Electronic Compilation Comments at July 28, 2010

8/6/2019 Electronic Compilation Comments at July 28, 2010

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TRANSMISSION CORRIDOR COMMITTEEReview of Draft Corridors Public Comments

Compiled for Meeting Dated

Wednesday, July 28, 2010 9:00 a.m.

State Capitol, Room 322

Santa Fe, New Mexico

Comments Received to Date (listed in order of date received):

1. Letter from Roosevelt County Manager, Charlene Hardin (6/28/10)

2. Letter from Roosevelt County Community Development Corporation,

Greg Fisher, Executive Director (6/29/10)

3. PNM Comments (7/09/10)

4. E-mail from Frio Ridge Energy Development Association, Jerry Powell,

President (7/13/10)

5. E-mail from Silicon Lighting in Union County, Art Grine (7/13/10)

6. E-mail from Lucky Corridor, LLC, Lynn Chapman Greene, President(7/16/10)

7. Letter from State of New Mexico Department of Game & Fish,

Matthew Wunder, Ph.D., Chief, Conservation Services Division (7/19/10)


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8. E-mail from Torrance County (Deer Canyon Preserve) resident, Nancy

Lockridge (7/22/10)

9. E-mail from Kirtland Air Force Base, Lt. Col. Greg Corkern and Lt. Col.Michael Doyle (including presentation of 58th Special Operations Wing

Training Areas (7/23/10)

10. Letter from Tri-State Generation and Transmission Association, Ron

Steinbach (7/26/10)

11. E-mail from Fort Bliss, Eric Walters (7/26/10)

12. Letter from The Wilderness Society, New Mexico Wilderness Alliance,

Sierra Club Rio Grande Chapter, Western Environmental Law Center,

Defenders of Wildlife, Western Resource Advocates, NRDC,

Southwest Environmental Center (7/27/10) including six (6) map

attachments

13. E-mail from The Nature Conservancy, Patrick McCarthy (7/27/10); letter

from The Nature Conservancy, Terry Sullivan (7/27/10); TNC Species

list; and TNC Corridor Analysis

14. Letter from Western Environmental Law Center , Monique DiGiorgio

(7/27/10)

15. Letter from First Wind, James Kelly (7/27/10)

16. Letter from US Army White Sands Missile Range, Daniel C. Hicks

(7/27/10)

17. Letter from Coalition of Renewable Energy Landowner Associations

(CRELA), Paul Stout (7/26/10, received 7/28/10)


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Roosevelt County


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From: Angela Gonzales-Rodarte

To: Joan Munsell

Subject: FW: RETA Transmission Plan and Roosevelt County Wind Projects

Date: Tuesday, June 29, 2010 1:36:52 PM

Attachments: RETA Comments from Roosevelt 062910.pdf

From: Greg Fisher [mailto:[email protected]]Sent: Tuesday, June 29, 2010 12:44 PMTo: Jeremy TurnerCc: [email protected]; Sarah Cottrell; [email protected]; 'OHare, Craig, EMNRD'; Miller,Brendan, EDD; 'Bowles, Thomas, GOV'; Grace, Anna (Tom Udall); Diane Ventura; Angela Gonzales-Rodarte; Mondragon, Fred, EDD; Oliver, Allan, EDD; 'Randy Knudson'Subject: RETA Transmission Plan and Roosevelt County Wind Projects

Dear Jeremy,

Attached are my comments on RETAs draft statewide renewable energy transmission plan. RETAs

recent progress toward transmission development and funding has been very impressive, and we

strongly support these efforts. Regarding the draft plan, we have the following comments:

1. The draft corridor plan should explicitly identify the major transmission route fromBlackwater DC Tie south to the Dora-Elida area and with connections east and westbound

to other statewide green grid elements. As you know, two major wind project developers

are willing to partner with RETA on transmission development, and one wind project in

particular is ready to move ahead very soon. RETAs acknowledgement and partnership

with shovel-ready clients can realistically bring $600 million in construction to eastern New

Mexico very soon with RETAs help. As you know these are not speculative projects and

the firms involved are very well-funded. Thanks for your help on this.

2. New Mexicos green grid and statewide transmission plan MUST recognize the immenseopportunities to export renewable power to the east (SPP) and not just to the west. While

PNM has been a great partner, eastbound transmission covers a large portion of our state.

Solar energy from New Mexico will be a hot commodity to export east in the future, and

we simply cant allow Arizona or other states to leapfrog over us because we did not plan

well for eastbound energy export connections at Blackwater and Artesia. The east-west

grid ties are in our state- lets acknowledge this and plan for it.

3. It seems that there are now three groups working on a statewide green grid (Tom Bowlescommittee, RETAs plans and a new Governors advisory committee). It seems that all

three of these efforts should be carefully coordinated to allow us to begin building key

elements of the statewide plan NOW so that we can quickly solidify our position as the first

state with a true renewable energy gathering and export system. Plus, the diverse talent

among these groups can only make such a plan stronger and more eligible for federal

support.

Roosevelt County Community Development Corporation
mailto:/O=CHOST/OU=EXCHANGE%20ADMINISTRATIVE%20GROUP%20(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=AGONZALES1mailto:[email protected]:[email protected]:/O=CHOST/OU=EXCHANGE%20ADMINISTRATIVE%20GROUP%20(FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=AGONZALES1


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The general concept of an efficient statewide transmission and gathering system that facilitates

poly-renewable energy production and balancing along with east and westbound exports is a

brilliant goal for New Mexico, especially given our excellent variety of renewable resources, ability

to plan together and move quickly to action, and given our ample right-of-way and location directly

on the backbone of two of Americas East-West grid ties (Blackwater and Artesia). We in Roosevelt

County are ready to build our part of this system as soon as possible to begin creating new green

jobs and green energy exports faster than competing states on either flank, with your assistance.Thanks again for all you do.

Best regards,

Greg Fisher

Greg Fisher, CEcD

Executive DirectorRoosevelt County Community Development Corporation

100 S. Avenue A

Portales, New Mexico 88130 USA

Office Direct 575-356-5354

Cell 575-607-8700

[email protected]

www.goportales.com

A 501(c)(3) corporation providing quality economic development services for Portales and RooseveltCounty, New Mexico as well as Eastern New Mexico University
mailto:[email protected]://www.goportales.com/http://www.goportales.com/mailto:[email protected]


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PNM reply to request for comments on New Mexico Renewable Energy Transmission Authority Proposed Renewable

Transmission Corridor Map

July 19, 2010 Page 1 of 3

PNMs comments on the New Mexico Renewable Energy Transmission Authority

(RETA) Proposed Transmission Corridor concepts

presented on June 11, 2010

On June 11, 2010, RETA presented conceptual transmission line corridors in partial

fulfillment of requests found in the 2009 New Mexico Senate Memorial Resolution

44.

Public Service Company of New Mexico (PNM) submits the following comments to

the conceptual transmission corridors presented at that RETA Transmission Corridor

Committee meeting.

PNM is and has for many years been an active leader in the facilitation of renewable

generation on its own system and as a part of the broader, regional and federal

dialogue on renewable energy issues. PNM has been a part of the solution to variable

generation issues through both near term and longer term initiatives that have been

implemented or are planned.

PNM supports RETAs efforts. New Mexico is poised to be a major contributor to the

renewable energy needs of the southwest. The state is at a critical juncture in the

development of such resources and the required delivery infrastructure. The

information and data now being accumulated by RETA in this process establishes a

good starting point. Since RETA is focused on export of renewable energy, ultimately

RETA needs to expand its efforts to beyond New Mexicos borders to ensure the

planning and coordination of any infrastructure expansion in New Mexico integrates

with the plans of the utilities across the region and meets the bigger picture needs of

the southwest.

Issue specific comments/suggestions:1. Clarify the intent of corridor definition. An accompanying white paper

explaining the intended uses for this information would allow all the users and

viewers of the corridor map to have shared expectations. This document

would ideally:

a. Explain how renewable energy developers and transmission plannersshould utilize the designated corridors.

b. Indicate if developers should view these designations as an indicatorthat areas adjacent to corridors are prioritized locations where

renewable energy development is encouraged.

c. Indicate what weight these existing and newly designated corridorsshould be given in the transmission development process.

d. Indicate if RETA is using these corridors to signify the areas where theyare most likely to participate in projects.

e. Document coordination with other agencies. Indicate where agenciesagree upon areas with low or minimal land development conflicts.

f. Indicate if the corridors are specific or generic as to location and width.

