A U G U S T 2 0 0 3

Final Environmental Assessment and Finding of No Significant Impact

DOE/EA-1425

RAYMOND-COSMOPOLIS TRANSMISSION LINE

REBUILD PROJECT
Bonneville Power Administration i

Table of Contents 

Chapter 1 Purpose of and Need for Action ..............................................................1-1 

1.1 Introduction.........................................................................................................1-1 

1.2 Underlying Need for Action.................................................................................1-1 

1.3 Purposes of Action..............................................................................................1-1 

1.4 Other BPA Projects in the Area ..........................................................................1-3 

1.5 Public Involvement..............................................................................................1-3 

Chapter 2 Proposed Action and Alternatives ..........................................................2-1 

2.1 Proposed Action .................................................................................................2-1 

2.2 No Action Alternative ..........................................................................................2-9 

2.3 Alternatives Considered but Eliminated from Detailed Study..............................2-9 

2.4 Comparison of Alternatives...............................................................................2-10 

Chapter 3 Affected Environment, Environmental Consequences, 

 and Mitigation ...........................................................................................3-1 

3.1 Introduction.........................................................................................................3-1 

3.2 Land Use ............................................................................................................3-4 

3.3 Geology And Soils ..............................................................................................3-9 

3.4 Vegetation ........................................................................................................3-13 

3.5 Fish And Wildlife...............................................................................................3-17 

3.6 Water Quality....................................................................................................3-26 

3.7 Wetlands...........................................................................................................3-31 

3.8 Floodplains .......................................................................................................3-36 

3.9 Visual Quality....................................................................................................3-39 

3.10 Air Quality .......................................................................................................3-45 

3.11 Socioeconomics .............................................................................................3-47 

3.12 Cultural Resources .........................................................................................3-52 

3.13 Health And Safety...........................................................................................3-55 

3.14 Noise ..............................................................................................................3-57 

Chapter 4 Environmental Consultation, Review, and Permit Requirements ........4-1 

4.1 National Environmental Policy Act......................................................................4-1 

4.2 Threatened and Endangered Species and Critical Habitat.................................4-1 

4.3 Fish and Wildlife .................................................................................................4-4 

4.4 Cultural and Historical Resources ......................................................................4-7 

4.5 State, Areawide, and Local Plan and Program Consistency...............................4-7 

4.6 Washington Forest Practices Act......................................................................4-11 

4.7 Coastal Zone Management Act Consistency....................................................4-11 

4.8 Air Quality.........................................................................................................4-11 

4.9 Floodplains and Wetlands Protection ...............................................................4-12 

4.10 Permits for Discharges into Waters of the United States................................4-13 

4.11 Global Warming..............................................................................................4-14 

4.12 Hazardous Materials.......................................................................................4-14 

4.13 Executive Order on Environmental Justice.....................................................4-15 

4.14 Resource Conservation and Recovery Act .....................................................4-15 

4.15 Noise ..............................................................................................................4-15 
ii Raymond – Cosmopolis Transmission Line Rebuild Project EA 

4.16 Federal Communications Commission ...........................................................4-16 

4.17 Requirements Not Applicable to this Project...................................................4-16 

Chapter 5 Persons and Agencies Consulted...........................................................5-1 

Chapter 6 Glossary and Acronyms...........................................................................6-1 

Chapter 7 References ................................................................................................7-1 

Chapter 8 Public/Agency Comments and Responses ............................................8-1 

Appendix A: Impact Level Definitions.................................................................... A-1 

Appendix B: Data Tables 

B-1. Plants Observed in Project Vicinity.................................................................B-1 

B-2. Stream Types and Fish Presence in the Project Corridor...............................B-4 

B-3. Fish and Wildlife Potentially Occurring in the Project Corridor........................B-7 

B-4. Population Trends for Grays Harbor and Pacific Counties, 1980-2002 ..........B-9 

B-5. Full and Part-time Employment in Grays Harbor and 

Pacific Counties, 2000 ..................................................................................B-10 

B-6. Wage and Salary Employment in Grays Harbor and 

Pacific Counties, 2000 ..................................................................................B-10 

B-7. Income Characteristics in Grays Harbor and Pacific Counties .....................B-11 

B-8. Race Distribution in the Two-County Region and 

Washington State, 2000 ...............................................................................B-12 

B-9. Median Household Incomes of Study Area and Washington State, 2001.....B-12 

B-10. Construction Noise in the Vicinity of a Representative Construction Site .....B-13 

B-11. Proposed Structure Location in Relation to Wetlands 

and Wetland Buffers .....................................................................................B-13 

Appendix C: Health and Safety Technical Report 

Appendix D: Mitigation Action Plan

LIST OF FIGURES 

Figure 1-1. Project Area Overview .............................................................................. 1-2 

Figure 2-1. Proposed Realignment of Existing ROW Segments................................. 2-3 

Figure 2-2. Typical Suspension Structure ................................................................... 2-5 

Figure 3-1. Land Use .................................................................................................. 3-5 

Figure 3-2. Floodplains ............................................................................................. 3-37 

Figure 3-3. Looking North at Structure 112 and 113 ................................................. 3-40 

Figure 3-4. Looking North at Structure 26 near Dixon Road ..................................... 3-42 

Figure 3-5. Tubular Steel Pole Structure Simulation ................................................. 3-42 

Figure 3-6. Looking North at Structure 52 in Foreground, in WSDOT Scenic 

Classification BX..................................................................................... 3-43 

Figure 3-7. Looking North Towards Structure 47 (foreground) and 48 & 49 

in the Background................................................................................... 3-44 
Bonneville Power Administration iii

LIST OF TABLES 

Table 2-1. Comparison of the Proposed Action and No Action Alternatives...............2-10 

Table 3-1. Summary of Impacts of the Proposed Action and 

No Action Alternatives.................................................................................3-2 

Table 3-2. Structures In or Within 50 Feet of Streams ...............................................3-27 

Table 3-3. Structures In or Within 50 Feet of Wetlands..............................................3-32 

Table 3-4. Activities in Floodplains and Their Impacts ...............................................3-38 

Table 3-5. Predicted Foul-Weather Audible Noise Levels at Edge of 

ROW for Proposed Project and Existing 115-kV Line ...............................3-59
Bonneville Power Administration 1-1 

Chapter 1 

Purpose of and Need for Action 

1.1 INTRODUCTION 

This Environmental Assessment (EA) was prepared by Bonneville Power Administration (BPA) 

pursuant to regulations implementing the National Environmental Policy Act (NEPA) (42 USC 

4321 et seq.), which requires federal agencies to assess the impacts their actions may have on the 

environment. Major federal actions significantly affecting the quality of the human environment 

must be evaluated in an Environmental Impact Statement (EIS). BPA prepared this EA to 

determine if the proposed action would cause effects that would warrant preparing an EIS. 

1.2 UNDERLYING NEED FOR ACTION 

BPA needs to take action because the existing 115-kilovolt (kv)1 transmission line between 

Raymond and Cosmopolis in Washington is old, physically worn, and structurally unsound in 

places. Its condition creates risks to public and worker safety and to reliable electrical service. 

The Raymond–Cosmopolis transmission line (Figure 1-1) was originally built in the 1920s and 

was acquired by BPA in the 1930s. BPA fitted portions of the line with new conductors (wires) 

and tower tops in 1952. Today, the existing structures and conductors show impact damage from 

trees falling on the line as well as normal deterioration due to age. Erosion and unstable soils 

have undermined the structure bases in some areas, and a number of the structures are leaning. 

Some structures do not have permanent access roads to reach them, which makes normal and 

emergency maintenance difficult and at times unsafe. The line’s poor condition raises concerns 

about its overall structural reliability and the safety of BPA workers who must maintain it. 

In addition, given current electrical loads in the area and the capacity of the existing conductor, 

transmission planning studies show that if there is an outage on the 230/115-kV transformer 

located at BPA’s Chehalis Substation, or if a double outage occurs on the Paul–Allston 500-kV 

transmission line, it overloads the existing Raymond–Cosmopolis transmission line beyond its 

rated thermal capacity. As the overloaded conductor heats up, it expands and sags closer to the 

ground. If it sags below a certain distance from the ground, it is considered to be a safety 

violation of the National Electrical Safety Code. 

1.3 PURPOSES OF ACTION 

The project would be expected to accomplish the following purposes: 

• Meet transmission system public safety and reliability standards set by the National 

Electrical Safety Code 

• Minimize environmental impacts 

• Improve safety for transmission line workers 

• Minimize costs 

• Use facilities and resources efficiently 

 

1

 Terms defined in the glossary (Chapter 6) are shown in bold, italicized typeface the first time they are used. 

FOR SECURITY PURPOSES 

This paragraph was deleted from the electronic version of this document 
1-2 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

Figure 1-1. Project Area Overview 

FOR SECURITY PURPOSES 

This figure was deleted from the electronic version of this document 
Bonneville Power Administration 1-3 

1.4 OTHER BPA PROJECTS IN THE AREA 

BPA recently completed or is planning several other projects along the Raymond-Cosmopolis 

transmission line. Each of these projects, as described below, is considered a separate project 

because it is needed regardless of whether the actions evaluated in this EA take place. 

The Raymond-Cosmopolis danger tree removal project was conducted in the summer and fall of 

2002. Danger trees are trees that could, within a 15-year period, be a hazard to the transmission 

line by falling into it. The project was needed because damage from trees caused an average of 

ten outages per year along this line. Environmental impacts of the project were assessed in a 

Supplement Analysis (SA-65, BPA 2002), tiered to the BPA Transmission System Vegetation 

Management Program Final Environmental Impact Statement (EIS) (BPA 2000). Danger trees 

were removed in areas adjacent to the Raymond-Cosmopolis right-of-way (ROW), generally 

within 175 feet. As part of the project, a number of roads also were improved. 

Ongoing access road maintenance was completed in the summer of 2002 to repair failed culverts 

and to improve roads that had become impassable. Some work was conducted in waterways, 

including replacing three culverts that are not in fish habitat, replacing four culverts in fish 

habitat with culverts that meet Washington Department of Fish and Wildlife (WDFW) Fish 

Passage Guidelines, and replacing one culvert with a bridge. This type of work normally is 

categorically excluded from further analysis under NEPA. 

BPA is proposing repair work on the bridge over Butte Creek on the entrance road to Raymond 

Substation, to ensure it meets guidelines and specifications for heavy vehicles. Some instream 

work, including placement of riprap, would be proposed to protect the western abutment of the 

structure. Environmental analysis and NEPA review has not yet begun; it is not known if it will 

be accomplished in time for maintenance to proceed in 2003 2004, if funding is available. 

BPA conducted vegetation management within the existing 50-foot wide ROW during the early 

spring and summer of 2003. Tall-growing woody vegetation within the 50-foot ROW that could 

pose an electrical hazard to the existing line was cut with a brush cutting machine or chainsaw. 

This work meets the guidelines established in the Vegetation Management Program EIS 

(BPA 2000); site-specific environmental impacts were analyzed in a Supplement Analysis to the 

EIS (SA-159, 2003). 

1.5 PUBLIC INVOLVEMENT 

On March 28, 2002, BPA sent a letter to people potentially interested in or affected by the 

proposed Raymond-Cosmopolis Transmission Line Rebuild Project, including adjacent 

landowners, public interest groups, local governments, Tribes, and state and Federal agencies. 

The letter explained the proposal, the environmental process, and how to participate. The letter 

also was posted on the BPA website. 

BPA determined that eight Tribes have a potential interest in this project, based on their historic 

or current use of the land within the project area. BPA provided information and comment 

opportunities to Tribal representatives and contacted their designated cultural resources 

specialists. 
1-4 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

BPA held two public meetings to describe the project and to solicit comments, one on April 17, 

2002, in Cosmopolis and the other on April 18, 2002, in Raymond. On August 28, 2002, 

landowners along the transmission line corridor who had been inadvertently omitted from the 

project mailing list were sent project information and given an opportunity to comment. 

Comments, both written and oral, that were received while the Preliminary EA was being 

prepared (from April to late November), were considered in the analysis. 

Numerous individuals from the Raymond area, including public officials, requested that fiber 

optic cable be installed on the transmission line should the project go forward. BPA responded 

to the requests by designing structures that can accommodate fiber optic cable and by proposing 

to install fiber optic cable as part of the project. 

Other questions or issues raised included: 

• Where structures would be located 

• What the structures would look like 

• Health effects of living near a transmission line 

• Minimizing costs related to environmental impact analysis 

• Ways to minimize impacts to fish and wildlife habitat, species, and water resources 

• How project activities would adversely affect communications facilities 

• The need for reliable power in the Raymond area 

• The historical significance of the line and the availability of an existing structure for 

display. 

These issues are addressed in appropriate sections in the EA. 

BPA released a Preliminary EA for review and comment. The Preliminary EA is posted on the 

BPA website (www.transmission.bpa.gov/projects). During the 2-week review period, BPA 

accepted comments orally, via e-mail, at public meetings, and by letter. Public meetings were 

held in Raymond and Cosmopolis in February of 2003. BPA considered all comments received 

during the review period in preparing the Final EA for the proposed project, and the Final EA 

includes responses to all substantive comments received in Chapter 8. Because the Final EA

provides evidence that impacts from the proposal will not be significant, BPA will then 

determine whether intends to prepare an EIS or a Finding of No Significant Impact (FONSI) for 

the Proposed Action. 
Bonneville Power Administration 2-1 

Chapter 2 

Proposed Action and Alternatives 

2.1 PROPOSED ACTION 

The proposed action (the “Rebuild Project”) involves removing the existing RaymondCosmopolis 115-kV transmission line and replacing it with a new 115-kV transmission line and 

installing fiber optic cable. The transmission line roughly parallels U.S. Route 101 between 

Raymond Substation (about 2 miles north of Raymond, Washington) north to Cosmopolis 

Substation in the southern part of the city of Cosmopolis (Figure 1-1). The Rebuild Project 

would cost approximately six 7 million dollars (2002 2003 dollars). 

The estimated requirements of the proposed action are summarized below. Numbers are subject 

to variation, depending on site-specific characteristics. Details explaining these requirements are 

in Sections 2.1.1 through 2.1.4. 

Corridor length: 18.3 miles 

Right-of-way (ROW) width: generally 50 feet 

New ROW easement acquisition: 

0.25 mile of additional ROW to widen existing 50-foot easement to 70 feet 

0.5 mile (approximately) of additional 50-foot width 

Number of structures removed: 171 

Number of new structures: 

Suspension 98 

Angle 34 

Dead-end 36 

Total: 168 

Number of guyed structures: 17 21

Structure height above ground: 48 50–110 feet 

Structure diameter at base:

 Suspension 31-42 inches 

 Angle and dead-end 55-70 inches 

Structure bases (type and number): 

 Embedded 149 

 Concrete 19 
2-2 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

Initial disturbed area:

 Structure removal 625 sq. ft. each structure (3 acres total)

New structure installation 4,000 sq. ft. per suspension structure (9 acres total) 

 12,500 sq. ft. per angle/dead-end structure (20 acres total) 

 Stringing/tensioning sites 1 acre every 2.5 miles (7 acres total) 

Staging area 5-10 acres

Conductor: non-lustrous (not shiny), 0.8 inch diameter, non-ceramic insulators 

Fiber optic cable: black, dull finish, 0.6 inch diameter 

Overhead ground wire: 0.5 mile out of each substation 

Access roads (12–14 feet wide average): 

 Within the ROW: 

 New roads 0.5 mile 1.7 acres 

 Improve existing roads 2.6 miles 5.7 5.8 acres 

 Outside of the ROW: 

 New roads 0.9 mile 3.1 3.3 acres 

 Improve existing roads 0.9 mile 2.1 acres 

2.1.1 Line Route and Right-of-Way 

Currently there are 171 structures on the Raymond-Cosmopolis line. The existing lattice steel 

structures within the 50-foot ROW are numbered from Structure 1, near Raymond Substation, to 

Structure 167, near Cosmopolis Substation. To the north of Structure 167, two wood pole 

structures, numbered 19/1 and 19/2, lead into the Cosmopolis substation, and two additional 

wood pole structures support conductors near Structures 67 and 69. 

The new line would require 168 structures. Most would be constructed within the existing 

50-foot ROW, usually no more than twelve feet ahead of or behind the existing structures. 

However, 18 structures would be moved more than 12 feet ahead or behind, either to avoid 

wetlands, to move them further from waterways, or to position them outside the Highway 101 

safety control zone. In addition, three two short segments of the transmission line would be 

realigned outside the existing 50-foot ROW and the transmission line would shift to the edge of 

the ROW in one area, as shown in Figure 2-1 and described below. 

• Structures 34 and 35 would be moved to the west, outside the existing ROW, to avoid a 

large wetland area around Structure 35. An additional 1,832 feet of 50-foot ROW would 

be required, part of it within the Washington State Department of Transportation 

(WSDOT) ROW (which does not require an easement), and the rest owned by a private 

timber company. No tree clearing would be required because this area was previously 

logged. 

• Structures 91, 92, 93, and 94 would be moved to the west outside the existing ROW. 

This section would be realigned because Structures 92 and 93 are within the wetlands 
Bonneville Power Administration 2-3 

Figure 2-1. Proposed Realignment of Existing ROW Segments 

FOR SECURITY PURPOSES 

This figure was deleted from the electronic version of this document 
2-4 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

associated with Joe Creek (one structure is surrounded by water on all sides) with no 

access to them. An additional 3,124 feet of 50-foot ROW would be required, most of it 

within the WSDOT ROW (which does not require an easement), and the rest owned by a 

private timber company. Approximately one five acres of forest, which includes both red 

alder stands and conifers, would be cut in the realignment area and some adjacent danger 

trees outside the new ROW. (The acreage estimate increased from the Preliminary EA 

because the timber company that had a permit to cut this area informed BPA in 

May, 2003, that they no longer plan to cut this area, so BPA will need to purchase the 

timber and remove it.)

• Structures 122 to 133 would be moved slightly to the east, from 20 to 40 feet, depending 

on the structure, within the existing 50-foot ROW (the width of the ROW varies in this 

area). They would be moved closer to the existing access road, an old railway grade, in 

order to minimize impacts to the Little North River. Trees that overhang the new 

alignment, and areas of danger trees, would need to be removed or trimmed

(approximately 1.5 acres). 

In addition to the easements required for the three realignment areas described above, BPA 

would need to acquire extra width in one area where strong winds could cause the conductor to 

swing outside the existing ROW. Existing easements for the segment between structures 115 

and 116 (a distance of approximately 1,300 feet) would be widened to 70 feet from the current 

50-foot easement, but no additional clearing would be required.

2.1.2 Structure Design 

The proposed structures consist of a single steel tube that tapers to the top (Figure 2-2). A photo 

simulation of the proposed structures in the landscape is in Section 3.9, Visual Resources

(Figure 3-5). All structures would have the same general appearance but would vary in size 

depending on their function. They are made of galvanized steel, which weathers to a dull finish 

after a few years. There would be three different types of structures: 

• Suspension structures are used where the structures are in a straight alignment or where 

turning angles are small (less than 15 degrees). They are the lightest structures because 

they do not have to withstand the stresses created by angles in the conductor, and they are 

not located at the end of long spans. Of the 168 proposed structures, an estimated 98 

would be suspension structures. 

• Angle structures are located at a point where the line changes direction, generally at an 

angle of 15 degrees or larger. The stress on the structure created by the angle of the 

conductor requires a heavier structure; structure size increases with the size of the angle. 

• Dead-end structures are heavier, stronger structures placed at intervals along the 

transmission line to independently carry the weight and tension of the conductors. Deadend structures may either be in a straight alignment, used at angles greater than 15 

degrees, or on very long spans such as canyon crossings. 

The structure type also depends on whether it has guy wires. Guy wires attach at various points 

along the structure and are anchored at the ground to lend stability to structures subject to stress, 
Bonneville Power Administration 2-5 
2-6 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

such as dead-end or angle structures. Guy wires would be within the ROW, anchored no further 

than 110 feet from a structure. 

Conductors. Alternating current transmission lines, like the proposed transmission line, require 

three conductors to make a complete circuit. The proposed structures have three arms; each 

conductor would attach to one of the arms using non-ceramic insulators. Insulators keep 

conductors a safe distance from other parts of the structure, preventing the electricity in the 

conductor from moving to other conductors, the structure, or the ground. Non-ceramic insulators 

are narrower than the series of disk-shaped ceramic insulators that are most often used on 

transmission lines; non-ceramic insulators are less susceptible to corrosion and damage from 

vandalism. 

Conductors are made from metal and are not covered with insulating material because the 

surrounding air serves as insulation. The conductor would be less than one inch in diameter and 

non-lustrous, which means it is dulled during manufacturing to provide a non-reflective finish. 

One overhead ground wire would be attached to the top of structures for the first half-mile out 

from each substation, to protect the structures and substations from lightning damage. If a 

structure is struck by lightning, the electricity is routed to the ground through the structure. 

Fiber Optic Cable. A fiber optic cable would be added to this transmission line, if Pacific 

County PUD has funding, to provide service to Raymond. It would be attached to structures on 

brackets located beneath the lowest arm. Fiber optic cable is black, dull in finish, and about 0.6 

inches in diameter. The lengths of fiber optic cable are joined in splice boxes, which are 

attached to some structures approximately 20 feet above the ground. 

Two vaults that house fiber optic line components would be installed near the Raymond and 

Cosmopolis substations. Vaults are concrete boxes up to 6 x 6 x 6 feet and are installed either 

above or below the ground. 

2.1.3 Access Roads 

Access to tower sites for construction and maintenance would be needed at various locations 

along the length of the transmission line corridor, both on and off the ROW. Access road 

construction would consist of improvements to existing roads, construction of new roads, and 

construction of approaches to individual tower sites. 

The existing transmission line was built in the 1920s in fairly rugged landscape. In some 

locations, structures were erected without creating permanent access roads. In other areas, 

existing roads would need to be improved to accommodate heavy construction vehicles such as 

cranes and concrete trucks. BPA would need to acquire easements along some existing roads. 

Most of the roads improved or constructed within the ROW would be permanent. BPA prefers 

permanent access to structures in the event of an emergency. In some areas, such as wetlands, 

temporary roads would be constructed for use only during construction. Rock would be placed 

on geotextile, then all materials would be removed once construction is complete. 
Bonneville Power Administration 2-7 

Most roads would be constructed to a finished 12- to 14-foot width, although some would be 

wider to allow vehicles to negotiate curves or bends in the road. 

2.1.4 Construction Activities 

Construction is proposed to begin at the earliest on April 1, 2004 June 1, 2003, and major 

activities would be completed by November 1, 2004 2003, although some tree removal could 

occur in October 2003. The various aspects of the construction process are described below. 

Impacts and mitigation activities are discussed in Chapter 3. 

Removal of Existing Structures. Structure removal would disturb an area approximately 25 

feet by 25 feet per structure, or a total of approximately 3 acres for all structures. Most structures 

would be removed by digging one foot below the ground surface and cutting the tower from the 

base. The existing structures would be lifted onto a truck with a crane and removed from the site 

for recycling or disposal in an appropriate location. Structures with a concrete base would be cut 

at the base, leaving the concrete in place, rather than excavating the concrete. This would be 

done in order to minimize soil disturbance and related environmental impacts. Structures in 

wetlands would be cut at the ground surface and lifted or dragged out to avoid excavation in 

wetlands. 

Installation of New Structures. New structures would either be directly embedded in the soil 

or bolted to a concrete base. Most would be directly embedded, except for structures that require 

extra stability, such as dead-end structures, angle structures that are not guyed, or structures in 

unstable or wet soils. For each direct-embedded structure, a hole would be augered. At first, the 

structure would be in several pieces, and would be brought into the work area on a large truck. 

The bottom piece (the stub) would be inserted into a hole and the hole back-filled with crushed 

rock. For most structures, the soil that is removed by the auger would be spread around the 

structures. However, for the two structures in wetlands, the augered soil would be removed from 

the site (see Section 3.7, Wetlands). 

The stub would protrude above the ground. Depending on structure height, the top portion 

would be assembled on the ground by attaching the arm pieces, then lifted into place. Most 

suspension structures and some guyed angle and dead-end structures would be directly 

embedded.

For concrete-based structures, a steel anchor bolt cage would be placed in the augered hole and 

the hole back-filled with concrete. The concrete base would extend 6-12 inches above the 

ground surface, approximately 18 inches beyond the structure. 

The area disturbed for structure construction depends on the type of structure, the topography, 

access to the structure, and the presence of any sensitive resources in the area that restrict the 

work space. Estimates are shown in Section 2.1, Proposed Action. 

Once the structure is erected, any guy wires that would be used would be installed and anchored 

at the base. Lighter guy wires can be inserted into the ground with screw anchors. Heavier guy 

wires must be anchored, generally with plate anchors—a steel plate that is embedded in concrete 

in the ground. 
2-8 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

The time required to construct a structure varies. Work on the transmission line would be done 

in phases, with construction occurring on more than one structure at a time, in different parts of 

the project area. 

Stringing and Tensioning Conductors. The conductors and fiber optic line would be strung 

from structure to structure through pulleys. Stringing and tensioning is done in several stages. 

Two large trucks, one with reels of conductor and one with tensioning equipment, must be 

positioned within the ROW. Similarly, a truck with reels of fiber optic line and one with 

tensioning equipment would occupy the site to pull and tension the fiber optic line. To avoid 

laying the conductor across roadways while stringing and tensioning, wood-pole H-frame 

structures would be temporarily erected at or near road crossings and on either side of a road. 

The conductor would be draped over these safety structures, enabling traffic to flow unimpeded 

along the roadway. 

The location and number of pulling and tensioning sites is not known at this time; they depend 

on the length of conductor and fiber optic line that is on one reel. Pulling and tensioning 

generally are done at heavier or larger structures such as dead-end or angle structures. An 

estimate of acreage needed for these sites is in Section 2.1, Proposed Action. 

Staging Areas. Staging areas are areas used to stockpile and store the structure pieces, arms, 

conductor spools, and other equipment during construction. There would be two staging areas, 

generally located near one another, covering a total of about five to ten acres. The locations are 

not known, but they would be in industrial/commercial land because a large, vacant, flat area 

would be needed. 

Access Road Construction and Improvement. Roads would be widened, constructed, 

reshaped and/or finished to a 12- or 14-foot running surface width, with a rock or gravel roadbed. 

Road improvements could include grading and placing rock on existing roads. Along some 

existing roads, it would be necessary to clear encroaching or overhanging vegetation within the 

roadbed or along the side of the road (brushing). Cross drains, dip drains, or culverts would be 

installed to improve drainage where needed. Access to the project area would be restricted in 

some areas by installing locked gates at the junction of access roads and public roads. 

2.1.5 Vegetation Management 

Some vegetation management is included in the Rebuild Project. Danger trees would be cut in 

some areas between Structures 118 to 125, totaling approximately 2 acres. This area was not 

included in BPA’s 2002 Danger Tree Removal Project because agreements could not be reached 

with landowners in that area. Some of these trees would need to be cut because the trees would 

hang into the area of the new conductor.

A narrow strip of danger trees would be cut adjacent to the 50-foot wide ROW in the 

realignment area between Structures 90 to 94. The area cut for the ROW and danger trees would 

total approximately 5 acres. The danger tree cutting areas are narrow strips, generally less than 

50 feet wide. In addition, five individual danger trees would be cut near the Joe Creek tributary 

near existing Structures 92 and 93. These danger trees are between 50 to 110 feet from the 

wetlands adjacent to this tributary.
Bonneville Power Administration 2-9 

For long-term vegetation maintenance of the transmission line ROW, BPA would develop and 

implement vegetation management consistent with its Transmission System Vegetation 

Management Program and associated EIS (BPA 2000), incorporated by reference in this EA. 

Under vegetation maintenance criteria, no tall-growing vegetation would be allowed to grow 

inside the ROW except for vegetation in deep canyons when it would not interfere with the much 

higher conductor. Healthy, stable trees outside the ROW would be left in place, unless removal 

of adjacent trees would make them vulnerable to wind damage. Only those trees that are leaning 

toward the transmission line, are dead, or otherwise pose a potential threat would be removed. 

BPA maintenance crews would be responsible for managing vegetation consistent with the 

maintenance criteria. 

2.2 NO ACTION ALTERNATIVE 

The No Action Alternative is usually defined as the status quo alternative. In this case, the No 

Action Alternative assumes that BPA would not rebuild the transmission line and would 

continue to operate and maintain the existing transmission line. Construction activities 

associated with the Rebuild Project would not occur, and the reliability and safety concerns that 

prompted the proposal for action would continue to be of concern. Fiber optic cable service to 

Raymond would not be provided. However, maintenance activities would continue within the 

corridor for the existing line. Given the line’s current poor condition (see Section 1.2), it is 

reasonable to expect that the No Action Alternative would result in more frequent and more 

disruptive maintenance activities within the corridor than under the proposed project. 

2.3 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM 

DETAILED STUDY 

2.3.1 Route Alternatives 

Examination of the project area indicated no other usable corridors between Raymond and 

Cosmopolis. The environmental impacts of locating the transmission line in an undeveloped 

corridor, versus in an already developed corridor, would be substantially greater because new 

ROW would have to be cleared and new roads constructed, which could lead to a variety of 

changes in land use and habitat for the length of the line. Direct costs also would be 

substantially higher due to the costs of the new clearing and roads, as well as the new easement 

rights that would need to be obtained. 

2.3.2 Installing New Conductor Using Existing Structures 

BPA considered using the existing structures to support a new higher-capacity conductor. 

Because the line was built in the 1920s by another utility, BPA does not have engineering design 

criteria that document the design strength and structural integrity of the existing structures. Due 

to the size and poor condition of the existing structures, BPA structural engineers concluded that 

they would not be able to safely support the new conductor and meet National Electric Safety 

Code standards. 
2-10 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

2.4 COMPARISON OF ALTERNATIVES 

Table 2-1 compares how well the Proposed Action and No Action Alternative meet the purposes 

(goals) of the project defined in Section 1.3, Purposes of Action. Detailed analysis of the 

environmental impacts is in Chapter 3. 

Table 2-1. Comparison of the Proposed Action and No Action Alternatives 

Purpose Proposed Action No Action 

Meet transmission 

system public safety and 

reliability standards set 

by the National 

Electrical Safety Code 

Meets both public safety (conductor 

distance from ground) and maintenance of 

service standards during outages of other 

lines in the area. 

– Does not allow maintenance 

of service during outages of 

certain other lines in the area. 

– Risks public safety during 

outages due to excessive 

conductor sag. 

Minimize environmental 

impacts

Construction impacts would be low to 

moderate, primarily short-term, and mostly 

can be mitigated. See Table 3-1 for a 

summary, Chapter 3 for a full discussion. 

Avoids construction impacts 

but maintenance impacts would 

increase as existing structures 

and roads deteriorate. See 

Table 3-1 for summary and 

Chapter 3 for details. 

Improve safety for 

transmission line 

workers

– Would reduce the need for maintenance 

during severe weather conditions. 

– Deteriorating and unstable structures 

would be replaced with stable structures. 

– Structures with no access would be 

relocated to provide access, making it 

easier and safer to reach structures during 

emergencies. 

Continues risks to worker 

safety from maintenance during 

severe weather conditions and 

from deteriorating and unstable 

structures and lack of access.

Minimize costs – Direct construction Total project costs: 

approximately $7 6 million. 

– Reduces maintenance costs. 

– Avoids materials and 

construction costs. 

– Incurs maintenance costs 

higher than proposed action. 

Use facilities and 

resources efficiently

– Avoids continued use of financial and 

human resources on maintenance of 

unsound structures. 

– Provides multi-use structures to improve 

local technological infrastructure (fiber 

optic line installation funded by Pacific 

County PUD if funds are available). 

– Existing unsound structures 

require more than normal 

maintenance, an inefficient use 

of resources. 

– No opportunity to use 

existing structures to improve 

local technological 

infrastructure. 
Bonneville Power Administration 3-1 

Chapter 3 

Affected Environment, Environmental Consequences, 

and Mitigation 

3.1 INTRODUCTION 

This chapter evaluates the potential impacts of the proposal and the no action alternative on 

human and natural resources to determine whether the proposed action has the potential to cause 

significant environmental effects. For each resource, the chapter describes the existing 

environment that would be affected by the alternatives, the environmental impacts of the 

alternatives, and mitigation. To evaluate potential impacts from construction, operation, and 

maintenance activities, four impact levels were used—high, moderate, low, and no impact. High 

impacts are considered to be significant impacts, while moderate and low impacts are not. 

Definitions of the impact levels vary with each resource and are provided in Appendix A. 

Both direct and indirect impacts were evaluated. Direct impacts are those that would occur 

within or next to the corridor during a construction activity and would have an immediate effect 

on the environmental resource being evaluated. For example, removal of vegetation used for 

foraging or refuge would constitute a direct impact on wildlife. Generally, direct impacts from 

the alternatives would be confined to the existing corridor, except in those areas where access 

road improvements are planned outside the corridor. Indirect impacts are those that would occur 

after a construction activity, or in an area adjacent to construction activities or outside the 

corridor. For example, the introduction of noxious weeds following the removal of vegetation 

that results in lower quality habitat for wildlife would be an indirect impact. If the affected 

environment for a specific natural or other resource extends beyond the general limits of the 

existing corridor, it is noted under the specific resource. 

The impact analysis lists mitigation that could reduce impacts and discusses cumulative effects 

of the proposal when combined with impacts from past, present, and/or foreseeable future 

projects in the area. If no cumulative impacts are expected, none are listed. 

The impacts of the No Action Alternative are discussed in the final part of each resource section. 

The location of an affected resource may be identified by structure number and local landmarks. 

Structure numbers refer to specific existing structures; numbering proceeds from south to north. 

Local landmarks used are county roads, parks, and other features. 

Table 3-1 is a summary of the impacts described in detail in the remainder of the chapter. 
3-2 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

Table 3-1. Summary of Impacts of the Proposed Action and No Action 

 Alternatives 

Environmental 

Resource 

Proposed Action No Action 

Alternative 

Land Use – Tree cutting on approximately 6 13 acres (for new 

roads, brushing of existing roads, danger tree removal, 

and tree clearing in realignment areas) and

– Withdrawal of approximately 10 acres from timber 

production. 

– Localized and temporary disruption of residential use, 

recreation, and traffic. 

Occasional but 

infrequent disruption of 

residential use or traffic 

during maintenance of 

the existing line. 

Geology and 

Soils 

– Short-term increases in erosion and run-off from 

clearing and soil disturbance during removal of old 

structures and construction of new ones. 

– Soil compaction by heavy equipment during 

construction and tree removal. 

– Localized soil disturbance, erosion and compaction 

during maintenance. 

Continued or slightly 

increased levels of 

localized soil 

disturbance, erosion 

and compaction 

associated with 

maintenance. 

Vegetation – Short-term removal/crushing of vegetation from 

construction activities. 

– About 3.1 5 acres of forest permanently removed for 

new road construction, about 1 5 acres removed for 

realignment areas, and 2 acres for danger tree removal.

– About 0.2 acre vegetation permanently removed for 

structures bases. 

– Up to one acre of vegetation removed during brushing 

of existing roads as part of road improvements. 

– Weeds, mainly Scot’s broom, thistles, and reed 

canarygrass, could colonize disturbed areas. 

Continued or slightly 

increased levels of 

vegetation removal, 

including periodic 

danger tree removal 

outside the ROW and 

cutting of tall-growing 

vegetation within the 

ROW. 

Fish and Wildlife – Localized and temporary disruption of fish and wildlife 

from construction noise. 

– Potential effects on fish and prey organisms from 

increases in stream turbidity and temperature due to 

construction activity and tree removal near streams. 

– Six Seven acres of existing or potential forest in 

realignment areas remain shrub dominated; about 3.1 6 

acres of forest habitat removed for new and improved 

access roads and 0.2 acres for structure bases 

permanently removed. 

– Moderate direct impacts on marbled murrelets from 

noise-producing activities near nest sites during the late 

breeding season, but reduced by restrictions on 

construction noise and timing.

– Moderate indirect impacts on marbled murrelets 

resulting from some degradation of remaining habitat in 

three areas where some tree trimming and tree removal is 

proposed at the edge of habitat areas.

Continued or slightly 

increased temporary 

disturbance to fish and 

wildlife associated with 

maintenance of the 

existing line, including 

moderate, indirect 

impacts on marbled 

murrelet from noiseproducing activities 

near nest sites. 
Bonneville Power Administration 3-3 

Environmental 

Resource 

Proposed Action No Action 

Alternative 

Water Quality – Temporary decrease in surface water quality from 

short-term increases in erosion and run-off rates and 

sedimentation due to construction, decreased shade due to 

tree removal could raise water temperatures, and 

maintenance. 

– Minor effects on ground water quality from small 

reduction in infiltration capacity. 

– Potential low impact from chemical spills (e.g., 

petroleum products used during construction). 

Continued short-term 

increases in erosion, 

run-off rates and 

sedimentation from 

periodic maintenance 

activities, with a 

possible increase in the 

number of incidents. 

Wetlands – Temporary and low level of impacts to wetlands from 

removing 9 structures in wetlands and 20 structures near 

wetlands. 

– Temporary and moderate impacts to wetlands from 

installing 2 new structures in wetlands and 19 structures 

near wetlands, including 0.43 0.30 acres of temporary fill. 

– Minor permanent impacts to wetlands from depositing 

0.08 0.018 acres of fill for a ford roads and the two 

structures in wetlands. 

– Indirect impacts to wetlands from adjacent construction 

activity. 

Continued disturbance 

to wetlands associated 

with maintenance, with 

possible increased 

levels where structures 

remain in wetlands 

with no access. 

Floodplains – Temporary and localized alteration of floodplain 

functions by removing 6 structures and erecting 4 

structures in floodplains. 

– Minor effects from deposition of up to 100 cubic yards 

of fill in floodplains for structure construction. 

– Minimal effect on floodplain functions due to 

improvements to existing access roads. 

Continued disturbance 

to floodplains at 

existing levels. 

Visual Quality – Minor visual impacts to motorists, residents, and 

recreationists; views may be improved for some if they 

prefer the look of the new structures to the old ones. 

– Intermittent and moderate impacts on motorists along 

two sections of Highway 101 classified as scenic 

highway. 

Continued visual 

impacts of the existing 

transmission line for 

motorists, residents, 

and recreationists. 

Air Quality – Short-term increase in pollutant levels, mainly 

particulates, during construction. 

Continued minor 

impacts. 

Socioeconomics – Minimal impact on housing availability to meet 

construction worker needs. 

– Short-term beneficial impact on employment and local 

sales tax revenues during construction. 

– Low potential for trespass and vandalism to homes and 

businesses. 

– Potential long-term contribution to economic growth 

from reliable power and access to high-speed 

communications. 

No impacts expected. 

Cultural 

Resources 

– No historical or archaeological resources found; 

therefore, no impacts expected. 

No impacts expected. 
3-4 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

Environmental 

Resource 

Proposed Action No Action 

Alternative 

Public Health and 

Safety 

– Potential risk of fire and injury with the use of heavy 

equipment, helicopters, and fuel; traffic safety issues 

during construction activities. 

– Low potential for nuisance shocks. 

– Electric fields comparable to the existing line; magnetic 

fields lower. 

Electric and magnetic 

fields would remain the 

same. 

Noise – During daytime hours, short-term noise impacts from 

construction activity for approximately 35 residences. 

Short-term noise 

impacts to residents 

from maintenance 

activity. 

3.2 LAND USE 

3.2.1 Affected Environment 

The area considered for the land use analysis includes the existing transmission line corridor and 

land up to 1,200 feet on either side of the existing corridor. Land uses along the corridor 

(Figure 3-1) include private and public forest lands used for timber production, some rural 

residences, recreation, and transportation [Highway 101 (U.S. Route 101)]. Most of the land is 

privately owned (Figure 1-1); the Weyerhaeuser Company is the largest landowner. Public lands 

adjacent to the corridor include forest land and the Butte Creek Picnic Area, both managed by 

the Washington State Department of Natural Resources (WDNR), and a small parcel of forest 

land southeast of Cosmopolis owned by Grays Harbor County. 

Forestry

The corridor passes through forest used for timber production for most of its length, and timber 

production activities are evident throughout the project area. Private forest lands within Grays 

Harbor and Pacific counties produce a significant amount of timber. In 2000, Grays Harbor 

County produced 531,731,000 board feet of timber and Pacific County produced 341,212,000 

board feet, ranking one and two, respectively, in terms of timber production within the state 

(WDNR 2002b). Grays Harbor and Pacific counties account for 16.5 percent (1,577,000 acres) 

of timber land in western Washington (USDA Forest Service 1997). The predominant species 

harvested are western hemlock and Douglas fir. 

Recreation

Three recreation areas are located near the corridor. Butte Creek Picnic Area, managed by 

WDNR, is located just north of the Raymond Substation between Highway 101 and the 

transmission line ROW. This day-use facility includes picnic tables, restrooms, water supply,

and hiking trails, and views of old-growth timber. It is generally open only during the summer. 

An estimated 50 to 100 visitors use the picnic area weekly (Estep 2002). 

Mill Creek Park is within the City of Cosmopolis, approximately 1,200 feet northwest of the 

Cosmopolis Substation. It includes restrooms, playground equipment, picnic tables, tennis 

courts, and a pond that is stocked year-round with fish. During summer months approximately 

50 to 75 people per day use the park (Raines 2002). The substation is not visible from the park. 
Bonneville Power Administration 3-5 

Figure 3-1. Land Use 

FOR SECURITY PURPOSES 

This figure was deleted from the electronic version of this document 
3-6 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

Highland Public Golf Course, a privately owned 18-hole course, is located adjacent to the 

Cosmopolis Substation and the corridor north of Structure 166. 

Residential Use

There are few residences along the corridor near Highway 101. Most residences occur in 

clusters between Structures 21 and 28, 36 and 38, 46 and 49, 115 and 122, 131 and 133, 140 and 

143. The largest cluster is between Lund Road and Artic Road (structures 115 to 122). Some 

existing transmission structures are in the yards of residences. 

Transportation

The corridor closely parallels Highway 101 for approximately one-half its length, and it crosses 

Highway 101 seven times. Highway 101 is the principal coastal transportation route between 

Oregon and the Olympic Peninsula, and is heavily used by tourists, local residents, and logging 

trucks. The average daily traffic volume is 5,500 vehicles near the south end of the corridor and 

4,400 vehicles near the north end (WSDOT 2001). 

Plans and Policies Affecting Land Use

Within Pacific County, the corridor is zoned as rural residential land. This zone is intended to 

promote and protect low-density rural residential areas that exist in harmony with the natural 

environment. Density is limited to one dwelling per acre. Aside from residential areas near the 

corridor, the predominant land use is timber production. Pacific County’s code does not 

specifically address utility corridors. 

Within Grays Harbor County, a county land use map designates the corridor “General 

Development.” There is no written comprehensive plan for this part of the county. The zoning 

is General Development 5 District (G-5), which permits a wide range of uses appropriate for that 

district at densities consistent with the level of available public facilities, public services, and the 

physical characteristics of the area. This zone allows dams, electrical power plants, flowage 

areas, transmission lines, and substations together with necessary accessory buildings. 

The Cosmopolis Substation is located on land designated and zoned Mixed-Use (MU). This 

zone permits residential and commercial uses. It is immediately adjacent to lands zoned for 

industrial and Public Preserve (Highland Public Golf Course). The City’s Comprehensive Plan 

and Zoning do not specifically address utility corridors. For more information on consistency 

with local plans and policies, see Section 4.5. 

WSDOT classifies two sections of Highway 101 as having high scenic value (Class BX) (WAC 

468-34-330), but transmission lines can be allowed. The sections are between milepost 66.2 and 

70.9 and between 77.0 and 78.5 (structures 48 to 95 and 150 to 165). The classification is 

intended to influence land uses along scenic highways (see Section 3.9, Visual Resources). 

3.2.2 Environmental Consequences—Proposed Action 

Forestry

For all construction, including access roads and realignment areas and danger tree removal, the 

proposed project would require cutting trees on approximately 6 13 acres of forest managed for 
Bonneville Power Administration 3-7 

timber production. Including areas that already have been cut or were slated for cutting by a 

private timber company, approximately 10 acres total would be permanently withdrawn from 

timber production to meet road or ROW needs of the line. This is considered to be a low impact 

because less than 0.1% of the county’s timber base would be affected. 

There would be no other direct or indirect impacts on timber producing lands because all other 

construction and operation activities would be entirely within the existing ROW, on existing 

access roads that would not result in displacement of forest land, accessed from Highway 101, or 

would take place on non-forest land. Widening 1,300 feet of the existing easement from 50 feet 

wide to 70 feet wide to accommodate swing in the conductor will be a low impact because of the

minimal restrictions and the rural nature of the area restricted.

Recreation

Recreational use could be affected by construction activities. Access to Structures 3 to 6 would 

be from the Butte Creek Picnic Area access road. These construction activities could require the 

temporary closing of the park or interfere with its use (Estep 2002). Road work would be done 

between August 5 and September 15; structure construction could not begin until after 

September 15, due to marbled murrelet restrictions (see Section 3.5.3, Fish and Wildlife). 

During these periods, vehicles would go in and out fairly regularly, but traffic would not be 

steady. Construction impacts on recreation at the Butte Creek Picnic Area would be moderate 

because there is the potential for frequent interference. During operation and maintenance, 

vehicles and equipment using the picnic area’s access road could delay or obstruct recreational 

use on an intermittent, infrequent basis. 

Similarly, construction activities could interfere with access to the Highland Public Golf Course 

because the transmission line crosses the golf course’s paved access road on its approach to 

Cosmopolis Substation. A new access road would be built from the golf course parking lot to the 

ROW. There would be no direct interference with use of the golf course during operation and 

maintenance. Overall impacts to the golf course would be low. Construction and operation 

would not interfere with use of Mill Creek Park. 

Residential Use

Construction, operation, and maintenance would be limited to brief, temporary disturbance in 

most instances because most construction activities would take place on existing ROW and 

access roads. Impacts to residents near but not immediately adjacent to the corridor would be 

limited to temporary inconveniences associated with traffic delays on Highway 101, and to dust 

and noise from, as well as the presence of, construction activity, including tree removal activities 

near one residence south of North River Road. 

Where construction activities take place within the “active” portions of private property, such as 

front yards or driveways, temporary and intermittent noise, dust, and interference with access to 

homes could cause a moderate impact on homeowners. Locations most likely to experience 

these effects are near Structures 22, 23, 38, 47, 115, and 121. Structures 22, 23, and 115 are in 

front yards of residential properties adjacent to Highway 101. Replacement of these structures 

would result in disturbance of up to 4,000 square feet each. Access to Structures 38 and 121 may 

temporarily interfere with use of driveways. At Structure 46, the line crosses to the west side of 
3-8 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

Highway 101, to Structure 47, which is in the middle of a residence’s mowed lawn. 

Replacement of Structure 47 could disturb up to 4,000 square feet of this lawn. Additional 

mowed lawn would be disturbed temporarily by a temporary rock road that would be laid down 

so that equipment could gain access to structures 47 and 48. Due to other physical constraints 

such as wetlands or span lengths, structure locations could not be moved from these front yards. 

Transportation

Construction activities near highway crossings may cause brief traffic delays. Sixty-four 

structures would be close to Highway 101, likely requiring one-lane traffic in short sections. 

Impacts to transportation from project construction would be short-term and moderate. 

Maintenance vehicles and activities would not disrupt the flow of traffic. 

Plans and Policies Affecting Land Use

The proposed project is consistent with the land use plans, policies, and zoning of Pacific and 

Grays Harbor counties and the City of Cosmopolis (see Section 3.2.1, Land Use). Although 

construction activities could detract from the high scenic values of the designated sections of 

Highway 101, transmission lines are allowed along those sections. 

3.2.3 Mitigation 

If the project is implemented, the following mitigation would be used to reduce potential impacts 

to land use from the project: 

• BPA’s Project Manager will be available to meet with concerned landowners to discuss 

issues and concerns. 

• A proposed schedule of construction activities will be distributed to all potentially 

affected landowners along the corridor so they know when they might experience 

construction-related disruptions. 

• BPA will prepare a notice about construction activities and a proposed schedule, for 

posting on the WSDOT Traffic Advisory. 

• Traffic safety signs and flaggers will be used to inform motorists and manage traffic 

during construction activities along Highway 101. 

• Construction activities and equipment will be kept clear of residential driveways as much 

as possible. 

• Disturbed areas will be revegetated with native seed, except in residential areas, where 

property owners will be consulted on plant selection. 

3.2.4 Unavoidable Impacts Remaining After Mitigation 

Some short-term construction impacts would be unavoidable, such as interference with 

residential activities and recreational use, traffic delays, and noise and dust for those close to 

construction activity. They would cease once construction is completed. The proposed action 

would not change existing land uses for the long term except where new access roads cross 

timber land (approximately 3 acres), within the realignment areas (approximately 7 acres), and 

where use is restricted on the 1,300 feet of wider easement proposed for acquisition. Operation 

and maintenance activities would have a low impact on land use because they would not disrupt 
Bonneville Power Administration 3-9 

the flow of traffic and would have very little impact on forestry, recreational use, or residents. 

Thus, the unavoidable impacts remaining after mitigation are expected to be low to moderate.

3.2.5 Cumulative Impacts 

The activities associated with BPA’s danger tree removal project and road maintenance in the 

summer and fall of 2002 contributed to increased traffic and traffic disruption as well as 

nuisance-type impacts on residential use. Private forest lands near and adjacent to the corridor 

will continue to be harvested and replanted over time. These operations would cause nuisance 

impacts to nearby areas similar to the noise and dust from the proposed transmission line 

construction, could disrupt traffic, and would temporarily alter the look of the land until it is 

replanted. Although there are no known maintenance or construction projects planned along 

Highway 101 during the construction of the proposed project, paving from Raymond to the 

Pacific county line near Structure 58 is planned for 2005 to 2006 and a proposed culvert and 

bridge replacement project could receive funding in the near future. This activity could once 

again cause delays to highway users, with only a year’s respite. The additional traffic, noise, and 

dust caused by BPA’s proposed project would add to irritants already caused or planned by BPA 

and others in the area, but the proposal’s contribution to these cumulative effects is very minor. 

