offsets and develop a framework for applying proceeds to 

maximize conservation benefits.”

Appro

[page]C-5 p 15, 3.0 -- 1 -- [blank] -- [commenter]Lynn Gemlo -- We do not support the use of crested wheatgrass and forage kochia because should use native species. They don’t provide a lot for sage-grouse. Where is the literature that supports your 

selection of these species? Concerns with not understanding the long term effects from use of forage kochia on the 

environment.

Appro

[page]C-5 p 15, 3.0 -- 1 -- [blank] -- [commenter]Julie Proell -- We recommend that project areas are reseeded or planted with native species that are within the adjacent undisturbed communities. Sage-brush should be included within the list of native species to be seeded and planted in disturbed areas.

Appro

[page]C-5 p 15, 3.0 -- 3 -- [blank] -- [commenter]Lynn Gemlo -- You need to utilize local data on population numbers to 

understand and accurately identify impacts to leks.

Appro

[page]C-5 p 15, 3.0 -- Table 5 -- [blank] -- [commenter]Lynn Gemlo -- How did you determine these ratios? Ap

pro

[page]F.1-49-50 -- Appendix F, Morley Nelson Snake River Birds of Prey National Conservation Area -- [blank] -- [commenter]Jeri Wood -- Appendix F, Morley Nelson Snake River Birds of Prey National Conservation Area. The DEIS 

introduces verbiage for an proposed RMP amendment as follows: “The Gateway West Transmission Line will be allowed to remove limited amounts of sagebrush for construction while maintaining a distance of at least 50 feet from existing or known peppergrass occurrences. These activities will be monitored and mitigated for.” Be aware that the removal of individual sagebrush plants within proposed critical habitat for the slickspot peppergrass constitutes an adverse effect to one of the 

primary constituent elements of slickspot peppergrass proposed critical habitat. If the Project cannot be modified to avoid impacts, formal conference is recommended if sagebrush plants, native forbs, or slickspot microsites within proposed critical 

habitat are expected to be lost or disturbed as the result of project construction, operations, maintenance, or decommissioning.

The list Ro
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100345 U.S. FISH AND 

WILDLIFE (cont.)

[page]J. -- Framework for Sage-Grouse impacts analysis -- [blank] -- [commenter]Julie Proell -- The Framework for sagegrouse impacts analysis for interstate transmission lines should be amended to reflect the recent changes in the location of the 

HEA.

The 

[page]3.11-95 -- [para]3 -- [blank] -- [commenter]Lynn Gemlo -- Again, federally listed as threatened. Place in appropriate 

section

Infosec

[page]3.11-96 -- [para]1 -- Lynn Gemlo -- Effects analysis to focus on 100 meters beyond the 100 yr floodplain. Ca

yea

[page]General -- [blank] -- [blank] -- [commenter]Jeri Wood -- It is our understanding that the BLM will not be conferencing on

candidate species. The DEIS indicates that section 7 conference on the potential effects of the Project will occur for the greater sage-grouse (Centrocercus urophasianus). Candidate species in Idaho that could also be evaluated in section 7 

conference include the Goose Creek milkvetch (Astragalus anserinus), the whitebark pine (Pinus albicaulis), and the wolverine 

(Gulo gulo luscus). If the BLM does consider section 7 conferencing, then all candidate species that may be affected by the 

Project should be included. Either way the DEIS needs to accurately reflect whatever action the BLM will take with regards to 

candidate species.

The gro

cro

[page]General -- [blank] -- [blank] -- [commenter]Julie Proell -- I recommend that avoidance, minimization, and mitigation 

practices that are supported by the Agencies on public lands be implemented throughout the project alignment, regardless of land ownership.

The as 

[page]General -- [blank] -- [blank] – [commenter]Julie Proell -- For Segment 1E, I am more supportive of Alt 1E-A and Alt 1E-C 

because of the shorter overall lengths, lesser impacts to wildlife, and lesser impacts to G. sage-grouse core area. It is difficult 

to support either the proposed segment 1E comparison with Alt 1E-B or Alt 1E-B because the proposed has lesser impacts on many wildlife species, though passes through a significant amount of G. sage-grouse core areas, while Alt 1E-B avoids G. 

sage-grouse core areas, but has greater impacts on other wildlife and their habitats.

Yosegthe Ch

[page]General -- [blank] -- [blank] – [commenter]Julie Proell -- For Segment 1E, I am more supportive of Alt 1E-A and Alt 1E-C 

because of the shorter overall lengths, lesser impacts to wildlife, and lesser impacts to G. sage-grouse core area. It is difficult 

to support either the proposed segment 1E comparison with Alt 1E-B or Alt 1E-B because the proposed has lesser impacts on many wildlife species, though passes through a significant amount of G. sage-grouse core areas, while Alt 1E-B avoids G. 

sage-grouse core areas, but has greater impacts on other wildlife and their habitats.

Yosegthe Ch

General -- [blank] -- [blank] -- Julie Proell -- For Segment 1W, I am more supportive of Alt 1W-A because it is shorter than the proposed comparison segment and has lesser impacts on many wildlife species and their habitats.

Yo

[page]General -- [blank] -- [blank] – [commenter]Julie Proell -- For Segment 2, I am more supportive of the proposed segments 

instead of the alternatives for 2A and 2B because of the lesser impacts on wildlife and their habitats. However, I am more supportive of Alternative 2C over the portion of the proposed alignment because it minimizes impacts to sage grouse. WILD 7, 

8, 10, 3, and PRC 12-14 and 18-20, and others should help to minimize impacts on the large number of raptor nests within 1 

mile of the alignment.

Yosup

[page]General -- [blank] -- [blank] – [commenter]Julie Proell -- For Segment 2, I am more supportive of the proposed segments 

instead of the alternatives for 2A and 2B because of the lesser impacts on wildlife and their habitats. However, I am more supportive of Alternative 2C over the portion of the proposed alignment because it minimizes impacts to sage grouse. WILD 7, 

8, 10, 3, and PRC 12-14 and 18-20, and others should help to minimize impacts on the large number of raptor nests within 1 

mile of the alignment.

Yosup

[page]General -- [blank] -- [blank] – [commenter]Julie Proell -- For Segment 4, it is difficult to determine which portion of the 

segment (between the proposed alternative and Alt 4A) would have the least impacts on wildlife and their habitats. I do not support the proposed or the alternatives. The proposed alignment has fewer nests within 1 mi of the alignment and has lesser impacts on riparian habitat. However, Alternative 4A parallels an existing 345 kV line and has the least amount of impacts in 

terms of new features on the landscape and lesser impacts to many wildlife species (except the most through grizzly bear 

habitat). Alternative 4F has the least impact to Black footed ferret, sage grouse core and key areas, and Mtn. plover habitats,but impacts much more of Canada lynx habitat than any other alignment.

Noto pnew des

[page]General -- [blank] -- [blank] – [commenter]Jeri Wood -- Candidate Species. The DEIS currently addresses effects of the 

Project on the Goose Creek milkvetch and the whitebark pine, however the DEIS does not appear to address effects of the 

Project on the wolverine. The wolverine became a candidate for listing under the Endangered Species Act (ESA) as of 

December 14, 2010. For recent information on the wolverine, see the FWS December 14, 2010 Federal Register notice. We 

recommend that the final EIS addresses potential effects of the Project on the wolverine.

The 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100345 U.S. FISH AND 

WILDLIFE (cont.)

[page]General -- [blank] -- [blank] -- [commenter]Jeri Wood -- RMP Amendments. In Appendix F, numerous land use plan amendments required for implementation of the Project are discussed. Many of the existing land use plans (at least in Idaho) 

are dated and have limited conservation measures identified for special status species. As conservation of species based on 

these older RMPs are likely not adequate for species survival and recovery, we recommend that specific conservation 

measures for special status species identified in the 2006 Conservation Agreement between BLM and FWS be addressed in the final EIS for this Project. In addition, the 2009 Conservation Agreement between BLM and FWS for the slickspot peppergrass should also be adhered to in the development of this Project. These Conservation Agreement conservation measures may be replaced by measures that are provide greater conservation value or are based on more recent scientific 

information pertinent to individual species and their habitats.

InfoCoCo

[page]General -- [blank] -- [blank] -- [commenter]Jeri Wood -- Segments. The FWS has concerns with certain segments of the 

proposed action and alternatives. Segments 9, 8, and 7 cross three Partners for Wildlife wetland projects that were funded by 

the FWS and other partners to promote the conservation of migratory birds. One is Bruneau River Ranch near the Bruneau River (Milepost 100) on segment 9, alternative 9C, another one is Spring Cove Ranch near Pioneer Reservoir (between 

Mileposts 30 and 40) on segment 8, and the third one is Six S Ranch east of Declo on Marsh Creek (Milepost 70) on proposed 

segment 7, and alternative 7D. For all of these sites the FWS recommends avoiding these wetlands and install bird diverters 

or markers on lines near these areas to reduce the possibility of avian fatalities. If ground disturbance is necessary, site 

specific management plans should be approved by the landowner, in conferencing with the FWS, and should include any 

proposed mitigation to offset the loss of wetland habitat. If segment 7 is approved for permit, we would support the alternative 

proposed by Ducks Unlimited to replace a portion of alternative 7D.

Se

[blank] -- [blank] -- [blank] -- [blank] -- Segment 9. Segment 9, alternative 9D, and G appears to be planned to span C.J. Strike 

Reservoir and a portion of the proposed route of segment 9 (between Milepost 90 and 100) will cross the Bruneau River. The 

Bruneau River is of significant value for migratory birds. The combination of lacustrine, palustrine, riverine and upland mitigation sites provides support for at least 240 species of birds (most of which are migratory bird species, several such as the long billed curlew, are of high priority to the FWS). The C.J. Strike Area is identified as a globally important bird area by the 

American Bird Conservancy. Significant investments of federal, state, and private funds have occurred in the Bruneau River valley to enhance fish and wildlife habitats. As a result of Federal Power Act and Fish and Wildlife Coordination Act conferencings between the IDFG, FWS, BLM and the FERC, the Idaho Power Company, as a requirement of their FERC licensing for the C.J. Strike Hydroelectric Project, purchased and is managing an extensive acreage of property for wildlife, 

wetland, and recreational mitigation. These mitigation sites are located on the Bruneau River, the Snake River, and the pool area of the C.J. Strike Reservoir. The Idaho Department of Fish and Game added to the value of the Bruneau River area by 

purchasing and managing a several Wildlife Management Areas. Recently, our FWS Partners for Fish and Wildlife program has been cooperating with Ducks Unlimited to restore and enhance wetlands on private lands adjacent to the WMAs in the 

Bruneau River valley. These partnership projects should further enhance the fish and wildlife value of the area. IDFG notes 

that upwards of 90,000 ducks and 12,000 geese occupy the WMA during some winter seasons. Concentrated daily and seasonal bird movement should be anticipated between C.J. Strike Project area and surrounding feeding/nesting habitats. 

Bald eagles commonly use the areas in late fall and early winter. High concentrations of staging waterfowl provide available 

prey. Golden Eagles occasionally nest along the basalt cliffs of the reservoir, and are present late in the area through early winter.

The list 

Ro

[page]General -- [blank] -- [blank] – [commenter]Jeri Wood -- Any decreases in habitat functions or value of the mitigation sites 

will need to be offset by the Idaho Power Company. I would recommend acquisition and restoration of currently damaged or at 

risk wetland/riparian habitats for the offset any losses to habitat functions and values. I would recommend at least a greater than 1:1 ratio of acres impacted to property purchased to allow for the uncertainty related to wetland creation/enhancement. 

Purchasing existing functional wetland/riparian habitats will have no mitigation value, unless it is at an otherwise legal/imminent threat from conversion/development.

No

[page]General -- [blank] -- [blank] – [commenter]Jeri Wood -- Segment 7. The FWS does not support any of the alternatives described in segment 7 nor do we support the proposed action for segment 7. This area supports a high concentration of sage 

grouse and key habitat in Idaho and would increase habitat fragmentation and loss of habitat. Installation of segment 7 would also increase the possibility of additional energy projects and would cumulatively lead to an adverse effect on sage grouse. 

We are supportive of segment 6, with appropriate timing restrictions and pre-construction surveys, as this area is already disturbed due to the existing 345kV line.

The app

We are supportive of segment 6, with appropriate timing restrictions and pre-construction surveys, as this area is already disturbed due to the existing 345kV line.

The inc

[page]General -- [blank] -- [blank] -- [commenter]Jeri Wood -- Segment 8. In general, segment 8 creates the potential for 

significant adverse effects on multiple species of concern, including raptors nesting in the Snake River Birds of Prey Area and

Lepidium papilliferum. Based on the assessment in the DEIS, we do not support this proposed route or its alternatives.

Yotab
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100345 U.S. FISH AND 

WILDLIFE (cont.)

[page]General -- [blank] -- [blank] -- [commenter]Jeri Wood -- Segment 5. For segment 5, the FWS is more supportive of alternative 5C. This alternative seems to have the least impacts to wildlife of concern and important habitat types, including shrublands and native grasslands.

Yo

[page]General -- [blank] -- [blank] -- [commenter]Jeri Wood -- Buffer Zones and Timing Restrictions. The FWS recommends 

that the FEIS include a consistent application of buffers and timing restrictions across the entire transmission line. For example, Wyoming Core Areas require that no more than 5% impact can be allowed within the area. This standard should be applied to Idaho key habitats. While each state and the BLM District have their own buffers and restrictions, for this project we 

recommend using the most conservation buffers and restrictions and apply them to the entire transmission line. Another 

example of inconsistency in application of buffer zones on Federal lands is the Ruby Pipeline project. This project required that 

the project proponent conducted surveys for leks within 2 miles of the pipeline and required all construction be avoided within

4 miles of a lek from March 1 and June 15 (in Utah).

The autautand req

[page]General -- [blank] -- [blank] -- [commenter]Jeri Wood -- Substations. The FWS does not support development of the 

Cedar Hill Substation. Similar to our concerns with the proposed segment 7, the Cedar Hill Substation is near a high 

concentration of sage grouse and key habitat. Development of this substation would add a significant cumulative effect on the 

species because it will lead to additional energy developments in the area. These same concerns apply to development of the Rogerson Substation.

Yosup

[page]General -- [blank] -- [blank] -- [commenter]Jeri Wood -- Mitigation. The FWS believes that release of the DEIS was 

premature and should have been released once the Habitat Equivalency Analysis and Density of Disturbance Calculation is completed. Both of these processes will affect mitigation for sage grouse and the public should have an opportunity to review and comment on that mitigation. At a minimum, the BLM should provide a longer than normal review process for the FEIS to 

allow the public to review results of the HEA and DDC.

A sgro

100346 U.S. ARMY CORPS 

OF ENGINEERS

After consideration of all these factors, the USACE prefers the proposed route with adoption of Alternative 1E-C. Yo

Seof Adet

We would support adoption of Alternatives 5A, 7B, 8A, or 9A. Yo

sup

Much of the predicted wetland losses would be due to construction of permanent roads, primarily in the Bear Lake Valley near Montpelier, Idaho. Segment 4 does not include an alternative route around wetlands in this area, which is justified based on numerous logistical constraints documented in Section 2.4.5. However, the USACE could consider alternative road networks 

or other forms of access to the area during its permit evaluation to further reduce wetland losses.

The Vabee

We do not support adoption of Alternatives 4A, 4B, or 4C due to similar issues concerning road construction through extensive 

wetlands adjacent to the Bear River near Cokeville

Yosup

It would be beneficial to include more details in the FEIS on proposed road networks and alternative access methods in areas where wetland losses for a single road crossing could exceed 0.50 acre.

No

Proposed compensatory mitigation measures through establishment of an in-lieu fee program or as permittee responsible inkind replacement as defined in Section 3.9.2.2 are acceptable methods of compensation for wetland losses. We would like to 

study these mitigation options and disclose more details in the final EIS.

Funto a

We understand that estimates of wetland impacts presented in the DEIS are based on the best available information because 

completion of delineations for each alternative in accordance with the Corps of Engineers Wetland Delineation Manual is simply not feasible. Delineation of wetland boundaries and other waters of the U.S. would be necessary when obtaining 

authorization for specific activities. Accurately defining compensatory mitigation requirements is not possible either until actual 

losses are defined through some form of permit process. We agree that these and other future regulatory requirements are 

adequately documented in Sections 1.2.3, 3.9, 3.16, and 4.4.10.

Yo1.2

100347 IDAHO OFFICE OF 

ENERGY RESOURCES 

we want to register our strong objection to the fact that BLM did not designate a Preferred Alternative in the Draft EIS The 

whwe

100348 CRAIG 

CASTAGNETO, RUSTY JOHNSON, ALLEN T NOBLE, MARK NOBLE 

Our comments are directed at the portion of the DEIS addressing the proposed route segment 9e.2 and segment 9g of the alternate route 9B. Both segments would bring the proposed high voltage power line through our agricultural land and would 

directly and adversely affect our farming operations.

Yo
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100348 CRAIG 

CASTAGNETO, RUSTY JOHNSON, ALLEN T NOBLE, MARK NOBLE (cont.) 

Our comments are directed at the portion of the DEIS addressing the proposed route segment 9e.2 and segment 9g of the alternate route 9B....when this project was first proposed, the line location was to the west of our projects. Later, without any 

input from or discussion with us, the proposed location was changed, purportedly because of height restrictions associated with the Saylor Creek bombing range....we request that 1) detailed consideration be given to moving the line back to its 

original proposed location west of our project and that we be involved in the discussions concerning the height restrictions and 

possible variances, and 2) consideration be given to routing the line in other locations that avoid our farm 

completely...Attached to these comments is another aerial photograph labeled Map 2 that presents an alternate alignment for 

the power line....These comments include a third aerial photograph labeled Map 3. This aerial shows a second proposal that 

would also serve to lessen the impact on our farms by keeping the line on rangeland to the extent possible and away from 

productive agricultural ground. We strongly oppose either of the alternatives studied in the DEIS. We propose that the final EIS require one of the following in our geographical area discussed in these comments: 1) Return the location of the power line to the original proposed alternative that had the line a couple of miles west of our 

projects; 2) Move the location of the line to the alignment shown on our Map 2 and institute a land exchange with the BLM to replace affected agricultural land with similar ground adjacent to our projects; or 3) Move the location of the line to the alignment shown on our Map 3 and institute a land exchange with BLM to replace affected agricultural land with similar productive ground adjacent to our projects.

The conthe 

100349 JOANN WYANT You can put it next to the one that is there now Se100350 TROUT UNLIMITED, 

WYOMING

The DEIS (Chapter 3) discusses potential environmental impacts but briefly as they affect streams and river systems. The 

development of permanent 8-foot wide roads to each transmission tower and the construction of pads to hold transmission towers within wetlands and riparian areas must account for downstream impacts both short-term and long-term. If at all possible, such development must be avoided in these areas. Impacts from sedimentation and water withdrawal used during 

the construction of this project have the potential to negatively impact the various river drainages within this project. Of significant concern to TU is the potential for the creation of fish passage barriers, impeding fish movements. ...if a road 

crossing or other surface disturbing activity occurs in an area that serves as habitat for fish during any time of the year the

crossing, or surface disturbing activity, needs to be constructed in a manner that does not create a barrier to fish passage. 

Specifically road crossings of streams that fish occupy for any part of the year should be constructed with a bottomless culvert 

with a width greater than the bankfull width of the stream. Fast moving water through narrow culverts can be detrimental to fish movement, including preventing opportunities for resting places. Culverts that are too wide disperse water to a thin layer 

becoming too shallow for fish to pass through. Further analysis for all river and stream crossings should include assessments that take into account the specific fish species, their life-span activities (the length of travel necessary along a river system to 

acquire food and mates), the river system itself, potential for non-native or invasive species to access native habitat, etc. The effects of poorly functioning culverts extend beyond the water’s edge, impacting water dependent species such as mammals, 

birds, amphibians, and insects as well. Finally, repairing poorly installed culverts is expensive. Developing appropriate culvert plans with appropriate size, placement, and maintenance prior to construction ensures watershed protection and successful 

fish passage. In the DEIS discussion for Roads and Culverts (Appendix B), plans are proposed for developing roads in areas with greater than 60% slope. TU feels there is a significant problem in developing roads on slopes greater than 40%; most land use plans 

have NSO (No Surface Occupancy) language that prohibits such development. Erosion, slides, hazards associated with such roads, and difficult maintenance all contribute to unstable road issues.

Disin S3.1are 

The DEIS does not reference bull trout due to the date of the fish and wildlife analyses which occurred for the DEIS. However, since new habitat designations have occurred in Idaho, we recommend the BLM review any potential impacts to bull trout 

habitat and implement appropriate mitigation measures.

Bu

The DEIS fails to address all the cutthroat trout identified in our comments, other than referencing Bonneville cutthroat 

occurring in Bear Lake (Ch. 3.10-18) and the Yellowstone cutthroat in the Table discussion on Affected Environment and Environmental Consequences (Ch 3.10-11; Table 3.10.2). We suggest, based on our information, that the Final EIS include 

more analysis of the cutthroat trout and other wild trout that may be impacted by this project.

Trostapro

In order to keep Yellowstone cutthroat trout populations stable, effective mitigation and management measures must be implemented to avoid impacting important habitat.

Mit

Westslope cutthroat (WCT) populations include habitat areas in Idaho and has been identified in the DEIS as a cutthroat 

species occurring within the project boundaries. However, the BLM may want to reassess this statement as most of the 

science and agency data shows its habitat range as further north (see Figure 7) from the proposed transmission corridor.

Info

as more research and information gaps are revealed about the understanding of Snake River fine-spotted cutthroat, the BLM 

must continue to implement strong conservation measures to protect stream habitat for this subspecies.

SeFIS
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100350 TROUT UNLIMITED, 

WYOMING (cont.)

The WGFD provides extensive discussion on the importance of amphibians and riparian/wetland habitat management as 

affected by renewable energy development in their “Wildlife Protection Recommendations for Wind Energy Development in Wyoming” (September 2010). The DEIS does not acknowledge this document and TU recommends this be included in the 

Final EIS along with the implementation of the document’s mitigation measures.

The to wand 

Several species of native trout are known to occur in Wyoming and Idaho and have been identified as occurring within the transmission corridor project, including Colorado River cutthroat (Oncorhynchus clarkii pleuriticus), Bonneville cutthroat 

(Oncorhynchus clarkii Utah), Snake River cutthroat (Oncorhynchus clarkii spp), Yellowstone cutthroat (Oncorhynchus clarkii 

bouvieri), and Westslope cutthroat (Oncorhynchus clarkii lewisi). In addition, populations of bull trout (Salvelinus confluentus) 

are known to occur in the Snake River and Columbia River basins in Idaho and Oregon. The DEIS does not mention reference 

to these management guidelines for each species but TU recommends such documentation and management guideline implementation be included in the Final EIS

The addtheimpthis For

Because the transmission corridor’s proposed route and alternatives are located in historic Colorado River cutthroat trout habitat, the BLM needs to include this information in the Final EIS

The to tSp

While the amount of disturbance to riparian and wetland areas in the long-term may be minimal, downstream impacts must be considered and accounted for as they might impact sensitive species in this environment.

Do

Inadequate mitigation and stipulation measures are not consistent among the numerous BLM offices in Wyoming and Idaho. Establishing universal mitigation and stipulation measures at the front of this proposal which provide for protection during the 

development, construction, and operational phases and contribute toward a more successful and acceptable portfolio for renewable energy development projects.

Mitaut

The discussion on Wetlands and Riparian Areas in the DEIS fail to coordinate the cumulative impacts from the loss of 

wetlands and riparian areas to construction and development activities associated with this project.

The Se

TU appreciates the project proponents’ commitment to avoid wetland and riparian areas during construction activities. In 

general, TU would like to see the least amount of impact possible to rivers and streambanks. This means providing protective 

setbacks from road intrusions and surface disturbance from construction activities, staging activities, and associated industrial 

pollutants that occur with these project actions. For definition purposes, we recommend a minimum 500-foot for all perennial 

waterbodies and a one-quarter mile buffer on rivers and streams containing sensitive or threatened species. Further, we 

recommend this buffer measure be implemented on all public lands within the project corridor....The Analysis Review, however, considers a 500- foot buffer from the centerline, which would mean a 250-foot buffer from either side of centerline.

Noreg

We support the BLM’s and the proponent’s attempt to locate approximately 55 percent of the transmission route along designated corridors or within current corridors.

Yo

...we prefer alternative 9B for section 09 since it parallels an existing transmission line and avoids crossing Salmon Falls Creek 

in either the eligible or designated wild and scenic river sections.

Yo

TU recommends the BLM update the 2008 Analysis Area data to account for the more recent development proposals in both 

renewable and nonrenewable energy development.

Tex

TU recommends the BLM update the 2008 Analysis Area data to account for ... updated state wildlife agency habitat and fish 

and wildlife population data

The 

Although alternative 4B-C, TU’s preferred alternative, also crosses the sage-grouse core area, it is associated with lower 

quality habitat and existing corridors so there will be less additional habitat fragmentation. These southern most alternative sections follow existing corridors, highways and railways. From the juncture of alternative 4B-C, we would then support the alternative section that becomes section 4E which follows Wyoming Highway 30. [Note: This text indicates that TU supports 4E, but the enclosed map shows their preferred route as 4D.]

Whshosup

We would recommend against alternative 4B-D The 

comalte

...we recommend baseline water quality monitoring in areas where stream and river crossings require unusual construction 

activities, have permanent structures within the riparian or wetland boundaries, and road access is year round. Baseline water 

sampling prior to the beginning of construction activities, followed by routine annual water sampling should be implemented as part of federal management plans. This is particularly important in areas where steep slopes are accessed, in forested areas 

where important vegetation cover along streambanks has been removed, and in unstable or fragile soil areas. In addition, remediation plans should be developed to compliment the water quality monitoring should results from the monitoring show 

impacts to water quality and quantity.

Noreg
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100350 TROUT UNLIMITED, 

WYOMING (cont.)

We suggest Appendix I be updated to reflect the numerous revised Land Use Plans, state agency mitigation plans for various 

energy actions, and include all BLM field offices and their stipulation measurements. Specifically, the following documents 

were not identified in the DEIS: 1. Wyoming Statewide Wildlife Action Plan. The WGFD has updated their Statewide Wildlife Action Plan (SWAP) to reflect new 

species designations, management objectives, and action plans (April 2011). This should be included in the Final EIS. No mention of any type of plan was identified for Idaho, though one was identified for Nevada (Ch 3.10-7). 

2. Wyoming Game and Fish Oil and Gas Mitigation Recommendations. The WGFD has updated the “Oil and Gas Recommendations” to reflect changes and data updates (May 2010). Included are buffer and timing restriction discussions and recommendations which the BLM should review. 3. Wyoming Game and Fish Wind Recommendations. The WGFD has developed a document which provides management 

recommendations for wind and renewable energy development (2010). This document should be included in the Final EIS. 

4. Wyoming BLM Statewide Reclamation Policy. The Wyoming BLM State Office has developed a statewide set of reclamation 

policy standards which strives to update and coordinate the numerous and often inconsistent field office reclamation plans for 

energy development. We recommend the Final EIS include this in their mitigation requirements as it is designed to create a more uniform policy standard that implements state-of-the-art reclamation practices. 5. Numerous Outdated BLM Resource Management Plans. The DEIS, in Appendix I, references numerous outdated RMPs. TU understands the amendments will be made to all land use plans for both the USFS and the BLM; however, amending 

outdated environmental plans without revising management objectives and resource conditions may not provide the best 

management guidance. The BLM should carefully review each RMP and assess whether NEPA is adequately addressed 

under the old management plans as applied to this transmission project.

ApWhmareqAp

in Appendix I, within the Wyoming BLM field offices, three different sets of stipulations have been identified for this project, 

ranging from limited to 500-foot- to 1,000-foot buffers on fish-bearing streams. In Idaho, there is a gapping lack of stipulations 

discussed for stream access and spawning timing limitations. Overall, the lack of consistent and uniform stipulations and buffer 

setbacks potentially increases the risk of contamination to streams based on the proponent’s ability to keep track of the variety 

and numerous types of local mitigation measures. Standardizing a set of streambank stipulations and setbacks for a linear 

project such as this provides the proponent with upfront expectations and certainties while creating a stronger plan of development for resource protections

Diffspemaon autreq

Appendix E lacks maps illustrating Key Habitat and Restoration Areas for Wyoming. The map for Idaho in Appendix E is 

specific to sage grouse habitat and TU suggests a similar map be prepared for Wyoming since considerable sage grouse habitat exists within this state.

TheWyAp

Buffer zones for riparian, wetlands, and water bodies lack consistency and widely differ among individual BLM offices in both Wyoming and Idaho. Strong buffer or setback preferences should be incorporated in order to minimize impacts to surface and 

water bodies where development occurs.

Buf

pro

TU recommends the BLM include all new publications, regulations, and recommendations regarding best management practices in the Final EIS as they relate to renewable energy development. Specifically, the Western Governors’ Association (WGA) released their “roadmap” which highlights key information compiled from existing national, regional, and state studies 

regarding renewable energy development from concept to construction (“Renewable Energy Transmission Roadmap”. 

Western Governors’ Association. June 2010).

Adinc

that alternative is shown in purple (01W) on the map as TU’s preferred alternative for this section of the transmission system. The 

lineAlteana

The DEIS’s suggested seasonal stipulations should be, at a minimum, universal for all wildlife and fish affected by this project on public lands and especially specific for sensitive species, state species of concern, and threatened/endangered/candidate 

fish and wildlife species identified as potentially being impacted by the proposed project.

Sevar

reg

Reclamation measures identified in the DEIS should be updated to reflect new standards and technology, including reference 

to the Wyoming BLM Statewide Reclamation Policy of 2010. Without adequate successful reclamation practices, the proposed project could adversely impact sensitive species and species of concern, in addition to big game habitat and migration 

corridors

Reage

100351 KADE LUSK In your Environmental impact statement you fail to recognize a sage grouse Lek in Segment five in the Arbon Valley. This Lek 

is in the proposed route of the transmission line. The Idaho Fish and Game have declared this Lek active.... This is a 

developing lek. Please consult the Idaho Fish and Game on this issues and consider using an alternate route. The current route goes right by this lek and right through the center of population for the community of Arbon Valley.

The wildpro
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100352 TOWN OF 

GLENROCK

Thank you for supplying the Town a more detailed map of the proposed location of the transmission line. With the updated town limits drawn on the map, the line is clearly within the town limits. This area was annexed to the town in 2004 as a growth

area for the town and zoned Commercial Highway Business (a copy of which is attached). At this time we are opposing the location of the transmission line and requesting the line be moved to one of the feasible alternatives (green lines) as shown on the map - Segment 1E/1W.

Yothe Procurfrom 

Thank you for supplying the Town a more detailed map of the proposed location of the transmission line. With the updated town limits drawn on the map, the line is clearly within the town limits. This area was annexed to the town in 2004 as a growth

area for the town and zoned Commercial Highway Business (a copy of which is attached). At this time we are opposing the location of the transmission line and requesting the line be moved to one of the feasible alternatives (green lines) as shown on the map - Segment 1E/1W. [1W-A is one of the alternatives, but isn't an option for 

coding]

Yoincthe Glebee

100353 ELMORE COUNTY 

GROWTH AND DEVELOPMENT DEPARTMENT

Section 3.17 Land Use - Page 7 "A CUP would not be necessary in Elmore County for construction of transmission lines. However, other facilities, such as 

storage yards, would require a CUP." A Conditional Use Permit ("CUP") is necessary for the construction of transmission lines. Elmore County adopted a new 

zoning and development ordinance ("ordinance") on May 13, 2009. Section 6-8-174.E.3 under Public or Quasi-Public uses states: "Electric transmission lines and substations shall require conditional use approval."

Infoline

I have attached a map of the wind farm and solar generating facilities locations. If you have any questions regarding this letter 

please contact me at [Phone]. Thank you for providing me the opportunity to provide comments. [see map attached to letter #100353]

Ba

Section 3.17 Land Use - Page 116 As a point of clarification Elmore County has approved one planned community with another at the Planning and Zoning 

Commission ("commission") for the public hearing process. I have attached a map that shows the boundaries of the 

developments. [see map from comment for location -

ThadevPro

Section 3.04 Socioeconomics - Page 23 Table 3.4-15 It is my understanding that remote portions of Elmore County are served by the Atlanta Power Company. I do not believe any 

of the proposed transmission locations cross Atlanta Power Company service areas.

Thi

Section 4.0 Cumulative Effects - Page 30 Table 4.2-7 I have provided some clarification on the existing wind farms within Elmore County. It appears there may have been some 

confusion as the names have been changed. It is my understanding that Mountain Home, John Deer became Hot Springs and Bennett Springs. Operational Wind Farms in Elmore County -Camp Reed Wind Farm, Camp Reed, LLC, 22.5MW+/- -Hot Springs Wind Farm, Hot Springs LLC, 21 MW +/- -Bennett Springs Wind Farm, Bennett Creek, LLC, 21 MW +/-

InfoCo

Section 4.0 Cumulative Effects - Page 46 Table 4.2-15 There have been several new wind farms approved in Elmore County. In addition, the Alkali project by Rick Koebbe is expected to be commissioned on September 23, 2011 and is now know as the Sawtooth Wind Farm, with Proponent Power Works, Rick Koebbe and a total production capability of 22MW+. As it is listed in the table Alkali and Sawtooth are the same project. I have provided a list of the following approved wind farms that are scheduled to start construction within the next year. 

Approved pending construction Wind Farms in Elmore County -Cold Springs Wind Farm, Cold Springs Windfarm LLC, 20MW+/- -Desert Meadow Wind Farm, Desert Meadow Windfarm LLC, 20MW+/- -Hammett Hill Wind Farm, Hammett Hill Windfarm LLC, 20MW+/- -Mainline Wind Farm, Mainline Windfarm LLC, 20MW+/- -Ryegrass Wind Farm, Ryegrass LLC, 20MW+/- -Two Ponds Wind Farm, Two Ponds Windfarm LLC, 20MW +/- -High Mesa Wind Farm, High Mesa LLC, 40MW +/- (Only 16.7 MW in Elmore County remainder is in Twin Fall County) -Tumbleweed Wind Farm, Tumbleweed LLC, 5-10MW+/- (Part of a joint solar/wind project.)

Infoinfo
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100353 ELMORE COUNTY 

GROWTH AND DEVELOPMENT DEPARTMENT (cont.)

Section 4.0 Cumulative Effects It may be appropriate to identify potential solar power facilities over 10MW production capability. Elmore County currently has

three approved solar facilities awaiting construction. I am unsure of the construction schedule of these facilities. I have provided a list of the approved solar facilities in Elmore County. Approved pending construction Solar Farms in Elmore County -Tumbleweed Solar Farm, Tumbleweed LLC, 5-10MW+/- (Part of a joint solar/wind project.) -Grand View Solar PV 1, 20 MW solar farm -Grand View Solar PV 2, 20 MW solar farm

Info

pro

100354 JOHN H 

DEHLER,DORIS DEHLER 

2.8.1 Alternatives lEA, 1E-B, and 1E-C compared to the Proposed Route 

Paragraph 2: "Alternative 1E-A was developed as an alternative to the northern segment of the Proposed Route in response to visual and 

land use impact concerns expressed by local citizens along the Proposed Route. This alternative would minimize the effect of separate transmission lines on private lands located along the existing Dave-Johnston-Rock Springs transmission line corridor. Alternate 1E-A is shorter than the comparison portion of the Proposed Route (16.1 miles vs. 17.6) but would have more 

impacts on visual resources as seen from residences in the Glenrock area". The Proponent' (Rocky Mountain Electric) first proposed 1E-A as the Proposed Route and then the report says that it was 

changed in response to Glenrock citizens. The report would make you believe that the Proponent's made the change to IE to 

satisfy the concerns of Glenrock citizens. Your report again says that 1E-A would have more impact on visual resources. 

According to the very vague map this is not correct.

Noconpro

 Chapter 2 -Alternatives 2-173 

2.8.1 Alternatives lEA, 1E-B, and 1E-C compared to the Proposed Route Paragraph 2: "Alternative 1E-A was developed as an alternative to the northern segment of the Proposed Route in response to visual and 

land use impact concerns expressed by local citizens along the Proposed Route. This alternative would minimize the effect of separate transmission lines on private lands located along the existing Dave-Johnston-Rock Springs transmission line corridor. Alternate 1E-A is shorter than the comparison portion of the Proposed Route (16.1 miles vs. 17.6) but would have more 

impacts on visual resources as seen from residences in the Glenrock area". Argument: Which is it? Alternative 1E-A was developed an alternative to visual and land use impact concerns expressed by 

local citizens along the Proposed Route or Alternative 1E-A would have more impact on visual resources as seen from 

residences in the Glenrock area.

Seof Adet

 Chapter 3 -2.2-97 

Segment 1W (Segments 1W(a) and 1W(c) -Windstar to Aeolus "Alternative 1W-A is a 16.2 mile alternative located near the town of Glenrock, which was the Proponents' Rocky Mountain Power) initial proposal before moving the Proposed Route at the suggestion of local landowners in order to avoid the more settled area around Glenrock." Argument: If Alternative 1W-A was the Proponents' initial proposal, which is clearly more consistent with the wishes of local landowners and Glenrock residents. Also, this was initially the only route that was presented to Glenrock residents.

NocurPre

 Chapter 3 -Affected Environment and Environmental Consequences 3.2-88 

Segment 1E -Windstar to Aeolus "Alternative 1E-A is a 16.1 mile alternative along the north end of Segment of 1E, which was the Proponents' initial proposal 

before moving the Proposed Route at the suggestion of local landowners to avoid the more settled area around Glenrock" Argument: This is very unclear. If 1E-A was the Proponents' (Rocky Mountain Power) initial proposal, this route would have 

avoided the settled area of Glenrock in the first place. Now, the Preferred Route of 1E runs through Mile Marker 162 -169 on 

the North side of I-25 through the Exit 165 into Glenrock and destroying any views of the landscape to the South. This severelylimits any potential future development between Glenrock and I-25, which is the only direction available due to wind turbines to 

the North.

SeEIS the Sein tCh

 Chapter 3 -3.2-96 

Segment 1E Conclusion "The comparison portion of the Proposed Route would have more evenly distributed visual impacts than Alternative 1E-A due 

to the Proposed Route being located 2.0 miles closer to Glenrock, creating a new visible disturbance from the many views of the residents with the town, and Alternate 1E-A being located closer to sensitive viewers mainly along Deer Creek". 

Argument: How can you say that the Proposed Route 1E would have more evenly distributed visual impact and in the same 

sentence say that the Proposed Route will be located 2.0 miles closer to Glenrock, creating a new visible disturbance from the 

many views of the residents within the town.

SerevAlteana
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100354 JOHN H 

DEHLER,DORIS DEHLER (cont.) 

I am requesting that a meeting be held in Glenrock for the citizens of Glenrock with a presentation of Proposed Route E1 and 

where exactly it will run between Mile Marker 162 -169 and photographs of the land these power lines and towers would be located. Also, discussion and photographs of where Alternative E1-Awould run in conjunction to Glenrock and I-25.

Sein tCh

 What cooperating agencies and public will you be working with in an attempt to reach a consensus? Will the City of Glenrock 

Mayor and County Commissioners be involved in this decision making process?

The like1E exilist det

100355 RON AND DONNA 

MILLER 

This thing of needing 2-250kv lines leaving Windstar instead of l-500kv just doesn't seem right. Looks like Warren's boys are trying to get a bunch of local collector lines installed as part of this project. Still if 2 lines are necessary, they should follow the 

same route, same towers ... after all they go to the same place.

Twdis

 It looks like a route north of Glenrock for both lines would cause the least disruption and not come close to any houses. The 

land north of Glenrock certainly has less development potential. This is the route the Railroad and numerous pipeline 

companies have chosen simply because there is a large corridor with virtually no development. Grass doesn't even grow good 

through there.

Yotab

 The E1 line is extremely unpopular here in Glenrock, as you probably already know. We don't have the lush trees and 

vegetation enjoyed by others to mask the looks of power poles. We truly value the look of our wide-open spaces. These lines 

are a huge distraction and really affect the quality of life. Placing this line right in the town's entrance really doesn't sit well. It 

has to be totally immoral to put this line through town. As small as Glenrock is, it wouldn't take much of an engineer to pick a 

better route

YoSeconpro

 First of all I hope there has been an independent review of the need for this project...not from the corporate point of view but 

from what is in the best interest of the country as a whole. Is this needed and how well does it fit with all the power generation facilities needs? Does it improve the overall system reliability? I am really concerned this project is another billionaires' plan to 

gain advantage in the market. Could this be strictly a bottom line strategy with an end goal of higher electric prices?

NoAlteana

 My biggest gripe with this whole project is the way the power companies have gone about it from the inception. If I wanted to 

run a line from my house to my shop in Glenrock (4 miles), the first thing I would do is talk to the landowners in between...find 

out which ones are open to the idea and which ones would warm up for a price. I would then plan a route taking into account 

the landowner concerns as much as possible. It may be that some people would even want it on their property for the easement fees. This whole project is based around the ability of these companies to condemn a right of way... My concern is 

there is no one to look out for the little guy concerning this project.

Plesug

 I do think it's great that you, or whoever, has kept portions of this line next to the interstate. I'm not real crazy about the section 

west of Jim Bridger. Some of that route is kind of barren ground but that's its appeal. Hopefully it follows an existing power line. I'm totally against scattering these lines all over the place.

Exi

100356 GEORGE BILL & 

JOANN KELLEY 

I am the owner of a 3000 acre farm which would be directly affected by the 7EF alternate line. The proposed site will interfere

with normal farming operations.

The Alteis p

 In addition, a rock quarry is in operation in the direct path of the proposed line. Because the rock is initially broken up using 

explosives, there is a great potential for damage to the power line during these procedures. The quarry covers over 900 acres 

of land permitted and zoned by Cassia County and the Idaho State Dept. of Lands for such use. The proposed line would go 

directly over this quarry. The 7EF proposed line will also interfere with guided hunts in the area. It will interfere with future plans to establish a game farm, as well.

The in t

 The 7 or 7H proposals are preferred. Yo

sup

100357 OWYHEE COUNTY 

BOARD OF COUNTY COMMISSIONERS

5. The proposed route through Owyhee County violates the intent of the Environmental Justice legislation passed by the 

Congress: A. 17.4% of residents in Owyhee County are below poverty level while only 11.8% of Ada county residents are below poverty 

level. B. 25.8% of Owyhee County residents are Hispanic and 4.3% are American Indian. Ada County figures in that regard are 7.1% 

and .7% respectively. C. The proposed transmission line project is projected to provide power to the populated areas of Ada, and Canyon counties to a significantly greater degree than to the rural population and small towns of Owyhee County.

No

D. Impacts to the workforce on the private lands of Owyhee County, which are limited in that approximately 80% of the lands in 

Owyhee County are federally owned, will be significantly greater than to the workforce of Ada County, which will be the beneficiary of the power provided.

No
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100357 OWYHEE COUNTY 

BOARD OF COUNTY COMMISSIONERS (cont.)

D. Analysis of impact to homes in Owyhee County has not been correctly addressed in the DEIS. 

(1.) If the line is routed as indicated in the variants of Alternate 9 (excepting 9D) there will be significant impact to current land 

value, future land value, and to current uses including agriculture. Location of the proposed line on private agricultural property will prevent future conversion of irrigation systems, as well as placement of future buildings and structures (both farm and 

residential)

PotSodisecothe 

(2.) The impact analysis found in the DEIS (table 2.2.8 on page 2.202) regarding homes in proximity to the proposed route is 

grossly incorrect. Enclosure 5 to the hand-delivered copy of this comment contains data provided by the Owyhee County 

Assessor. The map plots existing homes shown in proximity to the West Wide Energy Corridor.

The rev

E. Routing the line as proposed in the Alternative 9D, with modifications addressed later in this document, essentially 

eliminates these impacts to private property and public health. The proposed modifications to 9D have been discussed with 

Idaho Power Staff and were determined to be workable options.

Yo

A. The proposed routes labeled as variants of Route 9 are justified by Idaho Power and BLM as necessary for separation of 

parallel routes for redundant power needs. Various Idaho Power officials and staff have stated that the required minimum 

separation is a span width--1,500 feet. B. Stated reasons for the required redundancy are to prevent loss of the line during natural events such as fire or weather. C. The Murphy Complex Fire of 2007, burned more than 650,000 acres--an area that would have made the proposed spanwidth minimum separation distance moot. 

D. Weather events such as ice storms are often cited by Idaho Power as reasons to have the separation and redundancy. In 

reality, however, even the separation provided by proposed segments 8 and segments 9 would be insufficient to avoid the impacts of such storms in this region. E. The redundancy argument should be abandoned.

No

F. The segment 9 line should be located through the NCA to parallel the existing 138KW line, with minimum separation as 

required to avoid line-to-line interference.

NoNC

G. In that the proposed transmission line project is not in the Idaho Power Ten Year Plan, there is a valid question as to its 

necessity.

No

B. Idaho Power officials meeting with Owyhee County admitted early in the planning process that no structures can be built beneath the span of the transmission lines. Such limitations affect current farming/ranching operations and significantly limit

future highest and best use of the lands crossed by this line.

The fac

outThi

C. Health impacts to adjacent residents are of concern as addressed in the comment submitted by Robyn Thompson of 16990 Short Cut Road, Oreana, Idaho. With her comment Ms. Thompson submitted copies of articles indicating health risks 

associated with large electrical transmission lines. Owyhee County incorporates “A New View of ELF-EMFs” published in Environmental Health Perspectives, Volume 108, Number 10, October 2000 and “Childhood Leukemia and Magnetic Fields in Japan: A case control study of childhood leukemia and residential power-frequency magnetic fields in Japan” authored by 

Michineri Kabuto, et al, “Residential Exposure to Electromagnetic Fields and Childhood Leukaemia: a meta-analysis” by I.F. Angelillo and P. Villari, “Magnetic Fields and Cancer: Animal and Cellular Evidence--an Overview” by Bo Holmberg, “Exposure to electromagnetic fields (non-ionizing radiation) and its relationship with childhood leukemia: A systematic review: by M.F. 

Rernandez, et al, “Increased exposure to pollutant aerosols under high voltage power lines: by A.P. Fews, et al, and “Risk of hematological malignancies associated with magnetic fields exposure from power lines: a case control study in two municipalities of northern Italy” by Carlotta Malagoll, et al, into this comment. The articles in their entirety are contained within 

the Thompson comment.

The recSe

Changes made by BLM and/or contractor Tetra Tech changed the routing of a county proposed alternative from an area of 

little cultural significance to the junction of Sinker Creek and the Snake River--an area of significance for multiple reasons.

Nothe

A. Locating this project on private lands will alter the use of those lands for the considerable lifetime of this transmission line. No

Se

H. In early notices of scoping on Gateway West, public notices failed to provide sufficient notice to the landowning public in 

Owyhee County as to the potential impact of the project. Attendance at initial meetings was sparse as the result of the failed 

notices. When information as to the real impact began to be known, citizens’ groups developed in multiple counties to protest 

the early routes as developed by BLM and Idaho Power. I. This lack of initial proper notice prevented proper county involvement at the earliest planning stages, as is required by 

FLPMA.

Sevcou
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100357 OWYHEE COUNTY 

BOARD OF COUNTY COMMISSIONERS (cont.)

Upon release of the Draft EIS, Owyhee County immediately realized that the transcription of the county-proposed routes had 

not been correctly transcribed from the county provided maps to documents used by BLM in the Draft EIS. Maps and other descriptions within the Draft EIS did not accurately reflect the preferred county alternate route, labeled 9D in the Draft EIS. The 

errors of transcription were significant and the county immediately made them known to BLM during a coordination meeting 

with BLM Boise District. In addition, the errors were made known to State Director Steve Ellis and BLM Project Manager Walt George by letter dated September 6, 2011.

Noa n

Several of the alternative routes proposed in the Draft EIS, which place much of the proposed line on private property in 

Owyhee County, are unacceptable to the county in that they will adversely impact the current agricultural uses of the lands, 

diminish current and future land value, and will severely impact future highest and best use of those lands. This potential 

adverse impact is unacceptable to Owyhee County and unnecessary in achieving the desired intent of electric power delivery 

as envisioned under the Gateway West Project.

No

The scoping process for both the West Wide Energy Corridors and for this specific project was inadequate and flawed in 

eliciting early public involvement and meaningful participation.

No

A. Early public scoping notices and public Hearings related to the development of the West Wide Energy Corridors failed to 

impart to the public the true nature of the impact of the placement of the proposed corridors. 

B. Participants in the Energy Corridor Hearings were predominantly representatives of energy development or transmission 

concerns whose interests were far different from that of the local landowners who would find their private lands, businesses 

and other interests significantly impacted by the placement of the corridors. C. Those private landowners who did attend the Energy Corridor meetings were often told that this stage of the process was simply to lay out general corridors and that before any specific project could take place within the corridor, all requirements of 

NEPA’s public involvement must be satisfied and the project justified prior to any approval. D. That assurance proved to be worthless in dealing with Gateway West in that Idaho Power and Local BLM Officials all 

adhered to a position that they were constrained to place the line in the West Wide Energy Corridor. 

E. The 2005 Energy Act signed into law by President Bush provided for the development of the West Wide Energy Corridors. 

Section 368 of that Act required that the corridors were to be incorporated into federal plans. 

F. The Birds of Prey NCA was in development during the period when the West Wide Energy Corridor was developed in 

southwest Idaho. Contrary to the mandates of the 2005 Energy Act, BLM removed the corridor from the NCA plan rather than 

incorporating it. G. This defiance of the requirements of the Energy Act occurred late in the development of the plan, and occurred after an 

earlier draft incorporated the corridor in the vicinity of the existing 138 KW transmission line. That transmission line had been shown to be consistent with the needs of raptors and therefore consistent with the purposes of the NCA.

The not line maNereqcas

9. Impact of Alternative Route 9D to BLM non-motorized area in the vicinity of Cove Recreation Site: 

A. BLM analysis of 9D indicates that the route would not be acceptable due to impacts to a non-motorized area in the vicinity 

of Cove Recreation area. B. This non-motorized area was designated in the September 2008 NCA RMP, but mentioned only briefly in the RMP and 

there is little specific data as to the need and justification for the designation. C. In the specific comments provided later in this document, to proposed route changes to 9D are submitted as alternatives to 

minimize impact to the non-motorized area in the vicinity of Cove Recreation area.

Noareconin C

6. Placing the line segment in the Birds of Prey NCA is consistent with the purposes of the NCA: A. Studies completed by Karen Steenhof and others in the NCA, after construction of the existing 138 KV transmission line in the NCA, have shown 

benefits to raptor populations. B. The proposed line should parallel the existing 138 KV line. C. A major road improvement has been recently completed by BLM in the NCA using American Recovery and Reinvestment 

Act funds. The road project would provide much of the road access needed for line construction and negates a previous position by NCA management that a transmission line project in the NCA was harmful due to the need for road construction.

NoNC

7. Adverse Impact to Murphy Airport operations and farming and ranching operations may be possible as the result of the installation of the proposed Gateway West Transmission line. A. Helicopter activity during construction may have adverse impacts on other general aviation activity in the vicinity of the airport. B. Helicopter use during construction may have adverse impact on domestic livestock operators.

EffSeDE12. 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100357 OWYHEE COUNTY 

BOARD OF COUNTY COMMISSIONERS (cont.)

8. Alternative 9E is unacceptable and 9D is acceptable and consistent with resource issues: 

A. As noted above, Owyhee County submitted two routes: one route was eventually designated as 9D and the other as 9E in 

the DEIS. B. Even in the letter transmitting the routes, the County noted the inadequacies of the route eventually designated as 9E. 

C. The Owyhee County Sage Grouse Local Working Group noted the following in their review of 9E: The alternative route for Segment 9 that runs south of Highway 78 will impact important sagegrouse habitat in Owyhee 

County. This proposed route runs near dozens of known leks that are currently occupied by sage-grouse in the Owyhee Foothills. The Local Working Group feels that this is the least desirable alternative because the transmission line will attract 

avian predators, especially Common Ravens. Raptors and ravens use transmission lines for nesting, perching and roosting. 

Studies have shown that ravens are important nest predators of sage-grouse and that ravens move an average of 7 km and as 

far as 60 km from transmission line roosts each day. In addition, new roads required for this alternative would create extensive shrub loss and habitat fragmentation in previously undisturbed areas.

Nobeeconpro

Alternative... 9D is acceptable and consistent with resource issues Yo

Alte

curPre

D. The Owyhee County Sage Grouse Local Working Group noted the following in their review of Alternative 9D: 

The alternative (9D) that runs through the Morley Nelson Snake River Birds of Prey National Conservation Area (NCA) is a 

much better alternative. It would not affect Greater Sagegrouse because sage-grouse do not occur within the NCA. It would be 

compatible with maintaining raptor populations and the goals of the NCA. Research has demonstrated that properly designed 

transmission lines can be compatible with raptors. During the 1980s, a new 500-kV transmission line in the NCA enhanced opportunities for raptor perching, nesting, and roosting. Raptors and ravens were attracted to the towers, and productivity of hawks and eagles nesting on transmission towers was as good as and sometimes better than that of those nesting on canyon cliffs. Electrocution of raptors is not an issue because wires on transmission lines are spaced too far apart to electrocute 

raptors. Alternative 9D will follow an existing 138-kVtransmission line in habitat that has already been disturbed by fire. This alternative represents an opportunity to avert adverse effects of transmission lines on sagegrouse in Owyhee County. 

E. We concurred with that review, adopted it as a county position, and forwarded it to BLM in our September 8, 2010 letter.

No

4. Alternative Route 9 is unacceptable due to impacts on private property and other reasons as previously stated. Yo

PlecroRethe 

5. The changes made to Alternative Route 9D by transcription errors and/or by action of BLM Staff and contractor are not acceptable to the county and should not have been referenced in the document as a route supported by Owyhee County.

No

6. With the exception of the two areas of changes to Alternative Route 9D (vicinity of Cove Rec and Vicinity of Murphy and 

Snake River Crossing), Owyhee County Supports Alternative Route 9D as the proposed action.

No

1. Raptor impact analysis cited in the DEIS is flawed by the use of outdated or incorrect data. No10. Subsequent to the county submission of the September 1, 2009 letter and maps containing the two alternative routes 

proposed by Owyhee County, BLM and contractor made alterations to the northwest end of the County’s route 9D. A. These changes were apparently made as the result of requested changes on route 8 in the vicinity of Kuna, Idaho. 

B. The changes moved the county’s route 9D crossing of the Snake River from a viable and preferred crossing point to one with greater potential impacts. C. In addition to the changes made to the river crossing, the transcription of the route maps by either BLM or contractor staff

did not accurately transfer the route as proposed by the county in the vicinity of Eagle View subdivision. 

D. The transposing also did not show the continuation of the route 9D to the Hemingway substation.

Novarthe 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100357 OWYHEE COUNTY 

BOARD OF COUNTY COMMISSIONERS (cont.)

7. Regarding BLM’s changes to Route 9D in the vicinity of Murphy and the Snake River Crossing, we propose two alternatives to amend the route. They are shown graphically as marked green lines on Enclosure 1 to this document which is an electronic 

copy of a portion of a larger map product prepared by Idaho Power (Note: in the copy of this document delivered electronically 

to the Project Manager, the electronic file attachments will be incorporated as Encl’s 1 and 2. In the paper copy delivered to 

the Boise District Manager, we will include both electronic Encl’s 1 and 2, as well as three full sized map products): 

A. Our preferred option to correct the transcription error or changes made by staff to the Northwest end of Alternate Route 9D is shown on Encl 1 and described as follows: (1.) Use the routing submitted on our maps delivered on September 1, 2009. (2.) For reference on the routes and maps provided in the DEIS, this would be described as “Our original Route 9D to mile 

point (mp) 18.5, then west on Route 8 to mp 124, then straight west on section line to a point between mp 155 and mp 156 on route 9. B. Our second option for this section of our Route 9D is shown on Encl 1 and described as follows: Route 9D to mp 58, at mp 58 go southwest approximately one mile and then northwest approximately two miles then north to the point at which our preferred correction line joins Route 9 at approximate mp 155.5.