PNM


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g. WECC has developed specific transmission line separationconsiderations and criteria. They should be acknowledged by

reference.

2. The assumption that existing lines and easements could be upgraded andwould not require new rights of way or corridors may not be valid.

a. Many existing corridors are not suitable for expansion:i. Existing easement agreements, including easement width, were

developed for the current facility. Additional facilities within the

same easement may be impracticable, even with double circuit

construction. Some easements specify rights for construction,

operation, and maintenance of a single, voltage specific circuit.

Additional and/or upgraded facilities will generally require

additional time consuming permitting and easement

acquisition.

ii. Expansion of corridors may not be possible due to developmentof adjacent incompatible land use since initial construction.

Most existing corridors were developed 20 or more years ago

and land use has changed over time.b. The number of allowable or desirable facilities in an existing corridor

will usually need to be analyzed on a case by case basis.

c. If the assumption for use or expansion of corridors is not valid,additional corridors should be designated to accommodate renewable

energy.

3. Align corridors with priority development areasa. Notwithstanding the SM44 request to prioritize renewable energy zone

development, ultimately the market will determine the most desirable

locations to develop based on site specific energy quality, land

ownership, and specific linkages between renewable energy supplyingfacilities and electric utility demand.

b. Interconnection requests may, in reality, represent a de factoprioritization of renewable resource energy zones.

4. Identify linkages between corridors, export paths and targeted markets.a. There is a need to assess and identify which corridors can serve as

energy export paths and which paths support collector systems or

intrastate needs. Ideally those corridors should align with potential

identified local and out of state demand and proposed transmission

development plans in adjacent states. The WestConnects Southwest

Area Transmission Planning Group is currently working on relevantstudies through its Renewable Transmission Task Force. These and

other studies should permit RETA to identify target paths and the

capacity needed along those paths to deliver realistic quantities of

renewable energy to adjacent states and beyond over specific time

periods.


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b. Complete energy corridors, from generation to destination, need to beidentified clearly. This would include the use of the new corridors plus

the expectation to use some existing corridors. This would allow

evaluation of a complete system and if needed, the development of

alternatives.

c. The results of the planning processes for adjacent states may providea useful model for the coordination and designation of corridors in New

Mexico. It may be informative to include summaries of such processes

as part of the SM44 responses. The mandated corridor definition

processes in Colorado, Arizona and Texas (ERCOT) may be instructive

as further refinement and definition of New Mexico renewable energy

transmission corridors occurs.

d. Identify which markets individual corridors are intended to serve.e. Indicate the operating voltage range or megawatt capacity that is

considered appropriate for each corridor.

5. Grid Interconnection Requestsa. Interconnection requests are the appropriate source for identifying

potentially viable renewable energy development locales.

b. The source for Grid Interconnection Requests should be revisited andrevised to use perfected and currently pending requests with the three

New Mexico balancing area entities, Tri-state, El Paso Electric, and

PNM.

c. Areas without pending requests need not be prioritized fortransmission corridor development (unless they represent a critical

pathway for getting renewable generation to specific markets).

6. Acknowledge on-going regional transmission development projects and plans.Encourage consolidation of adjacent corridors as appropriate. Identify areaswhere it would be desirable to consolidate corridors and project assessments.


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Joan Munsell

From: Suzy Powell [[email protected]]Sent: Tuesday, July 13, 2010 10:05 PMTo: Joan MunsellSubject: "draft corridor"

In viewing the map on your website, it appears you used an old version map to identify the wind classes inEastern N.M. I refer you to AWS TRUEWIND map. This could greatly impact the need for more transmissioncorridors in Eastern N.M. especially with the contemplated completion of Tres Amigas in the next few years. I

also support and encourage RETA and the endeavors to improve transmission in New Mexico and give my full

support in that direction.Jerry Powell

575-357-8361

PresidentFrio Ridge Energy Development Association

Frio Ridge Energy Development Association


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Joan Munsell

From: [email protected]: Tuesday, July 13, 2010 4:14 PMTo: Joan MunsellSubject: transmission lines in union county

here in union county we have the natural resourses but no transmission lines to move the energy out. two company's thaI know of have come to Clayton and talked to us about wind turbines then they leave as fast as they came due to are lackof transmission lines we are trying to be a renewable friendly community, we beleive this could make us sustainable forgenerations to come pleasehelp us Thanks Art Grine

Silicon Lighting - Union County


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Joan Munsell

From: Jeremy TurnerSent: Friday, July 16, 2010 4:09 PMTo: Joan Munsell; Angela Gonzales-RodarteSubject: FW: Comments on draft corridors due July 27

Jeremy Turner

New Mexico Renewable Energy Transmission Authoirty

200 W. DeVargas St, Suite 4

Santa Fe, NM 87501

505-983-1594

505-699-6532

From: Lynn Greene [mailto:[email protected]]

Sent: Friday, July 16, 2010 1:09 PM

To: Jeremy Turner; [email protected]; [email protected]; [email protected]

Subject: Comments on draft corridors due July 27

Hi Jeremy, Greg, Carl, and Omar,

Im excited to see such a great group of people on the new transmission task force. Congratulations.

You have asked for comments:

1. Short-term, fix reliability problems first. The CO PUC has a paper a couple of years old on the reliability

problems in NE NM which need to be addressed by upgrades, loops in that area. The Lucky Corridor (hyperlink

below) addresses this. Does the PRC also have info on reliability problems in Taos, NE NM?

2. Short-term, plan east-west energy corridors. Lucky Corridor + Verde Project, BB345, SunZia, Sante Fe Line are

all east-west pathways. Short-term, I like our Lucky Corridor project because its only 130 miles, transports NM

not TX, renewables and gas, and we dont have to fix all of Albuquerques problems before grabbing some of

the CA clean energy market for NM. Because of western transmission problems, time is of the essence ingetting CA market share by being able to deliver some clean, firm energy to western markets in the next coupl

of years. Only limited amounts of energy can get to the LA Basin before future major transmission fixes are

completed. The goal is to get 24x7 NM energy there first, even if it is only 800MW or so, before the more

major transmission projects are required. Gas and water in the Raton area are important to claiming CA RECs.

Long term, energy resources from NM, CO and the Panhandle may support all of these east-west pathways.

Short-term, the NE NM energy resources are fabulous, the wind blows all year long, and economic developmen

is truly needed there, so those resources should be carried via the Lucky Corridor line.

3. Mid-term, create north-south backbone. If we assume that the HWY 385 corridor is one of the greatest energ

corridors in the nation (gas, coal, wind, solar, geothermal), we need to figure out how to inject that power to th

West without de-stabilizing the grid, which means moving the backbone of the Western grid further to the east

and completing the north-south 345 along I-25 corridor. Long-term, the HPX would provide backbone at the

eastern boundary of the western grid. Mid-term, fixing existing gaps in the 345 north-south along I-25 may be

priority.

4. Mid-term, connect a new Santa Rosa substation to Las Vegas and, long-term to Tucumcari-Gladstone.Because of the wind developers wanting to move from Storrie Lake to Springer and willing to upgrade that line,

a new line from Santa Rosa to Las Vegas could create another reliability loop and another pathway for wind in

eastern NM to get west without having to have it all on the Blackwater 345.

5. Mid-term, replace the 345 from Ojo to Four Corners with a DC line. The initial Lucky Corridor project, below,

will carry enough NM energy to fill up the 345 from Ojo to Four Corners. We will have room for expansion,

additional lines, later. However, that cannot happen until PNM replaces the 345 from Ojo to FC (as well as Tri-

Lucky Corridor, LLC


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State replacing its 345 at Taos?), with a large capacity DC line. It may be possible to do this without widening

that 345 corridor. Then a heck of a lot of gas and renewables could move west.

6. Long-term, please look at connecting Vilas and Gladstone. The Colorado Coordinated Planning Group (CCPG)

currently beginning a study on possibly connecting the planned (2016) new line to the Vilas substation in Baca

County, CO to Gladstone or Guadalupe sometime in the next 20 years. Reliability, backbone would be

improved.

I dont expect to be able to personally attend all your meetings or to take any policy role, but wanted to pass along thes

comments and ask for your support for the Lucky Corridor path in your upcoming deliberations.