BPA’s road maintenance project was conducted within the existing ROW and did not contribute 

to changes in land use. Timber harvest and other development activities have changed and will 

continue to change land use in the project area. Compared to these activities, land use changes 

caused by BPA’s project will be barely noticeable because the vast majority of the ROW has 

already been cleared; the few acres disturbed by tower installation and other construction 

activities will add only a minor amount to the total disturbed land in the area. 

3.2.6 Environmental Consequences—No Action Alternative 

Construction-related impacts would not occur. Only intermittent impacts such as noise, dust, and 

the intrusion caused by the activity itself would occur during maintenance of the existing line. 

3.3 GEOLOGY AND SOILS 

3.3.1 Affected Environment 

Located in the Willapa Hills, the project area is hilly and dissected by many steep-sided 

drainages. Three geological formations, all marine sedimentary rocks, underlie the project area. 

Soils primarily are those developed in accumulated rock debris at the base of steep slopes 

(colluvium); alluvial materials associated with drainages such as the North River, South Creek, 

and Elkhorn Creek; and soils derived from glacial materials at the extreme northwestern end of 

the project area (Pringle 1986). 

The separation of different layers of sedimentary rock along weathered siltstone beds is a 

primary mechanism of landsliding in the geological formation found in the northern third of the 

project area (West et al. 1980). A 2001 study evaluated slope stability along three portions of the 

transmission line (Shannon & Wilson 2001). These portions covered just over 3 miles of the 

18-mile project area. An active landslide was described adjacent to a steep-banked creek just 

south of Structure 10. Three landslides have occurred on slopes of 40 to 70 percent in the 
3-10 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

vicinity of Structure 97. Several old landslides and localized erosion and sloughing were 

observed at several locations between Structures 147 and 167. Additional studies were 

conducted in July and September 2002 (Shannon & Wilson 2002). Although evidence of 

landslides or slope movement was observed near some structure sites, the overall conclusion was 

that generally stable slope conditions are present along most of the transmission line ROW. 

3.3.2 Environmental Consequences—Proposed Action 

Removal of Existing and Installation of New Structures

The impact on soils from these activities is expected to be low to moderate. Direct impacts on 

soils could result from clearing of vegetation, grading, and compaction of soils by heavy 

equipment. Clearing and grading, commonly with a bulldozer, strips both vegetation and the 

uppermost, most biologically active portion of the soil. Loss of plants and soil disrupts 

biological functions, including nutrient retention and recycling, and thus reduces productivity at 

least temporarily. Compaction from heavy equipment degrades soil structure, reducing pore 

space needed to retain moisture and promote gas exchange, which is important for respiration 

and other metabolic functions of soil organisms. The extent of impacts at any one site would 

depend on the quality of soils, the amount of moisture in the soils, the amount of surface water 

flowing across the site, the steepness of slopes and, for new structures, the type of structure 

erected and whether guy wires would need to be anchored. The removal of trees within and 

adjacent to the ROW would result in low to moderate impacts due to the small area affected by 

tree removal.

Because most existing structures would be cut just below the base, effects on soils would be 

localized to structure locations. Structures in wetlands would be cut above ground, resulting in 

little to no impact to soils. For new structures, there would be minimal disturbance to soils 

resulting in minor sheet erosion and occasional small channels. 

The indirect impact on soils via erosion is expected to be low to moderate. Minor gullying and 

other erosion could occur if soils were left bare or were slow to grow new plant cover after 

mulching and seeding. The risk of erosion would be highest on steep slopes and during heavy 

rainfall. Mulching and prompt seeding or replanting of bare soils would reduce erosion and help 

disturbed sites recover more quickly. 

Access Roads

Portions of existing roads would be cleared of encroaching vegetation, graded, covered with 

crushed rock, and provided with better drainage, including new culverts. The direct impact on 

soils from this work is expected to be low to moderate. The areas at greatest risk of soil erosion 

are steep slopes. Routes to a few structures appear to lead up steep, overgrown terrain that 

would incur direct impacts from clearing, grading, and cutting and filling to accommodate 

construction equipment. Within the ROW, 144 structures stand in areas with soils mapped at 30 

percent slopes or less, and 27 stand in areas having soils on slopes of 30 to 65 percent. Only a 

few short lengths of road are to be improved in areas of steep slopes. 

Approximately 1.4 miles of new road would be constructed to provide access to structures and 

3.5 miles of roads would be improved. The new roads would convert approximately 4.8 5.0 
Bonneville Power Administration 3-11 

acres of land now covered by trees, shrubs, and herbaceous plants to road surfaces. Tree 

removal in areas adjacent to new roads would disturb up to 1 acre of land that would be allowed 

to re-grow. Direct impacts on soils would include compaction and severe loss or elimination of 

most natural biological functions. 

To install culverts under new roads, soils would be excavated, and excavations would be 

backfilled in a trench slightly longer than the road width. Only limited and minor erosion would 

be likely, a low impact. 

The indirect impact on soils from road work and culvert installation is expected to be low to 

moderate. The project area receives at least 80 inches of precipitation a year, most of it in 

winter. Erosion could be moderate during the rainy season, especially on steep slopes where 

clearing and grading are required. An estimated 0.57 mile of new road to access structures lies 

in areas of greater than 20 percent slopes. The potential for erosion would be greatest just after 

construction, before damaged or cleared vegetation is restored and bare soils are stabilized. 

Tensioning Sites

The direct impact of tensioning sites on soils is expected to be low. Up to 7 acres of vegetation 

would be cleared or crushed at these sites. Vehicles and other equipment may compact soils in a 

limited area. The indirect impact of subsequent erosion is expected to be low, because 

tensioning sites would be on more level ground, in use for a short time, and would then be 

revegetated. 

Operation and Maintenance

Maintenance of the corridor would require incidental repairs to access roads and management of 

vegetation, which could cause localized soil disturbance. In most cases, operation and 

maintenance would have a low direct impact on soils because the areas affected would be small, 

confined to the area of a particular maintenance action, and dispersed both in time and along the 

length of the corridor. Danger tree removal could result in low to moderate impacts due to 

clearing, grading, soil compaction, and erosion. 

3.3.3 Mitigation 

If the project is implemented, the following mitigation measures, used alone or in combination, 

will be used to reduce the adverse impacts on soils, landforms, and other resources: 

• Existing structures within 50 feet of waterways will be cut at the base rather than 

excavated the ground surface rather than cut 2 feet below the ground surface, to minimize 

soil disturbance. 

• Structures and new roads will be located as far as possible from nearby streams and 

wetlands. 

• Culverts, cross-drains, and water bars will be spaced and sized properly. 

• To minimize erosion, sedimentation, and soil compaction as much work as possible will 

be conducted during the dry season, when stream flow, rainfall, and runoff are low. 

• In disturbed areas, mechanical barriers to erosion, as specified in the Storm Water and 

Pollution Prevention (SWPP) Plan, will be used. 
3-12 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

• Vegetative buffers will be retained where possible to prevent sediment from eroding into 

water bodies. 

• Construction activities and equipment will be kept clear of residential driveways as much 

as possible.

• Disturbed areas will be revegetated with native seed. 

• After construction, access roads, culverts, and other facilities will be inspected and 

maintained to ensure proper function and nominal erosion levels. 

• Revegetation work and sites will be inspected to verify adequate growth; implement 

contingency measures as needed. 

3.3.4 Unavoidable Impacts Remaining After Mitigation 

The mitigation measures described above would reduce unavoidable impacts to low or moderate 

levels. Long-term impacts remaining after mitigation would be limited to soil compaction, 

erosion of formerly vegetated ground, and loss or elimination of most natural biological 

functions from some access roads needed to reach currently isolated structures. 

3.3.5 Cumulative Impacts 

The principal past and ongoing activities that affect soils in the vicinity of the proposed project 

are related to timber production. Much of the land adjacent to the ROW is managed for 

silviculture by private timber companies. A network of logging roads covers the landscape and 

facilitates the harvest of plantation-grown conifers. The area is sparsely developed, consisting of 

scattered clusters of rural residences. Few paved roads intersect with Highway 101 within the 

project area. 

The Washington State Department of Transportation (WSDOT) has scheduled improvements to 

Highway 101 within the project area over the next few years. The planned improvements 

include paving 4.4 miles of existing roadway south of the town of Artic and adding guard rails, a 

culvert replacement, and a bridge replacement. This could cause some compaction and erosion 

of soils within the existing road ROW (Ambrosino 2002). 

The removal of danger trees along the transmission line ROW in summer of 2002 resulted in 

compaction of soils by heavy equipment and scarification of soil surfaces during logging 

operations. BPA also replaced eight culverts with seven culverts and one bridge, and graded 

some access roads. Some danger tree logging was on moderate to steep slopes and across or up 

to the edges of streams. Best Management Practices (BMPs) for the BPA danger tree removal 

project, including mulching, matting, and hydroseeding, reduced the impact on soils. 

BPA’s proposal to rebuild the transmission line would add only minor, mostly temporary effects 

on soils to the much more widespread effects from timber production. 

3.3.6 Environmental Consequences—No Action Alternative 

Construction impacts would be avoided. Continued operation and maintenance of the existing 

transmission line would have low to moderate impacts (mainly compaction and erosion) on soils 

from vegetation maintenance, incidental use of access roads, improvement of existing roads, and 
Bonneville Power Administration 3-13 

construction of new roads, if needed to reach structures for which there is currently no access. 

No new impacts on soils are expected under this alternative. The increasing amount of 

maintenance that would be likely as existing structures deteriorate could lead to more erosion 

and compaction than currently experienced. 

3.4 VEGETATION 

3.4.1 Affected Environment 

The vegetation in the project area is influenced by the topography, climate, soils, and current and 

past human activities. It is in a transition area between the coastal Sitka Spruce Zone and the 

Western Hemlock Zone. The Western Hemlock Zone dominates the foothills and lowlands west 

of the Cascade Mountains (Franklin and Dyrness 1988; Cassidy et al. 2002). The project area 

has been defined more broadly for wildlife habitat as part of the Westside Lowlands ConiferHardwood Forest, the most extensive habitat type in the lowlands west of the Cascade Mountains 

(Johnson and O’Neil 2001). 

Elevations in the area are relatively low, ranging from about 80 feet to 500 feet above sea level. 

Moist air from the Pacific Ocean, 20 miles to the west, moderates temperatures and produces a 

mild, wet climate with a long growing season. The area receives from 80 to more than 100 

inches of precipitation annually, 80 percent of which falls from October through March. 

Summers are relatively dry (Pringle 1986). 

Table B-1 in Appendix B lists plant species that are common in the ROW. Forest stands along 

the ROW range from seedling-sapling to mature saw timber, with a few patches of older trees. 

The largest old-growth stand adjacent to the ROW is located within the Butte Creek Picnic Area, 

near Raymond. 

Most of the forested areas adjacent to the ROW are mixed coniferous forest dominated by 

western hemlock, Douglas fir, and Sitka spruce. Western red cedar is present in some stands but 

is not common. Salal, sword fern, and deer fern are common on the forest floor (understory), 

with limited cover by cascara, red huckleberry, and vine maple. 

Pacific blackberry, bracken fern, red elderberry, and cascara are common in open and disturbed 

sites, such as in the ROW. Plant species commonly found in wetlands and riparian (streamside) 

areas include Sitka spruce, red alder, salmonberry, skunk cabbage, small-fruited bulrush, and 

slough sedge. Although relatively few non-native species are found in most of the ROW, 

patches of reed canarygrass occur in disturbed wetlands. In drier, open areas, non-native species 

include Himalayan and evergreen blackberry, Scot’s broom (also known as Scotch broom), and 

foxglove. 

The transmission line corridor crosses heavily forested timber lands owned by private timber 

companies. Silvicultural practices, along with road construction and some residential 

development, cause the major changes to the project area’s vegetation today. Human actions 

have resulted in less diverse plant communities. Wind is the primary natural disturbance 

mechanism, but events causing severe damage are infrequent (Johnson and O’Neil 2001). 
3-14 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

Noxious Weeds

Noxious weeds are non-native plants that have been designated as undesirable plants by Federal 

law or noxious weeds by state law. Noxious weeds can degrade farm and rangeland, injure 

people and animals, and threaten native plant communities by displacing native species and 

decreasing species diversity. Many weeds do not bind soil well and so contribute to erosion. 

County noxious weed control boards bear the main responsibility under Washington State law 

for directing efforts to control noxious weeds and were contacted for information on weed 

species of concern in the project area. Washington State law requires that Class A noxious 

weeds be eradicated, Class B noxious weeds be controlled or designated for control, and Class C 

noxious weeds be controlled on a local basis, depending on threats and the feasibility of control. 

A noxious weed survey of the existing transmission line corridor was done in the summer of 

2002. Noxious weeds found in multiple locations include St. Johnswort, Scot’s broom, common 

tansy, tansy ragwort, reed canarygrass, Canada thistle, and bull thistle. Japanese knotweed was 

observed near the transmission line corridor in several areas. One individual of diffuse 

knapweed, found on the ROW near Cosmopolis, was destroyed. 

All weed species found in the project area are Class C weeds, except for diffuse knapweed and 

tansy ragwort, which are Class B species. In both Pacific and Grays Harbor counties, control of 

diffuse knapweed is mandatory. Tansy ragwort is a Class B “Select” weed in Pacific County, 

which has assigned highest priority to its control. 

Rare Plants

No Federally-listed, proposed, or candidate plant species are known to occur in the project area. 

Two Federal “species of concern” are known to occur in either Pacific County or Grays Harbor 

County. White-top aster is recorded for Grays Harbor County and frigid shooting star is 

recorded for Pacific County (Washington Natural Heritage Program 2002). Neither plant was 

observed by botanists during field visits in the summer of 2002, nor was habitat for either plant 

observed. 

The transmission line crosses land owned by the WDNR near Butte Creek north of Raymond. 

The Washington Natural Heritage Program, which maintains a database of sites where rare 

species are known to occur, has no record of Washington state-designated rare plant species 

within at least one mile of the project area (Estep 2002). Specifically, no occurrences of rare 

plants are recorded in the Butte Creek parcel (Caplow 2002), and no observations of state-listed 

plants were made by botanists who surveyed the area adjacent to the Butte Creek Picnic Area 

during site visits in the spring and summer of 2002. 

3.4.2 Environmental Consequences—Proposed Action 

Removal of Existing Structures and Installation of New Structures

The direct impact on plants of these activities is likely to be low to moderate. Construction could 

result in clearing and crushing of vegetation, damage to plant roots from compaction of soils by 

heavy equipment, and soil disturbance. The extent of direct impacts at any one site would 

depend on the quality of existing vegetation and soils, site topography, and (for new structures) 

whether guy lines would be used. Installation of structures could require temporary clearing of 
Bonneville Power Administration 3-15 

vegetation from a total of about 29 acres. Structure bases would permanently remove vegetation 

from about 0.2 acre in total. The realignment area near Joe Creek would require the permanent 

removal of approximately one five acres of forest. The removal of trees within and adjacent to 

the ROW in some areas between Structures 118 to 125 would result in low to moderate impacts 

on approximately 2 acres due to clearing and crushing of vegetation and soil compaction.

The indirect impact on vegetation is expected to be low. Noxious weeds could colonize 

disturbed soils if soils are left bare, but mulching and prompt revegetation through seeding and 

planting make it less likely. 

Access Roads

The direct impact on vegetation from road improvements is expected to be low. The impact 

would result from cutting back vegetation on each side of some existing roads and within the 

existing road bed. The direct impact of new road construction on vegetation is expected to be 

moderate. New roads would convert approximately 3.1 3.3 acres of forest land to bare road 

surfaces, and an additional 1.7 acres of new roads within the ROW would convert non-forested 

areas to bare road surfaces, and an additional estimated 2 acres would be cleared of trees but 

allowed to revegetate. Temporary roads would be built for use during construction to reach 

sensitive areas such as wetlands. Temporary roads would crush existing vegetation, damage 

roots and compact soils, but vegetation would likely recover over time; the areas would be 

seeded to speed the process. 

The indirect impact on vegetation from roadwork is expected to be low. Noxious weeds could 

colonize disturbed soils along the road edge, and new roads could provide new avenues for the 

dispersal of noxious weeds. Mitigation practices to avoid weed introduction (see Section 3.4.3, 

Vegetation), the relatively limited area of disturbance, and the dominance of native plants in 

much of the ROW means that the impact of noxious weeds is likely to be low. 

Tensioning Sites

The direct and indirect impacts of tensioning sites on vegetation would be low. Heavy trucks 

may damage roots and compact soils. The relatively small area of temporary clearing within the 

ROW, where vegetation is already maintained, would limit the impact. Noxious weeds could 

colonize areas cleared of vegetation, but clearing would be both limited and temporary. 

Operation and Maintenance

The direct impact on vegetation from operation and maintenance of the transmission line would 

be low. Maintenance of the corridor would require vegetation management activities, including 

periodic trimming, cutting, or clearing of trees and shrubs to allow access to transmission 

facilities, and removal of danger trees. The work would be conducted under BPA’s Vegetation 

Management Program, which uses a variety of methods to keep plants from interfering with 

transmission lines, including manual, mechanical, herbicide, and biological methods to foster 

low-growing plant communities (BPA 2000). Periodic removal of danger trees would continue, 

causing recurring impacts on maturing trees. 
3-16 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

The indirect impact from operation and maintenance is expected to be low. BPA’s use of 

herbicides and other methods would reduce the growth of noxious weeds targeted for control 

rather than promote their spread. 

3.4.3 Mitigation 

Mitigation would reduce both potential impacts on vegetation and the impacts on other resources 

from the loss of vegetation. If the project is implemented, the following mitigation activities will 

be used to reduce the adverse impacts of the proposed project: 

• Use existing road systems, where possible, to access structure locations. 

• Limit disturbance of native plant communities to the minimum necessary. 

• Develop and implement a noxious-weed control plan to minimize the introduction and 

broadcast of weed seeds, which will be submitted to the county weed control boards

specialists for recommendations. 

• Revegetate disturbed areas with native seed. 

• Inspect revegetation work and sites to verify adequate growth and implement 

contingency measures as needed. 

3.4.4 Unavoidable Impacts Remaining After Mitigation 

Construction of new access roads would permanently reduce vegetative cover in the project area 

by approximately 3 5 acres and temporarily remove vegetation in up to 1 2 acres. Improving 

existing access roads could further reduce cover, temporarily or permanently. Structure bases 

would permanently remove approximately 0.2 acres of vegetation. The realignment area near 

Joe Creek, along Highway 101, would permanently remove approximately 1 5 acres of forest. 

Areas cleared of mature plant communities that can be revegetated would still suffer temporary 

loss of mature plants, habitat complexity, and species diversity. Because of the limited length of 

new road surface required, unavoidable impacts remaining after mitigation are expected to be 

low to moderate. 

3.4.5 Cumulative Impacts 

Timber production is responsible for most of the past and ongoing impacts on vegetation in the 

vicinity of the proposed project, a situation that is likely to persist in the future as well. Much of 

the land adjacent to the ROW is managed by private timber companies, which grow and harvest 

conifers on large plantations. Development within the project area that could affect vegetation 

consists mainly of rural residences, with few paved roads. 

BPA removed more than 21,000 danger trees in and along the transmission line ROW during the 

summer of 2002. Trees were cleared up to 275 feet from the ROW centerline, disturbing a total 

of about 118 acres. In addition to large saw logs of harvestable age, isolated individual trees and 

small groups of old-growth Douglas fir, western hemlock, and Sitka spruce were cut in several 

locations. A few large trees were removed that were from 90 to more than 140 years old and 

from 5 to 7 feet in diameter at breast height. 

WSDOT performs several types of vegetation control along Highway 101 in the vicinity of the 

proposed project, including yearly spring applications of herbicides, summer and fall 
Bonneville Power Administration 3-17 

applications of herbicides to control noxious weeds, and mechanical cutting of vegetation 

(Ambrosino 2002). 

BPA conducted vegetation management activities within the ROW in the spring and summer of 

2003. The work involved the removal of tall-growing species such as cascara, red alder, 

elderberry, or vine maple that pose a threat to transmission line safety and reliability. The work 

was done under the guidance of BPA’s Vegetation Management EIS (BPA 2000) and sitespecific Supplement Analysis (SA-159, 2003). 

Impacts on vegetation of rebuilding the transmission line would be quite modest compared with 

the impacts of commercial logging on adjacent property and of BPA’s 2002 danger tree removal 

project. 

3.4.6 Environmental Consequences—No Action Alternative 

The nature of impacts to vegetation would be similar to those described for the proposal. Their 

intensity would be less than those of the proposal, but could increase slightly over current levels 

of disturbance as maintenance needs increase. Activities that could affect vegetation include 

transmission structure replacement, vegetation management activities, and access road 

improvements, with associated loss of vegetation. 

3.5 FISH AND WILDLIFE 

3.5.1 Affected Environment 

Fish

Washington Department of Natural Resources (DNR) classifies streams based on Types: 

Type 1-3 streams are perennial, known fish-bearing streams; Type 4 streams are perennial, 

probable fish-bearing or non-fish-bearing streams; and Type 5 and 9 streams are intermittent

streams. The ROW crosses or is adjacent to 30 fish-bearing streams or probable fish-bearing 

streams, and 33 non-fish-bearing streams (Table B-2, Appendix B). 

The main stream systems in or near the project area include Butte Creek, Smith Creek, Elkhorn 

Creek, Lower Salmon Creek, North River, Little North River, and Mill Creek. Fish species 

known or likely to occur in these streams and their fish-bearing tributaries are summarized in 

Table B-2 (Appendix B) (Williams et. al. 1975; Smith 1999; Smith and Wenger 2001; WDFW 

1998 and 2002c; WDNR 2002a). Fish species known to occur in the project area include 

anadromous and resident cutthroat trout; fall chinook, coho, and chum salmon; winter steelhead 

trout; sculpin, coast range sculpin, and reticulate sculpin; western brook lamprey; and three-spine 

stickleback. 

Wildlife

The proposed project area is dominated by upland forest habitat consisting of mid-successional

mixed coniferous forest, but also several other wildlife habitat types including wetlands and rural 

residential areas. Trees have been removed within the ROW, leaving it dominated by shrubs and 

herbaceous vegetation. Wetland and riparian habitats are scattered throughout the ROW. 
3-18 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

More than 300 vertebrate species are associated with the forests of western Washington (Olson 

et. al. 2001). There is a high density of these species, especially where habitats encompass 

riparian wetlands and urban, agricultural, and pasture lands. Key habitat elements within the 

project area include old-growth, early-successional stands, riparian forests, and forest edges. 

Most wildlife using the project area are likely to use all habitat types at one time or another for 

cover, breeding, nesting, foraging, or migrating. 

A list of wildlife likely to be found in the project area is shown in Table B-3 in Appendix B. 

Mammals common or present in the ROW and adjacent areas include mule deer, elk, coyote, 

raccoon, mice, rat, shrew, squirrel, bat, and mink (WDFW 2002c). Mule deer, elk, coyote, and 

raccoon likely use the ROW as a corridor to move between foraging areas. Birds common or 

present in the ROW and adjacent areas include chickadee, swallow, woodpecker, owl, hawk, and 

thrush. Songbirds are the largest wildlife group within the ROW and adjacent area (WDFW 

2002c). Reptiles and amphibians common or present in the ROW and adjacent areas include 

garter snake, bullfrog, giant salamander, newt, and tree frogs (WDFW 2002c). Dunn’s 

salamander and the Columbia torrent salamander have been found in one area in the ROW 

(WDNR 2002a). 

Priority Habitats and Species

The Washington Department of Fish and Wildlife (WDFW) has identified fish and wildlife 

species of special concern and listed these species as threatened, endangered, sensitive, 

candidate, or monitor species. WDFW has designated priority habitats as part of a strategy to 

maintain suitable habitat for these species. According to the WDFW Priority Habitat and 

Species Database (WDFW 2002b), the ROW crosses eight streams with habitat for both priority 

anadromous and resident fish and an additional three streams with habitat only for priority 

resident fish (Table B-2, Appendix B). The ROW does not cross any areas identified as 

supporting priority wildlife species or their habitat; however, priority habitat for wood duck, 

mink, Roosevelt elk, marbled murrelet, and northern spotted owl is located adjacent to the ROW. 

Threatened and Endangered Species

Three species listed as threatened under the Federal Endangered Species Act (ESA) are thought 

to occur in the proposed project area: bald eagle, marbled murrelet, and northern spotted owl 

(Table B-3 [Appendix B]; Berg 2002). Each is discussed below. 

The potential for bull trout, a listed species, to be found in the project area was investigated. The 

lower reach of the only stream that could support bull trout contains an impassable cascade 

where a dam has been constructed to create a small reservoir. The cascade and dam prevent the 

upstream migration of bull trout into the upper reaches of the creek. Fisher, a Species of 

Concern, historically was found in the area but has not been seen in Pacific or Grays Harbor 

counties for almost 100 years. 

No state-listed fish species are known to occur within the ROW and adjacent area 

(WDFW 2002b, 2002c, and 2002d). 

Bald Eagle. The bald eagle is both Federally and state-listed as threatened. Although bald 

eagles are commonly seen near the Chehalis and Willapa rivers, which are within a mile of the 
Bonneville Power Administration 3-19 

project area, their use of the project area is likely limited to occasional fly-overs and perching. 

No bald eagle nests have been identified within the ROW, although there are five known nests 

within 1.5 miles of the ROW (the closest nest is approximately 1 mile from the ROW). Bald 

eagles may winter throughout the project area (WDFW 2002b; K. Berg 2002). Eagles may 

forage where anadromous salmon are found (e.g., North River, Lower Salmon River, and Smith 

Creek). 

Marbled Murrelet. The marbled murrelet is a Federally and state-listed threatened bird. As 

part of the BPA danger tree removal project, stands of timber adjacent to the project area that 

meet the characteristics of potential habitat for marbled murrelet were identified. Twenty stands 

of potential habitat, encompassing approximately 347 acres, were identified near the project area. 

Three of these stands were subsequently logged by private timber companies. Of those twenty

the remaining seventeen stands, two stands were identified by WDFW as occupied by nesting 

marbled murrelets. Approximately 19 acres of potential marbled murrelet habitat was removed 

from stands as part of the BPA danger tree removal project in 2002. 

Northern Spotted Owl. The northern spotted owl is ESA-listed as threatened and state-listed as 

endangered. Its habitat requirements are similar to the marbled murrelet. Forested areas 

alongside the ROW could provide roosting and foraging habitat, but suitable stands are small and 

scattered. Most are located near Highway 101 and are continually affected by traffic noise and 

road activity. Use of the ROW and adjacent areas by the owl likely is limited due to stand size, 

fragmentation, and related edge effects (Harza 2002). Surveys conducted by adjacent 

landowners have documented northern spotted owl activity east of the ROW near the North 

River. The ROW crosses the edge of a single established northern spotted owl territory. 

Essential Fish Habitat (EFH)

Both chinook and coho salmon, which are administered under the amended Magnuson-Stevens 

Fishery Conservation and Management Act (see Section 4.3.1), occupy streams in the vicinity of 

the proposed project. The Act designates Essential Fish Habitat (EFH) for these species. EFH 

may be found in Butte, Elkhorn, Lower Salmon, and Joe creeks, the North and Little North 

rivers, and other unnamed tributaries that cross, or flow adjacent to, the project corridor. 

3.5.2 Environmental Consequences—Proposed Action 

Fish

Removal of Existing Structures and Installation of New Structures. Direct impacts on fish 

from these activities are expected to be low and limited to temporary disturbances from increased 

noise in the vicinity of fish-bearing streams. No equipment would enter streams to remove 

existing structures. Structures located immediately adjacent to fish-bearing streams or wetlands 

would be cut off at ground level to minimize impacts. Structures would be dragged out or lifted 

out by crane to avoid bringing construction equipment into streams and wetland areas. The 

temporary disturbances to fish are not expected to result in injury or death. 

Removing and installing structures could have moderate indirect impacts on fish due to the 

introduction of sediment into fish-bearing streams. There is some probability of fish mortality 

due to sediments entering fish-bearing streams during spawning and incubation periods. 
3-20 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

Increased turbidity, the suspended sediment carried by the stream, could affect fish directly by 

abrasion, clogging of gills, decreased feeding success due to reduced visibility, degradation of 

spawning gravels, increased egg and fry mortality, and reduced fry growth rates, and also could 

affect aquatic prey. Ten of the proposed structures would have construction areas within 50 feet 

of fish-bearing streams or primary tributaries to fish-bearing streams (see Table 3-2 in Section 

3.6.2, Water Quality). BPA would use standard construction practices and BMPs that would 

minimize or eliminate the delivery of sediments into streams (see Section 3.6.3, Water Quality). 

Riparian vegetation near the Joe Creek crossing of Highway 101 would be removed to create the 

new ROW alignment, a moderate impact. Trees, mainly red alder and one cottonwood, would be 

removed to the edge of the creek, and trees would be removed along two five non-fish bearing 

tributaries of Joe Creek. Removal of alder trees would expose a short reach of Joe Creek to more 

solar radiation, especially during the summer months. Additionally, it would remove cover and a 

source of terrestrial insects and organic matter. For some time after tree removal, it is possible 

that increased surface runoff and erosion could increase turbidity in Joe Creek. Because the 

creek appears to support a healthy riparian corridor along much of its length (3.8 miles), it is not 

expected that removal of the stand of alder trees just north of Structure 90 would substantially 

affect EFH. Any adverse impacts to EFH that would occur could be mitigated. Trees would be 

hand-cut and felled into Joe Creek to serve as large woody debris, where possible, and if 

consistent with WSDOT safety requirements. Planting of low-growing woody species in the 

riparian area would partially mitigate for the removal of these trees. To the north, five danger 

trees cut from 50 to 110 feet from the edge of a wetland along a tributary of Joe Creek would not 

be expected to impact EFH because the 50 foot vegetative buffer next to the wetland would not 

be disturbed.

A group of trees would be removed within 50 feet of a fish-bearing tributary to the Little North 

River. These trees would be left as snags and the tops felled into waterways to provide large 

woody debris, if because WDFW and NOAA Fisheries consider this desirable. 

Access Roads. Direct impacts on fish from road work would be similar in type and intensity to 

those for structure removal and installation. Road improvements are proposed over fish-bearing 

streams, including constructing a ford in one fish-bearing stream and rocking the existing road 

surface over several streams. The temporary disturbances to fish are not expected to result in 

injury or death because, after construction, fords would be used only during maintenance—on 

average four times per year. 

Indirect impacts on fish are expected to be low to moderate and result primarily from the 

removal of riparian vegetation, disturbance of soils, and the introduction of sediment into fishbearing streams. Removal of riparian vegetation and soil disturbance could introduce sediment 

into streams and cause increases in stream temperatures. Potential impacts on fish and prey 

organisms would depend on construction timing and whether sediment reached the stream. Road 

work would not endanger fish populations in the vicinity of the proposed project. 

Tensioning Sites. No impacts on fish from conductor tensioning sites are expected because 

these areas would not be placed within 50 feet of streams. 
Bonneville Power Administration 3-21 

Operations and Maintenance. Direct impacts on fish from routine maintenance activities are 

expected to be low to moderate. Maintenance activities could include access road 

improvements, culvert replacement, and vegetation management. They would have impacts on 

fish similar to those described for access road improvements. Maintenance activities would be 

unlikely to result in the injury or death of fish unless, in the future, it is necessary to replace 

culverts in fish streams.

Maintenance activities could result in habitat alteration due to cutting riparian vegetation, use of 

pesticides, changes in runoff and infiltration patterns (from upland vegetation clearing), 

sedimentation from cleared areas, and maintenance of access roads across streams. Effects from 

vegetation management activities are expected to be low because impacts would be minimized 

by implementing the standard mitigation described in the BPA’s Vegetation Management EIS

(BPA 2000). Impacts from road maintenance would be low to moderate, depending on the type 

of activity and proximity to streams, but WDFW requirements would be followed for all 

instream work, thus minimizing impacts. 

Wildlife

Removal of Existing Structures and Installation of New Structures. Direct impacts on 

wildlife from these activities are expected to be low to moderate. Loss of foraging habitat and 

ground-nesting habitat around existing structures is expected to have a low impact because the 

small amount of habitat that would be disturbed is unlikely to result in their injury or death. 

Approximately 1 7 acres of the 6 acres within two realignment areas would be cleared of trees; 

the other realignment area was recently logged and has only tree seedlings. The portion within 

the 50-foot wide easement of the realignment areas would not be allowed to re-grow as forest but 

would be maintained as a shrub-dominated ROW. 

Increased noise from construction equipment and human activities during the non-breeding 

season is expected to have a low impact on wildlife as species would likely avoid construction 

sites temporarily. Increased noise during the general breeding season (March to August) could 

result in moderate impacts on wildlife, if noise levels reduce the foraging effectiveness of adults 

or cause adults to abandon nest sites, thus leading to mortality in their young. Mitigation to 

minimize noise impacts to marbled murrelet, a listed species, is discussed in Section 3.5.3, Fish 

and Wildlife. 

Low indirect impacts on wildlife are expected because the amount of habitat that would be 

disturbed is a small percentage of the habitat available to wildlife along the ROW. Although 

noxious weeds could establish themselves in the disturbed area surrounding structures, BPA’s 

vegetation management program is expected to minimize that potential. 

Access Roads. Direct impacts on wildlife from access road work are expected to be low because 

removal of a small amount of low quality habitat, including some trees, is not expected to 

endanger wildlife populations or result in their injury or death. Species are expected to use 

surrounding non-affected areas for foraging and ground-nesting activities. Increased noise may 

cause wildlife to avoid the immediate work areas. 
3-22 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

Indirect impacts on wildlife that could result from roadwork include the introduction of 

sediments to undisturbed areas, the introduction of weed species, increased levels of noise, and 

some increased human access. Impacts are expected to be low to moderate. The work would 

cause only short-term degradation in the quality of wildlife habitat and generally would not 

disturb ESA-listed species. A possible exception is some road work that would be done during 

the late breeding season near occupied marbled murrelet habitat in order to observe instream 

work periods. To mitigate potential impacts, dusk-to-dawn noise restrictions would be observed. 

Tensioning Sites. Direct and indirect impacts on wildlife from conductor tensioning sites are 

expected to be low to moderate, depending on their locations. There would be short-term 

degradation to wildlife habitat inside and outside of the ROW from damage to vegetation and the 

possible short-term destruction of local prey species. Also, indirect impacts on wildlife could 

result from noxious weeds becoming established before native species have recovered. 

Operation and Maintenance. Some level of bird mortality would be expected as a result of 

collisions with conductors and structures. However, it is not expected to be higher than current 

levels as there are no known unusual circumstances, such as flyways in the project area, which 

would contribute to high levels of mortality. The 115-kV conductors are too widely spaced for 

an electrical connection to occur that would result in the electrocution of raptors. The overall 

level of impacts would be low. 

Migratory waterfowl have the highest incidence of mortality from collision with transmission 

lines, particularly near wetlands, feeding areas, or open water (Stout and Cornwell 1976). The 

line crosses few areas of open water or wetlands; it primarily crosses forest land. Because the 

existing line has not been documented to be a problem in the past, it is unlikely that the new line 

would have an increased adverse effect on waterfowl. 

Maintenance activities would remove trees and temporarily displace wildlife from work areas, 

but impacts are expected to be low. 

Priority Habitats

Direct and indirect impacts on priority habitats and species from the construction, operation, and 

maintenance of the transmission line are expected to be low to moderate. The ROW crosses 

several priority habitats for fish, where sedimentation impacts would be low, unless sediment 

was introduced during the spawning and incubation season, in which case impacts could be 

moderate from short-term decline in the quality of fish habitat. The ROW does not cross any 

priority habitats for wildlife. 

Threatened and Endangered Species

As required by Section 7 of the Endangered Species Act (ESA), BPA prepared a Biological 

Evaluation (BE) of the potential effects of the proposed project on listed species and to aid BPA 

in their consultation with the U.S. Fish and Wildlife Service (USFWS). It was submitted to 

USFWS as an aid to ESA decision-making. 
Bonneville Power Administration 3-23 

Most listed species are not expected to be adversely affected by the project. No direct or indirect 

impacts on bull trout are expected because no population of bull trout exists within the project 

area. 

Impacts on bald eagles would be low to moderate since their use of the project area is likely to be 

quite limited. No known roosting trees would be removed. The brief increase in constructionrelated noise could possibly cause bald eagles to avoid active construction areas, a temporary 

impact. Potential direct effects could result from increased construction-related noise and 

helicopter use. Construction would not begin until after the time when eagles are known to be 

most sensitive to disturbance (February 1 to mid-April). Helicopter use for construction 

activities would be prohibited until after September 15. Most construction activities would be 

completed before November 1, limiting any impacts to eagle use of the area during the 

November 15 to March 15 wintering period. 

Impacts on spotted owls would be low to moderate. No large trees suitable for nesting would be 

removed. Although some trees suitable for perching may be removed, the impacts would be low. 

Increased noise due to construction activities could cause spotted owl to avoid construction 

areas, a temporary impact. Because the proposed project is adjacent to Highway 101, any 

spotted owls in the vicinity would likely be accustomed to higher ambient noise levels and would 

be less affected by construction noise. The use of helicopters would be restricted until 

September 15, avoiding the critical nesting and fledging period. 

There would be no direct effects to marbled murrelet from the removal of habitat (nesting) trees 

during the nesting season. However, trees within one occupied habitat area would be limbed to 

remove branches that extend into the 50-foot ROW after the nesting season. In another area, a 

clump of red alder trees and a hemlock with two 16” diameter trunks would be removed from the 

edge of a potential habitat stand immediately adjacent to Highway 101. These trees are not 

suitable nesting trees and are located more than 100 feet from any suitable nesting trees. Tree 

limbing and removal would be done after September 15 to avoid affecting nesting marbled 

murrelet. Four red alders at the edge of a potential habitat stand would be removed to widen a 

curve in the road.

Noise above ambient sound levels can cause adult marbled murrelets to startle and abandon their 

nests. Marbled murrelets are most sensitive to noise during the early breeding season, April 1 to 

August 5, and are thought to be less sensitive to noise in the late breeding season, from August 6 

to September 15. Marbled murrelets are most sensitive to noise during dawn and dusk periods 

when adults arrive at the nest from ocean feeding areas bringing fish to chicks, or leave to return 

to ocean feeding areas. 

In some marbled murrelet habitat in the vicinity of the project, noise may be above ambient 

levels and persist for several hours to several days. However, approximately half of the marbled 

murrelet areas are near or directly adjacent to US highway 101, where the ambient noise level 

generated by the heavy vehicle use (primarily logging trucks and other construction-related 

vehicles) is very high. 
3-24 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

Mitigation is required to avoid nest abandonment. To minimize disturbance to nesting marbled 

murrelets, the USFWS and state agencies require or recommend noise restrictions of various 

types and degrees near habitat, depending on the type of activity. Fewer restrictions are 

recommended for construction activities that do not involve blasting, aircraft use, or other very 

noisy activities. For the construction activities involved in this project, dusk-to-dawn restrictions 

would be observed within 1⁄4 mile of habitat areas during the early and late nesting period (April 

1 to September 15) to prohibit noise in the early morning and evening hours: work cannot 

commence until 2 hours after sunrise and must cease 2 hours before sunset. Additional noise 

restrictions would be observed within 75 yards of occupied marbled murrelet stands and no 

construction activities would occur in the early breeding season, from April 1 to August 5. 

Therefore, with mitigation, noise would likely have a moderate impact on marbled murrelets.

Impacts to listed species could occur from some operation and maintenance activities. Noise 

impacts from occasional on the ground (vehicle) surveys of the line during operation and 

maintenance of the proposed project would be low. Noise impacts from helicopter use would be 

a moderate impact. Three times a year, generally in March, July, and October, a helicopter 

would fly the line to look for any problems or repair needs and vehicles would visit portions of 

the line. The July flight would impact marbled murrelet during the early breeding season and all 

flights could disturb spotted owl or eagles using the project area.

3.5.3 Mitigation 

If the project is implemented, the following mitigation measures will be used to reduce impacts 

to fish and wildlife: 

• When working in or next to water bodies, disturbance will be limited to the minimum 

necessary. 

• Existing structures within 50 feet of waterways will be cut at the base rather than 

excavated cut at the ground surface rather than cut 2 feet below the ground surface, to 

minimize soil disturbance. 

• Removal of forest habitat will be limited to those trees that would interfere with 

transmission lines or those cut to create access roads. 

• Existing structures located within 50-feet of fish-bearing streams will be cut off at ground 

level to minimize ground disturbance. 

• Disturbed areas will be revegetated with native seed. 

• Tensioning sites will not be located within 50 feet of streams or wetlands. 

• Mitigation measures required by WDFW will be followed when working in streams. 

• No structure construction will be carried out within 75 yards of the boundary of occupied 

marbled murrelet habitat until after September 15. 

• Instream work and other roadwork adjacent to occupied marbled murrelet habitat will 

not commence until after August 5. 

• Helicopters will not be used to string the conductor until after September 15 to avoid 

noise impacts to nesting marbled murrelet. 

• Dusk-to-dawn restrictions will be in place within 0.25 mile of all occupied or potential 

marbled murrelet habitat stands until September 15. 

• Any trees felled within 50 feet of the Joe Creek crossing will be felled into the stream to 

provide large woody debris, if approved by WSDOT, the landowner. 
Bonneville Power Administration 3-25 

• The five danger trees cut within 50 to 110 feet of the Joe Creek tributary (between 

Structures 92 to 94) will be cut as snags but the tops will not be felled toward the creek to 

avoid damaging the remaining trees in the riparian buffer.

• The riparian area within 50 feet of Joe Creek will be replanted with native, low-growing 

shrubs, if planting spots can be created safely.

• Any trees felled within 50 feet of the Little North River tributary between structures 123 

and 124 and tributaries will be cut as snags and the tops felled into the riparian area., if 

approved by WDFW and NOAA Fisheries.

• A Biological Evaluation has been prepared as required under the Endangered Species 

Act. It provides detailed actions to reduce or eliminate impacts on listed species. If an 

incidental take permit is issued, any terms and conditions will be implemented. 

3.5.4 Unavoidable Impacts Remaining After Mitigation 

Construction could cause short-term, localized degradation of habitat quantity or quality. Some 

forested habitats would be permanently converted to roads (about 3.1 3.3 acres) or shrubdominated ROW (about 6 acres). This would not substantially affect fish and wildlife or their 

habitat because of mitigation measures, seasonal work restrictions for in-water work (culvert 

replacements), the short-term nature of the effects on water quality, and the amount of remaining 

wildlife habitat in the project area. Therefore, impacts would be low to moderate. 

3.5.5 Cumulative Impacts 

Forested lowlands in western Washington have been managed for timber production for more 

than 100 years, resulting in the loss of most, and the fragmentation of the remaining, latesuccessional forests. Species dependent on these forests, such as marbled murrelets and 

northern spotted owls, have declined dramatically in the region as a result (Olson et al. 2001). 

Approximately 19 acres of marbled murrelet habitat were removed as part of the BPA danger 

tree removal project in 2002. Past and future danger tree removal may also contribute to the loss 

of riparian vegetation. Logging operations conducted along the ROW adjacent to water bodies 

have the potential to adversely affect water quality and fish habitat through erosion and release 

of sediments to fish-bearing waters downstream. Past culvert replacements by BPA and others 

typically have improved fish passage as old culverts have been replaced with WDFWrecommended culverts. WSDOT’s scheduled road improvements and vegetation control along 

Highway 101 could also remove or degrade small amounts of fish and wildlife habitat. WSDOT 

does not use herbicides in sensitive areas such as streams (Ambrosino 2002). 

Impacts related to this project are unlikely to contribute to further cumulative loss of wildlife 

habitat. The amount of habitat lost due to the proposed project is relatively small. Important 

corridors connecting key wildlife habitats, such as streams and riparian zones, would not be 

substantially affected by the project. 

3.5.6 Environmental Consequences—No Action Alternative 

Current levels of disturbance to fish and wildlife and their habitat would continue, or perhaps 

increase slightly. Activities that could affect fish, wildlife, or their habitat include vehicular 

traffic, replacement of transmission structures, vegetation management, and access road 
3-26 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

improvements. The current condition of the transmission line may contribute to the need for 

increased emergency and on-going repairs as the condition of structures continues to deteriorate. 

These activities could cause loss of vegetation, temporary increases in turbidity, and temporary 

increases in noise. Impact levels would range from low to moderate. 

3.6 WATER QUALITY 

3.6.1 Affected Environment 

Surface Water

The transmission line crosses or is adjacent to 66 streams, 30 of which are classified as perennial

fish-bearing streams and 33 as non-fish bearing, perennial or intermittent streams (see Table B-2 

in Appendix B for stream types and fish presence in the corridor). 

The streams south of Structure 150 lie within the North River basin of the Willapa Basin Water 

Resource Inventory Area (WRIA 24). Those streams in the short stretch between Structure 151 

and Cosmopolis Substation lie within the Lower Chehalis WRIA (WRIA 22). All of the latter 

are intermittent streams except Mill Creek, which is west of the ROW between Structures 156 

and 157. Mill Creek is a perennial, fish-bearing stream. 

Water Resource Inventory Area 24. The Willapa River is classified under the Washington 

Administrative Code as “Class A (Excellent)” (WAC 173-201A-130). Although its tributaries 

that cross the transmission corridor are not specifically classified, under the WAC, by definition, 

unclassified waters in this case would also be considered Class A. 

The state is required under Section 303(d) of the Federal Clean Water Act and the U.S. 

Environmental Protection Agency’s (EPA’s) implementing regulations (40 CFR 130) to prepare 

a list of water-body segments that do not meet state water quality standards for surface water. 

The North River and some of its tributaries crossed by the transmission line, including Elkhorn 

Creek, Joe Creek, Little North River, and Smith Creek, are included on Washington Department 

of Ecology’s (WDOE’s) 1998 303(d) list of streams that exceed the state’s temperature criterion 

of 18°C. 

A primary function of stream riparian zones is to moderate water temperature by providing 

shade. Washington State’s Forest Practices Rules (WAC 222-30-040) establishes shade 

requirements to maintain water temperature. Most of the Lower North River mainstem, Lower 

Salmon Creek, and Joe Creek rate low in riparian shade (Herger 1997 [in] Smith 1999). 

Although the Little North River riparian area is among the best in the sub-basin, shade levels are 

still rated as low. About 78 percent of the stream miles of the North River mainstem do not meet 

shade requirements (Smith 1999).

Water Resource Inventory Area 22. Like the Willapa River, the Chehalis River and its 

tributaries are Class A waters. The mainstem of the Chehalis River is at least a half mile from 

the ROW at the closest point, although eight intermittent tributaries cross the ROW. Many 

reaches of the mainstem Chehalis River are on the 303(d) list for temperature, dissolved oxygen, 

and fecal coliform violations (Smith and Wenger 2001), but no information on the unnamed 

tributaries was found. The Washington Conservation Commission recommends restoration of 
Bonneville Power Administration 3-27 

riparian vegetation and improving dissolved-oxygen concentrations in tributaries and the 

mainstem of the Chehalis River. 

Groundwater

Little information is available on groundwater quality or hydrology in the project area. Surface 

water is the primary source of drinking water for both counties (Toy 2002). No sole-source

aquifers have been designated or proposed by EPA in the area (US EPA 1996). Groundwater 

quality in the Chehalis basin is generally good, although there are concerns about the potential 

impacts of wastewater storage sites on groundwater quality (Smith and Wenger 2001). 

3.6.2 Environmental Consequences—Proposed Action 

Surface Water

Removal of Existing Structures and Installation of New Structures. The potential for direct 

impacts on water quality is expected to be low to moderate. Specific areas within the ROW that 

could be subject to water quality impacts are listed in Table 3-2. Direct impacts are most likely 

from erosion and increased runoff where structures are immediately adjacent to water bodies, 

especially perennial, fish-bearing streams (see Section 3.5, Fish and Wildlife, for a discussion of 

increased turbidity on fish). Vegetation removal and soil disturbance can increase wind and 

water erosion rates, resulting in sediment deposition directly into stream channels and increased 

turbidity. Erosion rates likely would return to their current levels once vegetation becomes 

reestablished. Impacts would depend on the timing of construction, weather conditions, local 

topography, the erosion potential of soils, and the effectiveness of BMPs implemented during 

construction to minimize soil erosion. Direct impacts from excavation for new structures are 

expected to be low because excavated soils would not be discharged to surface waters. BPA 

would implement standard construction practices and BMPs that would minimize direct impacts 

on water quality. Turbidity and sedimentation impacts on water resources would be reduced 

after temporary and permanent runoff and erosion controls are installed and would continue to 

diminish after revegetation. 

Table 3-2. Structures In or Within 50 Feet of Streams 

Existing Structure 

in Stream 

Proposed Structure 

in Stream 

(Type of Structure) 

Existing Structure 

within 50 feet of 

Stream 

Proposed Structure w/in 

50 feet of Stream 

(Type of Structure) 

 *13 (suspension) 

 *21 *21 (suspension

 *22 (suspension) 

 *27 

 *31 *31 (suspension) 

 *32 *32 (suspension) 

 *40 *40 (suspension) 

43 43 (suspension) 

*67 *67 (suspension) 

*73 *73 (angle suspension) 

 *74 *74 (suspension) 

*80 
3-28 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

Existing Structure 

in Stream 

Proposed Structure 

in Stream 

(Type of Structure) 

Existing Structure 

within 50 feet of 

Stream 

Proposed Structure w/in 

50 feet of Stream 

(Type of Structure) 

*92 

*93 

*128 *128 (suspension) 

*131 

*133 *133 (suspension) 

138 138 (angle suspension) 

(* This structure is within or near a known or probable fish-bearing stream) 

Riparian vegetation near the Joe Creek crossing of Highway 101 would be removed to create the 

new ROW alignment. Trees, mainly red alder and one cottonwood, would be removed to the 

edge of the creek and trees would be removed along two non-fish bearing tributaries of Joe 

Creek. Removal of alder trees would expose a short reach of Joe Creek to more solar radiation, 

especially during the summer months, which could raise water temperatures. This would be 

partially mitigated by replanting this area with shrubs. For some time after tree removal, it is 

possible that increased surface runoff and erosion could increase turbidity in Joe Creek. The 

effect on temperature and turbidity in this area and also along the tributary to the Little North 

River, would be localized and likely short term and therefore would be a low to moderate impact. 