AdBL

8. Regarding BLM’s concerns related to the non-motorized area in the vicinity of Cove Recreation Area, the county provides two alternate routing options which are shown as marked green lines on Encl 2 to the electronic copy sent to the project 

manager and on both Encl 2 and the full sized map sheet delivered to the Boise District Manager. A. Route 9D to a point at approximately mp 11.8 then proceed south to cross the Bruneau Narrows, continue south and then 

southwest skirting the edge of the Cove NMA until south of State Highway 78. Proceed northwest to Simplot property at Cove then continue on Simplot property to get back on 9D at approximately mp 14.25. 

B. Route 9D to mp 12, then proceed northwest north of the Bruneau Narrows until meeting the line of the two-track road which runs southwest through the Cove NMA, follow the line of the two track road to a point south of State Highway 78 then follow 

the route described above to approximate mp 14.25 on 9D.

AdBL

2. The Sage Grouse and Raven impact analysis is flawed due to missing critical reference material. Ad

pro

3. Alternative Route 9E is unacceptable for reasons as stated above. YoThe draft EIS focuses on specific cultural sites for avoidance and/or protection yet ignores significant areas of significant 

cultural value. B. Routes segments proposed under the Draft would interfere with multi-generational ranching operations, some dating to the 

mid to late 1800’s, as well as sites of historical significance in the vicinity of Oreana, Bruneau, Little Valley, and Murphy.

ThehisWybeedocrathwitthe the

100358 BILL KELLEY The 7EF alternate line falls too near the Albion Airport interfering with safe take-offs and landings. Due to the fact that the 

airport sits at the base of an 8000 ft. mountain to the south, a pilot often finds it necessary to take off and turn to the north in 

order to successfully complete the take-off. Take-off direction is also dependent upon weather conditions, pilot competency 

and load of aircraft. The proposed site for the power line would be in the direct line of ascent causing serious, even deadly 

consequences to the aircraft, passengers and the power line itself. This airport was designed and engineered by Briggs and 

Assoc. of Boise in 1969. A government grant financed the initial engineering of the airport. It has been in continuous operation 

since that time. My family owned and operated a crop-dusting business for 30 years based out of this airport. During the agricultural season, we would fly as many as 30 take-offs and landings each day. Student pilot training has also been conducted from this airport. The airport is located on 900 South and the 7EF proposed line will be as close as 800 South.

Adope

 Proposed line 7 or 7H would be preferred Yo

sup

100359 TOM CRANK Since the construction of the existing power line corridor (Segment 4A) from the Jim Bridger Power plant in Sweetwater 

County, Wyoming some houses, and other structures have been built within view of the existing power line corridor. During 

this same time numerous summer cabins and out buildings have been built in the Commissary Ranches and Spring Canyon Ranch area subdivisions near the proposed route of Segment 4. My point is that people buildings near the existing power line 

corridor (Segment 4A) all knew they were building near the power lines and could see them. People building homes and 

cabins along the proposed route did not plan on the power lines in their back yards but it may now be forced on them and greatly reduce the value they have placed on their properties.

Nothe in t
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100359 TOM CRANK (cont.) The existing power line route, known as Segment 4A, is in my opinion is the most viable route. Segment 4A follows an existing 

power line corridor so wildlife impacts and historic trails issues are in my opinion minimal. The impacts to sage grouse and big game (wintering mule deer, antelope and elk) would be limited to the existing power line corridor using Segment 4A whereas 

proposed segment 4 would open up new impacts to all wildlife. Recreationist following the historic pioneer trails near Kemmerer would not have any more view shed issues with the new power lines following Segment 4A. The proposed new route of Segment 4 would not remove the existing power lines of route Segment 4A and would add visual impacts to other pioneer trail segments north of the existing power line corridor.

YoProThe Pro

 The existing power line corridor along Segment 4A in my opinion is the best balance of all competing issues. It is also 

considerable shorter than the proposed route of Segment 4.

YoPro

 The preferred route of Segment 4 will open up an area of land that is used by most of southwest Wyoming to recreate and 

enjoy its open views. The preferred Route of Segment 4 would cross over the top of Slate Creek Ridge and South Fork 

Mountain and be visible for over 5O miles as it does so. The area between the south end of Fontenelle Reservoir and the Fontenelle Basin (Fontenelle Basin being between Slate Creek Ridge and South Fork Mountain) is critical big game winter 

range and sage grouse habitat. The presence of this new power line corridor, into this yet uncut section of country, will 

increase the ease of access. Road construction (be it improved or two track) always follow these power line routes for 

maintenance. The actual construction may be by limited entry roads and helicopter sets, but access roads always develop 

under these power line corridors. The section proposed to pass over South Fork Mountain West down into the Beaver Creek Drainage of the Hams Fork River is 

currently not accessible by motor vehicle and the presence of this power line corridor will greatly impact wildlife and recreation 

in this small canyon.

Thiexi

the Ch

 I am in favor of the project in general No the preferred route of Segment 4 is a travesty. No

the tha

 The existing power line corridor identified as Segment 4A is in my opinion the most viable route. Yo

100360 COALITION OF 

LOCAL GOVERNMENTS 

3. Visual Resource Management a. Decision #6051: VRM Class II Designations VRM Class II areas: A visual corridor extending up to 1 mile on either side of the Sublette Cutoff and the Slate Creek Cut-off north of U.S. Highway 

189 and east of Slate Creek Ridge in consideration of NHT views. The northwest portion of the planning area... 

b. Lincoln County Proposed Amendment for Alternative 4A: Reclassify the VRM Class designation to VRM Class III in the portion of the planning area north and east of U.S. Highway 30 

and west of the Hams Fork River (Tunp/Dempsey Trail Area 

The cha
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100360 COALITION OF 

LOCAL GOVERNMENTS (cont.) 

c. Decision #6053: Designated National Register Sites Viewshed Preservation 

Preserve the viewshed within 3 miles of the sites listed below, where the visual characteristics of the setting contribute to the 

eligibility of the site, by managing projects in federal sections to retain the existing character of the landscape so developments do not dominate the visible area to detract from the feeling or sense of the historic time period of the site. ROW will be 

designed to preserve the visual integrity of the sites consistent with BLM visual resources handbook/manual. The 

management action is intended to manage developments to maintain setting qualities and not to have an exclusion zone. Emigrant Spring/Dempsey (11 acres) Alfred Corum and Nancy Hill emigrant gravesites (1/2 acre) d. Lincoln County Proposed Amendment for Alternative 4A: Preserve the viewshed within 1 mile of the sites listed below, where the... Emigrant Spring/Slate Creek (87 acres) Emigrant Spring/Dempsey (11 acres) Johnston Scout Rock (2 acres) Alfred Corum and Nancy Hill emigrant gravesites (1/2 acre) Pine Grove Emigrant Camp (14 acres) Rocky Gap Trail Landmark (15 acres) Bear River Divide Trail Landmark (3 acres) Gateway Petroglyphs (518 acres) 

Several of these areas are either privately-owned or surrounded by privately-owned land. The limits imposed limit lawful 

access to private land. The presence of existing transmission lines should be considered when determining site eligibility and 

existing character of the landscape. The BLM manual regarding cultural resources states D. Allocations in Support of Goals. Allocate all cultural properties in the RMP area, whether already recorded or projected to occur on the basis of existing-data syntheses, to one or more of the following uses according to their nature and relative 

preservation value. DM 8130 ¶.2.D. These land use allocations pertain to cultural resources, not to areas of land. 

The Proconhav
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100360 COALITION OF 

LOCAL GOVERNMENTS (cont.) 

4. Visual Resource Management a. Decision #6054: Class 1 & 2 NHT Viewshed Preservation Manage the viewsheds of NHT segments as follows: (1)(a) Preserve the viewshed within 3 miles of Class 1 segments north and east of U.S. Highway 30 and 

west of the Hams Fork river (Tunp/Dempsey Trail area), where the visual characteristics of the setting contribute to the 

eligibility of the site, by managing projects in federal sections to retain the existing character of the landscape so developments do not dominate the visible area to detract from the feeling or sense of the historic time period of the trail setting. Design ROW 

to preserve the visual integrity of the settings consistent with the BLM visual resources handbook and manual. (1)(b) Preserve 

the viewshed within 1 mile of Class I segments outside of the Tunp/Dempsey Trail area and the checkerboard land pattern 

area, where the visual characteristics of the setting contribute to the eligibility of the site, by managing projects in federal sections to retain the existing character of the landscape so developments do not dominate the visible area to detract from the

feeling or sense of the historic time period of the trail setting. Design ROW to preserve the visual integrity of the settings consistent with the BLM visual resources handbook and manual... (2)(a) Preserve the viewshed within 1/2 mile of Class 2 

segments that exist in blocked federal lands west of U.S. Highway 189 (south of Kemmerer) and south of U.S. Highway 30 by 

managing projects in federal sections to retain the existing character of the landscape so developments do not attract the 

attention of the casual observer. (2)(b) On Class 2 trail segments outside of the area described in (2)(a) manage the viewshed 

to preserve the existing character of the landscape within the federal section where the trail occurs. (2)(c) On Class 3 

segments, manage the viewshed according to the appropriate VRM class for the area. b. Lincoln County Proposed 

Amendment for Alternative 4A: Reclassify all NHT Viewshed Classifications to Class III segments within the portion of the planning area north and east of U.S. Highway 30 and west of the Hams Fork River (Tunp/Dempsey Trail Area). BLM policy 

requires that it treat the projects differently when assigning and implementing VRM restrictions. CLG members remain 

concerned that Alternatives 4B through 4E will only impose expensive and time-consuming mitigation measures that increase the amount of new surface disturbance and alter sage-grouse core area habitat. These environmental and economic costs burden the right-of-way route selection process and appear to elevate viewshed to protect now invisible trail segments over 

protection of sage-grouse core areas, wildlife habitat, and limiting surface disturbance. The Kemmerer RMP improperly 

assigned VRM Class II designations to affect existing land uses, rather than having the VRM class be adjusted to reflect the 

permitted land uses. VRM classifications should be narrowly tailored to reflect previous and current land use decisions and 

appropriate land uses. VRM Class II classifications contradict BLM visual resource management policy. The Kemmerer RMP 

made the error of imposing VRM Class II along historic trail segments to protect cultural resources. A blanket VRM Class II 

cannot be imposed absent documentation of significance and sensitivity. This evaluation does not occur until the project level and thus the DEIS needs to conduct its own evaluation of significance and sensitivity. As explained above, if the trail segments 

are now invisible or not physically evident, they are neither significant or sensitive. Thus the DEIS cannot apply VRM Class IImeasures until it has done the site-specific analysis. This contradiction should also be addressed in the checkerboard lands 

and other areas where much or most of the land is owned by the State or private individuals. For example, the southern and 

central VRM Class II areas cover areas which are more than half private land. The RMP classified most of the land north of Highway 30 as VRM Class II based on federal ownership (lumping) VRM classification criteria does not authorize classification 

based on general land ownership. BLM policy limits Class II VRM objective to areas that are both sensitive and are not allocated to a conflicting land use. 

The cla
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100360 COALITION OF 

LOCAL GOVERNMENTS (cont.) 

5. Special Management Areas a. Decision #7014: Special Management Areas Manage the Rock Creek/Tunp area of 

significant resource concern with the objective of preserving and enhancing the critical wildlife habitats and cultural values that 

occur within the area. Restrict all new ROW actions to existing disturbance zones. No net loss of habitat function allowed from

any construction activity within the boundaries of the management area. Successful re-establishment or improvement of habitats could offset any new disturbance areas. Pursue opportunities to reclaim existing roads not necessary to attain 

management objectives. Restrict OHV use to existing roads and trails. No off-trail travel is allowed without prior approval from 

the authorized officer. Manage NHTs and sites settings and all surface disturbing activities to retain the existing character of 

the landscape in federal sections so developments do not dominate settings to detract from the feeling or sense of the historic

period of use... b. Lincoln County Proposed Amendment for Alternative 4A: Designate a utility corridor one (1) mile in width, generally centered on the existing transmission line (Bridger West #2). Lincoln County questions the merit of prohibiting or 

restricting disruptive activities. CLG provided the BLM with two reports, one on elk and oil and gas development and a second analyzing the literature said by the KFO planning staff to support the restrictions on disruptive activities. The comments 

included an exhaustive literature survey done by Renee Taylor to determine whether scientific literature supports the premise that wildlife are stressed by human presence. In addition, Taylor took the Sawyer survey data (Sawyer Nielson, Seasonal distribution and habitat use patterns of elk in the Jack Morrow Hills Planning Area, Wyoming (2005)) and overlaid it with oil and gas development in the Jack Morrow Hills area. Significantly, the data show the elk have become habituated to gas development and calve and winter there. This work supports the local governments’ criticism of applying the disruptive 

activities restriction throughout the planning area. It further shows that current data do not support the disruptive activities 

restriction. Even common sense suggests that wildlife habituate to “disruption.” If the assumptions upon which the restrictionson disruptive activities are based were true, then the ban on disruptive activities must also be applied to hunting, which is a

very disruptive human activity. The fact that game have adapted to rural subdivisions and hunting, as well as oil and gas 

development, suggest that the concerns about disruptive activities lack quality data to support them. 

TheProsco

 CLG supports using two single-circuit structures in place of the double-circuit structures that are proposed along Segment 4.

Segment 4 parallels three existing transmission lines that use the single-circuit structures and the divergence to much larger double-circuit towers would appear obtrusive. As opposed to the heavier double-circuit tower, the lower structure weight and 

configuration of the single-circuit structure would allow helicopter-aided construction techniques, providing the Proponents with 

the option of taking less time to construct. Separating the two 500-kV circuits onto two separate structures would allow energized maintenance procedures to proceed more easily than when both circuits are on the same structure. During a 

structure failure event, if a double-circuit tower fails, both circuits would be out of service. With two single-circuit lines, it is less 

likely that both circuits would be affected to the same degree during the same event. Thus, the two single-circuit structure 

alternative would have a higher operational availability during a tower failure event. 

The (se

 Any route deviation from the existing transmission corridor (proposed route, Alternatives 4B, 4C, 4D, 4E and 4F) that would 

introduce new structural elements to this view must require non reflective towers made of wood or dulled ionized steel, with 

non-specular wire. 

The list 

Rospe

 Guyed structures must only be used for “tangent” or in-line structures, not for angles or corners. Guyed structures must only

be used in rangeland, grassland, and shrub steppe. They must not be used in areas farmed with heavy equipment or using 

aircraft, in residential areas, or near airports. In those land use types, self-supporting lattice towers must be used. 

No witBL

 CLG encourages the location of associated worker housing within existing communities where services can be provided. The 

proponents, contractors and subcontractors must contract with local motels and hotels (within 30 miles) for temporary accommodation during construction of the Project site and with local RV parks for rental spaces to accommodate workers who have access to RVs. The Proponents must provide transportation to the Project site in the form of buses or vans, depending 

on workforce numbers, to ensure workers arrive at the Project site safely and to lessen the impacts to existing roads. 

The

 All materials used in the construction of the Gateway West Transmission Line through Lincoln County will use Lincoln County 

as the point of sale. This includes the proponents, contractors and subcontractors who deliver construction materials “Free on 

Board” (FOB) to the County in which the materials will be utilized. This will help ensure that the sales tax will be properly allocated and paid to the County where construction and related impacts will occur. 

The 

As expressed by SWC, the local governments support the transmission line but strongly recommend that it follow the existing 

transmission line corridors, as it does for most of the route through western Wyoming with the exception of Lincoln County.

The Alteis p

The local government cooperating agencies have repeatedly recommended that the new Gateway West Transmission Line 

follow, as closely as possible, the existing transmission corridor including the route through Lincoln County, Wyoming and that

this route be adopted as the preferred alternative. CLG and the public overwhelmingly supported this as the preferred route.

Yosup
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100360 COALITION OF 

LOCAL GOVERNMENTS (cont.)

These alternatives (4B-4F) sacrifice sage-grouse habitat to protect historic trail values and viewshed. In many cases, the trail 

segments that are to be protected lack physical integrity, a fact that the DEIS fails to address. BLM should evaluate each 

affected segment on its actual, as opposed to its assumed, significance and integrity.

Yotab

The recent decision if the Idaho District Court setting aside the Pinedale RMP due to its failure to adequately protect sagegrouse habitat requires BLM to reassess it’s priorities. Western Watersheds Project v. Kempthorne, 08-0516 (D. Idaho Sept. 

28, 2011) (holding that the Pinedale RMP failed to adequately protect sage-grouse habitat and was therefore unlawful). It 

would appear that the BLM generated alternatives for segment 4 violate the court’s ruling.

The inc

CLG recommends that BLM select the final route in Segment 4 as Alternative 4A. 

A. Alternative 4A CLG supports Alternative 4A as the preferred alternative. This alternative follows three existing 345-kV transmission lines 

between the Jim Bridger Power Plant and the Idaho border and is the shortest and most direct route to destination. Although 

the longer, proposed route would mean additional property tax revenues for the County, the added expense of construction will likely be passed on to the ratepayers. Alternative 4A requires the least amount of Greenfield ROW and also affects the least 

amount of sage-grouse core area, as compared to all other routes in Lincoln County analyzed. The State of Wyoming proposed this alternative, which primarily followed the existing transmission line corridor. It avoids sagegrouse core areas and involves less new surface disturbance than in previously undisturbed areas. DEIS at 2-70-2-71. 

Alternative 4A also conforms to Wyoming EO 2011-5 which establishes a 2-mile-wide corridor through the Sage and 

Seedskadee Core Areas centered on the three existing transmission lines. Constructing this segment adjacent to the existing 

transmission lines would significantly reduce the environmental impacts, especially to the sage-grouse core area habitat.

Yothe we

C. Protection of Historic Trails The BLM alternatives are intended to reduce the impacts on the historic trails. The trail segments for the Sublette Cutoff and Slate Creek Cutoff that might be affected by Alternatives 4 and 4A are not congressionally designated historic trails. They were the subject of feasibility studies but BLM never secured the required consent and cooperation from the affected landowners. 

...The DEIS incorrectly assumes that all of these trail segments could be listed on the National Historic Register without 

performing the integrity analysis required by the National Park Service (NPS). 

...CLG members object to the DEIS classification of the trail segments as Class 1 or 2. Virtually all of the affected trail 

segments have lost their physical integrity. ... BLM cannot justify sacrificing sage-grouse habitat in favor of protecting historic 

trail segments which lost their physical integrity a long time ago. ... DEIS Alternatives 4B-4E avoid the trail segments even 

though they are no longer physically visible. This is in error because NPS Guidelines require that the site maintain its physical 

integrity. When it is lost through development or the mere passage of time, NHPA criteria no longer mandate or permit 

imposition of restrictions to protect what is no longer physically there.

The Re

D. Proposed Amendments to Kemmerer RMP CLG members, however, question the nonconformance decisions reflected in Alternatives 4B through 4E. As explained below, KFO efforts to avoid historic trail segments are based on the incorrect assumption that National Historic Preservation Act 

protects trail segments that have lost their physical integrity. Such trail segments should not even be classified as potentially 

eligible. 2. Utility Corridors a. Decision #6008: Utility Corridors Prohibited Across NHTs. “Utility corridors are not designated where they are in conflict with NHT’s management objectives.” As noted above, the routes affect undesignated trails and this condition does not apply. b. Lincoln County Proposed Amendment for Alternative 4A: Designate a utility corridor one (1) mile in width, generally centered on the existing transmission line (Bridger West #2). 

An amendment is not required for any of the routes to be approved; however, Lincoln County recommends designating a 

corridor for future utility placement since there are two other transmission lines being proposed (TransCanada and Zephir). 

Although not currently designated as a corridor, four existing power lines parallel to each other would constitute a corridor to a 

rational thinking person. Lincoln County has repeatedly asked the Kemmerer FO to officially designate this corridor. There have been two previous 

opportunities to do so, during the Kemmerer RMP revision a year ago and during the West-Wide Energy Corridors EIS. Again we request the Kemmerer FO to recognize this as a utility corridor

The par

as 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100361 LEAH D OSBORN There would be an inherent negative impact created by the Gateway West Transmission Lines. It is a negative visual impact 

everywhere. In the table you fail to give weight to the fact that any resident who lives in the area looks at these lines up to

several times a day. A once a year recreationist certainly is not the same as a resident that may be impacted by a line through

their field 5 times a day. For example: ( 5) ( 360) =1,800 impacts per year. But that was just 1 person in the family of 5. It is a 

ranch that has a road going to 3 neighboring houses and each house has 5 family members. So now we can continue to figure 

impacts. 1800 x 5 =9000 and 9000x 15 = 135;000. Now figure for the whole county !!!! 135,000 really is no where near 20 (20 visitors once a year). 

Effcritquaana

 I do not support segment 9, which goes through private land in Owyhee County. I support putting the line in the area where it

will have the least impact by those that will have to live with this negative impact for years. 

Yo

 I support Segment 9 D only. Yo

To quote; “Helicopters generally fly at low altitudes.” Decibels were mentioned yet nothing of the effect on livestock. No mention what effect a low flying helicopter will have on confined livestock. No mention of stampeding animals. 

Keep the helicopters away from private pastures, feed lots and personal horses. The Gateway West Transmission Lines need to put where there are few livestock.

NoAlteagr

I support segment 9 D. YoI do not support segment 9. Yo

sup

Oreana is surrounded by BLM land. Public use...put it on public land. No

site ma

I do not support segment 9. Yo

sup

I support segment 9d. YoHere you say,” ground shaking and displacement related to earthquakes may damage human-made structures, including transmission lines and substations.” I cannot support any line that goes through the most populated areas of Owyhee County knowing that transmission lines may 

be affected by earthquake activity. Theses towers are approximately 190 feet tall. A 190 foot tower with an electrically charges 

line whipping around homes. This is irrational. Place these vulnerable towers where there are no homes!!!!!

Ea4.1com

I can only support Alternative 9D as is proposed by the Owyhee County Task Force. Yo

100365 BARRY WILLIAMS You are proposing running the lines over a rugged mountain on the west side of Arbon Valley where the snow drifts deep and 

becomes hard in late winter with sloping banks over any cut roads. Access would be difficult.

The for curPre

 A more feasivle route for the north line would be to follow the three existing lines through the Fort hall Indian Reservation north 

of Pauline.

The 

 A more feasible route for the south line would be to go south just north of Buist and then along the Utah and Nevada border. 

The other alternate route over Arbon, goes diagonal across wetlands meadows and across a considerable amount of farm 

land. It also crosses a rugged mountain on the west side of Arbon Valley.

Thi

 These lines should be run across public land as much as possible. The environmental impact on public land is not as great as 

the impact on private land owners.

The line Ap

100366 LANA D 

RICHARDSON AND DEREK EAGER 

I am not in favor of the high power Transmission lines going in just south of Glenrock. Yo

The Se

100367 FRANK & LORNA 

GILLETTE 

If a power line is put across the top the the Test Hill it would eliminate all flying in this area. I would like to have the line go south to the Nevada State line. I

No

100368 JANA REED TYLER absolute disapproval of your plan to put transmission lines on the south side of Glenrock. Visitors to Glenrock and Glenrock 

residents themselves will have to pass under these lines every single day, not to mention we will have to look at these 

monstrosities every time we look out the window hoping to see an unobstructed view of the mountains.

Yosupof Adet

 By putting your transmission lines so close to town you are absolutely limiting Glenrock's potential for future growth. Se
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100369 JAMES D 

SCHELL,DEBRA L SCHELL 

We strongly oppose the proposed route 1W(a)... a transmission line of that magnitude would greatly diminish our ability to sell

our property at anytime in the future and would severely degrade the value. 

YoThe conconin C

 we'd like information and documentation on noise and documentation on any studies done on health issues caused by having 

full time exposure to electrical emissions power lines of this magnitude may cause. 

InfoUSPu004or 

100371 ROBERT 

GERTSCHEN,CHRISTINE GERTSCHEN 

Segment Alt. 8A has far more impact than "Segment 8". We strongly support Segment 8 which minimizes deleterious impacts Yo

beeconhav

 Segment Alt. 8A has far more impact than "Segment 8". Yo

Se

in tCh

100372 TRANSWEST 

EXPRESS LLC

TWE generally supports the GWW Project, but is concerned that decisions on the GWW Project should not be treated by the 

agencies as consuming the Section 368 corridors (referred to as the “West-Wide Energy Corridors”) designated by the 

Approved Resource Management Plan Amendments/Record of Decision for Designation of Energy Corridors on Bureau of Land Management-Administered Lands in the 11 Western States (BLM 2009) or other designated utility corridors, thus 

precluding construction of other proposed transmission lines.

It is it fo

Figure 1.1-1 (Project Overview) includes a black dotted line around the proposed route and the alternatives but there is no 

legend on the map identifying the significance of that line. We assume this line describes either the study area for routing or

the resource analysis area but cannot confirm that assumption. Please include an explanation in the FEIS for the meaning of 

that line on Figure 1.1-1.

The 

There are statements on page 3.19-22 that Segments 2 and 3 generally follow I-25 and U. S. Highway 30. In fact, those 

segments generally follow I-80 and U.S. Highway 30.

Info

It is important that BLM consider all three projects [Gateway West, TransWest Express Project, and Gateway South] in any 

decision making so as not to foreclose multiple uses of the same corridor. In addition, BLM should leave flexibility in determining the ultimate routing of the projects to allow for cooperation and accommodation of the other projects.

Noare 

It is imperative that the GWW Project right-of-way be granted in a manner that will allow interconnection with the TWE Project northern terminal while avoiding interference with the siting, construction and operation of the TWE Project and the northern terminal.

The 

Proposed mitigation measure LU-4 (page 3.17-74) which would require coordination with the Chokecherry-Sierra Madre Wind 

Farm and the TransWest Express Project developers along the Segment 2 Proposed Route to ensure mutually compatible siting of transmission lines and wind energy facilities would address a number of the issues raised above and we encourage 

BLM to include this mitigation measure in its Record of Decision (“ROD”) for the GWW Project and right-of-way grants

LUin O

As disclosed on page 2-1, the Proponents have identified three variations to the overall GWW Project: 1) a right-of-way design 

variation, 2) a structure variation and 3) a schedule variation. TWE appreciates the BLM maintaining the flexibility in its ROD

(assuming the project is approved) for the Proponent’s to select among the proposed action and the variations based on economic conditions at the time of construction; however, the BLM must assure that such flexibility does not negatively impact 

other proposed transmission projects, such as the TWE Project, and that if an action alternative is selected that allows a rightof-way width of up to 375 feet, such right-of-way does not prevent other transmission lines from utilizing West- Wide Energy 

Corridors or designated land use plan corridors. The BLM should describe in the FEIS its plans to accommodate other 

proposed transmission projects within common corridors should the agency select an alternative which allows the three 

identified variations.

Noforeprohav

TWE does question, however, whether the DEIS satisfies the requirement of 43 C.F.R. §1610.4-7 that the draft EIS on a 

proposed plan amendment identify the BLM’s preferred alternative.

The DE

43 C.F.R. §1610.5-5(b) provides that if an EIS is prepared on a plan amendment, the amending process shall follow the procedure required for preparation of a plan, which includes identification of the preferred alternative in the draft EIS. TWE 

requests that the FEIS clarify how the plan amendment process set forth in the DEIS satisfies the requirements of the BLM 

regulations

The the 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100372 TRANSWEST 

EXPRESS LLC (cont.)

The VRM analysis in the DEIS (Section 3.2 and Appendix G) contemplates in several places that, although the GWW Project would not conform with the existing VRM classification for a given area, the project should be permitted in those “Areas of Inconsistency” as a visually altering action but without changing the VRM classification for the area. The discussions of these

revisions in Table 2.2-1, Sections 3.2, Chapter 4 and Appendix F are somewhat confusing regarding whether an amendment of various plans is proposed or simply a “one time” exception to the plan requirements....The descriptions of the potential plan amendments are also unclear regarding the extent of the proposed amendments; i.e., whether the VRM class is being 

changed only for the width of the right-of-way or for the width of the Cumulative Impacts Analysis Area for visual resources orfor some other area. We request that the FEIS make clear the geographic extent of any proposed amendment.

Eadepamchame

the cha

With respect to the Rawlins Resource Management Plan, PCW believes that it is appropriate to clarify that a VRM Plan 

Amendment is required by the ROD on the Rawlins Resource Management Plan (“RMP”) which was signed on December 24, 

2008.

Ap

The DEIS does not appear to have considered the pending VRM Plan Amendment for a portion of the Rawlins Field Office. see Notice of Availability, 76 Fed. Reg. 44039, July 22, 2011. The Decision Area for the draft VRM Plan Amendment includes 

a portion of Segment 2 of the GWW Project. TWE recommends that the FEIS incorporate the decision on the pending VRM Plan Amendment or, if no decision has been rendered by that time, at least incorporate discussion of the Preferred Alternative 

under the draft plan amendment

The RO

The DEIS proposes that the GWW Project be permitted in Proposed Segment 2, Area of Inconsistency R-3, within a quarter mile on either side of the North Platte River without changing the VRM classification (Class III under the current “no action” alternative which controls the Rawlins RMP until a plan-wide VRM amendment is prepared). Under the Preferred Alternative in 

the Rawlins draft VRM Plan Amendment, the quarter mile area on either side of the North Platte River would be designated 

VRM Class II. As indicated in its comments on the draft VRM Plan Amendment, TWE believes that it is inappropriate to attempt to manage for VRM Class II within a quarter mile on either side of the North Platte River in the areas within the viewshed of Interstate 80, existing pipelines, the railroad, and improved county roads

The outDis

Page G.1-3 of Appendix G-1 states that “the presence of a transmission line in VRM Class I and II and, in some special circumstances, Class III usually conform with visual management objectives”. We believe this statement may have meant to 

say that VRM Class I and II and, in some special circumstances, Class III usually do not conform with visual management 

objectives. TWE suggests that this statement be corrected or clarified in the FEIS

Thanot

The discussion on page G.5.1 of Appendix G-1 concerning VRM Class III compliance is confusing. The DEIS states that the proposed routes or alternatives across VRM Class III is consistent with class objectives “if consideration was given to 

alternative alignments that would avoid the area and feasible mitigation was applied”. It is not clear what is meant by consideration given to alternate alignments. If consideration was given to alternate alignments that avoid VRM Class III and 

none were found, then is the transmission line in compliance? In the FEIS, TWE requests that BLM clarify statements regarding VRM Class III compliance and provide a more robust discussion of factors considered when evaluating whether a 

transmission line is consistent with VRM Class III management objectives

Tex

Table 4.4-3 contains an error as it reflects no potential plan amendments for Segments 2, 3, 5 or 6. Table 2.2-1 does show 

potential amendments for the plans covering those segments. Please correct in the FEIS

Tabprecla

On pages 3.10-26 through 3.10-29, EPMs PGC-1 through PGC-36 for big game species are unclear. The wording of these EPMs does not allow for determination of whether monitoring is completed for the immediate vicinity surrounding construction 

areas or whether it is completed for the entire winter range, parturition area, etc. An area component (i.e., monitoring shouldoccur within 0.5 miles of construction areas) would clarify these EPMs and still provide adequate protection mechanisms to 

ensure that construction and operation activities do not impact these species

Therev

On page 3.10-35, EPMs PRC-12 through PRC-14 for golden eagles and mitigation measure WILD-4 for all raptor nests are 

unclear. The wording of these EPMs does not indicate the distance from the right-of-way in which surveys should occur nor 

does it indicate that the surveys should only be completed in suitable nesting areas. Restating these measures in a manner 

similar to that used for PRC-18 through PRC-20 (i.e., surveys should occur within 0.5 miles of the right-of-way in suitable habitat) would clarify the intent and still provide adequate protection mechanisms for nesting eagles and other raptors

ThePro
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100372 TRANSWEST 

EXPRESS LLC (cont.)

The DEIS states on page 3.10-26 that the agencies rejected the Proponents’ monitoring proposal for big game seasonal use 

stipulations because “only appropriate Agency personnel may determine presence or likely presence of big game species in 

restricted areas.” TWE would like to note; however, that there may be situations in which BLM-approved third party contractors 

are qualified and may be required to perform similar functions. For example, TWE understands that the biological monitors 

contemplated under mitigation measure WILD-4 may in fact be third party contractors approved by the Agency. TWE requests that BLM clarify the situations in which monitoring personnel are required to be Agency personnel from those situations in 

which the Proponents may provide qualified third party contractors. Also, if Agency personnel are required for monitoring the BLM should disclose in the FEIS how it intends to meet the likely large anticipated demand for monitors consistent with the 

Proponents’ purpose and need and project schedule and Agency staffing limitations and budgetary restrictions

The 

TWE assumes that the intent of VEG-8 is to prevent the spread of weeds, specifically by trucks and equipment traveling 

through infested areas. This measure as written appears to be extremely prescriptive and if strictly interpreted is a particularly onerous way to accomplish weed management. TWE believes it would be more appropriate on such a large project for BLM to leave some flexibility as to how to accomplish noxious/invasive weed management by instead requiring an instrument such as a Weed Management Plan that could be adapted to the requirements of the GWW Project in each area. This approach was 

set forth in the Sigurd to Red Butte No. 2 345 kV Transmission Project Draft Environmental Impact Statement (BLM 2011) and should be considered by BLM in the FEIS for the GWW Project

The pra

Mitigation measure WILD-5 on page 3.10-30 is not supported by the analysis in the document. There is no evidence presented 

that bat roosting sites within 0.5 miles of the ROW would be impacted by construction activities, although some impacts to 

roosting sites might occur within the disturbed areas of the ROW. To be reflective of the expected impacts that are presented in the DEIS, BLM should re-evaluate WILD-5 and require surveys only where direct loss of roosting habitats might occur from 

construction activities. In addition, this mitigation measure applies to all lands. The BLM should clarify in the FEIS its authority 

to require this mitigation measure on non-public lands

As meautcasStareqoccme

Mitigation measure WILD-6 is described on page 3.10-36 in a section regarding raptors. WILD-6 requires 10 years of annual 

reports on nesting activity on any towers constructed by the GWW Project. We assume that this requirement is limited to 

raptors, but the language of the mitigation measure itself is not so limited. Please clarify in the FEIS whether WILD-6 would 

apply to all nesting species or only to raptors

Ed

Mitigation Measure WILD-7, which requires all guy wires to be marked with bird deterrent devices to avoid avian collisions with

structures on public lands, cites BLM Instruction Memorandum 2010-022 (“IM 2010-022”) as its authority. IM 2010-022 does 

not require the marking of transmission tower guy wires with bird deterrents. IM 2010-022 is specific to fences and guy wires 

for turbines and MET towers. IM 2010-022 recommends, but does not require, all existing guy wires be marked. While marking of guy wires may be appropriate in some high risk areas, it is not appropriate and should not be required for the entire GWW 

Project. In addition, the DEIS fails to evaluate the visual effects of placing highly reflective, “glow in the dark” bird flight 

diverters on transmission tower guy wires. In our experience, placing bird flight diverters on MET tower guy wires greatly increases the visibility of the tower, often to several miles. In the FEIS we request BLM evaluate the effectiveness and visualimpacts of bird flight diverters on transmission tower guy wires and provide a justification (other than IM 2010-022) for 

requiring bird flight diverters on all structures located on public lands

Reonlfor 

TESWL-22 (page 3.11-69) prohibits guyed-structures within occupied sagebrush obligate habitats within the area managed 

under the Kemmerer Resource Management Plan. As disclosed in the DEIS, the risk to greater sage-grouse resulting from 

collisions with transmission structures is very low. Furthermore, anecdotal reports of mortalities do not constitute peer reviewed science or best available scientific information. TESWL-22 does not seem justified considering the very low risk to 

sage-grouse associated with guyed-transmission structures and BLM should re-evaluate the appropriateness of this proposed 

mitigation measure in the FEIS

Thiana

Although the DEIS states at page 2-173 that the environmental protection measures (“EPM’s”) proposed by the Proponents 

apply project-wide (i.e., regardless of land ownership), and the additional mitigation measures proposed by the agencies will apply only to federal lands (except for measures required by the USFWS to meet ESA requirements), the mitigation measure denoted WILD-10 (page 3.10-34) states that it will be applied project-wide, presumably referring to both public and private 

lands. This requirement is not required under the Endangered Species Act. TWE questions the authority of the agencies to 

enforce this mitigation measure on non-public lands and requests that the FEIS clarify the legal or regulatory authority for this mitigation measure

The Mig
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100372 TRANSWEST 

EXPRESS LLC (cont.)

Page 3.11-66 states that mitigation measures TESWL-14 and TESWL-15 are based on recent BLM Instructional 

Memorandums (“IM”). However, it is not stated which IMs are the basis for these statements. As stated, the mitigation 

measures appear to be in conflict with portions of the IMs that have been recently issued by BLM and with EO 2011-5. Wyoming BLM IM WY-2010-012 states that its intent is to be consistent with Wyoming’s core area policy. As such, it specifies that surface disturbing activities that occur in sage-grouse nesting habitat located outside of designated core areas are 

restricted within 2 miles (versus the 4 miles stated in TESWL-14) of occupied leks between March 15 and June 30. Wyoming 

BLM IM WY-2010- 012 also states that surface disturbing activities and surface occupancy in sage-grouse habitats outside of 

designated core areas are restricted within 0.25 miles of active leks (versus the 0.6 miles stated in TESWL-15). Mitigation 

measures TESWL-14 and TESWL-15 should be consistent with IM WY 2010-12 for those segments of the transmission line 

that are in Wyoming. Measure TESWL-11 should also be changed to reflect consistency with WY IM 2010-12

The

On page 3.11-105, PRC-6 (which requires pre-construction surveys) should only be required in habitats that are potentially 

suitable for ferruginous hawk nesting activities

Thireq

On page 3.11-18, the section regarding addressing direct losses of greater sage-grouse as part of the analysis framework should be reevaluated by BLM. Calculating direct loss of sage-grouse would be highly speculative and would likely result in an overestimate or underestimate of the actual impacts. The purpose of the Habitat Equivalency Analysis is to utilize habitat 

services as a surrogate for direct mortality as discussed in the DEIS. Calculating direct loss could be necessary if formal ESA

section 7 consultation was being completed for sage-grouse; however, formal consultation is not occurring. Calculating direct 

loss of individual sage-grouse does not need to be completed for the purposes of the NEPA analysis and should not be required by BLM

Relos

In the last paragraph on page 3.11-71 we would like to point out that listing of greater sage-grouse would have potential negative impacts on the economic stability of many industrial and agricultural activities in addition to the oil and gas industry in Wyoming. The mining, transmission, agriculture and ranching, and wind development industries would all be impacted by listing of greater sage-grouse. The BLM should include in the FEIS a list of all such activities and industries

Thiimp

there is an incorrect statement on page 4-45 that the proposed Chokecherry and Sierra Madre Wind Energy Project is located 

in sage-grouse core area as established by EO 2011-5. The wind project is not in core area and this statement should be corrected in the FEIS

Texwh

100373 GEORGE BILL & 

JOANN KELLEY 

We do not want this power line to interfere with our rock business No

red

100374 WINDI CRAGOE I am in favor of the proposed "red route" on the project Overview Map figure A-1 Yo

 I am not in favor of 2A and 2B proposed route Yo

tab

100375 ROBIN BROWN I am in favor of the "red route" on the Project Overview figure A-1 map Yo

tab

100376 LORI EGGLESTON I am not in favor of the 2A & 2B proposed alternative route through Fort Steele, WY Yo

tab

 I would like to see the route detour around Fort Steele and the community there. therefore I am in favor of the "red route" 

proposed on the Project Overview Figure A-1 Map

Notab

100377 MARTIN & SUSAN 

MUNK 

I am strongly opposed to the "proposed" route in segment 5 (Populus - Borah) Yo

sup

 Powerlines and sharptailed grouse do not mix well No

100378 RAYMOND GENE 

PAULK,MERLE JUNE PAULK,DOYLE GENE PAULK 

According to the Gateway West Transmission Line Project there is a third route called the red line route, and the Governor of Wyoming and everyone else we have talk to including B.L.M. and Rocky Mountain Power, no one want the third route or red 

line...Stay away #3 red line

Yo

100379 ELAINE USREY Why couldn't you run one of the lines north of Glenrock, as 1W(a) and the other line located as the 1E-A. Se

for 

of Adet

100380 CRAIG ROBBINS Segment 1 should follow the current corridor Yo

the conhav

100381 JOHN EATON to repair the power line should be in place where it is fairly accessible by repair personnel, equipment, etc. during the most 

adverse situation

No
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100381 JOHN EATON (cont.) in the winter, during cold weather, these power lines make quite loud popping and cracking noises that can be heard up to 

several miles away. Making it quite a nuisance for anyone that lives up to several miles away.

No conanathocordBA at s

 They also provide an unsightlyness to the views and the terrain around where these small private tracks of land are. Also 

when someone goes out in the country to enjoy the scenery and outdoors they don't want to be looking at power lines

No

 I propose that you follow existing power lines as much as possible No

as 

 Through the Kemmerer, Wy. area I believe this would be route 4A. As this would have the least determental effect on the 

private land owners and the esthetic value of our surrounding area

Yohas 

 In Idaho I do not like routes 7A or 7B. Yo

tab

 Now, the BLM representative we talked to here in Kemmerer was going to send us more information that would have included 

a more detailed map and how it would impact my properties. The one I have in twin creek out of Kemmerer and the other that I have South of Rockland Idaho. We never received this information as of this writing.

Nolocare

100382 ROBERT WIDNER I do not want this power line to be placed on the original proposal. Yo

SeRocurfrom 

 North of the Snake River near the existing lines is where the line should go Yo

sup

100383 PEGGY ROBINSON Please leave the private ground without wires-poles-pipelines and other entrapements. 

It states plainly in SEC 368 Energy Right-Of-Way Corridors on Federal Land -- that the corridor is to be on FEDERAL LAND

Noto b

100384 TEENA LEWIS If segment 9 is installed it would disrupt the self employed individuals who are making a living off their land by invading their 

properties...Segment 9 would interfere with 32.16% of prime agriculture land. This includes pivot line irrigation, flood irrigation, 

crop spraying and equipment usage, causing loss of crops and income.

Yosup

 Alternative 9D would not invade homes, ranches, farms. Yo Alternative 9D affects 9.65% private lands and Simplot has given permission to install the lines on the boundaries of their 

fields.

Yo

100385 MARDEE SMITH I am totally against the first proposed route of gateway project. Because it directly effects our family rancy. Our ranch is 

located from mile marker [number] to mile marker [number] off of Hwy [number]. We have historical trails, Bison jump and other archeological artifacts. It will destroy too of our alfalfa fields. One that we have a pivot on that will be useless if these lines run thru. [Reference number],[Reference number], [Reference number],[Reference number], [Reference number]. It will decrease the land value. It will reduced production of our crops witch is our livelyhood

Noeffe

 I am totally against the first proposed route of gateway project...Looking at the map of the red line (proposed) it would go thru 

the main ranch house, thru our corrals, then my brothers house and too alfalfa fields

Norouset hou

 I vote for alternatives route (green). No

100387 KALEE PARK My family has property up in the Spring Canyon Ranches in between 24N & 116W & 24N 115W. This is a place for my family 

to come and spend time camping, hunting, and hiking. These power lines will be a huge eye soar and also take down many trees.

NoPrethe 

 We strongly believe that Alternative 4A is the best route and it woudl receive our support. Along with resolving the concerns 

above, it is shorter and would result in less overall disturbance than the other routes.

Yo

100388 KRISTY 

PIGEON,JOHN D PRUDDEN 

If the transmission line is for the "greater good of the public" then it needs to be routed on public land. Therefore route 9D and 9E should the preferred route.

Yo
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100388 KRISTY 

PIGEON,JOHN D PRUDDEN (cont.) 

There were few KOP's performed in sensitive areas along proposed Segment 9 compared to the greater number of KOP's 

performed on the alternative routes. For example: The highly visually sensitive area where the proposed route 9 crosses the 

Bruneau River Valley was not studied.

Theadjreswe Se

 The comparative numbers of raptor nests impacted by the proposed route versus the alternative routes is not accurate. 

Regular counts are performed in the SRBOP (Snake River Birds of Prey), however, there is no accurate data for nest counts along proposed route 9 or alternative routes that are outside of the SRBOP boundaries. For example: Raptor nest counts were 

not performed along the area where the proposed route 9 crosses the Bruneau River Valley. This area supports considerably 

higher raptor densities than were noted in the majority of the SRBOP.

Are

upoupodefArepot

 Table 3:10 erroneously states that proposed segment 9 does not cross mule deer fawning areas. This past spring I noted one 

mule deer and one whitetail deer fawning areas within 200 yards of the centerline of this segment near the Bruneau River. Since this is a relatively small area that I happen to know well, I would surmise that the EIS data is completely inaccurate. In 

addition, there are no bighorn sheep herds near the alternative route 9D.

Muspeby theuse resnot gamthedet

 Table 3.9-9 states that the amount of construction impact to wetlands for the total length of proposed Segment 9 is .8 acres. 

This figure is not accurate because the damage to wetlands at the Bruneau River crossing point alone is considerably greater 

than .8 acres. In addition, the Natural Resource Conservation Service and the US Fish and Wildlife Service have completed 

wildlife restoration projects that would be negatively impacted and are located immediately under the path of proposed Segment 9 in this area.

No we

 The EIS does not address the impacts of the transmission line traversing the Burneau River Valley. Much of this area is held in 

private land ownership. The result of a power line through this environmentally sensitive area would cause a plummet in land value and a negative tax consequence to Owyhee County. In addition, the negative impact to wildlife and recreationalists who frequent the area would be dramatic.

Imppp. Se

100389 O PALMER 

AUST,SHARON AUST 

We are residents of Glenrock and are very concerned about the negative impact that the Gateway West 1E transmission line will ahve on our community. This proposed preferred routing of the line traverses between the town and Interstate 25. This preferred route is too close for several reasons: ... - Our beautiful view of the Laramie Mountains would be adversely affected. 

- The visual blight when approaching town from the freeway woudl be very detrimental to the community.

Noconpro

 We are residents of Glenrock and are very concerned about the negative impact that the Gateway West 1E transmission line 

will ahve on our community. This proposed preferred routing of the line traverses between the town and Interstate 25. 

This "preferred" route is too close for several reasons: ... - It dissects land that the Town of Glenrock plans for development.

Noconpro

 We strongly urge the US Bureau of Land Management use the optional route IE-A. This route would be far less impact on the 

Town of Glenrock.

YoSein tCh

 We are residents of Glenrock and are very concerned about the negative impact that the Gateway West 1E transmission line 

will ahve on our community. This proposed preferred routing of the line traverses between the town and Interstate 25. This 

preferred route is too close for several reasons: - The value of residential real estate in the immediate vicinity would be drastically reduced.

YosupAlteana

100390 JOAN PERMANN For the public put on public ground No

(se

100391 LYNN 

DAMPMAN,JOHN L DAMPMAN JR 

The proposed route between the town of Glenrock and I-25 will definitely be visible from homes in Glenrock. This is also the main road for the residents and visitors coming into and leaving Glenrock which commands a picture of pride. The town of 

Glenrock has planned development of that area for future growth and we're pretty sure a high powered transmission line isn't in their beautification concept. The visual impact alone will be enourmous for the residents of Glenrock and visitors alike with 

the current route

Yosupconexitho
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100391 LYNN 

DAMPMAN,JOHN L DAMPMAN JR (cont.) 

Moving the line further south, Route 1E-A, along existing high power routes, would affect fewer people for this portion of the 

project.

Seroucurfrom 

100392 SCOTT THAYER Project should be developed only if it avoids impacts to historic Fort Steele area. If project comes to the fFort Steele area it 

should stay to the proposed time to the South. 

Noconin C

100393 ROBERT L JR 

HARPER,TINA HARPER 

We would like to encourage the management team from Gateway West Project to use an alternate route for the line near Glenrock, Wyoming...The proposed route between the town of Glenrock and I-25 will definitely be visible from homes in Glenrock

Yoin tlist det

 Moving the line further south, Route 1E-A, along existing power routes, would affect fewer people for this portion of the project. Yo

supAlteana

 The proposed route between the town of Glenrock and I-25 will definitely be visible from homes in Glenrock. This is also the 

main road for the residents and visitors coming into and leaving Glenrock which commands a picture of pride. The town of 

Glenrock has planned development of that area for future growth and we're pretty sure a high powered transmission line isn't in their beautification concept. The visual impact alone will be enourmous for the residents of Glenrock and visitors alike with 

the current route.

YosupAlteana

100394 ANGIE ROYBAL According to the map "Project Overview Figure 1-1" the proposed route in red clearly goes around the Ft. Steele Community 

and historic site. I am in favor of this route for the following reasons: The transmission line does not go through or over thecommunity for Fort Steele therefore preserving human life, livestock, wildlife, the historic site, and the property value of all structures and residences.

Yosup

 I do not support the 2A and 2B alternate routes. Yo

tab

100395 ELSIE DEININGER As a landowner operating a ranch SW of Douglas, I am strongly opposed to any roject to build high voltage power lines 

through the mountains.

Noconpro

 The construction of power lines in high altitude mountains is hard to justify when the same transmission capacity could be 

achieved by parraleling existing corridors.

Noconpro

 the construction of extremely expensive lines to serve wind turbines is even more lacking in common sense. In the end, wind 

generated electricity will not prove affordable

Noconpro

100396 LONNIE BARTLETT My concern is that just this week on the county road (Lincoln 314) Sage Grouse were slowly crossing the road by the family 

ranch. If there is more traffic due to this line, these birds will die when people don't stop like the local people do to let them 

pass.

NoThe conpro

 I have read much of the material and I think the route the Govenor has recommended is best. Alternate 4A. Yo

100397 CALINE BARNES Our ranch is within Section 4 of the proposed route for the Gateway West Transmission Line Projet....We have many concerns 

about this route.

Nosup

 We strongly believe that Alternative 4A is the best route and it woudl receive our support. Along with resolving the concerns 

above, it is shorter and would result in less overall disturbance than the other routes.

Yo

100398 O PALMER 

AUST,SHARON AUST 

My family has property up in the Spring Canyon Ranches in between 24N & 116W & 24N 115W. This is a place for my family to come and spend time camping, hunting, and hiking. These power lines will be a huge eye soar and also take down many trees. 

Nocurfrom 

 We strongly believe that Alternative 4A is the best route Yo

now a d

100399 JESSI SUMMERALL We strongly believe that Alternative 4A is the best route and it would receive our support. Along with resolving the concerns 

above, it is shorter and would result in less overall disturbance then the other routes.

Yo

 Our ranch is within Section 4 of the proposed route for the Gateway West Transmission Line Project....We have many 

concerns about this route.

Yosup
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100400 TERRY ASKIN you can follow the 1 W line with 1EC line No

has conpro

 1 E route is not needed Yo

1E as 

 some of your wildlife information on birthing times are incorrect (use common sense) Ass

thePro

 there is a lack of impact results on livestock and private land owners, their rights are being overlooked. No

100401 GLENROCK 

ECONOMIC DEVELOPMENT INC. 

1E goes through the town of Glenrocks Gateway addition. This area is the future expansion of our town. Yo

supAlteana

100402 MARY MARTIN This letter is to express my OPPOSITION to Segment 1W(a) of the proposed Gateway West Transmission line project. I own 

land in Converse County and have strong concerns about how this project will negatively impact my property, the adjacent 

lands, and the quality of life in the area.

YoRolist det

 The disruptive nature of this project and the lasting implications of a permanent change to lands currently unspoiled by this 

type of development could be avoided by using the existing utility corridor. It is not valid for Rocky Mountain Power to create a new corridor when the existing one will work.

Nolinebee

100403 DONNA SCHNEIDER Please find a new route around Fort Fred Steele Wyo for the Gateway West Transmission Line. Yo

inc

 This should be thought out now to use a new route around old Fort Fred Steele area. There are many areas of open land 

between us and Walcott Open land south, that Gateway West Transmission Line can cross the North Platte River more easily.

NoRoas 

100404 RON GRANT The Alternative 4A is the routeI would support; it is shorter and would result in less overall disturbance than the other routes. Yo

proconin C

 Our ranch is within Section 4 of the proposed route for the Gateway West Transmission Line Project. I have many concerns 

about this route.

YosupThe Pre

100405 LEE GRANT The Alternative 4A is the route I would support; it is shorter and would result in less overall disturbance than the other routes. Yo

has in t

 Our ranch is within the proposed route for the Gateway West Transmission Line Project. I have many concerns about this 

route.

Nocom

100406 M. SUSAN EATON There are already multiple transmission lines in the 4A route. It seems this already has existing infrastructive and, therefore 

there is less environmental impact than the other routes in this area.

Yo

100407 JIM KOUACH It would appear that if the public and landowners opinions mean anything in this selection process, the "north route" through 

Lincoln county Wyoming would no longer be considered.

Yosup

 By choosing any of the three southern routes, it would seem that the possibility of litigation in this matter would be greatly

diminished.

Nosup

100408 ERNEST C 

BARNARD 

If the line was to go through, we are supportive of the line going from Poplus to Borah going through the Fort Hall Indian 

Reservation.

Yo

 We have been against his coming through our farm ground since it's inception several years ago. 

We have farm ground in Segment 7 in Rockland within the indicated "MILE radius".

Yosup

100409 TY HUNT I am opposed to the selection of the Northern Route Alternative being considered in Segment 4 of the EIS Yo

sup

100410 COLIN HUNT I am a fifth generation rancher on Fontenelle Creek, very near to the proposed northern route of the Gateway West 

transmission line. I am very much opposed to your approving this route

Yosup
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100410 COLIN HUNT (cont.) Since there is an existing corridor for high voltage transmission south of here, called by you a "Feasible Alternative", I request 

that you run your new line parallel to that existing route.

Yo

100411 SUE HUNT We are, of course, opposed to the proposed northern alternative for the transmission line Yo

sup

 Please consider running the new line parallel to the existing route Yo

100412 STACEY PERES I am not in favor of the 2A and 2B proposed alternate route through Fort Steele, WY Yo

tab

 I am not in favor of the 2A and 2B proposed alternate route through Fort Steele, WY. This route is too close to human life. 

I am in favor of the proposed "red route" on the Project Overview Figure A-1 map.

Yotabtab

100413 BRENDA JAURE I am not in favor of the 2A & 2B proposed alternative route through Fort Steele, WY Yo

tab

 I am in favor of the proposed "real route" on the Project Overview Figure A-1 map. Yo

100414 RICHARD C BISHOP The best way for The Gateway project to have the least environmental impact would be to follow existing utility right of ways 

without crossing additional municipal or private property. If it is absolutely necessary to cross private property, it should be 

parallel and adjacent to existing utility easements.

As use wh

 I am opposed to the project's plan to cross Glenrock's south municipal boundary and the creation of a new utility corridor 

through the Laramie Range and Shirley Basin.

Yosup

conexitho

100415 ALBANY COUNTY 

BOARD OF COMMISSIONERS 

1E-A and 1E-B would be constructed away from the existing 230 kV transmission line corridor between Aeolus and Windstar whereas alternative 1E-C would closely follow the existing 230 kV transmission Line. We are oppossed to alternatives 1E-A 

and 1E-B [*There appears to be some route confusion. 1E-A does go along an existing line near Glenrock. Instead of 1E-A 

and 1E-B, they may mean 1E and 1E-B, and the alternatives they prefer may be 1E-A and 1E-C; those follow existing 

transmission lines. But I'm entering it the way they wrote it.]

YoSe

in tCh

 We strongly disagree with Rocky Mountain's conclusion that 1E-C does not meet the projects purpose and need. They have 

not demonstrated the need to construct transmission east toward Garrett and the offsets proposed for Alternative 1E-C should 

meet criteria for line spacing established by the Western Electric Coordinating Council. If wind is developed to the east of 1EC, which we believe is unlikely given the location of sage grouse core area, laterals could be constructed directly between 

Aeolus and the wind farms without the need of constructing either alternative 1E-B or IE-A.