Best regards,

Lynn Greene

Lynn Chapman Greene, President

Lucky Corridor, LLC

(303) 681-3073 office

(303) 596-4821 cell

www.luckycorridor.com

Download the Lucky Corridor Detailed Proposal (PDF)


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State of New Mexico Department of Game & Fish


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Joan Munsell

From: Nancy Lockridge [[email protected]]Sent: Thursday, July 22, 2010 1:57 PMTo: Joan MunsellSubject: Torrance County Transmission Lines

Being a homeowner in Deer Canyon Preserve with a view of the railroad tracks and Hwy. 60, I

am most interested in developments regarding more detailed maps and possible placement of

transmission lines. Please advise me when more accurate maps have been developed along with

any pertinent news concerning any possible effects on our home views and the investment we

made when building in Deer Canyon.

Thank you,

Nancy Lockridge

[email protected].

Torrance County Resident


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Joan Munsell

From: Doyle, Michael D LtCol USAF AETC 58 OSS/CC [[email protected]]Sent: Friday, July 23, 2010 10:21 AMTo: Joan MunsellCc: Corkern, Gregory B LtCol USAF AETC 58 OSS/DOSubject: 58th Operations Support Squadron's information for RETAAttachments: 58 SOW Response to RETA (14Jul10).pptx

Joan,

Please note that the 58 SOW at Kirtland AFB, NM fully supports the WhiteHouse's initiative to encourage green energy options. We are happy tosearch for cooperative solutions which allow our nation to produce energywhich sustains our environment while at the same time allows us to continuetraining the USAF's premiere Personnel Recovery and Special Operations crewsfor the conflicts of today and tomorrow.

After reviewing the proposed powerline transmission areas presented at lastmonth's public presentation as well as your website, I'm pleased to note

that our self-identified low altitude areas (Low Altitude Training andNavigation - LATNs), are not impacted. I've attached a short powerpointslideshow. Some of the maps used come from your website. I placed a fewgraphics on these slides in order to show the predominance of 58 SOW's lowaltitude flying with respect to some of the proposed powerline transmissionrouting.

As a general rule, any new powerline transmission or windmill constructionproject within NM in the area surrounding Albuquerque will have some impacton low-level helicopter, tilt-rotor, and fixed wing flying training. It isimportant to understand that the 58 SOW can continue to train with thecurrently proposed routing. However, should these projects begin toencroach upon our LATNs to a great degree our training could be negativelyimpacted.

Respectfully,

Lt Col Greg Corkern58 OSS/DODSN: 263-5445COMM: 505-853-5445

Lt Col Michael DoyleCommander, 58th Operations Support Squadrondsn 263-5104 / bb (505)270-2096

From: Joan Munsell [mailto:[email protected]]Sent: Tuesday, July 13, 2010 3:57 PMTo: Joan MunsellSubject: Governor's Press Release

Kirtland Air Force Base


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Good afternoon~

Please direct your attention to RETA's website (www.nmreta.org) to read(under "Documents" / "Press Releases"):

"Governor Richardson Announces Formation of Task Force to Map StatewideClean Energy Transmission System", July 8, 2010.

Also, please note that there is a reminder to submit all public commentsregarding the RETA Transmission Corridor Committee's "draft corridors" nolater than July 27, 2010 (to be included in the July 28th meeting'sdiscussion) to: [email protected]

Thank you!

Joan

Joan Munsell

Administrative Manager

New Mexico RETA

200 W. DeVargas Street - Suite 4

Santa Fe, NM 87501

505-983-4458


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58th Special OperationsTraining Areas

Lt Col Greg Corkern

58th OSS Director of Operations

As of 14 Jul 10


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NM Collector System Cow/58SOW LATNs plotted

LATN

(LATN = Low Altitude Tactical Navigation Area)

Training the Bestto Lead the Rest

LATN


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PNM Collector Systew/58SOW LATNs plotted

(LATN = Low Altitude Tactical Navigation Area)

Training the Bestto Lead the Rest

LATN

LATN


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Potential Routing Solutiow/58SOW LATNs plotted

LATN

Routeare be

river cfor 58

LATN


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Tri-State Generation and Transmission Association


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towers would likely have to be fenced thereby creating large multipleobstacles.f. Power lines in theater that present a problem are typically blown anddestroyed. Also, in a combat operation commanders may accept a higher level

of risk.

Thanks for the opportunity to comment. Eric Wolters, Fort Bliss, DPW-E.


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July 27, 2010

Delivered via electronic mail [email protected]

Ms. Joan MunsellNew Mexico Renewable Energy Transmission Authority

200 West DeVargas St., Suite 4Santa Fe, NM 87501

Re: Comments on Proposed RETA Transmission Corridors

Dear Ms. Munsell:

Please accept and fully consider these scoping comments on the proposed RETA Transmission

Corridors (Corridors) on behalf of The Wilderness Society, Defenders of Wildlife, New MexicoWilderness Alliance, Sierra Club Rio Grande Chapter, Western Resource Advocates, Western

Environmental Law Center, NRDC and the Southwest Environmental Center. We appreciate the

opportunity to comment.

Clearly, our nations growing addiction to fossil fuels, coupled with the unprecedented threats

brought about by global warming, imperil the integrity of our wildlands as never before. To sustainboth our wildlands and our human communities, the undersigned believe the nation must transition

away from fossil fuels as quickly as possible. To do this, we must eliminate energy waste, moderate

demand through energy efficiency, conservation, and demand-side management practices, andrapidly develop and deploy clean, renewable energy technologies, including at the utility-scale.

New transmission lines will also be necessary in some cases to bring remote renewable energy

resources to population centers. Renewable energy and associated transmission development is not

appropriate everywhere, however, and thorough review under the National Environmental Policy

Act of 1969 (NEPA) is an essential part of determining which of the many proposed utility-scaleprojects should be permitted to go forward.

We strongly believe that the long-term, environmentally responsible success of RETAs renewable

energy transmission program depends on the development of policies and guidelines that guide

projects to the most appropriate locations, thus limiting environmental impacts and reducingobstacles to construction of the most appropriate projects. Designation of appropriate transmission

corridors can be an effective way of achieving these goals, as well as increasing public awareness

and engagement in the process. We are submitting these comments with the intent that in

collaboration with the public and interested stakeholders RETA can identify Corridors that providetransmission access to renewable energy without unacceptable impacts to the wildlands, water and

wildlife of our southwestern landscape.

Introduction and Recommendations to Improve the Corridors Identification Process

Given the limited amount of information that is currently available on the RETA website about theultimate purpose and use of the Corridors and the process by which they were identified, it is

difficult to comment on the broader goals and assumptions behind the Corridors. These are

important considerations, and we recommend that RETA provide this information to the public assoon as possible so input may be gathered on these questions.
mailto:[email protected]:[email protected]:[email protected]:[email protected]


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Without the benefit of this information, these comments are focused on four issues: 1) the need to

ensure transmission corridors identified for renewable energy truly do serve renewable energy and

do not facilitate additional fossil fuels development; 2) the degree to which these corridors do or do

not align with areas already identified through state and regional processes as high potential forrenewable energy development; 3) general recommendations on areas to prioritize and avoid for

siting transmission lines; and 4) specific concerns we have identified regarding the current locationsof the Corridors.

We are also concerned about the lack of clarity in the commenting process. Though the RETA

website says that comments are due by July 28th

, we learned on the morning of July 27th

that theTransmission Committee will be making revisions to their map on July 28 th, and that if we want our

comments to be considered as part of that revision process, we need to submit them by the

afternoon of July 27th

.

We are submitting our comment letter on the afternoon of July 27 th so that our recommendations

can be considered as part of the Corridor revisions meeting on July 28th

. However, because we had

planned on submitting the comments for the July 28th deadline listed on the website, some groupsmay not have had time to approve signing on to the comments. If this is the case, we will be

submitting a supplemental version of our comments with additional signatories on July 28th

.

We also request that RETA provide clear instructions to the public for commenting on the Corridorsgoing forward.

I. RETA Should Employ all Available Tools to Ensure that the Corridors ServeRenewable Energy and do not Facilitate Additional Fossil Fuels Development

RETA should do everything within its authority to ensure that the Corridors facilitate the

development and transmission of renewable energy and do not facilitate additional fossil fuels

development.

Siting Corridors in areas with high renewable energy development potential and low fossil fuelsdevelopment potential is one strategy which RETA should employ.

RETA should also consider any other mechanisms available to ensure that the Corridors do notfacilitate additional fossil fuels development. Although RETA does not have the authority to

approve or deny projects, or condition approvals of projects, it can impose requirements (such as the

30% renewables requirement currently in place) for projects that it finances. There may be other

mechanisms by which RETA could help ensure that the Corridors serve renewables, and/or otherforums in which RETA could strongly advocate for prioritized access to renewable energy in the

Corridors.