Direct impacts on water quality also could result from dewatering holes that are augered for new 

structures. Such impacts are expected to be low because only clean infiltration water that meets 

state water quality standards for turbidity in Class A streams (WAC 173-201A) would be 

discharged to streams or other waters of the state, and only if the discharge rate does not cause 

erosion or flooding. Clean water would not be mixed with dirty water. Turbid water from the 

holes would be conveyed to temporary holding areas, pumped to water trucks, infiltrated, or 

dispersed in nearby vegetated areas. 

Direct impacts on surface water quality resulting from oil and fuel spills from construction 

equipment used adjacent to streams or wetlands are expected to be low. Tanks and equipment 

containing oil, fuel or chemicals will be checked regularly for drips or leaks and will be 

maintained to prevent spills onto the ground or into state waters. All equipment and vehicles 

would be maintained and repaired on an impervious surface away from all sources of surface 

water. If the work must be done in the rain, it will take place undercover. Refueling and 

equipment maintenance would be carried out at least 200 feet from streams and wetlands, and 

spill containment and cleanup would be provided. All equipment fueling operations will utilize 

pumps and funnels and absorbent pads. Fueling will not take place adjacent to any natural or 

manmade drainage conveyance including ditches, catch basins, ponds, wetlands, and pipes. Spill 

prevention kits will be provided at designated locations on the project site and at the hazardous 

material storage areas. 

Potential impacts of fresh concrete coming in contact with surface water and elevating surface 

water pH would be low. Concrete would not be poured directly into any surface waters, and it is 

extremely unlikely that large volumes of fresh concrete would inadvertently enter surface water. 
Bonneville Power Administration 3-29 

Access Roads. Direct impacts would be similar to those from structure removal and installation. 

Culvert installation and replacement could disturb bank soils and shoreline vegetation. Where 

roads are improved immediately adjacent to stream channels, direct deposition of soil into the 

stream channel could increase turbidity and sedimentation. Eroded soils carried to water bodies 

by wind and sheet flow could also lead to this effect. As a result, water quality criteria in the 

project area could be temporarily exceeded. A culvert would be replaced in one perennial stream 

that may be fish-bearing; the culvert would be installed in a ditched portion of the stream, 

adjacent to Highway 101. Impacts on surface water quality are expected to be minimized 

because construction would occur during the dry season and implementation of BMPs would 

reduce the potential for erosion. 

Tensioning Sites. Direct and indirect impacts on surface water quality are expected to be low 

because tensioning sites would not be located within 50 feet of waterways and wetlands. 

Equipment used for tensioning conductors may compact soils, potentially resulting in increased 

surface runoff. Depending on how close the sites are to surface water, activities there could 

result in minor direct impacts on surface water quality such as increasing turbidity through 

transport of soil via surface runoff. Any impacts on surface water quality would be short-term, 

localized, and likely would not exceed state or Federal criteria. 

Operation and Maintenance. Direct impacts on surface water quality from routine access road 

maintenance are expected to be low to moderate. Activities such as grading and placing rock on

roads, replacing failed culverts, and controlling vegetation could increase erosion and surface 

water turbidity, possibly causing water quality criteria to be exceeded temporarily in a short 

stretch of stream. Perennial fish-bearing streams located near maintenance activities are at 

greatest risk for water quality impacts. A variety of factors, including the effectiveness of BMPs, 

could affect the nature and amount of impact, as described in the section on structure impacts. 

Direct and indirect impacts on water quality from herbicides used in vegetation management are 

expected to be low to moderate. Herbicides would be applied with buffer widths as specified in 

BPA’s Vegetation Management Program (BPA 2000). Because only spot spraying is proposed 

for the vegetation management activities planned for 2003, buffers would be 0 feet if herbicides 

classified as Practically Non-toxic to Slightly Toxic were used; 25 feet if herbicides are classified 

Moderately Toxic or are labeled with an Advisory for Ground/Surface Water; and 35 feet if the 

herbicide is classified as Highly Toxic to Very Highly Toxic) (BPA 2000). In the event of 

overspray, herbicides could be inadvertently applied directly to surface waters. Impacts could 

also occur if herbicide residues on vegetation and soil are transported to surface waters when it 

rains or snows. 

Groundwater

Direct impacts on groundwater from project activities are expected to be low. The project could 

directly affect groundwater quality through soil compaction, reducing infiltration capacity, 

increasing surface runoff to streams, and possibly increasing groundwater turbidity. However, 

the ratio of the potential impact area to the area available for groundwater recharge is extremely 

small. Any impacts would be localized, short-term, and likely would not exceed state or Federal 

water quality criteria. 
3-30 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

It is expected that direct impacts on groundwater quality from petroleum spills would be low. 

Such spills could infiltrate to the groundwater aquifer, but such an event is unlikely, given the 

precautions required (see previous discussion under Surface Water). Any chemical spills would 

be of small volume, contained, and cleaned up. 

3.6.3 Mitigation 

If the project is implemented, the following mitigation will be implemented to decrease surface 

runoff and exposed soil: 

• An environmental specialist will meet with contractors and inspectors in the field to visit 

wetlands and waterways near or within construction areas to review avoidance and 

mitigation measures and any permit requirements. 

• A Stormwater Pollution Prevention Plan will be prepared and implemented, addressing 

measures to reduce erosion and runoff and stabilize disturbed areas. 

• Existing structures within 50 feet of waterways will be cut at the base rather than 

excavated, ground surface rather than excavated 2 feet below the surface, to minimize 

soil disturbance. 

• When working in or near water bodies and wetlands (buffer areas), disturbance will be 

kept to the minimum necessary. 

• Vegetative buffers will be retained where possible to prevent sedimentation into water 

bodies. 

• To minimize erosion, sedimentation, and soil compaction, as much work as possible will 

be conducted during the dry season, when stream flow, rainfall, and runoff are low. 

• No construction vehicles and equipment will be placed within 50 feet of any stream or 

wetland unless it is authorized by a permit or is on an existing permanent or temporary 

road constructed for access to the site.

• Tensioning sites will not be located within 50 feet of streams, wetlands, or floodplains. 

• Roads and structures will be located to avoid wetlands whenever possible. 

• Roads will be designed and constructed to minimize drainage from the road surface 

directly into water features, including wetlands. 

• Mitigation measures required by WDFW will be followed when conducting instream 

work. 

• The riparian area within 50 feet of the Joe Creek crossing where riparian trees will be cut 

as snags and the tops felled into the creek will be replanted with native, low-growing 

shrubs, assuming planting spots are present and can be safely accessed within the woody 

debris felled into this area. 

• A Spill Prevention Control and Countermeasure (SPCC) Plan will be developed and 

implemented to minimize the potential for spills of hazardous material. 

• Machinery will be refueled and stored at least 200 feet from wetlands and waterways and 

will be inspected regularly for leaks. 

3.6.4 Unavoidable Impacts Remaining After Mitigation 

Short-term, localized water quality degradation during construction would not be expected to 

substantially affect water quality because of the mitigation measures implemented, seasonal 
Bonneville Power Administration 3-31 

work restrictions for in-water work (culvert replacements), and the short-term nature of the 

effects on water quality. Therefore, water quality impacts would be low to moderate. 

3.6.5 Cumulative Impacts 

Several activities in the area have the potential to adversely affect water quality through erosion 

and overland transport of suspended sediments to streams downstream of these operations. They 

include past, present, and future logging operations; Pacific County’s culvert replacement 

program; ongoing road and bridge maintenance; and BPA’s danger tree removal project. 

Especially compared to the extensive logging by private timber companies throughout the area 

(see Section 3.2, Land Use, or Section 3.4, Vegetation), the proposed Rebuild Project would 

contribute only a small increment to water quality impacts relative to other activities. 

BPA and WSDOT both use herbicides in vegetation control. Every spring WSDOT applies Oust 

and Round-Up to roadside shoulders along Highway 101, usually two to three feet from the 

pavement edge. Where there is water in the roadside ditches, no herbicides are applied. During 

the late spring, summer, and fall WSDOT uses several different herbicides to control noxious 

weeds and other nuisance vegetation. Herbicides are applied according to the product label 

directions and are not applied in sensitive areas such as streams. WSDOT also uses mechanical 

and biological vegetation control methods. 

BPA plans to conduct vegetation management activities within the ROW in the late winter or 

early spring of 2003. Although BPA’s ROW is in the Highway 101 ROW for about a third of its 

distance, areas sprayed by the two agencies are not likely to overlap. WSDOT’s vegetation 

management focuses on the edge of the road. BPA proposes only spot spraying of tall-growing 

species and weeds when they are seen to be a problem, so duplicate spraying of the same areas 

by the two agencies is unlikely. The policies and precautions of both agencies would thus limit 

the cumulative impacts from herbicide use. 

3.6.6 Potential Impacts—No Action Alternative 

Impacts to surface and groundwater quality would be similar in nature and intensity to those 

described for the proposal’s operation and maintenance program. However, the number of 

maintenance events and thus the level of impact could increase as structures deteriorate. Areas 

where structures are in or adjacent to streams and wetlands, especially those with no access, are 

at greater risk of experiencing increasing impacts to water quality. 

3.7 WETLANDS 

3.7.1 Affected Environment 

A field survey in August and September of 2002 identified numerous wetland areas within the 

50-foot wide ROW, and in areas off the ROW where roads would be improved or constructed. 

Wetlands in the project area are associated mainly with topographic depressions or riparian 

areas. Most wetlands in the ROW are dominated by shrubs (scrub-shrub wetlands). The most 

common shrub species in these wetlands is salmonberry, associated with a sparse cover of a few 

herbaceous species such as reed canarygrass, small-fruited bulrush, and slough sedge. Other 
3-32 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

shrubs found in scrub-shrub wetlands include various willows and Douglas spirea. Scrub-shrub 

wetlands are commonly found in low-lying areas adjacent to Highway 101 where water tends to 

back up against the highway berm, in other low-lying areas, and adjacent to stream channels. 

About one third of the wetlands in the ROW are dominated by herbaceous species (emergent 

wetlands). The most common species in these wetlands include reed canarygrass, small-fruited 

bulrush, and slough sedge. 

Although some forested wetlands adjacent to the ROW were logged as part of BPA’s danger tree 

removal project, there are none within the ROW. Forested wetlands in the project area are 

dominated by trees such as alder, Sitka spruce, western hemlock, and western red cedar. 

3.7.2 Environmental Consequences—Proposed Action

Removal of Existing Structures and Installation of New Structures

Twenty existing structures are within 50 feet of wetlands; of those, nine are in wetlands. 

Nineteen of the proposed structures would be within 50 feet of wetlands, only two of which 

would be in wetlands (Table 3-3). The location of existing and proposed structures in relation to 

wetland buffers is described in Table B-11 in Appendix B.

The impact on wetlands from removing existing structures would be low. Structures in wetlands 

would be cut at the base with no soil disturbance and lifted or dragged from the wetland area. 

Their removal could cause minor and temporary damage to wetland vegetation and soils. Plants 

within a small radius around the existing structures may be trampled, broken, or crushed by 

equipment when the structures are dismantled and removed by crane. Wetland boundaries in 

these areas would be marked to restrict the work area so that disturbance would be minimized. 

Table 3-3. Structures In or Within 50 Feet of Wetlands 

Existing 

Structure in 

Wetland 

Proposed Structure 

in Wetland 

(Type of Structure) 

Existing Structure 

within 50 feet of 

Wetland 

Proposed Structure w/in 50 

feet of Wetland 

(Type of Structure) 

 22 (suspension) 

25 Moved to Upland Site 25 (angle suspension) 

28 28 (suspension) 

 33 33 (angle suspension) 

 34 34 (dead end w/ concrete base) 

35 Moved to Upland Site 35 (angle suspension) 

39 Moved to Upland Site 39 (suspension) 

 43 43 (suspension) 

 44 44 (suspension) 

 47 47 (suspension) 

 48 48 (suspension) 

63 63 (suspension) 

64 64 (suspension) 

65 Moved to Upland Site 65 (suspension) 

67 Moved to Upland Site 67 (suspension) 
Bonneville Power Administration 3-33 

Existing 

Structure in 

Wetland 

Proposed Structure 

in Wetland 

(Type of Structure) 

Existing Structure 

within 50 feet of 

Wetland 

Proposed Structure w/in 50 

feet of Wetland 

(Type of Structure) 

72 72 (suspension) 

73 73 (angle suspension) 

 74 74 (suspension) 

92 Moved to Upland Site 

93 Moved to Upland Site 

140 140 (angle suspension) 

Impacts on wetlands from installing new structures in wetlands are expected to be low to 

moderate and mostly temporary. Proposed Structures 28 and 72 would be erected in wetlands; 

both would be suspension structures, which require the smallest disturbance area. Permanent 

disturbance would be limited to the portions of wetlands that are excavated or filled to embed the 

structure base. The total fill would be about less than 15 cubic yards, or approximately 25 square 

feet per structure. 

Work on structures that are near wetlands could temporarily disturb them resulting in low 

impacts; the amount of disturbance would depend on the structure type. Where possible, 

construction activities within wetlands would be avoided, and impacts minimized by restricting 

work while soils are wet. 

Access Roads

Impacts on wetlands from improving existing roads are expected to be low to moderate. Direct 

disturbance to vegetation or soils could result from excavation, grading, or placing rock within a 

few wetland areas. Loss of upland vegetation adjacent to wetlands would cause indirect impacts 

by removing protective upland vegetation buffers. 

Low to moderate impacts on a wetland associated with streams would result from depositing fill 

associated with culvert installation or replacement and installing a ford in an existing access 

road. Permanent impacts to wetlands from the deposition of fill would occur in the following 

location and from the activities described: 

• Wetlands associated with the stream between Structures 5 and 6: replace culvert, widen 

road to 12 feet, and rock road surface.[Deleted because there are no wetlands adjacent to 

this stream]

• Wetland and stream between Structures 15 and 16: create a rocky crossing (ford) of the 

stream area, widening the road to 12 feet. 

A few temporary access roads would be constructed in wetlands, resulting in moderate impacts 

at the following sites: 

• Approaches (short spur roads) to Structures 28 and 72. 

• Access road between Structures 46 and 48. A temporary culvert would be placed in a 

ditch at the edge of this wet meadow. 
3-34 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

Tensioning Sites

The use of tensioning sites would have no to low impact on wetlands because the sites would not 

be located within 50 feet of wetlands. 

Operation and Maintenance

Operation and maintenance is expected to have a low impact on wetlands and waterways. 

Maintenance would include occasional trimming or removal of tall-growing vegetation from 

wetlands and adjacent uplands and road maintenance activities near or within wetlands. 

Maintenance of structures or roads in or directly adjacent to wetlands would rarely be needed, 

but could result in minor disturbance of wetland or adjacent upland vegetation. 

3.7.3 Mitigation 

If the project is implemented, the following mitigation activities will be used to reduce impacts 

on wetlands: 

• Roads and structures will be located to avoid wetlands and streams whenever possible. 

• Any construction activities within wetlands will be designed and implemented to 

minimize impacts, and BPA will coordinate with the Army Corps of Engineers (ACOE) 

to obtain a permit for any fill placed in wetlands and comply with any required mitigation 

identified by the ACOE. 

• An environmental specialist will meet with contractors and inspectors in the field to visit 

wetlands and waterways near or within construction areas to go over avoidance and 

mitigation measures and any permit requirements. 

• Wetland boundaries in the vicinity of construction areas will be flagged or staked so 

wetlands and streams can be avoided. 

• When working next to wetlands (buffer areas) and water bodies, disturbance will be 

limited to the minimum necessary. 

• No machinery construction vehicles and equipment will be placed within 50 feet of any 

stream or wetland unless it is authorized by a permit or is on an existing permanent or 

temporary road constructed for access to the site. 

• Tensioning sites will not be located within 50 feet of wetlands. 

• Machinery will be refueled and stored at least 200 feet from wetlands and waterways and 

inspected regularly for leaks. 

• Mitigation measures required by WDFW will be used when conducting instream work. 

• Erosion control measures to avoid sedimentation of wetlands and streams will be used. 

• When temporary roads are built in wetlands, contractors will underlay temporary fill with 

geotextile fabric, remove all fill, and revegetate according to any permits. 

• When holes are excavated for structures in wetlands, contractors will avoid deposit of 

excavated material into wetlands by placing geotextile fabric around the excavation site, 

removing all excavated material from the wetland, and stabilizing it in an upland area. 

• Disturbed areas will be revegetated with native species, and specific revegetation 

guidelines in permits will be followed. 
Bonneville Power Administration 3-35 

3.7.4 Unavoidable Impacts Remaining After Mitigation 

In areas where temporary roads would be constructed in 0.43 0.30 acres of wetlands, some 

wetland functions would be lost or impaired during construction until revegetation and other 

mitigation efforts result in full recovery. Installation and replacement of culverts and a ford, and 

vegetation clearing for road and structure construction, would temporarily increase the discharge 

of sediment into wetlands, even with the use of silt fences, mulching, and other best management 

practices. The construction of two structures and an access road improvement would result in 

permanent fill in wetlands (0.08 0.018 acres), a minor amount. 

3.7.5 Cumulative Impacts 

Pacific County’s and WSDOT’s routine maintenance of existing roads and bridges could be done 

in or near wetlands in the project area, but, similar to BPA’s road maintenance work, such 

activities are expected to have no or low impact on wetlands. 

Past, present, and future logging activities in the project area, including BPA’s danger-tree 

removal project, have affected wetland functions. BPA removed danger trees in and near some 

wetland areas along the ROW; wetland vegetation was crushed and soils were compacted in 

some wetlands and wetland buffer areas. Road maintenance conducted by BPA resulted in the 

impacts to some wetlands associated with stream crossings. 

The U.S. Army Corps of Engineers (ACOE) issues permits under Section 404 of the Clean 

Water Act for filling (adding material) to wetlands. In the last 10 years, the Seattle District of 

the Corps issued a total of 312 Section 404 permits for wetland fill in Pacific and Grays Harbor 

counties. A total of 300.07 acres of wetland fill was permitted in the two counties, with a total of 

393.10 acres (131 percent) of mitigation required (U.S. Army Corps of Engineers 2002). 

Although total acreage of wetlands in the two counties is unknown, given the prevalence of 

wetlands in the project area, it is likely that only a small fraction of the total wetland acreage in 

the project area has been filled during the last ten years. The proposed action, including the 

approximate 0.08 0.018 acres of permanent fill and 0.43 0.30 acres of temporary fill in wetlands, 

would add only a minor amount to the total of past, present, and future wetland impacts in the 

area. 

3.7.6 Potential Impacts—No Action Alternative 

The nature of impacts to wetlands would be similar to those described for the proposal. 

Activities that could affect wetlands include vehicular traffic, replacement of transmission 

structures, vegetation management, and access road improvements, including culvert 

replacement. Under this alternative, seven structures would not be relocated from wetlands to 

uplands. Current levels of disturbance to wetlands would continue or increase as existing 

structures deteriorate, particularly structures in wetlands with no access. 
3-36 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

3.8 FLOODPLAINS 

3.8.1 Affected Environment 

The Federal Emergency Management Agency (FEMA) identifies areas with a one-percent 

chance of being flooded in a given year as 100-year floodplains. The floodplains of Lower 

Salmon Creek, the North River, and the Little North River are in or near the ROW (Figure 3-2). 

3.8.2 Environmental Consequences—Proposed Action 

Removal of Existing Structures and Installation of New Structures

Impacts on floodplains from these activities are expected to be low to moderate (Table 3-4). Six 

existing structures within or on the boundaries of floodplains would be removed; two of these 

structures would be relocated outside the floodplain. 

Activities within floodplains would be temporary, short-term, and localized, only minimally 

altering their functions. The primary direct impacts on floodplains are expected to result from 

soil compaction and removal of vegetation, leading to possible subsequent erosion. Soil 

compaction may interfere with the subsurface water flow in the floodplain, while vegetation 

removal may destroy some habitat and hinder the capacity of the floodplain to dissipate water 

energy during floods. Both of these actions could lead to erosion. Drilling holes that would 

support new structures may also result in some excavated soils being deposited within the 

floodplain. However, for the 4 structures, only 100 cubic yards of fill covering about 100 square 

feet would be permanently deposited in floodplains. The new tubular steel structures are less 

likely than existing structures to collect flood debris. BPA would use standard construction 

practices and BMPs that minimize damage to floodplains. 

Indirect impacts on floodplains are expected to be low and limited to incidental amounts of 

sediment deposition in the floodplain from soil erosion in disturbed areas. Installation of 

structures that are located directly upslope from floodplains, such as Structure 143, could cause 

erosion and the deposition of soils in floodplains. The amount of sediment deposited would not 

change existing flood storage capacity or alter the course of floodwaters. 

Access Roads

Improvements to existing roads are expected have a low to moderate impact on floodplain 

functions because only limited road improvements are planned near floodplains (Table 3-4). 

Indirect impacts on floodplains from road improvements are expected to be low because only 

incidental amounts of rock would be deposited in floodplains. 

Tensioning Sites

There would be no impact to floodplains because floodplains would be marked on project maps 

and tensioning sites would be restricted to areas outside of floodplains.
Bonneville Power Administration 3-37 

Figure 3-2. Floodplains 

FOR SECURITY PURPOSES 

This figure was deleted from the electronic version of this document 
3-38 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

Table 3-4. Activities in Floodplains and Their Impacts 

Floodplain Structure Access Road Proposed Structure 

66 No Impact: No road 

construction or 

improvements. 

Low impact: Move structure location 

10.8 feet to place it at the edge of the 

floodplain. 

Lower Salmon 

Creek 

73 No Impact: 

No road construction or 

improvements. 

Low Impact: Move structure location 

9.4 feet to increase distance from a 

perennial, fish-bearing stream; 

structure remains in floodplain. 

120 Moderate Impact: Improve 

approximately 200 feet of the 

existing access road at edge 

of floodplain. 

No impact: Existing and proposed 

structures are outside the floodplain. 

121 No Impact: Access on 

existing driveway and lawn 

would be restored. 

Low Impact: Move structure location 

10 feet to place it outside the 

floodplain. 

North River 

136 Moderate Impact: Improve 

approximately 270 feet of the 

existing access road at edge 

of floodplain. 

Low Impact: Replace existing 

structure; it remains on floodplain 

boundary, about 10 feet above the 

floodplain elevation. 

142 No Impact: Access through 

existing yard. 

Low Impact: Replace existing 

structure within floodplain. 

Little North 

River 

143 No Impact: Access from 

outside of floodplain. 

Low Impact: Move proposed 

structure outside of floodplain.

Operation and Maintenance

Direct impacts on floodplains from routine maintenance activities are expected to be low because 

such activities would be infrequent, short-term, and localized, and would not substantially alter 

floodplain functions. Routine maintenance of structures and access roads in or directly adjacent 

to floodplains could result in minor disturbances of floodplains. Maintenance of access roads 

and the ROW, including such activities as grading or rocking of road surfaces, replacement of 

culverts, and vegetation removal, could result in minor soil compaction and erosion. 

3.8.3 Mitigation 

If the project is implemented, the following mitigation activities will be used to reduce impacts: 

• Proposed roads and structures will be located to avoid floodplains, where possible. 

• Erosion control measures will be used to avoid sedimentation of floodplains. 

• Tensioning sites will not be located in floodplains. 

• Disturbed areas will be revegetated with seed from native species. 

3.8.4 Unavoidable Impacts Remaining After Mitigation 

Construction activity in or near floodplains could, on a very small scale, permanently affect the 

capacity of affected floodplains to dissipate flood energy, reduce the capacity to filter nutrients 

and contaminants to maintain water quality, and reduce structural complexity within the 

floodplains. However, the area within floodplains affected by the proposed project is relatively 

small, so unavoidable impacts are expected to be low. 
Bonneville Power Administration 3-39 

3.8.5 Cumulative Impacts 

Pacific County’s routine maintenance of existing roads and bridges could be done in or near 

floodplains in the project area; similar to BPA’s road maintenance activity, it is expected to have 

no or low impact on floodplains. The extent to which WSDOT’s scheduled road improvements 

may affect floodplains is unknown. None of the proposed WSDOT vegetation control projects 

appear likely to directly or indirectly affect floodplains. Effects on floodplains from road work 

and vegetation management associated with BPA’s proposed action, when added to other similar 

activities, would be minor. 

Past, present, and future logging activities in the project area, including BPA’s danger tree 

removal activities, could adversely affect floodplains. Danger trees were removed in floodplains 

at Structures 66, 73, 121, 142, and 143. Depending on their extent, future tree removal and 

logging operations in floodplains could reduce the floodplain’s capacity to dissipate flood energy 

and to filter nutrients and contaminants that maintain water quality; and could reduce structural 

complexity within the floodplain. Overall, though, the proposed action is not expected to 

contribute noticeably to cumulative changes in floodplain qualities and function, due to the small 

area involved. In addition, removal of two structures from floodplains would slightly reduce the 

impact to floodplains from future maintenance work. 

3.8.6 Environmental Consequences—No Action Alternative 

Removal of two transmission structures from floodplains (Table 3-4) and their replacement by 

structures on upland sites would not occur under this alternative. Few additional impacts on 

floodplains beyond those from current transmission line operation and maintenance would be 

expected, although maintenance needs could increase as structures deteriorate. Existing impacts 

are low because activities within or adjacent to floodplains result in only short-term, localized 

disturbances and only minimally affect floodplain functions. Furthermore, BPA would continue 

to follow BMPs that minimize damage to floodplains. 

3.9 VISUAL QUALITY 

3.9.1 Affected Environment 

The visual setting is the Willapa Hills area of western Washington, which is characterized by 

rolling, heavily forested hills. Locally, the topography has considerable relief, which obstructs 

long-distance views from most locations. The existing transmission line corridor is a dominant 

visual feature of the setting, providing contrasts with the surrounding forest land in terms of a 

cleared linear feature and the differing form and texture inherent in the existing lattice steel box 

structures. The affected area for visual resources extends beyond the corridor to adjacent forest 

lands dominated by coniferous species, Highway 101, and nearby residences. Areas where 

timber has been harvested, including areas cleared as part of the BPA danger tree removal 

project in 2002, are important visual features. 

Washington State Department of Transportation (WSDOT) has classified a few sections of 

Highway 101 as scenic. The agency has developed four classifications for scenic highways 

within the state. These designations range from Class A (superior scenic quality) through Class 

D (industrial, heavily urbanized or deteriorated area). Portions of Highway 101 in the project 
3-40 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

area are designated Class B (high scenic value), with a sub-classification known as BX. This 

designation refers to areas where an aerial facility (such as a transmission line) could be allowed 

if factors such as configuration, color and location allow landscape quality to be maintained. 

The existing transmission line corridor creates visual impacts. In general, they are most apparent 

where the corridor is adjacent to or near Highway 101, near residences, or near recreation sites. 

Figure 3-3 shows a representative scene of the existing corridor. 

Figure 3-3. Looking North at Structure 112 and 113 

3.9.2 Environmental Consequences—Proposed Action 

Construction, operation and maintenance of transmission facilities can affect visual resources on 

a long- and short-term basis. Any part of the proposed facilities can contribute to visual impacts: 

structures, conductors, insulators, spacers, ROW clearing, access roads, removal of existing 

structures, clearing for structures, and pulling and tensioning sites for the conductors. 

Construction activity within the corridor would cause short-term impacts on the visual 

environment. Potential long-term impacts would result from a change in the visual appearance 

of the transmission line and corridor by replacing the existing steel lattice structures with taller 

tubular steel poles. 

The greater the distance of the proposed line from sensitive viewpoints, the less visible it would 

be. Different landforms and vegetation influence visual impact; the topography and forest cover 

screen transmission line features at many locations. 

Impacts on Motorists

Motorists would continue to view the transmission line and structures in the areas adjacent to and 

near Highway 101. For the most part, views would be intermittent and the topography and 
Bonneville Power Administration 3-41 

forested landscape would continue to dominate the visual setting. For some motorists, the visual 

experience may be improved because the proposed single-pole structures would result in less 

contrast with the visual setting than the existing structures (Figures 3-4 and 3-5). Contrasts 

would be less because of their simpler form and texture. In general, visual impacts to motorists 

would be low. Visual impacts along those areas of Highway 101 classified as having high scenic 

quality would be similar to that described above, but impacts would likely be moderate because 

of the greater visual sensitivity of these areas. 

The corridor passes within two sections of Highway 101 that are classified BX. These sections 

are between Mile Posts 66.2 to 70.9, and 77.0 to 78.5 (structures 45 to 95 and 150 to 165, 

respectively). Structures 51 to 57, 68 to 78, 84, 87, and 90 would be seen between Mile Posts 

66.2 to 70.9 (Figure 3-6). Structure 163 is visible from Highway 101 between Mile Post 77.0 

and 78.5. Thus, approximately 30 percent of the highway classified as having high scenic value 

would have views of the transmission line, but this would be a low impact because this portion of 

the highway already has these views, and the proposal would not be considered a significant 

change from current conditions. 

Access to structures near or adjacent to Highway 101 would be from Highway 101 or existing 

access roads (except Structures 55 and 56 where new access would be developed). Motorists 

would be exposed to construction activity and intermittent lane closures while the new structures 

are erected. Construction activities and temporary lane closures along Highway 101 represent a 

low to moderate impact, because views would be brief and the effect short-term. 

Impacts on Residents

Residents are generally sensitive to changes in their surrounding environments and views. Those 

residents with direct views of transmission line structures on their property would be more 

sensitive to changes in views than those residents near the corridor with partial or no views. 

Residences tend to occur in small clusters near the corridor. However, the rebuilt line would be 

mostly within the existing corridor; residents close to the corridor already have the existing line 

in their view. Similar to impacts on motorists, visual impacts may be less for those residents 

who believe the new single-pole structures provide less contrast or who prefer the appearance of 

the proposed structures compared to the existing structures. 
3-42 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

Figure 3-4. Looking North at Structure 26 near 

Dixon Road 

Figure 3-5. Tubular Steel Pole Structure Simulation 
Bonneville Power Administration 3-43 

Figure 3-6. Looking North at Structure 52 in 

Foreground, in WSDOT Scenic Classification BX 

North of the Raymond Substation, the corridor passes near or adjacent to several homes (near 

Structures 21 to 28, 37 and 38, and 46 to 48). Views from six residences would be affected. 

Structures 22, 23 and 47 are located on the properties of residences, and the new structures 

would be visible to those residents (Figure 3-7 shows a sample view). Their views would be 

affected by short-term construction activity and long-term presence of the line, but impacts 

would be low because structure locations are moving less than 10 feet from the existing position 

in most places, and where they are moving more, they would be moved further from the houses. 

Impacts to remaining residents in this area are anticipated to be low because the line would be a 

less dominant feature in their view. 

There are 25 homes between structures 115 and 144 that have partial or no views of the corridor. 

A few residents along Lund Road have intermittent background views of Structures 115 and 116 

in the distance, because the structures are on higher ground. Structure 142 is partially visible in 

the background against a stand of trees. Impacts to these residents would be low because the 

majority of the corridor is shielded from view by the existing rugged, wooded landscape. There 

is one single-family home immediately north of the Cosmopolis Substation. Impacts to this 

residence would be low because the view is partially screened and the corridor already has 

established impacts. 
3-44 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

Figure 3-7. Looking North Towards Structure 47 

(foreground) and 48 & 49 in the Background 

Impacts on Recreation

Impacts on recreational use would be low. Between Structures 2 and 4, the corridor passes 

adjacent to Butte Creek Picnic Area, which is heavily wooded. No structures are clearly visible 

from within the park. Some hiking trails may pass near or under the line. Hikers would see 

some of the structures intermittently against a backdrop of old-growth trees. 

As the corridor enters the Cosmopolis Substation, it passes near Highland Public Golf Course. 

Structure 167 is partially visible from one of the golf course fairways. A brief section of the 

main entrance to the golf course has a short glimpse of the substation. 

Mill Creek Park, which is located below and approximately 1,200 feet west of the substation, has 

no views of either the substation or the corridor. Impacts to these recreation facilities would be 

low because views are shielded by the existing landscape. 

A gun club just northeast of the Raymond Substation has views of the substation but not the 

corridor. There would be no impacts to the gun club as a result of the proposed action. 

3.9.3 Mitigation 

If the project is implemented, the following mitigation will be used to help the transmission line 

blend more effectively with the surrounding environment: 

• Non-lustrous insulators (i.e., non-ceramic insulators) and conductors will be used. 

• Contractors will maintain construction sites free of debris. 
Bonneville Power Administration 3-45 

• BPA will maintain the corridor free of debris resulting from transmission line operation, 

maintenance, and construction activities after construction. 

3.9.4 Unavoidable Impacts Remaining After Mitigation 

Construction activities would be visible, resulting in temporary impacts. The transmission 

structures and conductors would become part of the visual setting and be visible to motorists, 

residents, and recreationists, a permanent impact but similar in nature to the existing 

transmission line. Therefore unavoidable impacts, after mitigation, would be low to moderate.

3.9.5 Cumulative Impacts 

Areas cleared for timber harvest have substantially changed the visual quality of the landscape. 

BPA’s danger tree removal project has also changed the landscape’s visual character. In some 

places, the corridor is more visible and open due to the removal of vegetation. Over time, the 

growth of vegetation in cleared areas would help cleared areas blend with the landscape. Timber 

harvesting will continue to alter the visual setting and contribute substantially to visual impacts. 

BPA’s ongoing vegetation management activities would also affect the area’s visual character. 

Because the proposed project is replacing an existing transmission line, most of the visual impact 

occurred when the original line was built; as a result, the rebuilt line would not noticeably add to 

the cumulative visual effect of past, present, and future activities in the area. 

3.9.6 Environmental Consequences—No Action Alternative 

Motorists, residents, and recreationists would continue to experience visual impacts of the 

existing transmission line and its maintenance. 

3.10 AIR QUALITY 

3.10.1 Affected Environment 

The agencies with primary air quality jurisdiction in Grays Harbor and Pacific counties are the 

Olympic Region Clean Air Agency (ORCAA), the Environmental Protection Agency (EPA), and 

Washington Department of Ecology (WDOE). The ORCAA has adopted the standards 

established by WDOE (WAC 173-470). Given the project’s rural setting, the three pollutants of 

potential interest are particulates, carbon monoxide and ozone. None of the project area is within 

a designated non-attainment area. 

Particulates

Particulate matter consists of fine particles of smoke, dust, pollen, or other materials that remain 

suspended in the atmosphere for a substantial period of time. Particulates are measured in two 

forms: Total Suspended Particulate (TSP) and PM10 (a subset of TSP). PM10 is fine 

particulate matter, defined as smaller than 10 micrometers in diameter, that is easily inhaled 

(respirable). The annual average air standard for PM10, as established by WDOE and adopted 

by ORCAA, is 50 micrograms per cubic meter. 

The cities of Aberdeen, Hoquiam, and Cosmopolis were the focus of two short-term studies in 

late 1997 and early 1998. The primary study focused on particulate matter (PM10); emissions 
3-46 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

were largely smoke and particles from solid fuel-burning devices such as woodstoves and 

fireplaces, as well as road dust and industrial emissions. None of the sampling equipment 

measured values exceeding the National Ambient Air Quality Standards (NAAQS) for PM10. 

Mills in Cosmopolis and Raymond emit air pollutants, including particulates. According to 

ORCAA, there have been no recent violations of standards or emission problems related to 

routine operations at mills in either location (Moody 2002). Principal sources of particulates 

near the corridor are wood stoves and fireplaces, dust from exposed soils in logged areas, 

logging equipment emissions, and burning of logging slash. 

Carbon Monoxide

Carbon monoxide (CO) is an air pollutant generally associated with transportation sources. The 

highest ambient CO concentrations often occur near congested roadways and intersections 

during periods of low temperatures, light winds, and stable atmospheric conditions. The 8-hour 

average standard, as established by WDOE and adopted by the ORCAA, is 9 parts per million. 

Vehicles along Highway 101 are the primary source of CO in the project area. Because ORCCA 

does not operate CO monitoring stations in Grays Harbor or Pacific counties, it is not possible to 

determine CO concentrations for the project vicinity. However, because the traffic volumes on 

Highway 101 rarely result in congestion, it is unlikely that CO levels exceed standards. 

Ozone

Ozone is primarily a product of more concentrated motor vehicle traffic on a regional scale. It is 

created during warm sunny weather by photochemical reactions involving hydrocarbons and 

nitrogen oxides. Small amounts of ozone may be produced by the existing 115-kV transmission 

line as a result of corona (the breakdown of air at the surface of conductors). ORCAA does not 

monitor ozone in Grays Harbor or Pacific counties. Ozone concentrations in the project area are 

anticipated to be less than the 1-hour average standard of 0.12 ppm because the area is sparsely 

developed and traffic levels are relatively low. 

3.10.2 Environmental Consequences—Proposed Action 

During the construction period from May April to November 2004 2003, air quality could be 

affected. Activities could increase dust and particulate levels on a temporary basis in a localized 

area. Water trucks would be used to control dust. Air quality impacts would be low. 

Vegetation cleared in conjunction with access road improvements and ongoing vegetation 

management activities would, in most cases, be left lopped and scattered, piled, or chipped. 

Wood burning could increase particulates, but the amount of burning would be limited, so air 

quality impacts are expected to be minor. 

The operation of heavy equipment during construction could impact air quality. Heavy 

equipment and vehicles emit pollutants such as carbon monoxide, carbon dioxide, sulfur oxides, 

particulates, oxides of nitrogen, and volatile organic hydrocarbons. Vehicle emissions would be 

short-term and localized, and thus would be expected to have a low impact on air quality. 
Bonneville Power Administration 3-47 

During operation, the transmission lines would emit limited amounts of ozone and nitrogen 

oxides as a result of the corona effect. However, these substances would be released in 

quantities generally too small to be measured or to have any adverse effect on humans, animals 

or plants. In addition, there would be occasional vehicle emissions during maintenance 

activities. Impacts on air quality during operation and maintenance would be low. 

3.10.3 Mitigation 

If the project is implemented, the following mitigation will be used to minimize impacts to air 

quality: 

• Water trucks will be used to control dust during construction. 

• All vehicle engines will be in good operating condition to minimize exhaust emissions. 

3.10.4 Unavoidable Impacts Remaining After Mitigation 

Emissions of pollutants associated with vehicles and equipment during construction and 

maintenance and with corona during operation could not be totally mitigated or avoided. 

However, these impacts would be low, and the mitigation measures identified in Section 3.10.3 

would further reduce the level of impacts associated with vehicles and equipment.

3.10.5 Cumulative Impacts 

Vehicular traffic on Highway 101 and local roads, logging activities, recent BPA danger tree 

removal activities, residential wood burning, and industrial emissions near Cosmopolis and 

Raymond in the past have resulted in and currently result in pollutant emissions. These sources 

of pollutants will continue in the future. Ongoing activities in the project area do not violate air 

quality standards. The proposed action would contribute a small amount to pollutant levels; it is 

unlikely cumulative concentrations would violate air quality standards. 

3.10.6 Environmental Consequences—No Action Alternative 

Impacts to air quality from construction activities would be avoided. Low impacts on air quality 

could be associated with corona during operation of the existing line and with vehicle use during 

maintenance activities. 

3.11 SOCIOECONOMICS 

3.11.1 Affected Environment 

Population Characteristics

Grays Harbor and Pacific counties, the two counties crossed by the corridor, have a combined 

2002 population of about 89,400, which is about 1.5 percent of the state’s population 

(Washington State Office of Financial Management 2002). Both of these counties are classified 

as nonmetropolitan. Grays Harbor County has more than 75 percent of the two counties’ 

population (68,400) and includes the largest city in the area, Aberdeen, with a 2002 population of 

16,250. Pacific County has a population of 21,000. See Table B-4 in Appendix B. 
3-48 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

Between 1990 and 2000, the two counties grew at a combined rate of about 6 percent, much 

slower than Washington State’s overall growth rate of 21 percent. Most of that growth was due 

to people moving into the area (about 82 percent), compared to the state where in-migration was 

responsible for only 63 percent of the gain. Between 2000 and 2002, population in the twocounty area increased at a much-reduced rate of 1.4 percent, compared to the state at 2.5 percent. 

Economic Characteristics

Historically, the economy of these two rural counties has been based on natural resources. 

Timber harvesting, commercial fishing, farming, and value-added processing (e.g., sawmills, 

pulp and paper mills, food and fish processors) continue to dominate economic activities. One in 

every six workers within the two-county area is engaged in natural resource industries. Grays 

Harbor is the state’s top ranked county in annual timber harvest and Pacific County is one of the 

leading counties for commercial and recreational fish and shellfish harvest. Agriculture is not 

prevalent in these counties except that both are among the leading counties in the United States 

in the production of cranberries. 

Despite their dependence upon natural resources, the leading employment sectors for both Grays 

Harbor and Pacific counties are services, retail, and government (U.S. Bureau of Economic 

Analysis 2002 and WA State Employment Security Department 2000). These three sectors 

account for over 60 percent of total employment in the two-county area. See tables B-5 and B-6 

in Appendix B. 

Income Characteristics

For the two-county area, dividends, interest, rent, and especially transfer payments (primarily 

retirement income), represent a greater share of total personal income than for the state (Table 

B-7, Appendix B). While total personal income in the state more than doubled in real terms over 

the two-decade period, personal income within the two-county area increased by only 17 percent. 

Because dividends, interest, and rent and transfer payments have grown in the area, this was 

enough to offset the real decline in net earnings during the twenty-year period. 

Both Grays Harbor and Pacific counties had modest growth in per capita income between 1980 

and 2000. In spite of overall growth in real per capita income, both counties had lower per capita 

incomes than Washington State and the gap has widened during the time period. 

Environmental Justice

Environmental justice, as described under Executive Order 12898 of 1994, directs Federal 

agencies to identify and address, as appropriate, disproportionately high and adverse human 

health or environmental effects on minority or low-income populations. 

Minority Population. The minority population for the two-county area is 11.2 percent, less than 

the state’s share of 14.6 percent (U.S. Bureau of the Census 2002). The 11.2-percent minority 

population does not surpass the minority threshold (50 percent) established as an indicator for 

whether a minority population is meaningfully greater than that represented within the state as a 

whole. However, the minority population for American Indian or Alaska Native in the twocounty area is meaningfully greater than for the state (4.1 percent versus 1.6 percent). Using this 
Bonneville Power Administration 3-49 

latter threshold, a minority population is present in the two-county area. See Table B-8, 

Appendix B. 

Low-Income Population. According to 2001 estimates, the two-county study area has a median 

household income of $36,468 or 75 percent of the median income according to Federal income 

limits (WA Office of Financial Management 2001). This median income level does not meet the 

“very low income” threshold for poverty status (i.e., 50 percent of the state median income). 

However, Grays Harbor and Pacific counties’ median household income falls below the 

80-percent “low income” threshold of the state’s median household income, which meets Federal 

low-income criteria (Table B-9, Appendix B). 

3.11.2 Environmental Consequences—Proposed Action 

Housing Availability

During peak construction in the summer of 2004 2003, a maximum of 50 workers would work 

along various segments of the 18-mile corridor. The origin of the work force is not known at this 

time and would depend upon where the construction contractor is based. If a local contractor is 

used, it is likely nearly all workers would commute and there would be no impact on housing. 

If workers (and possibly some dependents) are from out of the area they would require 

temporary lodging in the local area during construction. In the immediate project area 

(Raymond to Aberdeen), there are 12 motels with a total of 255 rooms and 6 RV parks and 

campgrounds. A number of the lodging facilities have kitchen units and could be used for 

extended stays by workers. Many construction workers could rent parking for RVs or other 

vehicles in which they reside. Also, rental housing vacancy rates in each of the counties are 

relatively high compared to that of the state. 

Because construction workers can be housed and they would not place an undue burden on 

communities in the area, impacts are considered low. 

Employment and Income

The proposed project would stimulate the area’s economy during construction through material 

purchases in the area, payroll, and related indirect and induced spending, or “multiplier effects.” 

These economic benefits would occur for a limited time during construction. 

Purchases of local supplies and materials and other spending by construction workers would 

create positive economic impacts. Total project costs have been estimated at approximately $5

$7 million (2002 2003 dollars) for the proposed project. An estimated 5 to 10 percent of total 

project costs would involve local purchases of fuel, vehicle parts and other goods and services in 

the two counties. Income (net) earned by construction workers would be about $1.3 million. 

Non-local workers spend an estimated 40 percent of their net pay locally. Both material 

purchases and salary would have additional multiplier effects that would create added short-term 

income. 
3-50 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

These impacts are very small relative to the amount of economic activity in the two counties, and 

are short-term by nature. Therefore, the impacts of these additional expenditures on overall area 

economic activity, while positive, would be low. 

After construction, the new transmission line would not increase economic activity in the area. 

However, the transmission line and fiber optic cable may contribute to regional stability and 

economic growth by reliably meeting power demands and providing access to high-speed 

communications. These are potential long-term positive impacts. 

Property Taxes

The construction of this project would not affect the amount of property taxes collected by the 

counties crossed by the proposed transmission line. Property owners would continue to pay 

property taxes in accordance with existing valuations; no property devaluations would be likely 

because few additional use restrictions are contemplated. Possible exceptions include an extra 

20 feet of width between structures 115 and 116 (a distance of approximately 1,300 feet) where 

strong winds could cause the conductor to swing outside the existing ROW; and the small areas 

where roads would be constructed. No direct beneficial tax effects would occur because sales of 

privately owned property to BPA for transmission line and access road right-of-ways are not 

subject to real estate tax (WAC 458-61-420 (1) (c)). 

Sales Taxes

States cannot tax direct purchases by the Federal government; however, Washington would tax 

local purchases by government contractors building the line (Excise Tax Bulletin 316.08.193 and 

WAC 458-20-17001). Workers would also be taxed on all local purchases of goods while in 

Washington, unless those individuals’ permanent residences are within states or other 

jurisdictions that are exempt from paying a local sales or “use tax” within the state. State sales 

tax in Washington is 6.5 percent. Each local jurisdiction also has a sales tax which, when 

combined with the state sales tax, could be 7.6 to 8.1 percent in the project area. 

With the exception of local purchases of crushed rock for access road widening, and other minor 

purchases such as fuel and replacement tools, few construction materials would be purchased by 

the contractor. Structure steel, conductors, and insulators and steel grills for footings would be 

supplied by BPA and would not be taxed. Any tax revenue received, however, would be a 

positive impact. 

Nuisance, Trespassing, and Vandalism

Local residents with land crossed by the corridor could have their land use restricted by 

construction and periodic maintenance activities. Maintenance of the transmission line requires 

periodic inspection and occasional action by maintenance crews. Landowners are contacted 

prior to crew entry. However, vegetation and soils may sometimes be damaged by vehicles used 

for maintenance, particularly for emergencies. 

Access roads could be used by unauthorized motorists and hunters who could be a nuisance to 

industrial forest owners and other landowners. However, because most of the corridor is remote 

and access is generally restricted by the use of locked gates, potential impacts from trespassing 
Bonneville Power Administration 3-51 

and vandalism would be low. Some gates are left open by timber land owners during hunting 

season so that hunters may enter private timber lands. 

Property Impacts

Some short-term adverse impacts on property value and salability could occur on an individual 

basis. However, these impacts are highly variable, individualized, and unpredictable. The 

project is not expected to cause overall long-term adverse effects on property values along the 

existing ROW. 

If landowners refuse BPA's offers to buy land rights (ROW easements), BPA would acquire the 

rights through condemnation. In limited cases, adjustments to ROW location may be made or 

feasible alternative means of access may be found. 

Environmental Justice

The statistical data indicate that the more restrictive environmental justice thresholds are 

exceeded (the minority population for American Indian or Alaska Native in the two-county area 

is meaningfully greater than for the state, and Grays Harbor and Pacific counties’ median 

household income falls below the 80-percent “low income” threshold of the state’s median 

household income). However, given the limited extent of the corridor in Grays Harbor and 

Pacific counties and the corridor’s passage through sparsely populated privately-owned lands, 

the project would not affect a disproportionately high percentage of low-income or minority 

residents. In addition, even if disproportionate impacts were to occur, they would be limited to 

visual resource impacts. Such impacts would be low to moderate. 

3.11.3 Mitigation 

BPA engineers would work with industrial forest owners and other landowners to site structures 

and roads to minimize impacts to forestry activities. 

3.11.4 Unavoidable Impacts Remaining After Mitigation 

Unlikely, but potentially low visual impacts on low income or minority populations could occur. 

3.11.5 Cumulative Impacts

In 2002, the BPA danger tree removal project created a small demand for temporary 

housing/lodging, stimulated a relatively small level of economic activity and, through acquired 

easements, had a small-scale effect on timber production and possibly taxes. Because of its 

short-term nature, BPA’s proposed transmission project would not add noticeable long-term 

benefits or impacts to employment, housing, or tax revenues in the area. However, the 

transmission line and fiber optic cable could contribute to economic growth, along with ongoing 

local efforts, by providing reliable electrical power and access to high speed communications. 

3.11.6 Environmental Consequences—No Action Alternative 

The socioeconomic impacts of construction activity, both beneficial and adverse, would not 

occur. The negligible socioeconomic effects of current maintenance activities would continue. 
3-52 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

3.12 CULTURAL RESOURCES 

3.12.1 Affected Environment 

Historic Overview

Before early pioneers settled in Grays Harbor and Pacific County, the Chehalis or Tsihalis and 

Chinook people inhabited the area in several villages, most located along the major rivers, Grays 

Harbor, and Willapa Bay. Other Tribes that once lived in the area were the Hookium, 

Humptulips, Wynoochee, Satsop and Quinault. There is little information on the area’s use by 

visiting Tribes, although several tribes report their historic use of the area. 

Euro-American exploration of the Grays Harbor region began in the late 1700s and early 1800s. 

Early settlers were mainly farmers. Because of the region's isolation from markets, the timber 

and fishing industries did not thrive until the arrival of schooners, which provided transportation 

for local products to outside markets. The Grays Harbor and Willapa Bay regions then 

developed to take advantage of the nearby abundant natural resources. The settlement of the 

Grays Harbor region was predicated on sawmills and timber. The earliest efforts began in 1852, 

when a sawmill was established on the Chehalis River at its confluence with Cedar Creek, near 

present day Oakville (Van Syckle 1980). 