YoSe

in tCh

100416 DALE 

ROBBINS,SAUNDRA ROBBINS 

We would like to see route 1E-C which follows the existing corridor used for this Transmission Line. Yo

Sein tCh

 We are against the routes of 1E,1E-A and 1E-B for the following reasons Yo

supof Adet

 Routes 1E,1E-A and 1E-B are not needed as there is a proposed transmission line, Wheatland-Chugwater to Aeolus that 

would pick up any wind turbines to the southeast of them.

Yosupof Adet

 Route 1E, 1E-A and 1E-B would go through prime elk habitat being area 7 which is one of the best trophy hunting areas in the 

state. The line and building of it would disrupt the elk mating and calving season as well as the hunting season

Yosupof Adet

100417 THERON BLAKE 

SOUTHWICK,JANA SOUTHWICK 

Feasible Alternative Route going to the South of the Proposed Route from mile post 99 (which crosses an existing power line) 

to the Caribou-Targhee National Forest Boundary at mile post 168. This Alternative Route would have less impact on the home owner residences of the Bear Lake Ranches by having the Gateway West Transmission Line to the south of the existing power lines. With this route there is also less transmission that needs to be constructed which will cut down on the cost of this 

transmission line section(in the proposed route there is a huge jog in the transmission line from mile post 100 to mile post 149 

that goes north). Another benefit of having this transmission line running south of the existing line is that there is a lot less of 

tall vegetation (trees) that will have to be controlled in the future thus lowering the maintenance cost of this section.

Noin t
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100418 HOLLIS R LARGE The possibility of a major power transmission line referred to as the northern alternative for Segment 4 of the Gateway West 

Project paralleling Fontenelle Creek and crossing Commissary Ridge is very disturbing. Not only does this area abound in wildlife, it is in extremely close proximity to the historic Sublette Cutoff of the Oregon Trail. Please consider a less disrupting 

route for this power line instead of across this pristine, scenic, historic terrain that will be forever changed. 

Yotabconpro

100419 LYNN 

FINDLAY,DAYLE FINDLAY 

Opposed to how this project would impact the Fontenelle Creek ranch lands. It would make an adverse impact on the livelihood of those who are dependent upon those lands.

Yosup

 It only seems logical to STAY WITH THE EXISTING CORRIDOR. No

as 

100422 OWYHEE COUNTY 

BOARD OF COMMISSIONERS 

We request a meeting at your earliest convenience to discuss in detail the impacts that resulted from the changes made to Route 9D and to discuss alternatives that will be more acceptable to the County

Ad

 In order to provide for sufficient time in which to resolve these issues and in which to prepare effective comments on the DEIS, 

we also request that the comment period be extended for an additional 60 days

Adcom

100423 WALTER SAVAGE It is my opinion to build the power lines in the northern route in Section 4 would also do a great injustice to those who own 

property in the Commissary Ranch and Spring Canyon.

Yosup(4ABL

100424 LINCOLN 

CONSERVATION DISTRICT (WY) 

The idea that it is needed for security reasons is ludicrous. Why then, does it not take an entirely different path throughout the 

whole stretch of the prosposed corridor? It seems something is being misrepresented.

Nois d

 It is not in the best interest to carve a new corridor through southern Lincoln county through scenic ranch land up Pomeroy 

Basin and down Pine Creek northeast of Cokeville, Wyoming, when an existing corridor already exists.

Noas 

100425 THOMAS THRASH I strongly request that Segment 4 Proposed Route be eliminated Yo

sup

 If Segment 4 is the route selected private landowners in Mamouth Hollow are off the grid. No provision is addressed in "EIS" 

for property owners to obtain power.

Yosup

100426 HIGH VALLEY 

RANCH, LLC 

I don't understand why route 1E through the mountains is being considered at all Se

the Ch

 Please give more consideration to using the existing corridor, route 1E-C, for the Gateway West Transmission line. Yo

Se

Alteana

100427 CAROLYN FIRTH I would very much favor the more southern route that essentially follows the Utah-Idaho state line Yo The Proposed Route would take out of production some of the most fertile land not only in Idaho, but in the whole world. Yo

sup

 the financial estimate of agricultural rental payments used on page 3.4-41 (Chapter 3). There is a statement that in Idaho 

cropland in 2010 rented for an average of $160 per acre for irrigated cropland. As a farmer, I have first hand knowledge of the

amount of money it takes to rent an acre of irrigated land. The figure of $160 per acre is definitely too low. A more accurate figure on the low end would be $200 per acre, and as high as $600 or $700 per acre for high value crops such as potatoes. 

No

 prime farmland in Cassia County....Proposed Route would be devastating to agricultural production in a portion of Cassia 

County. 

Yosup

 the EIS does not mention that once a right-of-way is established with one power line, it will be much easier to construct 

additional power lines along the same route. In fact, it is my understanding that as many as four additional power lines spanning a width of two miles could be constructed in the future. The EIS should make it clear that the scenario of a 2-mile 

wide corridor of five transmission lines side by side is very probable 

Thi

 the Power County Task Force was quoted numerous times, but findings of the Cassia County Task Force were not included in 

the EIS. Why were they not included? I know several people who spent many hours meeting with the Cassia County Task 

Force. Were their findings contrary to what Idaho Power prefers, so they were dismissed? 

As a PPow
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100427 CAROLYN FIRTH 

(cont.) 

The EIS mentions that the impact on agriculture will be minimal when compared to the entire project area, but I would argue 

that point. To the many farm families who would be affected, their entire livelihood would be destroyed. Idaho, and Cassia 

County in particular, will not benefit from this transmission line. Yet farmers in Cassia County are being asked to sacrifice everything. There will be a domino effect when production agriculture no longer contributes to the tax base in Cassia County. I

strongly urge you to seriously consider and alternative route, specifically the southern (state line) route for this transmission 

line. 

No

100429 APRIL 

BARNES,ERIC BARNES 

We believe that the transmission line should parallel the existing route. [segment 4] No

The conpro

 We are deeply concerned about the Northern Alternative being considered in Segment 4 of the EIS. 

We are opposed to the selection of the Proposed Northern Alternative.

Yosuplinetha

 The existing transmission line has already been compromised. It is unnecessary and completely ridiculous to disturb a new 

corridor.

NoThe conpro

 We are deeply concerned about the possbile health risks associated with high voltage transmission lines. Some research has 

confirmed the presence of chronic lymphocytic cancers and childhood leukemia in human populations associated with ELFEMF (extremely low frequency-electo magnetic fields). Ongoing recent studies have also identified neurodegenerative and cardiac diseases.

Ele

 [Ranch] is in the process of placing a Conservation Easement on its holdings. We are working with the Wyoming Game and 

Fish Department, and were advised that the proposed northern alternative for the transmission line will prevent the completion 

of the Easement. This will bring extreme economical hardship on our family and business.

NoThe 

conpro

 In light of the face that there is an existing line south of here, and it has already been disturbed, we ask you to authorize the 

new line to run parallel to it

NoThe conpro

100430 TIM NELSON There can be no doubt that a major new overhead transmission line will decrease the value of my land and any land it crosses 

or abuts.

The 

 OPPOSITION to Segment 1W(a) Yo

Serevin tCh

 There is an existing utility corridor that is the logical, sensible choice for siting new overhead transmission lines. I am FOR 

Alternative Segment 1W-A, which follows the utility corridor already in use.

Yo
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100432 KIMBERLY CAIN,DAVID

DIEDE,M D

GRIFFITTS,KEITHWAYNEGRIFFITTS,LARRY L

HERON,JOANNEHERON,SCOTT L

HOWE,JOANNEHOWE,GERALD LJENKINS,PATTYJENKINS,MELANIE

JONES,BRAD

JONES,(ILLEGIBLE)PLUMMER,SHELLEYPLUMMER,MELANIESERRES,HEATHSERRES,JOHNASTRADER,RANDYSTRADER,SALLYSUPPES,DOROTHYVELASQUEZ,VERNONVELASQUEZ,MICHELLEWICKISTON,SCOTTWICKISTON,KARENWORL

the specific portion of the route that we object to is the segment which runs between Glenrock and Rolling Hills and is labeled

1Wa (shown in red on the map).

YoProarebee

100434 VERNON CLIFFORD 

AND ELAINE MILLER 

I'm not in favor of the proposed route, because it goes through my productive farm ground - devaluating the property. Yo

 I'm not in favor of the proposed route, because it goes through my productive farm ground - devaluating the property. Yo

100435 RICHARD 

TEFERTILLER 

We are opposed to the Gateway West Project. No

 Our suggested route is the green route that would follow the excisting route. No The red route affects the Commissary Ridge area. It affects the South Fork mountain area specifically. It directly affects the

spring creek ranch area. 

Yosupline

100437 VERNON CLIFFORD 

AND ELAINE MILLER 

I am suggesting a method of keeping raptors from roosting on the towers where the power line crosses sage grouse and 

sharp-tailed grouse habitat for your consideration. The method is to use sheet metal so raptors' claws can not dig into the surface. On top of vertical parts of the tower a cone (Figure 1) can be welded to the top of the vertical part. The cone should

be very steep sided and pointed so raptors can not balance on the cone. On cross beams (Figure 2) a tall triangle of sheet 

metal can be welded to any horizontal beam or part of the tower where raptors might roost for long periods searching the 

ground for sage grouse or sharptailed grouse. I request you strongly consider this method of keeping raptor predation on sage 

grouse and sharptailed grouse.

Nocon

100438 NANCY 

FITCH,LARRY FITCH 

We cannot stop them so since we already have 3 lines running thru our property, I don't think we should have to have any 

more. They do devalue your property, a pain to farm around and if we were to end up with 2 more they would be over the top of our home.

No

100439 DARRELL M FUNK if this is a public benefit then put it on public lands No

site ma

 If you are worried about the roads you make close them No

hav

100440 RICHARD & SUE 

FARNER 

We are in agreement with the proposed route of 8 Yo

 We oppose the feasible alternative route 8B Yo
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100441 DEWITT & BECKY 

MARSHALL 

My request for the Gateway Project is to follow the proposed route for the SWIP transmission lines - which runs 2-3 miles to 

the west of my land along map section line 18E & 19E. The route has already received the proper easements and would be a much less intrusive route on farmers/ranchers in the area. Thank you for your consideration.

Noconpro

 The proposed Gateway corridor runs through my property and would be extremely difficult to navigate through my irrigation 

system & pivots

No

100442 WALTER SAVAGE Last I would like to point out that because you called the "northern" route the "proposed" route, most of the local people 

already believe the decision has been made and their views and comments don't matter and that there is no point in making comments.

Nocurfrom 

 I am opposed to the "northern route" Yo

suplinetha

 the "northern" (in Section 4) route will fragment and spoil an otherwise pristine area. Right now from the existing corridor north 

to Hoback and Daniel the entire area is a sportsman's paradise and this area would be degraded with a "northern" route 

decision. I fish regularly on Fontenelle creek which I consider to be a blue ribbon trout stream, rainbow, brown & cutthroat trout 

can exceed 20" and with power lines running overhead I would no longer fish there. #2 is the Sage Grouse population is very 

healthy in the Fontenelle Gap area. I have seen very large flocks when I've been antelope and elk hunting in the area

Yosuplinetha

 the migratory path raptors take along Commissary Ridge. 

I have sat in the blind with "Hawkwatch Int." and have read their reports that state that Commissary Ridge has one of the 

highest species passage rates of all their monitoring sites. Your "northern" route will be directly adjacent to Hawkwatch's 

monitoring sites and any raptors flying low will be subject to harm

NoThe dro

 the viewshed aspect. I realize that the Oregon Trail & Fossil Butte are part of the N.P. System and as such have special value. 

However with the existing lines already spoiling their view it makes absolutely no sense to go out and spoil another area that is otherwise pristine. Also Fossil Butte has a major trucking Hwy 30 and a railroad that already pass right next to it and every 

hilltop in the surrounding are now has a white scar on the top where new private fossil digging quarries are opening up, as a 

result the Fossil Butte view area is already spoiled

No

100443 CORDELL KRESS Possible Alternative Segments 5B and 7B of the Gateway West Transmission Line Project cross several miles of our owned 

and operated cropland. Consequently, we are opposed to the construction of both lines 

Yo

100444 CEL 

BARNES,HOLLY BARNES 

Our suggested route is the green route that would follow the excisting route. [**comment location and additional information indicate this is route Alternative 4A]

YoProlist det

 The Red route also affects the Commissary Ridge area. It affects the South Fork Mountain area specifically. It directly affects 

the Spring Creek Ranch area.

Yosuplinetha

 We are opposed to the Gateway West Project No

100445 JAMES COLLINS As a concerned citizen and resident of Glenrock, WY, I have an issue with the proposed route from the Windstar Substation 

near Dave Johnston Power Plant through the annexed city land between I-25 and the Town of Glenrock.

Yo

 Our (residents of Glenrock) proposed choice would be one of the alternative routes along or near an existing southwesterly 

power line from Dave Johnston Power Plant and bypassing Glenrock

Yo

100446 ROSALIE GOFF As a member of the Glenrock Town Council, I encourage you to find an alternative route for the transmission lines than to 

cross through the annexation area south of our town limits. I feel that the lines would be a hindrance to future development in

this area.

The tranlist det

100447 STUART & LINDA 

MININGER 

BLM and state ground is owned by the people, and it would be better to use one of the “Feasible Alternatives.” No

bee

 Twenty Mile Rd, Owyhee County, Grandview, ID. ...We would appreciate if someone in person would come out and look over 

this situation and give consideration.

Yotab

 The way I understand, the south proposed route would go up Twenty Mile Rd on the south side of the road we have a 1⁄4 mile 

pivot set up as a 1⁄2 swing with the pivot point backed up to the road. At the open house meeting in Murphy, ID in Sept. they told us on flat ground they span maybe 1200 feet between towers. The existing irrigation systems cover 2600 feet.

Effthaby 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100447 STUART & LINDA 

MININGER (cont.) 

asked them at the meeting if they realize this. No 1) the south side of the road they cant span 2600 ft. No 2) the north side of 

the road, my neighbors house is next to the road. Then you go up the road another 1⁄2 mile, I have a neighbors house 50 to 

100 ft on the south side with a shop on the North side (map included). The representative at the meeting said the aerial photos

don’t show all those details

NoAltehoufrom 

100449 IDAHO STATE 

HISTORIC PRESERVATION OFFICE 

3.3-219-3.3-220 -- [blank] -- Idaho SHPO -- Once again, photo simulations should be provided for segments in the area south of the Oregon Trail site of Three Island Crossing (KOP C61). 

Chfor at t

 alternative 7C. Its distance from Parting of the Ways seems adequate, but a photo simulation, especially from KOP C63, would 

be very helpful. Is it possible to develop an alternative that would swing to the north, closer to the freeway? 

Aptho

 3.3-197-3.3-199 -- [blank] -- Idaho SHPO -- Photo simulations should be provided for segments in the area south of the 

Oregon Trail site of Three Island Crossing (KOP C61). It is difficult to assess the effects of alternatives 8A or the proposed alternative 9. 

AdProwh

 3.3-241 -- [blank] -- Idaho SHPO -- Can a meaningful table be developed without using such a complex formula? 

3.3-243-3.3-247 -- [blank] -- Idaho SHPO -- Table 3.3-7. Why is an “Adjusted Impact Value” not provided for the proponent’s 

proposed alternatives for the entire line? It is very difficult to draw conclusions from this table without those figures. This may 

be due to our lack of understanding of the table, but to the cold reader, this table is not very valuable. 

Se

notthe culto happindproThirisk AlteImpof ivalfewAltefasbe 

 3.3-27 -- 5 -- Idaho SHPO -- Under Prehistoric Resources by Segment and Alternative, it states that the properties listed in 

Table 3.3-3 are those listed in the National Register of Historic Places, considered or assumed eligible for listing, or 

unevaluated. This should be restated in the title or in the footnotes for the table. 

Thi

 3.3-37-3.3-38 -- [blank] -- Idaho SHPO -- As above, are the sites presented in Table 3.3-4 only those listed, eligible, or 

assumed eligible for the National Register or unevaluated? If so, this should be clarified on the table. 

Adon hisor u1-m

 3.3-34 -- 2 -- Idaho SHPO -- The geographic feature “Browns Bench” lies largely in Idaho. It should be described in the Idaho

Prehistoric Resource Overview as well as in the Nevada overview. 

AdRe

 3.3-59 -- 3 -- Idaho SHPO -- City of Rocks should be described in this Section. Three of the alternatives pass close to this 

National Historic Landmark. 

The NH

 3.3-68 -- 1 -- Idaho SHPO -- The BLM conducted the 15% sample survey to gather data that would inform the BLM’s selection 

of a preferred alternative. Yet the only discussion of the 15% survey results in Idaho is presented in two sentences. How does this inform decisions? Overall, the DEIS provides little analysis of the archaeological information available—either previously

recorded properties or properties identified during the 15% survey. This shortcoming needs to be corrected before preparation 

of the final EIS so archaeological data can be fully considered in selecting a preferred alternative 

Newitinfoof i

 3.3-70 -- [blank] -- Idaho SHPO -- CUL-8 should also state that the relevant state burial law will be followed for human remains 

discovered on non-federal lands. 

CRpre

 3.3-71 -- 1 -- Idaho SHPO -- Under the fourth bullet, the words “within it.” should be deleted. Info 2-203 -- 4 -- Idaho SHPO -- The second sentence in this paragraph seems to contradict our understanding of BLM authority on 

this project. SHPO review is conducted under Section 106 of the National Historic Preservation Act. For purposes of Section 106, the BLM is reviewing the entire project, regardless of land ownership. Is this different under NEPA? 

The proma
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100449 IDAHO STATE 

HISTORIC PRESERVATION OFFICE (cont.) 

3.3-173-3.3-175 -- [blank] -- Idaho SHPO -- The proposed alternative 7 passes very close to the Oregon/California Trails site 

of Parting of the Ways. In that location, proposed alternative 7 should be dropped from consideration. 

Yosup

 3.3-128 -- [blank] -- Idaho SHPO -- KOP C105 It is difficult to tell if Segment 4 (in Idaho) in the area of Oregon Trail’s Big Hill 

will have a visual effect on that site. How can we evaluate visual effects for this segment if land owner access is denied? 

We site KOfrom denadd

 3.3-167-3.3-172 -- [blank] -- Idaho SHPO -- Alternatives 7H, 7I, 7J will adversely affect the setting of the California Trail and 

alternate trail segments (KOPs C22,23, 65-70 and others). From a cultural resources and historic preservation perspective, 

these alternatives should be dropped from consideration. 

Yotab

It is difficult to assess alternative 7C as there are no photo simulations from KOP C63 or KOP C64 toward alternative 7C. Its distance from Parting of the Ways seems adequate, but a photo simulation, especially from KOP C63, would be very helpful

Se

100450 KAREN BUCK do not want the alternative 4g.1 that will be crossing my property. This would totally destroy the beauty of the valley, cross the 

river in prime hunting and fishing areas, be a hinderance to the wild birds in the area, noise created from the lines, as well as being to close to the living quarters on my property. 

Yo

 keep it in the corridor with the other three already in place which has already shown little impact and to which the animals are 

used to, or to follow the proposed route 4 D.E south of Kemmerer. 

Yo

100451 WILLIAM KRALL oppose “Segment 4 Proposed Route” north of Kemmerer Yo

supline

 Putting the new lines next to the existing lines, it seems to me, would be beneficial from a business stand point also. Line 

inspection and maintenance would be economical since they would all be together and not all over the country

YoPro

 Opening up another portion of the Oregon Trail doesn’t make any sense as far as preservation is concerned. 

Segment 4 of the proposed route would put the transmission through some “wild and undeveloped” country. This area acts as 

the main ecosystem for deer, elk, moose, bear, and other populations of wildlife. It would affect the existence of such protected species as the lynx cat and wolverine. This area is also where migratory raptors are studied each year during the fall. I don’t

believe that the effects of this route have been completely addressed.

Yosupline

100452 LEWIS ROBERTS I submit that there are ...routes gateway can take with least impact on environment & people. 

1 – South rt. Proposed by Cassia Cty, but turning & taking rt. up through valley on west side of City rocks past Oakley 

reservoir.

No

 I submit that there are ...routes gateway can take with least impact on environment & people. ... 

A proposal by Bill Loghmiller that is a little north of proposed rt. of gateway’s.

NoThe

100453 GARY BAILIFF There are also several prime ranching operation on this Route, Section #4, that will be forever hampered in using their grazing 

lands for this transmission line.

No

 It is my understanding that many residents of Kemmerer, Commissary Subdivisions, Residents, Sportsmen from a variety of 

other areas, and the Governors of Wyoming (past & present) prefer using the existing corridor. Certainly NOT the proposed 

corridor (Section #4)

No

100454 CHRIS BILLINGTON I'd like very much to cast a voice towards Keeping it off public grounds No

site ma

100455 IDAHO 

DEPARTMENT OF LANDS 

Alignment of the Transmission Line to capture renewable resources along the route should be given attention. The 

sta

 Final location of any easements should be placed, wherever possible, in locations that will result in minimal negative impact to 

the function and productivity of Endowment land. 

The loc

 Among these impacts are: 

a. Spread of noxious weeds. Area-specific management plans will be necessary to protect the condition of the state land and 

neighboring land owners; b. Potential loss of access to Endowment Lands; c. Increased trespass activity due to proximity of new roads to Endowment Land. 

Meend

 Fire management and suppression activities may be severely hampered by the Transmission Line construction and operation 

and result in loss of Endowment Land productivity. Specific fire management plans should be a pre-construction requirement. 

A f
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100455 IDAHO 

DEPARTMENT OF LANDS (cont.) 

Major transmission line projects such as Gateway West and any accompanying infrastructure will be managed under a lease on endowment trust lands issued by IDL rather than by easement. 

Thi

 In Section 3.17-1, the document incorrectly states that any easement would need to be negotiated with the Idaho State Board 

of Land Commissioners. Negotiation of any easement or lease would occur with the Idaho Department of Lands as the 

administrative arm of the Board. 

Thi

 The location of the proposed route in Township 4 South Range 8 East (Segment 8, near MP 60 Midpoint to Hemingway) is 

unacceptable to the state...IDL recommends relocating this segment to 8d (Alternative not studied in detail) 

Yosup

 State Trust Land along the proposed route on Segment 8 (between MP 90 and MP100 Midpoint to Hemingway) in Township 1 

South Range 3 East and Township 1 North 2 East are identified as Peppergrass Element of Occurrence areas. Construction 

standards and practices should be adjusted to ensure compliance with the requirements for of the existing Candidate 

Conservation Agreement for Peppergrass between the Bureau of Land Management and the State of Idaho. 

Infothe meCC

 The project manager should be aware an IDL cropland lessee has experienced stray voltage issues from several existing 

transmission lines on endowment lands traversed by Alternative route 8a (Midpoint to Hemingway). 

Str

 The proposed route between Midpoint and MP 30 is preferred Yo

tab

 The proposed route between 4j. and 4k. (Wyoming to Populus) abruptly changes direction to the north to intersect with State 

Endowment Trust lands in Township 13 South Range 45 East. Both prior to and after these points, the proposed route closely parallels an existing power line. The location of the proposed line needs to stay as close to the Endowment ownership boundary as possible to minimize the impact to the larger parcel. 

The the avotheadjon 

 The proposed route between MP 180 and 200 (Wyoming Border to Populus) is unacceptable to IDL. The bifurcation of the 

management block by the proposed route unnecessarily encumbers the block as well as impacts future management 

opportunities. The Alternative Route Not Studied In Detail through this segment closely parallels an existing power line, would

maintain the opportunity of future development in this large block of Endowment Trust Land. IDL recommends the Alternative 

Route be. chosen for this location. 

Yo

 Consider the more direct, shorter route identified as Alternate Route 5c in the propose route of Segment 5 (Populus to Borah)

beginning at 5g. to 5I. 

Yo

 The proposed route negatively impacts the Endowment Trust Land. As 

admStatran

 ln general IDL recommends that fire mitigation plantings or improvements to be designed into the project due to the common 

large fire occurrence throughout the length of this project in Idaho. Suggestions include intensive planting and fuel breaks 

around specific high value improvements such as substations, plantings of forage kochia and crested wheatgrass green strips 

on either side of the power line, or similar plantings to create a master fuel break within drainages 

A f

100456 JOHN L FREEMAN I believe that the prefered route should remain in established power corridors. No100457 GORDON C SMITH Looking at the Route Detail Map 29 & 30 and using the Feasible Alternative Route going to the South of the Proposed Route 

from mile post 99 (which crosses an existing power line) to the Caribou-Targhee National Forest Boundary at mile post 168. This Alternative Route would have less impact

Nothe 

100458 GREGORY L POPE Segment 1E to Heward and Segments 1W(a) and 1W(c) from Heward to Aeolus follow existing power lines where the road, 

resource, and view damage has already been done. It certainly makes sense to keep any additional impacts within existing locations instead of spreading them out over previously unimpacted lands. Keep all new lines within existing corridors (1E-C, 

1W(a),1W(c)) which are already the shortest distance to be traveled and will allow for the least overall environmental impact.

The conexitho

 it would make more economic sense to connect any future wind generation within Shirley Basin with spur lines from Aeolus or 

Heward when and if needed, rather than constructing the entire, high-impact 1E section including points 1E(f), 1E(g),1E(i), 

1E(k) in advance.

No

conhav

 It appears that part of the reason for segment 1E between 1Ef and 1Eg is to provide transmission capacity for future wind 

generators to be located in the foothills. If this is indeed the case the future impact will be immense and totally destroy the

character and value of this entire section of the northern Laramie Range

Noconhav

 Please focus any impacts for new lines within existing corridors where most of the impact has already occurred. No

exi
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100458 GREGORY L POPE 

(cont.) 

strongly oppose segment 1E of this project, specifically that segment between reference points 1Ef and 1Eg on the map entitled “Segment 1E/1W Windstar to Aeolus” figure A-2.

YosupThe dro

100459 SALLY AND 

MICHAEL SARVEY 

support Gateway West staying in the established IW Se

follconpro

 not taking off to 1A or 1B through Albany County Se

follconpro

100460 LES AND SUSAN 

BENNINGTON 

Also the proposed 1W (a) should be moved to the 1W(a)-A alternate route from milepost 1 to 10 Yo

SeexiEISCh

 Please do not use the proposed route of 1E Yo

Sefollconpro

 instead use the alternative route of 1E-A. Yo

Sefollconpro

 Also the proposed 1W (a) should be moved to the 1W(a)-A alternate route from milepost 1 to 10. Yo

Sefollconpro

100461 RAYMOND GENE 

PAULK 

opposing your Northern route in section 4. without modifications No

100462 GALE WARD My answer is NO. I do not feel you should burn coal in Wyoming and run a huge line across our place and take the power to 

Nevada and California. Let those people produce their own power if they want it.

No

100463 SHOSHONEBANNOCK TRIBES The Tribes request that the Bureau of Land Management (BLM) consider the issues presented in this comment letter and respond in writing to the Tribes; indicating how the comments were evaluated and where changes, if applicable, were made for 

the final EIS and Record of Decision (ROD). 

The 

 If the proponent wants to pursue a ROW through tribal and allotted lands, the BIA and the proponent applying for a ROV/ 

across tribal lands has a responsibility to follow the process laid out in 25 CFR 169 for transmission lines that cross the 

reservation. The Tribes have the right to evaluate the value of the ROV/ using internal models. The Tribes apply an opportunity

cost model, in-flow methodology, or similar technique to provide an appropriate land valuation rate that considers appropriate 

mitigation for utilization of Tribal lands. The ROW must also be accompanied by the procurement of the appropriate trespass 

permits for proponent employees and closely coordinated with the Tribes' Land Use Department and the proponent has the obligation to follow all other tribal laws and ordinances. The Tribes will retain full enforcement rights on all Tribal lands and the 

corresponding rights to modify permits to accommodate changed circumstances and emergencies. 

The tribthe Tribconthe wrirenAltewit

 Since the BLM has already conducted various studies on the Reservation, the Tribes requests that all data from wildlife and 

cultural studies prepared for this project be provided to the Tribes and that the BLM treat the cultural resource information in a 

sensitive and confidential manner. If the Alternative 5A remains in the FEIS, the BLM and its contractors must coordinate with Tribal biologists and HeTO staff for all on Reservation activities. 

Thi

 Access to hunting areas is a vital component of the Treaty and inherent rights, any proposal to limit the ability to exercise

reserved or inherent rights will be viewed by the Tribes as unacceptable. 

Tre
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100463 SHOSHONEBANNOCK TRIBES 

(cont.) 

Cumulative impacts to the area, if the Project is ultimately approved, may lead to additional energy development along the corridor; further increasing the potential to impact sensitive resources and Tribal rights. The cumulative impacts analysis for

fish and wildlife, cultural resources and Treaty rights reveals substantial impacts to the Tribes in several key areas from this 

particular Project. Taken as a whole, the Project will increase the likelihood that irreversible and irretrievable impacts will occur 

to natural and cultural resources of importance to the Tribes. While it is important to reconcile energy needs with available 

resources, an analysis of the Project reveals impacts of serious magnitude to the Project area. Simply driving through major transportation routes in Idaho and eastern Wyoming, it's apparent that a dramatic increase of 

wind farms and natural gas development is occurring, which may result in impacts to migratory birds, wildlife and especially to

regional and local habitat. Major changes to the character of the land are being made, often with no analysis for those wind 

farms constructed on private lands. The purpose of an effective cumulative analysis is to account for those reasonable and foreseeable impacts from increasing the capacity of existing transmission lines; which in turn increases the demand for energy resources along the corridor from wind, hydroelectric, coal and natural gas. 

The forefutu

 adverse modifications to wildlife habitat are also a significant concern for the Tribes and a re-evaluation potential habitat

mitigation measures should also be considered during the planning process 

The 

 The integrity of the migratory flyaway is an issue that needs to be carefully examined in the final EIS and according mitigation 

measures need to be incorporated into the ROD for the Project. The Tribes are particularly concerned about the alignment for 

the Project being perpendicular to the migratory flyway and its potential to disrupt utilization of available habitat in the Project 

area 

Impund

 The raptor species are of critical cultural importance to the Tribes that would be negatively impacted by the Project, and each 

alternative contains significant risks to the integrity of the species along the Project corridor. Golden eagles carry an especially 

high intrinsic value to the Tribes, so the Tribes request to be involved in the studies that may be necessary to determine eagle use of the area, including potential telemetry studies, Invasive methods that may result in undue stress to eagles must be avoided. The Tribes are particularly concerned about the corridor's alignment alternatives that encroach near or through the 

Snake River Birds of Prey National Conservation Area south of Boise along the Snake River 

ImpSnundbe can 

 The Tribes do not support any proposals which would result in the short or long-term displacement of Sage Grouse, and urge 

the BLM to monitor habitat and populations to prevent adverse impacts from the proposed Project 

The 

 In accordance with the Tribes' Policy for Management of the Snake River Basin Resources, the Tribes urge the BLM to require 

active restoration of the native plant communities potentially affected by Project activities...The Tribes request a full restoration 

of any construction disturbance, utilizing native plant species, and the proponent give specific management protocol for 

preventing the spread of noxious or invasive species during other Project activities; such as routine driving along trails for maintenance...The Tribes would recommend including an analysis in the FEIS for a comprehensive vegetation management 

plan, developed by the BLM and the proponent, to reduce or eliminate the probable impacts to vegetation from the Project. At 

a minimum the Tribes would expect that a proposal for a large scale operation, such as the Project, would include a noxious weed control program and a native vegetation rehabilitation program within the area affected by operations and construction. Successful examples of noxious weed programs often include GIS modeling for weed spread, mechanical and chemical 

treatments, and transport vehicle cleaning stations for all vehicles entering the Project area. A rehabilitation project would 

focus on restoring those component vegetation resources in the project area where feasible. Replanting previously affected areas in the Project area with native species to increase the spatial structure of special status plants would help reduce the 

potential for the Project to adversely impact these resources. In reviewing the DEIS, the Tribes were concerned that these 

features were not adequately presented in the document, and would like to highlight the importance of resource planning for a project of this scope. 

The mu

 The Tribes are concerned about the visual impacts from the 110 to 130 feet steel towers, which would alter the areas that are

not within existing utility corridors. The value of the pristine open landscape is extremely high to the Tribes, must be protected from unsightly towers by constraining development to previously disturbed areas 

The Eff
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100463 SHOSHONEBANNOCK TRIBES 

(cont.) 

Assuming that approval to move forward with the Project is granted in the final EIS and Record of Decision, the Tribes formally

request that an off-site mitigation program be required of the proponent to replace lost or disturbed fish and wildlife habitatalong the corridor. For the purposes of the Project, the Tribes would recommend evaluating habitat impacts to Sage Grouse, 

Sharp-Tail Grouse, raptors, migratory waterfowl, small mammals, fish, and other protected species....The Tribes would 

propose to use the habitat inventory, by target species, found in the EIS to set up a base assessment of potentially lost or disturbed habitat. That assessment would then be converted to a ledger of habitat units that the proponent would be required 

to replace throughout the project life. The Tribes recommend that a program, composed of the relevant fish and wildlife 

managers, be given access to program funds to identify replacement habitat, purchase conservation easements or property from willing sellers, and manage that habitat for the benefit of target species in perpetuity. Every habitat unit replaced would 

then be assessed against the ledger until the transmission line is completely mitigated. Although the proponent will assume that the moderate compensatory mitigation for the easement is enough to cover the externalized impacts to habitat, the Tribes 

maintain the position that if the corridor is approved a program must be developed to replace lost habitat for target species. 

The effeEqperrevgrocovLakare reqbe golreqme

 The Tribes have an expanded definition of cultural resources, utilizing a holistic perspective that encompasses plants, water, 

animals and humans, and the relationship existing between them. Cultural resources located along the Project corridor are highly significant because they directly contribute to the Shoshone and Bannock peoples' unique cultural heritage. Simply stated, a cultural resource is any resource of cultural character. Cultural resources are those social institutions, practices,beliefs, religious practices, sacred landscapes and objects, archaeological sites, natural resources and their use, intellectual 

property, oral traditions, language, historical documents and structures, secular and non secular items are cultural resources.An expanded definition of cultural resources is warranted in the EIS to ensure all resources receive an inclusive analysis for project impacts. The EIS insufficiently characterizes cultural resources as only archeological resources, atypical 'stones and bones' analysis of impacts...In the event that the Project is ultimately approved in some form, the Tribes request that a cultural resource 

management plan should be developed, in consultation and concurrence with affected tribes for these BLM lands, and if 

possible, on private and state lands. If the BLM truly intends to include the Tribes in future preservation or data recovery efforts 

to promote effective management of cultural resources, then any agreements must include the tribes. An effective plan, with tribal participation, should address native plants, subsistence hunting and gathering, medicinal and ceremonial plants, petroglyphs, pictographs, and other traditional cultural properties which may be impacted by BLM land management. 

Interagency coordination may also be required between other federal land managers and local BLM field offices to avoid 

conflicting or duplicative management schemes for cultural resources. 

Formal consultation between local Field Office, Tribal staff, and the Fort Hall Business Council is necessary to effectively 

address the control of confidential information. NHPA [SECTION] 106 Consultation provides opportunity for Tribal input over how best to manage the cultural resources on BLM lands. To date, this Project has raised numerous 'red-flags' with the Tribal community regarding the irreversible loss of significant cultural resources. Any future consultation with the Tribes necessarily 

must include an in-depth discussion about the impacts and what can be 'avoided' through creative management strategies and 

what resources would be destroyed by development; in particular during the actual site selection for an approved route. 

A cultural resource management plan should also include protocols for coordinating with tribes regarding inadvertent discoveries, burials, curation of Native American cultural materials, and Native American archeological sites. The Tribes would

also need to be immediately notified if any cultural artifacts or human remains are uncovered or inadvertently discovered; with

an immediate stop work order for construction activities. When necessary, Section 106 compliance needs to occur or the required NAGPA consultation is initiated with the Tribes. In such a situation, the Tribes request no work proceed until Tribal staff concurs/approves. The Tribes further request that qualified Tribal members be hired to assist in monitoring requirements for this Project 

SeAmnotBLNanot plaPronotShbe The occdisProTredetincInvalteadvwhproculThe wh

dis

100466 IDAHO 

DEPARTMENT OF FISH AND GAME 

App C-3, Section 5.0, Pg. 13-15 -- Big Game - Big game detection surveys are to be conducted within a 1-mile buffer around 

active project facilities in "identified areas," which will presumably correspond to "mapped habitat." Verify that PGC measures

will be applied to all identified areas/mapped habitat within the 1-mile buffer. Also, state how areas to be surveyed, and 

consequently to which proposed PGC measures will apply, will be identified/mapped prior to the detection surveys 

The biobig ani

 App C-3, Section 5.0, Pg.13-15 -- Big Game - State the approach for applying PGC measures if big game animals are 

observed (e.g., incidental observations) during protection periods and within 1-mile of the ROW but outside of identified areas/mapped habitat 

De

 App C-3, Section 5.0, Pg.13-15 -- Big Game - Specify anticipated big game survey methods/effort levels to ensure adequate 

detection likelihoods. Also, define the anticipated size and arrangement of survey areas relative to the selected ROW within which areas will be determined as occupied or vacant 

Big appvac
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100466 IDAHO 

DEPARTMENT OF FISH AND GAME (cont.) 

App C-3, Section 5.0, Pg.13-15 -- Big Game - Construction is proposed to commence during big game protection periods in areas where none are present as determined after two consecutive weeks of surveys. Specify if weekly surveys will continue 

during a big game protection period after two consecutive weeks of big game absence and construction commences. Also, specify how PGC measures will be applied if big game animals return during a protection period even though construction might have commenced 

ApidechaPOact

 App C-3, Section 5.0, Pg.13-21 -- General- Each of the PGC, PMC, PRC, PAC, and PPC measure categories are structured 

very similarly which often results in redundant text. We suggest systematically structured tables to explicitly present species

specific aspects of the measures (e.g., (1) survey buffer distances, (2) cutoff dates for big game seasonal periods, (3) raptor

nesting seasons, (4) dates for surveys during "appropriate seasonal timeframes," and (5) nest protection buffer distances) would clarify the information while simultaneously providing an opportunity to streamline text 

Apidechathelan

 AppC-3, Section 5.0, Pg.13 -- Big Game - Big game animals can become habituated/acclimated to levels and types of existing 

anthropogenic disturbances for which they are regularly exposed. However, big game animals are uncommonly exposed to 

transmission line construction activities (e.g., those listed in 2.1.1) and unlikely to be habituated prior to the start of construction. Explain the basis to justify surface use stipulation waivers, and the Proponent's approach to identify when animals might become habituated/acclimated to transmission line construction activities 

The thame

 App C-3, Section 4.2.2, Pg. 11 -- Stipulation Selection - It is generically stated that many seasonal restriction stipulations are 

designed to assume species presence and to "broadly bracket the period in which there could be adverse impacts." We 

disagree with this characterization of the stipulations as this implies that the restrictions are unnecessarily long. Seasonal 

restrictions were conservatively identified to protect species from disturbance during known sensitive time periods 

Apidechathelan

 App C-3, Section 4.2.2, Pg. 11 -- [blank] -- Stipulation Selection - Excluding an RMP's or MFP's species protection measures is 

appropriate if the proposed restrictions offer equal or greater protection from disturbance, not because they are "not practical 

from a project design and development perspective." Appropriate species-, temporal-, and site-specific justifications must be provided if an RMP's or MFP's protection measures or stipulations are to be excluded or modified 

ApproconThe insrepfoll

 App C-3, Section 5.0, Pg.13-20 -- General- Define "regular human activity" for the existing anthropogenic disturbances 

(including metrics such as distance) used to make animal habituation determinations for surface use stipulation waivers 

Apidechaincnon

 App C-3, Section 4.2.2, Pg. 11 -- [blank] -- Stipulation Selection - Standardization of stipulations and protection measures for 

the Project is recommended where appropriate to meet species and habitat conservation needs and requirements. Clarify if 

RMP and MFP amendments will be required for proposed surface use stipulations interpretations, modifications, exceptions, and waivers 

ApanaadeMFF o

 App C-3, Section 4.2.1, Pg. 11 -- [blank] -- Land Management Plan -It is suggested that the plant and wildlife stipulations in 

RMPs and MFPs are not requirements and open to Proponent interpretation and modification as needed for Project activities. Differentiate which stipulations affecting the Project are open to interpretation and which are definitive requiring RMP or MFPamendments 

Apanaadeand Ap

 The DEIS implies a mitigation proposal was rejected by the state wildlife agencies (p. 3.11-71) but the Department 

perspective, also reflected in the DEIS, is that there was not sufficient technical effect assessment, particularly to sage-grouse 

habitat, to uphold a credible mitigation proposal. To date, the Department has not offered a policy conclusion about a mitigation proposal for this project. The Department understands that the Habitat Equivalency Analysis (HEA) will be used to 

aid in the assessment of compensatory mitigation for sage-grouse. The HEA is a method for calculating permanent or interim loss of habitat services from project related impacts. The HEA is focused on sage-grouse habitat impacted as a result of the 

Project and proposes to offset those impacts with acquisition and/or restoration of comparable habitat. We recognize development of the HEA is ongoing, with technical review and assistance from the Department and others. Notwithstanding 

work on the HEA, we are concerned that compensatory mitigation to offset effects to other species or habitats is not proposed 

in this DEIS and reference issues related to big game and Species of Greatest Conservation Need in the following detailed 

comment spreadsheet 

The comprecom
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100466 IDAHO 

DEPARTMENT OF FISH AND GAME (cont.) 

The DEIS highlights the variable affects to wildlife species from proposed routes and alternatives, but does not make clear 

what factors will be used in the final route selection. Specifically it is unclear whether some potential impacts may be weighted 

more heavily than others in the final route selection. The Department is concerned that certain routes may have localized 

unmitigatable impacts to special status wildlife and that such impacts may not receive adequate consideration during the 

decision-making process. For example, Alternative 9E would have substantially greater effects to occupied sage-grouse 

habitat and bighorn sheep habitat than the proposed route or other Segment 9 alternatives. Effects resulting from Alternative 

9E would be difficult to adequately mitigate for due to the level of impacts, particularly when considered within the proposed 

mitigation framework. The Department requests that additional clarification be added to the discussion of route selection 

Thereqto mdciDedisothto 4

 3.11-2 and 3.11-3 -- Table 3.11-1, -- Incorrect description and characterization of Key Habitat designations in Idaho. See 

pages 3-12 and 3-13 in Conservation Plan for the Greater Sage-grouse in Idaho (Idaho Sage-grouse Advisory Committee 

2006). 

The rev

 3.11-91, para 5 -- 3.11.1.5, -- If the dispersal of female sharp-tailed grouse from leks after mating is not well known, then the 

statement "The sharp-tailed grouse broads, rears young, and winters within a short distance of the mating grounds..." cannot 

be substantiated. Further, "broods" and "rears young" are the same activities. For more information on sharp-tailed grouse movements and home range see Meints 1991, Ulliman 1995, Boisvert et al. 2005 

Tex

 3.11-2 and 3.11-3 -- Table 3.11-1, -- Incorrect citation for the Conservation Plan for the Greater Sage-grouse in Idaho. Should 

be Idaho Sage-grouse Advisory Committee (2006) 

Info

 AppC-3 -- General - The plant and wildlife conservation plan provides a basic planning framework for avoiding or minimizing 

impacts during construction. To facilitate implementation within the selected ROW route, the conservation plan (or supporting 

plans) will require more detail (e.g., preconstruction survey schedules/protocols, protection measure locations/schedules, and 

compliance monitoring/reporting procedures) and synchronization with a construction plan 

The info

 App C-3, Section 1.0, Pg.2 -- [blank] -- Introduction - The second to the last sentence in this section states that the Plan 

addresses O&M activities. Clarify if this sentence correctly applies to this plan 

Appro

 App C-3, Section 3.0, Pg.5 -- [blank] -- Table 1- Greater sage-grouse should have a regulatory status of candidate species Ap

idechaPOact

 3.10-34, -- 3.10.2.2, (WILD-10, PRC-5, and others) -- No flagging of nests should occur (see Rollinson and Brooks 2007). 

IDFG can provide information on inconspicuous techniques for marking nests upon request 

WIreq

 3.10-40 -- 3.10.2.2, Operations Habitat -- For many species, "temporary" impacts will effect more than "several generations" 

given the time required for effective restoration of certain vegetation communities 

Ch

 3.10-34 -- 3.10.2.2, WILD-10 -- The document acknowledges nesting birds are particularly sensitive to disturbance yet only 

prescribes a 30-foot pre-construction survey for nesting birds within the disturbed portion of the ROW. We are unaware of the 

source or rationale for this level of survey effort. Further, no nest avoidance distances are provided. Pre-construction survey

efforts and avoidance distances should be clearly defined and included in the FEIS 

WIreq

 3.10-21 -- 3.10.2.2, -- Edge effects discussion focuses almost entirely on forested systems. Incorporating information from 

research conducted in sagebrush landscapes is relevant to this project (see Knick and Hanser 2011, Knick and Rotenberry 

1997, Vender Haegen et al. 2000, Knick et al. 2008, Hanser and Knick 2011, and others) 

Ad

 3.10-2 And Volume 3 appendix E. -- 3.1 -- Page 3.10-2 states that mapped areas of big game winter range as defined state 

and federal agencies were used in the analysis area whereas page 3.10-25 states that spatial data on big game winter ranges have been provided by federal agencies. Figure E.10-4 Designated Big Game Winter Ranges, Idaho and Nevada appears to 

include State of Idaho data. The narrative should be corrected to accurately reflect that state data has been provided and used

in analyses 

The 

 3.10-8, para 3 -- 3.10.1.4 -- Remote Sensing - This section is unclear with regards to determinations of wildlife habitat 

"suitability" as it pertains to species distribution and habitat information provided by state wildlife agencies. Specifically, were 

any of these data amended based on the result of remote sensing? 

The 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100466 IDAHO 

DEPARTMENT OF FISH AND GAME (cont.) 

3.10-9 and 3.10-10 -- 3.10.1-4 -- We are uncertain whether the habitat fragmentation methodology used in the DEIS was the 

most appropriate given the scale of the project. Focusing solely on number and size of patches with no assessment of other 

key principles like patch quality, patch isolation (distance between patches), or edge density may underestimate the effects of

fragmentation as a result of project implementation. Further, it is unclear: 1) how the fragmentation information is incorporated 

into the impacts analysis, 2) will the information be or has it been used in project siting and 3) how this important issue will be 

addressed in a compensatory mitigation strategy for the proposed project 

An of athe areincsecpatshonor 

 3.10-15, para 5 -- 3.10.1.5 -- Check current scientific names of reptiles and amphibians. For example, Pacific treefrogs are in 

the genus Pseudacris. Several other species of amphibians have recently been reclassified including species that were 

formerly in the genus Rana (to Lithobates) 

The tree

 2-144 -- Table 2.7-1, OM-30 -- Management authorities for several sensitive species fall under state jurisdictions. Unintentional 

taking of those species during construction and/or operations and maintenance should be reported to the appropriate state agency. 

No

 2-157 -- Table 2.7-1, WILD-1 -- BLM Information Bulletin No. ID-201D-D39 Seasonal Wildlife Restrictions and Procedures for 

Processing Requests for Exceptions On Public Lands in Idaho should be identified in the DEIS as the guiding document for exemptions to seasonal wildlife restriction in Idaho 

Thi

 2-156 -- Table 2.7-1, WILD-1 -- It is unclear how WILD-1 and related proponent proposed mitigation measures for construction 

and operations and management on big game winter range (e.g., PGC-5, PGC-6, PGC-7) would relate as they appear 

mutually exclusive. The Department recommends that WILD-1 (with modifications recommended above) be used as the default for seasonal exemptions. The DEIS states that the agencies reject the proponent proposed monitoring for seasonal 

occupancy of big game winter ranges (page 3.10-26). The Department agrees that agency personnel should determine the presence or likely presence of big game in restricted areas. Also, please provide page reference for Wild-1 in general wildlife

section 

As Promawoon addreg

 2-155 -- Table 2.7-1, WILD-7 -- Markings on guy wires are designed to reduce bird strike mortality. Optimally, they should 

include non-federal lands as well as federal lands, recognizing that BLM can only direct their lands 

The gov

 2-156 -- Throughout document -- Table 2.7-1 -- Big game winter range headings include “critical” in the title. The State of Idaho 

does not recognize critical winter range, nor are we aware of any such designation by federal land management agencies. The term critical should be removed when referring to big game winter range in Idaho 

Ch

 2-155, 2-156, 2-157, 2-158, 2-161 -- Table 2.7-1, PGC-4, PGC-6, PGC-9, PGC-13, PGC-17, PGC-21, PGC-24, PGC-28, PGC31, PGC-35, PMC-4 -- Monitoring results should be provided in addition to the federal land management agencies Thi

1. 

 2-160, 2-158 -- Table 2.7-1, PRC-1, PRC-5, PRC-12, PRC-18, PRC-19 -- Monitoring results should be provided to the 

appropriate state fish and wildlife agency and the US Fish and Wildlife Service in addition to the federal land management agencies 

Thi1. 

 BLM Instruction Memorandum No. 2008-204 outlines the BLM policy for the use of offsite mitigation where "Offsite mitigation is 

supplemental to onsite mitigation and is used to enhance the BLM's ability to fulfill its mission of providing multiple uses on the 

public lands, while ensuring its resource management objectives are met". While the DEIS addresses potential impacts and 

practices to be used to avoid and minimize adverse effects, nothing is suggested to compensate for unavoidable impacts. The 

Department recommends that the BLM apply IM2008-204 policy to unavoidable impacts to fish, wildlife, and habitats resulting from the Gateway West Project 

Cuas as alwresimppurproval

 The Department is concerned that State of Idaho SGCN are not included in the assessment of impacts to special status 

species, or in proposed mitigation actions. Forest Service and BLM sensitive species overlap with some SGCN, but several are not addressed. The Department recommends that these be included in Section 3.11 Special Status Wildlife and Fish 

Species 

Thenot eacassSta

 A seasonal protection is described for designated sage-grouse winter concentration areas and correctly notes that these areas

have not been mapped or designated. The Department, in cooperation with the Idaho BLM state office, has recently completed an effort to model sage-grouse winter habitat areas. Several potential wintering concentration areas exist along some of the 

alternative routes. This data should be incorporated into the FEIS in conjunction with consideration of data from field surveys

of these areas prior to construction to determine if implementation ofTESWL-19 (page 3.11-67) is warranted. Department staff 

will work to provide this information during preparation of the Final EIS 

Thi
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100466 IDAHO 

DEPARTMENT OF FISH AND GAME (cont.) 

ES-25 – Opening statement in paragraph two should clarify the context of "...minor effects on vegetation, soils, and 

waterbodies...including specifically sagebrush-obligate species... " While this may be accurate in the context of direct effects, 

the uncertainty with respect to indirect effects suggests this statement cannot be substantiated. Text should qualify this 

uncertainty or more clearly specify the context of the “effect.” 

The 

100467 EUNICE AND GARY 

GRAALMAN

I have several concerns about the Gateway West Transmission Line Project: 1. constant exposure of people to 3,000 megawatts 2. lower property value 3. detriment to the community of Ft. Steele and the people living there 4. disturbance to wildlife 5. preservation of Fred Ft. Steele Historical Site 6. degradation of aesthetic value

No500 the lineand Sewildconpro

I do support the proposed "Red Route" as shown on Project Overview Figure A-1 Map YoI DO NOT support the 2A, 2B proposed route. Yo

Pre

100468 EUNICE AND GARY 

GRAALMAN 

I do support the proposed "Red Route" as shown on Project Overview Figure A-1 Map Yo

 I DO NOT support the 2A, 2B, proposed route. Yo I have several concerns about the Gateway West Transmission Line Project: 

1. constant exposure of people to 3,000 megawatts 2. lower property value 3. detriment to the community of Ft. Steele and the people living there 4. disturbance to wildlife 5. preservation of Fred Ft. Steele Historical Site 6. degradation of aesthetic value 

The lineand Theare 3.4addEISCh

100469 LESLIE SCHMIDT Our concerns about Gateway West Transmission line project: 

1. constant exposure of people and livestock to 3000 megawatts. 2. lower property value. 3. detriment to the community of Ft. Steele & people living there. 4. disturbance to wildlife. 5. Preservation of Ft. Steele Historical site. 6. degradation of aesthetic value

No500the lineand Sewildconpro

I support the proposed "red route" on the project overview figure A-1 map. No

sup

Do not support the 2A and 2B proposed route. Yo

100470 GEORGE 

SCHNEIDER 

The last meting I attended showed the proposed route to the south of Ft. Steele. This is good. Just one mile north or south of 

Ft. Steele is vacant land suitable for 7 power lines.

Notab

100471 GALE WARD the line should go the shortest Route passable without going through private property and especially near homes No

site matho

100472 BRET MCKENZIE To encourage the BLM, who is going to make the final decision, NOT to use the Alternate Segment 8A Route, myself and 

others have noted some facts that the powers in charge have missed or chosen to ignore. 

Yo

 Interference with the Billingsly State Park 

Interference with the newly remodeled park and boat docks above and below Lower Salmon Dam. 

The the 

 Health Impacts from EMFs, Electromagnetic Fields [google power lines/Health Issues Ple The lowering of Real Estate values due to fear of Electromagnetic fields and visual interferences Thi Possible effects on many Historical Sites such as the Oregon Trail and Toana Road which has been added to the Register of 

Historical Sites 

Eff
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100474 SALLY JONES We feel the route proposed by the power co. is the best for this area. - Route #7 Yo

sup

Alternatives 7I & 7IJ will add an additional cost in excess of 100 million dollars to the ratepayers - this is just an estimate No

sup

These alternatives (7I & 7IJ) also go through a substantial sagehen area. With the precarious position of the sagehen being 

listed on the Endangered Species list. These alternative lines appear to be a very poor choice because of the sagehen

Notab

100475 BOARD OF 

COMMISSIONERS FOR CASSIA COUNTY

As you might recall there was discussion at least at the Burley and Almo meetings regarding breaking in a northwest direction 

off from the Stateline route (7R) to avoid the USFS roadless area, avoid many leks, and yet locate the line predominately on public land. This would bring the line up through the Goose Creek valley, then around the foothills by Oakley and south of Murtaugh to the Cedar Hills site area. We are enclosing a map with some "concept" lines drawn in the general area to provide some talking points in this regard. We would request the opportunity to sit down with BLM and review this alternative and consider it to be a seriously considered alternative to others as already proposed. [**See map attached to letter #100475]

Adthe 

Though there is a great deal of disappointment in the short shrift - perhaps even ignoring - of crucial Cassia County data in compiling the DEIS, we did take a small amount of hope that such deficit in study and consideration can be mitigated in the 

review and contemplation of an alternative route, which may be palatable to more of the parties involved in the siting of this project.

Nohel

100477 RAYMA CATES Table D. 17-1, Specific Land Uses Crossed or Within 1,000 Feet of the Proposed Action and Alternatives. It is hard to read 

Table D in the printed form. The font needs to be enlarged Page 5 of 12 This table does not acknowledge the true impact of Proposed Route 5 on the homes near Pauline. These homes are built 

against a hill to the north and so their entire view is to the south where Proposed Route 5 is located. At location 24 of 

Proposed Route 5, only one residence and the Arbon Elementary School are within 1,000 feet. Thus only these two items are 

listed on page 5 of 12 at location 24 and only these two items are documented in the draft. In reality, there are many more 

houses located within about 2,000 feet of the proposed line. The view from these houses will be totally dominated by the transmission line. This is also true for the City of Rockland, the houses along the East Fork of Rock Creek and the houses 

along Cold Creek Road. This table needs to be expanded to include residences, schools, businesses, etc. further than 1,000 

feet from the transmission line. Expanding this table to one mile would give a much better analysis of the population density 

and the effect on the view out of public’s living room windows along the proposed and alternative routes. Solution: Update Table D to include residences, schools, businesses, cemeteries, etc. within one mile or more of the transmission line routes. 

The rectabharprowh

100478 TRACY COOK As far as the proposed and alternative routes we feel the route south of Salmon Falls Canyon is preferable because of the 

visual impacts of such large towers and the possible sound impacts if their location is near residences.