Recommendations: RETA should explore and implement all available options, including but not

limited to those described above, to ensure that the Corridors serve renewable energy and do not

facilitate additional fossil fuels development.

II. RETA Should Provide Public Explanation of Which Renewable Energy Resourcesor Zones the Corridors Intend to Serve


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In an attempt to qualitatively gauge how well the Corridors would serve high potential renewableenergy development areas in New Mexico, we have overlaid the Corridors with existing priority

zones or high potential renewable energy development areas identified through various regional

processes.

a. Western Governors Association Western Renewable Energy Zones Project Qualified Resource Areas

The Western Governors Association (WGA), through their Western Renewable Energy Zones

Project (WREZ), has identified high priority renewable energy development areas in the western

states, western Canada and Baja Mexico. These Qualified Resource Areas (QRAs) haveundergone some screening to eliminate areas already excluded by law or policy, sensitive wildlands,

and other areas inappropriate for industrial developments such as renewable energy projects.

However, this screening project is not complete, and site-specific environmental analyses will be

necessary for any projects proposed within QRAs. In particular, additional attention is needed toaddress potential impacts to wildlife habitat and migration corridors.

Despite these limitations, the QRAs are valuable in identifying broad areas of high renewableenergy development potential.

As shown in the attached map (Attachment 11

), some of the Corridors overlap well with some ofthe QRAs, some of the Corridors do not overlap with the QRAs, and some of the QRAs are not

served by any Corridors.

Specifically, Corridors 2 and 5-8 intersect several of the QRAs. Corridors 1, 3, 4, 10 and 11 do not.

The QRAs to the north and south of Corridor 1 do not have any Corridors serving them.

b. Bureau of Land Management Solar Energy Study AreasThe Bureau of Land Management (BLM) has identified 24 Solar Energy Study Areas (SESAs) as

part of their ongoing development of a Programmatic Environmental Impact Statement for SolarEnergy Development on Public Lands. These SESAs are still being modified and improved2

1

Note that the map in Attachment 1 includes a legend that should also be used for the close-up maps included as

Attachments 2-6.

, but

were initially screened by BLM to identify high quality solar resources, low slope, and limited

2The appropriateness of the New Mexico SESAs, in particular, is in question. Though the BLM Las Cruces field office

originally identified the Mason Draw and Red Sand SESAs as potentially appropriate areas for solar development, the

field office has undertaken subsequent, more detailed review and identified unacceptable conflicts. Because of theseconflicts with natural and cultural resources and wildlife management areas, the field office has sent a letter to BLM

Washington Office recommending that both the Mason Draw and Red Sand SESAs be dropped from consideration. It

is clear that much potential for conflict exists in these areas, and BLM will need to study these areas in detail to

determine whether they are appropriate for inclusion as SESAs. The Afton SESA appears to have the least conflicts of

the New Mexico SESAs, with areas of potential for high reptilian diversity in the eastern portion of the SESA being the

most significant issue we have identified at this time.


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conflicts with wilderness quality lands, sensitive wildlife habitat, cultural resources, and othersensitive resources, values and uses.

As shown in Attachment 2, none of the Corridors serve the SESAs.

Recommendations: RETA should analyze whether it is possible to identify Corridors that serve

areas that have been identified as having high renewable energy potential while avoiding protectedlands and sensitive areas.

III. Siting Corridors Recommendations on Areas to Avoid and Ways to LimitImpacts by Maximizing the Use of Impaired Lands and Existing Infrastructure

Development of large-scale transmission facilities will have significant impacts on the lands upon

which they are located. These impacts include direct impacts from road construction, siting of

tower pads and support infrastructure, and potential for bird and bat collisions with towers andwires; as well as indirect impacts such as habitat fragmentation, increased predation from perching

raptors, and viewshed impacts. An inappropriately sited and constructed transmission line has the

potential to cause significant damage to the environment. Accordingly, it is crucial that RETAcommit to avoiding sensitive areas, obtain necessary information on lands with wilderness

characteristics and consider maximizing use of existing development corridors in siting

transmission lines.

a. Areas to AvoidRETA should identify areas to avoid in determining Corridor locations. Certain places are not

appropriate for transmission lines and certain categories of lands should be avoided. Based on their

important natural values and potential for damage from the construction, use and maintenance of

transmission lines, we recommend that RETA commit to not siting Corridors in the following areas:

1. Wilderness Areas;2. Wilderness Study Areas (WSAs);3. National Monuments;4. National Conservation Areas;5. Other lands within BLMs National Landscape Conservation System (NLCS), such as

Outstanding Natural Areas;

6. National Historic and National Scenic Trails;7. National Wild, Scenic, and Recreational Rivers, study rivers and segments, and

eligible rivers and segments;8. National Parks9. U.S. Fish and Wildlife Service National Wildlife Refuges10.Areas of Critical Environmental Concern (ACECs);11.Special Recreation Management Areas;12.U.S. Forest Service Inventoried Roadless Areas;13.Threatened, endangered and sensitive species habitat, as well as critical cores,

migration routes and linkages for wildlife;

14.Citizen-proposed wilderness areas and wilderness inventory areas;15.Other lands with wilderness characteristics;16.Lands protected by the State of New Mexico; and


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17.Culturally Sensitive AreasThis category should also include lands that are included in pending legislation for designation in

one of the above categories or would otherwise include provisions that prohibit siting of

transmission lines.

b. Maximizing Use of Impaired Lands and Existing InfrastructureIn addition to avoiding ecologically-sensitive lands, we recommend that already impaired lands be

considered first for Corridors.

Existing Rights of Way, degraded agricultural lands, and other already impacted areas provide

opportunities for siting transmission lines without loss of other uses and values. Such sites are often

close to existing infrastructure, which provides additional benefits. Proximity to existing

infrastructure will minimize new road construction or major roadway improvements (such as pavingand widening), avoiding another set of impacts.

Recommendations: To avoid unnecessary impacts, RETA should ensure that the Corridors avoidthe areas identified in section III a. and should specifically prioritize use of lands identified in

section III b. that are not identified for restoration.

IV. Specific Concerns Regarding Current Corridor LocationsAs described in section III, RETA should ensure that the Corridors avoid sensitive areas andprioritize areas with existing disturbance.

We have identified a number of specific concerns regarding the Corridors as currently proposed.

Attachment 1 identifies the Corridors as numbered below.

a. Corridor 1: Conflicts with Designated Wilderness and Other Sensitive Areas in GilaNational Forest

Corridor 1 is proposed to cross from the heart of the Gila Wilderness just northeast of Gila

Hotsprings and other adjacent roadless country, across state lands to just south of the New MexicoWilderness Alliance Continental Divide Citizens Wilderness Inventory (CWI) Area (see

Attachment 3).

Construction of transmission lines is not permitted in federally designated wilderness areas, and thesection of Corridor 1 that intersects the Gila Wilderness should be removed.

In addition, Corridor 1 crosses ecologically sensitive riparian areas at 6 locations identified as partof The Nature Conservancys Conservation Portfolio.

The Gila Wilderness contains world-renowned wildlife habitat and areas of high scenic, recreationaland cultural values. The area supports a healthy mountain lion population, porcupines, bobcats,

ringtails, coatis, several species of bats, many small mammals, and 291 species of birds, including

golden eagles, goshawks, and the great horned, flammulated, and Mexican spotted owls.Altogether, there are 453 species of vertebrates documented in the Gila Wilderness, including 35


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6

sensitive, threatened, or endangered species. Examples of threatened and endangered speciesinclude the threatened Mexican spotted owl, and the endangered Mexican gray wolf and Gila trout.

CWI Areas are lands that have been inventoried by citizens groups, conservationists, and agencies

and found to have wilderness characteristics, including naturalness, solitude and the opportunityfor primitive recreation. BLM defines wilderness characteristics in the Record of Decision for the

Arizona Strip Resource Management Plan as follows:

The following wilderness characteristics will be maintained:

High Degree of Naturalness: Lands and resources affected primarily by the forces ofnature and where the imprint of human activity is substantially unnoticeable.

Outstanding Opportunities for Solitude: When the sights, sounds, and evidence of otherpeople are rare or infrequent and where visitors can be isolated, alone or secluded fromothers.

Outstanding Opportunities for Primitive and Unconfined Recreation: Where the use ofthe area will be through non-motorized, non-mechanical means, and where no orminimal developed recreation facilities are encountered. (Record of Decision, p. 2-67)

Beyond these core values, these lands also provide important wildlife habitat, cultural and scientific

resources, invaluable ecosystem services including clean air and water, important economicbenefits, and many other resources and values.