The Willapa Valley area was first settled in 1852. Development of the area followed the same 

pattern as the Grays Harbor area to the north. Electric power was produced in the Willapa Bay 

region as early as the 1890s, albeit on a limited scale and possibly only intermittently. The 

earliest power generation plants were located onsite to provide power to run the lumber mills. 

Cultural Resource Surveys

Four cultural resource surveys were conducted in the project area for BPA over the past year; 

collectively they covered the entire ROW and areas outside of the ROW that could be affected 

by project activities. It was observed that previous disturbances within the transmission line 

ROW have resulted from logging and clearing activities, and the construction and maintenance 

of access roads; surface visibility was poor in many locations. No artifacts or evidence of 

cultural resources were observed during the surveys. 

The State Historic Preservation Office (SHPO) and Tribes, including one Tribal Historic 

Preservation Office (THPO), were given an opportunity to provide input on survey methodology 

and results of the first three of the surveys; they were provided with the Rebuild Project report in 

December 2002. Concurrence was received from the SHPO for the first three surveys. and BPA 

is currently consulting with the SHPO on the proposed action.

Historical Background of the Existing Transmission Line

The origin of the transmission line is obscured by conflicting accounts and numerous business 

dealings that prevent a simple accounting of when it was built and by whom. It is believed the 

transmission line was constructed around 1927 to connect the Grays Harbor area with the 

Willapa Bay region to the south, and to increase the amount of available electricity to Raymond 

and surrounding communities. Ownership of the line changed hands on several occasions in the 

ensuing years. According to the Public Utility District (PUD) #2 of Pacific County, the Willapa 
Bonneville Power Administration 3-53 

Electric Company purchased the existing transmission line in 1936 from the Western 

Washington Electric Light and Power Company (PUD n.d.). 

Subsequently, the Pacific County PUD #2 agreed in 1939 to buy the “business,” including the 

generation and distribution equipment, from the Willapa Electric Company while the newly 

created BPA agreed to purchase the Raymond Substation and the Raymond-to-Cosmopolis 

transmission line (PUD 1939). These facilities were added to BPA’s growing power grid 

anchored by the Bonneville and Grand Coulee dams. The PUD #2 then contracted with BPA to 

sell the PUD’s surplus power (PUD 1939). With the acquisition of the Willapa Electric 

Company’s power distribution facilities, the PUD #2 began supplying power to Pacific County in 

1940. The transmission line was constructed prior to construction of Highway 101. 

No original plans, schematics, or blueprints exist that show the design work or engineering that 

went into the construction of the original transmission line. The structures have been 

substantially modified and upgraded as needed over the years to keep pace with changing power 

requirements in the region. In 1952, the BPA added new structure tops and replaced the 

conductor. It is likely that individual structures have been replaced, because dismantled structure 

sections are located around the grounds of the Raymond Substation. 

The existing transmission line has some historic importance to BPA and to the local Historical 

Society because of its age, design, and historical context. While not the earliest electrical 

distribution system in the area, it greatly facilitated the spread of electrification to residential 

areas in the rural communities of Raymond and Cosmopolis. Although the line is important in 

BPA history, the structures themselves do not have the integrity to meet any of the criteria to be 

eligible for National Register of Historic Places listing. 

3.12.2 Environmental Consequence—Proposed Action 

Section 106 of the National Historic Preservation Act (NHPA) requires Federal agencies to 

consider the effects of their actions on historic properties. The NHPA provides a process (known 

as the Section 106 process) that enables agencies to access impacts to historic properties, and 

then avoid, minimize, or mitigate for these impacts. Historic properties may be prehistoric or 

historic sites, including objects and structures that are included in or eligible for inclusion in the 

National Register of Historic Places (NRHP). Historic properties also include artifacts or 

remains within historic sites and properties of traditional and cultural importance to Tribes. 

BPA consulted with the SHPO under Section 106 process for the proposed action. As a result, 

the impact definitions in Appendix A reflect the definitions of “adverse effect” in the Section 

106 regulations, the process to determine effects, and what is done if there are potential adverse 

effects. 

The investigations uncovered no archaeological materials in shovel test probes or on the ground 

surface, suggesting that no archaeological resources are located within the project area. Based 

on this evidence, it has been concluded that significant archaeological resources are unlikely to 

be located within the area of the proposed Rebuild Project. No archaeological resource impacts 

are anticipated. Because the transmission line does not meet NRHP eligibility criteria, there 

would be no adverse historic impact. In a letter dated December 27, 2003, the SHPO office 
3-54 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

concurred that no historic properties would be affected by the project as proposed and that the 

transmission line does not appear to be eligible to the National Register of Historic Places.

The transmission line is the only historical resource identified during the investigations of the 

area. The proposed project would result in the complete replacement of all remaining original 

structures. Any historical significance of the existing transmission line route would not be 

affected or obscured because the proposed project would preserve the route and maintain the 

original alignment within the existing ROW, although individual structure locations may be 

changed slightly. The new line would also maintain the function of the original line, serving as a 

link between Raymond and Cosmopolis. 

Because the local historical society and BPA are interested in the historical significance of the 

transmission line, features of the line would be documented, as described in 3.12.3 Mitigation. 

3.12.3 Mitigation 

The following mitigation will be pursued if the project is implemented: 

• Research was conducted to document the history and significance of the existing 

transmission line and presented to the Pacific County Historical Society. 

• The Pacific County Historical Society will be offered one of the existing transmission 

line structures for display at its new museum site. 

• In the event that archaeological material is encountered during project construction, the 

BPA archaeologist will immediately be notified and work will be halted in the vicinity of 

the finds; BPA will immediately notify the Washington SHPO. 

3.12.4 Unavoidable Impacts Remaining After Mitigation 

Implementation of the proposed action would have no adverse affects on known cultural or 

historic resources. 

3.12.5 Cumulative Impacts 

Although past, on-going, and future timber harvesting activities by other entities could affect 

cultural resources in the area, BPA’s proposal would not add to those effects. Construction and 

operation of the existing transmission line could already have affected archaeological resources 

if any were present. As noted above, the danger tree project and other BPA projects in the area 

were not expected to affect cultural resources. Therefore, the proposed Rebuild Project would 

not add impacts to cultural and archeological resources caused by past, present, or future 

activities in the area. 

3.12.6 Environmental Consequences—No Action Alternative 

It is unlikely that any adverse impacts to cultural resources would occur during operation and 

maintenance of the existing transmission line because there would be very little ground 

disturbance and there are no known cultural resources. 
Bonneville Power Administration 3-55 

3.13 HEALTH AND SAFETY 

3.13.1 Affected Environment 

This section summarizes public health and safety concerns such as electrical shocks, fires, 

aircraft obstructions, the effects of electric and magnetic fields related to transmission facilities, 

and construction activities. A more detailed discussion is provided in Appendix C. 

Transmission lines, like all electric devices and equipment, produce electric and magnetic fields 

(EMF). The strength of electric and magnetic fields depends on the design of the line and on 

distance from the line. Electric and magnetic fields are found around any electrical wiring, 

including household wiring and electrical appliances and equipment. There are no Federal or 

Washington state guidelines or standards for electric fields from transmission lines. BPA 

designs new transmission lines to meet its electric-field guideline of 9-kilovolt/meter (kV/m) 

maximum on the ROW and 5-kV/m maximum at the edge of the ROW. The proposed 115-kV 

line would easily meet BPA and National Electric Safety Code (NESC) requirements. 

Transmission lines and distribution lines (the lines feeding a neighborhood or home) can be a 

major source of magnetic field exposure throughout a home located close to the line. Similar to 

electric fields, there are no Federal or state guidelines or standards for magnetic fields. 

3.13.2 Environmental Consequences—Proposed Action 

Potential health and safety impacts associated with the project include those that could affect 

construction workers, operation and maintenance personnel, the public, and others who have 

occasion to enter the project corridor. Impact levels depend on public and occupational use of 

the land. The potential for public health and safety impacts increases in areas where human 

activities take place. 

Impacts During Construction

During construction and installation of the structures and conductor/ground wires, there is a risk 

of fire and injury associated with the use of heavy equipment, hazardous materials such as fuels, 

cranes, helicopters, and other activities associated with working near high-voltage lines. There is 

also a potential for fire during refueling of hot equipment such as trackhoes and bulldozers that 

cannot be taken off site for refueling. Connection of conductors may be accomplished using 

implosion fittings, which could be a source of injury to construction personnel. In addition, there 

are potential safety issues with more traffic on the highways and roads in the project area during 

construction. The level of potential impacts during construction is expected to be low because 

standard construction safety procedures would make the risk of injury very low. 

Impacts During Operation and Maintenance

Electrical Safety. Power lines, like electrical wiring, can cause serious electric shocks if certain 

precautions are not taken. The NESC specifies the minimum allowable distance between the 

lines and the ground or other objects. Given that the new line would be higher than the existing 

line, impacts related to electrical safety would be reduced relative to the existing line. 
3-56 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

Short-term Effects – Electric Fields. Electric fields from high-voltage transmission lines can 

cause nuisance shocks when a grounded person touches an ungrounded object under a line or 

when an ungrounded person touches a grounded object. The proposed line would easily meet the 

BPA electric-field guidelines at the edge of the ROW. Therefore, it is highly unlikely that 

nuisance shocks would be perceived under the line; the level of impacts would be low. 

Short-term Effects – Magnetic Fields. Magnetic fields from transmission lines can induce 

currents and voltages on long conducting objects parallel to the lines, which can interfere with 

electrical devices and also serve as a source of nuisance shocks. For the proposed 115-kV line, 

the distance where interference could occur under worst-case conditions would be reduced to 

about 40 feet from the centerline. Short-term magnetic-field impacts are expected to be low. 

Long-term Health Effects. The issue of whether there are long-term health effects associated 

with exposure to fields from transmission lines and other sources has been investigated for 

several decades. A review of recent literature on this subject suggests there is little evidence that 

electric fields cause long-term health effects such as adult cancer, or adverse effects on 

reproduction, pregnancy, or growth and development of the embryo. National and international 

organizations have established public and occupational EMF exposure guidelines on the basis of 

short-term stimulation effects, rather than long-term health effects. In so doing, these 

organizations did not find data sufficient to justify the setting of a standard to restrict long-term 

exposures to electric or magnetic fields. 

Electric and Magnetic Field Levels. An increase in public exposure to magnetic fields could 

occur if field levels increase and if residences or other structures draw people to these areas. The 

predicted field levels are only indicators of how the proposed project may affect the magneticfield environment, not measures of risk or impacts on health. 

BPA has predicted and compared the fields from the proposed line with the fields from the 

existing line (the No Action Alternative). Peak electric field levels are expected to be 

comparable but slightly less than under existing conditions. The peak values would be present 

only at locations directly under the line, near mid-span, where the conductors are at the minimum 

clearance. Peak magnetic field levels are expected to be less than the existing line. Lateral 

profiles of the maximum electric and magnetic field levels near the proposed and existing lines 

are provided in Appendix C. The public health and safety impacts associated with electric and 

magnetic fields for the proposed action would be low. Short-term effects, such as nuisance 

shocks, would be very unlikely. 

Toxic and Hazardous Substances. There are no known occurrences of hazardous materials or 

contaminants within the transmission line corridor; no impacts are expected. 

3.13.3 Mitigation 

The following mitigating measures will help minimize potential health and safety risks if the 

project is implemented: 

• Before starting construction, the contractor will prepare and maintain a safety plan in 

compliance with Washington requirements. The plan will be kept on-site and will detail 
Bonneville Power Administration 3-57 

how to manage hazardous materials such as fuel, and how to respond to emergency 

situations. 

• During construction, the contractors will hold crew safety meetings at the start of each 

workday to review potential safety issues and concerns. 

• BPA will meet with the contractor on a monthly basis to discuss safety issues. 

• At the end of each workday, the contractor and subcontractors will secure the site, as 

much as possible, to protect equipment and the general public. 

• BPA will construct and operate the new transmission line to meet the National Electrical 

Safety Code. 

• If a hazardous material is discovered that could pose an immediate threat to human health 

or the environment, BPA requires that the contractor notify the Contracting Officer’s 

Technical Representative (COTR) immediately and stop work in that area until given 

notice to continue work. 

3.13.4 Unavoidable Impacts Remaining after Mitigation 

Since the health and safety impacts of the proposed line are similar to those from the existing 

line, no unavoidable impacts would remain after mitigation. 

3.13.5 Cumulative Impacts 

Existing public health and safety risks related to logging and traffic on Highway 101 would 

continue. The proposed project would contribute a small increase in the overall risk of fire and 

injury to the public that could occur during construction and operation/maintenance. 

3.13.6 Environmental Consequences—No Action Alternative 

Electric and magnetic field levels in the project area are the same or slightly higher than for the 

proposed line. No difference in public health and safety impacts would be expected between the 

proposed and No Action Alternatives, except that the safety risks associated with construction 

activities would be avoided. 

3.14 NOISE 

3.14.1 Affected Environment 

Noise is commonly defined as unwanted sound that disrupts normal human activities or 

diminishes the quality of the human environment. Sources of noise associated with electrical 

transmission systems include construction and maintenance equipment, transmission line corona, 

and electrical transformer “hum.” Corona-generated noise, characterized as a hissing, crackling 

sound, is generally only of concern for transmission lines with voltages of 230 kV or greater. 

Environmental noise, including transmission line noise, is usually measured in decibels on the Aweighted scale (dBA). This scale measures sound in approximately the same way the human ear 

responds. Noise levels and, in particular, corona-generated noise vary over time. To account for 

fluctuating sound levels, environmental noise is typically described with terms that incorporate 

statistical concepts. Exceedence levels (L levels) refer to the A-weighted sound level that is 

exceeded for a specified percentage of the time during a specified period. Thus, L50 refers to a 
3-58 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

particular sound level that is exceeded 50 percent of the time. The equivalent sound level (Leq)

is generally accepted as the average sound level. 

Along the corridor of the proposed 115-kV transmission line, existing noise levels vary with the 

proximity to Highway 101 and other noise-generating activities. Most of the transmission line 

corridor is in rural, undeveloped areas. During foul weather, noise from the existing line is a 

source of background noise, along with wind and rain hitting vegetation. In the more developed 

areas, traffic and noise associated with human activity would be major contributors to 

background noise. 

The Washington Administrative Code (WAC 173-60) specifies noise limits according to the type 

of property where the noise would be heard (the “receiving property”) as well as land use of the 

noise source. Nighttime noise limits in residential neighborhoods are 50 dBA, in commercial 

areas 55 dBA, and in industrial areas 60 dBA. Transmission lines are classified as industrial 

sources for purposes of establishing allowable noise levels at receiving property. BPA has 

established a design criterion for corona-generated audible noise from transmission lines of 50 

dBA for the L50 (foul weather) at the edge of the ROW. Washington has interpreted this 

criterion to meet its noise regulations. 

3.14.2 Environmental Consequences—Proposed Action 

Impact levels depend on public and occupational use of the land. The potential for noise impacts 

increases in areas where human activities take place. 

Impacts During Construction

Construction activities create noise that is short term and typically does not cause any serious 

disturbances to residents. Sources of noise associated with construction of the proposed project 

include: 

• construction of access roads and structure foundations 

• removal of existing structures and erection of new structures 

• tree removal activities

• use of helicopters for stringing of conductors 

• potential use of implosive couplers for conductor splicing. 

Access roads and foundations at each structure site would be installed using conventional 

construction equipment (see Chapter 2). The overall noise caused by the conventional 

equipment involved in construction is estimated to be 89 dB Leq at a reference distance of 50 feet 

(see Table B-10 in Appendix B). Noise produced by construction equipment would decrease 

with distance at a rate of about 6 dB per doubling of distance from the site. Based on that 

assumed attenuation rate, the estimated construction noise levels at various distances from the 

construction site are shown in Table A-11. In addition, a helicopter could be used to string the 

conductors. The helicopter would be at a given location for only a few moments. 

Construction noise impacts would not occur over most of the corridor due to its sparse 

development and population. Potential impacts during construction would be limited mainly to 

the small clusters of residences along the ROW. There are an estimated 24 residences within 
Bonneville Power Administration 3-59 

400 feet of the ROW and another 11 within 400 to 800 feet. Overall, for those residents that 

would be affected, the level of impact would be moderate. 

Impacts During Operation and Maintenance

Noise impacts during operation and maintenance of the proposed project would be negligible. 

Three times a year, generally in March, July, and October, a helicopter would fly the line to look 

for any problems or repair needs and vehicles would visit portions of the line. When and if 

repairs are needed, field vehicles would be used to access the trouble spots and then conduct 

repairs. 

The proposed line would decrease the corona-generated foul weather audible noise level at the 

edge of the ROW compared to the existing line (Table 3-5). Audible noise levels were 

calculated for average voltage and average conductor heights for foul-weather conditions. 

The proposed project would improve audible noise levels compared to existing conditions. At 

the edge of the ROW, the foul-weather L50 audible noise level would decrease by about 12 dBA 

compared to the existing line. This would be perceived as reducing the noise level by about a 

factor of two. The calculated median level (L50) during foul weather at the edge of the proposed 

ROW is 19 dBA. The calculated maximum level (L5) during foul weather at the edge of the 

ROW is 22 dBA. These levels are comparable to ambient levels in rural areas. During fair 

weather, there would be no corona on the line. The 19-dBA level for the proposed line would 

meet the BPA design criterion and, hence, the Washington Administrative Code limits for 

transmission lines. 

Noise levels would remain the same at the existing Raymond and Cosmopolis substations 

because no transformers are being added. 

Table 3-5. Predicted Foul-Weather Audible Noise Levels at Edge of 

ROW for Proposed Project and Existing 115-kV Line 

AN Level Rebuilt Line Existing Line 

L50, dBA 19 31 

L5, dBA 22 34 

In summary, the overall level of impact from audible noise is low. Impacts would increase 

temporarily in residential areas where noise from construction could be heard. The noise from 

the proposed line during foul weather would be lower than for the existing line. 

Corona on transmission line conductors can also generate electromagnetic noise in the frequency 

bands used for radio and television signals. The noise can cause radio and television 

interference. In certain circumstances, corona-generated electromagnetic interference (EMI)

can also affect communications systems and other sensitive receivers. Interference with 

electromagnetic signals by corona-generated noise is generally associated with lines operating at 

voltages of 345 kV or higher. This is especially true of interference with television signals. 
3-60 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

Predicted EMI levels for the proposed 115-kV transmission line would be well below those 

considered unacceptable. No impacts of corona-generated interference on radio, television, or 

other reception are anticipated. 

3.14.3 Mitigation 

To reduce the potential for temporary, adverse noise impacts during construction, the following 

measures would be incorporated into contract specifications. 

• All construction equipment and vehicles will have muffled exhaust. 

• Landowners directly impacted along the corridor will be notified prior to construction 

activities. 

• Near residences, construction activities will be limited to daytime hours. 

• If radio or television interference occurs that is caused by BPA’s transmission line, 

measures will be taken to restore the reception to a quality as good or better than before 

the interference. 

3.14.4 Unavoidable Impacts Remaining After Mitigation 

Construction-related noise impacts would not be completely mitigated. However, 

implementation of the mitigation measures identified in Section 3.14.3 would ensure that impacts 

would remain low to moderate.

3.14.5 Cumulative Impacts 

Construction noise from the proposed project would temporarily add to noise from other 

activities in the area, such as logging and traffic on Highway 101. Once the new line is built, 

however, corona-generated noise would be less than the existing line, thus slightly reducing 

cumulative noise impacts near the project. 

3.14.6 Environmental Consequences—No Action Alternative 

Existing background noise levels in the project area would continue, including corona-generated 

noise. Other noise impacts would be similar to those described for maintenance of the new line. 
Bonneville Power Administration 4-1 

Chapter 4 

Environmental Consultation, Review, and Permit 

Requirements 

This chapter addresses Federal statutes, implementing regulations, and Executive Orders 

potentially applicable to the proposed project. Changes made to this chapter since the 

Preliminary EA are not shown because they merely reflect updates and progress in permitting 

and consultation. This Environmental Assessment (EA) will be sent to Tribes, Federal agencies, 

and state and local governments as part of the consultation process for this project. 

4.1 NATIONAL ENVIRONMENTAL POLICY ACT 

BPA prepared this EA pursuant to regulations implementing the National Environmental Policy 

Act (NEPA) (42 USC 4321 et seq.), which requires Federal agencies to assess the impacts that 

their actions may have on the environment. NEPA requires preparation of an Environmental 

Impact Statement (EIS) for major Federal actions significantly affecting the quality of the human 

environment. BPA prepared this Preliminary EA to determine if the proposed action would 

create any significant environmental impacts that would warrant preparing an EIS. 

4.2 THREATENED AND ENDANGERED SPECIES AND 

CRITICAL HABITAT 

The Endangered Species Act of 1973 (ESA, 16 USC 1536) as amended in 1988, establishes a 

national program for the conservation of threatened and endangered species of fish, wildlife and 

plants, and the preservation of the ecosystems on which they depend. The ESA is administered 

by the USFWS and, for salmon and other marine species, by NOAA Fisheries. 

Section 7(a) of the ESA requires Federal agencies to ensure that the actions they authorize, fund, 

and carry out do not jeopardize endangered or threatened species or their critical habitats. 

Section (7c) of the ESA and other Federal regulations require that Federal agencies prepare 

biological assessments addressing the potential effects of major construction actions on listed or 

proposed endangered species and critical habitats. 

BPA asked the USFWS to identify the listed and proposed species that are either known to occur 

or have the potential to occur in the project area. The USFWS responded on February 20, 2002 

that the bald eagle, bull trout, marbled murrelet, and northern spotted owl, all threatened species, 

should be addressed. BPA requested an update of the species list on December 23, 2002; no 

changes had been made. BPA checked the NOAA Fisheries website and determined there are no 

species administered by NOAA Fisheries in the project area. 

BPA is consulting with the USFWS on the potential effects of the project on the identified 

threatened species. A Biological Evaluation (BE) was prepared addressing potential effects to 

the four listed species. The BE was submitted to USFWS in January 2003, requesting their 

concurrence with BPA’s determination of effect to the four listed species and then amended in 

May, 2003, to include additional information requested by USFWS. The BE concluded that 
4-2 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

implementation of the proposed Federal action would have the following effects on listed 

species, as explained below and in Section 3.5, Fish and Wildlife: 

• no effect on bull trout, 

• may affect, but is not likely to adversely affect bald eagles, 

• may adversely affect marbled murrelets, and 

• may affect, but is not likely to adversely affect northern spotted owls. 

4.2.1 Bull trout 

No bull trout are expected to be in the project area and therefore no bull trout habitat would be 

adversely affected. The only documented population of bull trout in proximity to the proposed 

project area is in the Grays Harbor/Chehalis River, and the only fish-bearing tributary to the 

Chehalis River that crosses the proposed project area is Mill Creek. However, all bull trout are 

blocked from the part of the creek in the proposed project area by a dam approximately 2.5 miles 

downstream. Any increase in sedimentation and turbidity would not be detectable 2.5 miles 

downstream from the project area, because standard erosion control measures would be 

implemented as part of the project SWPP Plan. Because construction activities and operation 

and maintenance are not expected to affect the behavior or habitat of bull trout, the proposed 

project would have no effect on bull trout. 

4.2.2 Bald eagle 

No known bald eagle nests or activity areas are in the project area. Six nests have been 

identified at least 1 mile from the nearest structures within the corridor. The proposed line 

would cross few areas that bald eagles use and would run primarily through forest. No known 

roosting trees would be removed. However, bald eagles may be present, because there are 

several places where home ranges could overlap the project area. 

Construction-related noise, including helicopter use, could cause bald eagles to temporarily 

avoid the vicinity of active construction areas. Since much of the proposed project is adjacent to 

Highway 101, any bald eagles in the vicinity would likely be accustomed to higher ambient noise 

levels because the highway is heavily used by logging vehicles and other heavy equipment. 

Restricting use of helicopters until after September 15 would avoid potential noise during periods 

when eagles are most sensitive to disturbance (February 1 to mid-April). Because most 

construction would be completed by October 31, impacts to eagles that use the area during the 

November 15 to March 15 wintering period would be limited. 

Because the proposed project involves replacing an existing transmission line with a similar kind 

of line, the potential impact from collisions with the transmission line would be similar to 

existing conditions. Since eagle collisions with the existing line have not been documented in 

the past, and there are no documented nesting or wintering areas within a mile of the 

transmission line, it is unlikely that the presence of the new line would create increased potential 

for adverse effects from collisions. 

Because bald eagles may temporarily avoid construction areas, the project may affect, but is not 

likely to adversely affect bald eagles. 
Bonneville Power Administration 4-3 

4.2.3 Marbled murrelet 

There are 2 known occupied marbled murrelet stands immediately adjacent to the ROW and 15 

other potential habitat stands, some immediately adjacent to the ROW and others within 1⁄4 mile 

of the ROW (3 of the stands were logged by private timber companies in 2003). Because 

surveys to detect marbled murrelets were not completed in the 15 potential habitat stands, it was 

assumed for the purposes of the BE that they are occupied. There are no designated critical 

habitat units in or adjacent to the proposed project area, and the closest unit is located 

approximately 3.5 miles south of the Raymond Substation.

There would be direct effects to some marbled murrelet habitat resulting from tree removal in or 

directly adjacent to known habitat. Four red alders would be removed at the edge of a potential 

habitat stand, but these trees are not suitable nesting trees. The trees would not be removed until 

after the core breeding season (August 5), limiting potential effects. Due to the high ambient 

noise levels along Highway 101, the low quality habitat, and the habitat’s accessibility to 

predators, removal of these trees would not adversely affect the quality of the remaining habitat. 

About 50 trees, one hemlock and the rest red alder (with two 16 inch diameter stems), would be 

removed at the edge of one other potential habitat stand, immediately adjacent to Highway 101. 

Removal of these trees may increase the amount of insolation to potential nesting trees (which 

could overheat chicks) and allow access for predators; however, because marbled murrelets are 

notoriously clumsy fliers, it could also be beneficial by allowing marbled murrelets easier access 

to this potential habitat. The trees would not be removed until after September 15; therefore, 

there would be no effect on marbled murrelets during the breeding season. Removal of these 

trees would not likely significantly affect the quality of the remaining marbled murrelet habitat. 

Some tree limbs would be removed at an occupied marbled murrelet stand because they hang 

into the existing ROW where the new conductor would be located. The nest trees would not be 

removed—only the portion of the limb that extends into the ROW. The loss of limbs and the 

increased exposure of the remaining habitat areas to sunlight could adversely affect the quality of 

the remaining habitat. Effects would be limited because the work would be done after 

September 15. 

Road improvements would be conducted immediately adjacent to an occupied marbled murrelet 

stand during the late breeding season, in order to conduct instream work during the instream 

work period. This site is in a state park and experiences high ambient noise levels from heavy 

summer use. Therefore, with noise restrictions as described below, road work is not likely to 

significantly adversely affect any nesting marbled murrelets in the adjacent habitat. 

Noise restrictions would be implemented during the breeding season to further minimize the 

impact of noise on nesting marbled murrelets. No structures would be removed or erected within 

75 yards of documented occupied habitat polygons until after September 15 (end of breeding 

season). Work within 0.25 mile of all known or potential marbled murrelet habitat would be 

prohibited each day for a period from 2 hours before sunset until 2 hours after sunrise during the 

early and late breeding season. Helicopters would not be used until after September 15 in all 

areas. Even with these restrictions and the high ambient noise generated by Highway 101, the 

project may adversely affect marbled murrelets. 
4-4 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

4.2.4 Northern Spotted Owl 

The proposed project would not destroy nesting habitat because no large trees suitable for 

nesting would be removed; however, some trees suitable for perching may be cut. The proposed 

project would briefly increase noise at the project site, possibly causing owls to temporarily 

avoid areas in the vicinity of active construction. Although construction would not be timed to 

avoid periods of nesting activities (March 1 through September 30), there is no designated 

critical habitat within the action area. Any northern spotted owls in the vicinity would likely be 

accustomed to higher ambient noise levels due to the proximity of Highway 101 and would be 

less affected by construction noise. Helicopter use would be restricted until after September 15, 

thus avoiding the critical nesting and fledging period. Overall, northern spotted owl habitat 

conditions would be maintained in the project area, and the project would not significantly 

degrade habitat. Therefore, the proposed project may affect, but is not likely to adversely 

affect northern spotted owls or their habitat. 

Impacts to listed species could occur from some subsequent operation and maintenance 

activities. Noise impacts from on the ground (vehicle) surveys of the line during operation and 

maintenance of the proposed project would be negligible. Noise impacts from helicopter use 

would be a moderate impact. Three times a year, generally in March, July, and October, a 

helicopter would fly the line to look for any problems or repair needs and vehicles would visit 

portions of the line. The July flight could impact marbled murrelet during the early breeding 

season and all flights could disturb spotted owl or eagles using the project area. 

BPA has not received the Biological Opinion from USFWS as of August 7, 2003. The Terms 

and Conditions in the Biological Opinion will be followed. 

4.2.5 State-Listed Species on State Lands 

BPA addresses potential impacts to state-listed and sensitive species on state land. The project 

corridor crosses a parcel owned by the Washington DNR that includes the Butte Creek Picnic 

Area. The Washington Natural Heritage Program and the state botanist reported no known statelisted rare plants in this parcel; nor were any encountered during field surveys by a BPA 

environmental specialist who surveyed the site in April and July, 2002, or by MCS 

Environmental on September 4 and 5, 2002. 

4.3 FISH AND WILDLIFE 

4.3.1 Fish and Wildlife Conservation 

The Fish and Wildlife Conservation Act of 1980 (16USC 2901 et seq.) encourages Federal 

agencies to conserve and promote conservation of non-game fish and wildlife and their habitats. 

In addition, the Fish and Wildlife Coordination Act (16 USC 661 et seq.) requires Federal 

agencies with projects affecting water resources to consult with the USFWS and the state agency 

responsible for fish and wildlife resources. The analysis in Section 3.5, Fish and Wildlife, 

indicates that the alternatives would have no impact to moderate impacts on fish and wildlife. 
Bonneville Power Administration 4-5 

BPA is coordinating with the WDFW Area Habitat Biologist concerning all actions with the 

potential to affect fish and wildlife. The following site visits were made with a WDFW 

biologist: 

• In the summer of 2002, the WDFW habitat biologist, and a road engineer and an 

environmental specialist from BPA, visited sites where instream work would be done. 

• On March 5, 2003, the WDFW area habitat biologist met with BPA's project manager 

and environmental specialist to look at project actions that could affect fish habitat, and 

to discuss appropriate mitigation. 

• On April 9, 2003, the WDFW area habitat biologist, WDFW marbled murrelet specialist, 

the DNR representative, and USFWS personnel met with the BPA design engineer, 

wildlife biologist, and environmental specialist at a known marbled murrelet occupied 

site to discuss how project actions could effect the habitat and ways to minimize impacts. 

The WDFW biologist participated in approval of all instream work through the state’s Hydraulic 

Project Approval process. The WDFW area habitat biologist and marbled murrelet specialist 

were sent the BE (see Section 4.2) and the WDFW area habitat biologist was sent the Essential 

Fish Habitat Assessment (see Section 4.3.1) in early February, 2003, for review and comment. 

4.3.2 Essential Fish Habitat 

Public Law 104-297, the Sustainable Fisheries Act of 1996, amended the Magnuson-Stevens 

Fishery Conservation and Management Act (Magnuson-Stevens Act). Under Section 305(b)(4) 

of the Act, BPA is required to consult with NOAA Fisheries for actions that adversely affect 

Essential Fish Habitat; NOAA Fisheries in turn is required to provide Essential Fish Habitat 

conservation and enhancement recommendations. 

Both chinook and coho salmon, which are administered under the amended Magnuson-Stevens 

Fishery Conservation and Management Act, are found in the vicinity of the proposed project. 

Essential Fish Habitat for these species may be found in Butte, Elkhorn, Lower Salmon, and Joe 

creeks, the North and Little North rivers, and other unnamed tributaries that cross or flow 

adjacent to the project corridor. Because this project has the potential to adversely affect 

Essential Fish Habitat, an assessment of Essential Fish Habitat was submitted to NOAA 

Fisheries on February 3, 2003. 

BPA received a response from NOAA Fisheries on March 27, 2003, stating that the proposed 

mitigation is adequate, but also recommending as a conservation measure that the instream work 

be conducted in July or August. BPA responded by letter on April 29, 2003, stating that, 

although we cannot guarantee that the work would be completed in August, we would follow the 

instream dates in the Hydraulic Project Approval, as recommended by the WDFW area habitat 

biologist. The April 29th letter from BPA also included information on the additional tree cutting 

that is proposed near waterways. NOAA Fisheries responded on May 5, 2003, and stated that 

they amended the project file, conservation measures are adequate, and there was no need to 

reinitiate consultation. 
4-6 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

4.3.3 Migratory Bird Treaty Act 

The Migratory Bird Treaty Act implements various treaties and conventions between the United 

States and other countries, including Canada, Japan, Mexico, and the former Soviet Union, for 

the protection of migratory birds (16 U.S.C. 703-712, July 3, 1918, as amended 1936, 1960, 

1968, 1969, 1974, 1978, 1986, and 1989). Under the Act, taking, killing, or possessing 

migratory birds, or their eggs or nests, is unlawful. The Act classifies most species of birds as 

migratory, except for upland and nonnative birds such as pheasant, chukar, gray partridge, house 

sparrow, European starling, and rock dove. 

The proposed project may affect birds. Potential impacts, such as the loss of habitat, are 

discussed in Section 3.5, Fish and Wildlife. 

Operation of the transmission line could result in the injury or death of birds caused by collisions 

with the transmission line. Collisions typically occur in locations where conditions combine to 

create a high potential for birds striking lines (Avian Power Line Interaction Committee, 1994). 

Three factors contribute to this potential: the type of power lines, the amount of use of the area 

by birds, and the inherent tendency of a species to collide with overhead wires. Since bird 

collisions with the existing line have not been documented in the past and no unusual 

circumstances exist that would increase the likelihood of collisions, it is unlikely that the new 

line would have any such impact on birds. 

4.3.4 Bald Eagle and Golden Eagle Protection Act 

The Bald Eagle Protection Act prohibits the taking or possessing of and commerce in bald and 

golden eagles, with limited exceptions (16 U.S.C. 668-668d, June 8, 1940, as amended 1959, 

1962, 1972, and 1978). Because a small number of bald eagles reside within foraging distance 

of the proposed project, there is a remote possibility some bald eagles could die after hitting 

structures or conductors. However, as discussed in Sections 3.5 and 4.2, this effect is unlikely. 

Because the Act covers only intentional acts, or acts in “wanton disregard” of the safety of bald 

or golden eagles, this project is not considered to be subject to its compliance because any 

impacts would not be intentional or result from disregard. 

4.3.5 Responsibilities of Federal Agencies to Protect Migratory Birds 

Executive Order 13186 directs each Federal agency that is taking actions that may negatively 

impact migratory bird populations to work with the USFWS to develop an agreement to conserve 

those birds. The protocols developed by this consultation are intended to guide future agency 

regulatory actions and policy decisions; renewal of permits, contracts, or other agreements; and 

the creation of or revisions to land management plans. BPA, an agency of the U.S. Department 

of Energy, is cooperating with the Department in developing a memorandum of understanding 

with the USFWS to comply with this mandate. 

Construction, operation, and maintenance of the proposed project would result in low impacts to 

migratory birds, due to loss of habitat or direct mortality, as discussed in Section 3.5, Fish and 

Wildlife. 
Bonneville Power Administration 4-7 

4.4 CULTURAL AND HISTORICAL RESOURCES 

A cultural resource is an object, structure, building, site or district that provides irreplaceable 

evidence of natural or human history of national, state, or local significance, such as National 

Landmarks, archeological sites, and properties listed (or eligible for listing) on the National 

Register of Historic Places (NRHP). Regulations established for the management of cultural 

resources include: 

• Antiquities Act of 1906 (16 U.S.C. 431-433) 

• Historic Sites Act of 1935 (16 U.S.C. 461-467) 

• Section 106 of the National Historic Preservation Act (NHPA) of 1966 (16 U.S.C. 470 et 

seq.), as amended 

• Archaeological Data Preservation Act (ADPA) of 1974 (16 U.S.C. 469 a-c) 

• Archaeological Resources Protection Act (ARPA) of 1979 (16 U.S.C. 470 et seq.), as 

amended 

• Native American Graves Protection and Repatriation Act (NAGPRA) (25 U.S.C. 3001 et 

seq.) 

• Executive Order 13007 Indian Sacred Sites. 

Four cultural resources investigations of the project area were conducted in 2002. The 

investigations consisted of background research and archaeological field studies that included 

pedestrian surveys at locations that would be disturbed. Shovel test pit excavations were 

completed at sites with the potential to contain archeological resources. The Washington State 

Office of Archeology and Historic Preservation (OAHP) and eight Tribes were provided the 

methodology for each of these surveys and given an opportunity to comment. No comments on 

methodology were received. 

Based on the survey findings, significant archaeological resources were not found and are 

unlikely to be located within the project area for the proposed rebuild project (see Section 3.12,

Cultural Resources). On December 18, 2002, BPA submitted the cultural resources report on 

the Rebuild Project to OAHP requesting concurrence with the determination that no historic 

properties would be affected. BPA received concurrence from OAHP on December 27, 2002. 

The report was submitted to the eight Tribes with an interest in the project on January 6, 2003. 

The Quinault Nation responded on January 14, 2003, that they concur with BPA’s determination. 

Tribes that had not responded were contacted in April, 2003, to determine if they concur and 

they did not provide any additional comments. 

4.5 STATE, AREAWIDE, AND LOCAL PLAN AND PROGRAM 

CONSISTENCY 

BPA, as a Federal agency, is not required to comply with the requirements associated with 

obtaining state and local land-use approvals or permits because Congress has not waived Federal 

supremacy over these areas. Furthermore, as a Federal agency, BPA only obtains those state and 

local permits for which Congress has clearly and unambiguously waived sovereign immunity. 

However, BPA does, to the maximum extent practical, strive to meet or exceed the substantive 

standards and policies of the following environmental regulations. 
4-8 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

4.5.1 Land Use Planning Framework 

Land use plans and policies guide development within Pacific County, Grays Harbor County, 

and the City of Cosmopolis. 

• Pacific County’s Comprehensive Land Use Plan was adopted in October 1998, and the 

Land Development/Use Ordinance, December, 2001. Within Pacific County, the corridor 

is zoned as rural residential land. The County’s code does not specifically address utility 

corridors. 

• Grays Harbor County’s Comprehensive Zoning Ordinance was adopted in December, 

2001. The County has a Comprehensive Plan that does not include the project area. The 

County anticipates completing this section of the Comprehensive Plan sometime in 2003. 

Within Grays Harbor County, the corridor is designated General Development by a land 

use map. The zoning is General Development 5 District (G-5). This zone allows dams, 

electrical power plants, flowage areas, transmission lines, and substations together with 

necessary accessory buildings. 

• The City of Cosmopolis has a Comprehensive Plan that was revised in 2002, and a 

zoning code that was revised in 2001. The Cosmopolis Substation is located on land 

designated and zoned Mixed-Use (MU). The City’s Comprehensive Plan and Zoning do 

not specifically address utility corridors. 

The proposed project would be consistent with these land use plans and zoning ordinances. 

4.5.2 Washington Growth Management Act 

This 1990 Act requires that most counties and cities in Washington adopt comprehensive plans, 

including “a utilities element consisting of the general location, proposed location, and capacity 

of all existing and proposed utilities, including, but not limited to, electrical lines, 

telecommunication lines, and natural gas lines.” The 1991 and subsequent amendments to the 

Act added more planning requirements. None of the jurisdictions noted above have adopted 

comprehensive plans under the Growth Management Act. 

4.5.3 Washington Shoreline Management Act 

The State’s Shoreline Management Act (Chapter 90.58 RCW) identifies “Shorelines of the 

State” and “Shorelines of Statewide Significance” that would be spanned by the proposed 

project. The right-of-way (ROW) crosses the following streams designated “Shorelines of the 

State” (WAC 173-18): the Little North River, Lower Salmon Creek, and North River in Grays 

Harbor County; Elkhorn Creek and Smith Creek in Pacific County. Some structures would need 

to be placed within 200 feet of the shores of Smith, Elkhorn, and Lower Salmon creeks, the 

North River, and the Little North River and thus would fall under the jurisdiction of the 

Shoreline Management Act. 

BPA would take the following measures, where practicable, to assure consistency with the 

counties’ Shoreline Master Plans: 

• Structures near Shorelines of the State would be placed in an existing corridor 

• Structures would not be in water bodies 
Bonneville Power Administration 4-9 

• In one portion of the line, structures would be moved away from the banks of the Little 

North River to minimize impacts 

• In shoreline areas, disturbed land would be restored as closely as possible to pre-project 

forms and reseeded with native species 

• Erosion control measures would be implemented to protect the 200-foot shoreline area. 

Other mitigation measures that would protect shorelines are listed in Section 3.6, Water 

Quality, and Section 3.5, Fish and Wildlife. 

A letter describing shoreline area impacts was sent to Pacific County, Grays Harbor County, and 

WDOE, on March 11, 2003. Both counties requested a meeting with BPA to discuss the project 

and meetings were held in June. As a result of the meeting, BPA provided additional 

information on project activities, in July to Grays Harbor County and in August to Pacific 

County. The response from the counties will be sent to WDOE to assist the state in making the 

Consistency Determination under the Coastal Zone Management Act (see Section 4.7). 

4.5.4 Critical Areas Ordinances 

The Growth Management Act (GMA) requires that all local jurisdictions designate and protect 

critical areas, which are defined as wetlands, critical aquifer recharge areas, frequently flooded 

areas, geologically hazardous areas, and fish and wildlife habitat conservation areas. Pacific 

County and the City of Cosmopolis have adopted ordinances and plans protecting critical areas, 

but Grays Harbor County has not. In most cases, the proposed action would be consistent with 

the provisions of these ordinances and plans because BPA would avoid critical areas and critical 

area buffers to the maximum extent possible. BPA submitted a detailed project description to 

Pacific and Grays Harbor counties in March, 2003, and requested comments on the proposal. 

BPA received an e-mail from a Pacific County Planner on April 24, 2003, stating, “Based upon 

my review, it appears that BPA will need to obtain permit approvals from Pacific County as 

several of the proposed transmission line structures will either be located within wetlands, or 

within wetland buffers regulated by Pacific County's Critical Areas and Resource Lands 

Ordinance.” BPA met with Pacific County Planner, Mr. Mike Stevens, on June 24, 2003, to 

discuss wetland impacts and Mr. Stevens requested that BPA document the extent of impacts to 

wetlands and buffers and also “credits” that would result from removing structures currently in 

wetlands. This information was submitted to Pacific County, who will determine if a permit and 

mitigation is required, but it is unlikely because there are slightly more wetland “credits” than 

impacts. 

4.5.5 Washington Administrative Code 

The proposed rebuild of the transmission line roughly follows Highway 101, sections of which 

are considered to have scenic value. The following provisions of the Washington Administrative 

Code are relevant to the proposed project. 

WAC 468-34-280 Overhead Power and Communication Lines

This section of the WAC recommends that longitudinal installations of power lines (on public 

rights-of-way) be of single-pole construction, and that joint-use single pole construction is 
4-10 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

generally desirable and should be used whenever feasible. The proposed project’s design calls 

for the rebuilt line to be supported by modular steel pole structures; thus it is consistent with this 

section of the WAC. 

WAC 468-34-290 and 468-34-300 Vertical Clearance and Location

These sections require that vertical clearances for overhead power lines conform to the National 

Electric Safety Code and/or the clearances identified in the WAC, whichever are greater. The 

minimum clearances specified for 115-kV transmission lines are 32 feet above the groundline, 

including roadways. The code also specifies that utility lines be located as near as practicable to 

the edge of the ROW while still maintaining a reasonably uniform alignment. The proposed 

project would conform to the minimum clearances, as required by the National Electric Safety 

Code, and is located as close to the ROW edge as practicable. 

WAC 468-34-330 Scenic Enhancements

The Washington Department of Transportation has designated portions of Highway 101 in the 

vicinity of the proposed project as BX. The BX classification covers Highway 101 between Mile 

Posts 66.2 to 70.9 and 77.0 to 78.5. A number of structures are within this classification near the 

roadway. According to this section of the WAC: 

(1) ...Aerial facilities may be allowed (in this zone) if found acceptable to the department 

based on design and/or location which will not detract from scenic values typical of those 

found in Class A and B. 

(2) Special exceptions may be made where one or more of the following conditions exist: 

Power lines of voltage in excess of 35-kV, special design should be incorporated to 

minimize the visual impact of the facility. 

Other utility locations are not available, are unusually difficult and unreasonably costly, 

or are more desirable from the standpoint of visual quality. 

The placing of the utility underground is not technically feasible or is unreasonably 

costly. 

The impact of the required under grounding adversely affects the utility consumer rates 

or the long-term economics of the utility.

The proposed project is a rebuild of an existing 115-kV line, which is in excess of 35-kV. The 

existing lattice steel box structures would be replaced with modular steel poles that would be 

oxidized to blend more readily with the landscape. The conductors would be non-reflective to 

reduce light and glare from the transmission line in sunlit conditions. Undergrounding the 

transmission line is not feasible, due mainly to the cost of construction and the cost and 

difficulties of maintaining an underground line. BPA therefore conforms to the requirements of 

WAC 468-34-330, or meets the special exceptions. 

4.5.6 Transportation Permits 

The construction contractor and transmission line facilities manufacturers would consult with 

WSDOT and with City and County public works departments to secure necessary permits for the 
Bonneville Power Administration 4-11 

transportation of large loads on the roadways. BPA engineers and surveyors have consulted with 

WSDOT concerning activities within the Highway 101 control zone. 

4.6 WASHINGTON FOREST PRACTICES ACT 

The Washington Forest Practices Act (FPA) and Forest Practices Rules and Regulations are the 

state's principal means of regulating activities on non-Federal forestlands. The FPA rules and 

regulations are administered by DNR. The Forest Practices Act does not apply to Federal 

agencies on non-Federal land, therefore BPA would not obtain a FPA permit from the state. 

BPA will attempt to comply with the FPA where possible and has incorporated many of the 

BMPs described in the FPA into its proposal. In addition, as required under the FPA, BPA will 

consult with WDFW to protect critical habitats including riparian areas, wetlands, and habitat for 

the spotted owl and marbled murrelet. BPA will notify DNR of tree removal activities to meet 

the terms of an agreement made between DNR and BPA in 2002. 

4.7 COASTAL ZONE MANAGEMENT ACT CONSISTENCY 

As an agency of the Federal government, BPA follows the guidelines of the Coastal Zone 

Management Act of 1972 (CZMA) (16 U.S.C. Sections 1451-1464) and would ensure that 

projects are, to the maximum extent practicable, consistent with the enforceable policies of the 

state management programs. Because the proposed project is within Washington’s Coastal 

Zone, which includes both Pacific and Grays Harbor counties, BPA is subject to the coordination 

and consistency requirements of the Act. The State of Washington has an approved Coastal 

Zone Management Program, which is implemented by the state Department of Ecology 

(WDOE). The CZMA requires that “each Federal agency activity within or outside the coastal 

zone that affects any land or water use or natural resource of the coastal zone shall be carried out 

in a manner which is consistent to the maximum extent practicable with the enforceable policies 

of approved state management programs” (16 U.S.C. 1456c(1)(A)). These policies include the 

Shoreline Management Act and state air and water quality requirements. 

BPA believes that the proposed project is consistent to the maximum extent practicable with 

Washington’s Coastal Zone Management Program. BPA submitted a consistency statement to 

WDOE in March 11, 2003, including a detailed project description, and requested its 

concurrence. The response from the counties will assist WDOE in making the Consistency 

Determination under the Coastal Zone Management Act (see Section 4.7). 

4.8 AIR QUALITY 

The Federal Clean Air Act, as revised in 1990 (PL 101-542 (42 USC 7401), requires the EPA 

and individual states to carry out a wide range of regulatory programs intended to assure 

attainment of the National Ambient Air Quality Standards. In the State of Washington, EPA has 

delegated authority to the WDOE, which in most areas has delegated authority to local air 

pollution control agencies. Each of those agencies has regulations requiring all industrial 

activities (including construction projects) to minimize windblown fugitive dust. Water trucks 

would be used to minimize fugitive dust during project construction. 
4-12 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

There would be very little burning of cleared material, if any, due to the small amount of land 

where tree removal would take place. Vehicles used during construction of the proposed project 

would be maintained so as to minimize emissions. 

4.9 FLOODPLAINS AND WETLANDS PROTECTION 

The U.S. Department of Energy mandates that impacts to floodplains and wetlands be assessed 

and alternatives for protection of these resources be evaluated in accordance with Compliance 

with Floodplain/Wetlands Environmental Review Requirements (10 CFR 1022.12), and Federal 

Executive Orders 11988 and 11990. 

Wetland management, regulation, and protection is addressed in several sections of the Clean 

Water Act, including Sections 401, 402, and 404, as well as to a combination of other state and 

Federal laws. Other laws include the Coastal Zone Management Act, the critical areas 

ordinances of local governments, the Endangered Species Act, Historic Preservation Act, Rivers 

and Harbors Act, and the Wild and Scenic Rivers Act. 

The Notice of Floodplain and Wetlands Involvement for the Rebuild Project was published in the 

Federal Register on January 14, 2003 (Volume 68, Number 9, pages 1828-1829). This notice 

described potential impacts to floodplains and wetlands. Evaluation of project impacts on 

floodplains and wetlands are discussed briefly below and in more detail in Sections 3.7, 

Wetlands, and 3.8, Floodplains. 

4.9.1 Wetlands 

Numerous wetlands are found in the project area, but only a limited number would be impacted 

by activities in or near them. Twenty existing structures are within 50 feet of wetlands; of those, 

nine are in wetlands. Nineteen of the proposed structures would be within 50 feet of wetlands, 

only two of which would be in wetlands. The impact on wetlands from removing existing 

structures would be low. Structures in wetlands would be cut at the base with no soil disturbance 

and lifted or dragged from the wetland area. 