Yosup

 If the route were to be put on the north side of Salmon Falls (Canyon) the existing power lines a smaller tower(s) would lessen 

that impact.

Altealte

100479 MIKE HOHN [Business] is actively mining trona on leases covering Sections 1-5,7-29,33,35 36 T20N RI09W, Sections 25,35,36 T2lN RI09, 

Sections 16, 19,21,28-34 T21N R108W and Sections 5-8,18,19 T20 RI08W. The proposed location for the transmission line is through the heart of [business]'s active leases. This has the potential for significant future damage to the transmission line or to 

sterilize and prevent recovery of trona in these areas, as the result of techniques such as long-wall mining and solution mining 

that could result in subsidence.

Thiexiexicon2.4

 The draft EIS does not adequately address the rights of existing trona lease holders or the economic impacts that the 

proposed transmission line location will have on our operation

Co

 Therefore we strongly oppose putting the Gateway West transmission line in this area. Yo We propose that it be moved to the north or south of [business] trona leases to prevent loss of the trona resource or damage 

to the transmission line. There are existing power-lines that run to the north and south of the heart of [business]'s trona leases 

that are already impacted and there would be much less impact if one of these locations were used

Thiexiexicon2.4

100480 IDAHO 

DEPARTMENT OF ENVIRONMENTAL QUALITY

1. Idaho's 2010 Integrated Report has recently been approved by the Environmental Protection Agency Region 10 and can be 

found at: http://www.deq.idaho.gov/water-quality/surface-water/monitoring-assessment/integrated-report.aspx. This document is the latest compilation of information pertaining to the water quality status of all Idaho waters. It includes not only the §303(d) 

list of impaired waters (Section 5), but more broadly, the §305(b) list ofthe current condition of all state waters. Neither this 

document, nor its predecessor, the 2008 Integrated Report, are listed as references for the DEIS. The information contained in 

the report is important for the analyses conducted in the DEIS.

The Se
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100480 IDAHO 

DEPARTMENT OF ENVIRONMENTAL QUALITY (cont.)

2. The separate listing of impaired and non-listed stream crossings in Tables D.16-1 and D.16-6 and in much of the discussion 

in section 3.16 implies that a higher level of protection is required for those streams on the §303(d) list. While DEQ seeks to

improve water quality and return beneficial uses to those waters listed as impaired, DEQ policy, as stated above, also requiresthe maintenance of existing beneficial uses and prohibits the degradation of water quality. Regardless of the regulatory statusofthe waterbody (whether or not the stream is impaired), appropriate best management practices shall be implemented to 

prevent degradation ofwater quality and negative impacts to beneficial uses

BM3.1

3. DEQ feels it is imperative to include a discussion and proposal ofa post reclamation strategy to ensure long-term 

functionality and maintenance of best management practices as site disturbances are reclaimed. This strategy should include 

scheduled implementation of BMPs, ongoing surveillance and inspection routines and documented and measurable goals for site stabilization.

Nowill 

100482 PAM BRONDOS We have been in the process of planning a residence on a 40 acre parcel along the 1(W)a route, west of Glenrock on the river. 

This appears to be directly in the path of the proposed line. We strongly believe this 1W(a) route would destroy the value of 

our land and our ability to build.

Yosupconexitho

 We are opposed to 1W(a) and strongly urge the Bureau of Land Management and Rocky Mountain Power use the existing 

corridor and routes parallel to it.

Yosupconexitho

 We are opposed to 1W(a) Yo

supconexitho

100484 DOUGLAS PICKETT [page]3.2-8 -- Douglas T. Pickett -- Comment- This section makes numerous references to the City of Rocks National Reserve 

CMP 1996, etc., suggesting that portions of private property near Granite Pass may be considered for inclusion in the landmark. You have given absolutely no consideration to the fact that none of the City of Rocks National Reserve CMPs have jurisdiction over lands outside of the Reserve. Not only have you given undue consideration to the CMP, but you have blatantly ignored the fact that Cassia County has designated an energy transmission corridor over and across these private lands. These privately held lands will never be included within the regulating tentacles of the NPS or the City of Rocks. 

Requested Action - Remove reference to any current or supposed future plans by NPS to enlarge the realm of it regulatory 

influence over and across private lands. Insert language that acknowledges Cassia County's jurisdiction over its private lands

BotCity we

[page]3.2-11 -- Douglas T. Pickett -- Comment - This section would lead the reader to believe that "citizens are interested in 

implementing all three levels of preservation/management... " and also that 'restrictions that protect visual resources will be in 

place in the near future.." Both of these statements are erroneous. Citizens in the affected areas were and are overwhelming opposed to increased preservation and so called "management". You make no reference to the findings of fact that stipulated Cassia County's designation of an energy transmission corridor through this area. The county found that citizens believed alternative 7I to be the best location for a project of this magnitude in Cassia County. Your statement that "restrictions that

protect visual resources will be in place in the near future” is arbitrary and capricious. How can you purport to make such a claim? Requested Action - Remove language that indicates citizen support for increased preservation/management and insert language upholding private landowner rights and local land use authority as stipulated in Idaho State Law.

The pro

sta

[photo]C1160 -- Douglas T. Pickett -- Comment - This is a photo that is being used to indicate visual impacts to the City of 

Rocks Reserve visitor from the 7I alternative. What one really observes from this photo is that there are literally no visual 

impacts from the 7I alternative from this vantage point. The actual line is plotted on the other side of the small peaks in the

background. Any observation of the line to the east or the west would be trivial and insignificant as you have demonstrated in 

illustration 3.2-16. Requested Action - Mention that this photo is taken from outside of the Reserve Boundary and that it demonstrates that visual 

impacts from the 7I alternative will be insignificant to none.

Figma
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100484 DOUGLAS PICKETT 

(cont.)

[photo]C1105 -- Douglas T. Pickett -- Comment - his photo appears to have been taken along a gravel county road which 

dissects private land in Junction Valley. This location is not along the scenic by-way or along the road from the City of Rocks to Almo or Oakley. This road heads from the by-way south into Utah. The inclusion of this photo leads the uneducated observer to believe that there heightened visual impacts to the Reserve visitor, when in fact very few reserve visitors travel this direction. Requested Action - Remove this photo from the analysis and include only those photos and simulations that represent visual impacts from a public lands perspective.

The (Apinc

[page]3.2-16 -- Douglas T. Pickett -- Comment - This simulation is helpful in understanding the visual impacts of the power line 

against varying backgrounds. Requested Action - Why haven't you applied this same analysis to the area around Granite 

Pass, acknowledging that from a distance of over two miles and against a mountain background the visual impacts from this powerline will be insignificant?

The in Asimnothill

blank] -- Douglas T. Pickett -- Comment - I would like to make an observation from my experience at the Almo open house held last September by BLM. At that meeting I met Mr. Joe Iozzi of Tetra Tech. We discussed Cassia County's economic analysis, among other things, and I was surprised by many of his responses. It became apparent to me that neither BLM or 

Tetra Tech has anyone qualified to analyze economic impacts to agricultural production. For example, I indicated to Mr. Iozzi 

that powerlines crossing irrigated farmland will have a tremendous impact on the on-going profitability of that land. As an 

example, I indicated to him that a farmer would not be able to plant corn on ground that could not be irrigated by center pivots. 

He completely disagreed with my position and furthermore indicated to me that he had himself seen corn being irrigated by 

solid set or handlines-and that based on his observation, corn is apparently being grown on a broad-scale in this manner. I 

replied that in some instances a farmer may set up some handlines or solid-set around the edges of a center pivot, but that 

nobody would plant a field with com with the intent of irrigating it solely with handlines or solid-set. He would not accept this 

point of view. Unfortunately, what we have here is someone who thinks he has the personal knowledge and understanding of 

ag-related impacts to form his own conclusions irregardless of the data we have provided to the contrary. Requested Action - BLM cannot sufficiently analyze ag-related impacts without hiring someone with some actual economic credentials. Mr. Iozzi demonstrated to me an unwillingness to consider my position. His response was indicative of a biased or even contemptuous view of my position. I have first-hand knowledge of these production techniques and have been personally involved in irrigated com production for over 20 years. He responded to my concern simply by saying, "I just don't buy what 

you are saying."

As Coana3.1inc

100485 JASON 

WILLIAMS,DEJANET WILLIAMS

I am opposed to route "5" and route "5A". Both of these routes cut through the heart of the Deep Creek Mountain Range. First 

of all it seems hard to believe it is feasible to run a transmission line over those large, steep mountains. The mountains are 

steep and have no natural canyons or cuts through the mountains within routes 5 and 5A. Access to the lines in the winter 

would be very difficult because blowing and drifting snow and the steepness of the terrain.

Yosup

The proposed route 5 and 5A have the following negative consequences: 

- Arbon Elementary School is located in route 5 - The Arbon Church and Cemetery are located in route 5A

The 

The proposed route 5 and 5A have the following negative consequences: 

- Many people frequent the Deep Creek Mountains for recreation including citizens of nearby Pocatello

The 

The proposed route 5 and 5A have the following negative consequences: 

- The Deep Creek Mountains are important habitat to many big game animals and other wildlife

The 

he proposed route that runs through the Fort Hall Reservation "5C" has several advantages. - The route already has three transmission lines in place - The route follows terrain that is far less steep and rugged - There are only three houses close the the lines in route 5C - Disruption to wildlife and view sheds would be minimal since lines already exist 

- This route has the support of the Power County Zoning Board

Yo

100487 ALLIANCE FOR 

HISTORIC WYOMING 

did not spend enough time considering how the general public, which will generally access this document on-line, would be able to cross-reference the multiple maps included in the appendices. For instance, the viewpoint location maps included with 

the visual simulations provide no geographical information by which to pinpoint the observation point's location. Going back and forth between the visual simulations and the cultural resources maps to determine the reason for the numbering of the key 

observation points. (Example: KOP C8 is located right next to C645.) There was also a problem with one of the visual 

simulations in that the viewpoint location map identified the site as KOP C642 while the text on the same page called this C110. (Since I never found a C110, we have assumed this was KOP C642.) In the end, we never did locate C10. It is most 

unfortunate that you did not take advantage of the unique opportunities technology provides to interface documents so that the 

concerned public would have been better able to match up the information provided. 

The strueasinfoide
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100487 ALLIANCE FOR 

HISTORIC WYOMING (cont.) 

we were frustrated to only find the listing of historic trails and stage roads on the cultural resource maps. While we appreciate 

the complexity of data you were attempting to present, we feel that, in the end, you presented it in a format that would work 

much better for those few who were lucky enough to access the DEIS in hard copy and that you could and should have provided more accessible tools to the larger public who will access the information electronically. We hope that, in the future, 

you will work harder to interlink your documents so that they can be better understood and studied by the general public. 

Nonot accver

 Segment One, we were disappointed to find no visual simulations provided for any of the cultural KOPs on any of the routes. As 

simimpres1 mAp

 we are slightly more inclined to support Alternative 1W-A and 1E-B No

The dro

 Section Three gives us fewer concerns although we were somewhat disappointed to find no substantive discussion of the 

impact of this new line on Point of Rocks Stage Station. 

The appSefrom WyOvbouelig

 you chose not to provide any visual simulations from any of the numerous cultural KOPs identified around Seedskadee 

National Wildlife Refuge. The traces from the emigrant era of the treacherous crossing of the Green River in this area are quite remarkable and we regret having no visual information to inform us as to how these transmission lines will affect that 

impressive historic district. 

As 

simimpresexithe not a m

 disappointed to discover that there are no visual simulations from Alternatives 4B, 4C or 4D. 4D remains our preferred route 

through this fragile environment 

As simimprespreYo

 We do not feel as though you have thoroughly considered how these cumulative impacts to our National Historic Trails impact 

this resource. We disagree most sincerely with your "definition of cumulative impact area" for these historic trails. 

Sesomimpforeis a

 When we artificially decide that an "area of potential effect" begins and ends within the boundaries of a designated 

undertaking, we are completely disregarding the actual nature of these spectacular and unique historic properties 

The arethe the cauthawitPro

indhis
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100487 ALLIANCE FOR 

HISTORIC WYOMING (cont.) 

encourage you to undertake a more complete analysis of the cumulative impacts to the National Historic Trails of not only this 

particularly undertaking but also how the trails are being impacted by all of the industrialization of the Wyoming historic 

landscape that has occurred in this area in the last 5-10 years as well as the additional industrialization that is looming on the 

horizon. 

Sesomimpforeis a

 your socioeconomic impacts analysis is flawed in that it totally failed to consider the impacts that this project will have on those 

businesses and organizations that rely heavily on heritage tourism 

A dherdisas new 

 what will happen if an industrial horizon is all the heritage tourist sees? What if wind turbines dominate the skyline A d

herdisas new Ple

 address the need for improved in-house training for heavy equipment field operators working in proximity to the National 

Historic Trails 

Tra

 developing a comprehensive monitoring and cultural resource discovery plan for this project. A wide variety of these plans are 

in existence, some better than others. However, it is vital that a comprehensive plan be available for review by the general 

public and that it also be thoroughly vetted by those involved in the Section 106 discussions. We believe it should also be prominently attached to all future NEPA documents on this project. 

Thipro

 The Section 106 process is capable of addressing limited impacts from the project itself, i.e., necessary on-site mitigation 

within the area of potential effect. But the Section 106 process is simply inadequate to address the cumulative effects of these 

projects. With cultural resources being the only identified resource to suffer "significant adverse effects" from Gateway West 

itself, we do not believe that Section 106 will be sufficient to address the cumulative impacts anticipated by the DEIS, let alone 

the larger issues of landscape industrialization that we believe are inherent in this project. Therefore, we sincerely request that 

the BLM require additional off-site compensatory mitigation for the acknowledged adverse impacts to irreplaceable historic and 

cultural resources resulting from this undertaking. 

The Treas for 

100489 BART & SHARON 

FOWERS

We support the alternative route proposed by Frank Bachman and the Citizens Group...If we would have to remove that pivot, 

we would have to replace it with three smaller pivots resulting in “12 pivot corners”. The irrigation cost to farm corners is higher than that of non-corners.

Yo

With the proposed segment #9, the cost to remove and replace our existing pivot would be approximately $300,00.00. This would require putting in power, pipe lines, breaking the existing pivot into two smaller ones and purchasing an additional pivot 

to water the same acres.

The not 

100491 CASSIA COUNTY 

GATEWAY TASK FORCE

1. There is no mention of Cassia County Gateway Task Force or it’s submitted information from the last administrative draft 

environmental impact statement. As private land owners we held 8 recorded public meetings that Idaho Power and Tetra Tech representatives attended in the summer of 2009 and yet none of the documentation is found anywhere in the entire 3200 

pages of this EIS.

CaCoThi

Quotes a study by (HydroSolutions and Fehringer 2007) addressing the economic impact that is not comparable with the proposed tower structures of Gateway. Single pole and H-frame structures are much smaller than the four legged lattice structures for Gateway. The costs quoted are incorrect and of no use for this EIS. Also the values that Hyrodolutions and Fehringer estimates incorrectly combines non-irrigated and irrigated average cash rent to comprise an average rent price per 

acre to be $132 in Idaho. (USDA 2010b) Averaging two different categories such as irrigated and non-irrigated is not an acceptable method of evaluation or for appraisal.

AdconCoinc

Agriculture 3.18---Idaho Power reporting that it has not received any complaints regarding the impact of these existing transmission lines and structures discredits all ten subjects that are listed. The problems that were discussed would be on a 

case by case basis, most likely through negotiated terms between the landowner and proponents. That’s Not an overall plan of mitigation for this project. It’s discrimination for the individual left to mitigate for him or herself.

No

Cassia County Task Force meeting minutes submitted for BLM and Tetra Tech review for testimony for documentation where 

not included and all ten subjects in the Agriculture section originated from these meetings.

Ca

CoThi

100492 STEPHAN 

RENNELLS 

The 4f1-4f2 and 4f5 is what I prefer. Yo
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100494 DORIAN 

DUFFIN,SUSIE VADER 

We also ask that if this portion of Segment 9, south of Hammett, is pursued, no support facilities (e.g., cell towers, secondary 

power lines, SUbstations, natural gas pump stations) be allowed.

No

 If you decide to continue with Segment 9 south of Hammett, we ask that all access roads associated with the corridor be gated 

and locked to limit access to only power maintenance personnel and emergency fire responders.

Nolan

 The south corridor, specifically Segment 9, is riddled with problems. Yo

sup

 we do not feel that the current or projected power demand requires two corridors through Idaho. It makes sense to add a new 

line in the existing north corridor. However, we are not convinced that a second redundant line is needed to the south and we feel this requires more study.

No

100495 DEANNA S FOXLEY We encourage the adoption of the single solid pole-structures for the transmission line towers to the maximum extent possible 

in order to avoid supporting increases in common raven populations. Ravens are known predators of greater sage-grouse.

Noimp

 Power line structures without perch deterrents installed may also unnaturally concentrate raptors to the potential detriment of 

prey species such as: sage-grouse, pygmy rabbits, white-tailed prairie dog, ferruginous hawk, burrowing owl, sage thrasher, 

loggerhead shrike, Brewer’s sparrow, and sage sparrow.

No

 It is critical that raptor nest surveys and protection measures are adhered to during construction and operation activities to

avoid take of nests or disruption of breeding activity.

Nounl

 Regarding electrocution, we suggest that an Avian Protection Plan be developed for the transmission line in accordance with 

APLIC guidelines (http://www.aplic.org/).

Thi

 the EIS does not give adequate consideration to the raptor collision risk associated with the project proponent’s preferred route 

that transects a known raptor migration ridgeline [Commissary Ridge].

Disdat

100496 ROBERT & KELLY 

THOMAS 

this route, chosen by the BLM-Idaho Power-Rocky Mountain power, transverses privately owned ground-where in fact Owyhee 

County is nearly 80% publically owned. This astonished me, particularly when the corridors within which this transmission line 

lies, according to SEC.368 Energy Right-of-Way Corridors, should be placed on Federal grounds whenever possible.

The BLrou

BL

FE

 since the project was of a benefit to the public, the public i.e. BLM, should bear the burden where possible, of accommodating

Gateway West.

Nosite ma

 I am optimistic that the determining bodies will look at two alternate routes available, 9D & 9E No

of ARo

 The proposed route, Segment 9, is definitely the least appealing Yo

sup

100497 JERRY M 

KENNEDY,EVELYN KENNEDY 

I'm writing to express my support of proposed alternate route IE-B Yo

the list det

100498 LONNIE BARTLETT Our ranch is within Section 4 of the proposed route for the Gateway West Transmission Line Project...We have many 

concerns about this route.

Yosuptranas 

 We strongly believe that the Alternative 4A is the best route Yo

ProThe dro

 The ground the purposed route passes through is rich in historical sites and trails. There is also an Indian bison jump site 

located on the property. Many archeological artifacts have been found on the property and surrounding ground. Our family is 

concerned that increase of traffic and knowledge of these sights could cause damage to them. We as a family have worked hard to protect these sites.

No(Alttha
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100498 LONNIE BARTLETT 

(cont.) 

Our partnership is underway working with the Wyoming game and fish to create a conservation easement on our property. Our property is the third ranch on Fontenelle creek to enter into the easement process. It is very important to our family to see the 

property stay just as it is. We are working with Kerry Olson; land resource biologist, Wyoming game and fish Our current and anticipated funding partners: Farm ranch lands protection program (frpp) Wyoming landscape conservation initiative (wlci) Wyoming wildlife and natural resources trust account board Rocky mountain elk foundation Mule deer foundation We have been informed that these partners will pull out if the transmission lines come through our land. The power lines will devalue the conservation easement and endangers the land trust. If these lines follow the purposed route the Fontenelle 

ranches land values will suffer due to the visual shed.

NoThe curfrom 

 We are a small working ranch and have to remain self sustained; this proposed route would cut down the amount of hay that 

we normally grow. Hay is the staple that holds the operation together. We have installed a sprinkler pivot recently to increase

our hay production. If the purposed route goes the pivot and all the hay that it irrigates is lost. Lost hay in turn results in the 

loss of herd numbers.

Co3.1

 The Wyoming game and Fish is pursuing a conservation easement on our ranch property primarily due to it being crucial 

winter range for elk, moose, and mule deer. Per their numbers the following wildlife would be disturbed by placing the power lines on or near our property.

No(Alt

conpro

100501 JONATHAN 

TEICHERT 

follow, as closely as possible, the existing transmission corridor through the County and that this route be adopted as the 

preferred alternative 

The in tCh

 In many cases, the trail segments that are to be protected lack physical integrity, a fact that the DEIS fails to address The 

impeacImp

 Moreover, given recent litigation setting aside the Pinedale RMP due to its failure to adequately protect sage grouse habitat. 

Western Watersheds Project v. Kempthorne, 08-0516 (D. Idaho Sept. 28, 2011) (holding that the Pinedale RMP failed to 

adequately protect sage grouse habitat and was therefore unlawful). It would appear that the BLM generated alternatives for 

segment 4 are also in violation of the court’s ruling 

The 

 Lincoln County recommends that BLM select the final route in Segment 4 as Alternative 4A Thi

EIS

 The BLM Alternatives are also inconsistent with Wyoming EO 2011-5 because it would cross through the Fontenelle Core 

Area 15 miles north of the existing transmission line corridor 

Thiwe

 The trail segments for the Sublette Cutoff and Slate Creek Cutoff that might be affected by Alternatives 4 and 4A are not 

congressionally designated historic trails. They were the subject of feasibility studies but BLM never secured the required consent and cooperation from the affected landowners. The protective measures adopted in the Kemmerer RMP are based on BLM’s authority under the National Historic Preservation Act (NHPA). The DEIS incorrectly assumes that these trail segments could be listed on the National Historic Register without performing the integrity analysis required by the National Park Service 

(NPS). 

No incautlistbe 

 Lincoln County objects to the DEIS classification of the trail segments as Class 1 or 2. Virtually all of the affected trail 

segments have lost their physical integrity. The KFO RMP did not apply this level of analysis and thus the DEIS needs to 

correct the premise that NHPA can be invoked regardless of the lack of physical integrity. 

No Keare

 Lincoln County, however, questions the nonconformance decisions reflected in Alternatives 4B through 4E. ... KFO efforts to 

avoid historic trail segments are based on the incorrect assumption that National Historic Preservation Act protects trail segments that have lost their physical integrity. 

No

 b. Lincoln County Proposed Amendment for Alternative 4A: 

Manage the viewshed to preserve the existing character of the landscape within the federal sections where physical evidence 

of the trail occurs (routes and traces, grades, campsites, landmarks). 

ThiEIS
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100501 JONATHAN 

TEICHERT (cont.) 

b. Lincoln County Proposed Amendment for Alternative 4A: Designate a utility corridor one (1) mile in width, generally centered on the existing transmission line (Bridger West #2). An amendment is not required for any of the routes to be approved; however, Lincoln County recommends designating a 

corridor for future utility placement since there are two other transmission lines being proposed (TransCanada and Zephir). 

Although not currently designated as a corridor, four existing power lines parallel to each other would constitute a corridor to a 

rational thinking person. Lincoln County has repeatedly asked the Kemmerer FO to officially designate this corridor. There 

have been two previous opportunities to do so, during the Kemmerer RMP revision a year ago and during the West-Wide Energy Corridors EIS. Again we request the Kemmerer FO to recognize this as a utility corridor. 

A p

 Lincoln County Proposed Amendment for Alternative 4A: 

Reclassify the VRM Class designation to VRM Class III in the portion of the planning area north and east of U.S. Highway 30 

and west of the Hams Fork River (Tunp/Dempsey Trail Area). 

The cla

 Lincoln County Proposed Amendment for Alternative 4A: 

Preserve the viewshed within 1 mile of the sites listed below, where the... 

- Emigrant Spring/Slate Creek (87 acres) - Emigrant Spring/Dempsey (11 acres) - Johnston Scout Rock (2 acres) - Alfred Corum and Nancy Hill emigrant gravesites (1⁄2 acre) - Pine Grove Emigrant Camp (14 acres) - Rocky Gap Trail Landmark (15 acres) - Bear River Divide Trail Landmark (3 acres) - Gateway Petroglyphs (518 acres) 

The 

100502 U.S. 

ENVIRONMENTAL PROTECTION AGENCY 

demonstrating compliance with the Section 404(b)(l) Guidelines (Guidelines) (footnote 2) during the NEPA process is highly 

encouraged. 

The 

 we recommend that the FEIS include qualitative discussion(s) of the alternatives' relative impacts to project area aquatic 

resources from a functions and values perspective. 

Funto a

 we encourage the use of currently available geospatial analyses of the distribution, condition and vulnerability of aquatic 

resources in the project area; consider the recent publication, "A geospatial assessment on the distribution, condition, and 

vulnerability oj Wyoming's wetlands" Footnote 4: H.E, Copeland et al. Ecological Indicators 10 [2010] 

Info

 we recommend that the FEIS disclose where project features would impact multiple individual channels in a braided stream or 

river, or multiple individual arms of a large irregularly shaped wetland or lake. We are especially interested in instances where project impacts to single aquatic resources - including multiple individual channels in a braided stream, or multiple arms of alarge wetland or lake - are likely to be greater than 1/2 acre. Regardless of permit type, should compensatory mitigation be 

required, the Final Mitigation Rule requires that it be sufficient to replace the lost aquatic resource functions 

The of teacwill 

 wetland delineations would be necessary regardless of landownership, recommend the proponents to adopt WET-2 for the 

whole project. 

The bee

 wetland delineations to " ... prior to construction ... " may not effectively support permitting processes and could result in 

noncompliance with the Guidelines. 

WeProcon

nee

 by not following these mitigation measures on the whole project, and by not separating environmental impacts to 

landownership, the DEIS inaccurately presents impacts. ... we encourage the proponents to adopt WET-1 and TESWL-l for the whole project. 

The nonWE

 We recommend that the FEIS include additional information and analysis to account for differing environmental impacts where 

Agency Proposed Mitigation Measures are and are not adopted. Address, specifically, whether and how environmental impacts would differ per landownership if WET-l and TESWL-l were adopted only on Federal lands 

The agereqproproof t
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100502 U.S. 

ENVIRONMENTAL PROTECTION AGENCY (cont.) 

We recommend that the FEIS disclose all impaired waterbodies that could be impacted by the Project - including those which may be listed for pollutants other than sediment but that are indicators of problems with runoff, such as bacteria. 

• We recommend that the FEIS include a map of the transmission line route(s) along with all 303(d) listed or TMDL streams for all pollutants. Geospatial data for 303(d) and TMDL stream segments is readily available. 

The is tsecproopeinto freqmadatare not 

 FEIS address how project planning for the Gateway West Transmission Line has followed the steps detailed in Section 4 of 

the document, Catalog of Stormwater BMPs for Idaho Cities and Counties (footnote 9). We believe that the steps outlined in 

this document are necessary parts of adequately minimizing the risk of pollutants entering stormwater systems. Table 4.1 a - 

Selection Matrix for Construction Site BMPs, specifically, is a useful tool for increasing the likelihood that BMPs which 

appropriately account for targeted pollutants and physical constraints are incorporated into final Stormwater Pollution Prevention Plans (SWPPPs). Step 5 of Section 4 provides guidance on how to effectively use Table 4.1a. Footnote 9: 

http://www.deq.idaho.gov/media/622263-Stormwater.pdf 

Reinfo

 recommends that the FEIS include a commitment to avoiding shallow groundwater areas when siting towers to prevent 

potential contamination 

ShgroExcthe acccomhazawProTypexc

 consider incorporating a diesel retrofit EPM for the whole Project. Requiring equipment that does not have diesel particulate

filters to have filters installed, for example, can reduce particulate matter emissions up to 90% (footnote 13). For additional

strategies, grants, and publications on how to reduce diesel emissions from construction equipment and vehicles see the 

EPA's Clean Construction USA website 

The 

 We recommend that the BLM and proponents work closely with WECC to achieve environmental benefits through flexibility on 

this major siting constraint. The FElS should incorporate any possible siting refinements into FElS alternatives and disclose 

their environmental benefits, if any. • If flexibility on this constraint is not possible, we recommend that the FElS include additional information, such as the results of a reliability analysis, which more thoroughly justifies the project wide application 

of a 1,500 foot minimum separation distance between existing and proposed transmission lines. 

Ad

 While our review of the DEIS has not resulted in a specific set of alternative routes for the Project's segments which we believe 

would, in combination, be the environmentally preferable alternative, we suggest that the following design and structure variations appear to be environmentally preferable. • A smaller Right of Way (ROW) and fewer helicopter landing pads make the single doublecircuit design variation appear to be a likely component of an environmentally preferable alternative. • A smaller required operational space and decreased relative potential for direct impacts to birds make the self-supporting single-circuit steel lattice 500-kV structure appear to be a more likely component of an environmentally preferable alternative

than the guyed structure. 

Se
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100502 U.S. 

ENVIRONMENTAL PROTECTION AGENCY (cont.) 

We recommend that the agencies propose and encourage the proponents to adopt EPMs, or some other appropriate mechanism(s), that would ensure that designated tribal officials/ representatives with special expertise on relevant TCPs, 

values and treaty rights are directly engaged in the Project. We believe that such an EPM(s), or other mechanism, would be a useful addition to the FEIS' s Cultural Resource and Paleontological Monitoring and Mitigation Plan 

The for as TribparwilldevBasiteTrarepto-gto i

 We support the use of conclusions from Ethnographic Research to refine FEIS alternatives. Eth We recommend that the FElS include additional information about how the implementation and monitoring of EPMs will be 

ensured. Please identify responsible entities and scheduling issues for monitoring compliance. Examples of contractual 

agreements or a description of how the contracting strategy would ensure full implementation of all EPMs and mitigation measures associated with the ROD's selected alternative could be an effective means of disclosure. 

Ad

 We recommend that the proponents adopt WEED-4 and VEG-12 as EPMs for the whole project. 

• If WEED-4 and/or VEG-12 are not adopted by the proponents, we recommend that the FEIS be revised to more clearly 

address the impacts of no long-term, goal oriented invasive plant monitoring and treatment outside of federal lands. The FEIS should address, for example, whether and how invasive plant infestations that would result from long-term Project operations 

and maintenance activities which are not coupled with invasive plant monitoring and treatment could impact socio-economic 

resources such as private land values. 

The 

100503 GARRY MILLER The proposed GWW Project must be planned and sited so as to avoid interference with the siting, construction and operation 

of the CCSM Wind Project and transmission lines and facilities related to the development of the TWE Project, both of which 

are projects to which [business] has committed lands. The proposed GWW Project must also be planned and sited so as to 

avoid interference with [business]’s use and possession of its lands and must not impair [business]’s use of its other properties. BLM should consider these existing and future projects as well as [business]’s existing operations in its decision making process.

Notha(se

 Proposed mitigation measure LU-4 (page 3.17-74) which would require coordination with the CCSM Wind Project and the 

TransWest Express Project developers along the Segment 2 Proposed Route to ensure mutually compatible siting of 

transmission lines and wind energy facilities would address a number of the issues raised above and we encourage BLM to include this mitigation measure in its Record of Decision for the GWW Project and right-of-way grants.

No

 To prevent damages and injury to [business] and its affiliates, [business] requests that BLM maintain flexibility in the final siting 

of the GWW Project so that a mutually agreeable route can be developed in cooperation with landowners and other 

stakeholders.

No

 also concerned with the design variation for Segment 2 described in Section 2.1.2 which may allow two single-circuit 500 kV 

structures in a 350-footwide right-of-way. Such a configuration would not promote the efficient use of corridors, would result in 

larger impacts to [business]’s private lands, and present difficulties and uncertainty in future Ranch land use planning

Noconin C

 the Final Environmental Impact Statement (“FEIS”), BLM should evaluate whether allowing two single-circuit 500 kV structures 

instead of requiring a single double-circuit 500 kV structure is the highest and best use of its transmission corridors, promotes 

multiple use, and if such a configuration is compliant with the Wyoming Governor’s objectives for transmission development.

The 

 prefers Segment 2A as this route would have the least impact on present and future land uses on the Ranch, including the 

least interference with the TWE Project and the CCSM Wind Project to which [business] has committed lands.

Yo

 Segment 2 between reference points 2e.1 and 2e.3 (as shown on Figure A-3) would have the most impact on present and 

future Ranch land uses.

Yo

 In the FEIS, the BLM should consider impacts for Segments 2, 2A and 2B on the TWE Project and the CCSM Wind Project 

prior to granting a right-of-way for any of these Segments.

No

 The BLM and the Proponents should commit to working with landowners to find more effective means to limit unauthorized 

OHV use and more effective mitigation should be developed.

No
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100503 GARRY MILLER 

(cont.) 

The DEIS describes a possible plan amendment for Segment 2 in the area of the North Platte River SRMA (page F.1-10). As this area is within the checkerboard land ownership, [business] believes that any plan amendment should classify the public lands as Visual Resource Management (“VRM”) Class IV for the reason that the BLM lacks management authority over the 

private lands (owned by [business]) and has no control over actions taken by private landowners. Therefore, the BLM has no 

ability to manage for more restrictive visual resource objectives as required by VRM Classes I, II or III. Should a plan 

amendment be required in the area south of Fort Steele (Segments 2, 2A or 2B) or within any checkerboard ownership, BLM should address in the FEIS its ability to manage visual resources on federal lands where it has no control over actions on 

adjacent private surface ownership.

The Thi

 The DEIS does not appear to have considered the pending VRM Plan Amendment for a portion of the Rawlins Field Office. 

see Notice of Availability, 76 Fed. Reg. 44039, July 22, 2011. The Decision Area for the draft VRM Plan Amendment includes 

a portion of Segments 2, 2A and 2B of the GWW Project. [business] recommends that the FEIS incorporate the decision on 

the pending VRM Plan Amendment or, if no decision has been rendered by that time, at least incorporate discussion of the Preferred Alternative under the draft plan amendment

The plawill 

 recently learned of a planned CO2 pipeline proposed by DKRW that would cross the Ranch in the vicinity of the I-80 corridor 

and the GWW Project proposed and alternate routes. This pipeline is not described under Section 4.2.2.3 (cumulative effects) 

of the DEIS. BLM should confirm whether the proposed DKRW pipeline is a reasonably foreseeable future action and, if so, described the pipeline’s cumulative effects in the FEIS.

No 

100504 JON NICOLAYSEN, 

II 

I am strongly opposed to the Gateway West route 1W(a) and urge the Bureau of Land Management and Rocky Mountain Power to use the existing corridor.

Yoand 1W Alteana

 The proposed line cuts directly through our deeded land in sections 1 and 2, most of which is highly productive irrigated land. 

The high-voltage transmission line would significantly impair these ranching operations, all of which are critical to my lifework.

Notran

100505 John Lucas prefers that the GWTL be routed inside the corridor as identified in the Governor’s Executive Order 2011-5 (EO) in order to 

minimize future impact on the greater sage-grouse, especially in those non-industrial areas to the north such as the FontenelleCreek drainage. Specifically, the power lines should be routed inside the Governor’s corridor, following existing transmission lines where possible, through core sage-grouse population areas as discussed in the EO in item #16 (page 4), and as shown 

in the EO on Attachment D, Map 2. 

NoSe

 This proposed route around the Seedskadee National Wildlife Refuge is particularly concerning for us because it is located 

very close to several leks (in particular, the County Road 4 lek). [business]’s preference for the GWTL alignment in this area is 

to follow the north side of the existing 345 kV powerlines from stations (approximately) 46 to 70, and in general it appears that 

an alignment following the existing powerline would be advantageous for the same reasons even beyond station 70. It is also important to note that we are specifically indicating that the GWTL should be on the north side of the existing powerline in this general area to avoid the existing leks near the Granger Mine. Furthermore, there are few if any wildlife concerns by following

this suggested alignment even through the Seedskadee Refuge. In fact, the best alignment for the GWTL appears to be parallel to the existing powerline and just to the north of it through the Seedskadee Refuge. 

Yosupfollthe Ch

 We recommend against the south alternative route through the Seedskadee Core Sage Grouse Area shown as green in 

Figure 1 above. That route travels primarily through previously undisturbed habitat and lies alongside three leks in the 

Seedskadee Core Area. It should also be noted that this southern route could be subject to subsidence from historic and 

ongoing underground trona mining operations. 

The conin C

 The Interactive Project Map, Segment 4 identifies several active trona mines which are incorrect or incomplete as follows: The 

[business] Granger mine area is not identified as an active trona mine, the “Stauffer” Trona Mine is labeled inconsistently and

should be an “active trona mine”, and the map incorrectly indicates a trona mine south of Kemmerer which does not exist. 

Pro
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100506 Western Resource 

Advocates, Idaho Conservation League, The Wilderness Society,Audubon Wyoming, Natural Resources Defense Council, Defenders of Wildlife,Nevada Wilderness Project, Biodiversity Conservation Alliance, Rocky Mountain Wild WY, Outdoor Council, Powder River Basin Resource Council 

Disclose additional information on resources that could be impacted along the routes in a supplemental document for public 

review and comment, particularly for high-profile wildlife species such as Greater Sage-grouse and golden eagles 

Adaddrele

 Recognizing the benefits of energy-efficiency and a sustainable energy economy and the costs associated with continuing coal 

generation, create a “statement of purpose and need” for the project that prioritizes agency statutory purpose and public 

interest 

No

 Create clear criteria for the route selection process The 

(if a EIS

 Include a full range of alternatives for project development, including the potential for the joint use of corridors by other project 

sponsors; 

Noneetho

 Improve and expand opportunities for stakeholder involvement, which will be critical for minimizing impacts and building 

stakeholder confidence and support; 

The pubgro

 Include a detailed Construction, Operation and Maintenance Plan; Se

inc

 Provide comprehensive information and analysis on technologies that could be implemented to minimize impacts, such as 

burying lines; 

Bu

 Prepare a comprehensive Cumulative Impacts Analysis assessing the additional projects and ongoing activities already 

planned or reasonably foreseeable for the affected area, including but not limited to additional transmission lines, energy development, and power generation projects – as well as other activities which could impact individual species, ecosystems, 

landscapes and other resources; 

Cupro

 Consider a full range of off-site mitigation strategies to improve conditions for wildlife and habitat, in addition to avoidance and 

on-site mitigation; 

Nohas 

 Transmission planning should prioritize existing corridors, ROWs, brownfields or degraded lands, and other areas with colocating opportunities. Early review of geospatial datasets is important to predict and avoid environmental resource conflict, as 

transmission lines can contribute to loss, fragmentation, and diminished resiliency of vital habitats.

No

 The DEIS contains lists of potential mitigation measures in Chapter 2 and in Appendix C, but does not analyze anticipated 

effectiveness and does not make clear which mitigation measures are to be required.

The adefed

 We are also concerned that the “mutually agreed-to” statement may be unlawfully conceding BLM’s authority to require 

mitigation measures. Regarding rights-of-way over the public lands, as at issue here, Section 505 of FLPMA requires that BLM 

must avoid and minimize damage to fish and wildlife habitat, and that BLM retains authority to impose conditions necessary to achieve this purpose –or deny the requested right-of-way if it cannot do so consistent with Section 505 and other requirements 

of law.

Nofish 

 We are concerned with TESWL-16, which provides for requests for exceptions to the stipulations for sage-grouse and other 

species. The reference to WILD-1 for “established federal process” leads to a statement listing factors to be considered, but no 

specific guidance for granting exceptions. Exceptions to the stipulations established through the NEPA process must be 

disclosed and an opportunity for public comment provided

Thiexcpro
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100506 Multiple 

organizations, see first entry under 100506 (cont.) 

We recommend that mitigation measures be applied uniformly across the project, rather than applied within a single jurisdiction. For instance, mitigation measures TESWL-22 and -23, referenced in Table 2.7-1, should be applied project-wide rather than only in the Kemmerer Field Office

The 

 The introduction of aggressive fauna and flora invasive species are often linked to human disturbances, such as new roads 

and construction of facilities associated with the proposed transmission line. Page 3.10-43 states “The Reclamation, Revegetation, and Weed Management Plan would be in place, so noxious weed spread would be minimized and would not be 

expected to negatively impact wildlife habitat in the analysis area.” The mere existence of a plan does not minimize impacts or

create revegetated lands. The FEIS should include an aggressive weed management plan and reclamation plan, followed by 

required monitoring to determine effectiveness. The FEIS should also include an adaptive management plan to ensure that invasive species concerns or reclamation challenges are fully and promptly addressed. We strongly encourage consultation 

with other agencies having expertise in reclamation to employ the practices that have proven to have the best success in preventing quality habitat loss, having reduced impacts to existing vegetation using certain treatments where appropriate and to use the recommended seed mixtures and techniques to revegetate the area. Successes and failures should be documented and made publicly available to allow for improvements in future reclamation efforts. Additional information needs to be 

included regarding the trigger points and actions that will be taken if monitoring indicates that adaptive management is 

needed. This specificity is necessary in order for adaptive management to meet NEPA’s standards for mitigation measures that are likely to be effective and enforced. Monitoring commitments and criteria should be included for ground cover, 

community composition, and erosion. For much of the affected area of the project, BLM’s Technical Reference 1734-6, 

Interpreters of Rangeland Health, can be used to establish monitoring criteria and procedures. Qualitative and quantitative 

indicators to be used should be chosen from Table 2 of the technical reference and included in the FEIS

Mitthe con

 Three years of reclamation monitoring, particularly for long-lived and slow growing species such as sagebrush, is an 

inadequate time period for judging effectiveness of reclamation

The oveon 

 BLM should prepare a monitoring protocol that guides whether or not BLM plans to use adaptive management with specific 

resources. The FEIS should describe the resources and specific indicators that will be measured and used to determine adaptive management so that the public can provide meaningful comments on BLM’s proposed approach to adaptive management. The FEIS should include a detailed baseline inventory of resource conditions as well as specify indicators that will be used to

demonstrate the effects of reclamation efforts. A detailed monitoring plan is crucial for assessing potential impacts on resource conditions, ensuring that indicators are measured at regular and consistent intervals. Commitment of adequate resources for administration of this adaptive management process should 

be firm and sufficient to support the full implementation of adaptive management. For all indicators, the FEIS should identify the range of acceptable change from the baseline condition, using best available science, 

and specify those actions that will be taken in the event that unacceptable levels of change are identified. The adaptive management process should be managed so that the public can actively and effectively participate. The proposed corridors cross thousands of miles; citizens interested in the resources affected by the project reside across multiple states

NoAff

 Avian Protection Plans (APP) are extremely important in terms of identifying specific measures that will be used to avoid, 

minimize and mitigate impacts. These plans must be developed for the entire line, with public participation, prior to the 

authorization of this proposed project. The APP must be made available to the public and be available for comment. The DEIS 

repeatedly refers to proponent APPs on proponent websites, but this does not satisfy NEPA requirements...The APP should include the following at a minimum: adequate conductor-to-conductor and conductor-to- ground space to prevent avian 

electrocution, installation of overhead transmission structures with anti-perching devices to reduce perching by avian predators 

and prevent avian electrocution (Lammers and Collopy 2007, Slater and Smith 2010), mark lines to decrease potential for 

collisions (marker balls, clamp-on markers, etc.), use of single solid tubular pole structures to reduce perching, and relocation 

of development to less sensitive areas (foraging areas, nesting areas, flyways, etc). 

The APP should include identification of high-risk areas for collisions and the approaches for reducing collision risk, rather than 

planning for high-collision areas to be identified after construction. The APP should also be continually evaluated and refined

as monitoring data and new innovations become available, in a transparent fashion allowing public input to changes. The Eagle Conservation Plan should include a listing of risk factors, as noted in the USFWS’ Draft Golden Eagle Conservation 

Plan Guidance, and a discussion of these factors for the this project. An APP for this line should incorporate Wyoming 

Executive Order 2011-5 and Idaho’s Conservation Plan for Greater Sage- Grouse, which provide for minimizing impacts on grouse through restricting seasonal activities, including construction and maintenance.

An inc

 BLM should require that mitigation take place in the same ecoregion as the project site, to ensure the continued health of the

overall ecoregion.

Noare

 An assessment tool or evaluation strategy approved by USFWS should be used to quantify the interim and permanent impacts 

(injury) to habitats (direct, indirect and cumulative) and the ecological services provided by those habitats.

No
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100506 Multiple 

organizations, see first entry under 100506 (cont.) 

We support the proposed use of a Habitat Equivalency Analysis (HEA) as a tool for determining a portion of project impacts to 

Greater Sage-grouse.

No

The completed HEA must be presented in a Supplemental Environmental Impact Statement, with the data, methods, and 

results made available for public comments.

The suppreageenvreleOnbelnot In FBoin trevencBL

Off-site mitigation is necessary in some instances but should be used with emphasis placed on scientifically defensible habitatimprovements and strict development activity restrictions in important habitats.

The req

Monitoring for sage-grouse impacts will need to occur over more than a decade. Harju et al. (2010) detected time lags up to a decade in length in sage-grouse population responses to energy development. They did not, however, detect a cessation of responses, indicating that even after 10 years, sage-grouse populations were still reacting to these habitat changes.

The com

Candidate Conservation Agreements (CCA) and Candidate Conservation Agreements with Assurances (CCAA), whose goal should be net conservation benefit, are voluntary tools that should be considered in the FEIS as potential mitigation tools.

Noreg

we recommend that the proposed routes follow existing transmission and transportation corridors to minimize new 

disturbances to the landscape and decrease impacts associated with habitat fragmentation.

No

Where route segments run through high densities of known raptor nests and roosts, careful and conservative protective 

measures need to be implemented to the greatest extent possible. This includes, but is not limited to, the use of anti-perching

devices (at both water crossings and potential migration corridors), line markers, and single steel pole structures. Raptor nest 

surveys and protection measures (e.g., GWDEIS TESWL2 and 3.10-34, 35, and 36) must occur pre- and post-construction to (1) determine collision risk, (2) determine actual mortality, and (3) assist in determining appropriate mitigation measures to avoid take of nests or disruption of breeding activity.

Nofor 

We would like to see the Alternative (Not Studied in Detail) route, which runs along I-80 in Wyoming through Utah, analyzed 

(DEIS Figure A-1). This route follows the Westwide Energy Corridor.

The 

Pre-siting surveys of bird habitat use and migration pathways should be undertaken prior to the determination of tower 

locations and arrays. In addition, because wind farms tend to follow transmission lines, pre-siting surveys of raptor and mountain plover nesting areas should be undertaken and these areas should be avoided.

PreMeGa

We encourage the review and careful consideration of recent work published by Copeland et al. 2010. InfoSegment 1W: ...However, we are very concerned about the potential for additional renewable development within the Shirley 

Basin, a dramatic landscape which harbors some of the world’s last intact grasslands and a mix of Wyoming big sage 

communities. ...We would support this segment only if (1) the Heward substation were eliminated (the presence of this substation could potentially support proposed Dry Creek and Sand Creek wind projects (Footnote 7), which failed to be 

addressed in the DEIS and there are (2) assurances that public lands north of the checkerboard will not be available to new 

renewable energy development activities, as this important basin has already experienced considerable strain due to recent 

development pressures.

PleBaand pub

we propose a new route. This route would follow begin at Aeolus substation and could run along either the route proposed for 

Wheatland/Chugwater transmission line or the Overland Intertie

Thiconhav

Consensus Preferred Route...Segment 2 Yo

supfollin t

Consensus Preferred Route...Segment 3 Yo
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100506 Multiple 

organizations, see first entry under 100506 (cont.)

Consensus Preferred Route...Segment 4A, F Yo

The Alteis p

Segment 1E-B: Strongly opposed because it occurs in greenfield Yo

Seconpro

Segment 4 (northern-most route, “Proposed Route”): Strongly opposed because it occurs in greenfield. Yo

supAlteana

Disfavored routes...Segment 4 (southern-most route, “Feasible Alternative – “4B,C” & “4C,E”)...Segment 4 (“Feasible 

Alternative – “4B,D” & “4D,E”)...Segment 4F (“Feasible Alternative”)

Yosup

We question the need for two separate lines across much of Idaho, particularly given the use of outdated IRP projections. Updated demand projections in the FEIS may show that a single line is sufficient.

NoCh

We also recommend a closer examination of the proposed separation between transmission lines. New recognition of the 

environmental impacts of transmission line corridors should be brought to the regulating bodies’ attention to win smaller 

approved separation between lines, particularly where resource conflicts are high.

No

We recommend the proponents complete a community process such as the MSTI Review Project, currently underway and 

funded by the MSTI proponent (details and contact information included in Exhibit 6).

The alswit

Segment 9E is disfavored YoSegment 8 is problematic YoSegments 7A and 7B are not in conformance with the Malad MFP....Segments 7H, I, and J are disfavored Yo

tabMF

Segment 5B is disfavored YoInclude a map depicting all existing, designated and proposed energy transmission corridors, supplemented by a description of 

the nature of the corridor, and the date and status of designation

Figtran

The FEIS should develop a mitigation component that provides for no net loss in habitat for wildlife species. Nowe expect for BLM to scrutinize the probability that GWW will facilitate only renewable energy generation, and to explicitly 

address the possibility of facilitating new generation from coal plants.

Chwitpro

Analysis should consider the extent to which the region’s reliability goals can be achieved through other means than this 

proposed transmission project.

Thiline 

Chana

close scrutiny is needed on how impacts can be avoided and mitigated in the event multiple projects are ultimately approved and constructed. This includes analysis of: - the extent to which it may be possible for the same vertical structures to serve more than one project along all of the parallel routes or specific segments where the impacts of parallel lines would be most significant, and - in the alternative, if separate vertical structures are utilized, options for reducing the spacing between the lines for sensitive 

segments.

De

ana

To provide increased confidence that the line will principally carry renewable energy, PacifiCorp and BLM should provide 

continuous, transparent updates on potential subscribers to the line and explicit statements of generation intent for the line 

within any revisions of this EIS, IRPs, and state rate cases while acknowledging open access rules. The FEIS needs to also 

include discussion on how impacts can be avoided and mitigated in the event multiple transmission projects are ultimately approved and constructed within a given area.

AdFE

Analysis should include greater information on source of power, preferably with an emphasis on renewable energy sources The Gateway West is proposed as part of PacifiCorp’s larger Gateway Transmission Expansion program, which includes Gateway Central (already built) and Gateway South (proposed, DEIS pending). Accordingly, the DEIS needs to analyze the interrelationship between these connected actions.

The
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100506 Multiple 

organizations, see first entry under 100506 (cont.)

Greater sagegrouse are designated as a “sensitive” species by Idaho and Wyoming BLM; and as noted above, have been 

determined by the USFWS to be a “candidate” species that “warrants” listing under the Endangered Species Act. The FEIS 

must fully comply with the sensitive species policy and ensure that the project does not adversely affect sage-grouse.

Nohas 

mitigation measures should at least equal those found in USFWS “Draft Guidelines for Raptor Conservation in the Western 

United States” (Whittington and Allen 2008).

NoSe

The proposed and alternate routes travel through important raptor habitat, as supported by the BLM’s own designation of Key 

Raptor Areas (KRAs). The route near Rawlins passes through the southern end of a substantial KRA, Shamrock Hills. The 

route also passes very near four other KRA’s, which are all likely utilized by raptors. These three KRAs were among 223 identified by BLM field offices in the 1998 Raptor Research Report, because they contained unusually high raptor nesting, migration, or wintering concentrations that deserved special consideration during decision making (Olendorff et al. 1989). The 

FEIS should include discussion and management protections for possible KRAs in the remaining BLM field offices in Wyoming and Idaho. Unfortunately, these areas have not been acknowledged by the BLM in the DEIS

Key lanSnaddKR

Though inadequately addressed, the DEIS does reference Commissary Ridge as a major raptor migration route, where 

Golden Eagles were among the five most common species observed (DEIS p. 3.10-16). HawkWatch International, a respected 

research organization, has recorded an average passage of 3,665 raptors each fall and an average of 268 Golden Eagles 

(Aquila chrysaetos), 158 Bald Eagles (Haliaeetus leucocephalus), and 12 unknown eagles (Mika and Hawks 2011). This 

important North-South migration route is located along the Rocky Mountain Flyway (Hoffman et al. 2002) in southwestern 

Wyoming, just north of Kemmerer Wyoming. Between 2002 and 2009, during which conducted intensive raptor migration 

counts daily from August 27 through November 5, the annual mean over the eight years was 3,665 raptors migrating over the 

ridge (Mika and Hawks 2011). In 2010, researchers reported 5,602 migrant raptors of 17 species. Almost two-thirds of the raptors were Golden Eagles. In light of this information, it is unclear why the DEIS states that the project “would not have a 

measureable adverse effect on migratory bird populations or significant bird conservation sites” (DEIS p. 2-208.), especially as HWI has documented raptors using the entire north-south ridgeline of Commissary Ridge as a migration corridor. Furthermore, the DEIS fails to discuss raptor migration passage volume, use of the entire north-south ridgeline for migration, or collision risk associated with the proposed line crossing the ridge perpendicular to this migration pathway (DEIS 3.10-16).

Coincpat

We strongly recommend against the use of traditional lattice tower structures as these increase perching and nesting 

opportunities (Engel et al. 1992, Steenhof et al. 1993). Instead, single steel pole structures should be used to the greatest extent possible as these reduce raptor perching threats to a wide variety of BLM species of concern (pygmy rabbits, burrowing 

owl, sage-thrasher, Brewer’s sparrow, and sage-grouse). Where H-frame structures are used, we support the use of perch deterrents (DEIS TESWL-3).

No

tow

we request a commitment from all the agencies involved that all employees understand the importance of the conservation of sagegrouse and the steps we as the leaders of our respective agencies have chosen to conserve the bird and its habitat.

No

the BLM should not complete analysis or make a final decision on the Gateway West transmission ROW until interim guidelines related to the National Planning Strategy are released.

The of Ihas 

the FEIS must consider the cumulative impacts of the proposed transmission line on sage-grouse in combination with other existing and planned energy development.

The sagsee 

At a minimum, the FEIS must fully analyze the best available data on sage-grouse populations and habitats that may be 

affected – directly, indirectly, and as a result of cumulative impacts – in the context of this wealth of scientific information on 

human action impacts (such as transmission lines and towers) on sage-grouse. Sage-grouse impact analysis and mitigatio 

planning, including the Avian Protection Plan and Habitat Equivalency Analysis must be presented in a supplemental release 

of information, with the data, methods, and results made available for public comments. 

BLM must fully study the adverse impacts posed by the proposed route -- not just upon active lek areas but all current sagegrouse habitats within an 18-km distance from the proposed route (Knick and Connelly 2011). And as described in our 

mitigation section, BLM must evaluate a full range of alternatives, including routing and mitigation measures, to prevent adverse impacts to sage-grouse populations and habitat

The releFEteaEIS grodesas ran

the timing stipulations in the DEIS (March 1 to May 15) poses a serious threat to hens and young. Most hens are still sitting on nests in May 15, which is the last day of recommended protections from construction activities. In fact, peak hatch generally occurs in early June and is followed by early brood rearing, which also occurs near nesting habitat. Therefore, we strongly 

suggest that protections be extended until July 15 to be meaningful and maintain healthy future populations. The timing 

stipulation from March 1 to July 15 should apply to the entire core area in Wyoming (within 2 miles of a lek outside core area)and for those portions of transmission line that run through Key Habitat areas in Idaho

The 15 parlandisaddele
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100506 Multiple 

organizations, see first entry under 100506 (cont.)

When traversing core areas, the transmission route should follow the EO’s designated transmission corridors. Finally, the EO offers additional guidance on how to minimize impacts outside of core areas.

NoSe

the 1/4 mile NSO is well documented to be insufficient to maintain lek activity (Holloran 2005, Walker et al. 2007). Instead, the agency should avoid placing transmission lines within 5 miles of [Columbian sharp-tailed grouse] leks. Finally, because they 

are sensitive to ground clearing activities and they brood and rear young near leks, the timing stipulations in the DEIS (begins 

March 1) should be extended until July 15.

CuBLapp

The FEIS should assess and describe how the invasion of non-native plants will be 1) prevented and 2) mitigated without 

disturbance to mountain plovers and their habitats. Invasion and encroachment of non-native plants is an issue that needs to be comprehensively addressed across the project ROW.