The sensitive nature of these lands and their resources and values makes their protection critical.The industrial nature of transmission development makes it incompatible with wilderness quality

lands.

b. Corridor 2: Conflicts with New Mexico Wilderness Alliance Citizens WildernessInventory Areas and Other Sensitive Areas on the Sacramento Escarpment

Corridor 2 is proposed to run all the way across the Guadalupe Mountains, on Forest Service lands.The Sacramento Escarpment, which rises over 4,000 feet above the Tularosa Valley to an elevation

of 8,100 feet, is one of the more spectacular topographic features in the state. In addition to

potentially impacting the Guadalupe Escarpment Area of Critical Environmental Concern (ACEC),the proposed corridor would bisect and run adjacent to the Guadalupe Escarpment CWI Area, and

would also clip the Rawhide Canyon CWI Area on its southwestern side and Long Canyon CWI

Area on its southwestern side. A transmission line in this area would greatly diminish the primitivenature of this area, and would be antithetical to maintaining the wilderness characteristics and

values of numerous wild areas throughout this mountain range (see Attachment 4).

The Lincoln national forest supports a high diversity of habitats, which in turn support a richassortment of native animals and plants, all of which would have to be addressed by any new

transmission proposed for the area. The Guadalupe Mountains provide habitat for a diversity of

plant and animal species, including federally threatened species such as the threatened Mexicanspotted owl and state-listed species such as the gray-banded Kingsnake, Mottled rock rattlesnake,

Gray vireo, and Desert bighorn sheep. There are at least 18 rare plant species located in or near the

Sacramento Escarpment unit according to the New Mexico State Heritage Program (1984). Someof these include Sacramento prickly poppy, Alamo penstemon, button cactus, and Villards


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pincushion cactus. Over half of all the threatened or endangered plants in New Mexico and one-quarter of all the rare or endemic animals in New Mexico are found in the Lincoln National Forest.

Also, over 300 species of wildlife, including almost 200 types of birds, are found in the Lincoln.

The Guadalupe Mountain Escarpment is also contains high quality nesting and foraging habitat for

numerous raptor species such as peregrine falcon, which could potentially conflict with newtransmission lines.

Scenic quality in the Sacramento Mountains is superb. The BLM Sacramento Escarpment ACECwas designated in part to protect the scenic values of the Sacramento Escarpment. A new

transmission line could potentially impair scenic and other qualities for which this ACEC was

designated.

c. Corridor 3: Conflicts with Proposed Ute Mountain San Antonio NationalConservation Area and Winter Range ACEC

Corridor 3 is proposed to bisect the northwestern portion of the proposed Ute Mountain San

Antonio National Conservation Area and the existing BLM Winter Range ACEC. The proposed

NCA includes many of the same qualities as the CWI Areas described above, and the Corridorsshould not cross the proposed NCA. The Winter Range Area of Critical Environmental Concern is

an area located within the San Antonio Special Management Area, and was designated by the BLM

to protect and manage for important winter range for mule deer, elk and pronghorn. In addition, theACEC contains a portion of the Old Spanish Trail and contains culturally significant sites that were

used by the Apache and Ute bands. The BLMs draft revised Resource Management Plan calls for

expanding the Winter Range ACEC significantly to cover the entire San Antonio SpecialManagement Area. Corridor 3 would also cross the Rio San Antonio, a sensitive riparian corridor

that flows across both the Carson National Forest and adjacent BLM lands. This area of the Carson

National Forest supports habitat for a wide variety of wildlife species. The northernmost portion of

this proposed corridor crosses into a Conservation Portfolio site of The Nature Conservancy, which

is an indication this area is of high biological significance (see Attachment 5).

d. Corridor 4: Need to Consult with Jicarilla Apache Indian Reservation; Conflicts withEdward Sargent State Wildlife Management Area

Corridor 4 would begin in and cross the northwestern corner of the Jicarilla Apache sovereign

lands. Any proposal for a new transmission line would need express permission and engagement

from the Jicarilla.

The proposed corridor would also cut across the middle of the Edward Sargent State Wildlife

Management Area, which was initially conserved by the Nature Conservancy (See Attachment 6).It also bisects the Nature Conservancys conservation portfolio, an indication that this area containsareas of high conservation value. There are numerous sensitive resources and values in this area that

would have to be addressed by any new transmission proposals. The Edward Sargent is now one of

the largest properties owned and managed for wildlife values by the state of New Mexico. The areaborders the Chama River, and contains a major portion of the Chamita River Valley, which forms a

broad basin of grasslands that provide excellent habitat for deer and elk, as well as habitat for trout

and other aquatic species. Other wildlife species can be found in this wildlife management area,including coyote, porcupine, black bear and beaver, mountain lion and snowshoe hare. The area


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8

supports habitat for numerous birds, including American Kestrel, mountain bluebird, broad-tailedand black-chinned hummingbird, northern flicker, Stellers jay, Clarks nutcracker, mountain

chickadee, brown creeper, warbling vireo, common nighthawk, red-winged blackbird, and northern

shrike, as well as the occasional wild turkey or blue grouse. This area may also contain potential

habitat for the endangered lynx, as the southern boundary of its habitat extends to the Colorado stateline. The Edward Sargent property consists of high aspen meadows, alder-lines streams, oak groves,

and grassy meadows. Corridor 4 would also have to cross the Chama River.

In addition, Corridor 4 cuts through key north-south migration corridors for both mule deer and elk.

The protection of these movement corridors is important for these species survival, especially in

the face of climate change. The elk population in this area is one of the largest in the country andthe hunting revenues generated are important to many families, ranches, cultures, local and rural

communities and their economies, and county and state governments. Other proposed corridors may

also bisect important wildlife movement areas, however, more time to study the proposed corridors

would be needed to provide a full analysis of the impacts to wildlife movement.

Recommendations: RETA should revise the Corridors to exclude any intersections with federally

designated wilderness areas, CWI Areas and other areas proposed for conservation, including theproposed Ute Mountain San Antonio NCA, ACECs, as well as other extremely sensitive areas.

RETA should also address how impacts to other sensitive resources and values intersected by the

Corridors would be avoided, minimized and mitigated with off-site mitigation measures.

Thank you for your thorough consideration of these comments.

Sincerely,

Alex Daue, Renewable Energy Coordinator

The Wilderness Society1660 Wynkoop St. Suite 850

Denver, CO 80202

Nathan Newcomer, Associate Director

New Mexico Wilderness Alliance

P.O. Box 25464

Albuquerque, NM 87125

Dan Lorimier, Conservation Coordinator

Sierra Club Rio Grande Chapter

300 N Downtown Mall, 2nd floor

Las Cruces, New Mexico 88001

Monique DiGiorgio, Conservation Strategist

Western Environmental Law Center

520 E. Babcock Street

Bozeman, Montana 59715

Matt Clark, Southwest Representative

Defenders of Wildlife110 S. Church Ave. Suite 4292

Tucson, AZ, 85701

Gary Graham, Transmission Project Director

Western Resource Advocates

2260 Baseline Rd, Ste 200

Boulder, CO 80302

Helen OShea, Deputy Director, Western

Renewable Energy Project

NRDC111 Sutter Street, 20th Floor

San Francisco, CA 94104

Kevin Bixby, Executive Director

Southwest Environmental Center275 North Downtown Mall

Las Cruces, NM 88001-1213


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1

Joan Munsell

From: Patrick McCarthy [[email protected]]Sent: Tuesday, July 27, 2010 3:07 PMTo: Joan MunsellSubject: Comments on RETA proposed transmission corridorsAttachments: TNC_Comments_RETA_July_2010.pdf; TNC_RETA_Species_List.pdf;

TNC_RETA_Corridor_Analysis.pdf

Dear Ms. Munsell,

Please find attached The Nature Conservancys initial comments on the Renewable Energy Transmission Authoritys

proposed transmission corridors. Also attached are (1) a map showing our spatial analysis of the proposed corridors and

important conservation areas, and (2) a list of the species and ecological system types that occur in the conservation

areas that are crossed by the proposed corridors.

The Nature Conservancy fully supports the Renewable Energy Transmission Authoritys mission to promote the

development of renewable energy in New Mexico. We are confident that the Transmission Committee will be able to

identify suitable renewable energy development zones in New Mexico and we are eager to cooperate with RETA in tha

process. We appreciate RETAs invitation to provide input and realize the complexity involved in such a critical endeavoOur staff is available to discuss the issues raised in this letter, if needed.