Impacts on wetlands from installing new structures in wetlands and construction or improvement 

of access roads are expected to be low to moderate and mostly temporary. A total of 

approximately 0.30 acre of wetland would be temporarily filled and 0.018 acre of wetland 

would be permanently filled. Permanent impacts would result from two structures that would be 

constructed in wetlands, and a ford within a stream with adjacent wetlands. Temporary impacts 

would result from temporary access roads. Activities adjacent to wetlands could impair some 

wetland functions by degrading the quality of the wetland buffer. Operation and maintenance is 

expected to have a low impact on wetlands. Mitigation measures that would be implemented to 

minimize impacts to wetlands are discussed in Section 3.7.3, Wetlands. 

4.9.2 Floodplains 

Floodplains of Lower Salmon Creek, the North River, and the Little North River are near or 

within the ROW. Construction activities within floodplain areas would be temporary and 

localized, only minimally altering floodplain functions. Impacts from structure removal and 
Bonneville Power Administration 4-13 

installation are expected to be low to moderate. Six existing structures within or on the 

boundaries of floodplains would be removed; two of these structures would be relocated outside 

the floodplain (See Table 3-4 in Section 3.8.2, Floodplains). The primary direct impacts on 

floodplains are expected to result from soil compaction and removal of vegetation, leading to 

possible subsequent erosion. Drilling holes that would support new structures would result in the 

deposition of approximately 100 cubic yards of fill covering about 100 square feet. Indirect 

impacts on floodplains are expected to be low and limited to incidental amounts of sediment 

deposited in the floodplain due to soil erosion from construction activities near the floodplain. 

The amount of sediment deposited in floodplains would not change existing flood storage 

capacity or alter the course of floodwaters. Improvements to existing roads are expected have a 

low to moderate impact on floodplain functions because only limited road improvements are 

planned in and near floodplains (See Table 3-4 in Section 3.8.2). Operation and maintenance is 

expected to have a low impact on floodplains. Mitigation measures that would be implemented 

to minimize impacts to floodplains are discussed in Section 3.8.3. 

4.10 PERMITS FOR DISCHARGES INTO WATERS OF THE 

UNITED STATES 

The Clean Water Act (CWA) regulates discharges into waters of the United States. The various 

sections applicable to this project are discussed below. 

4.10.1 Section 401 

A Federal permit to conduct an activity that causes discharges into navigable waters is issued 

only after the affected state certifies that existing water quality standards would not be violated if 

the permit were issued. WDOE will review the project Joint Aquatic Resource Permit, which 

was submitted on March 28, 2003, for compliance. This review will take place once the Army 

Corps of Engineers (ACOE) completes its review for Section 404 compliance. 

4.10.2 Section 402 

This section authorizes storm water discharges under the National Pollutant Discharge 

Elimination System. The EPA, Region 10, has a general permit for Federal facilities for 

discharges from construction activities. BPA would issue a Notice of Intent to obtain coverage 

under the EPA general permit and is preparing a Storm Water Pollution Prevention Plan (SWPP) 

that will address stabilization practices, structural practices, stormwater management, and other 

controls (see Section 3.6, Water Quality). 

4.10.3 Section 404 

Authorization from the ACOE is required in accordance with the provisions of Section 404 of 

the CWA when there is a discharge of dredged or fill material into waters of the U.S., including 

wetlands. Impacts to wetlands are described in Section 3.7, Wetlands. A wetland determination 

and delineation located, described, and mapped all wetlands within the project area. Project 

engineers attempted to avoid wetlands in their design by moving proposed structures and access 

roads to uplands. 
4-14 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

For all unavoidable impacts to wetlands, BPA applied for a Section 404 permit from the ACOE 

on March 28, 2003. Impacts would be 0.30 acre of temporarily filled wetland and 0.18 acre of 

permanently filled wetland. Some fill for temporary access roads to structures in wetlands will 

be removed and the areas restored. Several Nationwide Permits (33 CFR 330) may apply to 

different wetland impacts. If the project activities are covered under an existing Nationwide 

Permit, all conditions of the permit would be followed. 

4.11 GLOBAL WARMING 

Gases that absorb infrared radiation and prevent heat loss to space are called greenhouse gases. 

Greenhouse gases are thought to be connected to global warming and include water vapor, 

carbon dioxide, methane, nitrous oxide, nitrogen oxides, non-methane volatile organic 

compounds and stratospheric ozone-depleting substances such as chlorofluorocarbons. At a 

maximum, the proposed project would clear or disturb vegetation on about 50 acres, which could 

release up to 50 tons of carbon dioxide to the atmosphere primarily through decay. Some slash 

materials might be burnt, releasing additional carbon into the atmosphere. However, because 

most disturbed areas would be revegetated, the project’s contribution to global warming would 

be temporary and negligible. 

4.12 HAZARDOUS MATERIALS 

Several pollution control acts apply to this project. The Spill Prevention Control and 

Countermeasures Act, Title III of the Superfund Amendments and Reauthorization Act, and the 

Resource Conservation and Recovery Act (RCRA) potentially apply to the proposed project, 

depending upon the exact quantities and types of hazardous materials stored on-site. Regulations 

would be enforced by WDOE. In addition, development of a Hazardous Materials Management 

Plan in accordance with the Uniform Fire Code may be required by local fire districts. 

The Toxic Substances Control Act is intended to protect human health and the environment from 

toxic chemicals. Section 6 of the Act regulates the use, storage, and disposal of PCBs. BPA 

adopted guidelines to ensure that PCBs are not introduced into the environment. Equipment 

used for this project will not contain PCBs. Any equipment removed that may have PCBs will 

be handled according to the disposal provisions of this Act. 

The Federal Insecticide, Fungicide and Rodenticide Act registers and regulates pesticides. BPA 

uses herbicides (a kind of pesticide) only in a limited fashion and under controlled 

circumstances. Herbicides are used on transmission line rights-of-way and in substation yards to 

control vegetation, including noxious weeds. When BPA uses herbicides, the date, dose, and 

chemical used are recorded and reported to state government officials. Herbicide containers are 

disposed of according to RCRA standards (see Section 4.14). 

If a hazardous material, toxic substance, or petroleum product is discovered, and may pose an 

immediate threat to human health or the environment, BPA requires the contractor to notify the 

Contracting Officer’s Technical Representative (COTR) immediately. Other conditions such as 

large dump sites, drums of unknown substances, suspicious odors, stained soil, etc. must also be 

reported immediately to the COTR. The COTR will coordinate with the appropriate personnel 
Bonneville Power Administration 4-15 

within BPA. In addition, the contractor will not be allowed to disturb such conditions until the 

COTR has given the notice to proceed. 

4.13 EXECUTIVE ORDER ON ENVIRONMENTAL JUSTICE 

In February, 1994, Executive Order 12898, Federal Actions to Address Environmental Justice in 

Minority and Low-Income Populations, was released to Federal agencies. This order states that 

Federal agencies shall identify and address as appropriate, disproportionately high and adverse 

human health or environmental effects of its programs, policies, and activities on minority 

populations and low-income population. The project would not cause disproportionately high 

and adverse impacts on minority and low-income populations; see Section 3.11, 

Socioeconomics. 

4.14 RESOURCE CONSERVATION AND RECOVERY ACT 

The Resource Conservation and Recovery Act (RCRA), as amended, is designed to provide a 

program for managing and controlling hazardous waste by imposing requirements on generators 

and transporters of this waste, and on owners and operators of treatment, storage, and disposal 

(TSD) facilities. Each TSD facility owner or operator is required to have a permit issued by EPA 

or the state. Typical construction and maintenance activities in BPA’s experience have 

generated small amounts of these hazardous wastes: solvents, pesticides, paint products, motor 

and lubricating oils, and cleaners. Small amounts of hazardous wastes may be generated by the 

proposed project. These materials would be disposed of according to state law and RCRA. 

4.15 NOISE 

The Federal Noise Control Act of 1972 (42 USC 4901) requires that Federal entities, such as 

BPA, comply with state and local noise requirements. Environmental noise limits relevant to 

this proposed project are regulated by WDOE’s Maximum Environmental Noise Levels 

(WAC 1 73-60), which establish limits on levels and duration of noise. Allowable maximum 

sound levels depend on land use at the location of the noise source and the land use of the 

receiving property. 

Nighttime noise limitations in residential neighborhoods are 50 dBA, in commercial areas 55 

dBA, and in industrial areas 60 dBA (WAC 1 73-60-040-2b). BPA designs to a nighttime 

residential level of 50 dBA. Noise from electrical substations is exempt (WAC 1 73-60-050-2a). 

BPA imposes its own 50-dBA limit at substation boundaries. Sound created by the installation 

or repair of essential utility services are exempt from the sound level limits during daytime hours 

(WAC 1 73-60-050-le). 

The proposed action would operate at or below existing state nighttime noise limits for 

residential property, commercial areas, and industrial areas (see Section 3.14, Noise). The 

facilities would be designed to meet these limits for the worst case, that is, at night, at the edge of 

the ROW, during rainy weather. During fair weather, noise levels are typically 25 dBA or less. 

Noise also decreases with distance from the ROW. 
4-16 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

4.16 FEDERAL COMMUNICATIONS COMMISSION 

Federal Communications Commission (FCC) regulations require that transmission lines be 

operated so that radio and television reception would not be seriously degraded or repeatedly 

interrupted. Further, the FCC regulations require that the operators of these devices mitigate 

such interference. It is expected that there would be no interference with radio, television, or 

other reception as a result of the proposed project (see Section 3.14, Noise). BPA would comply 

with FCC requirements relating to radio and television interference from the proposed project if 

any such interference occurs. 

4.17 REQUIREMENTS NOT APPLICABLE TO THIS PROJECT 

4.17.1 Permits for Structures in Navigable Waters 

The project would not involve construction, removal, or rehabilitation of any structures in 

navigable waters. 

4.17.2 Permits for Right-of-way on Public Lands 

The proposed project would not cross land administered by another Federal agency; therefore, no 

permits for ROW on such lands would be required. 

4.17.3 Safe Drinking Water Act 

No drinking water systems would be affected by the project, and no pollutants would be 

expected to reach drinking water supplies. 

4.17.4 Energy Conservation at Federal Facilities 

Energy conservation practices are not relevant because no Federal buildings would be 

constructed for the proposed project. 

4.17.5 Recreation Resources 

BPA used the Wild and Scenic River inventory of listed and proposed rivers (16 USC Sec. 1273 

(b)) qualifying for Wild, Scenic, or Recreation River to evaluate recreational resources and 

impacts. The corridor will not cross any listed segments. 

The Northwest Power Planning Council’s Protected Area Amendments to the Pacific Northwest 

Electric Power Planning Council Designation Act of 1980 are not applicable to the project. 

No designated wilderness or other areas of national environmental concern are found on or 

around the ROW.

4.17.6 Farmland Protection Policy Act 

The Farmland Protection Policy Act (7 USC 4201 et seq.) directs Federal agencies to identify 

and quantify adverse impacts of Federal programs on farmlands. The Act’s purpose is to 

minimize the number of Federal programs that contribute to the unnecessary and irreversible 
Bonneville Power Administration 4-17 

conversion of agricultural land to non-agricultural uses. The proposed project would not remove 

any farmland from production. 

4.17.7 Notice to the Federal Aviation Administration 

As part of transmission line design, BPA seeks to comply with Federal Aviation Administration 

(FAA) procedures. Final locations, structures, and structure heights would not be submitted to 

FAA for the project because no structures are taller than 200 feet above ground, and they are 

located outside the prescribed distances of airports listed in the FAA airport directory. 
Bonneville Power Administration 5-1 

Chapter 5 

Persons and Agencies Consulted 

Federal 

U.S. Army Corps of Engineers (ACOE) 

U.S. Fish and Wildlife Service (USFWS) 

National Oceanic and Atmospheric Administration: NOAA Fisheries 

State 

Washington Department of Ecology (WDOE) 

Washington Department of Fish and Wildlife (WDFW) 

Washington Department of Health 

Washington Department of Natural Resources (WDNR or DNR) 

Washington Department of Revenue 

Washington Department of Transportation, Olympic Region and Southwest Region

Washington Office of Archaeological and Historic Preservation 

Tribes 

Confederated Tribes of Chehalis 

Cowlitz Indian Tribe 

Nisqually Indian Tribe 

Puyallup Tribe 

Quinault Indian Nation 

Shoalwater Bay Tribe 

Skokomish Indian Tribe 

Squaxin Island Tribe 

Local Government and Utilities 

County of Grays Harbor, Board of Commissioners 

County of Grays Harbor, Noxious Weed Control Board 

County of Grays Harbor, Department of Planning

Grays Harbor County PUD No. 1 

Pacific County Department of Community Development 

Pacific County, Noxious Weed Control Board 

Pacific County PUD No. 1 

Landowners

James and Wanda Allen 

Edward E. Archie 

Karl and Linda Bogott 

Ray Boothe and Shelia Hurley 

Leonard and Sharon Bowen 

Joel and Vicki Bullington 

Charles A. Corral 

Frank E. Dianovich 

Lawrence A. Dianovich 

Rodger Doll , Shirley Doll , and Verna Doll 

Thomas Fisher 

George and Frances From 

Kendall and Mariam From 

Daniel and Leona Fruh 

Nicholas G. Glanschneg 

Michael R. Goulden 

Orrin G. Holt 
5-2 Raymond – Cosmopolis Transmission Line Rebuild Project EA 

Kenneth Hurley 

Larry E. Hurley 

George and Dorothy James 

George R. James 

Boyd and Myra Johnson 

Ronald E. Johnson 

Richard A. Jones 

Kazue Jones 

Phillip S. Jurasin 

Donald J. Lane 

Edward and Lynn Lantich 

Ardine Lewis 

Edward G. and Martha Marthe 

James and Vinita Mays 

Teresa Mays-Gabrielson 

David and Anne Nettnin Gene and Betty Nye 

Michael A. Olson 

William Padrazzetti 

Roy and Ann Pearmain 

Howard S. Pearson 

Terry and Vicki Peterson 

Mildred Roberts 

Louis and Claudia Russell 

Ralph and Lois Schley 

Michael D. and Terry Smith 

Charles and Janice Spradlin 

Joseph and Karon Strada 

Eric Sund and Kirk Sund 

Rodger E. and Verna L. Thein 

Robert H. Vallier 

John K. Walczak 

Anton H. Wildhaber 

Larry and Heidi Willard 

Brian and Carmen Woodell 

Associates Financial Services 

Bascom Pacific LLC / Forest Systems LLC 

Capitol Pistol Club Inc 

Champion Pacific Timberlands Inc 

Chehalis Valley Timber Inc 

City of Cosmopolis 

County of Grays Harbor 

County of Pacific Department of Public Works 

Forest Northwest 

Fruit Growers Supply 

Grays Harbor PUD No 1 

John Hancock Mutual Life Ins. Co. 

Mid Valley Resources 

Pacific County PUD No.2 

Port Blakely Tree Farm 

Qwest Corporation 

Rainier Mineral 

Rainier Timber Company 

Skarperud Timber Company 

State of Washington 

State of Washington DNR 

State of Washington Department of Transportation 

USHUD 

Weyerhaeuser Company 

Weyerhaeuser Timberlands Co. 

Willapa Harbor Gun Club 

W T Timber LLC 
Bonneville Power Administration 6-1 

Chapter 6 

Glossary and Acronyms 

Access road – Roads and road spurs that provide vehicular access to the corridor and structure sites. 

Where county roads, logging roads, driveways or other access is already established, access roads are 

built as short spurs to the structure site. Access roads are maintained even after construction except for 

temporary access roads. Temporary access roads are laid down on geotextile in sensitive areas such as 

wetlands or yards, so that they can be removed after use and the site restored. 

Alluvial – Deposited by flowing water, as alluvial sediment. 

Ambient noise – Noise within the surrounding area from sources such as a substation or road use, that are 

part of the background noise level. 

APE – Area of Potential Effects, as used in Section 106 of the National Historic Preservation Act is the 

geographic area within which an undertaking may directly or indirectly cause alterations in the character 

or use of historic properties. 

Aquifer – Water-bearing rock or sediments below the surface of the earth. 

AWQC – Ambient water quality criteria are elements of state water quality standards, expressed as 

constituent concentrations representing a quality of water that supports a particular use. When criteria are 

met, water quality will generally protect the designated use. 

BMP – Best Management Practices, a practice or combination of practices that are the most effective and 

practical means of preventing or reducing the amount of pollution generated by non-point sources to a 

level compatible with water quality goals. 

BPA – Bonneville Power Administration. 

Capacity – A measure of the ability of a transmission line, groups of lines (path) or transmission system 

to carry electricity. 

Carbon Monoxide (CO) – Colorless, odorless, poisonous gas produced when carbon burns with 

insufficient air. 

Chronic – Of long duration or frequent occurrence. 

Clean Water Act – A Federal law intended to restore and maintain the chemical, physical, and biological 

integrity of the nation’s waters and secure water quality. 

Colluvium – Soil material, rock fragments, or both accumulated at the base of steep slopes. 

Conductor – The wire cable strung between transmission towers through which electric current flows. 

Corona – Corona occurs in regions of high electric field strength on conductors, insulators, and hardware 

when sufficient energy is imparted to charged particles to cause ionization (molecular breakdown) of the 

air. 
6-2 Raymond – Cosmopolis Transmission Line Rebuild Project 

Culvert – A corrugated metal or concrete pipe used to carry or divert runoff water from a drainage such 

as a ditch or stream; usually installed under roads to prevent washouts and erosion. 

Cultural Resources – Those historic and archeological properties, properties of traditional and cultural 

significance, sacred sites, Native American human remains and associated objects, and cultural 

landscapes which are entitled to special consideration under Federal statute, regulations, and/or executive 

orders. 

Cumulative Impacts – impacts created by the incremental effect of a specific action when added to other 

past, present, or reasonably foreseeable actions. 

Current – The amount of electrical charge flowing through a conductor (as compared to voltage, which 

is the force that drives the electrical charge). 

Danger trees – Trees (or high-growing brush) in or alongside the right-of-way, which are hazardous to 

the transmission line. These trees are identified by special crews and must be removed to prevent tree-fall 

into the line or other interference with the wires. BPA’s Construction Clearing Policy requires that trees 

be removed that meet either one of two technical categories: Category A is any tree that within 15 years 

will grow to within about 18 feet of conductors when the conductor is at maximum sag (212oF) and 

swung by 6 lb per sq feet of wind (58 mph); Category B is any tree or high-growing brush that after a year 

of growth will fall within about 8 feet of the conductor at maximum sag (176oF) and in a static position. 

dBA – The first two letters (dB) are an abbreviation for “decibel,” the unit in which sound is most 

commonly measured. The last letter (A) is an abbreviation for the scale (A scale) on which the sound 

measurements were made. A decibel is a unit for expressing relative difference in power, usually 

between acoustic signals, equal to 10 times the common logarithm of the ratio of two levels. 

Decibel – A decibel is a unit for expressing relative difference in power, usually between acoustic signals, 

equal to 10 times the common logarithm of the ratio of two levels. 

DNR – State of Washington, Department of Natural Resources. 

Double outage – Simultaneous loss of two transmission lines that are on the same right-of-way, on the 

same structure, or are separated by 1,200 feet or less. 

Drain dips – Dips in secondary roads to reduce road surface and fill slope erosion by intercepting storm 

and seasonal runoff and diverting it to a safe disposal area. 

Drift – A collective term for all the rock, sand, and clay that is transported and deposited by a glacier 

either as till or outwash. 

EA – Environmental Assessment; an environmental document prepared by Federal agencies under the 

National Environmental Policy Act to determine whether the proposed action has the potential to cause 

significant environmental effects. 

Easement – A grant of certain rights to the use of a piece of land BPA acquires easements for many of its 

transmission facilities, includes the right to enter the right-of-way to build, maintain, and repair the 

facilities, and for the use, improvement, or construction of access roads. Permission for these activities 

are included in the negotiation process for acquiring easements over private land. 
Bonneville Power Administration 6-3 

Electric and magnetic fields (EMF) – The two kinds of fields produced around the electric wire or 

conductor when an electric transmission line or any electric wiring is in operation. 

Electromagnetic interference (EMI) – Interference caused by corona (See corona). 

Electromagnetic noise – The noise generated in the frequency bands used for radio and television signals 

caused by corona on transmission line conductors. 

Emergent Wetland–Wetlands dominated by herbaceous species. 

EPA – Environmental Protection Agency. 

Equivalent sound level (Leq) – Generally accepted as the average sound level. 

Exceedence levels (L levels) – Refers to the A-weighted sound level that is exceeded for a specified 

percentage of the time during a specified period. 

FAA – Federal Aviation Administration. 

FCC – Federal Communications Commission. 

Fecal coliform – Bacteria found in the intestinal tracts of birds and mammals that can be passed to the 

environment via fecal matter. 

FEMA – Federal Emergency Management Agency; produces flood insurance maps used to determine the 

location of floodplains. 

Fiber optic cable – Special wire installed on the transmission line that is used for communication 

between one location and another. 

Floodplain – That portion of a river valley adjacent to the stream channel that is covered with water when 

the stream overflows its banks during flood stage. 

Forested Wetland – A wetland with a tree canopy 

Generation – The power that is produced through some type of power plant. 

Glacial outwash – Materials deposited by glacial meltwaters. 

Glaciofluvial – Used of sediments transported by ice and deposited from the flowing meltwaters of a 

glacier. 

H-Frame – Refers to a type of transmission line structure usually made of wood, with vertical poles and 

horizontal crossarms. When erected, it resembles a capital letter “H.” 

Insulators – A ceramic or other non-conducting material used to keep electrical circuits from jumping 

over to ground. 

Intermittent –Creeks or streams with seasonal or periodic water flow; under the Washington state water 

typing classifications, Type 5 streams are intermittent. 
6-4 Raymond – Cosmopolis Transmission Line Rebuild Project 

Kilovolt (kV) – One thousand volts. 

Lattice steel – Refers to a transmission tower constructed of multiple steel members that are connected 

together to make up the frame. 

Load – The amount of electric power or energy delivered or required at any specified point or points on a 

system. Load originates primarily at the energy-consuming equipment of customers. 

Low-income population– Low-income population means any readily identifiable group of low-income 

persons who live in geographic proximity who would be affected by the Proposed Action, policy or 

activity. Low-income is generally defined as a household income at or below the US Department of 

Health and Human Services poverty guidelines. The guidelines establish poverty thresholds on an annual 

basis; the poverty threshold for 2001 was $11,559 for a 2-person household in the contiguous United 

States. However, other thresholds may be used as appropriate. 

Mbf – Thousand board feet; a way to measure amount of lumber. 

mG – Milligauss – A unit used to measure magnetic field strength. One-thousandth of a gauss. 

Minority population – Minority population means any readily identifiable groups of minority persons 

who live in geographic proximity, and if circumstances warrant, geographically dispersed/transient 

persons (such as migrant workers or Native Americans who will be similarly affected by a proposed 

program, policy or activity. A minority population is considered to be present if the minority population 

percentage of the affected area is greater than the minority population percentage in the general 

population or other appropriate unit of geographic analysis (census tracts are generally considered 

appropriate). Guidance from the U.S. Council on Environmental Quality (CEQ) states that “minority 

populations should be identified where either (a) the minority population of the affected area exceeds 50 

percent or (b) the minority population percentage of the affected area is meaningfully greater than the 

minority population percentage in the general population or other appropriate unit of geographic analysis” 

(CEQ, 1998). 

Mitigation – Steps or measures taken to lessen the potential effects predicted for a resource. They may 

include reducing the impact, avoiding it completely, or compensating for the impact. Some mitigation, 

such as adjusting the location, of a tower to avoid a special resource, is taken during the design and 

location process. Other mitigation, may be done during construction, such as measures to reduce noise, or 

after construction, such as reseeding access roads with desirable grasses in order to help prevent the 

proliferation of weeds. 

Multiplier Effects – The total increase in income and employment that occurs in the local economy for 

each dollar of local project expenditure.

NAAQS – National Ambient Air Quality Standards. 

National Environmental Policy Act (NEPA) – A law passed in 1969 that requires Federal agencies to 

assess the impacts that their actions may have on the environment. 

NESC – National Electrical Safety Code 

NHPA – National Historic Preservation Act. 

Non-lustrous – Non-reflecting conductor made of metal with a dull finish 
Bonneville Power Administration 6-5 

Noxious weeds – Plants that are injurious to public health, crops, livestock, land or other property, as 

identified by state law. 

NRHP – National Register of Historic Places. 

100-year floodplain – Areas that have a 1 percent chance of being flooded in a given year, designated by 

FEMA. (See Floodplain.)

OAHP – Office of Archeology and Historic Preservation. 

Open water – Water covers the surface at a mean annual depth greater than 6.6 feet or, if less than 6.6 

feet in depth, the habitat does not support rooted plant species. 

ORCAA – Olympic Region Clean Air Agency. 

Outage – Events caused by a disturbance on the electrical system, that requires BPA to remove a piece of 

equipment or a portion or all of a line from service. The disturbances can be either natural or humancaused. 

Overloaded – Too much current trying to flow over transmission facilities. Equipment has safeguards: 

in the event of overloading of the system, switches will disconnect sensitive equipment from the flow of 

electricity. 

Ozone – A form of oxygen, O3, produced when an electric spark or ultraviolet light passes through air or 

oxygen. 

Palustrine – A term used to classify wetlands; includes freshwater wetlands vegetated with plants and 

wetlands that occur in tidal areas where salinity due to ocean-derived salts is below 0.5 parts per 

thousand. 

Per capita income – Total personal income divided by population. 

Perennial – Refers to a stream or creek with continuous, year-round water flow; under the state water 

typing system includes Type 1-4 streams. When this term refers to plants, it means species that live for 

several years. 

Permanently Flooded – An area where water covers the land surface throughout the year in all years. 

Personal income – Labor earnings (proprietors income & wages and salaries); dividends, interest, and 

rent; and transfer payments. 

PM10 – Particulate matter having a nominal aerodynamic diameter less than or equal to 10 microns. 

Respirable – Easily inhaled. 

Right-of-way (ROW) – An easement for a certain purpose over the land of another, such as a strip of 

land used for a road, electric transmission line, pipeline, etc. 

Riparian – Pertaining to, living on, or situated on the banks of rivers and streams. 

Safety – The state of being safe from the risk of experiencing or causing injury, danger, or loss. 
6-6 Raymond – Cosmopolis Transmission Line Rebuild Project 

Scrub-shrub – Includes areas dominated by woody vegetation less than 6 m (20 feet) tall. The species 

include true shrubs, young trees (saplings), and trees or shrubs that are small or stunted because of 

environmental conditions. 

Seasonally flooded – Surface water is present for extended periods especially early in the growing 

season, but is absent by the end of the growing season in most years. The water table after flooding 

ceases is variable, extending from saturated to the surface to a water table well below the ground surface. 

Semi-permanently flooded – Surface water persists throughout the growing season in most years. When 

surface water is absent, the water table is usually at or very near the land's surface. 

Sheet erosion – Removal of a uniform, thin layer of soil by raindrops or water runoff on bare soil. 

SHPO – State Historic Preservation Office. 

Silvicultural – Concerning the cultivation and management of trees to establish or maintain age 

structures, species composition, and growth rates that contribute to forest management goals. This may 

include planting, thinning and selective cutting, and clear-cutting, often of single-species plantations. 

Single-circuit – A line with one electrical circuit on the same tower. 

Sole source aquifer – An aquifer designated by the Environmental Protection Agency which provides at 

least half of an area’s drinking water. 

Staging area – The area cleared and used by BPA/BPA’s contractor to store and assemble materials or 

structures. 

STP – Shovel test probes; are the hole dug and process undertaken to conduct subsurface cultural 

resource investigations. 

Structure – Refers to a type of support used to hold up transmission or substation equipment. 

Substation – The fenced site that contains the terminal switching and transformation equipment needed at 

the end of a transmission line. 

Successional – Refers to the gradual process of progressive change and replacement of ecological 

communities at a particular site over time. Age and structure of successional forest categories vary 

significantly by forest type and from one biogeoclimatic zone to another. 

 Early-successional – Early-successional stands typically comprise herbaceous plants, shrubs, 

seedlings, saplings, and small trees, including many shade-intolerant species. 

 Mid-successional – Typically includes stands of medium-sized pole and saw timber. Understories 

begin to open up as lower-growing species are shaded out. 

 Late-successional – Typically includes stands of larger trees (at least 24 inches in diameter at breast 

height), multi-layered canopies, downed logs, and standing dead trees (snags). Heavily shaded 

understories are more open but include shade-tolerant shrubs and herbaceous species. 

System reliability – The ability of a power system to provide uninterrupted service, even while that 

system is under stress. 
Bonneville Power Administration 6-7 

Take – Section 3 of the Endangered Species Act defines take as an act to a listed species with the effect 

“to harass, harm, pursue, hunt, shoot, wound, trap, capture, collect or attempt to engage in any such 

conduct.” The USFWS further defines “harm” as “significant habitat modification or degradation that 

results in death or injury to listed species by significantly impairing behavior patterns such as breeding, 

feeding, or sheltering,” and “harass” as “actions that create the likelihood of injury to listed species to 

such an extent as to significantly disrupt normal behavior patterns which include, but are not limited to 

breeding, feeding or sheltering.”

Temporarily flooded – An upland or wetland area where surface water is present for brief periods during 

growing season, but the water table usually lies well below the soil surface. 

Terrace – A flat, often narrow remnant of an old floodplain, which stands above a stream that has eroded 

its bed down to a new floodplain. 

Thermal rating – The maximum current that can flow in a transmission line conductor, device or 

electrical machine without a failure or damage caused by excessive temperature. 

THPO – Tribal Historic Preservation Officer is the tribal official appointed by the tribe’s chief governing 

authority or designated by ordinance or preservation program who has assumed the responsibilities of the 

State Historic Preservation Officer for purposes of Section 106 compliance on tribal lands in accordance 

with National Historic Preservation Act regulations

Threatened species – Species officially designated by the US Fish and Wildlife Service that are likely to 

become endangered within the foreseeable future throughout all or a significant portion of their range; 

states also designate threatened species. 

Transmission line – The structures, insulators, conductors, and other equipment used to transmit 

electrical power from one point to another. 

TSP – Total suspended particulate; a measure of water turbidity. 

Turbidity – A measure of the amount of particulate matter, such as suspended sediment, per unit volume 

of water. 

USFWS – U.S. Fish and Wildlife Service. 

Vegetation management – BPA’s policies and protocols that guide methods of controlling vegetation 

within and near electric power facilities. Vegetation that is controlled includes tall-growing species that 

pose a hazard to power lines, as well as noxious weeds. It also includes methods to encourage the growth 

of low-growing, desirable species that resist noxious weed invasion. 

Water bars – Smooth, shallow ditches excavated at an angle across a road to decrease water velocity and 

divert water off and away from the road surface. 

Watershed – A drainage basin defined by an elevated boundary area separating tributaries draining into 

different river systems. 

WDFW – Washington State Department of Fish and Wildlife.

WDNR – Washington State Department of Natural Resources. 
6-8 Raymond – Cosmopolis Transmission Line Rebuild Project 

Wetland – An area where anaerobic conditions (lack of oxygen) develop in the soil because of prolonged 

saturation or inundation by water during the growing season. Indicators of wetlands include plant species 

adapted to such conditions, characteristic soil colors and chemical properties, and physical evidence of 

flooding or waterlogged soils. 

WRIA – Water Resource Inventory Areas are administrative and planning boundaries developed and 

managed by the Washington State Department of Ecology. 

WSDOT – Washington State Department of Transportation. 
Bonneville Power Administration 7-1 

Chapter 7 

References 

Alt, D.D. and D.W. Hyndman. 1984. Roadside Geology of Washington. Mountain Press 

Publishing Company. Missoula, Montana. 

Ambrosino, P. 2002. Personal Communication. Washington Department of Transportation. 

Anderson, W.L. 1978. Waterfowl Collisions with Power Lines at a Coal Fired Plant. Wildlife 

Society Bulletin. 6(2):77-83. 

Anonymous. n.d. Power Memoirs: P.U.D. Manager Fribley Recalls Early Days Power. 

Reproduced newspaper article on file at the Pacific County Historical Museum, South Bend, 

WA. 

Arend, P.M. 1970. The Ecological Impact of Transmission Lines on the Wildlife of the San 

Francisco Bay. Prepared for U.S. Fish and Wildlife Service, San Francisco Bay National 

Wildlife Refuge, CA. 

Argentea (Argentea Environmental). 2001. Wetland Delineation Report; Raymond-Cosmopolis 

Transmission Line Culvert Replacement Project (Unpublished Report). Argentea 

Environmental, Wilsonville, OR. 

Atwater, B. F., and E. Hemphill-Haley. 1997. Recurrence Intervals for Great Earthquakes of the 

Past 3,500 Years at Northeastern Willapa Bay, Washington. U.S. Geological Survey 

Professional Paper 1576. 

Avery, M.L., P.F. Springer, and N.S. Dailey. 1980. Avian Mortality at Man-made Structures: 

An Annotated Bibliography. National Power Plant Team. U.S. Fish and Wildlife Service 

Biological Services Program Technical Report FWS/OBS-80/54. 

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Bonneville Power Administration 7-5 

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7-6 Raymond – Cosmopolis Transmission Line Rebuild Project 

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Research, Portland, OR. 
Bonneville Power Administration 8-1 

Chapter 8 

Public/Agency Comments and Responses 

This chapter presents comments received on the Preliminary EA and the response to these 

comments. Comments were received from state and local agencies, non-profit organizations, 

and private citizens via e-mail, letter, fax, and at the public meetings held on February 11, 2003 

in Cosmopolis and on February 12, 2003 in Raymond. 

The comments received were subdivided into individual comments addressing specific topics, 

which are organized by chapters and sections that correspond to the organization of the EA. 

Each comment was given an identifying number that corresponds to the order in which the 

comment was logged in to the official BPA comment file. Therefore, more than one comment 

addressed in this chapter may have the same number because they are different parts of one 

comment. 

The following comments were received: 

Comment #10, E-mail from Craig Zora, Aquatic Lands Division of the WA State Department 

of Natural Resources 

Comment #11, Comments written on flip charts at February public meetings 

Comment #12, Fax from Dale R. Seaman, City of South Bend 

Comment #13, E-mail from Jason Dunsmoor, P.E. Chief of Engineering & Operations, PUD 

No. 2 of Pacific County 

Comment #14, Letter from David John Weiss, private citizen 

Comment #15, Letter from Jeri Berube, WA State Department of Ecology, Administrative 

Coordinator, Southwest Regional Office, dated Feb. 20, 2003, 

Comment #16, Letter from Jeri Berube, WA State Department of Ecology, Administrative 

Coordinator, Southwest Regional Office, dated Feb. 21, 2003 

Comment #17, E-mail from Arthur Grunbaum, Friends of Gray Harbor 

Comment #18, Letter from Gary Graves, Forest Practices District Manager, WA State 

Department of Natural Resources 

Comment #19, E-mail from Abraham Ringel, private citizen, dated March 11, 2003 

Comment #20, E-mail from Abraham Ringel, private citizen, dated February 23, 2003 

As a result of reviewing and responding to the comments received, some changes were made in 

the Preliminary EA. Substantive changes to Chapter 1, 2, and 3 of the Final EA are marked 

using underlines for added text or strikethrough text for deleted material. 

________________________________________________ 

Chapter 1 Purpose of and Need for Action 

Section 1.3 Purposes of Action

Comment 11: The Pacific County PUD wants to see the project go ahead this year because of 

reliability concerns. 

Response: The Rebuild Project has received funding for Fiscal year (FY) 2004, with some 

funds extending into FY 2005. Because FY 2004 begins on October 1, 2003, cannot start until 
8-2 Raymond – Cosmopolis Transmission Line Rebuild Project 

2004. BPA is acutely aware of the age and condition of this transmission line but adequate 

funding was not available to implement the project in FY 2003. 

________________________________________________ 

Comment 13: In the past fifty years the District has endured many "bumps" on the transmission 

system due to outages on the Ray-Cosi line. The existing line has out lived its service life and is 

inadequate to serve the needs of a reliable transmission system for the District and the customers 

of Pacific County. 

Response: BPA proposed this project in light of the poor condition of the line and reliability 

concerns and proposes to begin rebuilding the line as soon as funds are available, in fiscal year 

2004. 

________________________________________________ 

Comment 13: The Ray-Cosi line is far overdue to be re-built, it would be fiscally irresponsible 

to not go forward with the project given the fact that BPA was recently appropriated $700 

Million in borrowing authority. 

Response: The money that was recently appropriated for extra borrowing authority would be 

used to cover agency-wide needs and expenses, based on priority. Within the Transmission 

Business Line, there are a number of transmission line projects that are proposed and there are 

not adequate funds to currently cover the expenses of building all of them should they be 

approved. Some of the larger transmission line projects that are currently approved are very 

expensive projects to build, such as the Grand Coulee Bell and the Schultz-Wautoma 

Transmission Line Projects. Besides new Transmission Business Line projects, there are other 

programs and projects that also compete for funding, such as Power Business Line Projects. 

BPA Chief financial Officer, Jim Curtis, addressed the financial crisis in early April in a briefing 

to the Northwest Power Planning Council. He stated that without a rate increase, successful cost 

reductions or some combination thereof, BPA projects a cash deficit in 2006 of $690 million. 

Mr. Curtis said, "We need to take action on rates and costs. We also have capital limitations, 

even with the new $700 million in borrowing recently granted by Congress. If we don't 

successfully restore borrowing authority by paying Treasury this and every year and if we don't 

proceed with debt optimization, our borrowing authority is consumed by 2007-2010, which 

means very shortly we would need to start constraining capital programs." He also told the 

Council that BPA cannot expect Congress to further extend BPA’s borrowing authority. 

BPA’s financial crisis unfortunately resulted in a delay of one year in implementing this project. 

________________________________________________ 

Comment 11: Leave the new poles galvanized. Do not pay to dull them to save money. 

Response: BPA made the decision to leave the poles galvanized and not pay extra money to 

have the manufacturer dull them. The cost of dulling the structures would be approximately 

$250,000. The galvanized steel structures will weather over several years to the same dull finish 

that we would pay for. The extra expense for dulling the structures was not considered 

acceptable because BPA did not receive any comments from the public on visual issues 

requesting dulled structures and because they will naturally dull over time.
Bonneville Power Administration 8-3 

________________________________________________ 

Comment 13: The right-of-way clearing this past summer improved many areas of the line, but 

failed to complete the task at hand. This is apparent, if there are still trees left on the right-ofway that can be felled into the line. (BPA Note: This comment is from the Pacific County PUD 

and followed several paragraphs discussing outages so it relates to reliability issues.)

Response: The BPA Danger Tree Removal Project was a separate project, conceived of and 

planned before the Rebuild Proposal and done for the purpose of improving the reliability of the 

existing transmission line. Danger trees are trees that could potentially grow, fall, or bend into 

the lines from the area next to the right-of-way. They are targeted for removal based on the 

tree’s overall condition, the ground around it, the tree species, and any other defects that might 

cause the tree to be unstable and therefore more likely to fall into the transmission line. The 

BPA forester examined tree stands along the right-of-way and decided to leave trees in several 

areas for various reasons including: 

• Douglas fir was left growing adjacent to the transmission line in several stretches because 

it is a stable species. 

• BPA made the decision to only cut trees in areas where landowners were willing to 

accept compensation for the trees, rather than acquire rights through condemnation. BPA 

is currently negotiating with these landowners to cut trees. 

• In two areas, trees were not cut because the Rebuild Project planning process began 

during the last six months of planning the Danger Tree Removal Project and two 

realignment areas were created to protect sensitive resources. Danger trees were not cut 

in these areas because it was anticipated that the transmission line might be moved out of 

these areas under the Rebuild Project, eliminating the need to cut these trees in sensitive 

areas. 

________________________________________________ 

Comment 13: The public meeting held on 2/12/03 concerning the re-construction of the RayCosi line revealed the possibility of the project not going forward this year or even at all. On 

behalf of the Public Utility District No. 2 of Pacific County I would like to express our concerns. 

BPA knows the statistics on outages for this particular line, so I do not see the need to reiterate 

them here. A considerable amount of time and money has been spent on the design and 

permitting of this project, along with the recent right-of-way clearing last summer. I would hate 

to see this money wasted prolonging the construction and then having to duplicate the work 

again in the future. 

Response: The delay in implementing the project will not result in much additional expense, if 

any, for design and permitting. The permits that will be obtained and the consultation process 

will be valid for the work that would be done in fiscal year 2004 and 2005. 

The BPA Danger Tree Removal Project, conducted last year, was done based on the need to 

improve the reliability of the existing transmission line, although in some areas trees were not 

removed because realignments were proposed under the Rebuild Project. Currently, there is less 

potential for tree-caused outages than before the trees were removed. 

________________________________________________ 
8-4 Raymond – Cosmopolis Transmission Line Rebuild Project 

Chapter 2 Proposed Action and Alternatives 

General Comment

Comment 11: Could the project be delayed due to lack of funding? 

Response: BPA proposes to begin rebuilding the line when funds are available, in fiscal year 

2004.

________________________________________________ 

Chapter 3 Affected Environment, Environmental Consequences, and Mitigation 

General Comments

Comment 20: Will proposed mitigations to damage be included in the draft Environmental 

Assessment? 

Response: Proposed mitigation measures were included in Chapter 3 of the Preliminary EA. 

These mitigation measures are included in the Final EA (Chapter 3 and Appendix D) and 

incorporated into the FONSI, obligating BPA to implement all mitigation measures. The 

construction requirements are developed based on the Mitigation Action Plan and then 

incorporated into the construction specifications. 

________________________________________________ 

Comment 19: May I also suggest that an environmental organization be a formally authorized 

inspector and arbiter of environmental and mitigation measures (which should be carefully and 

fully defined). The Grays Harbor Audubon Society appears to be the premier local 

environmental organization. There might be others, such as the Sierra Club, but they don't have 

a strong presence in the area. Certain factors, including my lack of appropriate experience, 

make me hesitate to step forward, but I would very much appreciate being kept informed of how 

things are progressing. Again, many thanks to you and the other good people involved in 

preserving the environmental characteristics that make this area desirable and unique. 

Response: Because BPA is committed to implementing the mitigation measures and complying 

with environmental regulations during the construction phase of the project, there will be a 

variety of individuals responsible for compliance. For this reason, we do not contemplate hiring 

or designating an outside individual at this time but we understand your concerns. Individuals 

who will be responsible for environmental compliance include: 

• BPA recently created a new position in response to the need to have one person 

responsible for oversight in coordinating environmental mitigation compliance. The 

BPA Environmental Resource Requirements Coordinator would be responsible for 

oversight of the implementation process, including resolving any problems or 

deficiencies that arise. 

• The construction inspector will work closely with the Requirements Coordinator and the 

two BPA Environmental Specialists who have been working on the project in order to 

ensure compliance with mitigation measures and environmental regulations. Meetings 

and site visits will be conducted prior to the beginning of the project to identify sensitive 

sites, go over materials (maps and written documents), explain procedures for 

implementing mitigation, and methods to provide notification and receive assistance if 
Bonneville Power Administration 8-5 

there are any problems or questions that arise when an environmental specialist is not on 

site. 

• The two BPA Environmental Specialists and the Requirements Coordinator will make 

periodic site visits to monitor compliance and address any questions/issues. 

• The contractor is required to hire a qualified erosion and sediment control manager to 

implement the SWPP Plan, who has been certified through the Washington Department 

of Transportation Construction Site Erosion and Sediment Control Course (or a similar 

course or certification program). 

• The local WDFW Habitat Biologist will be informed of the timing and location of all instream work so that they can monitor the work and visit the site if desired. 

________________________________________________ 

Comment 19: One concern is the lack of details regarding mitigation of potential and actual 

environmental damage. The PEA abounds with statements such as "An environmental specialist 

will meet with contractors and inspectors in the field to visit wetlands . . ." and "Roads will be 

designed and constructed to minimize . . ." (pars. 3.6.3 and 3.7.3); "Erosion control measures to 

avoid sedimentation of [wetlands, or floodplains, as applicable] will be used..." (pars. 3.7.3 and 

3.8.3); and "Proposed roads and structures and structures would be located to avoid floodplains 

where possible." (par. 3.8.3) Reference to appropriate plans and specifications might be 

appropriate. 

Response: As you noted, mitigation measures that will be implemented are listed in the 

appropriate sections of Chapter 3. These measures are discussed at an adequate level of detail to 

inform decision-makers, and more detailed information on how they will be implemented is not 

included. A more detailed description on what they entail and where and how they will be 

implemented is in the Mitigation Action Plan (Appendix D) of the Final EA. The construction 

requirements are developed based on the Mitigation Action Plan and then incorporated into the 

construction specifications. The Stormwater Pollution Prevention plan is the part of the 

construction specifications that contain the construction requirements for preventing and 

controlling erosion and sedimentation. 

The process of developing a mitigation framework began during the design process when 

decisions were made on where to locate roads and structures so as to avoid sensitive resources. 

Details on this process are not included in the EA except in general terms because many 

individual decisions were involved in this ongoing process. The mitigation process also included 

developing mitigation measures to implement during and after construction. 

In addition to the mitigation measures in the EA, mitigation is also included in the permits and 

written conservation recommendations received from various agencies during the consultation 

process. Mitigation measures will be included in the Erosion and Sediment Control Plan (ESC) 

and the Stormwater and Pollution Prevention (SWPP) Plan, which include the details of 

implementing these plans. 

A Mitigation Action Plan was developed that compiles all the mitigation measures from all 

sources into a single document. It refers to the source of the mitigation measure and details how 

it will be implemented and who is responsible to ensure that it is implemented. If details are not 

included in the Mitigation Action Plan, it refers to the specific document where the details can be 
8-6 Raymond – Cosmopolis Transmission Line Rebuild Project 

found, such as the SWPP. The environmental construction requirements that are part of the 

construction specifications are taken directly from the Mitigation Action Plan. A team of BPA 

staff will follow the implementation of mitigation measures, coordinated by the Environmental 

Resource Requirements Coordinator, and assisted by the two Environmental Specialists who 

worked on the project, the inspector, and the qualified erosion and sediment control manager 

hired by the contractor.

The details of how to implement mitigation in the Mitigation Action Plan are very clear and 

specific. In addition, a full set of maps of the project area are being created that depict the 

location of all sensitive areas and resources with information on each resource and where 

restrictions and special procedures can be found. These maps, which are included in the 

construction specifications, will be discussed at all pre-bid meetings with potential contractors, 

the contractor who is awarded the contract for this project, and the project inspector. They will 

be used at all site meetings regarding environmental issues. 

Some mitigation measures, such as the marking and flagging of sensitive resources, such as 

wetlands or trees to be cut as snags, will be implemented by environmental specialists. The 

details of the best way to do this are worked out with the project team based on prior experience 

implementing the mitigation measure, site characteristics that may influence implementation, and 

the recommendations of various stakeholders. Adjustments are made when any potential or 

actual problems are encountered. 

________________________________________________

Comment 19: May I suggest that control of the project might be enhanced by thoroughly 

detailing all construction design requirements and specifications that might apply to the project, 

and referring to such in a final Environmental Assessment? (That might already be in the works.) 

Failing that, as documented by my experience in design, construction and contracts, 

construction contractors would legitimately follow the most expedient, economical course during 

the life of the project. 

Response: The Mitigation Action Plan incorporates all the details of implementing the 

mitigation measures found in the EA and includes information on where each measure should be 

implemented. 

As you mention, without a sufficient amount of detail, it is possible that contractors would not 

carry these agreements out in such a way as to fully implement them. BPA is very aware that to 

honor the intent of the agreements, sufficient detail must be provided to the contractor so they 

can factor in the amount of work it will entail into their bid. A great deal of time and attention is 

devoted to careful use of language to ensure contractors understand what they must do. Part of 

the purpose of pre-bid and pre-construction meetings is to provide verbal clarification and then 

modify the documents if needed. The construction specifications will be very detailed in an 

effort to avoid the need for contract modifications while work is in progress. 

________________________________________________ 

Section 3.3 Geology and Soils

Comment 19: "Culverts, cross-drains, and water bars will be spaced and sized properly" (par. 

3.3.3) The word "properly" is subject to interpretation. Construction/engineering 
Bonneville Power Administration 8-7 

plans/specifications would be the best determinant of a definition; reference to such plans etc. 

might avoid problems. 

Response: BPA designs culverts, ditches, intercepting dips, and water bars using construction 

drawing (typical sections). The road engineer lists the specific locations where these structures 

should be installed, based on site characteristics. The choice of where to place these structures 

and the number of structures that will be installed will not be left to the discretion of contractors. 

The final location and number of culverts, cross-drains, and water bars will be verified in the 

field to ensure the will function correctly as designed. For these types of structures, BPA applies 

BMPs listed in Section 3 (Guidelines for Forest Roads) of the Washington Forest Practices 

Board Manual (See the Road Related Best Management Practices section). Guidelines for 

spacing of drainage structures are in Appendix C of the BPA document, Transmission 

Engineering Standard Access Roads. 

________________________________________________ 

Section 3.4 Vegetation

Comment 19: Statements such as "Revegetate disturbed areas with native seed" (pars. 3.4.3, 

3.2.3, and 3.5.3) appear indefinite. Specifications might help avoid possible conflicts among all 

parties, including landowners, regarding the types and adequacy of revegetation. 

Response: The following native grass seed mix would be used for revegetating disturbed areas, 

at a seeding rate of 50 pounds per acre: 

• Blue wildrye (Elymus glaucus), native grass, 30% by weight 

• Red fescue (Festuca rubra), 30% by weight 

• Regreen (a Trade name for Triticum x Agropyron), sterile wheat, 20% by weight 

• Mannagrass (Glyceria occidentalis, G. striata or G. elata depending on availability), 

native grass, 10% by weight 

• California brome (Bromus carinatus), native grass, 10% by weight 

This seed mix is specified in the Mitigation Action Plan and construction specifications that the 

contractor must follow. Although one component, Regreen, is not a native species, it was 

included in the mix because it provides quick cover by germinating very fast. It does not persist 

on the site because it is a sterile species and it is not a perennial species. Different species in the 

mix are adapted to grow in different water regimes, making it suitable for wetlands and uplands. 

This mix was used in 2002 for revegetating areas disturbed during the Danger Tree Removal 

Project and good germination and coverage was achieved. 