The to ltrea3.1

In the FEIS, the proponents should change the design of the structures and include perch deterrents, not only at water 

crossings but also in areas of potential migration corridors (such as Commissary Ridge).

Norou

Since raptors are known to concentrate along ridge tops, upwind sides of slopes, and canyons to take advantage of wind currents that are favorable for hunting and traveling, as well as for migratory flights, these locations should be avoided when

siting the transmission line. In addition, known raptor nests should be avoided in consultation with USFWS and state fish and 

game agencies.

Noboteffe

We recommend that BLM fully ensures compliance with BGEPA and ensures stable or increasing Golden Eagle breeding populations – an action that has not been adequately addressed in the DEIS....Areas out 10 miles from the application area should be evaluated....the Eagle Conservation Plan should include Advanced Conservation Practices to reduce risks to 

Golden Eagles and other raptors from the project.

Se

eag

We recommend Section 7 conferencing with USFWS for all candidate plant species. No

conM)

As a general principle, however, the Conservation Groups urge BLM to prioritize protection of habitat and biological resources 

over visual impacts – subject to case-by-case balancing of the relative impacts of various alternatives.

NoOffbe 

the FEIS should carefully examine options and methods to 1) avoid [visual] impacts altogether (40 CFR 1508.20(a)), and, if 

avoidance is not possible, 2) minimize impacts to visual and aesthetic resources (40 CFR 1508.20(b)) to a degree and extent 

that meets the applicable visual resource management objective for the area.

Nocou

The DEIS fails to discuss other types of towers that could be used that may lessen visual impacts, such as tubular V-string or 

guyed V-string (where guyed structures are appropriate). The DEIS also fails to discuss a) why towers need to be the 

proposed height when shorter towers may be less visible (and whether shorter towers can be employed for any sections of the 

proposed line), and b) lengthening the span between towers to reduce the overall number of towers. Second, the FEIS should discuss options involving low glare and low visibility coatings and materials on all metal surfaces. Reflection of sunlight from 

towers and lines, particularly the hour or two following sunrise and again before sunset, can be seen for miles and often dominates the natural landscape. Therefore, the FEIS must address ways to mitigate this particular kind of significant impact. 

Third, the FEIS should carefully examine on a site-specific segment-by-segment basis options to conceal or hide transmission lines and towers through use of natural topography and terrain features while avoiding habitat fragmentation.

Apwo

continuing a comprehensive outreach program will provide the public with a clearer understanding of the route alternatives 

under consideration, and of how the project may contribute to a cleaner grid. This program should specifically address (1) how 

the proposed transmission line fits into a broader set of plans for renewable energy development and transmission in the 

West; (2) the extent to which the line will incorporate renewable energy and contribute to greener grid; and (3) the extent to which the permitting process can result in decisions that avoid development of redundant, excess or duplicative transmission infrastructure.

Noand 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100506 Multiple 

organizations, see first entry under 100506 (cont.)

The FEIS should fully analyze construction, operation and maintenance (COM) issues by addressing the following questions: If the route is shared with other transmission lines or similar infrastructure, what can be done to minimize the total width of the routes, especially in sensitive areas? What is the plan for vegetative management below and near the line? Minimizing such management is best for habitat and ecosystem values. What is the construction and maintenance plan for planned access roads to service the line? What measures can be taken to minimize and mitigate the impacts of these roads, including prevention of unauthorized use? What is the efficacy of anti-roosting devices to discourage raptor perching, and what can be done to employ the most effective technologies? How will communication systems (including mobile radio systems) and regeneration sites be sited to avoid, minimize and 

mitigate impacts? Where are ground electrode facilities planned for each terminal?

Ananafram2.7ant

Apdevsubact

The FEIS should examine the option of line burial in areas identified in existing land use plans as visually sensitive and for other especially sensitive landscapes where burial would avoid or minimize the resource impacts of overhead lines.

Lin

The FEIS should fully evaluate the potential cumulative impacts of all current, proposed and reasonably foreseeable projects 

that will impact the lands and resources traversed by the line. An initial list of other projects and activities that should be

incorporated into the analysis includes (Footnote 10): Gateway South. Gateway Central. Wind farms and other energy development activity that could produce power to be carried by other proposed projects, whether 

in Wyoming or elsewhere, including the Chokecherry & Sierra Madre, Dry Creek, and Sand Creek Wind Energy Projects 

Plans and projections for a “IPP System” substation near Delta, Utah, including any energy generation and related infrastructure associated with such a station; and an analysis of how such component might influence the line’s economics. 

Any thermal plants or other projects proposed to provide “firming” power for TransWest, Gateway West or other lines. 

The Overland Transmission Project, which would carry 3,000 megawatts of DC power an estimated 550 miles from eastern 

Wyoming to Idaho. The Zephyr, a 500KV DC line that would run from approximately Medicine Bow, Wyoming, to Las Vegas. Current transmission projects being proposed for Wyoming are enumerated and mapped at http://wyia.org/projects/. All of 

these projects are reasonable foreseeable. Sigurd to Red Butte No. 2 - 345 kV Transmission Project, which would connect the Sigurd substation, located approximately 

six miles northeast of Richfield, Utah to the Red Butte substation, southwest of Central in Washington County, Utah. 

Mona to Oquirrh Transmission Project, a 500 kV and 345 kV alternating current line from Salt Lake City to Mona, Utah. One Nevada Transmission Project/SWIP South, a 500 kV AC line from Idaho to Las Vegas. 

Southern Nevada Intertie Project, a 500 kV AC line. TransCanada Corp.'s $3 billion Chinook line, proposed to carry as much as 3,000 megawatts of mostly wind-generated electricity from new and expanding wind farms in Montana to large population centers in Arizona, California and Nevada. 

Oil and gas leasing and development activity near the proposed route – in Wyoming, Colorado and Utah. 

Uranium or other mining leasing or mines. Wind, solar, geothermal or other renewable energy projects near the line, or under consideration in connection with other 

transmission proposals. (Footnote 10: For Wyoming, plans to integrate natural gas and wind are discussed at http://wyia.org/newsworthy/wyomingreleases-study-of-acollector- system-and-integration-of-wind-and-natural-gas-phase-2-study/ ) 

Several of the proposed transmission projects are depicted in Exhibit 23, a summary of Proposed Intermountain Transmission Projects compiled by Rocky Mountain Power. For the projects and activities listed above, the FEIS should prepare comparative projected GHG emissions, and compile a 

table showing the potential GHG impacts of each project and the total across all projects. Such analysis should focus on 1) 

GHG emissions from generation sources; and 2) the emissions associated with the length and efficiency of the line. Given the importance of reducing the threats from climate change, this analysis is an important component of the FEIS. Based on this comparison and other information, the FEIS should discuss the redundancy perceived by most of the environmental 

community for some of these projects as well as which ones are most likely to satisfy economic, environmental or socioeconomic expectations. Alternatively, BLM could perform this analysis independently and incorporate make the results 

available for public review in the FEIS. For all the above projects and activities, the FEIS should analyze potential impacts and timing to provide a full picture of potential cumulative impacts. The comprehensive cumulative impacts analysis will contribute to informed decision-making as required by NEPA, and help inform appropriate mitigation measures, opportunity costs and larger picture decisions about the 

level of development that can be sustained by the environment and local communities.

The witeffe
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100506 Multiple 

organizations, see first entry under 100506 (cont.)

In accordance with Secretarial Order 3310, BLM IM 2011-154, and new BLM Manuals 6301, 6302, and 6303, the project should avoid adversely impacting wilderness resources. Project analysis should highlight the important socioeconomic values 

of managing these lands for their wilderness characteristics.

No rouwildhav

The FEIS must provide a comprehensive socioeconomic and cost-benefits analysis....The FEIS should evaluate non-market 

values provided by wildlands, undeveloped landscapes, and other natural values and ecosystem functions. The total economic 

value approach should be incorporated.

The ananonNosocsug

proterm

Significant GIS data is being gathered as part of the EIS process for Gateway West. Public access to this data is needed to assist the public in understanding, analyzing and making substantive comments on the proposed project.

Nolaw

Executive Order 2011-5 (replacing Order 2010-4)...identified a two-mile wide transmission line corridor in south central and 

southwestern Wyoming, through Core Population Areas, in an effort to reduce impacts to Core Population Areas and other 

natural resources. The State stressed that new transmission lines sited outside this corridor within Core Population Areas should not be constructed unless it can be demonstrated by the state agency that the activity will not cause declines in Greater 

Sage-Grouse populations. Exhibit 1 at 3-4. The DEIS states “The Project would contribute to the permanent loss of suitable 

sage-grouse habitat and possible disturbances to birds.” and “The cumulative effects of the Gateway West Project on the 

greater sage-grouse when taken together with past, present, and reasonably foreseeable future projects would be substantial."

NoSeThe 

A similar 5-mile buffer around active sage-grouse leks should be employed by BLM here, because of the impacts that newlyconstructed transmission towers and power lines may have upon sage-grouse populations and habitats. Cu

BLapp

Make all GIS spatial data developed as part of the EIS process available for public download on the BLM project website; All 

locava

The purpose and need section in the FEIS must prioritize the agency’s statutory mission and public interest. The The Purpose and Need statement in the DEIS is also problematic because it is based on the 2009 IRPs. Both proponents have newer IRPs reflecting the decreased need for Gateway West, as originally configured

The 

Section 1.3.3.1 of the “Proponents Purpose and Need” statement references DOE’s National Electric Transmission 

Congestion Study. In Wilderness Society v. U.S. Department of Energy, the U.S. Court of Appeals for the Ninth Circuit found 

that the DOE’s congestion study was so flawed as to be illegal and in violation of the intent of the Energy Policy Act of 2005 

(EPAct). The court held that DOE failed to consult with the affected States in undertaking the Congestion Study as required by 

§ 824p(a)(1) of EPAct. As discussed in the decision, the failure to consult caused the study to fail to consider important issues, 

such as the definitions of “congestion” and “constraint,” the need to accommodate state laws and policies such as renewable energy standards, identifying areas subject to congestion and constraint, and the need to conduct an analysis of 

environmental consequences. As a result, BLM should not take the findings of the DOE’s Congestion Study into account when 

determining where transmission is needed. Rather, the agency should be considering other factors that affect the need for new 

transmission (such as renewable energy standards, efficiency and demand management initiatives, and environmental impacts). The question of whether demand-side measures and additional local generation could avert the need for large transmission projects is still open for analysis.

Se

The BLM’s Purpose and Need must reflect the June, 2011 report titled "A Policy Framework for the 21st Century Grid: 

Enabling Our Secure Energy Future."

The 

Conservation easements are one tool for identifying specific development restraints on sensitive wildlife habitats. However, onthe-ground surveys consistent with guidelines provided by the USFWS or state wildlife agencies will be required before ROWs 

are finalized and construction begins.

No

Make all underlying information, reports and studies referenced in the DEIS available for viewing and download on the BLM project website.

Theava
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100506 Multiple 

organizations, see first entry under 100506 (cont.)

In closing, we welcome the opportunity to meet with the Rapid Response Team as well as BLM state offices to share our 

expertise in transmission planning, wildlife habitat protection and restoration, and land management planning. Improving 

transmission infrastructure provides a unique opportunity to be forward-thinking in our approach, by selection of greener technologies and siting to preserve priceless landscapes and iconic wildlife species. However, we are sensitive to the reality 

that this proposed transmission line presents unique challenges, and thus we are all available should there be any questions or need for additional information. We recently learned of the BLM’s intention to hold stakeholder siting resolution meetings and are very interested in being involved with these. Thank you for your consideration of our comments

No

100507 KENDELL FARMS, 

HYMARK FARMS 

the siting of the Transmission Line as it connects to Borah in segment 5. We strongly support the County's preferred route. Yo

 We express our opposition to the alternative route labeled 5D and the river crossing at 5h. Yo100508 BOYD ANDERSON I favor the southern most proposed route. Birds of Prey Coalition is against that route, but there are 10 birds of prey to 1 bird of 

prey where I live on the Segment 8 alternative. The birds come to the farm ground to eat where there is food for them.

Yosup

100509 WALTER SAVAGE I am opposed to the "Northern Route" because I enjoy hunting on Commissary Ridge and fishing in Fontanelle Creek. I could 

no longer do either of these if the northern route is chosen. Also the northern route is important elk winter range, Commissary

Ridge is important Lynx habitat, and last but not least is the Raptor migration corridor along Commissary Ridge. I have seen flocks of over 100 Sage Grouse in the Fontanelle Gap area. Do not destroy a pristine area to save an already destroyed area (Hwy 30) Fossil Butte and the already ruined Oregon trail viewshed. Thank you.

Yosup

100510 SALLY A (ILLEGIBLE),

SCOTT B (ILLEGIBLE), A

(ILLEGIBLE) (ILLEGIBLE),B (ILLEGIBLE), B(ILLEGIBLE), KIMBERLY

CAIN, DAVID DIEDE,

JANICE DIEDE, S

(ILLEGIBLE), E

(ILLEGIBLE), M D

GRIFFITTS, KEITH

WAYNE GRIFFITTS,LARRY L HERON,JOANNE HERON,

JOANNE HOWE, SCOTT

L HOWE, GERALD LJENKINS, PATTY

JENKINS, BRADLEY A

JONES, MELANIEJONES, KAREN K LEWIS‐

WORL, (ILLEGIBLE)

PLUMMER, SHELLEY

PLUMMER, MELANIESERRES, HEATH SERRES,

JOHNA STRADER,

RANDY STRADER,DOROTHY VELASQUEZ,

VERNON VELASQUEZ,

MICHELLE WICKISTON,

SCOTT WICKISTON, D

WYANT

We, the undersigned would like to express our deep concern and opposition to the proposed alternate site for the Gateway Transmission Line. This location is in very close proximity to many parcels of property that are currently inhabited by residents/ 

property owners, some of which who have been there for 30 years or more, or in several cases property that has been 

purchased for the express purpose of building homes on. The construction of this massive line would immediately impact the quality of life for these persons. In addition to impacting the view, the devaluation of our properties would be significant not to mention the possibility of 

potential health hazards. In the case of the properties that were purchased for the purpose of building on, the line would be so 

adjacent to these properties as to make them basically worthless. We therefore humbly request that you use a route that won't 

so greatly impact the lives of persons living in the immediate area For the purpose of clarification, the specific portion of the route that we object to is the segment which runs between Glenrock 

and Rolling Hills and is labeled 1 Wa

Norema d

For the purpose of clarification, the specific portion of the route that we object to is the segment which runs between Glenrock 

and Rolling Hills and is labeled 1 Wa

Yo

100511 GUERAN HANSEN I don't like the transmission lines that are projected to go through the middle of Glenrock (between the interstate and S. 

Glenrock).

Seexithe Ch
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100512 ROB BONER Development of transmission lines are much needed for Wyoming and the country. That said, the burden should not fall on the 

shoulders of landowners. Companies should compensate landowners at current market rates for easements. These rates currently include an indexed, or adjusted, annual payment of some type. In Converse County, Wyoming, the current rate is $5/rod annually for a 30' easement. This is in addition to initial damage payments. Boner Bros. has specific concerns regarding

micro-siting and ensuring that a valuable gravel resource is protected along the IE route. This is a development that could, and 

should, be done in a manner to address all parties' concerns. If done properly, the project should allow electrical customers to access low cost resources, while protecting landowners' rights and property value.

Noiss

100513 CITY OF RAWLINS Municipal Service needs – The City is concerned about being able to respond to service demand increases from an increased 

transient workforce population coming to our community before revenues begin to be generated by the project to offset costs. 

We are also concerned with challenges created by a possible growth environment involving potential multiple project impacts 

and the associated decline following the construction phase(s). We are particularly concerned about being able to staff serviceneeds during a boom cycle coming off of our recent revenue decline and employment reductions. 

ThiInd

 [Original Comment Letter contains a table of other development projects in Carbon County; see original letter for table] Tha

fors

 City of Rawlins Fire Response Area (Resulting from the joint agreement of City of Rawlins and Carbon County on 5/11/2010 – 

updated 11-15-10) The following is our understanding of the response area discussed by the County Fire Marshal France, 

County Commissioner Weickum, Mayor Klouda, Chief Hannum, Police Chief Mike Reed and City Manager Golnar at our 

meeting of 5/11/2010 and subsequent discussions with the County Fire Chief. I have made the following changes We will respond to all property within the Rawlins City limits and: :anything on 287 North to and including the landfill road and landfill. :the house sitting in the middle of the field by the Rec Center, off of 287(the Seldomridge home), as well as the houses west of 3rd Street and the barn around Scarlet Drive). : the new elementary school and the Baptist Church. :Norm Harvey Airport – is a dual response area – both departments will be notified. : anything on I-80 between MM 211 and 215 including exit/on ramps. :TA truck stop and the Wyoming State Prison but nothing else south of the Interstate. : Dr Couch's office, the Methodist Church, and the Super 8 Motel : Rich Wilson's house between Spruce St and the Interstate, and Jim Piche's residence in the canyon : the industrial area and to the Rochelle Ranch Golf Course. : city property including but not limited to the City outdoor shooting ranges, the water treatment plant, the sewer plant and the 

140 acres of city property north east of the City limits by the Painted Hills Water Tank. 

Wewillnotrespondto: :anythingwestofDr.Couchesoffice :anythingwestofthe287–landfillroadintersectionorbeyondthelandfillroad 

:TheDowlin’sRanch,MillerEstateCompany,andDonHansenpropertyeastofInvernessstreet. 

No
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100513 CITY OF RAWLINS 

(cont.) 

a boom cycle coming off of our recent revenue decline and employment reductions. Legal Services, Felonies, Jail Services, 

Code Enforcement - Based on past experience during boom times, we have seen an increased demand on the need for law enforcement, judicial, jail services, code enforcement, recreation services and human service organizations, before significant

tax revenues are realized locally. Dan Massey the City of Rawlins, City Attorney reports that: “During the boom years of 2006, 

2007 and 2008 the City of Rawlins hosted transient workers from three pipe lines and a rebuild at the Sinclair refinery. The transient workers had the following effect on 

crime and code enforcement for the City of Rawlins: o City Prosecutions: In 2006, 2007 and 2008 the City was prosecuting on average 147 DWUIs and 1039 non-traffic violations (battery, assault, property damage, disturbing the peace etc.). After all of the transient workers left we went back to 

prosecuting an average of 72 DWUIs and 476 non-traffic violation in 2010. 

o Jail Expense: Jail expense (the fee that Carbon County charges the City of Rawlins for incarcerating individuals under 

violation of City of Rawlins Ordinance) went from over $110,000.00 in 2006 and 2007 back down to $48,000.00 in 2010. 

o Code Enforcement: The City also had a huge increase in code violations (Building, Nuisance, Zoning and Safety) during that period. Workers were renting and living in uninhabitable houses or were turning homes into boarding houses. There was not such a drastic change from the boom years to 2010 when it came to permanent construction. Building Permits averaged 625 a 

year during the boom and the city issued 531 permits in 2010. o Nuisance Abatement: A citation is only issued after several attempts have been made to get the property owner to comply. During the boom years an average of 30 citations were issued. Six people were issued nuisance citations in 2010. o Rawlins City Felonies: Violent felony and Drugs that our City Police arrested that went through District Court went from an average of 1325 prosecutions during the boom years down to 834 in 2010. Obviously there was a significant impact on the Municipal Court, the Police Department, code enforcement, nuisance 

abatement and the City Attorney’s office with problem issues doubling during the boom.” 

Se

 o Emergency Services – What is the plan for emergency service response from multiple jurisdictions within the project area? An  o Law Enforcement 

 E911 Service for project area covered by Rawlins 911- Dispatch.  Coordination on Transportation Mitigation Issues – The Rawlins Police Department needs to be involved in coordination of transportation plans in and around Rawlins. 

SeMashobe aut

 o Fire and Emergency Medical Services 

 Calls for response will increase with a large population of temporary workers living in or near Rawlins.  The Rawlins Fire Department has also begun first responder service where they run parallel with the Memorial Hospital of Carbon County’s Ambulance Service since the last boom in the years 2006, 2007 and 2008. An increase in the transient Gateway West Transmission Line workforce as predicted will result in 

increased demand for Fire services.  A City of Rawlins Fire Response Area near the City limits is defined by mutual agreement between the City Rawlins and Carbon County. (Attached is a copy of the description of the “City of Rawlins and map of the response area – Rawlins 

Attachment #2.) 

Inc
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100513 CITY OF RAWLINS 

(cont.) 

o Finance/IT Services –o Taxes & Expenditures–o Funding Gap - The City of Rawlins will experience lags in revenue receipts 

during the initial construction year and would be required to provide services to accommodate Gateway West traffic and 

workforce before we receive substantial revenues from the project. That fact, combined with recent cutbacks in some staffing 

could result in deterioration of service levels. The City of Rawlins reduced full-time general fund positions by 19.65 FTE from

the original FY2009-10 Budget through mid year 2010 -11-- from 114.65 FTE to 95.00 FTE. (see attached chart summarizing “City of Rawlins General Fund Position Reduction Status (1/25/2011 update - Rawlins Attachment #3) Excerpts from our 2010-11 budget message narrative read as follows:“With our sales and use taxes declining at a rate of 36% to 37% approximately by year-end we are now recommending a 41% decline in our FY 2010-2011 budget from what we received in FY 2008-2009 

as the CREG January 2010 anticipates continued decline for FY 2010-2011. We are recommending that all material & services budgets for all departments within the General Fund and Recreation Fund be no more than what was actually expensed in FY 2008-2009. This is a reduction of approximately $604,342 from the FY 2009-2010 original budget as stated above. Our goal to reduce our dependency on the County 1.0% option over three year fiscal year to a 66.7%/33/3% split of 

capital to operating expenses has been placed on hold so we can carry as many employees as possible to provide the 

services now being provided with a minimal level of funds available to capital expenses. The number in dollars we have in the original FY 2009-2010 budget for “Capital Expenses” was $4,122,422 for the combined General and Recreation Funds. 

Ourbudgeted revenue resources for this amount above were $1,785,595 from the County Optional 1.0% Sales Tax, $863,562 from the State of Wyoming Supplemental Direct Distribution, and $1,473,265 from prior year revenues currently held in 

ourbeginning fund balance. The new FY 2010-2011 “Capital Expense Budget” will not exceed $1,159,661 in total and it will come from the County 1.0% option at only 25% ($531,488) and the State of Wyoming Supplemental Direct Distribution of $628,173.The FY 2009-2010 adopted General Fund Reserve (often called the rainy day reserve) was at 25% or $2,646,918 

for FY 2009-2010. We did have additional reserves of approximately $728,000 which when combined with the 25% reserveabove combined to approximately $3.3 million. With the losses we are taking in FY 2009-2010 in our primary revenue 

accounts some of this reserve is being used to cover recurring operating expenses. We have requested operating assistance in theamount of $250,000 from the Carbon County School District #1 Recreation District and will not know the response until 

June 2010. Also with an unknown Census count which determines the majority of our State of Wyoming tax distributions we haverecommended in the FY 2010-2011 budget to hold onto as many employees as possible until this count is confirmed. To 

this end goal our recommendation is to use the estimated $2.9 General Fund accessible reserve fund balance as follows: $500,501 to operating expenses, $133,893 to the City’s self insurance fund leaving the City with a reserve fund balance for both the General and Recreation Fund of 24.8% or $2,294,719. We propose to monitor our budget performance and report and recommend needed adjustments quarterly throughout FY2010-11. Please remember the County Option Sales Tax is 

voted upon every four (4) years for approval by the general public so we will be at a greater potential of significantly reducing 

services, projects and employees if voted out here in 2010.” o FY2011-12 budget was proposed at $100,000 less than 2010-

11 because of a continued decline in sales and use tax revenues. The City of Rawlins’ total sales and use tax receipts for first 

quarter of FY2011-12 are down $25,000 from our estimate in the first quarter of FY 2011-12.o We are operating very leanly at 

present.o Assistance in monitoring and covering the front-end costs of growth related pressures is desired by the City of 

Rawlins. Hopefully this can be discussed with the Project Proponents as this project progresses.o 5 Year Financial Plan - The 

City of Rawlins will prepare a 5 Year Financial Plan anticipating various revenue levels, service levels and capital 

expenditures. [the comment then provides a table of "General Fund Operating Revenues"; see original comment] 

Inc
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100513 CITY OF RAWLINS 

(cont.) 

Recreation Services–o Please note that in addition to Rochelle Ranch Golf Course and numerous municipal parks throughout the City, the City of Rawlins also operates a Recreation Center (with 3 indoor gyms, an indoor track, 3 racquetball courts, a weight room, aerobic equipment, spinning bicycles, and an indoor shooting range), an outdoor shooting range and a host of 

recreational programs, green spaces, trails and athletic fields.o Recreation provides a healthy alternative for off time hours.o 

Recreational Facilities: Rawlins Recreation Services Director Chris Waller states that: “The wear and tear on recreational facilities that temporary workers cause is significant. We estimate that during that last boom period, our recreational facilities 

saw approximately a 33% increased usage due to temporary workers from 2006 to 2008 with some causing extreme over 

usage in areas such as weight room and cardio areas as well as others.”o Recreation facility hours have been limited particularly during the summer months (May 1st through September 30th) closing early with limited hours on weekends. Hours in the summer are 5:30am to 8pm M-TH and on Friday 5:30am to 7pm. On weekends, Saturday hours are 7am to 3pm and Sunday is closed.o The possibility of extending hours that the Recreation Center is open to accommodate workers in their off 

time would be a positive quality of life initiative.o If the Proponents encourage their employees to use the Rawlins Family 

Recreation Center or facilities, which increases demand on the facilities and capacity we would encourage that the BLM 

require the Proponents to coordinate with the City of Rawlins to mitigate the impacts of workforce use of these facilities.o For example, Cover Increased Operating Hours - If increased hours at therecreation facilities are required to accommodate 

Gateway Westworkers recreational schedules, then an arrangement withProponents should be made to offset the costs of staffing andmaintaining the facilities for the additional hours, at least until tax revenues from the project are substantial enough to cover such costs. Mitigate Wear and Tear on Recreational Facilities - The wearand tear on recreational facilities that temporary workers cause is significant. We estimate that during that last boom period, our recreational facilities saw 

approximately a 33% increased usage due to temporary workers with some causing extreme over usage in areas such as 

weight room and cardio areas as well as others. Air Conditioning of Recreation Center - Given the fact that thework force 

population is anticipated to be present in Rawlins during the warmer spring, summer and fall months, we suggest that Proponents could help in funding or advancing funds to achieve air conditioning of the Rawlins Family Recreation Center to 

make it more accessible and enjoyable in the summer months, during which construction will take place and your workers will 

be present for up to four years. This would make the facility more accessible and usable in the summer months and leave a 

long term benefit to the community. Recreation Center Expansion – This would be extremelybeneficial for project temporary workers and would contribute long term to the community. 

Co

 Public Works Issues – 

o Water  Water Supply – Where do the Proponents propose to acquire their water for project construction uses? How much water is 

proposed to be needed?  Water Quality - We are concerned about plans and any adverse affects to water quality relating to the Gateway West project plans near the North Plate River intake, in the Sage Creek Basin, or our Nugget Well field which are the City of Rawlins’ key sources of municipal water. 

Infosup

 The affect of additional discharge to the Rawlins Wastewater 

Treatment Facilities will need to be evaluated. o The City is currently classified as a Major Discharger under its current permit No. WY0020427. To date however its 

requirements for WHOLE EFFLUENT TOXICITY TEXTING (ACUTE) has been limited. With just minor increase in sewage volumes the City’s requirements for ACUTE and CHRONIC Wet Testing must be anticipated to increase with undetermined cost associated therewith. o There is always the potential for needing to upgrade the City’s sewage treatment to include tertiary treatment. Should the increase in population trigger such to occur provisions for these new developments 

Se

 At present there is no Master Plan for Sewers for the City. System needs assessments conducted in 2007 indicated portions of 

the local sewers reaching or exceeding their anticipated service life. Rehabilitation and replacement on parts of the City’s 

sewer system have been ongoing since the 2007 needs assessments were conducted. It is time now to re-evaluate the sewer 

rehabilitation and replacements as most of the projects identified in the 2007 Needs Assessments are being completed. As new housing or temporary housing increases service demands on the City’s ageing sewer systems the need for additional 

rehabilitation and or replacement will need to be assessed and addressed. The expansion of development into the extraterritorial periphery to the City creates needs for trunk main sewers that have not been provided hereto date. Areas to the 

South and West of the City need to be Master planned for how such areas can and will need to be sewered. 

No
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100513 CITY OF RAWLINS 

(cont.) 

o Solid Waste ManagementThe City in February of 2011 ended the disposal of its Municipal Solid Waste (MSW) at the 

Rawlins Landfill entering into agreement with the City of Casper for transferring its MSW the Casper Regional Landfill. 

Increased waste handling as well as potential need for expansion of the Rawlins transfer facilities and waste hauling to Casper

will increase costs. The bailer for the City’s transfer station is now estimated at more than 20 years old and is in need for major 

overhaul or replacement any increase in waste handling will need to be considered. The Rawlins landfill is currently restricted

to accept only Construction and Demolition Wastes to the year 2016 when permit extension will be reconsidered. The need for 

cover material to continue the current landfill usage is an ongoing concern for the landfill operation. 

No

 Streets - New Streets and Roadways that would connect to the City that may someday have the potential for City Annexation 

should be built to City Standard to allow acceptance by the City into the City Street System without having to be upgraded to City Standard. They should contain all standard improvements as far as paving thickness, curbs, gutters, sidewalks, street 

lighting, traffic striping, signing and signalization. 

The juriRacon

 City Transportation – The City of Rawlins is currently preparing an RFP for a transportation element of the City’s Master Plan. 

To be identified in it will be traffic counts and street designations for arterial and collector utilization. The affect of temporary 

and long term housing on the traffic circulation through and within the City needs to be projected as part of the Environmental

review. It is anticipated that new signalization for entry into commercial businesses may need to be considered as well as 

increased traffic routing to and from schools within the City. 

A tis pimpin aTrawitimpthe 

 o Rawlins Master Plan Updated - The City of Rawlins is in the process of requesting proposals for updating our master plan. 

This process will help the community and developers to envision ad implement future residential, commercial, industrial and 

economic development. A Rawlins Economic Development Master Plan Element is also being developed as a separate 

element of the Master Plan and is discussed below. 

No

 o Extraterritorial Utility and Infrastructure Expansion Plan – In 

response to the Goal of the Carbon County Comprehensive Land Use Plan (2010) to: “Locate new residential developments 

and commercial sites in close proximity to municipalities and developed areas”, the Rawlins City Council changed its policy on extension of water and sewer outside of City limits to not allow such extensions outside of City limits, unless they are in 

conformance with an adopted utility and infrastructure expansion plan. The reason for adopting this policy was to ensure planned and organized development of water, sewer, storm drainage, streets and right of ways along with annexation 

consideration for developing properties on the periphery of the City. ( See City of Rawlins Extraterritorial Utility and 

Infrastructure Extension Policy – Rawlins Ordinance No. 11-2010 Amending Section 13.04.170 (November 16, 2010) and Rawlins Resolution No. 10B-2010 Authorizing Development of An Extraterritorial Utility and Infrastructure Expansion Plan 

(October 19, 2010) – Rawlins Attachment #4) 

No

 Economic Development – We would like to work with the Gateway West Project to diversify our economy by increasing 

industrial, commercial and retail services in our community. We seek to reduce sales tax leakage through enhanced local 

economic activity, sustainability, community retail amenities, and attractiveness to those who work here and their families. 

This can best be achieved by the location of long term jobs in our community which pay a living wage with benefits. The City of

Rawlins has prepared and will be advertising in October 2011 a request for proposals for consulting assistance to perform an economic development plan as an element of our Master 

Plan Update. This will help to drive development of the master plan to accommodate new areas for residential, retail, 

commercial, business park and industrial development. 

The pro

 We are concerned about what impact the Gateway West project will have on tourism in Carbon County and Rawlins as a 

result of project construction and operations. 

A dThe and The Se
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100513 CITY OF RAWLINS 

(cont.) 

o Housing – We don’t want to encourage over building for a temporary construction workforce, but we would like to emphasize 

our interest in encouraging infill development that is of quality construction, accessible to amenities of the community and connected to the community. We see an opportunity with the housing of some of your temporary workers that facilities could be turned into other uses when the Gateway West Transmission project is done, or used by other employees of organizations 

and companies that expect to need housing for their employees. (Including The Wyoming State Penitentiary, Sinclair Oil Refinery, City of Rawlins, Carbon County, School District #1, BLM and the list of Current and Planned Projects and employers 

identified in Rawlins Attachment #1.) o The City would be interested in working with the Gateway West Proponents and BLM to coordinate solutions to temporary and permanent workforce housing challenges. o New or temporary house located adjacent to or in close proximity to the City where City Services and or Utilities may be needed should be considered for annexation to the City, or at minimum be built to City Standard so annexation may be 

considered in the future. o Streets and Utility Construction should also be built to City Standards so that they can be accepted by the City for future 

annexation. Connecting to said facilities should require the consideration for annexation before such is allowed. 

o Building Setback should also be consistent with City Standard to allow annexation without having to consider variance before acceptance. 

The lan

 o Housing Mitigation Measures Recommended by BLM - The City has reviewed and agrees to participate in helping to achieve 

the following Mitigation proposals suggested by BLM in Section 3.4.3 of the Draft EIS for the implementation of the Gateway 

West Transmission Project which includes: “Construction activities, depending on alternatives chosen, could extend approximately 1,100 miles across three states and multiple counties, and some of the areas crossed have limited housing 

resources. Housing shortages could occur in some locations if the Project coincides in time and space with other construction or development projects that involve large transient workforces. This type of scenario could result in fewer housing resources 

being available than is normally the case. The Proponents should address these types of potential housing shortages prior to 

construction by updating the housing analysis to reflect current conditions at the time of construction, including EPCspecific 

housing demands by community and housing type, the available supply of housing units, and projected demand from other 

sources, based on average demand patterns and demand from other large permitted and scheduled projects. In addition, the Proponents should prepare and submit a Housing Plan for review and approval. The Housing Plan must address those areas 

in Wyoming and Idaho where potential housing shortage concerns are identified and must demonstrate mitigation of any 

projected housing shortage during construction. The Agencies recommend that the Proponents incorporate the following 

measure into their EPMs and apply it Project-wide. SOC-1 Housing Plan with local motels and hotels for temporary 

accommodation within daily commuting distance of the Project site. Temporary accommodations will be selected based on 

value, cleanliness, and proximity to the Project site workers who have access to RVs. If temporary accommodation is not available within the Project area, seek motel and hotel accommodations outside the Project area. In this event, the Proponents would provide transportation to the Project site in the form of buses or vans, depending on workforce numbers, to ensure workers arrive at the Project site safely. If sufficient temporary accommodation is not available, depending on the location and 

the number of workers involved, the Proponents would explore other temporary housing options, including the use of 

temporary housing facilities established for other projects, establishing temporary RV lots, and developing Project-specific 

temporary housing camps. The Proponents would provide bus or other transportation to the Project site if these facilities were 

located outside the Project area. Contract with local RV parks for rental spaces to accommodate.” 

As non

 The following questions identified in the draft Gateway West Transmission Project EIS on the bottom of page 3.4-84 need to 

be answered relating to the Housing Plan and the City of Rawlins would like to be involved in this process: o To whom should this housing plan be submitted? o Who will approve it? o What will happen if it is neither submitted nor approved? 

The lanprobeehou

 2007 Rawlins Housing Study needs updating - The City is interested in maintaining a diversified and safe housing mix paying 

special attention to the needs identified in the 2007 Rawlins Housing Assessment. This includes the need for affordable housing, transitional housing (entry level apartments and townhomes to retain new residents in our community), senior citizen 

accessible small single family homes and assisted living housing options to encourage the location and retention of new 

residents and long term ones. The Rawlins May 2007 Housing Assessment needs to be updated because the supply and quality of structures has changed, as has the economy. An analysis should take into consideration a baseline analysis and various growth scenarios based on temporary workforce plans for Gateway West Project and other large scale reasonably 

foreseeable development projects (like those identified Rawlins Attachment #1 “Carbon county Industrial and Natural 

Resource Projects) beginning construction or development in overlapping time frames. Perhaps a synergistic approach to 

developing workforce and employee housing in Rawlins could be pursued which would benefit multiple parties (Employers and employees). [the original comment letter provided additional text and tables that list housing availability in the county; see the 

original comment letter] 

Whpro
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100513 CITY OF RAWLINS 

(cont.) 

Human Resource Organizations – the Human Resource Organizations in Rawlins, many of them non-profit, will see an increase in demand for their services with a large influx of temporary workers as described in the Gateway West Transmission 

Line Project Draft EIS. 

The Se

 o Cummulative Service Demands from an increased temporary workforce population, compounded with other projects that are 

under planning, or in stages of permitting which may be under construction at the same time including: Chokecherry Sierra Madre Wind Generation Project, UR Energy in- situ uranium extraction, Transwest Express Transmission Line, DKRW, 

Sinclair Refinery, Atlantic Rim and an additional 8,000 gas wells soon to be possibly permitted on Continental Divide Creston 

Ridge. (See Rawlins Attachment #1 describing potential additional area projects.) 

PaideSe

100514 JAMES & MICHELE 

HINTON 

section 8, the line between towers 124 and 123 runs through a very narrow gap between two sections of private property. Is 

there a possibility to instead reroute between towers 121 and 120 to connect over with route 9 (or in parallel with)? The junction where the route 9 alternates link up near Murphy seems ideal for that. 

We MuSeget WWthis waaligpinapp

100515 LEENA LEWIS I am concerned about the Gateway Powerline and its current plan 9 to build a monstrous power line. Yo

sup

 Why should we, private landowners, take such a hit and loss when this line could mainly run on public lands? No

site ma

 An alternate route has been mapped out by local citizens that is much less invasive to the private sector 9d. As 

valdue vasimp

100517 MARK WEBB wanted to write a letter expressing my feelings about the route of the transmission line thru Cassia County and why I feel the 

alternate route would be a much better alternative for our county.

No

 One thing that I have noticed is that I have not seen a single large transmission line, there has also been at least up to five in 

one corridor. To say that there is only going to be one transmission line thru Cassia County, I think we are fooling ourselves.

Like I stated, we could work around one single line, but multiple lines will take up prime farm ground and would go right 

through the center of fields taking out current pivots. Once a corridor is established for large transmission lines, it will be

impossible to fight against more coming.

Noeffe

100518 DAVID & SUSAN 

BECK 

...our concern is interrupting our private property and family businesses. There creates a liability concern with both personaland community involvement. The danger of these types of power lines crossing over homes and surrounding areas, which 

involve children, animals, and employees, is of great concern. Therefore, we feel a negative impact on personal and 

community life in our County.

No

100519 WESTERN 

WATERSHEDS PROJECT

There is no map of leks in Nevada -unlike ID and WY - so no way to make visual comparisons of impacts. Only a Table with 

number of leks listed in an Appendix. Lek mapping is in Appendix D with Nevada leks missing.

The The 

dro

The EIS avoidance for sage-grouse leks in Nevada is less protective than in other states. EIS 3.11-66 describes “the agencies have also identified the following mitigation measures ... TESWL-14: Surface disturbance shall be avoided within 0.6 to 4 miles of occupied or undetermined GSG leks from March 15-July 15 in all portions of the project except for Nevada. In Nevada, surface disturbance shall be avoided within view of or within all leks from March 1 to 

May 15; and within areas designated by Nevada as GSG brood rearing areas from May 15 to August 15”. It seems uncertain to me whether brood rearing areas are different than nesting habitat??? In earlier pages the text already sets it up so that even this all can be waived if BLM agrees, or it can also be cast aside if a 

highway or ag land (who knows how that might be defined) or line of sight is blocked between a lek and Gateway activity.

The No Alteana

Page 3.11-65 has “Proponent’s Mitigation Measures” - which are pathetic – but for Nevada even moreso, as PAC-8 describes no construction through ID and WY Core habitats within I mile of active leks from March 1 to May 15. But Nevada???

The No Alteana
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100519 WESTERN 

WATERSHEDS PROJECT (cont.)

There have also not been, as near as I have been able to determine from talking to BLM energy people in Idaho, surveys to determine if there are new leks, or lek activity (as at all the undetermined leks) yet.

The timApper

Much info in all the various models – including those on which supposed mitigation would rely, too, is lacking. Re

mocom

For any alternative other than the proposed route, there is even less info provided. Re

as 

An article a couple of weeks ago said this project has been fast-tracked. I would not under-estimate the political power of Idaho ag interests who are riled up in opposition to it to get this line shoved south by Nevada. 

And unless full and detailed information is provided on conflicts with sage-grouse and other wildlife in Nevada, it will be easier 

to do this. And of that is the case, here is what could happen: To the West of Salmon Falls Reservoir on the ID-NV border will be China 

Mountain = Dead Zone for grouse. To the east would be a new Gateway line – opening up the border area there to wind sprawl. BLM and the southern division of the Sawtooth Forest in Idaho have issued various wind rights-of-ways for MET towers in the South Hills area, and if this line is built - more are likely. So a combined huge impact to grouse and other wildlife 

over the whole region.

The ThiAltePrethe Ch

I am looking at the Gateway EIS and see that apparently BLM is treating Nevada like a sacrifice zone/third world situation. The 

list det

100520 MATT AND 

ROXANNE BECK

the negative effect this project brings The 

Ch

100521 WESTERN 

WATERSHEDS PROJECT 

For raptors, there is one Map with NV info. This is appendix E, Map 10-6 It depicts one raptor nest and/or roost in Nevada. A 

golden eagle. Since there have not been major mines or tower development here, how adequate have any previous surveys 

been? 

Alterapcomconpro

 This EIS was a long time in development, and the lack of critical biological information, baseline surveys and adequate 

information is distressing. 

Bares

secbio

 Raptor electrocutions and other problems do indeed happen (for example electrocuted birds can burst into flames and ignite 

fires – as has happened in SW Idaho), along with lines providing perches that impact predation of sage-grouse, pygmy rabbits, 

etc. and construction would occur along an unknown and unrevealed number of access roads, and potential new roading 

could be constructed and persist increasing human access and disturbance, along with the smashing or blading of sagebrush along areas where the line uprights are assembled. We could certainly also expect disturbance to raptor nest sites so this 

information needs to be scrutinized, too. 

BotUSincspe

 I have Attached photos we took of SWIP assembly near the Grant Range for your review. August 2011. Photo 3080 shows 

one part of the horizontal part of a tower laying on the bladed ground surface. Photo 3082 shows the adjacent sagebrush which likely had extended on to the bladed site. An adjacent road through sagebrush was all torn up, and appeared to have 

been expanded sideways, too –or it may have been new altogether [4 photos submitted with letter] 

TheareaccEIS we

100523 EDWARD LAWSON ISSUE 5: The Potential Impacts to Wildlife Habitats within the Gateway West Project Area. 

There are several big game animals in the area, including, but not limited to, elk, pronghorn, moose, mule deer, and mountain 

lions. The EIS must address the increased risk of reduction in wildlife habitats and big game populations. There is a need to 

protect and maintain crucial winter range for big game, critical winter habitat, and habitats for nesting, brooding, and rearing. In 

addition, the EIS must address the impacts on big game migration corridors and their maintenance as viable routes for the big game identified in the area. Furthermore, the EIS must address the location of the transmission lines in relation to rare and/or 

sensitive wildlife habitats, including kipukas, lava tubes, caves, wetlands, and riparian areas. Also, the EIS must address the

potential to increase disturbance of natural habitats and sensitive species by recreational vehicle use, hunting, and other increased access to remote sites through development corridor access

Imp3.1in Sand add
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100523 EDWARD LAWSON 

(cont.) 

Transmission lines, with their 145- to 190-foot-tall lattice steel towers, anywhere near the ranch would seriously diminish 

[Business] ability to collect revenues on these operations and decrease its ability to attract visitors because of the aesthetic 

blight they would bring to an area whose aesthetic and back-to-nature charm is the ranch's raison d'etre, as well as because of

perceived health risks associated with high powered transmission lines (See Issues 2 and 11). [**refers to northern alternative

to segment 6 (north of craters of the moon) dropped from further analysis]

Nosim

 TNC has acquired (most through charitable donations) conservation easements from property owners near the [Ranch] to 

protect the uniquely splendid area in and around Silver Creek. Any transmission line route bordering TNC's conservation easements, including those on [Ranch], the Swanson ranch, and the Purdys' Picabo Livestock Ranch would require the EIS to 

address the direct impacts the transmission line project will have on all of the conservation easements in the Silver Creek area.

No the Ch

 The following issues should be addressed in the EIS: (I) known impacts to birds from current transmission lines and other tall

structures should be thoroughly reviewed in order to identify potential impacts that could result from the transmission line; (2) 

the disturbance or other impacts that the construction, operation, and maintenance of a 500 kV transmission line project would 

have on migration patterns; (3) the potential impacts to raptors and their prey from transmission lines, including the risk of 

electrocution; (4) how new transmission lines and towers located in areas without trees or other natural perches may result in an increase in the hunting pressure on raptor prey species that are rare or declining; (5) the direct impact of osprey nesting on transmission lines; (6) the potential impacts to candidate species for Federal listing; and (7) the impacts on honey bee hives.

1) A con> MRapromaCahon

 ISSUE 6: The Potential Impacts on Sensitive Plants, Fish Species, Mammal Habitats and Migration Routes, Migratory 

Waterfowl and Shorebirds, and Water Quality. The proposed transmission line project may alter the habitat of sensitive fish species within Silver Creek. The disturbance could happen in multiple ways: (a) by increasing the amount of silt in the creek as a result of rain run-off over areas disturbed 

by the construction of the project or by the construction or use of roads contemplated by it (see Issue 10 below), (b) by herbicides that may be needed for control of noxious weeds (see Issue 8 below), and (c) by the magnitude and frequency of underwater noise and vibrations associated with the construction and operation of the transmission lines. There is a need to 

preserve and/or improve supporting habitats, including water flows and quality. The EIS should include an assessment of and the potential for adversely affecting fish and water quality due to increased siltation, herbicides, noise, or vibration. Particular 

emphasis should be given to the noise and vibration thresholds that may exist for each species. 

An assessment of these same issues also needs to be applied to the potential impacts upon migration routes of migratory 

mammals, such as elk, deer, and pronghorn, as well as the flyways for migratory waterfowl and shorebirds. 

Moreover, the proposed transmission lines may affect sensitive plant and rare native plant communities in the area. Among its abundance of wildflowers is the small yellow ladyslipper orchid, a state plant species of concern. The EIS should include an assessment of all plant species known in the area.

ImpsiltnoiIt is noiImpthe to SThryelUSDawaspe

 ISSUE 7: Increased Traffic and the Potential for Associated Impacts on Existing County, State and BLM Roads. 

Increased traffic on existing county, state, and BLM roads can result in increased traffic hazards, higher maintenance costs, the need to upgrade roads, and more intensive transportation planning. The EIS should include an assessment of the 

magnitude and frequency of fires due to the travel of trucks and equipment on these roads and also from lightning hitting the transmission lines and towers. The EIS should include an assessment of how viable the construction, operation, and 

maintenance of the transmission lines and towers of the proposed size is in this type of terrain, geology, and weather extremes[refers to segment 6 alternative north of craters of the moon that was dropped from further analysis]

Nome

 The EIS must address the potential introduction and spread of invasive species and weeds, the prevention of invasive species 

and weeds, the need to assure successful reclamation, including soil stabilization, interim reclamation within the first growing 

season, weed control, and monitoring or reclamation success with adaptive management in difficult areas. [**refers to segment 

6 alternative north of craters of the moon dropped from further analysis]

No(EP

 The EIS must address conflicts with livestock management operations, including reduced forage availability, livestock 

disturbance, harassment, electrocution, birth defects, stillborns, and the reduction of the viability of range improvement 

projects and compromised range/vegetation quality [**refers to northern alternative north of craters of the moon dropped from further analysis]

TheThe dro
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100523 EDWARD LAWSON 

(cont.) 

The following issues should be addressed in the EIS: (I) changes in water quality and quantity; (2) adverse effects to stream 

hydraulics, nutrient pathways, invertebrate production and fish production; (3) soil disturbance, in and around the stream, that 

will cause sediment to settle into the gravel spawning beds upon which fish depend for hatching their young; (4) erosion control; (5) increased sedimentation that will increase in perpetuity if any road is built near, over, or around the creek; (6) the 

increase of temperature to the creek, which will reduce the oxygen available to important aquatic organisms; (7) the likelihood

and description of chemical contaminations that may spill into the water and affect the quality of water and [Ranch] right of use 

and enjoyment, right of exclusion, and right of transfer of its land; (8) the measures such as an emergency response plan to 

mitigate impacts of contamination spills into or near the water; (9) the installation technique for the electrical cables and the 

effect on the water quality described above; and (10) the types of materials to be used in the water, such as stone, metals, 

concrete, etc., and the likely effects of interactions between water, encrusting organisms, and sediment. [refers to seg 6 alt dropped from further analysis (north of craters of the moon)]

Thein A

 The EIS must address the potential health impacts that the construction and operation of the transmission lines may create for

humans or livestock. The EIS's analysis of potential health impacts should give particular emphasis to known impacts to humans and livestock from exposure to Electromagnetic Fields (EMF) generated by high voltage transmission lines. Specifically, the EIS must include a thorough analysis of the current studies and reports associating exposure to high levels of 

EMF with human health risks such as leukemia and other cancers. Moreover, the EIS must address the potential accident 

scenarios concerning the transmission lines and the need for appropriate emergency preparedness plans [refers to rout north 

of craters of the moon - dropped from further analysis]

Ele

 [Business] expressly opposes any routing of power lines and poles of the Gateway West Project through any of the areas 

within the environs of [Ranch], including, without limitation, the Pioneer Mountain foothills, the environs of the City of Carey, 

and/or the Silver Creek/Picabo valley.

NoAlteana

 A transmission line in the vicinity of Picabo and Silver Creek Preserve not only would defeat the purpose of TNC's 

conservation easements

NoAlteana

100524 MINIDOKA COUNTY 

BUILDING AND ZONING

The southern route through Cassia County makes more sense! Let's put this thing as much as possible on gov. land that we 

all own and impact to the least degree our prime ag land and communities

Yorou

disas 

do not go through the heart of Cassia County! No

the 

100525 NATIONAL PARK 

SERVICE

Page 3.3-70 3.3.3.2 Impacts Common to All Action Alternatives - CUL-1: Monitoring and Mitigation Plan: ... --Will a paleontologist be on site in areas of possible fossil locations to monitor activities? --Will an archeologist be on site to monitor all ground disturbing activities to ensure no subsurface cultural material?

EPmo

Page 3.3-70 3.3.3.2 Impacts Common to All Action Alternatives - CUL-1: Monitoring and Mitigation Plan: 

--Has this plan been written or is it in the process of being written?

The the 

The NPS has initiated a new General Management Plan process. As part of this process, we consider whether current park 

boundaries adequately protect core resources and values fundamental to a park's legislated purpose. The area south of the Reserve, including Sparks Basin, has been internally identified as an appropriate, integral, potential expansion of the park. 

This area has historical and cultural integrity fitting for inclusion within Reserve boundaries. To this end, the NPS has expended a significant amount of money received from appropriations through the Land and Water Conservation Fund Act and BLM's Federal Land Transaction Facilitation Act for acquiring additional land along the southern boundary of the Reserve, both within and potentially outside Reserve boundaries. The NPS is also concerned with indirect impacts to the Reserve. Construction, operation, and maintenance of the transmission 

lines and associated infrastructure will impact more than just the viewshed and cultural landscape.

Nolist Ro
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100525 NATIONAL PARK 

SERVICE (cont.)

The City of Rocks is designated as a National Historic Landmark (NHL). Section 110(f) of the ational Historic Preservation Act (NHPA) requires that agency officials, to the maximum extent possible, undertake such planning and actions as may be necessary to minimize harm to any NHL that may be directly and adversely affected by an undertaking. The Advisory Council 

on Historic Preservation (ACHP) regulations (36 C.F.R. § 800.10), pursuant to Section 106 of the NHPA, require a Federal 

agency to contact the Secretary of the Interior and the Advisory Council when proposed undertakings have the potential to affect NHLs. Idaho Power Company will likely be the lead on the Section 106 consultation process. 

The NPS, as the Secretary of the Interior's representative, actively monitors NHLs and has an ongoing relationship with 

owners of NHLs. (36 C.F.R. § 65.7.) Please ensure that the NPS Regional Director, Pacific West Region, as well as the Superintendent of the Reserve, are copied on future correspondence and compliance documentation. The NPS should be consulted and invited to be a signatory on any Memorandum of Understanding or Programmatic Agreement developed to 

address specific mitigation for this project

Nolist Ro

The NPS is very concerned with the cumulative impacts to the viewshed and cultural landscape that will result from this projectin addition to the five other separate transmission line projects projected for the southern route corridor, particularly through 

Sparks Basin. The view from the Reserve, especially as one stands on the California Trail and looks south toward the Cedar 

Hills and Sparks Basin, will be greatly impacted. Thorough consideration and analysis of the cumulative impacts to natural, recreation, aesthetic/visual, auditory, cultural, 

archeological, historical and paleontological resources should occur prior to selection of any route. Ultimately, no mitigation

measure can remedy the permanent clearing and impacts of an energy corridor. The nationally significant values of the 

Reserve will likely be impacted by multiple transmission lines and towers placed so close to the Reserve and within clear view

Nothafrom Sewe

The southern route is much closer to the Reserve than Idaho Power's preferred route. The southern route transects private 

land and land managed by the Bureau of Land Management (BLM), and adds an additional 29 miles of transmission line to 

Idaho Power's preferred alternative. Physical, geographic constraints further limit a viable route through what is known as, 

"Sparks Basin," just south of the Reserve. The southern route will parallel or cover approximately 30 miles of National Historic 

Trails, including the California Trail (main route) and Salt Lake Alternate of the California Trail, as well as parallel or cover the marked Mormon Battalion Trail, and Boise-Kelton Stage Route. Towers may exceed 180 feet in height, and the cables 

required to transmit high voltage will be substantial. In short, the location and presence of large, dominating infrastructure in an 

otherwise pristine area will have major impacts that can only be partially and likely minimally mitigated.

YoTheconpro

Page 3.3-85 Table 3.3-6: Oregon Trail NHT - C62: Figure Number Reference is not correct. In table it states 3.3-167 - 3.3-168 

is associated with Hagerman Fossil Beds National Monument.

Infocor

On page 3.3-220 Figure 3.3-167 is labeled KOP C60 "View from Three Island Crossing ...." which it could be since it is not in 

the Hageman Fossil Beds NM area

Infocor

Also, on page 3.3-221 Figure 3.3-168 looks to be from Hagerman Fossil Beds NM from the Oregon Trail Overlook looking 

south. The picture is too dark to get a good idea of the exact location/view

Cocap

Page 3.3-221 Figure 3.3-169 KOP 62 states that it is a view looking north towards Alternative 8A. This view is looking east, not towards Alt. 8A, but more towards Alt. 9B. In the Table 3.3-6 on page 3.3-85, Figure 3.3-169 is said to be associated with C81-Rock Creek Station and Stricker Ranch

Info

Page 3.3-87 Table 3.3-6 Segment 10 - C82: table states Figure 3.3-189 is Wilson Butte Cave, but on page 3.3-237 Figure 3.3-

189 states "... Segment 9 and Alternative 9E from the northwest side of the Owyhee County Courthouse." On page 3.3-238 

has Figure 3.3-190 KOP C82 "...looking southwest towards the Proposed Route in Segment 10." I'm assuming this is the 

Wilson Butte Cave area?