Sincerely,

Patrick McCarthy

Patrick McCarthy

Director, Conservation Programs (New Mexico)Director, Southwest Climate Change Initiative

[email protected]

(505) 988-1542 ext. 217 (office)

(505) 988-4095 (fax)(505) 310-2117 (mobile)

http://nmconservation.org/

The Nature Conservancy

212 East Marcy Street, Suite 200

Santa Fe, NM 87501


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The Nature Conservancy in New Mexico212 East Marcy StreetSanta Fe, NM 87501Tel: (505) 988.3867Fax: (505) 988.4905

July 28, 2010

Delivered to:[email protected]

Ms. Joan MunsellTransmission Corridor Committee

New Mexico Renewable Energy Transmission Authority200 West DeVargas Street, Suite 4Santa Fe, New Mexico 87501

Re: Comments Concerning Proposed RETA Transmission Corridors

Dear Ms. Munsell:

We appreciate the opportunity to provide comments on the transmission corridors proposed byNew Mexicos Renewable Energy Transmission Authority. We look forward to working

cooperatively with the Transmission Corridor Committee and RETA in addressing the

conservation issues involved with this project.

The mission of The Nature Conservancy is to preserve the plants, animals and naturalcommunities that represent the diversity of life on Earth by protecting the lands and waters they

need to survive. The Conservancy recognizes that climate change is one of the most critical

threats to biodiversity around the world and we understand the need for renewable energy toreduce greenhouse gases and lessen the impact of global warming. The Conservancy also

understands that the current infrastructure of energy transmission will need to be expanded to

effectively distribute growing renewable energy supplies to consumers. Our primary concern isthat energy transmission corridors be located such that their direct impact on biodiversity is

minimized, even as New Mexico develops its clean energy infrastructure.

The Nature Conservancy has made significant investments in science-based tools to help usachieve our mission. Specifically, our Ecoregional Assessments and the Development by Design

approach have direct application to the identification and resolution of conservation concerns

within the proposed RETA Transmission Corridors and associated renewable energydevelopments in New Mexico.

Using our Ecoregional Assessments as a guide, the Conservancy has reviewed the draft corridorsproposed by RETA on June 11, 2010. We have identified eleven areas of concern in the map

attached as reference in our cover e-mail message. We have also attached a list of the important

species and ecological system types associated with each of these eleven areas.
mailto:[email protected]:[email protected]:[email protected]


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Below are preliminary comments that summarize our concerns about these conservation areas.The Nature Conservancy will provide additional comments about these places, as well as

information about the Development by Design process, to RETA within the 30-day comment

period.

Conservation Concerns Regarding Proposed Transmission Corridors

Gila Wilderness and Gila River Complex: The Gila Wilderness became the first congressionally

designated wilderness area in the U.S. in 1924. The area is home to a vast number of plant and

vertebrate species, and has one of the highest concentrations of threatened and endangered

species in New Mexico. The Gila provides habitat for 35 imperiled vertebrates, including theMexican wolf, the Gila trout and the Mexican Spotted Owl, all three of which are listed as

endangered or threatened by the U.S. Fish and Wildlife Service. Moreover, construction of

transmission lines within a federally designated Wilderness Area would be extremely difficult, ifnot impossible, to permit.

The Gila River is one of the last remaining free-flowing perennial rivers in the U.S. Southwest.The Gila River Complex conservation area contains high-quality riparian and aquatic

communities that support a host of endemic, rare, and declining species. A full range of desert,

transitional and montane species and communities is represented at the site, which stretches from

the river's headwaters down into the Apache Highlands near Arizona. The conservation areacontains 57 species and natural communities of concern, including several federally listed

threatened and endangered species. Avoidance of development within the Gila River corridor is

critical for preservation of biodiversity of the area.

Guadalupe Mountains and Escarpment: The Guadalupe Mountains and Escarpment contain awide range of ecosystems that provide habitat for an enormous variety of plant and animal

species. There are more than 1,000 species of plants, 60 species of mammals, 289 species of

birds, and 55 species of reptiles in the area. The Guadalupe Mountains are home to theendangered grey-banded kingsnake, the Davis Mountain Cottontail, the endangered Kuenzlers

hedgehog cactus, and 16 species of bats. The Guadalupe Mountains provide critical wildlife

habitat that should be carefully preserved.

Edward Sargent Wildlife Management Area: The Edward Sargent Wildlife Management Area is

a 20,400 acre wilderness originally purchased by The Nature Conservancy and now owned and

managed by the New Mexico Department of Game and Fish. The site borders the Chama Riverand also contains a large stretch of the Rio Chamita and Nabor Lake. The area is renowned for

its excellent trout fishing and elk hunting. The wildlife area is also home to snowshoe hare,

turkey, blue grouse, and the Rio Chamita valley is often dense with wildflowers. The area is apopular destination for hiking, mountain biking, and horseback riding. The Edward Sargent

WMA is a natural gem of Northern New Mexico, and the utmost care should be taken to protect

the pristine beauty of this sensitive area.

Ute Mountain and Rio San Antonio Gorge: These areas have been proposed for federal

designation as National Conservation Areas, and they are currently designated and managed bythe BLM as the Winter Range Area of Critical Environmental Concern (ACEC). The Ute


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Mountain and Rio San Antonio Gorge region supports large herds of elk and abundant wildlife.The Rio San Antonio provides regionally important wildlife habitat. Energy development and

transmission in this area would appear to conflict with the proposed designation of Ute Mountain

and San Antonio Gorge as a National Conservation Area.

Prairie Conservation Areas of Northeastern New Mexico: Ecological analyses by theConservancy and others have shown that, of the many habitats in New Mexico, grasslands andriparian areas are at greatest risk of degradation or loss and, regionally, are the most unique or

irreplaceable. The shortgrass prairies of northeastern New Mexico represent some of the largest

unfragmented grasslands within the North American Great Plains. The proposed transmission

corridors overlap with seven prairie conservation areas. Avoidance of additional site disturbanceand fragmentation are important to preserving the biodiversity and character of New Mexicos

prairies.

Summary

The Nature Conservancy fully supports the Renewable Energy Transmission Authoritys missionto promote the development of renewable energy in New Mexico. We are confident that the

Transmission Committee will be able to identify suitable renewable energy development zones

in New Mexico and we are eager to cooperate with RETA in that process. We appreciate

RETAs invitation to provide input and realize the complexity involved in such a criticalendeavor. Our staff is available to discuss the issues raised in this letter, if needed.

Sincerely,

/S/ Patrick D. McCarthy, Director of Conservation Programs

FOR

Terry Sullivan

New Mexico State Director


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TNC Conservation Area Targets

Name Duran Grasslands

Scientific Name Common Name

Astragalus siliceus Flint Mountain Milk-vetch

Western Great Plains Closed Depression Wetland

Western Great Plains Shortgrass Prairie

Name Gila River Complex


Accipiter gentilis Northern Goshawk

Agosia chrysogaster Longfin Dace

Allium gooddingii Goodding's Onion

Apachean Grassland and Savanna Condition Class A

Apachean Grassland and Savanna Condition Class B

Apachean Shrubland

Apacheria chiricahuensis Cliff Brittlebush

Arizona Sycamore - Emory Oak

Arizona Sycamore / Sand Dropseed

Aspidoscelis flagellicauda Gila Spotted Whiptail

Astragalus naturitensis Naturita Milk-vetch

Athene cunicularia hypugaea Western Burrowing Owl

Atriplex polycarpa Shrubland Cattle-spinach Shrubland

Besseya oblongifolia Egg-leaf Coral-drops

Bufo microscaphus Arizona Toad

Buteo albonotatus Zone-tailed Hawk

Buteogallus anthracinus Common Black-Hawk

Canis lupus baileyi Mexican Wolf

Caprimulgus vociferus Whip-poor-will

Cardellina rubrifrons Red-faced Warbler

Castilleja mogollonica White Mountains Paint Brush


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Catostomus clarkii Desert Sucker

Catostomus insignis Sonora Sucker

Catostomus latipinnis Flannelmouth Sucker

Chihuahuan Desert Scrub

Cicindela oregona maricopa Maricopa Tiger Beetle

Cienega

Coccyzus americanus occidentalis Western Yellow-billed Cuckoo

Colaptes chrysoides Gilded Flicker

Conioselinum mexicanum Mexican Hemlock-parsley

Contopus cooperi Olive-sided Flycatcher

Cyprinodon macularius macularius Desert pupfish

Dendroica petechia Yellow Warbler

Desert riparian shrubland and woodland

Desert Wash

Desert-willow Intermittently Flooded Shrubland Allian

Douglas Fir Forest Community (specific)