In an effort to work with landowners and minimize the potential for conflicts over revegetation 

of disturbed areas, the BPA realty specialist made contact with all the landowners either by 

phone, mail, or in person and discussed the new locations of the structures. Weyerhauser owns 

approximately 85% of the land in this project and there are not a large number of private 

landowners. The realty specialist explained that any disturbed areas would be restored as near as 

possible to their natural state and seeded with a native seed mix. She explained that trees would 

not be planted on the right-of-way because it would present future problems with line safety. At 

this point she has not encountered any conflicts or issues, but should some arise during 
8-8 Raymond – Cosmopolis Transmission Line Rebuild Project 

implementation of the project, a site meeting would be held to determine the best way to resolve 

the issue. 

________________________________________________ 

Comment 19: "Develop a noxious-weed control program . . ." (pars 3.3.3 and 3.4.3) might be 

more effective if preparation were to be done in accordance with specified parameters and 

contingent on approval by a specified agency. 

Response: The components of a noxious weed control plan are included in the Mitigation 

Action Plan to address the site-specific conditions of this project, the species known to occur in 

the project area, regulatory requirements for control of certain species, and the type of activities 

that will occur. The noxious weed control plan will be fully developed and then submitted to 

both the Grays Harbor and Pacific County Weed Control Boards for comments prior to 

implementation. After construction, any subsequent weed control activities would be done under 

BPA’s Transmission System Vegetation Management Program Final Environmental Statement 

(May 2000). 

________________________________________________ 

Sections 3.5 Fish and Wildlife, and 3.6 Water Quality

Comment 14: I have read most of the related documents and have had several field visits of the 

Raymond-Cosmopolis Transmission Line Rebuild Project. The major problem I encountered 

with the project was the power line roads. The road system used to access and maintain the 

power line is poorly designed, poorly built and not maintained. The current road system directly 

impacts water quality and fish habitat, and will continue to do so until correctly designed and 

maintained regularly. Aside from the feel good environmental information in the documents the 

text in the related documents and the comments from Bonneville Power Staff is very clear, BPA 

is not required to build or maintain their roads to any specific standards. BPA does not 

acknowledge it has a severe problem with its road system, or that there is continued 

environmental damage from old and new BPA roads. It is not what you are required to do, it is 

what is correct to do for the environment. 

Response: To protect water quality and fish habitat, preventative measures and the use of Best 

Management Practices (BMPs) that would prevent sediments from entering waterways are part 

of the design, construction, and maintenance plans. 

Design elements (including location) incorporated into the project include: 

• Careful selection of the location of new roads to avoid water resources, including 

wetlands, where possible 

• Culverts appropriately sized to meet 100-year flood flows and allow debris and fish 

passage as applicable 

• Crossdrains and waterbars on slopes above waters, spaced appropriately, utilizing 

guidelines in the Washington Forest Practices Act and BPA’s Transmission Engineering 

Standard Access Roads 

• An existing ford is being improved based on the direction provided by the WDFW 

Habitat Biologist 

• Roads will be gated to prevent the wear and tear from the use of unauthorized vehicles, 

unless the use by others makes the use of a locked gate infeasible 
Bonneville Power Administration 8-9 

Measures that will be in place during construction: 

• Sediment and erosion control measures will be in place prior to conducting any clearing, 

grading, or construction 

• Construction will take place during the dry season 

• Temporary rather than permanent approaches will be constructed in wetlands, during the 

dry season to minimize water quality impacts and areas will be restored upon completion 

of construction 

• All permit conditions in the HPA and the 404 permit will determine how and when instream work is conducted

• Roads within the BPA right of way that are used solely by BPA are left in a stable 

condition after construction and the road surface, ditches, cutslopes, and fill slopes are 

seeded and mulched to help ensure the integrity of the road so that it will be usable upon 

the next entrance into the area for maintenance

Regular maintenance practices include: 

• Maintain road on an ongoing basis, conducting major repairs on an as-needed basis 

• When culverts in fish-bearing streams are replaced, they are replaced with a culvert that 

enables fish to pass (For example, in 2002, 4 culverts that blocked fish passage were 

replaced with 3 culverts that allow fish passage (designed to meet state standards, with 

the assistance of the WDFW Area Habitat Biologist) and a bridge that enabled fish to 

pass) 

• Blocked culverts are cleaned out, either immediately or on a schedule, depending on the 

extent of the blockage

________________________________________________ 

Comment 14: BPA must recognize the totality of the impacts it has to the natural resources of 

Washington State, and actively and aggressively implement changes to deal with these problems. 

This could be a proactive change showing that BPA is a true leader in clean power production 

and distribution and will continue to lead with vision and action to protect natural resources. 

Or BPA could ignore the impacts and wait for a boot in the ass that’s big enough to make BPA 

implement change. 

Response: BPA considers the totality of its impacts to natural resources as part of the NEPA 

process, specifically through the process of considering the cumulative impacts to each resource, 

as required by the Council on Environmental Quality regulations. The discussion on cumulative 

impacts for each resource for the Rebuild Project can be found in the appropriate sections in 

Chapter 3 of the EA. 

In addition to obligations to consider cumulative impacts under NEPA, BPA considered its 

impacts to resources under other statutes (Refer to Chapter 4 for a complete listing). As an 

example, BPA complied with both the Endangered Species Act (ESA) and the MagnusonStevens Fishery Conservation and Management Act (MSA) and entered consultation to assess 

impacts under both statutes. Under the ESA, BPA must assess its impacts to listed species (See 

Section 4.2). As part of this assessment, BPA evaluated the direct and indirect effects of the 

proposed activities and consulted with the U.S. Fish and Wildlife Service. BPA also considered 
8-10 Raymond – Cosmopolis Transmission Line Rebuild Project 

the cumulative effects of its activities on listed species. BPA is currently in consultation with 

USFWS with the objective of minimizing the effects to listed species. 

BPA assessed the effects of its activities on Essential Fish Habitat, as required by the MSA. 

BPA has consulted with NOAA Fisheries and accepted recommended conservation measures 

that will be taken to minimize or eliminate the impacts to Essential Fish Habitat (see Section 

4.3.2).

________________________________________________ 

Section 3.6 Water Quality

Comment 19: "A Spill Control and Countermeasure Plan (SPCC) will be developed . . ." (par. 

3.6.3) might be better stated " . . . developed and implemented in accordance with, and for 

approval by [a specified document and agency] . . ." 

Response: As a condition of the Stormwater Pollution Prevention (SWPP) Plan, the SPCC plan 

addresses the requirements of the U.S. Environmental Protection Agency (USEPA) regulations 

specified in Title 40 of the Code of Federal Regulations (CFR). These regulations codified in 40 

CFR Part 112 establish the procedures, methods and equipment to prevent discharge of oil (i.e., 

petroleum products) from non-transportation-related onshore and offshore facilities into or upon 

the navigable waters of the United States or adjoining shorelines. This SPCC plan also meets the 

State of Washington requirements in Washington Administrative Code (WAC) Chapter 173-181, 

which specify the spill response, cleanup, and disposal requirements of oil. For the Spill 

Prevention Containment and Countermeasures (SPCC) portion of the SWPP Plan, materials such 

as fuels, oils, solvents, and chemicals used in operations and maintenance, solid waste products, 

and contaminated soils and water encountered or generated on the construction site will be 

managed so as not to create hazards or pollution prior to, during, and after construction. 

________________________________________________ 

Comment 15: Erosion control measures must be in place prior to any clearing, grading, or 

construction. These control measures must be effective to prevent soil from being carried into 

surface water by stormwater runoff. Sand, silt, and soil will damage aquatic habitat and are 

considered pollutants. 

Response: In advance of any ground disturbing or construction activities at a specific site, 

BPA’s contractor and subcontractors would evaluate and design a site-specific erosion and 

sediment control (ESC) plan for that location and activity, in order to prevent impacts to waters 

of the U.S. They would use the BPA, state, and/or local jurisdiction best management practices 

(BMPs). The ESC Plan would be reviewed by BPA and no work will be done or activity 

conducted within the project site until BPA has agreed to the ESC Plan and the proper BMPs are 

installed. Typical BMPs that may be used during road construction activities may be found in 

the Washington Forest Practices Act Board Manual, in the text in Section 3 (Road Related Best 

Management Practices). 

________________________________________________ 

Comment 15: Any discharge of sediment-laden runoff or other pollutants to waters of the state 

is in violation of Chapter 90.48, Water Pollution Control, and WAC 173-201A, Water Quality 

Standards for Surface Waters of the State of Washington, and is subject to enforcement action. 
Bonneville Power Administration 8-11 

Response: The U.S. Environmental Protection Agency (EPA) and delegated states regulate the 

discharge of stormwater into waters of the United States through the National Pollutant 

Discharge Elimination System (NPDES) permitting program. Under the Storm Water Phase II 

program, all construction activities that result in the disturbance of one or more acres of land are 

being regulated, which would include this project. As part of this program, BPA would receive a 

general NPDES permit, which would regulate stormwater discharges associated with 

construction activities. For Federal facilities in the state of Washington, Federal EPA has 

retained enforcement and permitting authority. 

The General NPDES permit requires permittees to notify the issuing agency of proposed 

construction activities, prepare and implement Stormwater Pollution Prevention (SWPP) plans to 

control stormwater pollution associated with construction activities, and to notify the issuing 

agency once construction ceases and the site has been stabilized. BPA would prepare a SWPP 

Plan to meet the requirements of the EPA General Permit of the NPDES permitting program. 

The EPA General Permit also requires that BPA construction projects comply with state water 

quality standards set by the State in the Washington Administrative Code (WAC) to ensure that 

non-point source pollution does not contaminate the water of the U.S., both during and after 

construction. 

________________________________________________ 

Comment 15: Proper disposal of construction debris must be on land in such a manner that 

debris cannot enter the waterbodies or cause water quality degradation of state waters. 

Response: As a condition of the Stormwater Pollution Prevention (SWPP) Plan, BPA would 

take measures to prevent solid wastes from becoming a source of pollutants to stormwater and to 

prevent decomposition products of construction debris from entering waters of the state. The 

SWPP plan will include Best Management Practices (BMPs) to contain, segregate, store, and 

dispose of solid wastes consistent with state and local statutes and ordinances controlling solid 

waste disposal. Unused excavated material will be deposited and stabilized away from sensitive 

areas and in upland areas, above the 100-year floodplain level. 

________________________________________________ 

Comment 15: Proper erosion and sediment control practices must be used on the construction 

site and adjacent areas to prevent upland sediments from entering the waterbodies. All areas 

disturbed or newly created by construction activities must be revegetated, use bioengineering 

techniques, use clean durable riprap or some other equivalent type of protection against erosion 

when other measures are not practical. 

Response: As a condition of the Stormwater Pollution Prevention (SWPP) Plan, sediment ponds 

and traps, geotextile temporary silt fencing, perimeter dikes, sediment barriers, and other Best 

Management Practices (BMPs) intended to trap sediment on-site would be constructed as a first 

step in grading. These BMPs must be functional before land disturbing activities take place. 

Existing vegetation (trees, bushes, shrubs, grasses) would be preserved when their removal is not 

necessary for the construction of the project. Because most of the existing vegetative cover 

would remain, permanent seeding and planting will be conducted as needed using a native seed 

mix. All temporary conveyance channels and outfalls would be stabilized to prevent erosion and 

reduce sediment transport from the site. Revegetation, erosion blankets, rock, or combinations 
8-12 Raymond – Cosmopolis Transmission Line Rebuild Project 

of these would be used to protect channels from anticipated erosive forces. Rock check dams 

would be installed to permanently reduce erosive forces in the conveyances and capture 

sediment. Erosion would be prevented at all pipe outlets by using revegetation, rock, geotextile 

fabric, erosion control blankets or combinations of these measures. 

________________________________________________ 

Comment 15: During construction, all releases of oils, hydraulic fluids, fuels, other petroleum 

products, paints, solvents, and other deleterious materials must be contained and removed in a 

manner that will prevent their discharge to waters and soils of the state. The clean up of spills 

should take precedence over other work on the site. 

Response: The Spill Prevention Containment and Countermeasures (SPCC) portion of the 

SWPP Plan would include provisions to ensure that materials such as fuels, oils, solvents, 

chemicals used in operations and maintenance, solid waste products, and contaminated soils and 

water encountered or generated on the construction site would be managed so as not to create 

hazards or pollution prior to, during, and after construction 

Provisions in the SPCC would address storage of potential pollutants. They would be stored in a 

manner consistent with the manufacturer’s recommendations, in a secure location, away from 

storm drain inlets, sedimentation/detention ponds and other water bodies. Whenever possible, 

potential pollutants would be stored in a covered area with secondary containment. Incompatible 

chemicals would be stored in separate areas to prevent violent reactions, should a spill occur. 

Provisions in the SPCC would address maintenance and repair. Tanks and equipment containing 

oil, fuel or chemicals would be checked regularly for drips or leaks and maintained to prevent 

spills onto the ground or into State waters. Maintenance and repair of all equipment and vehicles 

would occur on an impervious surface away from all sources of surface water. If the work must 

occur during a rain event, the work would take place undercover. 

Provisions in the SPCC would address refueling. All equipment fueling operations would utilize 

pumps and funnels and absorbent pads. Fueling would not take place within 200 feet of natural 

or manmade drainage conveyances including ditches, catch basins, ponds, wetlands, and pipes. 

All fueling would be restricted to designated fueling areas. 

Spill prevention kits would be provided at designated locations on the project site and at the 

hazardous material storage areas. An emergency spill response contract with a BPA approved 

spill response provider would be established for petroleum product or hazardous/toxic materials 

and in the event of a release of hazardous materials, clean up operations would start immediately. 

________________________________________________ 

Comment 15: Coverage under the General Baseline Stormwater Water Permit is required for 

construction sites greater than five acres. 

Response: The U.S. Environmental Protection Agency (EPA) and delegated states regulate the 

discharge of stormwater into waters of the US through the National Pollutant Discharge 

Elimination System (NPDES) permitting program. As part of this program, General NPDES 

permits will be issued to the Bonneville Power Administration (BPA) to regulate stormwater 
Bonneville Power Administration 8-13 

discharges associated with construction activities. Under Storm Water Phase II, all construction 

activities that result in the disturbance of one or more acres of land are being regulated. For 

Federal Facilities in the state of Washington, Federal EPA has retained enforcement and 

permitting authority. The General NPDES permit requires permittees to notify the issuing 

agency of proposed construction activities, prepare and implement Stormwater Pollution 

Prevention (SWPP) plans to control stormwater pollution associated with construction activities, 

and to notify the issuing agency once construction ceases and the site has been stabilized. BPA 

will prepare this SWPP Plan to meet the requirements of the U.S. EPA General Permit of the 

NPDES permitting program. 

________________________________________________ 

Comment 15: Erosion and sediment control is a key to preserving habitat and preventing 

denudation of a developing area. The following practices are recommended: 

• Clearing limits and/or any easements or required buffers should be staked and flagged in 

the field. 

• A permanent vegetative cover should be established on denuded areas at final grade if 

they are not otherwise permanently stabilized. 

• Properties adjacent to the site of a land disturbance should be protected from sediment 

deposition through the use of buffers or other perimeter controls, such as filter fence or 

sediment basins. 

• Cut and/or fill slopes should be designed to minimize erosion. Methods such as slope 

roughening, terraces, or pipe slope drains may be used. 

• Provisions should be made to minimize the tracking of sediment by construction vehicles 

onto paved public roads. If sediment is deposited, it should be cleaned every day by 

shoveling or sweeping. Water clearing should only be done after area has been shoveled 

out or swept. 

Response:

• As a condition of the Stormwater Pollution Prevention (SWPP) Plan, specific areas that 

need to be avoided, such as wetlands or stream buffers, will be fenced before construction 

in that vicinity begins. Fencing may be orange construction fence or other approved 

material. In some cases, silt fence may be installed to serve two purposes: vegetation 

preservation and prevention of sedimentation. Signs will be posted on fences marking 

wetland and buffer areas to indicate that they are sensitive areas and everyone is to 

remain outside of the fence. All workers will receive training in wetland and buffer 

fencing identification, protocol to follow when the fencing is encountered, and 

notification and reporting if wetland or buffer incursion occurs. Wetlands that are next to 

access roads or work areas will be protected with silt fence if it is determined there is risk 

of sediment inputs into the wetland. Any areas disturbed by construction activities that 

drain to wetlands will be regraded to pre-existing conditions and stabilized with 

vegetation. 

• As a condition of the SWPP Plan, appropriate structural and cover Best Management 

Practices (BMPs) would be used to protect adjacent properties from construction site 

runoff. Properties and waterways downstream from the project will be protected from 

erosion by preventing increases in volume, velocity and peak flow rates. Increases in 

storm water volumes will be minimized by preserving vegetation, by roughened exposed 
8-14 Raymond – Cosmopolis Transmission Line Rebuild Project 

slopes, and by applying mulch. In addition, surface roughening and buffer zones will 

serve to reduce runoff. Disturbed areas would be reseeded with a native seed mix. 

• As a condition of the SWPP Plan, if cut and fill slopes are to be installed, they will be 

constructed in a manner that will minimize erosion. All surface runoff will be routed 

away from exposed soils. Slopes will be left in a roughened condition when at finish 

grade or whenever they will be left unworked for more than 7 days. Final stabilization 

BMPs will be installed within 14 days of slope completion. 

• As a condition of the SWPP Plan, tracking of sediment onto paved roads will be 

minimized by the use of stabilized construction entrances. Wherever construction vehicle 

access routes intersect paved roads, provisions must be made to minimize the transport of 

sediment and mud onto the paved roads. If any sediment were transported onto a paved 

road surface, the road would be cleaned thoroughly at the end of each day. Sediment 

would be removed from roads by shoveling or sweeping and it would then be transported 

to a controlled disposal area. If rock or gravel does not prevent the tracking of sediment, 

a wheel wash system might be installed. If a wheel wash is used, wash water would be 

disposed of according to state of Washington requirements and would not at any time be 

allowed to enter any drainage course flowing to, or discharged to streams, wetlands, 

rivers, or other waters of the state. 

________________________________________________ 

Comment 16: We reviewed the environmental checklist and have one additional comment to the 

letter previously sent on February 20, 2002. Managing roads to protect water quality in the 

short term during construction has been addressed in the NEPA. The steps to address 

environmental impacts listed in the document appear adequate. Long term plans to address 

water quality concerns also needs to be developed as part of the access needs for transmission 

line maintenance. A maintenance plan addressing the maintenance of culverts, bridges, 

streambank stabilization, and other activities associated with road use and maintenance needs to 

be developed. Blocked culverts, scour, and other events will occur that could impact water 

quality and will require attention. (BPA Note: This comment is the WA State Department of 

Ecology SEPA Administrative Coordinator.) 

Response: BPA’s Transmission Field Services Access Road Plan (Plan) is followed as a guide 

to ensure that the Transmission Business Line (TBL) balances reliability and cost when 

conducting activities on access roads while complying with all applicable state, Federal, and 

local environmental regulations. The plan states that: 

• TBL shall maintain access roads on a regular and standardized basis. 

• Standardized maintenance of roads must be done in order to avoid issues such as 

decreased reliability due to restricted access to transmission lines and facilities, unsafe 

conditions to BPA employees, backlogged road workloads, and the risk of fines due to 

environmental violations. 

• The TBL shall comply with the National Environmental Policy Act, Endangered Species 

Act, Clean Water Act, and all other applicable Federal, state, and local environmental 

regulations when conducting activities on access roads. 

The roads along this transmission line are inspected on an annual basis and as part of this 

inspection, problems with culverts, other structures or with the road itself are noted. Problems 

may be fixed immediately, based on the severity of the problem, or put on a list for scheduled 
Bonneville Power Administration 8-15 

maintenance. Problems with roads are also noted and reported to the BPA Region during other 

visits by various BPA personnel to the transmission line for other purposes. 

________________________________________________ 

Section 3.7 Wetlands

Comment 20: I read with interest the preliminary Environmental assessment of the proposed 

Raymond –Cosmopolis transmission line upgrade. My residence is in North Cove. One of the 

many attractive characteristics of the area is its environmental ambience – the cleanliness and 

natural features make it unique among the many places in which I've lived in the United States 

and overseas. I do hope that during the design and construction phases of the upgrade, the 

importance of retaining unsullied the natural characteristics of the area be preserved. This 

includes preserving the wetlands, retaining appropriate wetlands buffers, and disposing of 

construction wastes properly. 

Response: Avoiding and minimizing environmental impacts to the natural environment that you 

and others value has been a major objective of the project team throughout the planning stages of 

the project. Chapter 3 addresses the specific natural resources in the area and explains how 

impacts to the resources were avoided or minimized, and the mitigation that was or will be 

implemented. The commitments BPA is making in the Mitigation Action Plan (Appendix D) 

will ensure that environmental concerns remain an important focus during the implementation of 

this project. 

During the design process, efforts were made to avoid impacts to wetlands and their buffers. 

Two of the realignment areas were specifically created to move the transmission line completely 

out of wetlands, including the highest quality wetland in the project area. These realignment 

areas are located adjacent to Highway 101, which enabled the road engineers to design very short 

access roads in upland areas to reach the proposed structures, all of which would be in uplands. 

In other portions of the transmission line, the line could not be relocated to avoid wetlands. 

Many of the stretches of the transmission line with wetlands are located directly adjacent to the 

Highway. Relocating the transmission line away from the Highway would require clearing a 

new right-of-way and building a new access road system, which would have a much greater 

impact to the environment and would also involve some wetland impacts or additional stream 

crossings. For that reason, relocation was not considered feasible. 

Wetland buffers are discussed in the comment that follows. Proper disposal of construction 

wastes are discussed above in the comments addressing water quality. 

________________________________________________ 

Comment 17: In my quick review of the environmental impacts of the EA, it was not clear how 

you arrived at the wetland impacts. In particular, there was no discussion of buffers to the 

wetlands. As you are aware, adequate and healthy buffers are very important to the function and 

value of a wetland. 

Response: The wetland impact definitions, which define what would constitute a high, medium, 

or low impact to wetlands are located in Appendix A, page A-4. Discussion of wetland buffers 

was not included in the document except in the mitigation section for wetlands (Section 3.7.3). 
8-16 Raymond – Cosmopolis Transmission Line Rebuild Project 

To make it clear that impacts on wetlands buffers was considered a wetland impact that was 

considered during the design process, Table B-11 was added to Appendix B, on page B-13. 

Table B-11 summarizes the distance that proposed structures would be located from wetlands 

and wetlands buffers, in relation to the location of existing structures, as an aid to assess the 

extent of impacts to wetland buffers. 

The location of each proposed structure was analyzed to determine if they could be moved out of 

wetlands, out the wetland buffer, or both. The structural engineer was asked to redesign portions 

of the line several times (known as re-sagging the line) in order to move structures further away 

from wetlands and buffers. 

The location of roads was not analyzed in Table B-11 or in the discussion that follows because 

the further structures are located from wetlands and buffers, the fewer impacts there will be from 

access roads to the structures. Some impacts to wetlands and wetland buffers would result from 

improvements to the existing road system. Improvements to existing roads resulted in fewer 

impacts than constructing new roads because stream crossings would be required in either case. 

Because of engineering constraints, not all structures could be moved completely out of wetlands 

or wetland buffers. Several factors contributed to the difficulty of relocating structures. These 

include the strength of the conductor, strength and height limitations of the structures, 

topography of the area, alignment of the transmission line, width of the right-of-way, and 

accessibility to the structure site. Also, the span length must remain as uniform in length as 

possible for an efficient design. Drastic changes in span lengths, and large angles in the line 

require the use of dead end structures, which are larger than other structures and have a concrete 

foundation. A dead end structure impacts over three times the area of a suspension structure. 

Moving a structure could require a new access or approach road. 

This transmission line has an extremely narrow right-of-way. This narrow right-of-way requires 

the conductor to be strung at a higher than normal initial tension in order to limit the amount of 

sag in the spans. Limiting the sag is necessary to provide adequate ground clearance, and 

prevent the conductor from swinging outside the right-of-way during windy conditions. 

Wetlands are often present in the flat, low-lying areas along the line, where span lengths are 

limited due to the strength of the conductor, as well as the strength and height limitations of the 

structures. Longer spans are possible when conditions allow, such as over canyon crossings, 

where the topography of the land can be taken advantage of to accommodate the additional sag, 

and still meet code requirements for ground clearance without exceeding the strength limitations 

of the conductor and structures. 

BPA is working with Pacific County, as explained in the following comment, to address the 

wetland buffer requirements in their Critical Areas and Resource Lands Ordinance. 

________________________________________________ 

Comment 17: It is not clear what mitigation will be in place for the temporary and permanent 

impacts to the wetlands and riparian areas. 

Response: BPA has submitted a Joint Aquatic Resources Permit Application to the appropriate 

Federal and state agencies and local governments, which details temporary and permanent 
Bonneville Power Administration 8-17 

wetland and waterway impacts and lists conceptual mitigation. A detailed conceptual mitigation 

plan was not submitted with the application because although an applicant can submit a proposed 

mitigation plan, the U.S. Army Corps of Engineers (ACOE) makes the final determination on 

what is appropriate and practicable mitigation. BPA expects to work out the details of 

acceptable mitigation with the ACOE, as part of the permitting process. In addition, WDFW 

conditioned the Hydraulic Project Approval with mitigation measures, which included 

revegetation of disturbed riparian areas with woody species. 

Most of the temporary wetland impacts would occur from installing a temporary road across a 

wetland, immediately adjacent to Highway 101, in order to reach several structures. A 

temporary culvert would be placed in the ditch line at the edge of the field. This wetland is 

regularly mowed during the summer and fall as a large field/yard extension area, and therefore 

the main functions are water storage and recharge and water quality improvement. A road would 

be temporarily constructed by placing rock on geotextile fabric during the summer months. 

Immediately upon completion of construction activities, the culvert would be removed and the 

topsoil removed from the culvert area would be replaced (previously stockpiled) and the site 

would be returned to the original contour. The rock road would be removed and the area would 

be reseeded with native herbaceous species, mainly grasses. The mix would contain both upland 

and wetland species because much of the wetland area is marginal and currently has a mix of 

upland/wetland species. The landowner does not want any woody material introduced to the site 

because he plans to continue to manage the area as a moved field/yard. The functions of the 

wetland may be affected by soil compaction but it is not expected that the area impacted, relative 

to the large size of the wetland, will significantly affect the functioning of this wetland. 

Similar mitigation measures would be in place for the other temporary impacts to wetlands. Two 

short temporary roads (approaches) would be constructed across wetlands to reach the two 

structures that would remain in wetlands, because they could not be moved to an upland site. 

The temporary fill, culvert, and geotextile would be removed and the disturbed areas would be 

revegetated with native species. These areas are currently vegetated mainly with small-fruited 

bull-rush (native species) and reed canarygrass (a non-native species), both or which are 

rhizomatous species that will likely regrow or recolonize the area after the fill is removed. 

Permanent impacts would result from installing two structures in wetlands, road improvements 

that involve two stream crossings (ford and a culvert replacement), and the installation of a 

culvert in a ditch. The area disturbed by the installation of the culvert in the narrow roadside 

ditch would be recontoured and revegetated. The stream crossing areas would be revegetated as 

required in the HPA. All work would be done “in the dry” (which involves diverting the water 

around the stream through a pipe during work), following all conditions within the HPA to 

prevent unnecessary sedimentation. 

The two structures that would be replaced in wetlands would involve an estimated 0.00011 acres 

of fill in Category 4 wetlands, adjacent to Highway 101. Any disturbed area around the 

structures would be revegetated with native species. No further mitigation has been proposed at 

this time for the actual fill area because it is difficult to effectively propose mitigation for such a 

small amount of fill, given that a likely mitigation ratio would be 3 acres of mitigation for each 1 

acre impacted. It may be difficult to design meaningful mitigation for this small an impact. 
8-18 Raymond – Cosmopolis Transmission Line Rebuild Project 

Even using a functional assessment approach to determining impacts (currently the preferred 

approach) it is clear that impacts from the structure installation are minor because these are 

Category 4 wetlands, adjacent to Highway 101, with low species diversity in the vegetative 

cover. 

A Planner from the Pacific County Department of Community Development notified BPA on 

April 24, 2003, that “Based upon my review, it appears that BPA will need to obtain permit 

approvals from Pacific County as several of the proposed transmission line structures will either 

be located within wetlands, or within wetland buffers regulated by Pacific County's Critical 

Areas and Resource Lands Ordinance (as well as several permanent and temporary roadways).” 

BPA is working with Pacific County to determine if mitigation is appropriate.

Trees would be cut along a short stretch of the Joe Creek riparian area in a proposed realignment 

area. Assuming WSDOT, the underlying landowner agrees with WDFW recommendations, the 

trees would be cut as snags and the tops felled across the creek. No woody material would be 

removed within 50 feet of the stream. Machinery would not be allowed within 50 feet of the 

stream. The riparian area would be replanted with native, woody species. 

________________________________________________ 

Comment 17: Wetlands also provide an important function in the flow of a river system. 

Therefore there should be a policy of a no-net-loss and increase in function which would begin 

to address the goal of "long term gain." 

Response: Comment noted. As stated in the National Wetlands Mitigation Action Plan 

(December 24, 2002), the Bush Administration affirmed its commitment to the goal of no net 

loss of the Nation’s wetlands. The Army Corps of Engineers (ACOE) issued a Regulatory 

Guidance letter on December 24, 2002 that stated: 

There may be instances where permit decisions do not meet the “no overall net loss of 

wetlands” goal because compensatory mitigation would be impracticable, or would only 

achieve inconsequential reductions in impacts. Consequently, the “no overall net loss of 

wetlands goal” may not be achieved for each and every permit action, although all 

Districts will strive to achieve this goal on a cumulative basis, and the Corps will achieve 

the goal programmatically. 

BPA will rely on the ACOE, Pacific County, and WA Department of Ecology to determine if 

this permit decision should meet the no net loss objective. 

________________________________________________ 

Comment 17: FOGH (Friends of Grays Harbor) strongly supports assigning a high category 

classification to wetlands that provide hydrologic support to downstream fish bearing streams. 

Response: Comment noted. Wetlands were rated into categories based on the methodology in 

the Washington State Department of Ecology document, Washington State Wetlands Rating 

System for Western Washington. 

________________________________________________ 
Bonneville Power Administration 8-19 

Comment 17: We recommend that any and all mitigation should be placed under control and 

auspices of a nonprofit organization to provide stewardship for that mitigation. We recommend 

that in addition to the transfer of mitigation areas, funds should be supplied to maintain those 

areas. Our further recommendation is that Grays Harbor Audubon Society should be the holder 

of the mitigation properties. They have a significant habitat conservation program in both 

Grays Harbor and Pacific Counties and are already set up to administer the details of such a 

program. 

Response: BPA appreciates the offer by Grays Harbor Audubon to participate in mitigation that 

could occur for this project. As discussed in the comments above, off-site mitigation is not 

currently proposed for this project. If the Army Corps of Engineers (ACOE) requires off-site 

mitigation for the type of impacts that would occur (in-kind mitigation), BPA will look for 

suitable sites and gladly accept suggestions that the ACOE might approve. The appropriate 

group or organization designated to control or possibly even own the mitigation area would need 

to be determined based on the type of mitigation project and the current ownership. For 

example, if mitigation was part of a project being conducted by a local or state government, they 

would likely control and own the mitigation area or be the party to determine the ultimate owners 

and managers of the site. 

________________________________________________ 

Comment 15: We appreciate the efforts made to avoid and minimize impacts to wetlands and 

other aquatic resources. This should greatly increase the efficiency of the permit process. It 

may still be necessary to obtain local shoreline permits and Federal and State permits for 

wetland impacts. We will be happy to work with the applicant as potential impacts are further 

identified to ensure regulatory issues are also clearly identified. (BPA Note: Comment is from 

the WA Department of Ecology)

Response: We appreciate your willingness to assist us with the permit process. BPA is 

currently engaged in the permitting process in the following areas: 

• BPA submitted a JARPA to the Army Corps of Engineers, state agencies, and Pacific and 

Grays Harbor Counties for all permits and approvals required for work in Waters of the 

US and State, which includes wetlands 

• BPA sent information to both Pacific and Grays Harbor County to address their Shoreline 

Management Plans and to WDOE for a Consistency Determination under the Coastal 

Zone Management Act 

• BPA is working with Mr. Craig Zora of the Aquatic Lands Division of the Washington 

State Department of Natural Resources to secure an Aquatic Resources Easement, 

required for the transmission line to cross navigable waters, specifically the North River 

crossing. 

________________________________________________ 

Section 3.11 Socioeconomics

Comment 13: The District has inquired into the cost of placing fiber optic cable on the new 

structures, at which this time the District has funding to hopefully pay for 100% of the cost, even 

though we have never received a cost estimate. This cable would benefit not only the District, 

but BPA for its internal communications. By prolonging the construction, the District may end 
8-20 Raymond – Cosmopolis Transmission Line Rebuild Project 

up losing this funding, which would leave a large gap in upgrading high speed communications 

for Pacific County to the outside world. 

Response: BPA recently provided Pacific County PUD a copy of the cost of the installation of 

the proposed fiber optic cable. We recognize that getting high-speed communications to the 

Raymond area is a pressing need for the community and regret that our funding situation and the 

subsequent delay in the construction start date could lead to the loss of funding for the Pacific 

County PUD to install cable on the proposed transmission line. 

________________________________________________

Comment 11: The Pacific County PUD are concerned they will lose the funding they acquired 

for fiber installation. There are no other options for getting fiber to Raymond at this point (other 

than the Rebuild Project). 

Response: Please see the response to the comment above. 

________________________________________________ 

Comment 11: The Pacific County PUD is interested in Structure 35, if they propose a North 

River Project in the future. Could they still tap into it? They had a 35 megawatt dam proposal 

in the past that would tap into the Raymond – Cosmopolis line at Structure 35. 

Response: In the future, if Pacific County PUD proposes to build the North River Project, they 

will need a way to transmit their power to the market. One way is to connect (tap) into the 

Raymond – Cosmopolis transmission line. In the future, if Pacific County PUD is interested in 

connecting into BPA's transmission network, they will have to apply for an interconnection and 

transmission agreement. BPA will review their facilities capability and determine if they can 

accommodate this request. The Rebuild Project does not currently make allowances for a tap at 

Structure 35. 

________________________________________________ 

Comment 11: Is there fiber to the Cosmopolis Substation? 

Response: Presently, there is no fiber optic cable to the Cosmopolis substation. As part of the 

project proposal, fiber would be installed on the Raymond-Cosmopolis transmission line, and 

therefore would reach Cosmopolis substation. The closest BPA fiber optic cable to the 

Cosmopolis Substation is at Aberdeen Substation, which is about 5 miles away. 

________________________________________________ 

Section 3.12 Cultural Resources

Comment 11: Pacific County Historical Society would like a structure for their new museum 

site to recognize the contributions of the electrical distribution system in the development of the 

area. 

Response: BPA will make a structure available for display at the Pacific County Historical 

Society. This structure will serve as a token of our appreciation for the assistance the Historical 

Society provided in the effort to document the contributions of this transmission line in the 

development of the area, as part of the cultural resources investigation. The details of donating a 

structure such as which structure will be the best example for display, which structure is 
Bonneville Power Administration 8-21 

accessible and can be safely removed from the site, and who will transport it, will be worked out 

with the Director of the Historical Society. 

________________________________________________ 

Section 3.13 Health and Safety

Comment 11: Take the trees out along highway – they are unsafe for drivers, they fall across 

the road. 

Response: When BPA cuts trees near the highway, the trees must meet BPA danger tree 

criteria. Danger trees are trees that could potentially grow, fall, or bend into the lines from the 

area next to the right-of-way. They are chosen for removal based on the tree’s overall condition, 

the ground around it, the tree species, and any other defects that might cause the tree to be 

unstable and therefore more likely to fall into the transmission line. If a tree does not meet BPA 

danger tree criteria, BPA will not remove the tree. The Washington State Department of 

Transportation is the appropriate agency to contact regarding trees that could pose a threat to the 

safety of motorists. 

________________________________________________ 

Comment 12: We (City of South Bend) have no environmental concerns per se, but are 

interested if any and to what extent power outages may be expected. We realize that failure to 

perform this work would create more and more outages through aging failure, but we need to be 

made aware of planned outages well in advance of the fact to ensure that we don't fail in our 

public mission of providing potable water and pumping sewage without spills. 

Response: Electrical service would not be interrupted as a result of the construction of the 

Raymond – Cosmopolis Transmission Line. The Raymond and Cosmopolis Substations each 

receive power from another BPA transmission line supply besides the Raymond – Cosmopolis 

Transmission Line. These other sources will provide power to the local community. There is a 

slight risk to having only one source of power while the Raymond – Cosmopolis Line is out, 

because an outage on the source line would not have the back-up source that normally keeps the 

area from experiencing black-outs. BPA will inform the Pacific County PUD of planned outages 

well in advance. 

________________________________________________ 

Chapter 4 Environmental Consultation, Review, and permit Requirements 

Section 4.5 State, Areawide, and Local Plan and Program Consistency

Comment 18: We want to thank you for providing the Department of Natural Resources (DNR) 

the opportunity to review this project. During this review, several locations were identified 

which indicated that some timber would be harvested during the construction of this project. We 

recommend that you follow the agreement reach between our agencies, as outlined in the letters 

dated March 6, and July 1, 2002, to Mr. Frederick Johnson (copies enclosed) to address our 

forest practices concerns. We will need a letter from your agency prior to the start of 

construction activities that provides assurances to the DNR that you are meeting the intent of the 

enclosed letters. If any locations exist along this project, where you do not meet the forest 

ownership criteria, as outlined in the enclosed letters, you will be required to obtain a forest 

practices application(s) for those locations. 
8-22 Raymond – Cosmopolis Transmission Line Rebuild Project 

Response: BPA will follow the agreement between DNR and BPA, outlined in the letters 

mentioned in your comment, regarding the Forest Practices Act. BPA will provide DNR with 

the information needed to meet the agreement prior to the start of any construction activities, 

which includes any tree removal. 

________________________________________________

Comment 10: Does the transmission line cross any rivers? (BPA Note: this comment was 

from the Aquatic Lands Division of the Washington Department of Natural Resources in relation 

to the need for an Aquatic Resources Easement.) 

Response: As discussed in Chapter 3.6, Water Quality and Appendix B of the EA, the 

Raymond-Cosmopolis transmission line crosses several rivers and larger creeks and parallels 

creeks and rivers in some areas. Some waterways are named as creeks but could just as easily be 

called rivers. The larger creeks and rivers the transmission line crosses are: 

• Butte Creek crosses the line near Raymond between Structures 6 and 7 

• Smith Creek near existing Structure 21 visible from Highway 101 (a bend of the creek 

comes near the line) 

• Smith Creek flows near the line, crossing it between Structures 26 and 27 

• Elkhorn Creek crosses the line near Structure 40 

• Lower Salmon Creek crosses the line near Structure and flows near Structures 72 to 74 

• Joe Creek crosses the line between Structures 90 and 91 

• The North River crosses the line between Structures 120 and 121 

• The Little North River parallels the line near Structures 127 to 138 (sometimes hundreds 

of feet from the transmission line) and crosses between Structures 141 and 142 

BPA is currently working with WA DNR to submit an Aquatic Resources Easement Application 

for the transmission line crossing of the North River under RCW 79.90.450. 
APPENDIX A 

Impact Level Definitions 
Bonneville Power Administration A-1 

Impact Definitions—Land Use (see Section 3.2.2)

There would be a High Impact when project activities result in: 

• Displacement of several residences. 

• Substantial permanent reduction in timber land base (>0.5% of county’s timber land 

base). 

• Permanent interference with recreational activities. 

• Frequent interference with traffic during project operations and maintenance. 

• Impacts cannot be mitigated. 

There would be a Moderate Impact when project activities result in: 

• Frequent interference with residential or recreational use during construction and 

intermittently during operation and maintenance. 

• Moderate reduction in timber land base (0.1 to 0.5% of county’s timber land base). 

• Frequent interference with traffic, generally due to slowing or delays, during 

construction. 

• Impacts may be partially mitigated. 

There would be a Low Impact when project activities result in: 

• Nuisance impacts on residential or recreational use, such as noise and dust associated 

with construction and operation/maintenance (no direct interference). 

• Small reduction in timber land base (<0.1% of county’s timber land base). 

• Infrequent and temporary interference with traffic during construction, operation, and 

maintenance. 

• Impacts may be mostly mitigated. 

There would be No Impact when land use is unaffected. 

Impact Definitions—Geology and Soils (see Section 3.3.2)

There would be a High Impact when: 

• Widespread clearing, grading, excavation, and compaction of soils leads to long-term 

accelerated erosion and increases in stormwater runoff. 

• Erosion occurs through landslides or sloughing of large volumes of material, and slopes 

become severely eroded with multiple gullies carrying sediments into streams and/or 

wetlands. 

• Impacts on soils cannot be mitigated. 

There would be a Moderate Impact when: 

• Limited grading, clearing, excavation, and compaction of soils leads to temporary 

increases in stormwater runoff. 

• Erosion is limited to erosion via shallow channels at a few sites, but most sediment is 

intercepted before reaching streams and wetlands. 

• Impacts can be partially mitigated. 
A-2 Raymond Cosmopolis Transmission Line Rebuild Project EA 

There would be a Low Impact when: 

• Clearing, grading, excavation, and compaction of soils are minimal and lead to little or no 

stormwater runoff. 

• Erosion of slopes is limited to minor sheet erosion and occasional small channels; 

erosion and sedimentation levels would remain near present levels during and following 

construction. 

• Impacts can be substantially mitigated. 

There would be No Impact when there is no clearing, compaction, or other disturbance of soils. 

Impact Definitions—Vegetation (see Section 3.4.2)

There would be a High Impact when:

• Clearing and grading permanently remove large stands of mature or maturing native 

forest. 

• One or more Class A or Class B noxious weeds are introduced from outside of the area 

and become established as a result of the project. 

• One or more populations of Federal species of concern within the project area or statelisted or sensitive species on state-owned lands within the project area suffer losses that 

put at risk the viability of the species. 

• Impacts cannot be mitigated. 

There would be a Moderate Impact when: 

• Native, maturing but not old-growth, forested plant communities are permanently 

removed. 

• One or more Class C noxious weeds are introduced from outside of the area and become 

established as a result of the project. 

• One or more populations of Federal species of concern within the project area or statelisted or sensitive species on state-owned lands within the project area suffer damage that 

do not affect the viability of the species but may put local populations at risk. 

• Impacts can be partially mitigated. 

There would be a Low Impact when: 

• Vegetation is temporarily damaged or cleared but rapid recovery to pre-disturbance 

conditions is likely. 

• Some Class C noxious weeds already established in the vicinity may colonize disturbed 

sites but would not change the character of the pre-disturbance plant community. 

• Any rare plant habitat in the project area is minimally damaged but would recover 

quickly, and no rare plant individuals are harmed. 

• Impacts can be substantially mitigated. 

There would be No Impact when vegetation would remain undisturbed, and no weeds would be 

spread or introduced. 
Bonneville Power Administration A-3 

Impact Definitions—Fish and Wildlife (see Section 3.5.2)

There would be a High Impact when: 

• Project activities cause long-term declines in the quality or quantity of existing fish or 

wildlife habitat within or near the ROW. 

• Fish or wildlife mortality or injury contributes to the need for Federal listing of a species. 

• Project activities cause long-term or continued intermittent destruction of local 

populations of prey species. 

• ESA-listed species are killed, injured, or permanently disturbed. 

• Impacts on fish or wildlife species cannot be mitigated. 

There would be a Moderate Impact when: 

• Project activities cause short-term declines in the quality or quantity of existing fish or 

wildlife habitat within or near the ROW. 

• Fish or animal mortality or injury occurs without causing a risk of endangering the 

population or contributing to the need for Federal listing. 

• Project activities cause short-term destruction of local populations of prey species. 

• An ESA-listed species is indirectly and temporarily disturbed. 

• Impacts on fish or wildlife species can be partially mitigated. 

There would be a Low Impact when: 

• Project activities cause short-term degradation in the quality or quantity of existing fish 

or wildlife habitat located within or near the ROW. 

• Fish or animals suffer temporary disturbance not resulting in injury or death. 

• Project activities indirectly cause short-term reduction of local populations of prey 

species. 

• No ESA-listed species is disturbed. 

• Impacts on fish or wildlife species can be mostly mitigated. 

There would be No Impact when there is no degradation of existing habitat, disturbance, injury, 

or death of any species of fish or wildlife. 

Impact Definitions—Water Quality (see Section 3.6.2)

There would be a High Impact when: 

• A water body that supports fish, wildlife habitat, or human uses would be extensively 

altered, in and beyond the project area, so as to affect its uses or integrity. 

• State or Federal chronic ambient water quality criteria (AWQC) probably would be 

exceeded for weeks or longer in a large portion of the water body. 

• Mitigation could not reduce any impacts. 

There would be a Moderate Impact when: 

• A water body that supports fish, wildlife habitat, or human uses would be altered only 

locally (within the project area) so as to affect its uses or integrity. 

• There is a possible short-term alteration of water quality, such as exceeding Federal or 

state AWQC, that is confined to the local project area. 
A-4 Raymond Cosmopolis Transmission Line Rebuild Project EA 

• Impacts could be partially mitigated. 

There would be a Low Impact when: 

• A water body that supports fish, wildlife habitat, or human uses would be slightly altered 

only locally (part of the project area) so as to affect its uses or integrity. 

• Normal background water quality parameters would be altered without exceeding Federal 

or state AWQC. 

• Impacts could be mostly mitigated. 

There would be No Impact when surface water and groundwater are unaffected by construction 

activities or operation and maintenance of the transmission line. 

Impact Definitions—Wetlands (see Section 3.7.2)

There would be a High Impact when: 

• Disturbance of wetland hydrology, wetland vegetation, or wetland soils is extensive. 

• Wetland functions are permanently lost or impaired beyond recovery. 

• Waterways are permanently rerouted or severely degraded due to the placement of fill in 

stream channels. 

• Mitigation cannot compensate for impacts. 

There would be a Moderate Impact when: 

• Disturbance of wetland hydrology, vegetation, or soils is slight (small portions of 

wetlands are permanently filled) or temporary (as from temporary road fill). 

• Wetland functions would be modestly impaired. 

• Waterways are partially filled due to the installation or replacement of culverts or fords, 

or due to road widening, resulting in a temporary loss of functions or habitat. 

• Recovery of vegetation and wetland functions requires restoration and monitoring, but is 

achieved largely within several years after seeding and planting; or impacts are mitigated 

by off-site mitigation. 

There would be a Low Impact when: 

• Disturbance of wetlands is temporary and affects only small patches of wetland 

vegetation that may be crushed or cut and small areas of wetland soils that may be 

compacted. 

• Wetland functions are temporarily and slightly impaired. 

• Waterway function or habitat is temporarily degraded from adjacent activities but no fill 

material is placed in stream channels. 

• Recovery from impacts occurs naturally, without the need for restoration activities; 

impacts can be mitigated except for brief loss or impairment of some wetland functions. 

There would be No Impact when wetlands or directly adjacent uplands are not altered or 

disturbed, although transmission lines may span or run adjacent to wetlands. 
Bonneville Power Administration A-5 

Impact Definitions—Floodplains (see Section 3.8.2)

There would be a High Impact when: 

• Activities within floodplains result in long-term alteration of floodplain functions, such as 

significantly decreasing flood-storage capacity over a large area in the floodplain or 

altering the course of flood waters.

• Activities adjacent to floodplains result in deposition of a large amount of sediment into 

the floodplain, significantly decreasing flood storage.

• Activities within floodplains result in a significant loss of natural resources, such as longterm or permanent removal of a large area of riparian vegetation or destruction of wildlife 

habitat or off-channel habitat for salmonids. 

• Impacts on floodplains cannot be mitigated. 

There would be a Moderate Impact when: 

• Activities within floodplains result in long-term alteration of floodplain functions but 

only minimally decrease flood-storage capacity within the floodplain and do not alter the 

course of floodwaters. 

• Activities adjacent to floodplains result in the deposition of a small amount of sediment 

into the floodplain, only minimally decreasing flood storage. 

• Activities within floodplains result in minimal loss of natural resources within the 

floodplain, such as short-term losses or long-term or permanent removal of only a small 

area of riparian vegetation, with little destruction of wildlife habitat or off-channel habitat 

for salmonids. 

• Impacts can be partially mitigated. 

There would be a Low Impact when: 

• Activities within floodplains result in short-term, localized alteration of floodplain 

functions but only minimally or temporarily decrease flood-storage capacity and do not 

alter the course of floodwaters. 

• Activities within floodplains result in minimal loss of natural resources, such as shortterm loss of only small areas of riparian vegetation, with little or no destruction of 

wildlife habitat or off-channel habitat for salmonids. 

• Activities adjacent to floodplains result in deposition of incidental amounts of sediment 

into the floodplain, not decreasing flood storage. 

• Impacts can be mostly mitigated. 

There would be No Impact when project activities would not take place in or near floodplains, 

or floodplains are spanned by transmission lines but not otherwise affected. 

Impact Definitions—Visual (see Section 3.9.2)

There would be a High Impact when: 

• A large number of additional people (compared to existing conditions), highly sensitive 

to their surroundings, would see the transmission line in the foreground and middle 

ground on a permanent basis, and the line would dominate views. 

• Scarring and/or erosion from new or improved access roads or clearing would be evident 
A-6 Raymond Cosmopolis Transmission Line Rebuild Project EA 

and potentially severe and/or extensive over a long time period. 

• Views of an officially recognized scenic or recreational resource would be adversely 

affected for a large number of people on a permanent basis. 

• Impacts cannot be mitigated. 

There would be a Moderate Impact when: 

• The line would be visible to large numbers of additional people but it would not be a 

dominant element in the landscape because views would be partially screened, large 

segments of the line would be visible but only for a short time, and/or most views would 

be in the middle or background. 

• Scarring and/or erosion from access roads or clearing would be evident and not severe or 

extensive over a long time period. 

• The line would conflict with prevailing land patterns but be visible to few people or for 

short periods. 

• Impacts may be partially mitigated. 

There would be a Low Impact when: 

• Few additional viewers would see the line because it would be isolated, screened, or seen 

at a distance; existing conditions (transmission lines) have already established impacts. 

• Access road scars and clearing would not substantially detract from the setting. 

• Views would be short-lived and no visually sensitive resource would be affected. 

• Impacts may be mostly mitigated. 