Infocor

Also on page 3.3-87 Table 3.3-6, Segment 10, the table has C99 Figure 3.3-190 associated with Minidoka National Historic Site, but on page 3.3-239 the figure is Figure 3.3-191

Infocor

Page 3.3-220 talks about the Oregon Trail that runs through Hagerman Fossil Beds NM being ".... 1.4 miles northeast of Alternative 9B.... ". "Alternative 9B would be located to the south of this location on the south side of an existing, wooden Hframe transmission line, which parallels the trail (within feet) at the Hagerman Fossil Beds National Monument, between the 

trail and the Project, which will be built 1.5 miles away". This is a bit confusing. Is Alt. 9B 1.4 or 1.5 miles from the KOP C62, 

(figures 3.3-168 - 3.3-169)? Where is Alt. 9B in association with the Monument's southern boundary?

Texto Abou

It would have been a good idea to have a simulation photo at KOP C62 since Alt. 9B is so close to Hagerman Fossil Beds 

National Monument.

Co

Opposed to Alternative 8A and 9B due to adverse impacts to Hagerman Fossil Beds National Monument YoPage 3.13-9 Description of Hagerman Fossil Beds National Monument should note that the Hagerman Horse Quarry is a National Natural Landmark, as noted during previous comment periods

Infois a 

We continue to be concerned as to the adverse visual impact at Hagerman Fossil Beds National Monument. As noted during 

previous comment periods, cumulative effects have not been adequately addressed, especially in regards to the great 

increase in the number of wind turbines in the area in just the past year

The Hain C
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100525 NATIONAL PARK 

SERVICE (cont.)

On the CD that was given with the Draft EIS, Minidoka National Historic Site simulation is EJ-49 and E.50. There is no E.3-55 and E.3-56 on the CD

Info

Continued concern with the adverse visual impact on Minidoka National Historic Site in the Proposed Route for Segment 10 YoBLM and its consultants have prepared an extensive and thorough DEIS with multiple alternatives for most of the 10 Gateway 

West power line segments under consideration. Altogether, a menu of49 alternatives is presented and analyzed. These include the proponents' proposed alternatives for each segment, but as yet, no agency-selected preferred alternative

Thiidedes

Based on the available data, then, the project could incur up to nine direct, adverse impacts on the Oregon and California 

National Historic Trails. Ultimately, the number of direct adverse impacts could be even higher once the final route is chosen and project personnel are permitted to access and analyze project/trail interfaces on private property. 

The DEIS does not provide a similar table summarizing indirect (typically visual intrusions) adverse impacts, which probably 

will be the majority of adverse impacts to the national historic trails

Ad

In addition, the DEIS notes in its cumulative impacts section that construction of the Gateway West transmission line "could 

lead to the establishment of a corridor in which other lines may be installed in the future." In fact, BLM reports, three other

projects currently in the environmental review process have already inquired about using some or all of the segments or 

alternative routes that are considered in the Gateway DEIS. Since parallel transmission lines require a space buffer to prevent

arcing, these corridors ultimately could become broad swaths of multiple power lines.

No

Finally, BLM's DEIS also provides some informative tables of other proposed energy development projects, which show 12 (in addition to Gateway) proposed new transmission lines in Wyoming and Idaho; two coal-fired power plants in Wyoming; five geothermal projects in Idaho; 25 new wind facilities in Idaho and five in Wyoming, requiring construction of between 1,709 and 2,039 new miles of transmission lines; and five pumped storage projects in Idaho and Wyoming with pre-permits already 

approved. No figures are provided for oil and gas development.

Ple

this project will result in dozens of irreversible direct, visual, and cumulative adverse impacts to nationally significant, historic remnants of the original Oregon and California emigrant trails. NPS urges BLM, wherever feasible, to select alternatives that 

will avoid or minimize those impacts at the key locations cited above. In those situations where adverse impacts to NHT 

resources are deemed unavoidable, meaningful mitigation actions of comparable magnitude will be in order.

Noin t

We observed that under Alternative 4F of the DEIS, the transmission lines may pass within 1000 feet of the Pine Creek Ski 

Resort in Lincoln County, Wyoming. Lincoln County, the grant sponsor, received financial assistance from the LWCF program to improve the ski area through grants 56-00371, 56-00467, 56-00602, 56-00772, and 56-00781. While the DEIS only 

indicates the potential proximity of the new transmission lines to this public ski area, we wish to point out that the granting of 

any new right-of-way and/or the placement of transmission lines within the boundary of the Pine Creek Ski Resort will 

constitute a conversion to other than public outdoor recreation under Section 6(1)(3) of the LWCF Act (public Law 88-578, as 

amended). Avoiding the Pine Creek Ski Resort will prevent any LWCF conflicts

Nolist Ro

it appears at this early stage that Idaho Power's preferred route through Cassia County will have the least impacts to the Reserve.

Yosup

Page 3.3-56 Idaho National Historic Trail Resource Overview - Oregon NHT: The Oregon Trail goes through the southern 

portion of Hagerman Fossil Beds National Monument. How far away will Alternate Route 9B be from the Monument's southern 

boundary? This is about 1-mile from the Oregon Trail.

The the sou

Please accept the following specific comments related to Hagerman Fossil Beds National Monument and Minidoka National 

Historic Site. -Page 3.3-24 Segment 7, Line 26-27: "The exception is Alternative 71, which dips south to run along the Utah and Nevada 

border." Should this not be "Idaho and Nevada border?"

Lan

bor

Later in the document, Figures 2.4-2 and 2.5-1 (pages 2-86 and 2-118 respectively) clearly display and label the alternative routes for those segments of the project. It would be useful to the reader to provide similar maps, at similar scales for the 

alternatives in segment 4.

Prothe MaGIS ele

The map on page 2-65, Figure 2.4-1 that provides an overview of the segment 4 routes does not depict the 6 alternatives for 

alternative 4 in a clear manner. The routes 4A through 4F are not labeled

Thi

The routes that would best serve the interests of the Monument are located 4 - 6 miles north of the monument (Alternative 4, 

4A or 4F) or a similar distance south of the monument (Alternatives 4D or 4E).

Yoin t

Fossil Butte National Monument's interests would best be served by not developing the proposed route located one mile south of the monument (Alternatives 4B or 4C

Yotab
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100525 NATIONAL PARK 

SERVICE (cont.)

The Alternatives 4B and 4C would construct along U.S. Hwy 30, within one mile south of the monument boundary and would 

have significant visual impacts for visitors on the Historic Quarry Trail, from the visitor center, and from the Chicken Creek Nature Trail and research quarry as well as from the scenic road up into the high country. The surrounding vegetation is primarily sagebrush steppe and from the monument, there is nothing to block the visual intrusion of such a high profile, power transmission line. In addition to visual impacts, noise impacts during construction would be intrusive to visitors. After 

construction, visual impacts would be long term and adversely affect every visitor to Fossil Butte National Monument from 

every location that is currently developed for visitor use.

ImpImpbacvisskyvisgiv

Furthermore, Greater Sage Grouse (a federal candidate species) breed on leks in the monument and travel 3 - 6 miles to 

select nesting and rearing sites for the completion of the breeding cycle. These birds would be adversely impacted during 

transmission line construction activities, and habitat would be directly lost due to the construction footprint all along this corridor one mile south of the monument (Alternatives 4B and 4C).

NocurPre

this transmission line corridor would likely attract additional infrastructure development and the Monument would be adversely 

impacted by additional developments in the future.

NocurPre

Visual Simulations The NPS recommends that Idaho Power Company include digital-generated images of surrounding terrain with the proposed 

transmission line from several different vantage points, which would assist the NPS in determining visual impacts. 

Images of both the single transmission line and the full build-out of all five transmission lines should be included in the 

environmental review document.

Co

Finally, the NPS recommends considering whether better alternatives to transmission lines might be available to meet regional 

energy needs, such as more local renewable energy sources like solar and wind, and which do not require transmission lines 

that extend for hundreds of miles, retrofitting existing transmission lines for greater energy efficiency, etc.

Deana

The initial scoping process for the Gateway West Transmission Line project in Owyhee County was flawed. 

I am enclosing the article which appeared May 28, 2008 in the Owyhee Avalance announcing a public scoping meeting to authorize ROW for Gateway West on BLM land. The public was not notified reguarding the impact of this PUBLIC utility project 

on private land. As a result only 13 people attended the June 3, 2008 public scoping meeting held in Murphy, ID. The citizenry of Owyhee County was not adequately represented in this initial scoping process resulting in conciderable time, labor and expense once the consequence of proposed seg 9 come into our awareness spring 2009

The methe

100526 OWYHEE COUNTY 

TASK FORCE

in sec. 368 the establishment of energy right-of-way corridors on FEDERAL land. These corridors are to be on FEDERAL land 

following existing ROW's (i.e. roads, existing transmission lines per the Federal Land Policy and Management Act of 1976) 

and were to be INCORPORATED into agency land use and resource management plans. This is not what occurred in Owyhee 

County.

As in O

please amend the SRBOP RMP to accomodate segment 9D as outlined in appendix F-1. The 

NCRM

In chapter 3 the only historical site listed in Oreana is Our Lady Queen of Heaven Catholic Church that is affected by the 

Proposed Route. Our community of Oreana is entirely comprised of old established family ranches from the 1800's - early 

1900's. The [name], [name], [name], [name], [name], [name], [name], [name] and the [ranch] (next to the church). The families 

have been running these ranches for decades and their properties have old homesteads still standing surrounded by old farm implements. The Proposed Route would traipse right through these historic properties. The same can be said for the 

communities of Bruneau, Grand View, Little Valley and Murphy. [name] owns the [ranch] est. 1865. [name] is a [name] descendant. [name]'s son [name] is a 5th generation [name] working 

this family owned ranch. The [ranch] is the oldest family owned ranch in the state of Idaho. The Proposed Route goes right through this ranch

The inccomdes

One trip to the Owyhee County Historical Museum will expose the hundreds of historical and cultural sites the proposed route traverses; one of which is the museum itself! The museum is located right behind the Owyhee County Courthouse - also 

located within the Proposed Route!

NoRocomdes
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100526 OWYHEE COUNTY 

TASK FORCE (cont.)

Prior to Sept 4, 2009 all counties had to have alternative proposals submitted to the BLM for analysis in the DEIS. Idaho 

Power changed their perferred route for segment 8. Originally Idaho Powers preferred route was what is now 8B affecting significant amounts of agricultural and residential properties. Idaho Power accomodated the Ada County Commissioners. 

Owyhee County Commissioners strongly urged Idaho Power to adapt seg 9D as their preferred route to no avail. 

11.8% of Ada County = below poverty level 17.4% of Owyhee County = below poverty level 7.1% of Ada County = Hispanic 25.8% of Owyhee County = Hispanic 0.7% of Ada County = American Indian 4.3% of Owyhee County = American Indian Selecting Alternative 9D would negate this issue

No

There may be an association between exposure to electromagnetic fields and adverse health effects. The Proposed Route is 

sited where we live and work

Yosup

The Proposed Route is sited where we live and work. Alternative 9D would have significantly less impact in this category YoAccording to this table the Proposed Route has 6 residencies within 300 feet of the center line, 9 residencies within 1,000 feet. 

This is woefully inaccurate. Owyhee County has 13 homes within 300 feet of the center line. 40 homes within 1,000 feet. This 

information was deduced off of a 911 map obtained from the Owyhee County Assessors Office. The Owyhee County 

Commissioners will have possesion of this map

The if a 

The Proposed Route would negatively affect all of our property values with an adverage decrease of 10% (Delaney and 

Timmons 1992

Yosup

This would markedly decrease our county's tax revenues. This is one of the many reasons the Owyhee County Task Force has worked so hard to submit Alternative 9D.

Yosup

An earlier comment addressed the fact that the Proposed Route is comprised of 18.4 miles of unanalyzed private property 

which incorporates some positively breathtaking creeks, ponds, canyons and old homesteads.... There are an incredible 

number of KOP's excluded from this DEIS due to the fact they are on private property

Se

I must point out the analysis of the KOP's on the Proposed Route lists many impacts as low to moderate due to "human made alterations". There is a 10 mile stretch of BLM land between my house and [name]'s ranch which does not so much as have a service line in it! The Proposed Route would be a huge new environmental impact of all of Owyhee County

CoAlssim

Please select Alternative 9D for the Gateway West Transmission Line Project. Yo

100528 IDAHO 

DEPARTMENT OF ENVIRONMENTAL QUALITY 

Cache Valley PM2.5 nonattainment area (NAA) - This nonattainment area spans two states (Utah and Idaho). In Idaho the 

NAA does not cover the entire Franklin County. It is hard to tell from your figure 3.20-1 whether or not this is the case, but DEQ believes that the portion of the transmission line that cuts through Franklin County, Idaho would not fall in the NAA 

boundary. It would be good if the figure showed the Cache Valley NAA spanning the two states or address the fact that the 

NAA crosses over into the Utah side (especially since graphic shows that portion of Utah. The shading of the area also 

appears to be wrong on the 3.20-1 figure showing up as an area of concern rather than a NAA. It might be beneficial to get a GIS overlay from DEQ showing the correct NAA boundaries for the Cache Valley NAA. 

Thi

 Portneuf Valley PM10 Maintenance Area - This area is currently listed as a maintenance area and has been redesignated to 

attainment with respect to the PM10 standard. This area is shaded incorrectly on the map as a nonattainment area and should 

be shaded as an area of concern since it is redesignated and listed as a maintenance area. 

Thi

 The Fort Hall PM10 Nonattainment Area - This area is managed by the Environmental Protection Agency and the ShoshoneBannock Tribes. This area does not appear on the figure and is not discussed in the text. This area is still listed as a PM10 

nonattainment area. 

Seinfo

 All of the shading in the Boise area should reflect area of concern only. There are currently no Nonattainment Areas in that 

area. The Boise details are as follows: The Northern Ada County Area is in maintenance for CO and PM10, this area has been 

redesignated to attaining the standards and should be shown as an Area of concern. The Treasure Valley Ozone and PM2.5 is currently just an area of concern. This area currently meets both air quality standards and is listed as an attainment area. This 

area is close to violated both ozone and PM2.5 and should be listed as an area of concern. 

Thi

 The Figure 3.20-1 needs to be fixed with shading for the areas of concern and nonattainment areas. The Fort Hall NAA needs 

to be added and DEQ suggested the correct legal description of the Cache Valley NAA be added to the map to show that the transmission line will fall outside of the NAA boundary 

Thi

 The correct way to type PM10 and PM2.5 is to subscript the numbers when using the chemical abbreviation. I did not provide 

my numbers this way through the comment system since, I could not find a way to subscript the numbers. 

The 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100529 JOAN 

PERMANN,IVAN PERMANN 

The alternative routes of 5&7 are probably the best routs to take for any future growth, as they will be setting precedence for

future lines coming through this area. Power lines are for the public and therefore should be put on public land!

Yosup

 Private landowners should have say as to where these lines go as they are the ones who pay the taxes to the county, state 

and federal government. We are the landowners--your wages come from the taxes we pay. There is not fair compensation 

down the road for the abuse the landowners are caused by working and living around the power lines and towers. The utility 

companies reap the profits and benefits, while the landowners are just supposed to deal with the hindrances that are caused by towers and power lines on their farm ground. If the power lines must come through, fair compensations to the land owners 

need to be made and not only a onetime payment. The power companies are reaping the profits yearly and so should the 

landowners. If the utility companies are making a profit each year the landowner should be receiving just compensation yearly. 

If landowners are dealt with properly, they would not be so opposed to having the towers on their land.

The Coaut

 Your impact statement tries to compare these towers to existing lines, but the existing lines are much smaller. The new towers

will be huge in comparison.

No

100530 CLINT RODEMAN, 

SHARON RODEMAN 

1E-A and 1E-B corridors are crowded onto primarily private land and cross into the foothills of the Northern Laramie Range. 

The line continues to be in the mountains in some areas rather than the plains and this can't be the most economical project for the RMP ratepayers. It appears this line was designed to avoid the core sage grouse area and therefore (with no other 

logical reason than to pick up wind development on the Dunlap Ranch) it ended up crammed between the mountains and the core area.

Yotabconpro

 1E-A and 1E-B corridors are located within recorded Wyoming G&F elk migration and winter ranges. The elk herd in Area 7 is 

known as one of the best in the state and brings in revenue for the state yearly.

Yotabconpro

 As a landowner in the Gateway West proposed 1E corridor, we would like to express our...oppose 1E-A and 1E-B. Yo

tabconpro

100530 CLINT RODEMAN, 

SHARON RODEMAN (cont.) 

As a landowner in the Gateway West proposed 1E corridor, we would like to express our support for 1E-C Yo

Hoconpro

 1E-C would parallel 1W and would stay in the existing corrdor thus following Governor Mead's executive order. No

conpro

 1E-C would not cross additional core sage grouse area. This is important as Wyoming has received an award for the 

protection of these areas.

Noconpro

100532 DAN MCHARGUE We don't want any part of this line on our land. Whave 16 tenets of land between East Fork and Portage Canyon. You have 

been given two options of routs to use other than through Rockland. Use one of them!

Notab

100534 LAWRENCE B FOX the concerns I have are mostly the route and is there one with less impact on the residents of the area and wildlife by 

fracturing habitat with roads and clearing of R of W. Could it be possible to cross the Bridger lines west of Sharon and followthe clearing for the existing line that follows Hwy 36 to the Bear River above Preston. An advantage of this might be less 

roads, less clearing of trees, and long-term disruption of wildlife migration by creating open areas or "shooting lanes" duringhunting seasons.

No

100535 TOD E AND DEITA L 

JENSEN 

4. Companies need to address weeds that may grow in right of way through discussions with property owner. No

owRO

 1. To avoid impacts to cabins, move line along south edge of GISID #34. This will also avoid maple arch road used by 

professional photographer who is my wife. 2. Shift north onto parcel GISID #7426 because access to route must cross my property anyway.

The via The 

 3. Companies need to further discuss access related to locked gates with property owner. The 

via The 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100536 GLENN MONIZ strongly oppose Alternatives 1E-A and 1E-B in northern Albany County. The Albany County Commission has raised objections 

to these alternatives as has the Governor. I want to add my opposition to these alternatives. 

Yosupprotha

 Alternative 1E-C, which follows Rocky Mountain Power's existing transmission line between Windstar and Aeolus, will result in

significantly less impacts to landowners that reside in that area. I see no evidence in the DEIS that suggests that constructing all three lines between Windstar and Aeolus can not be accomodated in the existing corridor. I recommend the BLM choose 

Alternative 1E-C in the Record of Decision for the project 

Yosupparwe

100537 EARL SHOEMAKER proposed route 1E be scraped in favor of the feasible alternative 1E-A route Yo

sup

conhav

 proposed route 1E be scraped in favor of the feasible alternative 1E-A route Yo

sup

conhav

 favor of the feasible alternative 1E-A route. An even better route might be the one that goes almost due south or southeast 

from Windstar, eventually circling around to the Aeolus substation. This plan is the purple line that in the legend is referred to 

as "alternative not studied in deal" on the map labled "Project Overview" figure A-1.

Yosupconhav

 what effect high tension lines have on radio, TV, and cell phone communications for those living or doing business underneath 

or near them. I only know what effect they have on my radio when I drive below them.

Rawhlinesuca c

100538 PATSY ANDERSON After meeting with Idaho Power representatives, Todd Adams and Scott Flinders, the following reasons for rerouting the 

Gateway West Transmission Line Project (blue line on attached map) were mutually agreed upon and are as follows: 

1. The transmission line would not hinder views of the Historic Oregon Trail and surrounding area rated VRMII. 

2. There would be less area to reclassify. 3. The transmission line would cross Clover Creek at a more favorable location. This place of crossing the creek is not as undulating and would be easier to emplace roadways for axcess for the erecting of transmission line structures and for the maintenance and upkeep of this line. 4. Only 2 angles in the transmission line would be needed as shown by the blue line whereas 5 angles would be required by 

the proposed route, (red line). This change would lower impact on the environment for erecting the transmission line structures

and be more cost efficient for Idaho Power/Rocky Mountain Power. 5. The distance of the proposed route (red line) is 6.4 miles. The distance of the proposed change (blue line) is 6.8 miles, a distance change of only .4 miles. 6. The proposed route (red line) would pass over existing home. With the newly proposed change this problem would be 

eliminated (milepost 38.3).

The homCo

100539 WILLIAM J & 

COLLEEN LOUGHMILLER 

I am writing this in response to the conversation that we had in Almo with Todd Adams from the Idaho Power Company. I have 

prepared two maps of a route which is close to the original proposed route through Cassia County. The route uses The south side of 1000 South as the primary route. The proposal has been shown to Commissioner Dennis 

Crane, Representative Scott Bedke and Todd Adams. Each thought it had merit but should be held until after the draft EIS was 

released. In our discussion Todd said he would be willing to share the maps with you and I am willing to propose the plan 

publicly if and when needed. I believe the route is a good compromise and the most economical route. If you need more information please contact me anytime.

No
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100542 ANONYMOUS, DAVID A.,

BRANDON, ALBERT, KT,ANONYMOUS,

ANONYMOUS, SCOTT,

ANONYMOUS, CHELSIE,

BETTY A, LORA BARNES,

PAUL BEACHLEY, DONBISHOP, CLINT BOWEN,

CRYSTAL BOWEN,

AMANDA BUG, PAMELA &

ROGER BURG, PENNY

CLARKE, C COOPER,

GEORGIA COPLEN, LARRY

COPLEN, JANELLECORNING, MELISSA

CROWTHER, KRISTI DEACH,

DESTRY DEARDEN, BECKY

DIKE, JEFF ENDECOTT,

VERONICA ENDECOTT,

PERRY A FAGNANT,

GREGORY GILBERT, JOHN

GIORGIS, ANGELINA

GIORGIS, GINA HANNEY,

RICHARD HARNELL, SARAH

HEMKER, DONNA HINTON,

LAWRENCE HINTON, JOHN

A HUNZIE, DARCY HUNZIE,

JOHN W HUNZIE, RENEE

HUNZIE, JOHN JETKOSKI,JOE KALAN, SHALEE

KILPACK, ZACH KILPACK,

DAVID KING, TAMMIEKING, J KRUCKUBERG, KAY

LAYLAND, ALDO LEBOLO,

W MARCHIROND, SARA

MARTINEZ, MATTHEW

MCCLOUD, BUTCHMORETTI, FRANKIE

NELSON, JEANNE NELSON,

DAVID ORYILL, JUDY

OURADA, TY P, STEVE

PEART, MAJIL PEART,

NICOLE PETERSEN,JENNIFER SHERLOCK,BLAINE SUORLAND, KELLYTUCKER, NICKY TUCKER,KEETON TUCKER,

CHRISTINE TURNER, R

WAYNE ULIS, MARK

VICKERY, MARGIE VICKERY,

STANLEY WEBON

This letter is to "PROTEST" and "DISAGREE" with the Gateway West Transmission Line Project, especially the RED 

number four route. Starting at Montpelier Id. through Lincoln County/Kemmerer area. 

Yono linebee
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100542 ANONYMOUS, DAVID A.,

BRANDON, ALBERT, KT,ANONYMOUS,

ANONYMOUS, SCOTT,

ANONYMOUS, CHELSIE,

BETTY A, LORA BARNES,

PAUL BEACHLEY, DONBISHOP, CLINT BOWEN,

CRYSTAL BOWEN,

AMANDA BUG, PAMELA &

ROGER BURG, PENNY

CLARKE, C COOPER,

GEORGIA COPLEN, LARRY

COPLEN, JANELLECORNING, MELISSA

CROWTHER, KRISTI DEACH,

DESTRY DEARDEN, BECKY

DIKE, JEFF ENDECOTT,

VERONICA ENDECOTT,

PERRY A FAGNANT,

GREGORY GILBERT, JOHN

GIORGIS, ANGELINA

GIORGIS, GINA HANNEY,

RICHARD HARNELL, SARAH

HEMKER, DONNA HINTON,

LAWRENCE HINTON, JOHN

A HUNZIE, DARCY HUNZIE,

JOHN W HUNZIE, RENEE

HUNZIE, JOHN JETKOSKI,JOE KALAN, SHALEE

KILPACK, ZACH KILPACK,

DAVID KING, TAMMIEKING, J KRUCKUBERG, KAY

LAYLAND, ALDO LEBOLO,

W MARCHIROND, SARA

MARTINEZ, MATTHEW

MCCLOUD, BUTCHMORETTI, FRANKIE

NELSON, JEANNE NELSON,

DAVID ORYILL, JUDY

OURADA, TY P, STEVE

PEART, MAJIL PEART,

NICOLE PETERSEN,JENNIFER SHERLOCK,BLAINE SUORLAND, KELLYTUCKER, NICKY TUCKER,KEETON TUCKER,

CHRISTINE TURNER, R

WAYNE ULIS, MARK

VICKERY, MARGIE VICKERY,

STANLEY WEBON

"Insist" you keep the transmission lines out of the wooded areas & river bottoms and go with the already existing route or 

the "GREEN" route (feasible alternative). 

NoThPre
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100544 CASSIA COUNTY 

GATEWAY WEST TASK FORCE, POWER COUNTY TASK FORCE 

Chapter 1 Section 3.3.3 -- 1-10 through 1-13 -- [blank] -- DJB for Power County Task Force -- This Comment is on the role WECC separation criteria plays and should play in the EIS. On numerous occasions throughout the DEIS, the proponents 

refer to WECC separation criteria, including using it as a negative comment on Power County’s proposed Segment 5E. The 

proponents’ use of this criteria is inconsistent. For example the proponents indicate that WECC separation criteria can be waived for the final five towers coming into a substation. In addition, Segment 6, admittedly does not even come close to 

meeting the WECC separation criteria, and yet the proponents have no concern about that. The factors that go into creating the WECC separation criteria are not absent any more in Segment 6 than they are in 

Segment 5 or 7, and yet the proponents ignore Segment 6. 

As 

towbuibel

 WECC recently has proposed revising their separation standards. One of the reasons that WECC has proposed this revision is 

that “these requirements create significant hardship for environmental siting/permitting.” WECC report. The WECC comments 

concerning common corridors noted the hardship. They hinder development of renewable energy resources. In fact, perhaps 

in response to Gateway, the Drafting Team noted that “project developers for many projects, which are currently in the siting 

and permitting stage of development, are finding that they cannot place an additional line in an existing transmission corridor

due to the more stringent system performance requirements placed on facilities in order to comply with the WECC criteria. However, it is difficult to convince Federal and State land management agencies that independent corridors are needed to achieve maximum transfer capabilities for the projects.” The WECC proposal notes that the reason for the span length requirement is the possibility of an airplane dragging a 

conductor from one circuit to another circuit on a separate tower. WECC notes “The Drafting Team believes that this is an extremely low probability event and practically impossible. Designing a system for this very low probability event by treating 

the two circuits as if they are on the same tower is not appropriate.” Furthermore the draft modification notes that transmission structures are designed to crumple, not topple. 

The Drafting Team also notes that the concerns about fire are overstated. “The time between common outages as a result of 

fire varies, depending upon the rate the fire advances. Often transmission operators have time to reduce transfers even 

though the fire is moving at a rapid rate, because they are notified of the fire in the area. The time delay between outages caused by fire, and the advance preparation that is likely for fire, reduces the severity of the multiple circuit outages when there are separate towers.” Although WECC has not officially modified their separation criteria, it is obvious that finally some common sense is being 

suggested, and that modification is imminent. The same must be true in Gateway West, an absolute rule of WECC separation criteria rejecting a proposed route is not appropriate. As previously noted, it is the duty of the proponents to use common sense in constructing their system and convince WECC that their common sense is far more productive in generating reliability than some hard, fast and inflexible rules. 

Idaho Power and Rocky Mountain Power are both members of WECC. Power and Cassia County suggest that the process in 

this case should be the complete analysis of a route or a segment based upon that individual analysis without hiding behind 

some inflexible rule. If the analysis is that a proposed segment is superior or a reasonably viable alternative, then it should be 

the job of WECC, through Idaho Power and Rocky Mountain Power, to accept that analysis as the best overall result. WECC 

separation criteria can be modified, amended or waived based upon specific facts. That should be the rule of the proponents, 

and not the impacted parties. SUGGESTED CHANGE: As previously noted on other comments, any reference to WECC separation criteria should be 

eliminated from the DEIS, and any decisions or even arguments made on behalf of that criteria should be rejected or 

reevaluated. As noted, and now realized by WECC, WECC separation criteria is often inapplicable and ridiculously inflexible. The routes in the DEIS must be individually analyzed on their own merits, and not simply rejected by some distant and irrelevant standard. As an example, if Segment 5E were analyzed under a common sense evaluation, the separation criteria would not apply. Therefore Power and Cassia Counties request that any references to WECC separation criteria playing a role 

in route analysis be eliminated. 

Ad
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100544 CASSIA COUNTY 

GATEWAY WEST TASK FORCE, POWER COUNTY TASK FORCE (cont.) 

The same is true concerning the comment that the substation would be prohibitively expensive. No figures, analysis or data were ever given and no analysis ever completed concerning that statement. As the BLM and Tetra Tech are well aware, the 

Borah substation is the goal for many proposed transmission line projects, not just Gateway. Idaho Power has told the Power County Planning and Zoning Commission that their recent upgrades to Borah had nothing to do with Gateway, and that if 

Gateway were to come into Borah, the entire Borah substation would have to be doubled in size with new transformers, capacitors and other equipment. As it is going to have to be built from the ground up in any case, we should be able to analyze

those costs. That alone should provide the basis to analyze the expense and other considerations to the location of the substation. Suggested remedy: Study the suggestion and answer the question as to why existing transmission corridors could not be used. In addition it is requested that an explanation be provided as to why Tetra Tech rejected the request to move Borah. It is not appropriate for a simple conclusion to reject a suggestion. Shine the public light on the costs of having a substation at a

place other than Borah explained so that it can be analyzed and criticized, if appropriate. 

The summobe havpoiProreaBLana

 Chapter 1 Section 3.4 -- 1-13 -- [blank] -- [blank] -- This Section concerns the purpose of the Gateway West proposed action.

The stated purpose is to provide for the delivery of up to 3000 megawatts of the service area of the proponents, and possibly 

other markets. The DEIS then states Idaho Power’s prediction for peak load growth is based upon their 2009 IRP. The 2011 IRP substantially decreases the forecast load growth from the 2009 IRP and generally negates any reference that there will be a need for power from the Gateway West project to serve Idaho Power customers. In fact at the hearings on the 2011 IRP, 

Idaho Power states that Gateway West is not needed as a power source in Idaho Power’s plan, for at least the next ten years 

and maybe longer. At those hearings Idaho Power admitted that any planning beyond 10 years is purely an academic exercise and not based upon any reasonable forecast. Therefore the question is obvious, why go through this entire process when 

there is no way to know if it will be needed, or that the Gateway West line will ever be built? 1.2.4 goes on to state that Gateway West would be used to transport electricity from where it is generated in Wyoming to where it is needed, mostly 

Idaho and Utah. The Idaho Power IRP establishes that it is not needed in Idaho and therefore the Populus to Hemmingway 

section is unnecessary for Idaho Power’s service area. Populus to Ben Lomond has already been completed and Populus 

East to Jim Bridger is not addressed by the Idaho Power IRP. SUGGESTED CHANGE: The section concerning the stated purpose to provide delivery of power to Idaho Power customers should be eliminated and the need for the Gateway West project by Idaho Power seriously questioned. This entire idea and section needs to be reanalyzed in light of Idaho Power’s 2011 plan. 

AdCh

 Chapter 2 -- 85-86 -- [blank] -- [blank] -- The DEIS contains the following language on these pages “The question was raised 

by Power and Cassia Counties about why Segment 7 could not be routed along the existing transmission corridor between 

Populus and Midpoint and why the substation at Borah could not be relocated for more orderly land use development in Power County.” Tetra Tech noted that they removed this alternative from study because “it would not meet the reliability criteria” and that 

relocation of the substation would be prohibitively expensive. Power and Cassia Counties submit that the same analysis concerning WECC separation criteria would be appropriate here. The proponents have a series of existing transmission lines, in various sizes. They have publicly stated they never want to 

take transmission lines out of service, or combine the voltages into a larger one, they just build the larger one and add on to

the corridor. To then use WECC separation criteria to prevent them from continuing in their own corridor is not proper 

environmental planning, it is not proper economic planning or proper land use. The fact that WECC is revising their separation 

criteria, and noting that many of the bases for that criteria really are academic or theoretical only should give the BLM and 

Tetra Tech a basis to go beyond the simple statement of “it would not meet the reliability criteria” and actually analyze why that request was rejected. Those transmission towers and transmission line will essentially be in place forever, at least for 50 – 80 

years. Another 6 months to analyze that alternative is completely appropriate. 

WE

100545 BOISE METRO 

CHAMBER OF COMMERCE

Within the Boise Metro Chamber's Energy Resources Policy, the Chamber supports the development of additional electrical infrastructure projects to meet the area's energy needs and to accomodate economic development. This includes implementation of plans which specify necessary transmission facilities.The Boise Metro Chamber supports the proposed 

route for the Gateway West Transmision Line Project

Yo
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100548 CASSIA COUNTY 

GATEWAY WEST TASK FORCE, POWER COUNTY TASK FORCE 

Proponents Purpose and Need For The Project. These comments are with regards to Pages 1-7 through 1-9, and 1-13 of the 

DEIS. These comments are submitted from Power County Idaho and Cassia County Idaho, Cooperating Agencies on the Gateway West Draft Environmental Impact Analysis. The DEIS provides that Idaho Power has submitted a purpose and need for the project. Much of that Purpose and Need is based upon Idaho Power's 2009 Integrated Resource Plan (IRP) concerning projections for demand for electricity. 

Idaho Power has submitted documents to the BLM indicating that their purpose and need for this project is largely based upon 

their analysis of demand for electricity estimated in 2007 through 2009. At the time of submission of this information, Idaho Power was operating under the 2009 IRP. Power and Cassia County believe that many of the assumptions used by Idaho Power to justify this extremely expensive project are faulty, and those assumptions are not likely and have not proven true 

since the 2009 IRP. The 2011 IRP, issued by Idaho Power in June of 2011 specifically states that their current "average system load forecast is 

lower than the 2009 IRP average system load forecast in all years of the forecast." There are several reasons for this lower 

forecast, including assumptions of federal carbon legislation that proved to be faulty, assumptions about the economic and housing recovery which have not occurred and the anticipated commercial demand for power, which has also not occurred. In 

addition Idaho Power has, on its own, added natural gas peaking plants and is currently building the Langely Gulch Plant, 

which will provide an on demand peaking capacity of 300 megawatts. Furthermore the cost of wind energy, upon which the Gateway West Project is based, has been very publically criticized by Idaho Power, who basically claim that they do not want 

to pay for and do not need any wind energy. Idaho Power has announced that with the completion of the Hemingway/Boardman Transmission Line, that Idaho Power will be able to purchase additional peaking power and thus complete their ability to supply anticipated demand, for at least the next ten years. The 2011 IRP discussed the Gateway West Project, and now has placed that project as a possibility long into the future, to be reconsidered again in the year 2021. The near term 10 year plan does not even discuss the Gateway West Project. Thus things have changed greatly, and the Counties submit that the Proponents’ Purpose and Need for the project has essentially disappeared 

Ad1. 

 In addition to this questionable background, the fact is that no entity has approved or agreed with the Proponents’ “Purpose 

and Need.” Other portions of the DEIS refer to that. For example, Chapter 2, Page 185(2.8.5) has the Proponents objecting to 

alternative 5E because that alternative ostensibly would not meet the separation criteria “established as part of the Project 

Purpose and Need.” Although the WECC separation criteria will be addressed in another comment, for the Proponent to rely upon an established 

“purpose and need” is misleading and incorrect. Almost the same argument could be made to any alternative proposed, that the proponents’ disagree with it because they do not want it, and therefore it does not meet their established “Purpose and Need.” The Idaho Public Utilities Commission does not get involved in projects such as this, prior to the project being commenced, without a specific request from the regulated utility. That request has not been made. Thus the only governmental entity reviewing the Purpose and Need is the BLM in this EIS 

Ad

 Much of the electricity supplied for Gateway West will come from coal fired power plants in Eastern Wyoming. Considering that

the market for much of this energy will be the Desert Southwest, it is not energy efficient for coal generated electricity to travel thousands of miles to its ultimate destination. Thermal generation is likely a better alternative as it should be available closer to 

the needed market 

The pro

 The Counties suggest that the entire Purpose and Need Section sited be revised to reflect that there is not a need for 

additional electrical service to Idaho Power or Rocky Mountain Power customers in Idaho to be served by this project. The 

section should reflect the possible revisitation of that purpose and need in an additional ten years. The section would also reflect the fact that the questioned need for wind energy, as well as the economics of wind energy make it less likely that this 

project will be needed to serve any customers in Idaho. 

Yoinfo

 The DEIS reports that Power County expressed concern about GPS interference. The Proponents’ response was that they do 

not track reports of interference, but they have not received any specific reported instances of interference. This is not 

accurate. Cassia County and Power County both had public hearings at which many representatives of the Proponents were present, when specific instances of GPS Interference with tractor navigation systems and irrigation systems were explained by 

the persons affected. Representatives of Idaho Power specifically spoke with witnesses at those hearings about the instances 

of interference both with irrigation systems and with tractor navigation systems. Not only did individual land owners testify, representatives of irrigation companies testified about their reports, and their attempts to correct or repair damage. Cassia County will supply the specific testimony as they recorded their hearing 

Trathe wayea
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100548 CASSIA COUNTY 

GATEWAY WEST TASK FORCE, POWER COUNTY TASK FORCE (cont.) 

Either TetraTech or Idaho Power then asserted, in the DEIS, a 2001 and a 2002 study to indicate, essentially, that the reports 

of interference were incorrect or inaccurate. GPS has evolved greatly since 2001 and 2002, and those studies, on their face, are not relevant to 2011. This is a serious enough problem and potentially of great concern, that it is essential that the EIS just not reflect the line from 

the Proponents. For example, the fact that the Proponents contend that they have never received any specific instances of 

interference is indicative of their attitude toward this problem. Further they cannot say that they have not received any specific 

instances of interference if they, by their own admission, do not track those reports. 

A study commissioned by the Electric Power Research Institute, by its very structure, will favor the power companies 

Stragrby Ba

(DCPa

 Power County requests that TetraTech retain an independent expert to specifically conduct studies, and speak with the 

witnesses, to investigate this problem, and have the EIS based upon real experience. The numerous people who testified to Idaho Power about the very problems they experienced with those systems, under transmission lines, was not falsified or made up. That was actual experience. It is not appropriate just to dismiss this as unknown complaints. The EIS should require remedial steps be required to prevent interference and eliminate it as a problem to those affected 

At thireincin t

 This is a comment on and in support of Power County’s proposed segment 5C and 5E for the Northern Gateway West line to 

Boise. This comment addresses the statement on Page 2-185 of the DEIS, Volume 1A. That statement indicates that Power 

County’s proposed 5E would not meet the separation criteria Idaho Power established as part of the Project Purpose and Need. That Purpose and Need is generally discussed in Chapter 1.3.3.3. Power County adopted 5E as the official designated corridor that Power County would allow a transmission line to be located. Power County carefully analyzed the WECC separation criteria given the particular circumstances of Alternative 5E and the connection to the Borah substation. Power County had rejected the WECC separation criteria as being unreasonable and 

unworkable. Power County firmly believes that Alternative 5E completely complies, through experience and judgment, with the 

goals of system reliability. Power County accepted the reasoning as to that route and designated it as the official corridor, authorized by the Idaho Land 

Use Planning Act. Idaho Power has commented that our proposed 5E would not meet WECC separation or reliability criteria. Power County 

completely rejects the comment that the proponents established WECC separation criteria as part of the project purpose and 

need. As explained in the comments submitted by Power and Cassia County to section 1.3, the Counties do not accept the project purpose and need, and note that no one has considered that “established.” The Idaho Public Utilities Commission has not agreed with Idaho Power’s statement of purpose and need. In general, Idaho Power states that WECC would allow close proximity to other transmission lines heading toward a substation, for a maximum of five towers. Power County does not believe that any of the reasons for separation criteria magically disappear for those final five towers, but can suddenly 

reappear beyond tower 5. Judgment and analysis are needed, not inflexible rules. 

AdWE

 Power County does not accept the WECC analysis in this instance. ... WECC and Idaho Power cannot logically justify 

objecting to this separation distance in this instance. In fact the entire Gateway West Transmission line splits between Segment 5 and Segment 7, establishing hundreds of miles of separation distance between 5E and Section 7I 

Suggested remedy: remove the second sentence from paragraph 5 on page 2-185. In addition, remove any reference to 

WECC separation criteria from the entire Draft EIS, as explained above. 

Ad
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100548 CASSIA COUNTY 

GATEWAY WEST TASK FORCE, POWER COUNTY TASK FORCE (cont.) 

3.18 -- 4,13,14,15and 24 -- [blank] -- [blank] -- The termination fees for GRP and Wetland could be much different as those 

involve long term and perhaps even permanent easements being placed on the land. Thus those programs would require a separate analysis. The authors of the DEIS do not understand the damages suffered by land owners if a CRP contract is found in violation, or terminated. The whole contract can be terminated, with payments to date required to be repaid, plus interest and damages. In the affected area most of these contracts are over 10 years old, so the financial impact to a landowner could be substantial. 

On page 14 an example of an 18 acre CRP land is misstated. The land involved in that 18 acre contract went into CRP on October 5, 1998 and the calculations used were as if it were taken out of CRP on December 15, 2009. The interest rate calculated was 4.875% and the annual rental rate was $35.00 per year. The calculations for the damages are as follows: Principal payback = $7,560.00 Interest =$1,706.20 C/S + Interest = $ 409.93 Liquidated damages =$ 157.50 Total on 18 acres =$9,833.63 Obviously Tetra Tech contested the Power County Task Forces figures without understanding them, or without a basis of 

understanding the CRP program. Requested remedy is that the DEIS be revised to reflect the actual calculations, showing their accuracy and emphasizing the 

potential impact. On pages 14 and 15 of that section, the BLM just states that those damages would be mitigated by the proponents to 

negotiated terms of easements. That is not the state of the law in Idaho concerning eminent domain. Unless the BLM is 

ordering Idaho Power to compensate for full economic damages as a condition of the EIS, then the proposed response is 

meaningless 

The wit13 constanecin tliquprorem(emThe $9,facintethe is faddRestabe by easThe laneasa c

 In addition, the DEIS does not even address the SAFE program, which is a type of CRP oriented toward wildlife. To get in to 

the SAFE program a piece of land has to be within a certain distance of a sage grouse lek. Because of the emphasis on 

wildlife, and the conflicts of wildlife with power lines, ground near power lines, may not even be accepted into the SAFE program. That has the potential for economic impact on land owners. Some land owners on the proposed route have already 

signed SAFE contracts. Suggested remedy: Safe Program be explained and the EIS address potential economic losses, and require appropriate 

mitigation 

Thehowlekshasee 

 3.18-4 -- [blank] -- [blank] -- [blank] -- Contrary to what is stated in the draft, only the Conservation Reserve Program (CRP) is 

administered by the USDS-Farm Services Agency (FSA). The Grassland Reserve Program (GRP) and the Wetland Reserve 

Program (WRP) are administered by the USDA- Natural Resources Conservation Service (NRCS). The Grassland Reserve 

Program and the Wetland Reserve Program often involve permanent conservation easements. The location of a transmission structure on this type of land very likely will result in the land owner being removed from the program. In fact the regulations 

setting up those programs specifically state “the installation or relocation of new public or private utilities, including electric, 

telephone, or other communication systems over the property, is prohibited, except as provided in this provision.(emphasis 

added)” The provision goes on to state that existing structures can be repaired and maintained. Thus the task force considers 

this to be a serious issue which should be dealt with in this EIS, including under socioeconomic section, 3.4 

The and ReForprolancleCRsub

 Appendix E -- [blank] -- [blank] -- [blank] -- This comment concerns labeling photos shown in Appendix E in a way that 

identifies the valley where the photos were taken. Figure E.2-34a and E.2-34b are both labeled existing landscape of the Rockland and Arbon Valleys. Because the Rockland Valley and Arbon Valley are separated by the Deep Creek Mountains the photos of them should be labeled so the viewer can 

identify which valley they are observing. There is currently a transmission line in the Arbon Valley. Figure E. 2-34a and E. 

2034b as labeled could give the erroneous impression that there are currently transmission lines in both valleys 

The
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100548 CASSIA COUNTY 

GATEWAY WEST TASK FORCE, POWER COUNTY TASK FORCE (cont.) 

This comment concerns clarification of the visual impacts to the Public Campground located on State of Idaho land on the East Fork of Rock Creek. Recommend including recognizable features from the East Fork Campground in the photograph and 

photographic simulation for KOP 242. A photographic simulation is given from Key Observation Point 242 Segment 5 Figure E.21b. Key Observation Point 242 is very close to the public campground on the East Fork of Rock Creek. However, the general public is not likely to recognize this. It would be more informative if the Key Observation Point and Photographic Simulation showed the visual changes as observed from the East Fork Campground or from the East Fork of Rock Creek. Including the creek in the photo would be 

helpful in documenting the existing visual resource of the stream 

Adimp

 Segment 5 Populous to Borah, Figure A-7 and Figure E. 2-6 have an incorrectly labeled road. The road labeled Cutoff Rd. is 

known to the locals as Deeg Road. I have checked a topographic map and a Big Sky map of Power County and both label the road as Deeg Road 

De

 Visual KOP Locations, Segment 5-IDAHO, Figure E.2-6 shows an enlargement with KOP 241, 242, and 257. It would be much 

easier to recognize the location of these KOP’s if streams in the area were shown. There is plenty of room on this enlargement to show these additional features 

We 

 Appendix E- Large Format Figures: Difficulty determining Cultural KOP locations from the information given on the KOP 

Figures. Figures E.3-12 (page 74) to Figure E.3-50 (page 112) show Cultural Key Observation Points. It is very hard to determine the location of these KOP’s. These 38 pages do not have a reference to the route segment they are associated with. They are 

also not in numerical order according to their Key Observation Point. The small map on each page does not usually include any information that would give the general population an idea of the KOP location, There are 10 maps on page 63 (Figure E.3-1) to 73 (Figure E. 3-11) with very fine print that would have to be closely examined to determine the location of the Cultural KOP’s. Solution: More precisely label each Cultural KOP photo. 

In eeacmadis

tranisorefeloc

 3.18 -- 24 -- [blank] -- [blank] -- This section discusses aerial application of agricultural chemicals (crop spraying). On page 24 

Idaho Power reports that it has never received any complaints regarding the impact of existing transmission lines and structures on crop spraying. That is not true. Idaho Power was present at many hearings conducted by Cassia County Task 

Force and Power County Task Force where individual farmers explained the problems, and made complaints regarding the 

impact of existing transmission lines. Many farmers testified that in their fields where there are existing transmission lines, crop 

dusting services simply will not apply. A member of the Power County Task Force specifically testified that he personally 

witnessed 6 people die in 3 different accidents as a result of striking transmission lines. One of the crop dusters was a helicopter, in fact. Idaho Power certainly knew about it, as they had to come repair the transmission line. This is a huge problem for the Cooperating Agencies, and for Idaho Power to pretend that it does not exist is disingenuous. The impact will be addressed in Section 3.4, but this section of the DEIS should be corrected to show that Idaho Power has received those complaints, in this process 

Adreq

 Chapter 3.4 -- 39-43 -- [blank] -- [blank] -- This section of the DEIS addresses socioeconomic impacts and particularly impacts 

to land owners for economic losses from their land. The DEIS notes that Power County submitted substantial estimates of the 

potential economic impact of the project on agricultural operations in Power and Cassia Counties. These comments will address Tetra Tech’s responses to those analysis. It is initially noted that once those analysis were given from Power and 

Cassia County to Tetra Tech, Tetra Tech did not contact Power County, did not ask for any explanation or assistance, and did 

not consult with Power County concerning their figures or analysis 

Sevaddinfo

 The DEIS lists 5 ways that the project could affect net earnings from crop land. The cooperating counties believe that this list 

does not come close to summarizing the potential economic damage. Power County noted that many additional potential 

problems would affect net earnings as well. Substantial information was given to the BLM that the presence of transmission 

structures in or near irrigated crop land could result in serious problems with attempted aerial application of agricultural 

chemicals. Aviation companies would or could refuse to aerially apply agricultural chemicals, thus requiring those chemicals to

be applied by ground equipment. Such application destroys 9-11% of the crop field, because of the presence of farming 

equipment in the field all the crops are growing, thus ruining those crops. In addition those methods are less effective. The 

cost and slowness of ground application also reduces net earnings. There are instances when the crop fields are too wet for 

ground application and aerial application is the only option. A pest infestation may require immediate attention, and the lack of aerial application could cause an entire field to be lost. In addition, this lack of aerial application could also allow an infestation to spread to neighboring fields, causing a wide-spread epidemic. This is a very serious problem that cannot be dismissed by 

the company saying “they have not received any complaints about aerial application.” 

As to aAs the revpreCo
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100548 CASSIA COUNTY 

GATEWAY WEST TASK FORCE, POWER COUNTY TASK FORCE (cont.) 

Many land owners testified about the problems with equipment steering systems in the presence of high voltage transmission 

towers. Modern farming techniques require extreme precision from farming equipment, which could be damaged or destroyed 

by the proposed project. The close margins in modern farming require land to be efficiently used, agricultural chemicals to be 

precisely applied, and waste to be eliminated. All of those goals are directly impacted by the project and thus resulting 

economic losses to the land owners. 

As relaDEAg

disimpand 

 The Tetra Tech analysis simply relied upon average cash rent paid for crop land, and presumed the minimal amount of crop 

land impacted by a project will be less than Power Counties estimates. This is a superficial analysis which does not deal with the reality of agriculture in Power and Cassia Counties. A transmission towers or a series of towers in a field could effectively 

render that entire field non productive. To take a section out of a field, and presume that the farmer can efficiently and 

effectively farm around that impacted section ignores reality. The proponent does not guarantee that they will not place 

transmission towers inside an irrigated field, and in fact their history is that those towers will be wherever the proponent wants them, regardless of impact 

The Wyproby by doeEstDEFECo

 The estimates for disturbance used by the task force were based upon actual experience, many members of our task force 

deal with high voltage transmission lines, including the presence of a 345kv line through the center of Pleasant Valley. Thus 

Power County estimates were based upon real experience, and not some distant analysis 

Noagrcon

 The estimates for disturbance used by the task force were based upon actual experience, many members of our task force 

deal with high voltage transmission lines, including the presence of a 345kv line through the center of Pleasant Valley. The 

Power County estimates were based upon real experience, and not some distant analysis. Tetra Tech seems to attempt to discredit this historical and actual analysis. Tetra Tech disputed, without any basis, the fact that crop dusters would refuse to 

apply chemicals in or near fields with 185 foot high voltage transmission towers. Similarly apparently Tetra Tech believes that

center pivot irrigation systems will work around towers 

As the che3.43.1disagrcon

 Tetra Tech then goes on to rely upon an analysis done by Hydro Solutions Inc. to dispute Power Counties figures. An analysis 

of that Hydro Solutions Inc. report shows that it is so far removed to be irrelevant. 

That analysis was done for the Montana Alberta Tie power line (MATL), based upon a 2007 study. The Hydro Solutions 

analysis dealt only with spring wheat in the Great Falls to Cutback Montana area and actually only dealt with the experience of

1 farmer. The model was a 230kv line which would use either single monopole structures of 21 inches in diameter or H frames, 60 feet tall that do not require concrete foundations, and use 2-18 inch diameter poles. The Gateway West Project for segments 5 and 7 will use 500kv lattice towers that would be from 160-190 feet tall. Each tower would require a 20 foot deep rebar enforced concrete foundation. The width of the overhang, simply under the tower, is 162 1⁄2 

feet wide. The total foot print of the concrete base for the tower structure is 50 feet by 50 feet, or 2500 square feet. The MATL 

structure footprints were 385 square feet for the H pole and 141 square feet for the monopole. The Gateway West footprints dwarf those upon which the MATL study was based, yet Tetra Tech tries to use that study to 

make an analysis with the Gateway West Project. Not only is it obviously inappropriate, there are further problems to be 

addressed. The Hydro Solutions analysis did not even deal with irrigated crops. In fact, on page 14 of that analysis, the conclusion was 

that “all care should be taken to not place structures in a sprinkler irrigated field due to the additional costs of having to break 

apart a wheel line to move it past a pole, and the cost of disrupting a pivot from making a complete revolution. These costs 

have not been addressed in the alternative analysis because each field will have a unique situation to calculate.” 

The this DEresHyCosimDEcomCoalsconapp

 Aerial application costs were not addressed. Neither were problems with GPS and auto steer, as the MATL analysis assumed 

that “technology will figure that out.” 

Thithecon
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100548 CASSIA COUNTY 

GATEWAY WEST TASK FORCE, POWER COUNTY TASK FORCE (cont.) 

The Gateway EIS should not be a case of assuming a rental rate for irrigated or non-irrigated crop land, presuming a minimal disturbance by that footprint, and then just relating damage to the loss of that footprint 

The Wyproby by doe

EstDEFECo

 Furthermore the EIS concludes that the proponents would negotiate damage related issues during the easement acquisition 

process. No support is given for this statement, and certainly it does not appear that the BLM will require that element of 

negotiation. It would be welcome 

CoProparSe

 Under Chapter 2.7, the proponents have no proposed mitigation measures for socioeconomic impacts. Thi

bec

 Suggested change: Tetra Tech should be required to provide an independent economic analysis specific to Power and Cassia 

Counties. Tetra Tech should be required to meet with the affected land owners and the Power County Task Force to understand and further analyze those entities estimates as to losses. The MATL project should not even be mentioned, as it is 

irrelevant, based upon the facts. The DEIS should not go forward until this important element, socioeconomic impacts, is fully and properly addressed. 

The BLanaForpre

100549 LINDA OTTE, SHELL 

ROBERTSON 

completely against Segment 1E Yo

Selist det

 Building transmission lines for wind energy, which is more expensive and less reliable to the consumer, is an incorrect 

principle 

No

 Your current compensation formula does not take into account future values and income. We will not be fairly compensated for 

the loss of use of agriculture lands during construction, the loss of those lands from production due to roads and towers with 

pads, and the loss future values. 

NoSta

 #3. Your one time payments mean that we will lose the largest percentage of your payment in taxes No

Sta

#4. You do not compensate for loss of view-shed. That is forever lost to us No

Sta

#5. We have spoken with our neighbors for a 50 mile radius. The only ones who are interested in developing wind farms are 

those in the middle of the sage grouse core area. They are forbidden by law to do so. So to rape and pillage our ranch, when no one in our area wants or can have a wind farm, is the ultimate of incorrect principles, especially considering that we live in 

America

SeAlteana

#6. To push this transmission line through faster as the request of President, to try to increase his approval ratings is also an 

incorrect principle.

Onind

#7. You can't even access our area all winter, unless you plan to fly in to each pad and tower with a helicopter. And most daysin the winter, the winds are so bad, you can't even do that!

Noof Adet
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter 

Number 

Organizations/ 

Individuals Comment 

100566 366th FIGHTER 

WING MOUNTAIN HOME AIR FORCE BASE 

We seek additional consideration of planning and mitigation measures which would address potential safety issues involving the transect of the project across the Jarbidge Military Operating Area (MOA) as well as restricted air space (R 3202) contained within the Jarbidge MOA and located over and adjoining the Sailor Creek Range, an air to ground training facility. The Jarbidge MOA is authorized for military training operations to a floor of 100 feet above ground level. The R 3202 restrict 

area is authorized for military flight operations to ground surface. The following recommendations are consistent with the following Public Health and Safety IOP measure contained as Item 1 on page B-12 of the ROD: "An electricity transmission 

project shall be planned by the applicant to comply with FAA regulations, including lighting regulations, and to avoid potential 

safety issues associated with proximity to airports, miliary bases or training areas, or landing strips." The following recommended mitigation measures identified by the 366 FW would address potential flight safety issues associated with the proposed project; - Recommend burying or using 100' towers in the portion of the proposed segment between approximately MP 46 and 57 to acccomodate flight safety considerations as this portion is within the Jarbidge MOA. - Recommend burying or using 100' towers in the portion of the proposed segment between approximately 46 and 57 and MP 57 and 90 to accomodate 

flight safety considerations as this portion is adjacent to the Jarbidge MOA and Saylor Creek restricted airspace structures. -

Recommend burying the portion of the proposed routing between approximately MP 57 and 90 and 90 to 97 to accomodate flight safety considerations as this portion is within the Saylor Creek restricted airspace in the northwest corner. - Recommend 

on any tower structures built within 5 miles of the Jarbidge or Saylor Creek airspace elements that Night Vision Goggle (NVG) LED obstruction lights be installed that comply with Aviator Night Vision Imaging Systems (ANVIS) technology which is the 

current military standard sensing infrared (IR) light in the 600 to 900 nanometer (nm) wavelength range. - Recommend that at 

the points where the key microwave paths between Blue Butte and the Hagerman site, and between Blue Butte and Mountain Home AFB cross the Gateway West transmission infrastructure, that they be mitigated by burial if they are not already, by 

recommendation.