Draba mogollonica Mogollon Whitlowgrass

Eleocharis palustris/Anemopsis californica Marsh Spikerush / Yerba Mansa Herbaceous Vegetatio

Empidonax traillii extimus Southwestern Willow Flycatcher

Empidonax wrightii Gray Flycatcher

Erigeron hessii Hess' Fleabane

Eriogonum heermannii var. apachense Apache Wild Buckwheat

Eumops perotis californicus California Bonneted Bat

Falco peregrinus anatum American Peregrine Falcon

Fremont Cottonwood Riparian Woodland Community (

Gila intermedia Gila Chub

Gila robusta Roundtail Chub

Glaucidium brasilianum cactorum Cactus Ferruginous Pygmy-owl

Haliaeetus leucocephalus Bald Eagle

High diversity high elevation forests and meadows of a


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Hyla eximia

Interior Riparian Marsh

Ixobrychus exilis hesperis Western Least Bittern

Junonia genoveva nigrosuffusa Dark Peacock

LACHLANIA DENCYANUAE GILA RIVER MAYFLY

Lampropeltis pyromelana Sonoran Mountain Kingsnake

Lesquerella gooddingii Goodding's Bladderpod

Limenitis archippus obsoleta Arizona Viceroy

Lontra canadensis sonora Southwestern River Otter

Lupinus lemmonii Lemmon's Lupine

Macrotus californicus California Leaf-nosed Bat

Madrean Encinal

Madrean Pine-Oak Forest and Woodland

Madrean Pinyon-Juniper Woodland

Meda fulgida Spikedace

Migratory bird concentration area

Montane Mixed Forest

Montane Riparian Woodland and Shrubland

Myotis velifer Cave Myotis

Oncorhynchus gilae apache Apache Trout

Oncorhynchus gilae gilae Gila Trout

Packera cynthioides White Mountain Groundsel

Packera neomexicana var. metcalfei Metcalfe's Groundsel

Packera quaerens New Mexico Groundsel

Pedicularis angustifolia Mogollon Mountain Lousewort

Penstemon linarioides ssp. maguirei Maguire's Penstemon

Penstemon superbus Superb Beardtongue

Perityle gilensis var. gilensis Gila Rockdaisy

Pipilo aberti Abert's Towhee

Poeciliopsis occidentalis occidentalis Gila Topminnow


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Ponderosa Pine Forest and Woodland


Ponderosa Pine Forest Community (specific)

Prosopis (glandulosa var. torreyana, velutina) Woodlan (Western Honey Mesquite, Velvet Mesquite) Woodland

Ptychocheilus lucius Colorado Pikeminnow

Purshia x subintegra Arizona Cliffrose

Pyrgulopsis arizonae Bylas Springsnail

Pyrgulopsis gilae Gila Springsnail

Pyrgulopsis thermalis New Mexico Hot Springsnail

Rabbitbrush Shrubland

Rallus longirostris yumanensis Yuma Clapper Rail

Rana chiricahuensis Chiricahua Leopard Frog

Rana pipiens Northern Leopard Frog

Rana yavapaiensis Yavapai Leopard Frog

Rhinichthys cobitis Loach Minnow

Rhinichthys osculus Speckled Dace

Riparian Woodland

Riparian Woodland

Riparian Woodland Community (specific)

Rumex orthoneurus Blumer's Dock

Salix arizonica Arizona Willow

Sciurus arizonensis Arizona Gray Squirrel

Sclerocactus erectocentrus var. 1 Acuna Cactus

Semi-Desert Chaparral

Sonoran Desert Scrub

Stellaria porsildii Porsild's Starwort

Strix occidentalis lucida Mexican Spotted Owl

Subalpine Spruce-Fir Forest and Woodland

Thamnophis rufipunctatus Narrow-headed Gartersnake

Toxostoma lecontei Le Conte's Thrasher


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Trifolium neurophyllum Mogollon Clover

Tryonia gilae Gilae Tryonia

Ursus americanus American Black Bear

Vireo bellii Bell's Vireo

Xyrauchen texanus Razorback Sucker

Zapus hudsonius luteus New Mexican Jumping Mouse

Zigadenus mogollonensis Mogoll Deathcamas

Name Milagro Springs


Chihuahuan-Sonoran Desert Bottomland and Swale Gr

Cirsium wrightii Wright's Marsh Thistle

Helianthus paradoxus Pecos Sunflower

Intact Prairie Dog Towns and Associated Animal Asse

Pinyon - Oak - Juniper Woodlands and Shrublands


Western Great Plains Saline Depression Wetland


Name Mt. Dora Shortgrass


Aimophila cassinii Cassin's Sparrow


Buteo regalis Ferruginous Hawk

Calamospiza melanocorys Lark Bunting

Callipepla squamata Scaled Quail

Charadrius montanus Mountain Plover

Great Plains Mixedgrass Prairies

Melanerpes erythrocephalus Red-headed Woodpecker

Numenius americanus Long-billed Curlew




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Name Pasamonte Shortgrass



Astragalus wittmannii Wittmann's Milk-vetch






Great Plains Mixedgrass Prairies



Pinyon - Oak - Juniper Woodlands and Shrublands

Southern Rocky Mountain Ponderosa Pine Woodland


Western Great Plains Tallgrass Prairie

Name Pastura Grasslands



Astragalus siliceus Flint Mountain Milk-vetch








Western Great Plains Mesquite Woodland and Shrubla



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Name Punche Valley


ALPINE/MONTANE MODERATE AND LOW GRA


Astragalus ripleyi Ripley's Milk-vetch


Catostomus plebeius Rio Grande Sucker


Cynomys gunnisoni Gunnison's Prairie Dog

Dipodomys ordii montanus

Eumeces multivirgatus epipleurotus Variable Skink

Gila pandora Rio Grande Chub

INTERMONTANE - FOOTHILL GRASSLAND

LOWER MONTANE - FOOTHILLS SHRUBLAND

MONTANE MODERATE AND LOW GRADIENTS L

MONTANE MODERATE AND LOW GRADIENTS S

MONTANE STEEP & VERY STEEP GRADIENTS O

Neoparrya lithophila Rock-loving Aletes

Perognathus flavus sanluisi


Populus angustifolia Sand Dune Forest Narrowleaf Cottonwood Sand Dune Forest

Rocky Mountain Juniper Woodland and Savanna

SAGEBRUSH STEPPE

Southern Rocky Mountain Pinyon-Juniper Woodland (

Spermophilus tridecemlineatus blanca A Ground Squirrel

Thomomys bottae pervagus Botta's Pocket Gopher

Name Rio Chama


ALPINE DRY TUNDRA & ALPINE/SUBALPINE W

ALPINE STEEP & VERY STEEP GRADIENTS O HE


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Astragalus iodopetalus Violet Milk-vetch

Astragalus micromerius Chaco Milk-vetch

Catostomus plebeius Rio Grande Sucker

Empidonax traillii extimus Southwestern Willow Flycatcher

Gila pandora Rio Grande Chub

Haliaeetus leucocephalus Bald Eagle

INTERMONTANE - FOOTHILL GRASSLAND

LOWER MONTANE - FOOTHILLS SHRUBLAND

Mentzelia conspicua Conspicuous Blazingstar

Montane Mixed Forest

MONTANE MODERATE AND LOW GRADIENTS

MONTANE MODERATE AND LOW GRADIENTS

MONTANE MODERATE AND LOW GRADIENTS L

MONTANE MODERATE AND LOW GRADIENTS S

MONTANE STEEP & VERY STEEP GRADIENTS O

MONTANE/FOOTHILLS, FOOTHILLS MODERATE

MONTANE/FOOTHILLS, FOOTHILLS MODERATE

Oncorhynchus clarkii pleuriticus Colorado River Cutthroat Trout

Oncorhynchus clarkii virginalis Rio Grande Cutthroat Trout

Phlox caryophylla Pagosa Phlox


Rana pipiens Northern Leopard Frog

Riparian Woodland

Rocky Mountain Juniper Woodland and Savanna

SAGEBRUSH STEPPE

Southern Rocky Mountain Pinyon-Juniper Woodland (

Strix occidentalis lucida Mexican Spotted Owl

Utacapnia poda A Stonefly


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WINTERFAT SHRUB STEPPE

Name San Juan de Dios


Cirsium wrightii Wright's Marsh Thistle

Helianthus paradoxus Pecos Sunflower


Vireo bellii Bell's Vireo




Name Sand Springs



Euphorbia strictior Panhandle Spurge


Proboscidea sabulosa Dune Unicorn-plant



Western Great Plains Sandhill Steppe


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- 1 -

July 27, 2010

Delivered via electronic mail to [email protected]

Ms. Joan Munsell

New Mexico Renewable Energy Transmission Authority200 West DeVargas St., Suite 4

Santa Fe, NM 87501

Re: Comments on Proposed RETA Transmission Corridors

Dear Ms. Munsell:

Thank you for the opportunity to submit these scoping comments on the proposed RETA

Transmission Corridors (Corridors) on behalf of The Western Environmental Law Center (WELC).