• There would be No Impact when the existing visual setting would not change or the 

project would result in improved visual impacts because the proposed pole structures 

would be more aesthetically appealing than the existing structures. 

Impact Definitions—Air Quality (see Section 3.10.2)

There would be a High Impact when project activities result in: 

• A widespread reduction in air quality that could pose a probable risk to human health and 

safety, and would violate an established air quality standard. 

• Impacts cannot be mitigated. 

There would be a Moderate Impact when project activities result in: 

• A localized reduction in air quality on a temporary basis that could create a possible but 

unlikely risk to human health and safety, and would not violate an air quality standard. 

• Impacts may be partially mitigated. 

There would be a Low Impact when project activities result in: 

• Minor increases in emissions of pollutants would occur on a temporary basis, air quality 

would not be perceptibly affected, effects would be confined to the immediate vicinity of 

the project, and health and safety risks would be unlikely. 

• Impacts may be mostly mitigated. 
Bonneville Power Administration A-7 

There would be No Impact when no increases in emissions of pollutants would occur during 

construction or operation/maintenance. 

Impact Definitions—Socioeconomics (see Section 3.11.2)

A High Impact would result from one or more of the following conditions: 

• Regional reduction of the quality or quantity of social or economic resources. 

• Significant reduction of long-term economic productivity. 

• Consumption of significant amounts of non-renewable resources. 

• Disproportionately high impacts on low-income or minority populations. 

• Impacts could not be mitigated. 

A Moderate Impact would result from one or more of the following conditions: 

• Local reduction of the quality or quantity of social or economic resources. 

• Marginal reduction of long-term economic productivity. 

• Consumption of moderate amounts of non-renewable resources. 

• Potential impacts on minority or low-income populations would be moderate or less or 

would not be disproportionate. 

• Impacts would be mostly mitigated. 

A Low Impact would result from one or more of the following conditions: 

• Reduction of the quality or quantity of social or economic resources within the site of the 

proposed project. 

• Any reduction in economic productivity would be short-term. 

• Consumption of negligible amounts of non-renewable resources. 

• Potential impacts on minority or low-income populations would be unlikely. 

• Impacts would not require mitigation. 

No Impacts would occur when there is no perceptible change in socioeconomic conditions or 

disproportionate impacts on low-income or minority populations. 

Impact Definitions—Cultural Resources (see Section 3.12.2)

There would be a High Impact when: 

• Activities related to the construction, operation, or maintenance of the proposed project 

adversely affect a historic resource eligible for listing in the NRHP by directly or 

indirectly altering any of the characteristics of the resource in a manner that would 

diminish the integrity of the property’s location, design, setting, materials, workmanship, 

feeling, or association and adverse effects cannot be mitigated. 

There would be Moderate to Low impacts when: 

• NRHP-eligible historic resources are adversely affected, but impacts would be reduced 

through avoiding, minimizing, and mitigating for adverse impacts through the Section 

106 process of the NHPA. 

There would be No Adverse Impact when known historic resources would not be affected 

directly or indirectly by construction, operation, or maintenance of the proposed project or; if 
A-8 Raymond Cosmopolis Transmission Line Rebuild Project EA 

present, the project is modified to ensure there would be no adverse effects to cultural resources, 

and the SHPO and any participating THPO agree there would be no adverse effect. 

Impact Definitions—Health and Safety (see Section 3.13.2 and Appendix C)

• A High Impact would occur if the new line poses a significant new health or safety risk, 

or precludes the use of the ROW or nearby areas for pre-existing activities. 

• A Moderate Impact would occur if the new line poses a new health or safety risk, or 

alters pre-existing activities on or near the ROW. 

• A Low Impact would occur if the new line poses a new health or safety risk, but it would 

not produce a change in activities on or near the ROW. 

Impact Definitions—Noise (see Section 3.14.2)

• A High Impact would occur if noise levels from construction or operation of the new 

line exceed existing state standards. 

• A Moderate Impact would occur if residents are present and nuisance noise levels from 

construction or operation of the new line exceed ambient noise levels during a portion of 

the time. 

• A Low Impact would occur if any contribution of the new line on ambient noise levels 

would not be easily perceived by nearby residents. 
APPENDIX B 

Data Tables 
Bonneville Power Administration B-1 

Table B-1: Plants Observed in Project Vicinity 

Common Name Scientific Name Native? Noxious 

Weed Class 

Trees 

Bigleaf maple Acer macrophyllum 9

Cascara 

Frangula purshiana (=Rhamnus 

purshiana) 

9

Douglas-fir Pseudotsuga menziesii 9

Pacific yew Taxus brevifolia 9

Red alder Alnus rubra 9

Sitka spruce Picea sitchensis 9

Western hemlock Tsuga heterophylla 9

Western redcedar Thuja plicata 9

Shrubs

Douglas’ spirea Spiraea douglasii 9

Evergreen blackberry Rubus laciniatus 

Fool’s huckleberry Menziesia ferruginea 9

Himalayan blackberry Rubus discolor 

Indian plum Oemleria cerasiformis 9

Ninebark Physocarpus capitatus 9

Ocean-spray Holodiscus discolor 9

Oregongrape Berberis nervosa 9

Red elderberry Sambucus racemosa 9

Red huckleberry Vaccinium parvifolium 9

Salal Gaultheria shallon 9

Salmonberry Rubus spectabilis 9

Scot’s broom Cytisus scoparius Ba

Sitka willow Salix sitchensis 9

Thimbleberry Rubus parviflorus 9

Trailing or Pacific 

blackberry Rubus ursinus 

9

Vine maple Acer circinatum 9

Willow Salix sp. 9

Herbs

Angled bittercress Cardamine angulata 9

Bentgrasses Agrostis spp. 

Bigroot (wild cucumber) Marah oreganus 9

Boltonia Boltonia asteroides 

Bracken fern Pteridium aquilinum 9

Birdsfoot-trefoil Lotus corniculatus 

Bull thistle Cirsium vulgare C 

Canada thistle Cirsium arvense C 

Cleavers (bedstraw) Galium aparine 9

Columbia brome Bromus vulgaris 9

Common cat-tail Typha latifolia 9

Common horsetail Equisetum arvensis 9
B-2 Raymond Cosmopolis Transmission Line Rebuild Project EA 

Table B-1: Plants Observed in Project Vicinity (cont.) 

Common Name Scientific Name Native? Noxious 

Weed Class 

Herbs (cont.)

Common plantain Plantago major 

Common St. John’s-wort Hypericum perforatum C 

Sow thistle Sonchus oleraceus 

Common tansy Tanacetum vulgare C 

Common velvetgrass Holcus lanatus 

Cooley’s hedgenettle Stachys cooleyae 9

Cow-parsnip Heracleum lanatum 9

Creeping buttercup Ranunculus repens 

Curly dock Rumex crispus 

Deer fern Blechnum spicant 9

Diffuse knapweed Centaurea diffusa Bb

Elk-moss Lycopodium clavatum 9

English Plantain Plantago lanceolata 

False lily-of-the-valley Maianthemum dilatatum 9

Fireweed Epilobium angustifolium 9

Foamflower Tiarella trifoliata 9

Foxglove Digitalis purpurea 

Giant horsetail Equisetum telmateia 9

Hairy cat’s-ear Hypochaeris radicata Ba

Hairy willow-herb Epilobium ciliatum 9

Inside-out flower Vancouveria hexandra 9

Japanese knotweed Polygonum cuspidatum Ba

Kentucky bluegrass Poa pratensis 

Lady fern Athyrium filix-femina 9

Large-leaf avens Geum macrophyllum 9

Mountain sweet-cicely Osmorhiza chilensis 9

Oxeye daisy Leucanthemum vulgare 

(=Chrysanthemum leucanthemum) 

 Ba

Pearly everlasting Anaphalis margaritacea 9

Pig-a-back plant Tolmiea menziesii 9

Pioneer violet Viola glabella 9

Red fescue Festuca rubra 9

Reed canarygrass Phalaris arundinacea C 

Sedges Carex spp. 9

Self-heal Prunella vulgaris 9

Skunk cabbage Lysichiton americanus 9

Slough sedge Carex obnupta 9

Small-fruited bulrush Scirpus microcarpus 9

Smooth hawksbeard Crepis capillaris 

Soft rush Juncus effusus 9

Spreading wood fern Dryopteris expansa 9

Sweet coltsfoot Petasites frigidus 9
Bonneville Power Administration B-3 

Table B-1: Plants Observed in Project Vicinity (cont.) 

Common Name Scientific Name Native? Noxious 

Weed Class 

Herbs (cont.)

Swordfern Polystichum munitum 9

Tansy ragwort Senecio jacobaea Bc

Twinflower Linnaea borealis 9

Vanillaleaf Achlys triphylla 9

Water parsley Oenanthe sarmentosa 9

Western springbeauty Claytonia sibirica 9

White clover Trifolium repens 

White trillium Trillium ovatum 9

Wild carrot Daucus carota Ba

Wood sorrel Oxalis oregana 9

a Class B not designated for control in either Pacific or Grays Harbor County. 

b

 Class B designated for control in both Pacific and Grays Harbor County c

 Class B not designated for control in Pacific or Grays Harbor County but selected for control by Pacific County 

Noxious Weed Control Board. 
B-4 Raymond Cosmopolis Transmission 

Table B-2: Stream Types and Fish Presence in the Project Corridor.

Stream Name

Adjacent 

Structures

DNR 

Stream 

Type*

WDFW 

Modified 

Stream 

Type Anadromous Resident

WDFW 

Priority 

Habitat** Comments

Butte Creek South of 1 1-3 Coho salmon; 

Winter 

steelhead; 

Cutthroat trout

Cutthroat trout

Unnamed Trib. No. 1 4-5 4-5 a Primary trib to Butte Cr

Unnamed Trib. No. 2 5-6 5 Primary trib to Butte CrButte Creek 6-7 1-3 Coho salmonUnnamed Trib. No. 3 7-8 5 Primary trib to Butte CrUnnamed Trib. No. 4 9-10 5 Primary trib to Butte CrUnnamed Trib. No. 5 13-14 4-5 Secondary trib to Smith Cr.Unnamed Trib. No. 6 15-16 5 Secondary trib to Smith Cr.Unnamed Trib. No. 7 22-23 1-3 Cutthroat trout R Primary trib to Smith CrSmith Creek 26-27 1-3 Chinook 

salmon, Chum salmon; Coho 

salmon; 

Cutthroat trout 

Cutthroat trout AR

Unnamed Trib. No. 8 28-29 5 Primary trib to Smith CrUnnamed Channel No. 1 32-33 4Unnamed Channel No. 2 35A 5Unnamed Channel No. 3 35-36 5Elk Horn Creek 40-41 1-3 Chinook 

salmon; Coho 

salmon; 

Cutthroat trout 

Cutthroat trout AR

Unnamed Trib. No. 9 42-43 1-3 Cutthroat trout Primary trib to Elk Horn CrUnnamed Trib. 10 43-44 1-3 a Unknown Unknown Primary trib. to Elk Horn Cr.

Unnamed Trib. No. 11 50-51 4 1-3 Cutthroat trout Secondary trib to Elk Horn CUnnamed Trib. No. 12 52-53 4 1-3 Cutthroat trout Secondary trib to Elk Horn CUnnamed Trib. No. 13 56-57 5 Secondary trib to Elk Horn CUnnamed Trib. No. 14 56-57 5 Secondary trib to Elk Horn CUnnamed Trib. No. 15 62-63 4 1-3 Cutthroat trout Primary trib to Lower Salmon Unnamed Trib. No. 16 65-66 5 Primary trib to Lower Salmon Unnamed Trib. No. 17 65-66 1-3 Cutthroat trout Primary trib to Lower Salmon 

Known Fish Presence†
Bonneville Power Administration 

Lower Salmon Creek 65-66 1-3 Chinook 

salmon, Chum salmon; Coho 

salmon; 

Cutthroat trout 

Cutthroat trout AR

Unnamed Trib. No. 18 67A-68A 1-3 Cutthroat trout Primary trib to Lower 

Unnamed Trib. No. 19 72-73 1-3 Coho salmon Cutthroat trout R Primary trib to Lower Lower Salmon Creek 73-74 1-3 Chinook 

salmon; Chum 

salmon; Coho; 

Winter 

Steelhead; 

Cutthroat trout

Cutthroat trout AR

Unnamed Trib. No. 20 75-76 5 Primary trib to Lower Unnamed Trib. No. 21 79-80 5 Secondary trib to LowUnnamed Trib. No. 22 80-81 1-3 Coho salmon Primary trib to Lower 

Unnamed Trib. No. 23 82-83 5 Primary trib to Lower Unnamed Trib. No. 24 84-85 5 1-3 Cutthroat trout Secondary trib to Joe 

Unnamed Trib. No. 25 85-86 5 1-3 Cutthroat trout Secondary trib to Joe 

Unnamed Trib. No. 26 86-87 4 1-3 Cutthroat trout Primary trib to Joe Cr

Unnamed Trib. No. 27 87-88 1-3/5 Primary trib to Joe CrUnnamed Trib. 28 88-89 4-5 a

Joe Creek 90-91 1-3 Coho salmon; 

Cutthroat trout

Cutthroat trout AR

Unnamed Trib. No. 29 91-92 1-3 Coho salmon Primary trib to Joe Cr

Unnamed Trib. No. 30 93-94 1-3 Primary trib to Joe CrUnnamed Trib. No. 31 93-94 5 Secondary trib to Joe Unnamed Trib. No. 32 95-96 5 1-3 Cutthroat trout Secondary trib to Joe 

Unnamed Trib. No. 33 97-98 1-3 Cutthroat trout Secondary trib to Joe 

Unnamed Trib. No. 34 100-101 5 Secondary trib to Joe Unnamed Trib. No. 35 102-103 5 Secondary trib to Joe Unnamed Trib. No. 36 110-111 1-3 Salmonids Secondary trib to NorUnnamed Trib. No. 37 111-112 4 Secondary trib to NorUnnamed Trib. No. 38 115-116 5 Secondary trib to Nor
B-6 Raymond Cosmopolis Transmission 

North River 120-121 1-3 Chinook 

salmon; Chum 

salmon; Coho; 

Winter 

Steelhead; 

Cutthroat trout

Cutthroat trout AR

Unnamed Trib. No. 39 123-124 1-3 Coho salmon Salmonids Primary trib to Littl

Unnamed Trib. No. 40 127-128 4 1-3 Cutthroat trout Primary trib to Littl

Unnamed Trib. No. 41 129-130 5 Primary trib to LittlUnnamed Trib. No. 42 131-132 1-3 Cutthroat trout Primary trib to Littl

Unnamed Trib. No. 43 133-134 1-3 Coho salmon Cutthroat trout AR Primary trib to LittlUnnamed Trib. No. 44 136-137 4 Primary trib to LittlUnnamed Trib. No. 45 137-138 5 Primary trib to LittlUnnamed Trib. No. 46 141-142 1-3 Coho salmon Cutthroat trout R Primary trib to LittlLittle North River 141-142 1-3 Coho salmon; 

Cutthroat trout 

Cutthroat trout; 

sculpin; lamprey

AR

Unnamed Trib. No. 47 147-148 5 Secondary to Brick Unnamed Trib. No. 48 149-150 5 Secondary to Brick Unnamed Trib. No. 49 155-156 5 Primary trib to Mill Unnamed Channel No. 4 163-164 5Unnamed Channel No. 5 164-165 5Unnamed Channel No. 6 167-168 5* DNR Stream Typing: 1-3 are fish-bearing streams

4 is perennial non-fish-bearing5 is intermittent non-fish-bearing

** A = Priority Anadromous Fish R = Priority Resident Fish

† = Data Sources: Washington State Natural Heritage Database; Washington State Priority Habitats and Species Database; 

 Williams et al., 1975; and WDFW electroshocking and stream-typing data

a Based on field survey data for essential fish habitat
Bonneville Power Administration B-7 

Table B-3: Fish and Wildlife Potentially Occurring in the Project Corridor (WDFW 2002c).

Common Name Scientific Name State Federal

Mammals

Beaver Castor canadensis

Bendire's Shrew Sorex bendirii

Big Brown Bat Eptesicus fuscus

Black Bear Ursus americanus

Bobcat Lynx rufus

Bushy-tailed Woodrat Neotoma cinerea

California Myotis Myotis californicus

Coast Mole Scapanus orarius

Coyote Canis latrans

Creeping Vole Microtus oregoni

Deer Mouse Peromyscus maniculatus

Douglas' Squirrel Tamiasciurus douglasii

Elk Cervus elaphus

Ermine Mustela erminea

Fisher Martes pennanti Endangered Species of Concern*

Forest Deer Mouse Peromyscus keeni

Gapper's Red-backed Vole Clethrionomys gapperi

Hoary Bat Lasiurus cinereus

House Mouse Mus musculus

Little Brown Myotis Myotis lucifugus

Long-eared Myotis Myotis evotis

Long-legged Myotis Myotis volans

Long-tailed Vole Microtus longicaudus

Mink Mustela vison

Montane Shrew Sorex monticolus

Mountain Beaver Aplodontia rufa

Mountain Lion Felis concolor

Mule Deer Odocoileus hemionus

Muskrat Ondatra zibethicus

Northern Flying Squirrel Glaucomys sabrinus

Norway Rat Rattus norvegicus

Opossum Didelphis virginiana

Pacific Jumping Mouse Zapus trinotatus

Porcupine Erethizon dorsatum

Raccoon Procyon lotor

Red Fox Vulpes vulpes

River Otter Lutra canadensis

Shrew-mole Neurotrichus gibbsii

Silver-haired Bat Lasionycteris noctivagans

Snowshoe Hare Lepus americanus

Spotted Skunk Spilogale gracilis

Striped Skunk Mephitis mephitis

Townsend's Big-eared Bat Plecotus townsendii Candidate

Townsend's Chipmunk Tamias townsendii

Townsend's Mole Scapanus townsendii

Trowbridge's Shrew Sorex trowbridgii

Vagrant Shrew Sorex vagrans

Yuma Myotis Myotis yumanensis

Listing Status
B-8 Raymond Cosmopolis Transmission Line Rebuild Project EA 

Birds

American Goldfinch Carduelis tristis

American Robin Turdus migratorius

American/Northwestern Crow Corvus brachyrhynchos/caurinus

Bald Eagle Haliaeetus leucocephalus Threatened Threatened

Band-tailed Pigeon Columba fasciata

Barn Owl Tyto alba

Barn Swallow Hirundo rustica

Barred Owl Strix varia

Bewick's Wren Thryomanes bewickii

Black-capped Chickadee Parus atricapillus

Black-headed Grosbeak Pheucticus melanocephalus

Black-throated Gray Warbler Dendroica nigrescens

Blue Grouse Dendragapus obscurus

Brown Creeper Certhia americana

Brown-headed Cowbird Molothrus ater

Bushtit Psaltriparus minimus

Cedar Waxwing Bombycilla cedrorum

Chestnut-backed Chickadee Parus rufescens

Cliff Swallow Hirundo pyrrhonota

Common Loon Gavia immer Sensitive

Common Nighthawk Chordeiles minor

Common Raven Corvus corax

Common Yellowthroat Geothlypis trichas

Dark-eyed Junco Junco hyemalis

Downy Woodpecker Picoides pubescens

Evening Grosbeak Coccothraustes vespertinus

Golden-crowned Kinglet Regulus satrapa

Gray Jay Perisoreus canadensis

Great Horned Owl Bubo virginianus

Hairy Woodpecker Picoides villosus

Hutton's Vireo Vireo huttoni

Killdeer Charadrius vociferus

Marbled Murrelet Brachyramphus marmoratus Threatened Threatened

Northern Flicker Colaptes auratus

Northern Pygmy-Owl Glaucidium gnoma

Northern Saw-whet Owl Aegolius acadicus

Northern Spotted Owl Strix occidentalis caurina Endangered Threatened

Olive-sided Flycatcher Contopus borealis

Orange-crowned Warbler Vermivora celata

Pacific-slope/Cordilleran Flycatcher Empidonax difficilis/occidentalis

Pileated Woodpecker Dryocopus pileatus Candidate

Pine Siskin Carduelis pinus

Purple Finch Carpodacus purpureus

Red Crossbill Loxia curvirostra

Red-breasted Sapsucker Sphyrapicus ruber

Red-tailed Hawk Buteo jamaicensis

Red-winged Blackbird Agelaius phoeniceus

Rock Dove Columba livia

Ruffed Grouse Bonasa umbellus

Rufous Hummingbird Selasphorus rufus

Song Sparrow Melospiza melodia

Spotted Towhee Pipilo maculatus

Swainson's Thrush Catharus ustulatus

Tree Swallow Tachycineta bicolor

Turkey Vulture Cathartes aura

Varied Thrush Ixoreus naevius

Vaux's Swift Chaetura vauxi Candidate

Violet-green Swallow Tachycineta thalassina

Warbling Vireo Vireo gilvus

Western Screech-Owl Otus kennicottii

Western Tanager Piranga ludoviciana

White-crowned Sparrow Zonotrichia leucophrys

Wilson's Warbler Wilsonia pusilla

Winter Wren Troglodytes troglodytes

Wood Duck Aix sponsa
Bonneville Power Administration B-9 

Reptile and Amphibians

Bullfrog Rana catesbeiana

Columbia Torrent Salamander Rhyacotriton kezeri Candidate

Common Garter Snake Thamnophis sirtalis Species of Concern*

Cope's Giant Salamander Dicamptodon copei

Dunn's Salamander Plethodon dunni Candidate

Ensatina Ensatina eschscholtzii

Long-toed Salamander Ambystoma macrodactylum

Northwestern Salamander Ambystoma gracile

Pacific Giant Salamander Dicamptodon tenebrosus

Pacific Treefrog Hyla regilla

Red-legged Frog Rana aurora

Roughskin Newt Taricha granulosa

Tailed Frog Ascaphus truei

Western Redback Salamander Plethodon vehiculum

Western Toad Bufo boreas Candidate

Fish

Bull trout Salvelinus confluentus Candidate Threatened

Chinook salmon Oncorhynchus tshawytscha

Chum salmon Oncorhynchus keta

Coho salmon Oncorhynchus kisutch Candidate

Coastal resident/searun cutthroat trout Oncorhynchus clarki clarki

Pacific lamprey Entosphenus tridentatus Species of Concern*

River Lamprey Lampetra ayresi Candidate Species of Concern*

Sculpin Cottus sp.

Steelhead trout Oncorhynchus mykiss

*Species of Concern is an informal federal status that has no regulatory standing or implications.

Table B-4: Population Trends for Grays Harbor and Pacific Counties, 

1980-2002 

County 1980 1990 2000 2002

Grays Harbor County 66,314 64,175 67,194 68,400

Pacific County 17,237 18,882 20,984 21,000

Total, Two Counties 83,551 83,057 88,178 89,400

 Percent Change na -0.6% 6.2% 1.4%

 Percent of Total State Population 2.0% 1.7% 1.5% 1.5%

State of Washington 4,132,353 4,866,659 5,894,121 6,041,700

 Percent Change na 17.8% 21.1% 2.5%

Note: na is “not applicable.” 

Sources: U.S. Bureau of Census; Washington State Office of Financial Management 
B-10 Raymond Cosmopolis Transmission Line Rebuild Project EA 

Table B-5: Full and Part-time Employment in Grays Harbor and 

Pacific Counties, 2000 

Sector 

Grays

Harbor Pacific

Two-County 

Total 

Washington

State

Total full-time and part-time employment 32,520 9,544 42,064 3,560,164

Wage and salary employment 25,580 6,721 32,301 2,938,765

Proprietors' employment 6,940 2,823 9,763 621,399

Farm proprietors' employment 500 317 817 38,711

Nonfarm proprietors' employment 2/ 6,440 2,506 8,946 582,688

Farm employment 604 363 967 79,886

Nonfarm employment 31,916 9,181 41,097 3,480,278

Private employment 26,653 7,309 33,962 2,933,709

Ag. services, forestry, fishing, & other 3/ 1,224 961 2,185 64,508

Mining 84 41 125 5,664

Construction 1,790 388 2,178 216,748

Manufacturing 4,809 1,059 5,868 371,436

Transportation and public utilities 1,210 178 1,388 167,892

Wholesale trade 781 67 848 168,912

Retail trade 6,063 1,624 7,687 594,402

Finance, insurance, and real estate 2,079 607 2,686 272,353

Services 8,613 2,384 10,997 1,071,794

Government and government enterprises 5,263 1,872 7,135 546,569

Federal, civilian 248 75 323 69,151

Military 293 162 455 72,831

State and local 4,722 1,635 6,357 404,587

State 1,000 311 1,311 132,128

Local 3,722 1,324 5,046 272,459

Source: U.S. Bureau of Economic Analysis, Regional Economic Information System. 

Table B-6: Wage and Salary Employment in Grays Harbor and 

Pacific Counties, 2000 

Sector 

Grays Harbor 

County

Pacific

County

Two-county 

Region Total 

Washington

State

Agriculture, forestry & fishing 534 396 930 91,530

Construction & mining 1,162 228 1,390 152,790

Manufacturing 4,267 900 5,167 345,830

Transportation & public utilities 795 83 878 139,684

Wholesale trade 611 35 646 150,196

Retail trade 4,780 1,176 5,956 483,740

Finance, insurance & real estate 1,015 192 1,207 133,937

Services 5,622 1,375 6,997 747,048

Government 4,875 1,685 6,560 458,482

Total 23,661 6,070 29,731 2,703,237

Source: Washington State Employment Security Department, Labor Market & Economic Analysis Branch. 
Bonneville Power Administration B-11 

Table B-7: Income Characteristics in Grays Harbor and Pacific Counties 

County/State 1980 1990 2000

Grays Harbor County 

 Total personal income ($000) $1,308,179 $1,408,531 $1,471,312

 Net earnings ($000) $910,648 $843,856 $852,682

 Dividends, interest & rent ($000) $212,758 $274,679 $272,156

 Transfer payments ($000) $184,773 $289,996 $346,474

 Per capita income ($) $19,690 $21,873 $21,908

Pacific County 

 Total personal income ($000) $324,050 $390,994 $440,091

 Net earnings ($000) $195,608 $196,437 $212,166

 Dividends, interest & rent ($000) $69,815 $100,034 $108,981

 Transfer payments ($000) $58,627 $94,523 $118,944

 Per capita income ($) $18,676 $20,621 $21,042

Two-county Region 

 Total personal income ($000) $1,632,228 $1,799,525 $1,911,403

 Net earnings ($000) $1,106,255 $1,040,293 $1,064,848

 Dividends, interest & rent ($000) $282,572 $374,713 $381,137

 Transfer payments ($000) $243,401 $384,519 $465,418

 Per capita income ($) $19,480 $21,588 $21,702

Washington State 

 Total personal income ($000) $88,377,791 $136,513,481 $184,517,693

 Net earnings ($000) $64,270,728 $93,207,248 $129,712,222

 Dividends, interest & rent ($000) $14,577,114 $27,193,915 $33,121,758

 Transfer payments ($000) $9,529,950 $16,112,319 $21,683,713

 Per capita income ($) $21,273 $27,843 $31,230
B-12 Raymond Cosmopolis Transmission Line Rebuild Project EA 

Table B-8: Race Distribution in the Two-County Region and 

Washington State, 2000 

Grays Harbor County Pacific County 

Race Number Percent Number Percent 

One Race 65,111 96.9% 20,392 97.2% 

 White 59,335 88.3% 18,998 90.5% 

 Black or African American 226 0.3% 42 0.2% 

 American Indian or Alaska Native 3,132 4.7% 513 2.4% 

 Asian 818 1.2% 436 2.1% 

 Hawaiian & Other Pacific Islander 73 0.1% 19 0.1% 

 Some other race 1,527 2.3% 384 1.8% 

Two or more Races 2,083 3.1% 592 2.8% 

Hispanic Origin (of any race) 3,258 4.8% 1,052 5.0% 

Total 67,194 100.0% 20,984 100.0% 

 Two-County Region Washington State 

Race Number Percent Number Percent 

One Race 85,503 97.0% 5,680,602 96.4% 

 White 78,333 88.8% 4,821,823 81.8% 

 Black or African American 268 0.3% 190,267 3.2% 

 American Indian or Alaska Native 3,645 4.1% 93,301 1.6% 

 Asian 1,254 1.4% 322,335 5.5% 

 Hawaiian & Other Pacific Islander 92 0.1% 23,953 0.4% 

 Some other race 1,911 2.2% 228,923 3.9% 

Two or more Races 2,675 3.0% 213,519 3.6% 

Hispanic Origin (of any race) 4,310 4.9% 441,509 7.5% 

Total 88,178 100.0% 5,894,121 100.0% 

Note: Some other race, refers to a “write-in” category in which respondents listed multi-racial, mixed, interracial, 

Hispanic or Latino. The Census Bureau estimates that 97 percent of respondents who reported as “Some other race” 

were Hispanic or Latino. 

Source: U.S. Census Bureau. 

Table B-9: Median Household Incomes of Study Area and Washington 

State, 2001 

Geographic Area 

2001 Median 

Household Income 

Percent of 

Median 

Grays Harbor County $36,761 75.82% 

Pacific County $33,999 70.13% 

Two-County region $36,468 75.22% 

Washington State $48,482 100.00% 

Source: Washington State Office of Financial Management. 2001 Population Trends for Washington State. 
Bonneville Power Administration B-13 

Table B-10: Construction Noise in the Vicinity 

of a Representative Construction Site 

Distance from 

Construction Site (feet) 

Hourly Leq 

(dBA) 

50 89 

100 83 

200 77 

400 71 

800 65 

1600 59 

Note: The following assumptions were used: 

Equipment used: (1) each- grader, bulldozer, heavy truck, backhoe, Pneumatic tools, concrete pump, crane 

Reference noise level: 89 dBA (Leq) 

Distance for the reference noise level: 50 feet 

Noise attenuation rate: 6 dBA/doubling of distance 

This calculation does not include the effects, if any, of local shielding or atmospheric attenuation. 

Table B-11. Proposed Structure Locations in Relation to Wetlands and 

Wetland Buffers 

Number of 

Structures 

Wetland Classification Category 

and Buffer Width 

Effect of Existing and Proposed 

Structures on Wetlands and 

Wetland Buffers 

PACIFIC 

COUNTY: 

Pacific County Wetland Buffer Widths:

Category 3 wetland – 50 foot buffer 

Category 4 wetland – 25 foot buffer

2 Category 3 and 4 Existing and proposed structures inside 

buffer; one structure is between wetlands 

and the proposed structure would be closer 

to one wetland as it becomes further from 

another, another structure was moved to the 

outer edge of the buffer 

1 Category 4 Existing structure in wetland would 

remain in wetland because the wetland is a 

long, linear wetland with a boundary 65 feet 

south of the structure and it extends several 

hundred feet north of the structure 

1 Category 4 Existing structures in wetland, proposed 

structures would be within wetland 

buffer 

2 Category 4 Existing structure within wetland, 

proposed structure would be moved 

outside wetland buffer 
B-14 Raymond Cosmopolis Transmission Line Rebuild Project EA 

Number of 

Structures 

Wetland Classification Category 

and Buffer Width 

Effect of Existing and Proposed 

Structures on Wetlands and 

Wetland Buffers 

GRAYS 

HARBOR 

COUNTY: 

WA Department of Ecology 

Recommended Wetland Buffer Widths: 

Category 2 wetland – 100 to 200 foot buffer

Category 3 wetland – 50 to 100 foot buffer 

Category 4 wetland – 25 to 50 foot buffer

2 Category 2 Existing structure within wetland, 

proposed structures would be moved 

outside wetland buffer (realignment area 

to avoid wetland impacts) 

1 Category 3 Existing and proposed structure inside 

buffer; structure is between two wetlands 

2 Category 3 Existing structures in wetland, proposed 

structures would be within the wetland 

buffer 

12 Category 3 and Category 4 Existing and proposed structures outside 

buffer 

1 Category 4 Existing structure in wetland would 

remain in wetland because the wetland is a 

long, linear wetland with a boundary 100 

feet south of the structure and it extends 

several hundred feet north of the structure; 

the structures could not be moved outside 

the wetland. 

4 Category 4 Existing and proposed structures within 

buffer, but proposed structures moved 

further away from wetland 

2 Category 4 Existing structures within or on edge of 

buffer, proposed structures would be 

outside buffer 
APPENDIX C 

Health and Safety Technical Report
Bonneville Power Administration C-1 

HEALTH AND SAFETY TECHNICAL REPORT 

Prepared for Bonneville Power Administration 

By Dan Bracken 
C-2 Raymond Cosmopolis Transmission Line Rebuild Project EA 

TABLE OF CONTENTS 

Affected Environment..................................................................................................................... 3 

Environmental Consequences of the Proposed Action................................................................... 4 

Potential Impacts During Construction....................................................................................... 4 

Potential Impacts During Operation and Maintenance............................................................... 4 

Electrical Safety...................................................................................................................... 4 

Short-term Effects – Electric Fields........................................................................................ 5 

Short-term Effects - Magnetic Fields..................................................................................... 5 

Long-term Health Effects ....................................................................................................... 5 

Electric and Magnetic Field Levels ........................................................................................ 6 

Toxic and Hazardous Substances............................................................................................ 7 

LIST OF TABLE AND FIGURES 

Table 1 Typical Magnetic Field Strengths................................................................................. 4 

Figure 1 Maximum electric field at 3.28 ft. height from proposed and 

existing Raymond – Cosmopolis 115-kV transmission lines. ...................................... 7 

Figure 2 Maximum magnetic field at 3.28 ft. height from proposed and 

existing Raymond – Cosmopolis 115-kV transmission line......................................... 8 
Bonneville Power Administration C-3 

HEALTH AND SAFETY TECHNICAL REPORT 

Affected Environment 

Transmission facilities provide electricity for heating, lighting, and other services essential for 

public health and safety. These same facilities can potentially harm humans. Contact with 

transmission lines or any electrical line can kill or seriously injure people. Transmission 

structures and conductors can present an obstruction for aircraft. This technical report describes 

public health and safety concerns such as electrical shocks, fires, aircraft obstruction warnings, 

the effects of electric and magnetic fields related to transmission facilities, and construction 

activities. 

The Federal Aviation Administration (FAA) establishes requirements for towers and other tall 

structures that would potentially interfere with aircraft safety. Structures taller than 200 feet may 

require flashing warning lights for aircraft safety. BPA submits the final locations of structures 

and structure heights to FAA for their review and recommendations on airway marking and 

lighting. 

Transmission lines, like all electric devices and equipment, produce electric and magnetic fields 

(EMF). Voltage, the force that drives the current, is the source of the electric field. Current, the 

flow of electric charge in a wire, produces the magnetic field. The strength of electric and 

magnetic fields depends on the design of the line and on distance from the line. Field strength 

decreases rapidly with distance. 

Electric and magnetic fields are found around any electrical wiring, including household wiring 

and electrical appliances and equipment. Electric fields are measured in units of volts per meter 

(V/m) or kilovolts per meter (thousands of volts per meter, kV/m). Throughout a home, the 

electric field strength from wiring and appliances is typically less than 0.01 kV/m. However, 

fields of 0.1 kV/m and higher can be found very close to electrical appliances. 

There are no Federal guidelines or standards for electric fields from transmission lines. 

Washington has no electric-field limit. BPA designs new transmission lines to meet its electricfield guideline of 9-kV/m maximum on the ROW and 5-kV/m maximum at the edge of the 

ROW. The National Electric Safety Code (NESC) specifies that the maximum permissible 

induced shock current from large vehicles under transmission lines with voltages above 170 kV 

cannot exceed 5 milliamperes (mA). This portion of the NESC does not apply to the proposed 

115-kV line. Both the BPA guideline and the NESC induced current requirement are important 

for 500-kV lines. The proposed 115-kV line would have much lower fields than a 500-kV line 

and would easily meet all these requirements. 

Magnetic fields are measured in units of gauss (G) or milligauss (thousandths of a gauss, mG). 

Average magnetic field strength in most homes (away from electrical appliances and home 

wiring, etc.) is less than 2 mG. Fields of tens or hundreds of milligauss are present very close to 

appliances carrying high current. Typical magnetic field strengths for some common electrical 

appliances are given in Table 1. Unlike electric fields, magnetic fields from outside power lines 

are not reduced in strength by trees or building material. Transmission lines and distribution 

lines (the lines feeding a neighborhood or home) can be a major source of magnetic field 

exposure throughout a home located close to the line. 
C-4 Raymond Cosmopolis Transmission Line Rebuild Project EA 

There are no Federal guidelines or standards for magnetic fields. Washington does not have 

magnetic field limits. BPA does not have a guideline for magnetic field exposures. Guidelines 

for public and occupational magnetic-field exposures are well above environmental levels and 

above the levels found near transmission lines. These guidelines are based on short-term 

stimulation, not effects of long-term exposures. 

Table 1: Typical Magnetic Field Strengths 

(1 foot from common appliances) 

Appliance Magnetic Fields (mG)1

Coffee maker 1-1.5 

Electric range 4-40 

Hair dryer 0.1-70 

Television 0.4-20 

Vacuum cleaner 20-200 

Electric blanket2 15-100 

mG = milligauss 1

 The magnetic field from appliances usually decreases to less 

than 1 mG at 3 to 5 feet from appliances. 2

 Values are for distance from blanket in normal use (less than 

1 foot away). 

Source: Miller 1974; Gauger 1985 

Environmental Consequences of the Proposed Action 

Potential health and safety impacts associated with the project include those that could affect 

construction workers, operation and maintenance personnel, the public, and others who have 

occasion to enter the project corridor. 

Potential Impacts

Potential Impacts During Construction 

During construction and installation of the structures and conductor/ground wires, there is a risk 

of fire and injury associated with the use of heavy equipment, hazardous materials such as fuels, 

cranes, helicopters, and other activities associated with working near high-voltage lines. There is 

also a potential for fire during refueling of hot equipment such as trackhoes and bulldozers that 

cannot be taken off site for refueling. Connection of conductors may be accomplished using 

implosion fittings, which could be a source of injury to construction personnel. In addition, there 

are potential safety issues with more traffic on the highways and roads in the project area during 

construction. Standard construction safety procedures would make the risk of injury very low. 

Potential Impacts During Operation and Maintenance 

Electrical Safety 

Power lines, like electrical wiring, can cause serious electric shocks if certain precautions are not 

taken. These precautions include building the lines to minimize shock hazard. All BPA lines are 

designed and constructed in accordance with the NESC and BPA practices. The NESC specifies 

the minimum allowable distance between the lines and the ground or other objects. These 
Bonneville Power Administration C-5 

requirements determine the edge of the ROW and the height of the line; i.e., the closest point 

houses, other buildings, and vehicles are allowed to the line. 

People must take precautions when working or playing near power lines. It is extremely 

important that a person not bring anything, such as a TV antenna, irrigation pipe, or water 

streams from an irrigation sprinkler too close to the lines. BPA provides a free booklet that 

describes safety precautions for people who line or work near transmission lines (Living and 

Working Safely Around High Voltage Power Lines). Given that the new line would be higher 

than the existing line, impacts related to electrical safety would be reduced relative to the 

existing line.

Short-term Effects – Electric Fields 

Electric fields from high-voltage transmission lines can cause nuisance shocks when a grounded 

person touches an ungrounded object under a line or when an ungrounded person touches a 

grounded object. Transmission lines are designed so that the electric field would be below levels 

where primary shocks could occur from even the largest (ungrounded) vehicles expected under 

the line. Fences and other metal structures on and near the ROW would be grounded during 

construction to limit the potential for nuisance shocks. Questions about grounding or reports of 

nuisance shock received under a line should be directed to BPA. Electric fields from the 

proposed line would be much lower than those from 230-kV and 500-kV lines. The proposed 

line would easily meet the BPA electric-field guidelines of 9 kV/m on the ROW and 5 kV/m at 

the edge of the ROW. Therefore, it is highly unlikely that the above-mentioned effects would be 

perceived under the line. 

Short-term Effects - Magnetic Fields 

Magnetic fields from transmission lines can induce currents and voltages on long conducting 

objects parallel to the lines. These voltages can also serve as a source of nuisance shocks. 

However, the effects are well understood and can be mitigated by grounding and other measures. 

Magnetic fields from transmission lines (and other sources) can distort the image on computer 

monitors. The threshold for interference depends on the type and size of monitor. Historically, 

this phenomenon is reported at magnetic-field levels at or above 10 mG, but some more sensitive 

monitors may exhibit image distortion at lower levels. For the proposed 115-kV line, the 

distance where interference could occur under worst-case conditions would be reduced to about 

40 feet from the centerline. 

Long-term Health Effects 

The issue of whether there are long-term health effects associated with exposure to fields from 

transmission lines and other sources has been investigated for several decades. A review of 

recent literature on this subject was conducted for this project. There is little evidence that 

electric fields cause long-term health effects. Estimates of magnetic-field exposures have been 

associated with certain health effects in studies of residential and occupational populations. 

Research in this area is continuing to determine whether such associations might reflect a causal 

relationship. 

Scientific reviews of the research on EMF and health have stated that there is insufficient 

evidence to conclude that EMF exposures lead to long-term health effects, such as adult cancer, 

or adverse effects on reproduction, pregnancy, or growth and development of the embryo. Based 

on epidemiology studies, some uncertainty remains about the possible effect of magnetic-field 
C-6 Raymond Cosmopolis Transmission Line Rebuild Project EA 

exposure above 4 mG on the risk of childhood leukemia. However, as the scientific reviews also 

indicate, animal or cellular studies provide little support for the idea that the statistical 

associations reflect a causal relationship, i.e., that magnetic-field exposure increases the risk of 

childhood or adult cancer. 

National and international organizations have established public and occupational EMF exposure 

guidelines on the basis of short-term stimulation effects, rather than long-term health effects. In 

so doing, these organizations did not find data sufficient to justify the setting of a standard to 

restrict long-term exposures to electric or magnetic fields. 

Electric and Magnetic Field Levels 

An increase in public exposure to magnetic fields could occur if field levels increase and if 

residences or other structures draw people to these areas. The predicted field levels are only 

indicators of how the proposed project may affect the magnetic-field environment. They are not 

measures of risk or impacts on health. The 18-mile-long corridor in which the proposed line 

would be built is sparsely populated along most of its length. 

BPA has predicted the annual peak electric and magnetic fields during 2004 from the proposed 

and existing transmission lines to compare the fields from the proposed line with the fields from 

the existing line. The predicted levels for electric and magnetic fields are maximum levels that 

would occur under maximum voltage conditions for electric fields and annual peak current 

conditions for magnetic fields. 

Peak electric field levels are expected to be comparable but slightly less than under existing 

conditions. The calculated peak electric field expected on the ROW of the proposed line is 1.4 

kV/m. The peak values would be present only at locations directly under the line, near mid-span, 

where the conductors are at the minimum clearance. The calculated peak levels are rarely 

reached under real-life conditions. The estimated peak electric field under the existing 115-kV 

line would be 1.5 V/m. The largest value expected at the edge of the ROW of the rebuilt line 

would be 0.6 kV/m. The estimated largest electric field at the edge of the ROW for the existing 

line is 0.7 kV/m. Lateral profiles of the maximum electric field levels near the proposed and 

existing lines are shown on Figure 1. 

Peak magnetic field levels are expected to be less than under existing conditions. The peak 

calculated 60-Hz magnetic field expected at 3.28 feet above ground for the proposed line is 30 

mG. This field is calculated for the maximum current of 224 A, with the conductors at a height 

of 24 feet. The maximum field would decrease for increased conductor clearance. For an 

average conductor height over a span of 31 feet, the maximum field would be 19 mG. The peak 

magnetic field during 2004 for the existing line with a clearance of 20.5 feet would be 43 mG. 

Lateral profiles of the maximum magnetic field levels near the proposed rebuilt line and the 

existing line are shown in Figure 2. 

At the edge of the ROW of the proposed line, the calculated magnetic fields for maximum 

current load conditions are 18 and 14 mG on either side of the line. The higher fields would be 

on the side of the line with the lowest conductor. The calculated magnetic fields of at the edge of 

the ROW of the existing line are about 17 mG. Magnetic fields averaged over a year would be 

about one-half the estimated maximum values. 

The magnetic field would fall off rapidly as distance from the line increases. At a distance of 

100 feet from the centerline of the proposed line, the field would be about 2 mG for maximum 
Bonneville Power Administration C-7 

current conditions. The calculated magnetic field for maximum current would be less than 

10 mG at about 40 feet from the centerline. 

The public health and safety impacts associated with electric and magnetic fields for the 

proposed action would be comparable to those from the existing line. The magnetic fields from 

the proposed line would be less than those from the existing line. Short-term effects, such as 

nuisance shocks, would be very unlikely. 

Toxic and Hazardous Substances 

There are no known occurrences of hazardous materials or contaminants within the transmission 

line corridor; no impacts are expected. 

Figure 1: Maximum electric field at 3.28 ft. height from proposed and existing 

Raymond – Cosmopolis 115-kV transmission lines. 

DISTANCE FROM CENTERLINE OF PROPOSED LINE, feet

-100 -75 -50 -25 0 25 50 75 100

ELECTRIC FIELD, kV/m

0.00

0.25

0.50

0.75

1.00

1.25

1.50

1.75

2.00

Proposed

No-action

EDGE

OF

ROW

EDGE

OF

ROW
C-8 Raymond Cosmopolis Transmission Line Rebuild Project EA 

Figure 2: Maximum magnetic field at 3.28 ft. height from proposed and existing 

Raymond – Cosmopolis 115-kV transmission line.

DISTANCE FROM CENTERLINE OF PROPOSED LINE, feet

-100 -75 -50 -25 0 25 50 75 100

MAGNETIC FIELD, mG

0

5

10

15

20

25

30

35

40

45

Proposed

No-action

EDGE

OF

ROW

EDGE

OF

ROW
APPENDIX D 

Mitigation Action Plan 
Bonneville Power Administration D-1 

MITIGATION ACTION PLAN 

FOR THE 

RAYMOND – COSMOPOLIS TRANSMISSION LINE 

REBUILD PROJECT

This Mitigation Action Plan (MAP) is referenced in the Finding of No Significant Impact 

(FONSI) for the Raymond – Cosmopolis Transmission Line Rebuild Project (Department of 

Energy Environmental Assessment-1425). The project involves rebuilding an existing 115-kV 

transmission line between the towns of Raymond and Cosmopolis in Pacific County and Grays 

Harbor County, Washington. 

This MAP includes all of the mitigation measures recommended in the Final Environmental 

Assessment (EA) to mitigate adverse environmental impacts. It includes some measures that are 

essential to render the impacts of the proposed action not significant and other measures that will 

decrease impacts that did not reach the level to be considered significant. 

Mitigation has and will occur throughout the entire timeframe of the project. Mitigation has 

occurred during the planning and design phase, and it will continue during pre-construction 

planning, construction, and after construction is completed (when the site is being stabilized and 

revegetated). The purpose of this MAP is to explain how the mitigation measures were or will 

be implemented. It clearly identifies the components of each mitigation measure and identifies 

who was or is responsible for the implementation, and at what time during the project they were 

or will be implemented. 

A BPA contractor will rebuild this transmission line. To ensure that the contractor will 

implement mitigation measures, the relevant portions of this MAP will be included in the 

construction contract specifications (the directions to the contractor) for the project. This will 

obligate the contractor to implement the mitigation measures that relate to their responsibilities 

during construction and post-construction. 

If you have general questions about the project, contact the Project Manager, Gary Beck, at 

360-619-6596 (gobeck@bpa.gov). If you have any questions about the MAP, contact the 

Environmental Lead, Kimberly St.Hilaire, at 503-230-5361 (krsthilaire@bpa.gov). This MAP 

may be amended if revisions are needed due to new information or if there are any significant 

project changes. 

PERMITS AND OTHER CONSULTATION RELATED TO MITIGATION MEASURES 

BPA is in the process of obtaining required permits and consulting with state and Federal 

agencies. Although some of the consultation is complete, some was ongoing at the time the 

MAP was finalized. Table D-1 lists the types of consultation and permits that are referenced in 

this MAP. Although the requirements of all permits and consultation are not specifically listed 

in the MAP, the contractor and BPA are required to follow the terms and conditions and 

provisions of the various permits and consultation required by various state and Federal agencies. 
D-2 Raymond Cosmopolis Transmission 

Table D-1. Permits and Consultation 

Permit or 

Consultation Type Date Initiated 

Agency Issuing Permit 

or Conducting 

Consultation 

Progress as of 

August 1, 2003 

Mea

in 

Section 7 Consultation under the Endangered Species Act 

Biological Evaluation submitted on 1/29/2003 and amended on 5/20/2003 

US Fish and Wildlife Service (USFWS) 

Consultation in progress The M

ConditOpinioand WMeasu

Essential Fish Habitat (EFH) Assessment Consultation 

EFH Assessment submitted on 2/3/2003 

National Marine Fisheries Service (NMFS or NOAA Fisheries) 

Consultation Complete NMFS 

March mitigaEA are 

Clean Water Act Section 404 Permit 

JARPA submitted on 3/28/2003 

Army Corps of Engineers (ACOE) 

ACOE has requested additional information, which were submitted in July 2003 

The Mprovis404 pe(WetlaMeasu

Clean Water Act Section 401 Water Quality Certification 

JARPA submitted on 3/28/2003 

WA Department of Ecology (WA DOE) 

WA DOE determines if Water Quality Certification is required after the ACOE permit is issued 

The M401 Ceany mDOE w(Water Measu

Hydraulic Project Approval (HPA) 

JARPA submitted on 3/28/2003 

WA Department of Fish and Wildlife 

Received HPA on May 14, 2003 

The Mprovisbe follMitigaFish anMeasu
Bonneville Power Administration 

Permit or 

Consultation Type Date Initiated 

Agency Issuing Permit 

or Conducting 

Consultation 

Progress as of 

August 1, 2003 

Mea

in 

Clean Water Act NPDES Permit 

EPA Notice of Intent (NOI) will be submitted at least 2 days prior to start of construction 

Environmental Protection Agency (EPA) 

Stormwater Pollution Prevention (SWPP) Plan in Draft form 

The MPlan wimplemMitiga

Pacific County Critical Areas Ordinance permit for wetland impacts 

Letter Report detailing Shoreline impacts submitted on 3/13/2003 and JARPA submitted on 3/28/2003 

Pacific County BPA submitted additional 

information to Pacific County in June 2003 to determine if a permit and any mitigation are required 

The MmitigaCounty and fo(Wetla#3) 

Grays Harbor and Pacific County Shoreline Substantial Development Permit 

Letter Report detailing Shoreline impacts submitted on 3/13/2003 and JARPA submitted on 3/28/2003 

Grays Harbor County Pacific County 

BPA met county planners in June 2003, this project may fall under shoreline exemptions 

If any measube foll

Section 106 Consultation (Historic Properties) 

Submitted Cultural Resources Report to the State Historic Preservation Office (SHPO) on 12/27/2003 

WA Office of Archaeology and Historic Preservation (SHPO) 

SHPO concurred that there are No Historic Properties Affected on 12/27/2003 

The SHdated Dno addmeasuwhat i
D-4 Raymond Cosmopolis Transmission Line Rebuild Project EA 

NATIVE SEED MIX 

In the MAP table that follows, reference is made to a native grass seed mix that will be used for 

revegetating disturbed areas, at a seeding rate of 50 pounds per acre: 

• Blue wild rye (Elymus glaucus), native grass, 30% by weight 

• Red fescue (Festuca rubra), 30% by weight 

• Regreen (a Trade name for Tritium x Agropyron), sterile wheat, 10% by weight 

• Mannagrass (Glyceria occidentalis, G. striata or G. elata depending on availability), 

native grass, 10% by weight 

• California brome (Bromus carinatus), native grass, 10% by weight. 