NoJar

Recommend for any support structures built within 5 miles of the Jarbidge MOA or Saylor Creek Restricted Area (R-3202), 

they be constructed from tubular steel rather than lattice structures to minimize raptor nesting opportunities, thus reducing the 

bird strike hazard in and around these airspace elements. Steel lattice structures provide increased nesting and perching 

opportunities for raptors. 

NoJar

The 366 FW also requests the following correction within the EIS; the notation (Postema 2010) from paragraph 1, on page 2-

10 needs to be corrected in that this guidance was received from an Idaho Air National Guard. The consultation referred to was conducted with the 366 FW Operations Support Squadron (OSS/OSOA), the managing entity for the affected training areas. 

NoJar

100573 NATIONAL 

AUDUBON SOCIETY

There is a alternative route to be proposed going south from Burley (?) through the Goose Creek drainage to the Nevada 

border that is still in the planning stage and there is no details and/or maps available at this time. There are no plans at this 

time to have a meeting concerning Gateway in Twin Falls, Idaho. As local chapter Prairie Falcon Audubon's Conservation 

Chairpersonin Twin Falls, Idaho, I brought up the fact there is a established 640,000 acre National Audubon International Important Bird Area (IBA), the "South Hills" in the Gateway project area in Cassia and Twin Falls counties in southern Idaho. I

am sending you a map of the IBA I drew up by mail. I am not sure which side of the Goose Creek Reservoir the IBA's east 

boundary is on and I do not want to mislead you as I don't have that information. Colleen Moulton <colleen.moulton@idfg.idaho.gov> is our IBA coordinator for Idaho. She is with the Idaho Fish and Game, their office number 

is (208) 334-3700. She will be able to answer any question you may have about the South Hills IBA. If you have any questions 

that I can help you with please let me know.

Info

add
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS Sage-grouse Addendum Comment Response Table 

Letter # Owner Comment 100614 US GEOLOGICAL SURVEY,JAMES F 

DEVINE,BRENDA JOHNSON,GARY LECAIN 

Pg. 14: The Addendum to the DEIS identifies several important variables affecting suitability of sage-grohabitats, but does not include variables and information available in the more recent publication of Wisdal 2011. Wisdom et al (2011) compared habitat in extant and extirpated populations of sage grouse. The variables associated with extirpation were: “sagebrush area (Artemisia spp.); elevation; distance to transmission lines; distance to cellular towers; and land ownership. Mean distance to electric transmissiolines was 2 times farther in occupied range than in extirpated range.” We suggest that these variables aadditional information be included in the discussion and analysis. Wisdom, M. J., C. W. Meinke, S. T. Knick, and M. A. Schroeder, 2011, Factors associated with extirpatio

Sage-Grouse, published in Greater Sage-Grouse: ecology and conservation of a landscape species and habitats, S. T. Knick and J. W. Connelly (editors) Studies in Avian Biology, vol. 38, pp. 451-472, UniversCalifornia Press, Berkeley, CA. 

100615 IDAHO CONSERVATION LEAGUE, THE 

WILDERNESS SOCIETY, WYOMING OUTDOOR COUNCIL, NATURAL RESOURCES DEFENSE COUNCIL, NATIONAL AUDUBON SOCIETY, WYOMING, WESTERN RESOURCE ADVOCATES, NEVADA WILDERNESS PROJECT, DEFENDERS OF WILDLIFE, OREGON NATURAL DESERT ASSOCIATION, CENTER FOR NATIVE ECOSYSTEMS, GREATER YELLOWSTONE COALITION, NATIONAL AUDUBON SOCIETY, COLORADO, SIERRA CLUB, BARBARA COZZENS, NADA CULVER, GARY GRAHAM, JENEANE HARTER, ERIN LIEBERMAN, MATT LITTLE, HELEN O'SHEA, SOPHIE OSBORN, JOSH POLLOCK, LARA ROZZELL, BRIAN A RUTLEDGE, CATHERINE SEMCER, KEN STROM 

While BLM and the U.S. Fish and Wildlife Service (FWS) have acknowledged the need for specific mod

to address sage-grouse impacts from Gateway West, and have attempted to address this using the HEAHSM methods as currently proposed are not based on the best available science and do not address cumulative and indirect effects to the extent needed to be set forth as a standard framework for future projects. We believe that the HSM model as currently proposed contains serious flaws, and recommend BLM instead adopt an existing greater sage-grouse habitat model created by USGS for the Wyoming Ba

Ecoregional Assessment. This comprehensive analysis employed sage-grouse habitat use data gathereacross the ecoregion to model relative sage-grouse habitat use vs. availability, selecting the best habitapredictors from a large set of candidates using objective methods, incorporating indirect effects and scawhen estimating habitat quality, and making use of improved habitat predictors using readily available dTo ensure BLM moves forward with an HEA that provides the most accurate assessment of impacts on Grouse, the agency should rely on the USGS model to estimate habitat services; this model represents most complete and current habitat suitability analysis for the species. 

 We believe the results of the proposed Gateway West HSM model must be objectively evaluated by an 

independent set of experts using this peer-reviewed, data-based model as the standard. 

 Under the Data Quality Act, federal agencies are required to use information that is of high quality and th

objective, useful, and verifiable by others. (Footnote 1). Agencies must also use “sound statistical and 

research” methods. (Footnote 2). Similarly, under the National Environmental Policy Act 

(NEPA), BLM must not only “insure that environmental information is available to public officials and citizbefore decisions are made and before actions are taken” but also “information must be of high quality.” 4C.F.R. § 1500.1(b). Overall, “[a]ccurate scientific analysis, expert agency comments, and public scrutiny 

essential to implementing NEPA.” Id. Consequently, if model outputs are significantly different based on 

review, the WBEA model should be substituted for the proposed HSM model to assess habitat services 

areas impacted by Gateway West as well as areas proposed for offsite mitigation. 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100615 IDAHO CONSERVATION LEAGUE, THE 

WILDERNESS SOCIETY, WYOMING OUTDOOR COUNCIL, NATURAL RESOURCES DEFENSE COUNCIL, NATIONAL AUDUBON SOCIETY, WYOMING, WESTERN RESOURCE ADVOCATES, NEVADA WILDERNESS PROJECT, DEFENDERS OF WILDLIFE, OREGON NATURAL DESERT ASSOCIATION, CENTER FOR NATIVE ECOSYSTEMS, GREATER YELLOWSTONE COALITION, NATIONAL AUDUBON SOCIETY, COLORADO, SIERRA CLUB, BARBARA COZZENS, NADA CULVER, GARY GRAHAM, JENEANE HARTER, ERIN LIEBERMAN, MATT LITTLE, HELEN O'SHEA, SOPHIE OSBORN, JOSH POLLOCK, LARA ROZZELL, BRIAN A RUTLEDGE, CATHERINE SEMCER, KEN STROM (cont.) 

In order for the quantitative assessment and related compensatory replacement of habitat services to be effective, the following objectives must be met: 1. Ensure that variation in sage-grouse habitat value is accurately reflected by the HSM model, including cumulative and indirect effects of development on habitat. These elements are not explicitly incorporatethe proposed HSM. 2. Ensure that lost habitat services in high-quality sage-grouse habitat are replaced by habitat services ihigh-quality sage-grouse habitat, rather than by large areas of lower-quality habitat in need of significant 

restoration. Replacement of habitat services should balance habitat quality and quantity to optimize miti

and maximize conservation benefit. 3. Ensure that the measures used for mitigation actually represent a gain to sage-grouse that will offset 

impacts to sage-grouse, rather than incorrectly characterizing actions that the BLM is already required to complete (i.e. post-fire stabilization and restoration) as compensatory mitigation actions, as is proposed HEA. 4. Ensure that conservation easements counted as compensatory mitigation are also clearly a gain to sagrouse that offsets negative impacts on sage-grouse, rather than merely a continuation of use of existinhabitat. 5. Ensure that conservation easements for the species are acquired and maintained as long as transmislines and structures are present on the landscape, not just during the estimated 100 year period when awithin the ROW are recovering from disturbance. Since there is no evidence that sage-grouse will re-octhese areas in close proximity to power lines and associated structures, they should be treated as a permanent loss of sage-grouse habitat. 6. Clearly define the habitat services lost and replaced. 7. Clearly describe the time frames and risks of failure for habitat restoration efforts. 

 Although the scoring system was based on a fairly thorough literature review and a consensus based 

process, albeit with a restricted set of stakeholders, due to its structure it lacks scientific defensibility and to provide an open, transparent, and scientifically defensible study design to quantify lost habitat serviceare very concerned that the structure of this scoring system, which sums ordinal ranks as if they had a mathematical relationship with habitat quality, violates basic assumptions of measurement theory (Robe

1984), has a structure that grossly undervalues high quality habitat, and will lead to inadequate mitigatiorefinement of this type of model structure is found in the FWS Habitat Suitability Index (HSI) models, wh

can be downloaded from the USGS National Wetlands Research Center Digital Library (http://www.nwrc.usgs.gov/wdb/pub/hsi/hsiintro.htm). These models are based on a set of continuous 

mathematical functions scaled from zero to one that rank habitat based on field measurements. These 

models are more quantitative in structure than the current HSM model, and often based on extensive research and analysis, but they are still judgment models not directly based on modeling observed sage

grouse habitat use, and as a result the webpage above states that The models should be viewed as hypotheses of species-habitat relationships rather than statements of proven cause and effect relationsh

Their value is to serve as a basis for improved decision-making and increased understanding of habitat relationships because they specify hypotheses of habitat relationships that can be tested and improved. statement above underscores a fundamental problem of expert opinion-based models; however wellformulated, they only allow the consequences of assumptions about species habitat preferences to be 

explored since they are not based on an evaluation of actual occupancy data. There is no basis to statis

evaluate - The strength of the relationship between each predictor and probability of habitat use - Interabetween predictors (e.g. sagebrush patch size, % cover, and canopy height in the proposed HSM modeChanges in the power of predictors when aggregated at different scales - Uncertainty associated with moutput - The predictive power of competing predictors and competing models Objective evaluation of the 

above is critical to ensure that variation in sage-grouse habitat value, including indirect effects of develo

on habitat, is accurately reflected, and that this analytical process is impartial and unbiased. Getting as cas possible to the “proven cause and effect relationships” mentioned in the quote above requires data-dmodels that use the best available science to derive these relationships based on observed habitat use 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100615 IDAHO CONSERVATION LEAGUE, THE 

WILDERNESS SOCIETY, WYOMING OUTDOOR COUNCIL, NATURAL RESOURCES DEFENSE COUNCIL, NATIONAL AUDUBON SOCIETY, WYOMING, WESTERN RESOURCE ADVOCATES, NEVADA WILDERNESS PROJECT, DEFENDERS OF WILDLIFE, OREGON NATURAL DESERT ASSOCIATION, CENTER FOR NATIVE ECOSYSTEMS, GREATER YELLOWSTONE COALITION, NATIONAL AUDUBON SOCIETY, COLORADO, SIERRA CLUB, BARBARA COZZENS, NADA CULVER, GARY GRAHAM, JENEANE HARTER, ERIN LIEBERMAN, MATT LITTLE, HELEN O'SHEA, SOPHIE OSBORN, JOSH POLLOCK, LARA ROZZELL, BRIAN A RUTLEDGE, CATHERINE SEMCER, KEN STROM (cont.) 

Numerous approaches exist to fit habitat models to observed wildlife habitat use, ranging in data requireand predictive power from envelope or profile models that accept presence-only data to statistical, likelih

based models using more detailed wildlife use surveys. The latter models provide the strongest inferenc

habitat without collecting detailed demographic data, and can be used to predict occupancy probability, occupancy to habitat quality, and objectively evaluate the criteria listed above. Fortunately, a rigorous an

driven modeling effort for sage-grouse was just released, with multiple predictive layers available for dowthat evaluate both brooding and general habitat for the majority of the GatewayWest ROW. The general

ordered logistic regression-based model used to analyze greater sage-grouse habitat for the Wyoming B

Ecoregional Assessment by Hanser et al (2011) can legitimately predict habitat quality in unmodeled are

estimate the relative effects of habitat predictors, estimate direct as well as indirect effects on habitat quand characterize uncertainty in all these estimates. 3. Review of Recommended WBEA Sage-Grouse H

Model The analysis framework for all species modeled as part of the WBEA (Leu et al. 2011) was based 

stratified sampling design that allocated sampling effort for species occurrence or abundance equally intstrata across two gradients; vegetation as represented by the Normalized Difference Vegetation Index 

(reference), and human land use based on the cumulative spatial effect areas of communication towersand inactive oil/gas wells, interstate highways, irrigation channels, power lines, railroads, secondary roa

highways, agricultural land, and human industrial/urban/exurban/rural impact zones. The effect area of ehuman land use was based on the latest published studies; for example the effect area of transmission with respect to sage-grouse was based on Robel et al. (2004), a six year study on lesser prairie-chicken 

found - 90% of 187 nesting prairie chickens avoided power lines by 1,181 feet (+/- 197 feet) - 95% of 18

prairie chicken telemetry locations were absent from areas within 2,067 feet (+/- 131 feet) of power lines 

study design allows synergistic responses of species to human development as well as habitat change taccounted for. Defining the response to habitat for all species modeled in the WBEA involved hierarchicspatial sampling within strata using species-specific survey protocols. For greater sage-grouse transect-sage-grouse pellet-count surveys (Boyce 1981, Hanser and Knick 2011, Schroeder and Vander Haegen 

were the straightforward and robust survey method used to assess relative abundance at both dispersed and brood sites. Surveys performed for three months each summer for two years on 487-7.29 hectare sblocks were sufficient to build models for multiple sagebrush species valid across suitable habitat within 133,321 square mile study area. Similar to the proposed Gateway West HSM, previous sage-grouse resregarding distribution, habitat requirements, disturbance responses, seasonal movements, and so on we

incorporated into the process of defining predictors. The WBEA sage-grouse habitat model recommend

below used similar public domain data sources as the proposed HSM model, but created predictors from data that have more power to discriminate patterns in the data. This is true for two reasons. First, rather using distances to the nearest feature as in the proposed HSM model, the WBEA model uses the densitfeatures within a set of different radii and tests each as a predictor in the model, allowing species habitaoccupancy patterns to dictate the impact of cumulative disturbance and the effect over which this is influSimilarly, instead of using unmodified average slope within a pixel as a predictor, for example, the WBEmodel uses indices of topography that represents variation in topography throughout a pixel in a more ro

and comprehensive way. Second, the WBEA sage-grouse model uses variables in their continuous form 

than classing them arbitrarily based on researcher preconceptions with additional iterations to fine tune perceived fit to the data. The manipulation of the data in the proposed HSM model does not take full advof information content, and moreover introduces hidden bias that impairs interpretation of the data. The 

sage-grouse model selection process (Hanser et al. 2011) involved a rigorous statistical analysis of altemodels using objective scientific methods such as model evaluation and multi-model inference using AkInformation Criterion (Burnham and Anderson 2004), as well as a formal model validation and adjustmeprocess to evaluate performance. The predictors in the final models are shown below. Note that most predictors are generated with reference to a spatial neighborhood around the cell in order to explicitly mthe spatial influence of predictors [Table - see PDF] As described in Hanser et al. (2011), the WBEA sag

grouse model went through rigorous validation, and was approximately 75% accurate based on these analyses. Although validating a non-statistical judgment-based model is less clear cut, the scores from tproposed Gateway West HSM model could be qualitatively assessed by comparing them with occurrence/abundance probabilities from the WBEA model as well as by using methods for comparison wildlife field data (Soniat and Brody 1988, Haxton et al. 2008, Tirpak et al. 2009). Whatever methods are the evaluation process must include experts from academia and NGOs as well as agency personnel, anoutcome of this process must be open for public comment and review. Changes in existing model structhabitat predictors, and suggestions for additional habitat predictors should be determined based on this evaluation process; at this time, suggestions are premature. 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100615 IDAHO CONSERVATION LEAGUE, THE 

WILDERNESS SOCIETY, WYOMING OUTDOOR COUNCIL, NATURAL RESOURCES DEFENSE COUNCIL, NATIONAL AUDUBON SOCIETY, WYOMING, WESTERN RESOURCE ADVOCATES, NEVADA WILDERNESS PROJECT, DEFENDERS OF WILDLIFE, OREGON NATURAL DESERT ASSOCIATION, CENTER FOR NATIVE ECOSYSTEMS, GREATER YELLOWSTONE COALITION, NATIONAL AUDUBON SOCIETY, COLORADO, SIERRA CLUB, BARBARA COZZENS, NADA CULVER, GARY GRAHAM, JENEANE HARTER, ERIN LIEBERMAN, MATT LITTLE, HELEN O'SHEA, SOPHIE OSBORN, JOSH POLLOCK, LARA ROZZELL, BRIAN A RUTLEDGE, CATHERINE SEMCER, KEN STROM (cont.) 

The Habitat Equivalency Analysis for Gateway West is an unprecedented use of this process for a transmission line project, and is only the third application of HEA for terrestrial public lands energy projeDefensible results for this and future projects are predicated on an evaluation of habitat services that accounts for species habitat preferences in the most comprehensive manner possible. As discussed abothe existing HSM model is a judgment or consequence model that implements a set of assumptions abowhat is thought to be good habitat for a species, not a data-driven model that represents the most compobjective, and current habitat suitability analysis for the species. It is unclear if the modeling process as described to date is sufficient. If the results of the proposed HEA model are not consistent with those of more comprehensive Wyoming Basin Ecoregional Assessment greater sage-grouse model, based on a thorough and inclusive validation process, the HSM evaluation must be revisited using the WBEA modeassess habitat for the eastern part of the line and performing additional analyses as needed to extend th

WBEA model to the western portion of the line. 

100616 WESTERN WATERSHEDS, KATIE FITE The meeting concerned the simplistic and limited habitat model being used to develop mitigation for the 

controversial Gateway transmission line and roadnetwork. There are many assumptions being made in model, often with very little data to back them up. BLM and consultants admitted that in many areas affeby proposed routes, it was not known how sage-grouse actually used the landscape in fulfilling their seaneeds. The most information was known about general vegetation (GAP type info) and other general database info. New powerline route-specific data collection occurred primarily in association with the PoCompany’s initial Proposed Route only. For the various alternatives, including the very harmful alternativ

Segment 7 and some other areas, basic site-specific information on habitats and populations has not becollected. Databases, instead, are being used. Nowhere, under any alternative route, does there appear have been adequate data collected on how local sage-grouse populations use the landscape over the cof the year; on what constitutes a local population; on how degraded or fragmented habitat already is so there can be an understanding of how large an effect punching a powerline and new road network throu

area actually would have; or how crucial and irreplaceable any habitat fragmented by Gateway really is, 

So several years into this proposal, there is still no way to gauge to the full impact of this massive powerand roading disturbance on sage-grouse or other wildlife populations. WHY has BLM sat back and allowthis to progress so far and new routes to be proposed all the time – without collecting vital site-specific don the birds upfront? Is it because of the Wyoming view that there are lots of sage-grouse out there – thlosses outside Wyoming’s own Core Areas - are no big deal? 

 Why hasn’t Idaho BLM better and more effectively stood up for Idaho sage-grouse values in this proces

now understand there is yet another variation on segment 7 being proposed near the BLM-Forest boundthe general area of Goose Creek –that would rip apart sagebrush habitats instead of staying in disturbed 

areas. 

 Across much of this region - BLM doesn’t know for sure if wintering habitat exists - as in many areas of 

Segment 7 alternatives since there haven’t been studies done on the birds. So it has no way of knowing 

severe impacts will be to affected populations of sage-grouse. It does not know how the birds use the 

landscape, and it has not identified the affected population, or the degree to which it would really be imp--- or the likelihood of a local population being extirpated as the multiple adverse impacts of the powerlinroad network, and likely increased development linked to the line all play out. So the simplistic lek and n

based habitat modeling Gateway is doing has little to no meaning for mitigation purposes. PLUS there is nothing in the modeling that is being done, or in this process, to identify areas where impacts cannot be 

mitigated – and thus mitigation by avoidance must be chosen. What good is a model when it can’t even determine irreplaceable habitats? 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100616 WESTERN WATERSHEDS, KATIE FITE (cont.) I specifically asked if the model being used provided for an understanding of situations where mitigation 

really not possible – for example, if the project would lead to the decline and loss of a local population. I told No. And the Project Lead said that “since sage-grouse are a wide-ranging bird and are the same acbroad area, we assume that mitigation somewhere else will make up for impacts from any part of the rou

BLM prefers mitigation close by – but this is not necessary. 

 Mitigation by Avoidance Is Ignored 

When questioned if the model would identify habitats where impacts could not be mitigated, we were tol

BLM “No”. Even considering irreplaceability of habitats is summarily shunted aside. 

 Model Does Not Account for Magnitudes of Difference in Adverse Impact Among Various Variables 

The model places many variables on an equal level. If sagebrush is bladed off in one area, this is compl

destruction of the habitat. But it is “only” counted as one of many variables. So cataclysmic habitat loss 

occur – but the scale and sweep of the loss is not represented in the findings of the model. The model is only dealing with direct effects. The adverse impacts of the massive powerline and road ne

disturbance Footprint is much greater. There is no effort made with this poor model to address indirect a

cumulative impacts. 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100616 WESTERN WATERSHEDS, KATIE FITE (cont.) Model Fails To Take Into Account Grazing and Other Degradation 

The Model assumes - as one of its variables – that adequate grass cover is present if there is 15-25% c

of grass. But this does not reflect the adequacy of the height of the grass. BLM or the Forest or a private 

owner may annually graze the grass down to 2 inches stubble height, which does not provide for adequ

nesting. So habitat modeled as being acceptable receives extensive abuse. As another example, the mo

does not differentiate between crested wheatgrass and native bunchgrass cover – even though crested wheatgrass is not as suitable for nesting. It is also not clear how the model takes into account presence cheatgrass in understories, and risk of expansion with disturbance. The model does NOT take into account grazing disturbance of habitats during nesting season, and the adverse impacts of this disturbance on grouse – thus rendering the habitat less suitable for nesting. Recstudies show significant disturbances by livestock. Such effects may be amplified with the presence of powerlines and other elevated structures and disturbance that provide abundant predator advantages – top of a habitat that lacks necessary nest screening cover from visual and scent predators, as well as m

lack sufficient winter sagebrush habitat 9percent sagebrush cover writes off – i.e. provides a lower value 

habitat with denser sagebrush – despite this being the habitat required by wintering sage-grouse. The malso does the same with bunchgrass cover – if there is greater than 15% bunchgrass cover – the model places this in the same category as habtats with 2-55 bunchgrass cover. This too is madness. It is illustrates how the model – by applying some general idealized sage-grouse habitat components – dnot take into account the needs of other sagebrush species – like pygmy rabbit that rely on dense sagebor sage-grouse requirements in winter or other periods. 

 Model Is Based Far Too Much on Leks without Incorporating Other Critical Habitats 

The model does not address the full needs of sage-grouse – a landscape bird. The model is greatly flaw

that it relies far too much on the lek-based Core Model idea. 

The BLM and consultants admitted at the meeting that they don’t have data on how the birds that would impacted actually use the landscape in many instances. Thus, there can really be no valid “modeling” conducted. Many of the vegetation characteristics of the model are based on nesting needs – not winter habitat nee

not later brood rearing, not habitat needed for connectivity. The model is not designed to reflect the full s

habitat needs. 

 There Is No Effort to Look at Local Populations and Their Use of Habitats in Landscape 

It is critical to look at the landscape used by a population of birds to understand how severe direct, indireand cumulative impacts of a project will be. It is also necessary to look at the number of birds in 

thepopulation, and the trajectory of the population. This model does not do this. The model does not ide

populations, or threats facing populations – so that all cumulative impacts can be understood. 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100616 WESTERN WATERSHEDS, KATIE FITE (cont.) Model Is Based on “Compensating” for Direct Bulldozed disturbance Only The model is based on direct 

disturbance only. This is a huge flaw – since the complete Footprint and indirect and cumulative impacts often much greater that direct disturbance alone. And the direct disturbance sets in motion cascading ev– like cheatgrass invasion, with subsequent invasion into surrounding grazed landscapes. We are greatconcerned that the whole NTT and the IMs are also based n only considering the direct disturbance of th

hugely damaging linear disturbances. Is that the case? So then 3 or 5% or whatever of a landscape cou

torn up by a battery of linear disturbances – yet the total directly disturbed land would still fall within the 5% allowed for a “Core” area? If so, such a an approach is utterly worthless for protecting or conserving mitigating in sagebrush wild lands 

 We are very concerned that no real new information wasprovided at the meeting. It is clear that a 

supplemental EIS is needed. That requires sound and complete baseline information. It requires greatly expanding the criteria examined for understanding habitats and populations, and the impacts of this masproject on them. Why won’t BLM require that the Utilities take the time to collect solid baseline data on aaffected landscapes, populations use of these landscapes, and the quality of the habitat –including factoin livestock degradation and other impacts and disturbances? 

100617 WESTERN WATERSHEDS,KATIE FITE There is no way to mitigate the impacts of the southern and more remote routes on sagebrush habitats. 

powerline must follow the existing disturbed area routes and be bundled with existing lines to the maximextent. 

 We also increasingly believe this extremely expensive line is not needed, and this project should be 

abandoned. 

100618 BIODIVERSITY CONSERVATION ALLIANCE, 

DUANE SHORT 

While we agree that different restrictions are appropriate for different breeding densities and quality of sgrouse habitat, we are troubled by the patchwork of varying protections planned according to land owneBCA joins other conservation groups in recommending that stipulations and protective measures be sele

for maximum protection of sage-grouse and habitat, and applied across landownerships. 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100618 BIODIVERSITY CONSERVATION ALLIANCE, 

DUANE SHORT (cont.) 

We are concerned that the HEA and the scientific backing specifically related to how certain variables adesigned in the analysis are inadequate in scope and substance. Our overriding concern regarding the implementation and follow-through of the HEA is that the loss of quality native habitat may be never truly 

replaced even with the best mitigation efforts. No new land is being made within the sage grouse histori

current ranges. We can agree on this. Loss of suitable sage grouse habitat is the principal problem at haHow, facing this reality does the BLM and the project proponents propose to mitigate, on a “no net habitquality and quantity loss” basis the impacts of the proposed project? We have yet to receive a clear and comprehensive answer to this question. 

 Human disturbance associated with machinery or heavy equipment is one of the top threats to sage gro

The Task Force Recommendation asserts that essential public services should be located at least 1 km active leks. Power lines provide perch sites for raptors, therefore it is recommended that these structure

located at least 3 km to 4 km from seasonal habitats ( see p. 12). We strongly recommend structures be 

buried and/or be modified to prevent their use as raptor perchs. Rocky Mountain Power’s requirement o

surface occupancy within 0.25 miles of a lek has been repeatedly identified as having no scientific validi

[emphasis added]. The 0.6 mile buffer proposed elsewhere in the HEA is a minor improvement, but larg

buffers are recommended in the body of scientific literature. Expanded buffer zones are essential if the Bureau is to ensure protections of sage grouse. Consistent with scientific literature and conservation assessments of the sage grouse, we also recommend that construction occurs outside March 15 to Junof the calendar year. 

 The BLM should consult closely with the U.S. Fish and Wildlife Service, Idaho Department of Fish and G

and the Local Sage-grouse Working Group to determine appropriate measures to avoid, minimize and mitigate impacts. 

 Given the considerations of year-round habitat use and known impacts of human activity on sage-grous

populations, mitigation will be needed for disturbance to sagebrush near lekking areas; disturbance and 

of sagebrush and native forbs used for early brood-rearing; and disturbance and impacts to hydrologic 

function of wet areas used for early to late brood-rearing. A conservative estimate for the nesting and brrearing area affected will include buffers with radii of 6.2 miles around known leks. Baseline mitigation specifics could model a mitigation template recently created for the Lesser Prairie Chicken, a ground-nespecies facing similar threats (Horton et al. 2010). 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100618 BIODIVERSITY CONSERVATION ALLIANCE, 

DUANE SHORT (cont.) 

Transmission Line Location/Redundancy The BLM must prioritize routes that avoid sage grouse habitat

need for two separate lines in Idaho should be more clearly explained to the public. We question the neetwo separate lines, particularly given the use of outdated IRP projections. Updated demand projections 

FEIS may suggest that a single line is sufficient. We request the BLM more closely examine the proposeseparation between transmission lines. Most recent recognition of the environmental impacts of transmisline corridors should be considered by the Bureau. Science is suggesting that separation between lines, particularly where resource conflicts are high, may be smaller than earlier studies would suggest. Sufficivalidation of the need for two separate lines in Idaho still appears lacking in our view 

 Mitigation must be designed to offset all adverse impacts from habitat loss or avoidance caused by the 

construction and operation of this proposed transmission line project. 

 Additionally, the Service asserts that sage-grouse could be impacted through a direct loss of habitat and 

human activity (especially during construction periods). Indirect loss of habitat associated with “connecteand “similar” projects in the vicinity of the Gateway West project area must also be considered. All ongoand proposed projects must be considered as “cumulative” effects are analyzed. 

 We request that the BLM analyze the location of the project with respect to maps produced by the Idaho 

Grouse Task Force which distinguish Core Habitat, Important Habitat and General Habitat Zones. These 

three zones are important for permanent and seasonal habitat, as well as connectivity 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100618 BIODIVERSITY CONSERVATION ALLIANCE, 

DUANE SHORT (cont.) 

Additionally, transmission lines are listed under “infrastructure” developments in the Idaho Sage-Grouse Force Recommendations and thus recommendations for this type of development should pertain to this 

project. The ISGTF recommends sage-grouse conservation measures to be implemented over the next year period to accomplish the following: - Conserve existing sage-grouse habitat; - Increase the resiliencthe habitat to disturbances, such as fire, and reduce existing habitat fragmentation; and - Provide sagegrouse the opportunity to increase and expand its population in Idaho Specific to the areas which have bdistinguished at any degree of sage grouse habitat zone, the Task Force recommends that infrastructurdevelopment be limited to projects that meet the requirements of the CHZ for incremental upgrades of 

existing infrastructure. These recommendations are listed as: - Limit the consideration of infrastructure development to only those projects with valid existing rights or incremental upgrade/capacity increase of existing essential developments (e.g., projects for increasing the capacity of an existing transmission linImpacts of such projects would be limited to an existing footprint with only an incremental expansion (approximately a 50 percent or less increase in footprint or size for existing confined development appro

for the particular industry) and associated impacts. - Limiting development to these types of projects will substantially constrain the level of new disturbance by limiting impacts to previously disturbed or affecteareas, minimize proliferation of roads and decrease opportunities for invasive weeds to colonize, while providing significant public benefit. - Timing of construction would be designed to minimize impacts to sagrouse during critical times of their life cycle (e.g., breeding, wintering). Other BMPs would be required t

minimize impacts. 

 Routes which transit the least amount of area known as sage-grouse habitat should be given the greate

consideration. Routes which cross the Core Habitat Zone (CHZ) for sage-grouse as determined by the Isage-grouse Task Force should be avoided entirely. These areas are vital to maintaining and promoting grouse populations. Areas determined as CHZ should be protected against habitat fragmentation, such known to occur due to the construction and existence of transmission lines. 

 The Biodiversity Conservation Alliance is highly concerned regarding some of the alternative routes prop

for the Gateway West Transmission line through Idaho. We are particularly concerned with routes that w

impact sage-grouse habitat. We continue to request that lines crossing the Wyoming-Idaho border are loto avoid all types of sage grouse habitat mentioned earlier in these comments as well as sensitive wildlif

habitats that are prevalent in the border area. Migrating waterfowl and raptors, in particular, are placed aby the installation of power lines in this sensitive area. 

 BCA supports the following comments produced locally by the Idaho Conservation League. Segment 9: 

Cedar Hill to Hemingway The Idaho Conservation League is strongly opposed to Alternative Segment 9to the fragmentation and introduction of predator perches into the relatively undisturbed sage-grouse ha

in Owyhee County. This route would transverse 49.3 miles of important and core sage-grouse habitat. TOwyhee County Sage-grouse Local Working Group and the Owyhee County Commissioners have also 

opposed this route 

 Alternative 9D is the Idaho Conservation League’s most preferred route. Additional[l]y, this route is prefe

by the Owyhee County Task Force. This route would have minimal effects on raptors because it is immediately adjacent to an existing 138-kV transmission line through the Snake River Birds of Prey Nat

Conservation Area (SRBOPNCA). Studies have shown that raptors can exist happily and sometimes beneficially alongside transmission lines. [footnote 1] By paralleling the existing line through the SRBOPthis route would eliminate the need for new roads. While other areas of the SRBOPNCA are not suitable new transmission projects (as explained for the proposed routing of segment 8) this area is the best optavoiding sage-grouse habitat in Owyhee County. It also offers the ability for reclamation activities to take place along the previously disturbed area. However, the route proposed in Alternative 9D must be reconsidered where it crosses the Snake River Canyon. Studies conducted on the compatibility of rapto

transmission lines have not considered the [e]ffects of lines on cliff habitat. At the present time Alternativcrosses the Snake River at the confluence of the Snake River and Sinker Creek. This crossing point con

with both ecological and scenic interest. It is a pristine riparian area and important cliff habitat for raptors 

the National Conservation Area. This alternative should be rerouted to cross by the Swan Falls Dam. Th

alteration to 9D would work to conserve both important sage-grouse and raptor habitat 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100618 BIODIVERSITY CONSERVATION ALLIANCE, 

DUANE SHORT (cont.) 

Segment 8: Midpoint to Hemingway Segment 8 is problematic because it is incompatible with the objectof managing the SRBOPNCA. While raptors have been shown to successfully exist alongside transmisslines, the additional stress this line would put on raptor habitat is inconsistent with the management of thSRBOPNCA. This is due to the 1,500 ft. distance that would be required between the existing 500-kV lin

the proposed line. Such a distance means that a new road would have to be built in the NCA for the line

construction and maintenance. This road would run through shrub habitat causing further habitat fragmentation for raptor prey and ultimately affecting raptor predation. The Idaho Conservation League believes that the need for two separate transmission lines through Idaho should be reconsidered. If two 

must be built it is suggested that Segment 8 does not transit the SRBOPNCA. Alternatives 8B, C, and D should then be used to avoid the NCA while also allowing for Segment 9 to avoid crossing the Snake RiCanyon near Sinker Creek. 

 The Idaho Conservation League’s preferred route for Segment 7 is the currently proposed option. This r

is the best option for avoiding important and core sage-grouse habitat. 

 The Idaho Conservation League strongly opposes Segments 7H, I, and J. These routes would all impac

significant areas of sage-grouse habitat, totaling more than 328 miles of the CHZ. Segments 7I and J arparticular concern as they would impact the highest breeding density class (top 25%) for sage-grouse. Troute is unacceptable for proper sage-grouse management. Additionally, various pieces of routes 7H, I, are not in conformance with the Cassia and Wells RMP’s, the Twin Falls MFP, or the Sawtooth Forest P

 Segments 7A and 7B are not in conformance with the Malad MFP. Segment 7A would cross a roadless 

with wilderness characteristics. 

100619 ROBYN C THOMPSON I have reviewed the folloiwng Tables in the Addendum to the DEIS: Table 1, Table 2, Table 3, Table 4, T

5, Table 6, Table 7, Table 8, and Table 9. I have also reviewed map E.11-3 Key Habitat and Restoration Areas, Idaho Volume 3 Large Format Appendicies (Appendicies E). This comment is regarding Segment 9: Owyhee County. In 100% of the above mentioned data Alternatihas significantly less impact on sage grouse than the Proposed Route or Alternative 9E. Please chose Alternative 9D with the recent changes agreed upon by the Owyhee County Task Force, the Owyhee Co

Commissioners and the Boise Office Distrct BLM in the FEIS. 

100620 STATE OF WYOMING, OFFICE OF STATE 

LANDS AND INVESTMENTS 

In the original draft EIS, approximately 9% of the land necessary for the proposed routes impacted state lands (33,208 parcel acres with a direct easement encumbrance of 4,000 acres within the Wyoming corAccording to the captioned addendum, it now appears that the new proposed routes will impact 28,700 tparcel acres with direct easement encumbrance of approximately 3,450 acres. 

Notwithstanding the federal NEPA process or federal approvals, for actions that affect state trust lands, 

project proponent must comply with the Rules and Regulations adopted by the Board of Land Commiss

in accordance with W.S. 36-2-107 and W. S. 36-9-118. The project proponent must procure an easeme

special use lease, pursuant to the Rules and Regulations of the Board of Land Commissioners in place time of application. Any other facility, road or other use of state trust land would have to be appropriately 

permitted as well. As a supplement to the current easement process and forms, the applicant will also brequired to provide satisfactory responses to the following questions upon initial submission to OSLI: 1. Description of all adjacent uses undertaken on the parcel in question and the surrounding parcels; 2. Description of opportunities to route the proposed easement within an existing easement or use; and, 3. Opportunity to reroute the proposed easement use off of state trust lands (and description of the effecadjacent landowners, if any). 

 Although it appears that the proposed route adjustments comply with the Governor's Executive Order 20

Greater Sage-Grouse Core Area Protection, we would like to reiterate that siting of any sort on state truslands will require the proponent to comply with the Governor's Executive Order 2011-5. 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100621 LINCOLN COUNTY, BOARD OF 

COMMISSIONERS (WY), KENT CONNELLY, JONATHAN TEICHERT 

OMITTED FACTORS Predation The sage grouse is found in areas where there are numerous predatorsincluding coyotes, foxes, skunks, raccoons, ravens, eagles, hawks, and magpies, to name a few. Preda

populations are at an all time high in the western states. While research has acknowledged the role of ra

on nesting success, the Analysis entirely omits the role of predators in direct sage grouse mortality. DOI 

BLM’s support for predator control has been hostile or lukewarm at best. The omission of predators promthe erroneous conclusions regarding the impacts of land uses on sage grouse numbers. West Nile Virus attention on the sage grouse and its allegedly dwindling populations coincided with the spread of West N

Virus into Wyoming. It was first documented in 1999 and well-established by 2002. Most avian deaths aunreported because the remains are eaten by scavengers. It is, thus, impossible to determine the numb

sage grouse affected by West Nile Virus. But given the virtual elimination of all song birds for the initial y

that West Nile Virus infested urban areas and the number of human infections, it is reasonable to assumWest Nile Virus exacted a similar toll on sage grouse. Western Wyoming also suffered severe drought dthe same time frame which reduced insects necessary to feed the brood during the nest rearing phase. combined impacts of disease and drought depressed bird numbers during the same time period and it is that other estimates, which attribute bird population declines to land uses err by omitting the cumulative 

effects of predation, disease, and drought. Hunting The sage grouse is still hunted in most of the affecte

states. The fact that the Analysis omits this important cause of mortality, while focusing on potential colliwith guide wires, underscores the deficiencies in the analysis to date. Even if BLM does not regulate hu

it must still acknowledge mortality due to hunting. Similarly, wing counts are still used by wildlife agencieestimate bird populations. They are said to be more accurate than the lek counts, which apply only to observed males. The Analysis focuses on lek counts while not even mentioning wing counts as the 

supplemental source of bird populations. The disconnect is also illustrated by its treatment of livestock gas a disturbance while hunting is exempt from all recognition of impact. Hunting is a direct disturbance atypically includes loud noises and motor vehicles. And yet this activity is entirely ignored in the Analysis. 

of Big Game Animals on Herbivory The Analysis conspicuously omit the role of big game on herbivory. Ta material flaw, because big game populations have increased significantly over the last several decade

Wyoming, elk numbers continue to increase, often in or overlapping with sage grouse habitat areas. Elk an ungulate with the same or very similar habitat impacts as cattle. In addition, deer and antelope, which browsers that will consume sage brush, have also increased. Livestock and elk do not eat the sage brusonly forbs and grasses that might form an understory for the larger sage brush. Omission of the browser

impacts, their numbers and the issue of direct competition must be rectified. Role of Soils in Potential SaBrush Habitat The Addendum omits entirely the variation of soils and relation of soils to sage brush hab

By way of example, much of southwestern Wyoming has alkaline or sodic soils, which will not support sabrush. This and other limitations will apply throughout the Rocky Mountain and western rangelands. No should be written without a Level III analysis of the soils. 

 Premise of Historic Range 

The premise of sage grouse having lost most or all of its historic habitat is deeply flawed. The assumptioignores recorded history, soils, and climate. The BLM lacks any data for the historical rangeg and it grosoverstates original sage grouse populations and range. BLM has a legal obligation to use actual data and records, not just take for granted the unsupported hyperbole found in the USFWS finding. 

 Livestock grazing is described as a diffuse disturbance while ignoring other equally direct and diffuse 

disturbances, including wild horses, wildlife herbivory and hunting. It is difficult to understand the basis o

criteria used. In most western states, livestock numbers have declined while wildlife and predator numbehave increased. The Analysis need to develop the data regarding big game, wild horses, and livestock numbers for each project area. The premise that livestock grazing as currently managed adversely affects sage grouse or sage grouse 

habitat lacks documentation. Livestock do not eat sagebrush, the winter cover and food source for sage grouse. Livestock do not directly harm sage grouse. For more than 15 years, grazing has been regulated under rangeland health standards. Virtually all opeuse a deferred or rest rotation system and do not use the rangelands year-round, unlike some wildlife anof the wild horses. 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100621 LINCOLN COUNTY, BOARD OF 

COMMISSIONERS (WY), KENT CONNELLY, JONATHAN TEICHERT 

There is no basis to withdraw public lands solely on the basis of potential impacts on sage grouse habitaadmitted, there is no reliable data supporting the premise that sage grouse numbers are declining. Indee

numbers appear to be stable or increasing. Lincoln County is also concerned about the hostility to all oil 

gas, coal, and mineral development. A number of reports only document that sage grouse leave an activsite or field. There is no research showing whether the birds relocated and no data suggesting that they as a result. Relocation should be researched, especially any adjustments made by sage grouse. Wyomihas seen an increase in energy development. Interestingly, Idaho doesn’t have a single producing gas wthe entire state, yet has reported sharper declines in population numbers than Wyoming. That coincided part with drought, West Nile Virus and high numbers of predators. Until the factors can be weighed, comand considered this rush to judgment is unwarranted. 

 The Addendum incorrectly assumes that travel is the primary vector for invasive species. In fact wind, w

and birds, all of which are present on public lands in abundance, are the primary vectors. That is not to sthat invasive species are not a significant problem. BLM authorized the use of crested wheatgrass for reclamation throughout the Rocky Mountain and Great Basin states in the 1990s. This is an invasive nonative that is virtually impossible to reduce or eradicate. Similarly, current reclamation policies have bee

ineffectual in controlling non-native species. Halogeton can be seen at most reclamation sites and often untreated. Lincoln County working as part of a group with the State of Wyoming, BLM and University of 

Wyoming has recommended steps intended to better address these invasions in the context of reclamatThe steps involve early site stabilization and use of non-native sterile seed mixes to give native plants thtime to be re-established. Reclamation expectations often fail to consider soil types and the limited productivity of Rocky Mountain soils, especially if they are sodic or alkaline. Finally, BLM needs to suppoefforts to improve rangelands by removing pinon juniper, mahogany, and other undesirable brush. The 

encroachment of these species has reduced prime sage brush habitat. Too often these projects are postponed. 

 Research Needs and Pursue Them Land management changes should not occur without important rese

issues being addressed. For example, much of the consternation focuses on lek absence in the middle drilling fields. But there is no data regarding whether the birds died or merely relocated. The failure to di

whether the sage grouse relocated is a huge gap in the knowledge base. A related question is sage grouse of reclaimed habitat. How does that differ from sage grouse use of other habitat that has been the s

of vegetation improvement projects. Do sage grouse return to a well site or field once traffic and activity die down. Certainly other wildlife return to the fields once activity levels drop off. 

 Lincoln County believes that continued management of public rangelands to meet healthy standards wil

ensure viable populations of sage grouse for decades to come. BLM should adopt the object of managin

rangeland resources and rangeland health and monitor population numbers. Then if there are changes numbers, BLM would adjust based on the factors specific to the site. 

100622 WYOMING OUTDOOR COUNCIL, SOPHIE 

OSBORN, JULIA STUBLE 

We recommend that all new transmission lines follow existing transportation and utility corridors, whenefeasible, especially if those corridors are densely used and are equally sized transmission lines with the 

proposed project. We are less inclined to support transmission line proposals that follow older, existing transmission corridors with lower voltage, or create their own, newly developed, corridors. 

 We support the route chosen for Segment 3, which largely follows existing high-voltage utility corridors a

transportation corridors. However, we are concerned about the routing of the three other Wyoming segm

of the Gateway West transmission line: Segment 1, Segment 2, and Segment 4. 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100622 WYOMING OUTDOOR COUNCIL, SOPHIE 

OSBORN, JULIA STUBLE (cont.) 

All of the feasible alternatives for Segment 1 cut across the Shirley Basin, which the Wyoming Outdoor Council has designated as one of its Heritage Landscapes. See http://www.wyomingoutdoorcouncil.org/html/what_we_do/public_lands/heritage_landscapes.shtml (pres

the Wyoming Outdoor Council Heritage Landscapes). It is our policy that energy development should nooccur in the Heritage Landscapes. We identified the Shirley Basin as an important, relatively undeveloped mixed-grass prairie and sagebru

landscape that supports abundant wildlife, including sensitive species such as golden eagles and greate

sage-grouse, big game, and the endangered black-footed ferret. We are particularly concerned with the potential impacts that the Gateway West transmission line would pose for golden eagles and greater sagrouse if it were routed through the Shirley Basin. We continue to urge the Bureau of Land Management to fully analyze a route for this transmission line twould follow I-25 from Glenrock to Cheyenne and then continue west on I-80. This route would have the 

following benefits: - Ensure that the transmission line would have very minimal negative environmental impacts across mosWyoming. - Facilitate the consolidation of an energy transmission corridor with other proposed transmission projecincluding the Wyoming-Colorado Intertie and the High Plains Express. - Support appropriately sited and sized renewable energy development in the eastern third of the state, area that has been widely acknowledged to have a “world class” wind resource. 

 As we noted in our previous comments, the Purpose and Need of a National Environmental Policy Act 

(NEPA) analysis is designed to address the purpose of the project for the BLM, not for the project propo“In determining the alternatives to be considered, the emphasis is on what is "reasonable" rather than on whether the proponent or applicant likes or is itself capable of implementing an alternative. “Reasonable alternatives include those that are practical or feasible from the technical and economic standpoint and common sense, rather than simply desirable from the standpoint of applicant.” BLM National EnvironmePolicy Act Handbook, H-1790-1 at 50 (citing the Council on Environmental Quality Forty Most Asked Questions Concerning CEQ’s NEPA Regulations, March 23, 1981). As BLM’s purpose and need for a p

like Gateway West would be to balance environmental impacts with development, a route that followed tInterstate highways is in fact feasible. Feasibility should not be solely determined by financial viability foproponent. While a project must be cost-effective, the cheapest route for the proponent may well be the 

expensive route for the citizens of Wyoming, if one calculates the invaluable resources a development c

impact. 

 The proposed route for segment 1W is concerning because of likely negative impacts to wildlife species 

Shirley Basin. Golden eagles, whose populations appear to be declining in the West (Footnote 1), are garnering increasing concern in Wyoming because of their vulnerability to collisions with wind turbines. Ware concerned about potential impacts of the Gateway West transmission line bisecting the Shirley Basibecause it could facilitate additional wind energy development in this important wildlife area, which woulplace both resident and wintering eagles at risk. Wyoming has experienced unexpectedly high levels of fatalities at operating wind farms in the last few years and the Shirley Basin supports a robust golden eapopulation that could be adversely impacted by additional transmission lines and wind energy developmthe area. Importantly, as we noted in our previous comments, if Gateway West’s increased transmission capabilities concomitantly provide for increased production, then that production must be analyzed as a “cumulative effect.” It seems likely, as capacity on Gateway West is increased between two substations without an existing power production site, that this proposal is counting on increased energy production 

area to justify or support it. This production could increase the impacts to golden eagles in the Shirley Baand this must be accounted for in the final EIS. 

 We also are concerned about the proposed Shirley Basin route because of potential increases in 

electrocution fatalities for golden eagles. Finally, we are concerned with the habitat fragmentation, anthropogenic disturbance, and increased eagle persecution that could be associated with additional 

transmission lines in the Shirley Basin area. In particular, eagles perched on power poles are highly visiand more vulnerable to human persecution, such as shooting, than those perched on less prominent na

topographical features. Given the increased hostility toward eagles in Wyoming as a result of the perceiv

threat that they pose to greater sage-grouse, which are being considered for listing under the Endanger

Species Act by the U.S. Fish and Wildlife Service, the potential for increased human persecution must btaken seriously and factored into decisions about where to route the Gateway West transmission corrido
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100622 WYOMING OUTDOOR COUNCIL, SOPHIE 

OSBORN, JULIA STUBLE (cont.) 

The proposed 1W route also concerns us because of the potential impacts to greater sage- grouse as thtransmission corridor crosses through core area sage-grouse habitat. The proposed 1W route would be 

constructed in close proximity to a significant number of occupied sage- grouse leks in this area. Althougscientific research on the effect of transmission lines on sage- grouse remains inconclusive, the proximit

the transmission line to these leks could displace grouse and lead to the increased predation by raptors 

lekking grouse as well as of hens and broods. A transmission line through this core sage-grouse habitat 

is likely to lead to increased depredation of sage-grouse nests by common ravens. The construction of plines is known to dramatically increase the availability of nest substrates for ravens (Footnote 2) with a 

concomitant increase in raven occupation and use of the surrounding habitats. Finally, the construction transmission line through this important sage-grouse core area could fragment sage-grouse habitat and facilitate the invasion of non-native plants, thereby adversely affecting local sage-grouse populations. O

than the significant wildlife concerns associated with this segment, there is also a legal concern that the 

must take into consideration. This segment follows a corridor outlined by the West-Wide Energy Corrido

established under Section 368 of the Energy Policy Act of 2005. However, the suitability of this corridor 

recently been successfully challenged in court. The recent decision in The Wilderness Society et al v. UStates Department of Interior et al. designates this corridor as “no-go” (Footnote 3) until further environm

review is concluded, particularly for sage-grouse. This conclusion and the court’s decision implicates Ga

West’s plans to use this proposed route, and makes rerouting the transmission line required. In the settl

agreement (Footnote 4) for the above-referenced lawsuit the plaintiffs identified the West-Wide Energy 

Corridor 78-255 (Footnote 5), which Gateway West’s proposed Segment 1W follows, as having “specific environmental issues” relating to “sage-grouse core area habitat.” The defendants (including BLM) agrepursue further environmental analysis of the impact of energy development along this corridor. As such, cannot approve Gateway West’s use of this corridor until the additional environmental review, ordered bcourt, has been completed. This agreement was only reached in the summer of 2012; the Gateway Wesproject must be delayed until the review is complete. Or, the BLM could analyze alternative routing for th

segment. We believe the impacts of the proposed Segment 1W route are significant, as will be shown badditional environmental review, and that therefore the BLM should abandon it and move the transmissiline corridor route to the I-25/I-80 route we have advocated. 

 Our second concern with the proposed route for the Gateway West transmission line concerns the north

section of Segment 2. Alternative 2C, which is now the proponent’s proposed route, is a baffling choice. route does not appear to follow any existing transportation or utility corridors. In the Sage-Grouse AddenBLM notes that Alternative 2C was chosen in order to bring the line into accordance with the Governor’s 

Executive Order 2011-5, page 3. However, Alternative 2C, which bisects a designated core sage-grouse 

area, has tremendous implications for sage-grouse. Not only would the route disturb a previously undist

landscape and fragment sagebrush habitat, it is also too close to numerous sage- grouse leks. Thirty-eig

leks occur within four miles of this proposed route and 155 leks occur within an eleven mile buffer of the proposed route. Addendum, Table 3 at 41. Research has shown that development impacts to sage-grou

can extend more than four miles from leks.(Footnote 6) Furthermore, 74-80 percent of female grouse mnest within four miles of the leks on which they breed. (Footnote 7) Therefore, the proposed route could adversely impact significant numbers of lekking grouse in addition to disturbing and displacing nesting females, and increasing sage- grouse predation risks. We strongly urge the BLM to reconsider this route 

given its potential impact on core area sage-grouse. Although we have previously argued that proposed 

transmission lines that must pass through designated core areas should follow the Governor’s proposed transmission corridor (as outlined in EO-2011-5), the number of leks that could be impacted by the curreproposed routing through a high-lek density core area is unacceptable. We argue for rerouting this segma less vulnerable area. Given that an existing transportation corridor lies in close proximity to the proposroute, we urge the BLM to select a route that would follow existing disturbance rather than placing large 

numbers of undisturbed sage-grouse leks at unnecessary risk by complying with the Governor’s core artransportation corridor. Other alternatives for this section would take the route into closer proximity to a transportation corridor, Highway 287, or another utility corridor. The other alternatives for this route all wimpact fewer leks than Alternative 2C. Addendum, Table 3 at 41. The BLM should develop a route that 

complies with the Governor’s EO 2011-5 while minimizing adverse impacts to sage-grouse by avoiding amany leks as possible. We do not support Alternative 2C because of the high number of sage- grouse le

implicates, and we believe that this route contradicts the conservation measures that are developed as p

BLM’s National Greater Sage-Grouse Planning Strategy. 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100622 WYOMING OUTDOOR COUNCIL, SOPHIE 

OSBORN, JULIA STUBLE (cont.) 

Our third concern for routing of this transmission line pertains to Segment 4. While we appreciate the nu

of alternatives analyzed to avoid important wildlife areas such as Seedskadee National Wildlife Refuge aCokeville Meadows National Wildlife Refuge, we urge the BLM to consider an alternative that avoids the Commissary Ridge area. The Commissary Ridge is a particularly important corridor for raptors that migr

through Wyoming. Constructing an additional and larger voltage transmission line through this area wouplace the seasonal concentration of raptors that use this area at elevated collision and electrocution riskSince raptors use the full extent of the north-south ridgeline of Commissary Ridge during the fall migratio

season, we recommend that the Gateway West transmission line avoid crossing any portion of this ridgeThis will reduce potential raptor collisions and electrocutions. Though not fully analyzed, an alternative wproposed that headed southwest from Granger, WY toward Lyman. This alternative more closely follows 

highway and interstate rights-of-way and would allow disturbance to be concentrated in an existing corri

that is already highly disturbed. This is also the high voltage transmission line corridor recommended in Record of Decision for the Kemmerer RMP revision. Land Resources Rights-of-Way and Corridors. Map Following this route would avoid and minimize the threats to raptors posed by a Commissary Ridge routby doing so, would help the proponent stay in compliance with the Migratory Bird Treaty Act and the Bal

Golden Eagle Protection Act. It is also in accordance with the guidance of the Kemmerer RMP and is therefore a preferable route to the current Alternative 4A. 