Although one component, Regreen, is not a native species, it was included in the mix because it 

provides quick cover by germinating very fast. It does not survive beyond a few years because it 

is a sterile species and it is not a perennial species. Different species in the mix are adapted to 

grow in different water regimes, making the mix suitable for both wetlands and uplands.

PERSONS IMPLEMENTING PLAN 

Persons in various roles within BPA and the contractor are responsible for implementation of 

various mitigation measures. In the MAP table (Table D-2, below), the roles of the persons 

responsible for the implementation of that measure are included in abbreviations after each 

component of the measure. For example the Project Manager is referred to in the table as the 

PM. The following persons will be responsible for the implementation of mitigation measures: 

Project Manager (PM): The Project Manager has the ultimate responsibility for the 

contract (including construction specifications) and environmental performance and is 

responsible for budget, schedule and project compliance with environmental regulations 

Design Engineer (DE): Designs the transmission line and works with the project team to 

site structures and other project elements, and to use construction materials and 

techniques that minimize adverse environmental impacts 

Environmental Specialist (ES): Either the ES from the Environmental Planning Analysis 

group or from the Pollution Prevention and Abatement group; responsible for 

environmental planning and permitting, the preparation of the MAP, contractor 

orientation, monitoring of compliance with mitigation measures, and resolution of any 

issues regarding measures 

Contracting Officer’s Technical Representation (COTR): Includes the inspector and 

other BPA personnel who work with the contractor on a regular basis to ensure the 

contractor follows the construction specifications, which includes the relevant portions of 

the MAP 

Road Engineer (RE): Designs and sites roads and other access and works with the project 

team to locate roads and use construction materials and techniques that minimize adverse 

environmental impacts 

Public Affairs Specialist (PAS): Cooperates with other project team members to 

disseminate information to the public concerning the project plans and schedule 

Lands Specialist (LS): Works with landowners to ensure they are informed of project 

activities and given the opportunity to provide input; works with landowners to achieve 

resolution of any issues that arise 
Bonneville Power Administration D-5 

Construction Specifications Writer (CSW): Works with project team members to write 

the construction specifications, the document the contractor will follow to implement the 

project 

Archeologist (ARCH): Works with Tribes and agencies to determine if any cultural 

resources will be affected, designs mitigation and responds if any cultural resources are 

found during the course of construction 

Forester (FOR): Determine which trees need to be cut to ensure the safe construction and 

operation of the transmission line and works with the Environmental Specialist to 

determine how to limit the disturbance from tree removal activities to mitigate for 

adverse environmental effects 

BPA Olympia Region staff (BPA Region): The Olympia Region office is responsible for 

ongoing operation and maintenance of the transmission line, including vegetation 

management and any repairs or necessary maintenance activities to structures, conductor, 

roads and other facilities associated with the transmission line 

Contractor (Contractor): Hired by BPA to build the project; works with the COTR to 

ensure that all contract specifications are followed 

Prior to project implementation, a Contact Information Table will be created that lists the 

names of persons in these roles, issues they can address, and contact information, including 

alternate contacts if that person is unavailable. The contact information sheet will be distributed 

to all BPA project members, contractors, and Federal and state agencies with permits or other 

approvals/recommendations that are committed to within the MAP. 

Table D-2. Mitigation Action Plan Table 

Resource Area and 

Mitigation Measure 

Components of Mitigation Measure 

(Person(s) Responsible for Implementation)

Schedule (Time of 

Implementation) 

LAND USE 

1. BPA’s Project Manager will 

be available to meet with 

concerned landowners to 

discuss issues and concerns. 

1.1. Landowners were contacted by letter and 

some were also contacted by phone or 

visited to determine what concerns they 

have with the proposed project (LS) 

1.2. During construction, all information on 

any landowner contacts will be promptly 

routed to the project manager to address 

(all project members, Contractor) 

1.3 If landowners raise concerns, schedule a 

meeting with the landowner and the 

appropriate team members (PM, LS) 

1.1 Completed during 

initial design/ 

planning process 

1.2 Inform PM of any 

landowner concerns 

within 2 business days

1.3 As needed 
D-6 Raymond Cosmopolis Transmission Line Rebuild Project EA 

Resource Area and 

Mitigation Measure 

Components of Mitigation Measure 

(Person(s) Responsible for Implementation)

Schedule (Time of 

Implementation) 

2. A proposed schedule of 

construction activities will 

be distributed to all 

potentially affected 

landowners along the 

corridor so they know when 

they might experience 

construction-related 

disruptions. 

2.1 Develop a list of activities with a 

potential affect on landowners and 

schedule of those activities (Contractor) 

2.2 Distribute schedule to landowners (PAS) 

2.3 Update schedule and redistribute 

(Contractor, PAS) 

2.1 Prior to construction 

2.2 Prior to construction, 

give two weeks notice 

where possible 

2.3 As needed during 

construction 

3. BPA will prepare a notice 

about construction activities 

and a proposed schedule, 

for posting on the WSDOT 

Traffic Advisory. 

3.1 Prepare notice and schedule and update as 

needed (COTR, Contractor) 

3.2 Deliver notice to WSDOT for posting 

(COTR, PAS) 

3.1 Within appropriate 

time frame for timely 

posting 

3.2 As needed 

4. Traffic safety signs and 

flaggers will be used to 

inform motorists and 

manage traffic during 

construction activities along 

Highway 101. 

4.1 The contractor will develop a Traffic 

Safety Plan that will address when signs 

and flaggers are needed and the Plan will 

be approved by BPA (PM, COTR, 

Contractor) 

4.2 Ensure that the contractors use signs and 

flaggers when required (COTR) 

4.1 Prior to and during 

construction 

4.2 During construction 

5. Construction activities and 

equipment will be kept clear 

of residential driveways as 

much as possible. 

Covered in Land Use, 

Mitigation Measure 2 

6. Disturbed areas will be 

revegetated with native 

seed, except in residential 

areas, where property 

owners will be consulted on 

plant selection. 

6.1 Consult landowners on plant selection 

(LS) 

6.2 Reseed using the seed mix and seeding 

rate described in the text section above 

this table (COTR, Contractor) 

6.1 Prior to construction 

6.2 Seed disturbed areas 

between September 1 

and 15 and any areas 

disturbed after that 

will be reseeded 

before the end of 

construction 

GEOLOGY AND SOILS 

1. Existing structures within 

50 feet of waterways will be 

cut at the ground surface 

rather than cut 2 feet below 

the ground surface, to 

minimize soil disturbance. 

1.1 Identify these structures in the field and in 

the construction specifications (COTR, 

ES) 

1.2 Site meeting to discuss removal methods 

(COTR, ES, Contractor) 

1.3 Ensure that the contractor cuts appropriate 

structures (COTR) 

1.1 Prior to construction 

1.2 Prior to construction 

1.3 During construction 
Bonneville Power Administration D-7 

Resource Area and 

Mitigation Measure 

Components of Mitigation Measure 

(Person(s) Responsible for Implementation)

Schedule (Time of 

Implementation) 

2. Structures and new roads 

will be located as far as 

possible from nearby 

streams and wetlands. 

2.1 During the design phase, wetland 

boundaries and streams were located and 

mapped relative to proposed structures 

(ES) 

2.2 Most proposed structure locations were 

visited at least twice and impacts to water 

features and buffer areas were avoided or 

minimized by locating proposed structures 

as far away as possible (DE, ES) 

2.1 Wetland delineation/ 

determination 

completed 

2.2 Completed during 

design phase 

3. Culverts, cross-drains, and 

water bars will be spaced 

and sized properly. 

3.1 During road design, the guidelines for 

spacing and sizing of water structures in 

the WA Forest Practices Act Board 

Manual, Section 3 were followed (RE) 

3.2 The Access Road Summary, which lists 

all proposed road work and the location, 

identifies specific locations requiring 

water structures (RE) 

3.3 Prior to constructing water structures, 

verify in the field that their location and 

spacing is adequate to minimize drainage 

from the road surface directly into water 

features, including wetlands (COTR) 

3.1 Completed during 

design phase 

3.2 Completed during 

design phase 

3.3 During construction 

4. To minimize erosion, 

sedimentation, and soil 

compaction as much work 

as possible will be 

conducted during the dry 

season, when stream flow, 

rainfall, and runoff are low. 

4.1 Project activities will occur during April 

through November, 2004, with most of 

the major construction activities occurring 

during the drier portions of the year, from 

June though early October (PM) 

4.1 The proposed 

schedule is April 

through November, 

2004 

5. In disturbed areas, 

mechanical barriers to 

erosion, as specified in the 

Storm Water and Pollution 

Prevention (SWPP) Plan, 

will be used. 

5.1 In advance of any ground disturbing or 

construction activities, BPA’s Contractor 

and subcontractors will follow BPA, state, 

and/or local jurisdictional Best 

Management Practices (BMPs) to 

evaluate and design a site specific Erosion 

and Sediment Control (ESC) Plan for that 

location and/or activity to prevent impacts 

to waterways and wetlands (ES, 

Contractor) 

5.2 No construction activity will be permitted 

until required protective measures 

associated with that work are installed 

(ES, COTR, Contractor) 

5.3 All on-site erosion and sediment control 

measures will be inspected at least once 

every seven days and within 24 hours 

after any storm event of greater than 0.5 

inches (ES, COTR, Contractor) 

5.1 Prior to construction 

5.2 Prior to construction 

5.3 During construction 
D-8 Raymond Cosmopolis Transmission Line Rebuild Project EA 

Resource Area and 

Mitigation Measure 

Components of Mitigation Measure 

(Person(s) Responsible for Implementation)

Schedule (Time of 

Implementation) 

5.4 Damaged or inadequate erosion and 

sediment control measures will be 

repaired within 24 hours of the inspection 

(ES, COTR, Contractor) 

5.5 Once sites are stabilized and BPA has 

conducted a final inspection, any 

materials used as temporary erosion and 

sediment control devices will be removed 

and disposed of (ES, COTR, Contractor) 

5.4 During and after 

construction 

5.5 After construction, 

once the site is 

stabilized 

6. Vegetative buffers will be 

retained where possible to 

prevent sediment from 

eroding into water bodies. 

6.1 On project maps used by BPA and 

contractors, depict buffers 50-feet from all 

wetland boundaries and streams (ES) 

6.2 Designated wetland and stream buffers 

will be conspicuously flagged or staked 

(using plastic ribbon, carsonite stakes, or 

paint, as appropriate) to designate areas 

where vegetation should be cut or 

crushed, rather than removed through 

grading or uprooting, where possible (ES) 

6.3 Site meeting to view representative 

examples of buffer markings (ES, COTR, 

Contractor) 

6.4 Ensure that vehicles or construction 

equipment do not enter into wetland and 

stream buffers, except in the designated 

area where construction activities occur or 

as needed for access (COTR) 

6.1 When maps are 

developed, prior to 

construction 

6.2 Prior to construction 

6.3 Prior to construction 

6.4 Prior to construction 

7. Disturbed areas will be 

revegetated with native 

seed. 

7.1 Reseed using the seed mix and seeding 

rate described in the text section of this 

MAP above this table (COTR, Contractor)

7.1 Areas disturbed before 

September 1 will be 

seeded by September 

15 and any areas 

disturbed after that 

will be reseeded 

before the end of 

construction 

8. After construction, access 

roads, culverts, and other 

facilities will be inspected 

and maintained to ensure 

proper function and nominal 

erosion levels. 

8.1 Conduct post-construction monitoring of 

roads, culverts, facilities and provide 

maintenance as needed (COTR, ES, 

Contractor) 

8.2 Inspect roads and culverts on an annual 

basis, and maintain them on an as-needed 

basis (BPA Region) 

8.1 Within 1 month of the 

end of the 

construction activities 

and again in the spring 

of 2005 

8.2 After construction, at 

least once per year, 

during spring, 

summer, or fall 
Bonneville Power Administration D-9 

Resource Area and 

Mitigation Measure 

Components of Mitigation Measure 

(Person(s) Responsible for Implementation)

Schedule (Time of 

Implementation) 

9. Revegetation work and sites 

will be inspected to verify 

adequate growth; 

implement contingency 

measures as needed. 

9.1 A qualified person will inspect 

revegetation sites to determine if seeds 

are germinating and can be expected to 

attain the areal coverage specified in the 

SWPP Plan (70% of the natural 

vegetative cover for that area at final 

stabilization) (ES, COTR, Contractor) 

9.2 If a determination is made that an area is 

unlikely to attain the coverage needed for 

final stabilization, reseed all areas that 

have inadequate growth (ES, Contractor) 

9.1 Follow the inspection 

schedule in the SWPP, 

which mandates 

inspection on a regular 

basis until final 

stabilization is 

achieved 

9.2 As needed and inspect 

areas reseeded on a 

regular basis until 

final stabilization is 

achieved 

VEGETATION 

1. Use existing road systems, 

where possible, to access 

structure locations. 

1.1 During project planning, design the 

project to use existing roads as much as 

possible in order to eliminate the need to 

construct additional roads (DE, RE, PM, 

LS, ES) 

1.2 Contractors will be required to use only 

designated roads or request approval to 

use alternate access (COTR, ES, 

Contractor) 

1.1 Completed during 

design phase 

1.2 During construction 

2. Limit disturbance of native 

plant communities to the 

minimum necessary. 

2.1 Most proposed structures will be located 

close to existing structures (within 10 

feet), to keep disturbance in an area that 

has been previously disturbed by 

construction and maintenance activities; 

in some cases the proposed structures will 

be located further than 10 feet from the 

existing location to avoid sensitive 

environmental resources (DE, ES) 

2.2 Use designated access roads unless this is 

not feasible due to an engineering or 

environmental constraint (DE, ES, 

Contractor) 

(Also covered in Geology and Soils, 

Mitigation Measure 6) 

2.1 Completed during 

design phase 

2.2 During construction 

3. Develop and implement a 

noxious-weed control plan 

to minimize the introduction 

and broadcast of weed 

seeds, which will be 

submitted to the county 

weed control boards 

specialists for 

recommendations. 

3.1 Submit Plan (Components 3.2 to 3.9 that 

follow) to County Weed Control Board 

Specialists for recommendations (ES) 

3.2 Conduct a baseline weed survey (Survey 

of Undesirable Plants) prior to conducting 

any construction activities (LS) 

3.3 Provide a copy of the Survey of 

Undesirable Plants to the Contractor, 

which includes maps of their locations 

(LS) 

3.1 Prior to construction 

3.2 Completed in 2002 

3.3 Prior to construction 
D-10 Raymond Cosmopolis Transmission Line Rebuild Project EA 

Resource Area and 

Mitigation Measure 

Components of Mitigation Measure 

(Person(s) Responsible for Implementation)

Schedule (Time of 

Implementation) 

3.4 The contractor must certify in writing that 

all vehicles, equipment, and machinery 

are free of all weeds including seeds 

before moving the equipment into the 

construction area (COTR, Contractor) 

3.5 Only weed free materials, or inert 

materials will be used for mulching and 

for erosion control (ES, COTR, 

Contractor) 

3.6 Minimize disturbance to existing 

vegetation to prevent the colonization of 

disturbed areas by weed species (COTR, 

Contractor) 

3.7 Reseed disturbed areas with native seed 

mix (COTR, Contractor) 

3.8 Ensure that adequate cover (at least 70% 

of natural coverage for that area) by newly 

planted seed will be achieved before final 

stabilization, verified through monitoring) 

or implement contingency plan to ensure 

adequate cover of disturbed areas (ES, 

COTR, Contractor) 

3.9 Monitor the right-of-way for new 

invasions or expansion of the existing 

weed populations, solicit information 

from Weed Control Boards, and develop 

and implement control measures if needed 

(BPA Region) 

3.10 As part of ongoing vegetation 

management encourage the growth of 

plant community of low growing 

herbaceous and shrubby species within the 

ROW, including natives or non-invasive 

species, to discourage weed germination, 

survival, and spread (BPA Region) 

3.4 Prior to and during 

construction 

3.5 Prior to and during 

construction 

3.6 During construction 

3.7 During and after 

construction (see 

Geology and Soils, 

Measure 7) 

3.8 After construction 

(See Geology and 

Soils, Measure 9) 

3.9 On an annual basis 

after construction 

3.10 After construction 

4. Revegetate disturbed areas 

with native seed 

Covered in Geology and Soils, 

Mitigation Measure 7 

5. Inspect revegetation work 

and sites to verify adequate 

growth and implement 

contingency measures as 

needed. 

Covered in Geology and Soils, 

Mitigation Measure 9 
Bonneville Power Administration D-11 

Resource Area and 

Mitigation Measure 

Components of Mitigation Measure 

(Person(s) Responsible for Implementation)

Schedule (Time of 

Implementation) 

FISH AND WILDLIFE 

1. When working in or next to 

water bodies, disturbance 

will be limited to the 

minimum necessary. 

1.1 Designated 50-foot buffers along fishbearing streams and wetland buffers will 

be conspicuously flagged or staked (using 

plastic ribbon, carsonite stakes, or paint, 

as appropriate) (ES) 

1.2 Entry into wetlands and streams is only 

permitted if authorized by permit and in 

wetland and stream buffer areas (50-foot 

on either side), entry is only permitted if 

necessary for construction (COTR, 

Contractor) 

(Also covered in Geology and Soils, 

Mitigation Measures 1, 5, and 6) 

1.1 Prior to construction 

1.2 During construction 

2. Existing structures within 

50 feet of waterways will be 

cut at the ground surface 

rather than cut 2 feet below 

the ground surface, to 

minimize soil disturbance. 

Covered in Geology and Soils, 

Mitigation Measure 1 

3. Removal of forest habitat 

will be limited to those trees 

that would interfere with 

transmission lines or those 

cut to create access roads. 

3.1 During design, map all areas where forest 

would need to be removed on project 

maps as they are identified and look for 

ways to avoid or limit as much tree 

removal as possible (FOR, DE, ES) 

3.2 Mark individual trees that are to be 

removed and the back line of all cut areas 

with paint (FOR) 

3.4 On project maps for BPA and contractor 

use, depict all tree removal areas and list 

cut areas in the construction specifications 

(FOR, CSW) 

3.5 Site meeting to go over the location and 

marking of tree removal areas, including 

all tree markings and what they mean 

(FOR, COTR, Contractor) 

3.6 Ensure that contractors cut only trees 

identified as to be cut within the contract 

(COTR) 

3.1 Completed during 

design phase 

3.2 Prior to construction 

3.3 Prior to construction 

3.4 Before construction 

3.5 During construction 

4. Existing structures located 

within 50-feet of fishbearing streams will be cut 

off at ground level to 

minimize ground 

disturbance. 

Covered in Fish and Wildlife, 

Mitigation Measure 2 
D-12 Raymond Cosmopolis Transmission Line Rebuild Project EA 

Resource Area and 

Mitigation Measure 

Components of Mitigation Measure 

(Person(s) Responsible for Implementation)

Schedule (Time of 

Implementation) 

5. Disturbed areas will be 

revegetated with native 

seed. 

Covered in Geology and Soils, 

Mitigation Measure 7 

6. Tensioning sites will not be 

located within 50 feet of 

streams or wetlands and 

within 100-year floodplains. 

6.1 On project maps (for contractor use), 

depict a 50-foot buffer on either side of 

wetlands and streams, and the boundaries 

of the 100-year floodplains boundaries 

(ES) 

6.2 Include tensioning site restrictions in 

construction specifications (CSW) 

6.3 Contractor will be required to obtain 

approval for each tensioning site location 

(COTR) 

6.1 When maps are 

developed, prior to 

construction 

6.2 Prior to construction 

6.3 During construction 

7. Mitigation measures 

required by WDFW will be 

followed when working in 

streams. 

7.1 Obtain Hydraulic Project Approval (HPA) 

from WDFW (ES) 

7.2 Provide copies of HPA to contractors who 

must follow all provisions within the HPA 

(ES, COTR) 

7.3 Site meeting to go over provisions within 

the HPA at all covered sites (COTR, ES, 

Contractor, invite WDFW habitat 

biologist to attend) 

7.4 Notify WDFW habitat biologist when instream work will commence (COTR, 

Contractor) 

7.5 Invite WDFW habitat biologist to view 

sites near the completion of instream work 

to ensure compliance with all conditions 

(COTR, ES) 

7.6 Conduct site protection/revegetation 

required by the HPA (ES, COTR, 

Contractor) 

7.1 The project HPA was 

issued by WDFW on 

May 14, 2003 (Log 

No. ST-F6006-01) 

7.2 Prior to conducting 

any instream work 

7.3 Prior to conducting 

any instream work 

7.4 Notify at least 3 

business days prior to 

commencing work 

7.5 When instream work 

is nearly completed 

but contractor is still 

working on-site 

7.6 During construction 

(site protection, as 

needed) and after 

instream work is 

completed (site 

protection within 7 

days, revegetation 

within one year) 
Bonneville Power Administration D-13 

Resource Area and 

Mitigation Measure 

Components of Mitigation Measure 

(Person(s) Responsible for Implementation)

Schedule (Time of 

Implementation) 

8. No structure construction 

will be carried out within 75 

yards of the boundary of 

OCCUPIED marbled 

murrelet habitat until after 

September 15. 

AND 

9. Instream work and other 

roadwork within 75 yards of 

OCCUPIED marbled 

murrelet habitat will not 

commence until after 

August 5. 

8.1 On project maps for contractor and BPA 

use, depict the 75-yard construction buffer 

around occupied marbled murrelet sites 

(ES) 

8.2 Construction specifications will contain a 

written description of the restricted areas 

by structure number and the specific 

timing restrictions (CSW, ES) 

8.3 Attend contractor construction meetings 

to go over locations of restricted area and 

timing of noise restrictions (ES, COTR, 

Contractor) 

8.4 Ensure that the contractor follows timing 

restrictions (COTR) 

8.1 As maps are 

developed, prior to 

construction 

8.2 Prior to construction 

8.3 During construction 

8.4 During construction 

10. Helicopters will not be 

used to string the 

conductor until after 

September 15 to avoid 

noise impacts to nesting 

marbled murrelet. 

10.1. Ensure timing restrictions are adhered to 

(COTR) 

10.1 During construction 

11. Dusk-to-dawn restrictions 

will be in place within 

0.25 mile of all 

OCCUPIED AND 

POTENTIAL marbled 

murrelet habitat stands 

between April 1 and 

September 15. 

11.1 On project maps for contractor and BPA 

use, depict the area within the 0.25 mile 

buffer around all occupied or potential 

marbled murrelet habitat (ES) 

11.2 Construction specifications will contain 

a written description of the restricted 

area by structure number and a weekly 

table of the time of day when work can 

begin and the time it must end (CSW, 

ES) 

11.3 Attend construction meetings with 

contractor to go over locations of 

restricted areas and timing of noise 

restrictions (ES, COTR, Contractor) 

11.4 Ensure noise restrictions are adhered to 

(COTR) 

11.1 As maps are 

developed, prior to 

construction 

11.2 Prior to construction 

11.3 During construction 

11.4 During construction 

12. Any trees felled within 50 

feet of the Joe Creek 

crossing will be felled into 

the stream to provide large 

woody debris, if approved 

by WSDOT, the 

landowner. 

12.1 On project maps for BPA and contractor 

use, depict this tree cutting area (ES) 

12.2 Conspicuously mark all trees within 50 

feet of Joe Creek with paint indicating 

they are to be left as at least 30-foot tall 

snags with the tops felled into the creek 

(FOR) 

12.3 Meet on site to point out the tree 

marking and discuss special cutting 

requirements (ES, COTR, Contractor) 

12.1 Prior to construction 

12.2 Prior to construction 

12.3 Prior to construction 
D-14 Raymond Cosmopolis Transmission Line Rebuild Project EA 

Resource Area and 

Mitigation Measure 

Components of Mitigation Measure 

(Person(s) Responsible for Implementation)

Schedule (Time of 

Implementation) 

12.4 During tree felling, a biologist must be 

on-site to ensure trees are properly felled 

to ensure stream channel is not damaged 

or blocked (COTR, ES) 

12.5 Invite WDFW habitat biologist to view 

tree felling to ensure fish habitat 

concerns are addressed (ES) 

12.6 After tree felling, inspect area to ensure 

there are no blockages or problems 

resulting from the large woody debris 

(ES, COTR) 

12.4 During construction, 

COTR will arrange 

schedule with 

biologist 

12.5 During construction 

12.6 Within one month 

after tree felling 

13. The five danger trees cut 

within 50 to 110 feet of 

the Joe Creek tributary 

(between Structures 92 to 

94) will be cut as snags 

but the tops will not be 

felled toward the creek to 

avoid damaging the 

remaining trees in the 

riparian buffer. 

13.1 On project maps for BPA and contractor 

use), depict the area of the individual 

danger trees as polygons (ES) 

13.2 Mark the danger trees with paint to 

identify them as trees to be left as snags 

(FOR) 

13.3 List these trees and special cutting 

requirements in the construction 

specifications (CSW, FOR) 

13.4 Meet on site to point out the marking 

and discuss the special cutting 

requirements (ES, COTR, Contractor) 

13.5 Ensure that these are the only trees cut 

beyond the back line in this area 

(COTR) 

13.1 Prior to construction 

13.2 Prior to construction 

13.3 Prior to construction 

13.4 During construction 

13.5 During construction 

14. The riparian area within 

50 feet of Joe Creek will 

be replanted with native, 

low-growing shrubs, if 

planting spots can be 

created safely. 

14.1 Obtain WDFW recommendations on 

appropriate shrub species to be planted 

(ES) 

14.2 Inform the planting crew to create 

planting spots and replant, if possible to 

do so safely (FOR, COTR) 

14.1 Prior to construction 

14.2 After construction 

15. Any trees felled within 50 

feet of the Little North 

River tributary between 

Structures 123 and 124 

will be cut as snags and 

the tops felled into the 

riparian area. 

15.1 On project maps for BPA and contractor 

use depict this tree cutting area (ES) 

15.2 Conspicuously mark all trees within 50 

feet of the creek with paint indicating 

they are to left as at least 30-foot tall 

snags with the tops felled into the creek 

(FOR) 

15.3 During tree felling, a biologist must be 

on-site to ensure trees are properly felled 

to ensure the stream channel is not 

damaged or blocked (COTR, ES) 

15.4 Invite the WDFW habitat biologist to 

view tree felling to ensure fish habitat 

concerns are addressed (ES) 

15.1 Prior to construction 

15.2 Prior to construction 

15.3 During construction, 

COTR must arrange 

schedule with 

biologist 

15.4 During construction 
Bonneville Power Administration D-15 

Resource Area and 

Mitigation Measure 

Components of Mitigation Measure 

(Person(s) Responsible for Implementation)

Schedule (Time of 

Implementation) 

16. A Biological Evaluation 

has been prepared as 

required under the 

Endangered Species Act. 

It provides detailed 

actions to reduce or 

eliminate impacts on listed 

species. If an incidental 

take permit is issued, any 

terms and conditions will 

be implemented. 

16.1 Consult with the US Fish and Wildlife 

Service under Section 7 of the 

Endangered Species Act on the impacts 

to listed species and obtain a Biological 

Opinion (ES) 

16.2 Provide project team members and the 

contractor with a copy of the Biological 

Opinion and go over the Terms and 

Conditions at a pre-construction meeting 

(ES, COTR) 

16.3 Ensure the contractor follows the Terms 

and Conditions in the Biological 

Opinion (COTR) 

16.1 In progress 

16.2 Prior to construction 

16.3 During construction 

WATER QUALITY 

1. An environmental specialist 

will meet with contractors 

and inspectors in the field to 

visit selected wetlands and 

waterways near or within 

construction areas to review 

avoidance and mitigation 

measures and any permit 

requirements. 

1.1 Determine which wetlands are near or 

within construction sites (ES) 

1.2 Meet on site to discuss restrictions while 

working near waterways and wetlands, 

including mapping, marking, and permit 

conditions and protocol to follow if 

flagging/staking is inadvertently removed 

or missing (ES, COTR, Contractor) 

1.3 If Section 401 Certification is required 

(Clean Water Act), any mitigation 

required by WA Department of Ecology 

will be implemented (ES, COTR) 

1.1 Prior to construction 

1.2 Prior to construction 

1.3 Prior to, during, and 

after construction, as 

required 

2. A Stormwater Pollution 

Prevention (SWPP) Plan 

will be prepared and 

implemented, addressing 

measures to reduce erosion 

and runoff and stabilize 

disturbed areas. 

2.1 The SWPP Plan will meet the 

requirements of the U.S. EPA General 

Permit of the NPDES permitting program 

to control stormwater pollution associated 

with construction activities (ES, 

Contractor) 

2.2 The SWPP Plan will address the projectspecific erosion and sediment control 

measures that the contractor must 

implement (COTR, Contractor) 

2.3 Ensure contractor implements the SWPP 

(COTR) 

2.1 Prior to construction 

2.2 During construction 

2.3 During construction 

3. Existing structures within 

50 feet of waterways will be 

cut at the ground surface 

rather than cut 2 feet below 

the ground surface, to 

minimize soil disturbance. 

Covered in Fish and Wildlife, 

Mitigation Measure 2 
D-16 Raymond Cosmopolis Transmission Line Rebuild Project EA 

Resource Area and 

Mitigation Measure 

Components of Mitigation Measure 

(Person(s) Responsible for Implementation)

Schedule (Time of 

Implementation) 

4. When working in or near 

water bodies and wetlands 

(buffer areas), disturbance 

will be kept to the minimum 

necessary. 

Covered in Soils and Geology, 

Mitigation Measure 6 

5. Vegetative buffers will be 

retained where possible to 

prevent sedimentation into 

water bodies. 

Covered in Soils and Geology, 

Mitigation Measure 6 

6. To minimize erosion, 

sedimentation, and soil 

compaction, as much work 

as possible will be 

conducted during the dry 

season, when stream flow, 

rainfall, and runoff are low. 

Covered in Soils and Geology, 

Mitigation Measure 4 

7. No construction vehicles 

and equipment will be 

placed within 50 feet of any 

stream or wetland unless it 

is authorized by a permit or 

is on an existing permanent 

or temporary road

constructed for access to the 

site. 

Covered in Fish and Wildlife, 

Mitigation Measure 1 

8. Tensioning sites will not be 

located within 50 feet of 

streams, wetlands, or 

floodplains. 

Covered in Fish and Wildlife, 

Mitigation Measure 8 

9. Roads and structures will be 

located to avoid wetlands 

whenever possible. 

Covered in Soils and Geology, 

Mitigation Measure 2 

10. Roads will be designed 

and constructed to 

minimize drainage from 

the road surface directly 

into water features, 

including wetlands. 

Covered in Soils and Geology, 

Mitigation Measure 3 

11. Mitigation measures 

required by WDFW will 

be followed when 

conducting instream work. 

Covered in Fish and Wildlife, 

Mitigation Measure 7 
Bonneville Power Administration D-17 

Resource Area and 

Mitigation Measure 

Components of Mitigation Measure 

(Person(s) Responsible for Implementation)

Schedule (Time of 

Implementation) 

12. The riparian area within 

50 feet of the Joe Creek 

crossing where riparian 

trees will be cut as snags 

and the tops felled into the 

creek will be replanted 

with native, low-growing 

shrubs, assuming planting 

spots are present and can 

be safely accessed within 

the woody debris felled 

into this area. 

Covered in Fish and Wildlife, 

Mitigation Measure 12 

13. A Spill Prevention Control 

and Countermeasure 

(SPCC) Plan will be 

developed and 

implemented to minimize 

the potential for spills of 

hazardous material. 

13.1 As part of the Stormwater Pollution 

Prevention (SWPP) Plan, a Spill 

Prevention and Response section will be 

prepared to address petroleum and 

hazardous materials handling and 

management procedures for this project; 

the spill plan will also meets the State of 

Washington requirements in Washington 

Administrative Code (WAC) Chapter 

173-181, which specify the spill 

response, cleanup, and disposal 

requirements of oil (ES, Contractor) 

13.2 The spill plan will be modified to include 

all hazardous substances (including oil 

and other petroleum products) associated 

with the scope of work (Contractor) 

13.3 Ensure that the provisions within the spill 

plan are followed during construction 

(COTR) 

13.1 Prior to Construction 

13.2 Prior to and during 

construction 

13.3 During construction 

14. Machinery will be 

refueled and stored at least 

200 feet from wetlands 

and waterways and will be 

inspected regularly for 

leaks. 

14.1 Tanks and equipment containing oil, fuel 

or chemicals shall be checked regularly 

for drips or leaks and shall be maintained 

to prevent spills onto the ground or into 

State waters (Contractor, COTR) 

14.2 All equipment fueling operations shall 

utilize pumps and funnels and absorbent 

pads; fueling shall not take place within 

200 feet of natural or manmade drainage 

conveyance including ditches, catch 

basins, ponds, wetlands, and pipes; all 

fueling shall be restricted to designated 

fueling areas (Contractor, COTR) 

14.1 Prior to Construction 

14.2 During construction 
D-18 Raymond Cosmopolis Transmission Line Rebuild Project EA 

Resource Area and 

Mitigation Measure 

Components of Mitigation Measure 

(Person(s) Responsible for Implementation)

Schedule (Time of 

Implementation) 

WETLANDS 

1. Roads and structures will be 

located to avoid wetlands 

and streams whenever 

possible. 

Covered in Water Quality, 

Mitigation Measure 9 

2. Any construction activities 

within wetlands will be 

designed and implemented 

to minimize impacts, and 

BPA will coordinate with 

the Army Corps of 

Engineers (ACOE) to obtain 

a permit for any fill placed 

in wetlands and comply 

with any required mitigation 

identified by the ACOE. 

Design is covered in Wetlands, Mitigation 

Measure 9 and implementation is covered in 

the following text: 

2.1 Mitigation measures are included in the 

Section 404 permit application submitted 

to the Army Corps of Engineers, including 

removing any material excavated, 

minimizing work areas, and revegetation 

of disturbed wetland areas (ES) 

2.2 Ensure that all Section 404 permit 

requirements are followed by the 

contractor (COTR) 

2.1 Completed in 

submitted permit 

application 

2.2 During construction 

3. An environmental specialist 

will meet with contractors 

and inspectors in the field to 

visit wetlands and 

waterways near or within 

construction areas to go 

over avoidance and 

mitigation measures and 

any permit requirements. 

3.1 Meet at each wetland and waterway work 

site covered by state or Federal permits to 

discuss requirements for work in 

wetlands, including all permit conditions 

and provisions (Clean Water Act Section 

404 permit, HPA, and any mitigation 

required by Pacific County) and 

avoidance of wetland buffers, where 

possible (ES, COTR, Contractor) 

3.1 Prior to conducting 

any work in wetlands 

4. Wetland boundaries in the 

vicinity of construction 

areas will be flagged or 

staked so wetlands and 

streams can be avoided. 

Covered in Water Quality, 

Mitigation Measure 4 

5. When working next to 

wetlands (buffer areas) and 

water bodies, disturbance 

will be limited to the 

minimum necessary. 

AND 

6. No machinery, construction 

vehicles and equipment will 

be placed within 50 feet of 

any stream or wetland 

unless it is authorized by a 

permit or is on an existing 

permanent or temporary 

road constructed for access 

to the site. 

Covered in Water Quality, 

Mitigation Measure 4 
Bonneville Power Administration D-19 

Resource Area and 

Mitigation Measure 

Components of Mitigation Measure 

(Person(s) Responsible for Implementation)

Schedule (Time of 

Implementation) 

7. Tensioning sites will not be 

located within 50 feet of 

wetlands. 

Covered in Fish and Wildlife, 

Mitigation Measure 8 

8. Machinery will be refueled 

and stored at least 200 feet 

from wetlands and 

waterways and inspected 

regularly for leaks. 

Covered in Water Quality, 

Mitigation Measure 14 

9. Mitigation measures 

required by WDFW will be 

used when conducting 

instream work. 

Covered in Fish and Wildlife, 

Mitigation Measure 7 

10. Erosion control measures 

to avoid sedimentation of 

wetlands and streams will 

be used. 

10.1 The contractor will evaluate site 

conditions and design a site specific 

erosion and sediment control (ESC) plan, 

using the BPA, state and/or local 

jurisdictional BMPs, subject to BPA 

approval (Contractor, ES, COTR) 

10.2 No construction activity will be permitted 

without prior completion of protective 

measures associated with that work 

(COTR) 

10.3 The contractor will inspect all on-site 

erosion and sediment control measures at 

least once every seven days and within 

24 hours after any storm event of greater 

than 0.5 inches; damaged or inadequate 

erosion and sediment control measures 

will be repaired within 24 hours of the 

inspection (Contractor, ES, COTR) 

10.1 Prior to any ground 

disturbing or 

construction activities

10.2 Prior to and during 

construction 

10.3 During and after 

construction 

11. When temporary roads are 

built in wetlands, 

contractors will underlay 

temporary fill with 

geotextile fabric, remove 

all fill, and revegetate 

according to any permits. 

11.1 The Joint Aquatic Permit Application 

(JARPA) contains a plan view, section 

view, and mitigation measures for 

temporary fill construction and these 

areas are listed in the Access Road 

Summary (RE, ES) 

11.2 Ensure contractor fulfills all permit 

conditions related to temporary fill sites 

(COTR) 

11.1 Completed during 

design phase 

11.2 During construction 
D-20 Raymond Cosmopolis Transmission Line Rebuild Project EA 

Resource Area and 

Mitigation Measure 

Components of Mitigation Measure 

(Person(s) Responsible for Implementation)

Schedule (Time of 

Implementation) 

12. When holes are excavated 

for structures in wetlands, 

contractors will avoid 

deposit of excavated 

material into wetlands by 

placing geotextile fabric 

around the excavation site, 

removing all excavated 

material from the wetland, 

and stabilizing it in an 

upland area 

12.1 The Joint Aquatic Permit Application 

(JARPA) includes removing any material 

excavated from wetlands to an upland 

area as mitigation, so this will be a 

requirement of the Section 404 permit 

(Clean Water Act) from the Army Corps 

of Engineers (ES) 

12.2 Ensure contractor fulfills all permit 

conditions related to disposal of 

excavated material (COTR) 

12.1 Completed during 

design phase 

12.2 During construction 

13. Disturbed areas will be 

revegetated with native 

species, and specific 

revegetation guidelines in 

permits will be followed. 

Covered in Geology and Soils, 

Mitigation Measure 7 and 

Wetlands, Mitigation Measure 3 

FLOODPLAINS 

1. Proposed roads and 

structures will be located to 

avoid floodplains, where 

possible. 

1.1 Create map of floodplain boundary in 

relation to existing and proposed 

structures and roads (ES) 

1.2 Relocate proposed structures outside 

floodplain where possible (DE, ES) 

1.3 No proposed roads will be located in 

floodplains 

1.1 Completed during 

design phase 

1.2 Completed during 

design phase 

1.3 Completed during 

design phase 

2. Erosion control measures 

will be used to avoid 

sedimentation of 

floodplains. 

2.1 BPA’s Contractor and subcontractors will 

evaluate site conditions and design a site 

specific Erosion and Sediment Control 

(ESC) plan, using BPA, state and/or local 

jurisdictional Best Management Practices 

(BMPs); the plan will be subject to BPA 

approval (ES, COTR) 

2.2 No construction activity will be permitted 

without prior completion of protective 

measures associated with that work (ES, 

COTR) 

2.3 All on-site erosion and sediment control 

measures will be inspected at least once 

every seven days and within 24 hours 

after any storm event of greater than 0.5 

inches. Damaged or inadequate erosion 

and sediment control measures will be 

repaired within 24 hours of the inspection 

(ES, COTR) 

2.1 Prior to any ground 

disturbing or 

construction activities 

2.2 Prior to and during 

construction 

2.3 During and after 

construction 

3. Tensioning sites will not be 

located in floodplains. 

Covered in Fish and Wildlife, 

Mitigation Measure 8 
Bonneville Power Administration D-21 

Resource Area and 

Mitigation Measure 

Components of Mitigation Measure 

(Person(s) Responsible for Implementation)

Schedule (Time of 

Implementation) 

4. Disturbed areas will be 

revegetated with seed from 

native species. 

Covered in Geology and Soils, 

Mitigation Measure 7 

VISUAL QUALITY 

1. Non-lustrous insulators (i.e., 

non-ceramic insulators) and 

conductors will be used. 

1.1 1.1 Specify non-lustrous conductors and 

insulators (smaller than existing ones) in 

the materials order (DE) 

1.1 When materials are 

ordered 

2. Contractors will maintain 

construction sites free of 

debris. 

2.1 Inspect construction sites and inform 

contractor if there is any unwanted 

material that must be removed (COTR) 

2.1 During construction, 

on a regular basis and 

when construction is 

finished do a final 

inspection 

3. BPA will maintain the 

corridor free of debris 

resulting from transmission 

line operation, maintenance, 

and construction activities 

after construction. 

3.1 Inspect the right-of-way by helicopter and 

vehicle (BPA Region) 

3.2 Report any unwanted debris to the 

appropriate BPA staff member and 

arrange for disposal (BPA Region) 

3.1 Each year, three 

helicopter surveys and 

one vehicle inspection 

are conducted 

3.2 As needed 

AIR QUALITY 

1. Water trucks will be used to 

control dust during 

construction. 

1.1 Perform work in a manner that minimizes 

the production of dust, which includes 

limiting vehicle speeds along dirt roads to 

15 miles per hour and covering 

construction materials that are a source of 

blowing dust (COTR, Contractor) 

1.2 Determine if dust is being generated on 

the project site and develop protocol for 

the use of water trucks and water as 

needed; do not withdraw water for dust 

control use from any water body in the 

project area, unless permitted (COTR, ES, 

Contractor) 

1.1 During construction 

1.2 As needed during 

construction 

2. All vehicle engines will be 

in good operating condition 

to minimize exhaust 

emissions. 

2.1 Visually check the operation of exhaust 

system on construction equipment to 

ensure they are in good operating 

condition and do not have obviously 

excessive exhaust emissions (COTR) 

2.1 During construction, 

on a regular basis 
D-22 Raymond Cosmopolis Transmission Line Rebuild Project EA 

Resource Area and 

Mitigation Measure 

Components of Mitigation Measure 

(Person(s) Responsible for Implementation)

Schedule (Time of 

Implementation) 

SOCIOECONOMICS 

1. BPA engineers will work 

with industrial forest 

owners and other 

landowners to site structures 

and roads to minimize 

impacts to forestry 

activities. 

1.1 Meet with forest landowners to determine 

the location of roads and structures and 

ways to minimize impacts (PM, LS, DE) 

1.1 Prior to construction 

CULTURAL RESOURCES 

1. Research was conducted to 

document the history and 

significance of the existing 

transmission line and 

presented to the Pacific 

County Historical Society. 

1.1 A qualified, professional, archeologist 

conducted research and prepared written 

and photographic documentation meeting 

state standards (ES, ARCH) 

1.2 Present documentation to the Pacific 

County Historical Society (ES) 

1.1 Completed by Applied 

Archeological 

Consultants of 

Portland, OR in 

January 2003 

1.2 Sent to the Historical 

Society in March 

2003, who 

acknowledged receipt 

on April 2, 2003 

2. The Pacific County 

Historical Society will be 

offered one of the existing 

transmission line structures 

for display at its new 

museum site. 

2.1 Identify which structure is a representative 

structure that can be safely removed for 

display (DE, PM) 

2.2 Notify the Historical Society Director of 

required safety protocol during removal of 

structure; the Historical Society will 

provide transport to the museum site 

(COTR) 

2.1 Initially discussed in 

February 2003 with 

the Historical Society 

Director, continue 

discussions and make 

decision by Spring 

2004 

2.2 Prior to removal of 

structure 

3. In the event that 

archaeological material is 

encountered during project 

construction, the BPA 

archaeologist will 

immediately be notified and 

work will be halted in the 

vicinity of the finds; BPA 

will immediately notify the 

Washington SHPO. 

3.1 The contractor is required to immediately 

notify the COTR upon encountering any 

material that may be archeological 

material and halt work in the vicinity of 

the material so there is no further 

disturbance of the area (COTR, 

Contractor) 

3.2 The COTR will immediately notify the 

BPA archeologist and request direction on 

how to proceed (COTR) 

3.3 The BPA archeologist will immediately 

notify the Washington SHPO, determine 

how to proceed and notify the COTR 

when work can resume in that area 

(ARCH) 

3.1 During construction 

3.2 Immediately upon 

discovery (within the 

same business day) 

3.3 Call to archeologist on 

the same day the 

archeological material 

is encountered, if 

unavailable, call down 

the notification list 
Bonneville Power Administration D-23 

Resource Area and 

Mitigation Measure 

Components of Mitigation Measure 

(Person(s) Responsible for Implementation)

Schedule (Time of 

Implementation) 

HEALTH AND SAFETY 

1. Before starting construction, 

the contractor will prepare 

and maintain a safety plan 

in compliance with 

Washington requirements. 

The plan will be kept onsite and will detail how to 

manage hazardous materials 

such as fuel, and how to 

respond to emergency 

situations. 

1.1 Review plan prepared by contractor and 

provide feedback and request changes if 

needed (COTR) 

1.2 Determine where safety plan is kept onsite (COTR) 

1.3 Ensure contractor maintains plan on a 

regular basis and as needed (COTR) 

1.1 Prior to construction 

1.2 Prior to construction 

1.3 At a minimum, at each 

monthly meeting and 

after any incident 

requiring plan updates

2. During construction, the 

contractors will hold crew 

safety meetings at the start 

of each workday to review 

potential safety issues and 

concerns. 

2.1 Ensure contractor holds safety crew 

meetings (COTR) 

2.2 Obtain schedule of where and when crew 

safety meetings occur and attend as 

needed (COTR) 

2.1 During construction 

2.2 BPA personnel will 

attend at a minimum 

four times per month 

3. BPA will meet with the 

contractor on a monthly 

basis to discuss safety 

issues. 

3.1 Schedule and attend meetings (COTR, 

Contractor) 

3.1 At a minimum, on a 

monthly basis 

4. At the end of each workday, 

the contractor and 

subcontractors will secure 

the site, as much as 

possible, to protect 

equipment and the general 

public. 

4.1 Identify potential safety hazards that 

require corrective action, notify contractor 

that steps must be taken, and ensure 

potential risks are minimized (COTR) 

4.1 During construction 

5. BPA will construct and 

operate the new 

transmission line to meet 

the National Electrical 

Safety Code (NESC). 

5.1 Design the transmission line to meet or 

exceed NESC standards (DE, PM) 

5.2 Operate and maintain the transmission 

line to meet NESC standards (BPA 

Region) 

5.1 Completed during 

design phase 

5.2 After construction, 

during operation 
D-24 Raymond Cosmopolis Transmission Line Rebuild Project EA 

Resource Area and 

Mitigation Measure 

Components of Mitigation Measure 

(Person(s) Responsible for Implementation)

Schedule (Time of 

Implementation) 

6. If a hazardous material is 

discovered that could pose 

an immediate threat to 

human health or the 

environment, BPA requires 

that the contractor notify the 

Contracting Officer’s 

Technical Representative 

(COTR) immediately and 

stop work in that area until 

given notice to continue 

work. 

6.1 If hazardous material is encountered, the 

contractor is required to stop work before 

the conditions are disturbed, take 

necessary safety and health precautions, 

and notify the COTR (Contractor) 

6.2 Upon receiving notice that a hazardous 

material is present, the COTR will call in 

an environmental specialist to characterize 

the nature and extent of the contamination 

and to determine how the work may safely 

be completed (ES, COTR) 

6.3 Work will not proceed until measures 

approved by WDOE are put in place to 

prevent the spread of contaminated 

materials and protect the health and safety 

of workers (ES, COTR) 

6.1 During construction 

6.2 During construction 

6.3 During construction 

NOISE 

1. All construction equipment 

and vehicles will have 

muffled exhaust. 

1.1 Check the exhaust system of contractor 

construction equipment regularly to 

ensure they have muffled exhaust (COTR)

1.2 During construction 

2. Landowners directly 

impacted along the corridor 

will be notified prior to 

construction activities. 

Covered under Land Use, 

Mitigation Measure 2 

3. Near residences, 

construction activities will 

be limited to daytime hours. 

3.1 Ensure that construction activities that 

take place within hearing distance of 

residences do not begin until 1 hour after 

dawn and end 1 hour before sunset 

(COTR, Contractor) 

3.1 During construction 

4. If radio or television 

interference occurs that is 

caused by BPA’s 

transmission line, measures 

will be taken to restore the 

reception to a quality as 

good or better than before 

the interference. 

4.1 If BPA is notified of a problem, contact 

and meet with the affected landowner and 

determine if the problem is caused by 

BPA’s transmission line (LS, PM) 

4.2 If the problem is caused by the 

transmission line, determine what steps 

are needed to remedy the problem, and 

implement the solution (PM) 

4.1 Respond to landowner 

within 2 weeks to 

schedule meeting 

4.2 As soon as possible 
Bonneville Power Administration

PO Box 3621 Portland, Oregon 97208-3621

DOE/BP-3542 AUGUST 2003 101