 In the event that the BLM or proponent is unwilling to reroute this segment to avoid the Commissary Rid

area, we urge the full implementation of best management practices that would protect raptors from 

electrocutions and collisions. Many of the mitigation measures proposed for Segment 4 appear to be creditable. And, because the proposed route does follow an existing transmission line, we recognize the proposed route is already disturbed, even though this existing line is of smaller voltage (and less threateto avian species) than the proposed project. Although the BLM must remain in compliance with the Governor’s EO-2011-5, it should ensure that minimum disturbance to sage-grouse is allowed in core arehabitat and conservation measures are adopted to ensure minimal impacts to sage-grouse in the proposcorridor. The use of perch deterrents, while not a panacea, also could help reduce raptor impacts on sag

grouse. We urge the BLM to require extensive pre-siting surveys to identify areas of concern for raptors 

sage-grouse. However, routing the transmission line away from Commissary Ridge would be far more 

preferable, regardless of the mitigation measures applied to this section. If the proposed section is appro

BLM must be diligent with the mitigation measures it applies to this project 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100622 WYOMING OUTDOOR COUNCIL, SOPHIE 

OSBORN, JULIA STUBLE (cont.) 

Habitat Equivalency Analysis We thank the BLM, the proponent, and other involved parties for their worconducting a sage-grouse HEA analysis for the Gateway West project. This biologically based analyticashould help inform mitigation and compensation for the project’s likely impact on greater sage-grouse 

populations along the proposed transmission corridor. We appreciate that this quantitative approach is a relatively new one for Western energy-related projects and hope that it will be used to benefit wildlife in tface of future energy development as well. Because it is a new approach, we understand that it has limitand we ask the BLM to be cognizant of these, and to treat both the analyses and the mitigation plans th

result from it as dynamic processes and documents. Given the lengthy time frame that is involved in the restoration of sagebrush habitats, the BLM should approach and manage this HEA analysis and any resmitigation and compensation plans adaptively and be open to making future refinements as new science new conservation measures become available. The HEA Should Incorporate Indirect Impacts or Provide Additional Mitigation/Compensation to Offset Presumed Indirect Impacts This HEA should result in more 

targeted and more successful mitigation for sage-grouse populations that likely will be impacted by the 

Gateway West project than would be implemented without an HEA. However, we are concerned that thi

addresses only direct impacts of the project. We view this as a significant weakness to this HEA and be

that impacts to sage-grouse will be grossly underestimated and proposed mitigation and compensation inadequate, unless some additional conservation measures are incorporated to offset indirect impacts. THEA does not address important indirect impacts such as habitat fragmentation, increased predation (on grouse by raptors and on sage-grouse nests by ravens), and habitat conversion resulting from the invasnon-native plants. Indirect impacts of energy development ultimately may exact a more severe toll on sagrouse populations than direct impacts. While direct impacts may displace or even kill grouse, indirect 

impacts may have significant long-term effects on sage-grouse productivity and recruitment, which ultimcould result in significant population declines. For example, preliminary research on the impact of wind turbines on greater sage-grouse, suggests that although females may nest adjacent to vertical structurepost-construction since the species exhibits extreme nest site fidelity, nest and brood productivity may bsignificantly lower for hens that nest close to turbines. Nests within 1 km of turbines were 94 percent molikely to fail, nests within 3 km were 83 percent more likely to fail and nests within 10 km were 53 percenmore likely to fail. Broods within 1 km of turbines were 62 percent more likely to fail, broods within 3 km 24 percent more likely to fail, and broods within 10 km were less than 1 percent more likely to fail.(Footn

Increased predation was the likely mechanism for the lower documented nest and brood success in this and while areas under transmission lines are unlikely to have the dead birds and bats that attract predat

that subsequently may depredate grouse nests in wind farms, the research certainly illustrates the signifadverse impacts that indirect effects of tall vertical structure development may have on sage-grouse populations. The HEA explains that indirect impacts such as habitat fragmentation and increased predat

are difficult to quantify and scientific research addressing these issues is limited. We concur with this assessment but urge the BLM to make additional efforts to address this concern by taking a broader looexisting research. For example, the BLM could use the increase over time in the number of nesting rave

and raptors along a new transmission line in Idaho (Footnote 9) as a starting point to document possible increases in raven and raptor occurrence and use following construction of the Gateway West line. 

Furthermore, information regarding potential correlations between raven presence and activity and grou

productivity might be gleaned through a search of scientific research on raven activity in relation to land (Footnote 10) nest predation of sage-grouse in the face of altered predator communities, (Footnote 11) 

raven nest predation rates. (Footnote 12) If likely indirect impacts cannot be quantified and included in th

Gateway West sage-grouse HEA, then additional mitigation and compensation measures should be fact

in to the analysis to offset the excluded, but doubtless significant, suite of potential indirect impacts. And note, that under the regulations governing environmental impact statements, the indirect impacts of an aand their significance, must be considered. 40 C.F.R. § 1502.16(b). The only limitation of what indirect emust be considered is that they must be “reasonably foreseeable” and the effects of a project are synonymous with its impacts. ld. §1508.8 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100622 WYOMING OUTDOOR COUNCIL, SOPHIE 

OSBORN, JULIA STUBLE (cont.) 

We appreciate the HEA’s attempt to address the indirect impacts of noise and human presence on sagegrouse that might reduce habitat services around substations and transmission lines during periods of aconstruction (HEA at 10-11), but note that these analyses do not accommodate the suite of indirect impathat likely will affect sage-grouse well beyond the construction period. As a result, we believe that the HEshould consider retaining the indirect disturbance buffers that were applied to the reduced habitat servicaround substations and around transmission lines during periods of active construction then dropped froeverything except substations and regeneration stations post-construction. Maintaining permanent indiredisturbance buffers around transmission lines might offset indirect impacts such as the increased predatpressure exacted by raptors and ravens that use these lines and their associated structures. In addition, 

“accounting” such as scoring lost habitat services from the difficult-to-quantify impacts of noise and humpresence as if they were equivalent to the impact of a secondary road as is done in the HEA might be a 

means to address indirect impacts such as increased predation, habitat fragmentation, and habitat convfrom non-native species that were not addressed in the HEA calculations. 

 Although we were surprised to see the 18-km project buffer/assessment area that is used in the DEIS 

reduced to the 9-km buffer that is used in the HEA analysis, the BLM’s arguments for doing so were not without merit. While we are not convinced that the decreased model processing time by the GIS softwara smaller buffer is sufficient argument to reduce the assessment area--under the regulations governing environmental impact statements the BLM must abide by strict requirements where it claims that needed information is incomplete or unavailable, 40 C.F.R. § 1502.22--we do recognize that scientific research oimpacts to sage- grouse beyond 9-km of development is limited and we appreciate that none of the serv

losses that were modeled (vegetation loss, noise, and human presence) extended beyond 9 km of the 

transmission line. Nevertheless, recent preliminary research on the impacts of wind turbines on sage-groin Wyoming argue for a larger assessment area than the 9-km buffer used in the Gateway West HEA. (Footnote 13) As mentioned above, nests in this study that were within 10 km of wind turbines were 53 percent more likely to fail. This preliminary finding argues for a larger assessment area in the Gateway WHEA since the indirect impact of a vertical structure in sage-grouse habitat resulted in significantly lower 

success and sage-grouse productivity as far as 10 km away from the structure. While it is not known if 

transmission poles and wind turbines have similar effects on nesting grouse, these recent findings provipersuasive evidence that indirect impacts to sage-grouse may extend beyond distances that were consi

when attempting to quantify the potential indirect impacts of the Gateway West transmission line on 

associated sage-grouse populations. Development impacts to greater sage-grouse that extend beyond also were documented by Taylor and others (2011) in Wyoming’s Powder River Basin. In examining impof energy development on sage-grouse, the researchers identified the spatial scale at which energy 

development most influences sage-grouse populations as indexed by lek counts of males. Development the greatest influence on male counts within 20 km surrounding a lek. Considering that decreased lek cocan result from decreased recruitment of young males to leks as a result of lower nest success, indirect 

impacts of development on grouse could extend as far out as 20 km from energy infrastructure and associated disturbances. While transmission impacts may not be comparable to oil and gas impacts, we nevertheless caution that indirect impacts may extend beyond the 9-km assessment area used in the 

Gateway West HEA analysis. We believe the assessment area should be extended beyond 9-km to ensmore comprehensive analysis of both direct and indirect impacts of the proposed transmission line on sa

grouse. 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100622 WYOMING OUTDOOR COUNCIL, SOPHIE 

OSBORN, JULIA STUBLE (cont.) 

We are concerned that in quantifying direct impacts, the HEA focuses only on the “construction footprintincluding the loss of all habitat services in the footprint of permanent facilities (i.e., substations, regenerastations, and transmission structure pads), but does not include the disturbance corridor that is comprisethe transmission lines. Although, it is unclear to us whether the HEA includes the line segments between transmission poles as lost habitat services during the construction period, it certainly does not do so dur

the restoration and recovery periods. We believe that this results in a significant underestimate of projec

impacts on sage-grouse. In our experience, the habitat under transmission lines is kept continuously cleof brushy vegetation to facilitate access and maintenance. As a result, the transmission corridor will reprcontinued habitat fragmentation and could precipitate unanticipated edge effects such as avoidance of ttransmission corridor. (Sagebrush obligate passerines and greater and lesser prairie chickens have shosensitivity to such edge effects). (Footnote 14) Furthermore, the transmission lines can facilitate perching by corvids and some raptors. As a result, the transmission lines will continue to exert a long-term affect on area sage-grouse populations for the life oproject. The entire transmission corridor, not just associated buildings and transmission structure pads sbe considered as directly impacting sage-grouse when quantifying impacts in the HEA. We believe that underestimated indirect impacts that the Gateway West transmission is likely to have on sage-grouse wmore than be offset by any potential overestimate of direct impacts by the inclusion of the transmission l

corridor for the life of the project. 

 Although using grazing allotment boundaries as a stand-in for fences in a GIS database appears to be a 

legitimate means of capturing the existing fences that might impact sage-grouse in the assessment areabelieve that it underestimates the presence of fences on the landscape. Using a more accurate databassupplementary database of fences is essential since fences are included in calculations of habitat qualitwell as serving as structures that can be removed or modified (with fence diverters) to mitigate for transmission impacts to sage-grouse. We believe the Wyoming Landscape Conservation Initiative may a database of fences in Wyoming. If so, the difference between the allotment boundaries and actual fen

Wyoming could possibly be used to develop a more accurate assessment of fences in Idaho. 

 In discussing the use of mitigation measures to offset the loss of sage-grouse habitat services from the 

Gateway West transmission line, the BLM states that “Within 2 km of large leks and in other high risk are(e.g., winter concentration areas, movement corridors), existing fences would be removed where practic

necessary fences would be outfitted with flight diverters.” HEA Table 6 at 13. We ask that BLM either pro

more specific information about what it believe constitutes a “large” lek or amend this mitigation measurapply to all leks. Lek sizes can vary by region and based on habitat quality. We do not think that mitigatimeasures should be entirely dependent on lek size. For example a “small” lek in a connectivity area may critically important. Likewise, the loss of one male sage-grouse at a lek with only 10 remaining males ma

more significant, since it may increase chances that this lek will be extirpated, than the loss of five males 

lek with 100 males since such a loss is unlikely to lead to lek extirpation. That said we appreciate that laleks are likely to experience higher collision rates with nearby fences and believe that the removal of fenand the application of fence diverters are vitally important mitigation measures. We simply ask that the B

determine which leks will most benefit from this type of mitigation on a case-by-case basis rather than applying this measure solely to unquantified “large” leks. 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100622 WYOMING OUTDOOR COUNCIL, SOPHIE 

OSBORN, JULIA STUBLE (cont.) 

We appreciate the BLM’s justification regarding not weighting the individual habitat variables that comprthe habitat services component of the HEA analysis. We agree that by default the sagebrush variables aappropriately weighted more heavily because there are more sagebrush related-variables than other havariables. Nevertheless, we believe that weighting the distance-to-leks variable may be warranted to proa more accurate picture of existing habitat services. The level of sage-grouse occupancy is indicative of habitat suitability (unless lag effects from new development impacts have not yet been sustained). As a 

the presence of leks should contribute more significantly to models of habitat services than, for exampledistance to fences. An alternative to using the simple additive model developed for this HEA would be to statistical analysis to develop a model that incorporates appropriately weighted habitat variables to more accurately determine habitat selection by sage-grouse and the associated value of habitat services. 

 We have ongoing concerns with the Habitat Services Metric (HSM) used by the BLM. We and other 

conservation group representatives expressed these concerns in a letter dated April 4, 2012. We incorpthat letter into these comments by this reference and attach the letter as Exhibit 3. We believe that it is imperative for BLM to subject the HEA that it is has developed to an independent group of experts for pe

review. The BLM also should validate the results of its HSM model by comparing it to results from other 

habitat suitability analyses such as the existing greater sage-grouse habitat model created by the USGS the Wyoming Basins Ecoregional Assessment. The HEA analysis and HSM model should be deemed scientifically defensible before the BLM issues a Notice to Proceed. We would note that given the ongoi

amendments to resource management plans throughout the West to accommodate sage-grouse conser

concerns, the presence of BLM’s National Technical Team for sage-grouse, many local sage-grouse implementation teams, not to mention sage-grouse experts in state wildlife agencies, there should be mexperts available for peer review. 

 The significant restoration timeline (over 100 years) necessary to recovering and restoring baseline cond

to the proposed Gateway West transmission corridor raises serious issues that need to be addressed in detail by the BLM. We are unclear who will monitor and oversee restoration efforts (BLM? the proponen

proponent contractors?) given the lengthy time frame, and who will bear the financial burden of ensuring 

restoration is proceeding apace. The division of responsibilities must be made clear in the Final EIS, and 

required in the record of decision. We also are concerned by the necessarily lengthy restoration timeline given uncertainties about future conditions. Predicted increases in drought conditions in the West as a result of ongoing and future climachange put a premium on mitigation measures that will ensure sage- grouse persistence in the short-terWhile long-term mitigation measures such as restoring impacted sagebrush habitat is critical, it should n

undertaken at the expense of sustaining and maintaining existing sage-grouse populations that are immediately impacted by the construction of the transmission line. Lengthy restoration schedules and unknown future conditions argue for an adaptive mitigation approach that continuously monitors current expected conditions and incorporates the most effective science-based methodologies for ensuring saggrouse persistence on disturbed landscapes. 

100623 KEVIN LARSON The number one thing is to stay away from the sage grouse and what little is left of there habitat. In our 

county the commissioners are all Republicans that are very anti-wildlife. 

They want to put it right thru what little is left. The obvious choice in our county is to go thru private property where there is no wildlife to displace. 

A lot of the landowners are yapping about not wanting power lines on there property, but what people hagotten used to and do not even think about is the fact that there are already hundereds of miles of existipower lines that go around each and every square mile in every county around. Another one is just that 

another power line where there are already others. Wildlife are a one time deal. 

100624 NATIONAL AUDUBON SOCIETY- PRAIRIE 

FALCON SOCIETY, JULIE RANDELL 

PFA strongly opposes all of the alternative routes proposed in the DEIS Addendum south of the Snake 

in Idaho, including the split route connecting through the proposed Cedar Hill substation. 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100624 NATIONAL AUDUBON SOCIETY- PRAIRIE 

FALCON SOCIETY, JULIE RANDELL (cont.) 

We still do not have a clear and definitive explanation from BLM, or the project proponents, for use of an

the senseless alternative routes through critical Sage-grouse and other sage-steppe obligate species' ha

in southern Idaho, including the South Hills Global IBA and possibly, the Raft River/Curlew Valley Globa

 Though the DEIS Addendum goes into great detail about mitigating the negative impacts of the project, 

know from experience that as long as overgrazing and the lack of monitoring continue on Forest and BLpublic land, restoration projects will almost always end up with irreversible and adverse impacts to the aWe believe “mitigation by avoidance” to be the best plan in all key/priority Sage-grouse habitat. 

 Disturbed areas within key/priority habitat should be rested or retired and not used to develop infrastruct

As stated in BLM's Best Management Practices (BMPs), “Place new utility developments, powerlines, pipelines, etc. in existing utility or transportation corridors”. 

 We believe BLM's preliminary and to a greater degree, Idaho Governor's task force maps trivialize and 

minimize the importance of Sage-grouse habitat in central and eastern Idaho. 

 the DEIS Addendum acknowledges direct, indirect, and cumulative impacts to Greater Sage-grouse, bu

the same time draws the conclusion that because of purpose and need, the project should proceed despthe severity of these impacts. 

 If this project is allowed to use the alternative routes throughout key/priority habitat including IBAs it sets 

precedent for new routes for other transmission lines, oil and gas and even water export. 

 The only routes through Idaho on the DEIS Addendum map that make any sense to us are the ones NO

of the Snake River crossing near Melba to Hemingway. 

100625 THE WILDERNESS SOCIETY,NATIONAL 

AUDUBON SOCIETY, DEFENDERS OF WILDLIFE, ELIZA CAVA, ALEX DAUE, DALY EDMUNDS 

Our concerns are focused on the high sensitivity of HEA-defined mitigation to error in habitat service estimates and the associated lack of rigor in the model that provides these estimates. We recommend a rigorous and impartial statistically-based analysis in place of the subjective and incomplete expert modepoint to the Wyoming Basins Ecoregional Assessment sage-grouse models as a template for the recommended approach. 

 The HEA process hinges on scaling compensation to encompass both primary and compensatory mitiga

incorporating the net present value of resources lost as well as the net future value of compensation. Th

makes the results of an HEA highly sensitive to scaling parameter values, which often aren't known with certainty, and according to Efroyemson et al. 2008, can lead to large discrepancies between HEA-definecompensation and that truly needed to offset impacts. (Footnote 3) Violations of required HEA assumptican also create substantial error. 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100625 THE WILDERNESS SOCIETY,NATIONAL 

AUDUBON SOCIETY, DEFENDERS OF WILDLIFE, ELIZA CAVA, ALEX DAUE, DALY EDMUNDS (cont.) 

...in order for the quantitative assessment and related compensatory replacement of habitat services to 

effective, the following objectives must be met: 1. Ensure that variation in sage-grouse habitat value is accurately reflected by the HSM model, including cumulative and indirect effects of development on habitat. These elements are not explicitly incorporate

the proposed HSM. 2. Ensure that lost habitat services in high-quality sage-grouse habitat are replaced by habitat services ihigh-quality sage-grouse habitat, rather than by large areas of lower-quality habitat in need of significant 

restoration. Replacement of habitat services should balance habitat quality and quantity to optimize mitiand maximize conservation benefit. 3. Ensure that the measures used for mitigation actually represent a gain to sage-grouse that will offset 

impacts to sage-grouse, rather than incorrectly characterizing actions that the BLM is already required to complete (i.e. post-fire stabilization and restoration) as compensatory mitigation actions, as is proposed HEA. 4. Ensure that conservation easements counted as compensatory mitigation are also clearly a gain to sagrouse that offsets negative impacts on sage-grouse, rather than merely a continuation of use of existinhabitat. 5. Ensure that conservation easements for the species are acquired and maintained as long as transmislines and structures are present on the landscape, not just during the estimated 100 year period when awithin the ROW are recovering from disturbance. Since there is no evidence that sage-grouse will re-octhese areas in close proximity to power lines and associated structures, they should be treated as a 

permanent loss of sage-grouse habitat. 6. Clearly define the habitat services lost and replaced. 7. Clearly describe the time frames and risks of failure for habitat restoration efforts. 

...Recommendation: use statistical models, not expert opinion-based models, to evaluate habitat service

for the Gateway West Greater Sage-Grouse HEA. 

 We support the extensive set of predictors shown in Appendix A [see original letter], as these were all 

rigorously tested for inclusion in the final WBEA roost and general use models 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100626 THE NATURE CONSERVANCY OF WYOMING, 

THE NATURE CONSERVANCY OF IDAHO, ANDREA ERICKSON QUIROZ, TONI HARDESTY 

Of greatest concern to the Conservancy is the Addendum’s barring from consideration the effects of indimpacts to sage grouse from transmission lines and tall structures due to a stated “lack of peer-reviewed 

research.” We respectfully point out that there exists a great body of evidence, including peer reviewed 

publications as well as significant additional evidence, implicating the effects of transmission lines and tastructures on sage-grouse habitat, including habitat fragmentation and habitat loss caused by behavioraavoidance of transmission corridors. We have attached a compilation of some of the research and publications on this matter, which includes guidance issued by the U.S. Fish and Wildlife Service (the Service), the Washington Department of Fish and Wildlife, and others. In particular, we point out that the Service issued a briefing paper titled “Prairie Grouse Leks and Wind Turbines: U.S. Fish and Wildlife Service Justification for a 5-Mile Buffer from Leks” (2004) which places grouse and prairie grouse in the same “prairie grouse” category, and concludes the avoidance impacts f

vertical structures to both species are the same. This guidance goes on to say that “the Service feels it iimportant to clarify that avoidance of vertical structures by grassland and sage steppe-obligate wildlife is new issue.” In light of this key finding by the Service, the justification provided for not addressing the full of long-term indirect impacts is not warranted nor grounded in best science. This matter is of most concern as it relates to the proponent’s compensatory mitigation plan. The 

compensatory mitigation plan explicitly states that its purpose is to mitigate for “known” impacts to sage 

grouse habitat. We may agree that indirect impacts are difficult to measure, but we do not agree that theexistence is in question. Again we reference you to the body of literature on this topic that is included at end of these comments. 

 The Conservancy is pleased to see that certain key elements are incorporated into the proponent’s mitig

plan. In particular, the inclusion of a no net loss goal for habitat services is appropriate. We appreciate th

effort at including other key elements such as the in lieu fee approach and the development of an Overs

Committee. Although we appreciate the proponent’s efforts at developing a compensatory mitigation plan, we believ

isolated effort will not achieve the intended results. Adequate mitigation is unlikely to be achieved by considering each infrastructure development project, and the required mitigation for that project, separatThis “one off” approach historically has resulted in a patchwork of small “mitigation offset” sites that are 

insufficient scale and connectivity to be ecologically viable, or to actually fully offset impacts over time. 

We recommend the Bureau of Land Management (BLM) address the need to focus compensatory mitig

investments from a number of projects collectively to increase the likelihood of actually achieving effectiv

and enduring mitigation of ecological impacts. The Conservancy recommends BLM and the proponents develop a regional mitigation plan to prioritize and how mitigation investments should be made to ensure the highest return on investment. The Servic12-month finding concisely articulates this point: “Meaningful restoration for greater sage-grouse requirelandscape, watershed, or eco-regional scale context rather than individual, unconnected efforts.” 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100626 THE NATURE CONSERVANCY OF WYOMING, 

THE NATURE CONSERVANCY OF IDAHO, ANDREA ERICKSON QUIROZ, TONI HARDESTY 

(cont.) 

We are concerned that the HEA Model does not accurately reflect the variation in sage-grouse habitat vOur specific comments on the model are: a. The model assigns linear scores for each category, sums these ordinal variables to generate a single and then treats these scores as meaningful in a mathematical sense, when in fact we don’t know that relationship. In order for the model to be truly meaningful, the BLM must provide evidence that there is a mathematical relationship between these categories and conditions in the field. If the BLM wants to use framework as a quantitative model for assessing habitat quality, it must provide the mathematical relationships between these categories, and relate them to the published literature. b. It appears to us that the model is artificially inflating habitat quality since the minimum value for many 

habitat variables is equal to one. This further undervalues the best quality habitat by increasing scores fopoorest quality sites. As an alternative, using a logarithmic scale would increase the value of high quality habitat (e.g. 100) relative to medium quality habitat (e.g. 10) or low quality habitat (e.g. 1). 

c. The model ignores any interaction among variables that might impact habitat quality. For example, a sthat is close to a lek and is in a large patch of intact sagebrush is far more valuable to sage-grouse than that has a similar patch size but is >8 km from an active lek (all other variables held constant). Yet, the mvalues the former as having only a 7.5% greater value to sage grouse. A cursory examination of the varreveals many such interactions documented in the literature (e.g., sagebrush cover and bunchgrass covThese clearly need to be reflected in the model. By ignoring these interactions, the current model is a 

significant step backward from the Habitat Suitability Index models developed for other prairie grouse sp

Finally, by not incorporating interactions among variables, the current model further undervalues the higquality sage grouse habitat. d. The importance of the “service” currency is accentuated when it is used to value mitigation lands. The 

model is explicit that “successful” mitigation occurs when the total service value impacted is replaced by mitigation. As a result, service value gained by mitigating poor quality habitat to moderate quality habitat same as that from moderate to high quality. Thus, the loss of an acre of high quality habitat could be mit

by seeding three acres of post-fire habitat to bring those lands up to marginal quality. We disagree with 

notion that this reflects effective, or appropriate, mitigation. The Conservancy’s sage-steppe mitigation experience is that it is far easier to create low to moderate quality sage grouse habitat than to re-create quality habitat. Thus, the current model’s structure would foster restoration of poor quality habitat as mitfor the loss of higher quality habitat. We suggest that the valuation model be used to identify quality-clas

(e.g. acres with a score >20 = quality class 1) and require that mitigation replace all acres of quality claswith quality class 1 lands. This ensures that the total habitat quality is not ratcheted downward by consta

replacing high quality lands with those of lower quality. 

 The Addendum does not discuss the fact that adult sage-grouse exhibit strong site fidelity in both lek an

sites (Holloran et al. 2010) and that population response to development is slow. Lag times of up to ten have been documented, indicating it may take time for the avoidance effect to manifest. These lag-effecshould be incorporated into any assessment of impacts from the Project to sage grouse. 

 The Proponent’s own mitigation plan states that mitigation projects “will be located more than 18 km from 

transmission centerline to minimize the possibility that the Project itself would reduce the effectiveness o

mitigation project” further confirming that indirect impacts from the Project are of concern to sage-grouse
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100626 THE NATURE CONSERVANCY OF WYOMING, 

THE NATURE CONSERVANCY OF IDAHO, ANDREA ERICKSON QUIROZ, TONI HARDESTY 

(cont.) 

The final EIS or HEA model should account for the loss of sage-grouse habitat associated with both behavioral and predation impacts from tall structures and transmission lines and should provide compensatory mitigation to offset these indirect impacts. 

 Conservancy is concerned about the statement in the compensatory mitigation plan that “Compensatory 

mitigation will be applied to offset the modeled sage-grouse habitat service losses so that there is no neas a result of project construction and operation.” Again we are disturbed by the notion of limiting mitigat

“modeled” sage grouse habitat losses. This approach fails to offset the indirect effects of building verticainfrastructure in sage grouse habitat. This is a crucial omission that renders the entire mitigation underta

inadequate. 

 The approach outlined by the Proponents for siting compensatory mitigation projects has as the first prio

siting mitigation actions in proximity to the Project. This approach fails to take into account landscape-scopportunities to target the most important mitigation actions. As previously stated, given the uncertaintieassociated with sage grouse habitat mitigation, we recommend the development of a regional mitigation that would direct mitigation to “habitats where mitigation has [the greatest] value in providing long term bto sage-grouse.” 

 Conservancy recommends that compensatory mitigation account for factors such as risk of project failur

time lag, and the ability to be transparent in comparing benefits with impacts. 

 responsibilities for the Oversight Committee as outlined in the plan look acceptable. However, there sho

stronger guidance clarifying that the Oversight Committee’s tasks should include ensuring accountability 

providing benefits that offset all project impacts. Thank you for your consideration of these comments. 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100627 STATE OF IDAHO, DEPARTMENT OF FISH AND 

GAME, STATE OF IDAHO, OFFICE OF ENERGY RESOURCES, JOHN CHATBURN 

4.2, p.ll: The Department notes that the referenced sage-grouse surveys are now four years old and use these data in analysis may be questioned particularly when updated state-maintained lek databases are for much of the other analysis. 

 4.3.2, p.l3: The Department does not consider research as mitigation for direct loss of birds.  5.0. p.15-16: We anticipate the State of Idaho will recommend an alternative habitat classification appro

for federal planning and we suggest the final EIS should include a comparable analysis should the recommendation be incorporated into the federal planning process (Idaho's Alternative for incorporation 

the National Greater Sage-Grouse Land Use Planning Strategy). 

 6.1, p. 18: WILD-10 provides prescriptions for vegetation clearing prior to the onset of avian breeding se

that targets sage-grouse. It is unclear whether similar accommodation is made for raptors. We recommesimilar consideration. 

 6.1, p.20: For PAC-7 and PAC-8, the biological rationale for use of 1 mile as a distance metric is unclea

For PAC-8, Our Southwest regional staff recommends 10:00 a.m. as a start time for activities near leks 

surveys in the southwest region of the state have shown birds till lekking past 9:00 a.m. Further, we note 

marking the off-limit areas may potentially attract avian predators or people to the sensitive areas so the Companies should consider whet her physical marking (versus geospatial like GPS) is necessary. 

 6.1, p. 22: TESWL-14 does not allow surface occupancy within 0.6 mile of the perimeter of an occupied 

We note that currently, lek perimeters are not an available metric and thus to appropriately implement thEPM, lek perimeters need to be mapped. The intent of TESWL-15 appears to protect birds on leks or protect nesting birds. However, the project anot being visible from the lek due to topography does not necessarily protect nesting birds out to 4 miles 

because the birds may be nesting between the project and the lek so the visual effect and disturbance to nesting birds may different than experienced by birds on leks. 

 6.1. p. 25: We strongly recommend no flagging of known occupied structures utilized by sensitive specie

described in TESWL-8. Locations can be accommodated by GPS and maps for informed construction crews. Further, we suggest review of the Migratory Bird Treaty to ensure that a

appropriate bird species nests (beyond those classified as TE or sensitive) are addressed by this EPM. 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100627 STATE OF IDAHO, DEPARTMENT OF FISH AND 

GAME, STATE OF IDAHO, OFFICE OF ENERGY RESOURCES, JOHN CHATBURN (cont.) 

6.5. p. 34: The section notes the impact of potential ESA listing on the economic stability of Wyoming's o

gas industry. It should be noted that a sage-grouse listing would have much broader economic effect acboth states to include impacts to grazing, other energy development, and other multiple uses. 

 6.6. p. 34: The conclusions seem a bit definitive given the combination of: 1) uncertainty regarding the n

and extent of indirect effects, as acknowledged throughout the document, 2) the long-term beneficial effof project decommissioning and 3) at least some degree of uncertainty regarding mitigation effectivenesDepartment made several recommendations to the proposed compensatory mitigation plan that should strengthen the foundation of the conclusion but we point out that factors beyond the control of the Comp

(such as wildfire either within or outside of the project area) have the potential to alter the conclusion ab

effects of the project on overall sage-grouse population trend, thus is there a cumulative aspect to consithe conclusion. 

 8.0, p. 64, Table 9: As a general comment, we note that the Proponent-Proposed EPMs will occur on St

lands but there should be allowance for future State of Idaho decisions about sage grouse management relative to the Governor 's Sage-Grouse Task Force recommendations that may modify activity on State lands. We recognize the focus of both the Proponent-Proposed EPMS and the Agency-Required Mitigation 

Measures is sage-grouse. While there are aspects of these that deal with avian and other sensitive spec

such as survey protocols, we find little in the way of EPMS or mitigation measures relative to other impo

state wildlife resources that might be affected, such as big game. The Depa1tment acknowledges that sof the mitigation measures for sage-grouse will have a broader species benefit. 

 PAC-7, We recommend area searchers rather than point location surveys to account for potential annua

variation in lek locations/activity centers. 

 WILD-1, the description in the "Applied on Private/State Lands" column should state.... does not apply to 

privately or state managed lands. 

 We recognize this Plan is specific to sage-grouse. The Department has previously commented on the n

for substance regarding mitigation for other wildlife effects of the project, recognizing that sage-grouse mitigation actions will have benefits to other species. 

 We recognize the effort of the Companies to develop a comprehensive mitigation plan for the project an

reserve future comment to incorporate detail of State of Idaho recommendations for integration into fedeland planning, that are still in development. In general, we observe the following: Habitat restoration shohave higher value and emphasis in the Plan than fence marking and conservation easements. Conservaeasements to not mitigate habitat loss from the project; they mitigate the imminent threat to the habitat bput under easement and reserve the stat us quo of the easement property so there is no net gain unless additional management improvements are made to the easement property. Mitigation (project) success criteria and mechanisms for addressing and rectifying unsuccessful projects would substantially strengththe Plan. An in-lieu fee approach as suggested by the Plan is being considered by the State of Idaho bupolicies and structure necessary for such an approach have not been adopted. We encourage more emphasis on establishing priorities for mitigation that focus on highest likelihood for long-term persistencsage-grouse, rather than nearest suitable location benefitting the impacted population. The Department recognizes the challenge of developing compensatory mitigation for indirect and unknown impacts and 

suggests that research may play a role in addressing these. As noted in the Plan, the HEA really only accounts for direct effects. 

 1.2, p.l: Third bullet should reference State of Idaho rather than IDFG and the Idaho Task Force. 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100627 STATE OF IDAHO, DEPARTMENT OF FISH AND 

GAME, STATE OF IDAHO, OFFICE OF ENERGY RESOURCES, JOHN CHATBURN (cont.) 

Section 1.3.1. p.l: The Office of Governor Otter has not finalized adoption of a State of Idaho draft alternfor sage-grouse management in Idaho to integrate into federal planning. However, the State generally supports a mitigation strategy for known impacts in areas that provide the highest likelihood for long-term sage-grouse persistence, even when this may mean directing resources to areas that are not considerekind, in place", relative to the project. While the mitigation strategy generally supports this approach, theshould be more emphasis on ensuring highest likelihood for success and benefit to long-term persistencthe priorities described in Section 2.2. 

 Section 2.2, p.4: The first and second priorities could be combined and emphasis changed to conservat

opportunity in PPH/core habitats rather than proximity to the transmission line. 

 Section 2.4, p.4: We recognize and appreciate the Companies desire for technical guidance including to 

in-lieu fee administering entity. Further detail to be presented in the final mitigation proposal regarding th

Oversight Committee should include financial support for members of the Committee as this is a substatask and workload, particularly if the Committee takes on monitoring and maintenance. The final plan shclarify the committee role relative to both directed mitigation and in-lieu fee project oversight. Although thCommittee is charged with assessing monitoring and effectiveness, no mechanism is proposed to corre

deficiencies or failures of mitigation projects. The plan suggests an adoptive management approach for fee mitigation in the case of project failure which should also apply to directed mitigation projects. 

 Section 3.1 .1, p.6: The plan states that compensatory mitigation funding is fixed. Success of any meani

mitigation, especially compensatory mitigation, should be measured on the ground with mitigation criterimeet specific performance measures. The HEA and the plan already provide methods for measuring 

mitigation project outputs. The plan should ensure that the Companies will meet compensatory mitigatioobligations as identified by HEA, the plan, and the Oversight Committee. Fixed funding also does not taaccount variable costs associated with easements and restoration so a mechanism to deal with failure is needed. 

 3.1.1, p. 7: The Department considers the proposed level of 25% of the mitigation obligation in fence ma

as overemphasized for benefit expectations of this action. Fence marking is an out-of-kind mitigation norelated to habitat loss, unlike habitat restoration. The Sage-Grouse Task Force considers fences to be a secondary threat. The USFWS memo states that fence marking should not be the central focus of mitigaWe suggest there should be reconsideration of some of the financial resources al located to fence markinto more direct habitat restoration measures. 

 3.1 .1. p. 8/10: Sagebrush and understory restoration are proposed at fairly low levels, citing cost as the 

primary reason. Again, meeting the mitigation obligation should be the focus. Restoration is in-kind mitig

and is recommended as a high mitigation priority in the Task Force plan. 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100627 STATE OF IDAHO, DEPARTMENT OF FISH AND 

GAME, STATE OF IDAHO, OFFICE OF ENERGY RESOURCES, JOHN CHATBURN (cont.) 

3.1.1, p. 10: Conservation easements generally do not reduce fragmentation; they only retain the status of the landscape unless there is an associated change in management of easement property that leads habitat connectivity. While there would be benefits to habitat that could be met though easements where valuable piece of habitat is under imminent threat of Joss and the land is available for an easement, the 

original habitat loss due to the transmission line is not what is mitigated but instead, it is the threat to the that was put under conservation easement, that is mitigated. A blanket statement that 35% of the mitigaobligation will be met through easements seems overly optimistic. 

 4., p. 12: The monitoring and maintenance plan suggests establishing success criteria. That is a necess

component, but only if the plan includes measures to address problems when success is not met, otherw

such criteria are hollow. 

100628 STATE OF WYOMING, GAME AND FISH 

DEPARTMENT,JOHN EMMERICH,MATT FRY 

The addendum appears to be thorough and we have little concern with the document as a whole. 

 However, the mitigation plan discussed in Attachment 2 of the document proposes that a large portion (2

of mitigation will be focused on fence removal/marking. We recommend that the proponents only be crea mitigation offset for documented “problem fences". As all fences do not pose the same risk, equal benshould not result for marking or moving any fences within 1.2 miles of a lek. 

100629 POWER COUNTY TASK FORCE, RAYMA CATES I did not see the leks that were found in spring 2012 by the Idaho Department of Fish and Game include

the addendum analysis. The maps at the end of the Addendum show 4 leks in the Arbon Valley portion Power County, Idaho. I have been given a Fish and Game map that shows 27 leks in this same area. I aconcerned that there are many leks near the proponents preferred route in this area which are not being 

consideration. This has the potential of erroneously making the proponents route through Arbon Valley appear to have less impact on sage grouse than the route the Power County Task Force supports. 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100630 HAWKWATCH INTERNATIONAL,STEVE SLATER PAGE 29: “TESWL-3 requires that anti-perch devises be used in certain locations; however, current stu

have shown that perch deterrents and anti-perch devices are limited in their effectiveness (Lammers anCollopy 2007; HawkWatch International 2008; Prather and Messmer 2010; Slater and Smith 2010). For example, during a study on H-framed lines in Wyoming, Slater and Smith (2010) observed some specie

raptors perching more often on lines fitted with deterrents compared to non-deterred lines.” Our research in Wyoming on perch deterrents (Slater and Smith [2010]) actually found that they were hi

effective in reducing perch use by raptors (13-45 fold difference in perch use between deterred and nondeterred line). I also believe the comment about some raptors perching more often on lines with deterreout of context and irrelevant: the only species this was true of was Rough-legged Hawk and Swainson’s and these birds did not perch on deterrents, but alternate areas (e.g., cross-brace). The rough-legged hmade up most of these observations and they are definitely not sage-grouse predators, nor or Swainson

Hawk considered a primary sage-grouse predator. You should be focusing on Golden Eagles as sage-g

predators and the deterrents were very effective in reducing their perch abundance. I appreciate that yoadvocate for the use of deterrents regardless of these statements, but feel these misleading statements 

should be corrected in the final draft to avoid their perpetuation elsewhere. 

100631 LINCOLN CONSERVATION DISTRICT 

(WY),ERICK ESTERHOLDT 

After reviewing the additional Sage-grouse information available June 29, 2012, for review and commenconcerning the Gateway West Transmission Line Project, the Lincoln Conservation District (LCD) board supervisors see very little affect to Sage grouse. After reviewing a special report titled "Sage Grouse SoSpotted Owl" by Carolyn Dufurrena, it confirmed board members' view that predation, especially ravens

the number one ki ller of Sage grouse. It is clear that the new BLM goal for the Sage grouse is not to maa minimum effective population to prevent listing, but to greatly promote sustainable populations many tgreater than what is truly needed. Perhaps the Sage grouse is just another radical environmental tool to livestock grazing and all types of necessary development off federal lands for sanctuary purposes and 

personal reasons. 

100633 IDAHO CONSERVATION LEAGUE, JOHN 

ROBISON 

While we agree that different restrictions are appropriate for different breeding densities and quality of sgrouse habitat, we are troubled by the patchwork of varying protections planned according to land owneWe recommend that stipulations and protective measures be selected for maximum protection of sage-g

and sage-grouse habitat, and be applied consistently across different land ownerships as much as poss

 We recommend the BLM follow the recommendations of the Idaho Sage Grouse Task Force (Footnote 

issued June 15, 2012 (see link and attachment). The Task Force recommended a ban on major infrastrudevelopment within core habitat with limited exceptions. We also recommend the Best Management Pralisted in section A of the Report (p. 12) be followed. 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100633 IDAHO CONSERVATION LEAGUE, JOHN 

ROBISON (cont.) 

We are concerned that there is no mention of how the success or failures of the HEA will be monitored. 

is an important step for future projects which may benefit from the development and use of an HEA. 

Monitoring is important so that we can learn what worked in the HEA and what did not. A comprehensivto monitor the impacts of the HEA should be created and utilized. 

 In closing, the BLM should prioritize routes which do completely avoid sage grouse habitat and restorati

areas. 

 Careful evaluation of the need for two separate lines in Idaho should also occur. It is our conclusion that 

line would be sufficient in many areas. 

 When impacts cannot be avoided, the BLM needs to develop a mitigation program designed to offset an

adverse impacts from habitat loss or avoidance due to this project. 

 Conservation groups have expressed the need for validation of two separate lines through much of Idah

continue to question the need for two separate lines, particularly given the use of outdated IRP projectioUpdated demand projections in the FEIS may show that a single line is sufficient. We also recommend a closer examination of the proposed separation between transmission lines. New recognition of the 

environmental impacts of transmission line corridors should be brought to the regulating body’s’ attentio

reconsider decreasing the separation distance between lines, particularly where resource conflicts are hWe have not seen sufficient validation for the need for two separate lines in Idaho. 

 Task Force Recommendation state that essential public services such as small distribution lines should 

located at least 1 km from active leks. Larger projects should be located farther from leks and other impohabitats. Due to the fact that power lines provide perch sites for raptors, it is recommended that these structures not be built within 3 km of seasonal habitats (p. 12). If these structures must be built it is recommended that they be buried or the poles be modified to prevent their use as raptor perches. Rocky 

Mountain Power’s requirement of no surface occupancy within 0.25 miles of a lek has been repeatedly identified as having no scientific validity. The 0.6 mile buffer proposed elsewhere in the HEA is a minor 

improvement, but larger buffers are recommended in the literature. We believe that a greater buffer sho

put in place to ensure protections of sage grouse. The Task Force also recommends that lines be constoutside of March 15 to June 30. 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100633 IDAHO CONSERVATION LEAGUE, JOHN 

ROBISON (cont.) 

Task Force Recommendation state that essential public services such as small distribution lines should located at least 1 km from active leks. Larger projects should be located farther from leks and other impohabitats. Due to the fact that power lines provide perch sites for raptors, it is recommended that these structures not be built within 3 km of seasonal habitats (p. 12). If these structures must be built it is recommended that they be buried or the poles be modified to prevent their use as raptor perches. Rocky Mountain Power’s requirement of no surface occupancy within 0.25 miles of a lek has been repeatedly identified as having no scientific validity. The 0.6 mile buffer proposed elsewhere in the HEA is a minor 

improvement, but larger buffers are recommended in the literature. We believe that a greater buffer sho

put in place to ensure protections of sage grouse. The Task Force also recommends that lines be constoutside of March 15 to June 30. 

 The use of a standardized one-to-one ratio for habitat services lost/habitat services mitigated in the HEA 

unacceptable. It is well documented that restoration and recovery do not replace services on a one-to-obasis, therefore requiring a higher replacement ratio to compensate for the decreased services. The U.S

and Wildlife Service recommends that this standardized ratio be revised. They list the following biologica

factors that may provide justification for adjusting the minimal mitigation ratio beyond one-to-one. (a) According to the best available science on the relative value of Sage-grouse populations, some local populations may contribute more to long-term species viability than others, justifying higher mitigation ra

Such populations are located in: southwestern ID, central and northwestern NV, eastern OR, and WY populations contribute most to the long-term viability of the species; (b) Regarding individual birds contri

to populations, hens have a much higher biological value than males; (c) Localized habitats of high ecolvalue such as (but not limited to) those serving key functions in demographic, genetic, or seasonal 

connectivity, important wintering areas, or leks; (d) Time lags for mitigation success such that habitat se

in treatment areas are not immediately available to Sage-grouse. (Gateway West Greater Sage-Grouse Detailed Mitigation Plan Outline, p. 16 

 Given the considerations of year-round habitat use and known impacts of human activity on sage-grous

populations, mitigation will be needed for disturbance to sagebrush near lekking areas; disturbance and 

of sagebrush and native forbs used for early brood-rearing; and disturbance and impacts to hydrologic 

function of wet areas used for early to late brood-rearing. A conservative estimate for the nesting and brrearing area affected will include buffers with radii of 6.2 miles around known leks. Mitigation specifics cbe based on a mitigation template recently created for the Lesser Prairie Chicken, a ground-nesting spefacing similar threats (Horton et al. 2010). 

 Section 6.4 of the DEIS states that “no direct loss of birds is expected during the construction phase of t

Project”(p. 33). This is an implausible expectation for a construction activity which will occur over 1100 m

much of which is adjacent or on known sage grouse habitat. Due to the existence of an exception proce

guarantee exists that the agency-required mitigation measures will even be applied during the course of construction. In addressing the direct loss of birds it should be noted that contributing financially to research projects dnot directly compensate for the loss of birds. While such monetary contributions will facilitate impacts analysis, range wide jeopardy analysis, and add to the current and future NEPA processes, its does not restore birds or habitat loss. 

 Existing Conditions In describing the existing conditions of sage grouse habitat in Idaho it is stated that 

“breeding habitat (i.e., spring habitat) and late brood-rearing habitat (i.e., summer habitat) is characteriz10 to 25 percent sagebrush cover” (p. 14). This statement should state that 10 to 25 percent sagebrush is needed at a minimum. Likewise on page 15 a minimum of 10 to 30 percent canopy cover is needed in winter habitat. 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100633 IDAHO CONSERVATION LEAGUE, JOHN 

ROBISON (cont.) 

Seasonal implications The BLM should also impose restrictions on transmission line construction to a seasonal schedule that avoids conflict with sage grouse. Additionally, transmission lines are listed unde“infrastructure” developments in the Idaho Sage-Grouse Task Force Recommendations and thus recommendations for this type of development should pertain to this project. The Task Force recommensage-grouse conservation measures to be implemented over the next 10-year period to accomplish the following: - Conserve existing sage-grouse habitat; - Increase the resiliency of the habitat to disturbance

such as fire, and reduce existing habitat fragmentation; and - Provide sage-grouse the opportunity to incand expand its population in Idaho 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100633 IDAHO CONSERVATION LEAGUE, JOHN 

ROBISON (cont.) 

Key habitat zones The project area is located adjacent to and often within Core, Important, and General Habitat Zones for the greater sage grouse. The Idaho Sage-Grouse Task Force gives detailed explanatithe importance of each degree of habitat on the health of the sage grouse. The BLM should analyze the location of the project with respect to maps produced by the Idaho Sage Grouse Task Force which distinCore Habitat, Important Habitat and General Habitat Zones. These three zones are important for perma

and seasonal habitat, as well as connectivity. The Task Force recommends that infrastructure developmthe Core Habitat Zone be limited to projects that meet the requirements of the Core Habitat Zone for 

incremental upgrades of existing infrastructure. These recommendations are listed as: - Limit the consideration of infrastructure development to only those projects with valid existing rights or incrementa

upgrade/capacity increase of existing essential developments (e.g., projects for increasing the capacity existing transmission line). - Impacts of such projects would be limited to an existing footprint with only aincremental expansion (approximately a 50 percent or less increase in footprint or size for existing confidevelopment appropriate for the particular industry) and associated impacts. - Limiting development to t

types of projects will substantially constrain the level of new disturbance by limiting impacts to previously disturbed or affected areas, minimize proliferation of roads and decrease opportunities for invasive weedcolonize, while providing significant public benefit. - Timing of construction would be designed to minimizimpacts to sage grouse during critical times of their life cycle (e.g., breeding, wintering). Other BMPs worequired to minimize impacts. Large-scale infrastructure projects would be precluded in the Core HabitaZone, unless an exemption is made that considers the following circumstances: - An assessment to determine the proposed action’s impact on the State of Idaho’s ability to achieve the conservation objecand - The project cannot otherwise be accomplished technically or economically outside of CHZ. Within 

Important Habitat Zone, the Task Force makes the following recommendations: Limit infrastructure 

development in the IHZ to projects that either meets the requirements of the CHZ for incremental upgradexisting infrastructure, or new development is permitted if the proposed project meets the following criteProvide a demonstrated high-value benefit to the State of Idaho; - Collocate the project with existing infrastructure to the extent practicable. Otherwise, the siting of a facility must best reduce cumulative im

and/or avoid other high value natural, cultural, or societal resources; - Cannot reasonably be achieved, technically or economically, outside of IHZ; - Does not threaten the connectivity or persistence of CHZs; 

Must not result in undue fragmentation or other impacts that cause future declines in the population withzone. - An effects analysis precedes project approval (e.g., NEPA analysis on federal lands and/or Wind Energy Guidelines (FWS 2012) tiered analysis on federal, state, and private lands) - Mitigate unavoidabimpacts through an appropriate compensatory mitigation plan implemented through the Idaho sage-groumitigation framework (see ISAC 2011) Appropriate site-specific BMPs would also be required to minimizimpacts (e.g., project siting, site restoration, avoidance of leks, timing and/or spatial buffers, etc.). Compensatory mitigation should be directed to projects that enhance and benefit CHZ or IHZ. Within the General Habitat Zone, the Task Force recommended deferring to Local Sage-grouse Working Group plaand the local Resource Management Plan: Although development in areas that are not in the SGMA is preferred to development in GHZ, development in GHZ is preferable to development in CHZ or IHZs. Infrastructure development in GHZ is allowable under the following circumstances: - An effects analysis precedes project approval (e.g., NEPA analysis on federal lands and/or Wind Energy Guidelines (FWS 2tiered analysis on federal, state, and private lands) - Apply sage-grouse habitat management BMPs (see BMPs below) - Impacts must be minimized as much as practicable - Collocate the project with existing infrastructure of similar type or degree of disturbance to the maximum extent practicable - Project must micro-sited to minimize impacts - If compensatory mitigation is deemed necessary by the permitting entiproject developer, use the Idaho sage-grouse mitigation framework (see ISAC 2011 and E. Mitigation Framework) 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100633 IDAHO CONSERVATION LEAGUE, JOHN 

ROBISON (cont.) 

Best management practices Additionally, the BLM should work to establish Best Management Practices (BMP) for this project to ensure the species and habitat is adequately protected. While not comprehensi

its scope, BMPs listed by the task force which apply to this project are: - Use existing roads, or realignm

of existing routes. Build new roads to minimum standards necessary. Locate roads to avoid IHZs as bespossible. - Micro-site linear facilities to reduce impacts to sagebrush habitats when possible. Encourage development to occur in areas of existing development, or locations outside of SGMA. - Locate staging outside of the CHZ to the greatest extent possible. - Co-locate linear facilities in the IHZ within 1 kilomet(“km”) of existing linear facilities when possible. - Locate essential public services (distribution lines, dom

water lines, gas lines) at least 1 km from active leks. If not possible, construct lines outside of March 15 June 30. - To the extent practicable, avoid building power lines and other tall structures that provide persites for raptors within 3 km of seasonal habitats. If these structures must be built, or presently exist, the 

should be buried or poles modified to prevent their use as raptor perch sites (Connelly et al. 2000). (IdahSage-Grouse Task Force Recommendation p. 16) 

 Mitigation scaling tool The HEA is described as a “method of scaling compensatory mitigation requireme

and not as an impacts analysis (Effects of the Proposed Project on Greater Sage-Grouse p. 13). The ph“mitigation scaling tool” is not seen elsewhere in the literature. This term should defined as to its use, purposes, and how it relates to the NEPA process. If the HEA is not an impacts analysis, but simply a to

mitigation scaling, then we believe that a quantitative impacts analysis should be completed in addition tHEA 

 We discourage the use of un-modeled mitigation measures, as described in Appendix E. Some of these 

measures may actually result in harm to sage grouse habitat, and the benefits to others are not quantifiarecognizable. All mitigation measures should be modeled or proven before put to use. Mitigation should factor in the probability of failure of restoration efforts and the time lag before restoration projects meet hobjectives. 

 Routes which transit the least amount of area known as sage-grouse habitat should be given the greate

consideration. The Idaho Conservation League is highly concerned regarding some of the alternative roproposed for the Gateway West Transmission line through Idaho. We are particularly concerned with ro

that would impact sage-grouse habitat. Routes which cross the Core Habitat Zone (CHZ) for sage-grousdetermined by the Idaho sage-grouse Task Force (see maps in Task Force Recommendations) should avoided entirely. These areas are vital to maintaining and promoting sage-grouse populations. Areas determined as CHZ should be protected against habitat fragmentation, such as is known to occur due to 

construction and existence of transmission lines. Routes that might impact the Important Habitat Zone (Ineed to be collocated unless the route best addresses multiple ecological and societal concerns. 

 The Idaho Conservation League is strongly opposed to Alternative Segment 9E due to the fragmentatio

introduction of predator perches into the relatively undisturbed sage-grouse habitat in Owyhee County. Troute would transverse 49.3 miles of important and core sage-grouse habitat. The Owyhee County Sagegrouse Local Working Group and the Owyhee County Commissioners have also opposed this route. 
Gateway West Transmission Line Final EIS

Appendix L – Responses to Comments on Draft EIS 

Letter # Owner Comment 100633 IDAHO CONSERVATION LEAGUE, JOHN 

ROBISON (cont.) 

Alternative 9D is the Idaho Conservation League’s most preferred route. Additionally, this route is preferthe Owyhee County Task Force. This route would have minimal effects on raptors because it is immediaadjacent to an existing 138-kV transmission line through the Snake River Birds of Prey National Conserv

Area. Studies have shown that raptors can coexist and sometimes benefit from transmission lines. (Foo2) By collocating the new line with the existing line through the Birds of Prey NCA, this route would elimithe need for new roads. While other areas of the Birds of Prey NCA are not suitable for new transmissioprojects (as explained for the proposed routing of segment 8) this area is the best option for avoiding sagrouse habitat in Owyhee County. It also offers the ability for reclamation activities to take place along th

previously disturbed area. However, the route proposed in Alternative 9D must be reconsidered where it crosses the Snake River Canyon. Studies conducted on the compatibility of raptors and transmission lin

have not considered the affects of lines on cliff habitat. At the present time Alternative 9D crosses the SRiver at the confluence of the Snake River and Sinker Creek. This crossing point conflicts with both ecoand scenic interests. It is a pristine riparian area and important cliff habitat for raptors in the National Conservation Area. This alternative should be rerouted to cross by the Swan Falls Dam. This alteration 

would work to conserve both important sage-grouse and raptor habitat. 

 Segment 8: Midpoint to Hemingway Segment 8 is problematic because it is incompatible with the object

of managing the Birds of Prey NCA. While raptors have been shown to successfully exist alongside 

transmission lines, the additional stress this line would put on raptor habitat is inconsistent with the 

management of the Birds of Prey NCA. This is due to the 1,500 ft. distance that would be required betwthe existing 500-kV line and the proposed line. Such a distance means that a new road would have to b

in the NCA for the line’s construction and maintenance. This road would run through shrub habitat causi

further habitat fragmentation for raptor prey and ultimately affecting raptor predation. The Idaho ConservLeague believes that the need for two separate transmission lines through Idaho should be reconsideretwo lines must be built it is suggested that Segment 8 be routed around the Birds of Prey NCA. Alternati8B, C, and D should then be used to avoid the NCA while also allowing Segment 9 to cross near Swan 

Dam and to avoid crossing the Snake River Canyon near Sinker Creek. 

 The Idaho Conservation League’s preferred route for Segment 7 is the currently proposed option. This r

is the best option for avoiding important and core sage-grouse habitat. 

 The Idaho Conservation League strongly opposes Segments 7H, I, and J. These routes would all impac

significant areas of sage-grouse habitat, totaling more than 328 miles of the CHZ. Segments 7I and J arparticular concern as they would impact the highest breeding density class (top 25%) for sage-grouse. Troute is unacceptable for proper sage-grouse management. Additionally, various pieces of routes 7H, I, are not in conformance with the Cassia and Wells RMP’s, the Twin Falls MFP, or the Sawtooth Forest P

 Segments 7A and 7B are not in conformance with the Malad MFP. Segment 7A would cross an Invento

Roadless Area with wilderness characteristics. Footnote 2: Steenhof, K., Kochert, M. N., & Roppe, J. A. 

(1993). Nesting by raptors and common ravens on electrical transmission line towers.