WELC is a nonprofit public interest environmental law and policy firm that works to protect andrestore western wildlands and advocates for a healthy environment on behalf of communities

throughout the West.

Background Wildlife Corridors and Climate Change

The West once experienced spectacular seasonal movements of wildlife across the landscape, with

species moving from summer to winter range, or from birthing to feeding grounds. Unfortunately,

landscape scale habitat loss and fragmentation threaten the integrity of our natural heritage bydisrupting important ecological interactions and patterns of wildlife movement. Such disruptions

undermine the health of wildlife and the likelihood they will persist over time and are exacerbated by

climate change. Local climate disruptions will cause changes in patterns of precipitation andtemperature, and wildlife will need to move in response to these changes, making them highly

vulnerable to extirpation or extinction.

Accordingly, through our Western Wildlife Corridors Campaign, WELC is working to protect and

restore the Wests most critical wildlife habitat and wildlife corridors to ensure species resilience in

a warming world. With this goal in mind, the region from the San Juan to the Rio Grande is one of

three priority landscapes in the entire West that we are devoting our time and resources to.

Corridor 4: Conflict with Wildlife Corridors and Private Lands Conservation Efforts

In addition to the comments provided by The Wilderness Society and other conservation groups,WELC would like to bring to your attention additional information regarding Corridor 4, which is

proposed to bisect key north-south migration areas for both mule deer and elk.


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WELC is working with private landowners in the southern San Juan Mountains of Colorado andnorthern New Mexico to launch the Chama Peak Landowner Conservation Alliance (The

Alliance) in October 2010. The Alliance is an association of conservation minded landowners who

are interested in working together on common issues and problems in the southern San JuanMountains of Colorado and New Mexico. The Alliance is unique in the region because it contains a

concentration of contiguous, large expanses of wildlands. Land ownership, management, and use are

very diverse but the landowners in this region share a common desire to keep this spectacularlandscape healthy and unfragmented through land stewardship efforts.

The mission of the Alliance is to enhance, conserve, and protect wildlife movement, watershedhealth, and the landscape integrity of the southern San Juan Mountains of Colorado and northern

New Mexico for present and future generations. We recognize that we are part of a larger region

from the San Juan to the Rio Grande and beyond which contains critical wildlife migration corridors,

habitats and dispersal at the landscape scale.

Corridor 4 is in direct conflict with the private lands that are being prioritized for conservation. We

highly encourage you to seriously reconsider the siting of this particular line, as there will be directconflict moving forward and irreparable impacts to critical wildlife habitat and migration corridors.

Thank you for the opportunity to comment. Please do not hesitate to contact me with any questionsor comments. Additionally, please be sure to add me to your contact list for meetings and comment

opportunities in the future.

Sincerely,

Monique DiGiorgio, Conservation StrategistWestern Environmental Law Center

520 E. Babcock Street Bozeman, Montana 59715

direct 406.451.0051 cell 406.548.1592 fax 406.443.6305

[email protected] www.westernlaw.org

cc: Alex Daue, The Wilderness Society

Gary Graham, Western Resource Advocates


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First Win

600 B Street, Suite 130

San Diego, CA 9210

Tel: 619.684.772

Fax: 619.684.779

July 26, 2010

Jeremy Turner

Director, RETA

200 West De Vargas #4

Santa Fe, NM 87501

RE: Comments on RETAs Draft Transmission Corridors

Dear Jeremy,

First Wind acknowledges RETAs effort in facilitating transmission planning for renewable energy in New

Mexico and commends RETAs efforts to help provide access to New Mexicos valuable and abundant

renewable energy resource. In regards to the recently published Draft Transmission Corridors and request fostakeholder input, First Wind would like to submit the following comments:

Please clarify the evaluation criteria used in selecting the corridors proposed in the draft.

Please quantify what benefits are associated with the particular corridor segments that have been

identified. (How many MWs, which resource, transmission capacity made available, lower risk of

environmental impacts, etc?)

Large scale export of New Mexicos renewable energy will depend on access to western markets via

new transmission. How does the current proposal achieve that?

Focus should be placed on how to provide renewable resource with access to markets.

Development of resources with lower development costs being delivered to high value markets shouldbe emphasized.

RETA should augment and enable large merchant transmission activities.

First Wind encourages RETA to take a lead in coordination and development of renewable energy

collector systems.

Recent FERC Notice of Proposed Rulemaking provides an opportunity to develop creative solutions to

the integration of planning efforts and regional cost allocations.

First Wind appreciates the opportunity to provide these comments and looks forward to working together to

bring renewable energy projects forward in New Mexico.

Sincerely,

James Kelly

Director, Development

Email:[email protected]
mailto:[email protected]:[email protected]:[email protected]:[email protected]


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DEPARTMENT OF THE ARMY US ARMY WHITE SANDS MISSILE RANGE 100 Headquarters Avenue WHITE SANDS MISSILE RANGE, NEW MEXICO 88002-5000 REPLY TO July 27, 2010ATTeNTION OFOffice of the Chiefof Staff

Mr. Jeremy Turner, DirectorRenewable Energy Transmission Authority ofNew Mexico200 West De Vargas, Suite 4Santa Fe, New Mexico 87501Dear Mr. Turner,

White Sands Missile Range (WSMR) fully supports the Green Initiative directives comingfrom the White House and applauds the work that has been accomplished by RETA in the pastyear. WSMR continues to search for cooperative solutions to the rapidly expanding transmissionline developments in New Mexico.WSMR has reviewed the proposed transmission network areas provided at the June 11,2010, public presentation. WSMR is not impacted by the proposed Renewable TransmissionCorridors identified in_bright yellow on the provided map. However we continue to beconcerned about some of the proposed projects, specifically parts of the SunZia and the EastWest routes through the middle of the state. I've attached a brief that goes in detail on theimpacts of these specific routes. In brief, some of the impacts are:Electromagnetic interference. Recently, WSMR was chosen to conduct high powerImprovised Explosive Device (lED) defeat testing. These US systems use high-power directedenergy to overload and damage IEDs to defeat them before they can inflict casualties on USSoldiers deployed in combat theaters. WSMR was chosen for this test mission over other testranges because of remoteness, i.e., there are no nearby commercial electrical and telephonenetworks. Significant infrastructure investment has already been expensed to construct testingsites to execute this mission. These lED defeat systems are both ground based and carried onairborne platforms, mainly Unmanned Aerial Systems (VAS). The future development of thesesystems appears to be in the direction of increased power and sensitivity in coupling tocommercial networks. There is great concern that if parts of the SunZia or East West routes aredeveloped, WSMR testing of these systems would be affected.Reduced Safety Fans. All tests conducted at WSMR require an evaluation for safety with adetermination of the area required to conduct that test safely, i.e., a safety fan. Up to twenty-fivetimes a year, areas outside ofWSMR boundaries identified as extension areas must be evacuateddue to the safety fans. Most routes located in the central part ofNew Mexico are located in these


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extension areas. As discussed in the item below, any power line located in these safety fans aresubject to damage. IfWSMR were required to eliminate safety fans in the extension areas due tothe proposed transmission lines, an 18.5% loss of area available for test missions would result.This would reduce or eliminate WSMR's capability to test certain systems which cannot betested overland anywhere else in the United States. This is an extreme negative impact onWSMR.Weapon systems designed to damage power lines. As mentioned above some of thesesystems employ directed energy to defeat IEDs. Many of these tests employ extremely highpowers with unknown ranges of effectiveness. Additionally in the past, the US has developedweapon systems specifically designed to damage and disrupt power transmission lines. Theseare primarily air delivered weapons and are greatly affected by winds. Even with great care, thechance of inadvertently damaging some of the SunZia or East West power lines is a reasonableconcern. In terms of risk, the salient point is the enormous hazard such a disruption wouldgenerate to customers dependent on continuous supply of electricity.Physical Interference of 200 ft power lines. WSMR airspace extends beyond ourborders. This DoD airspace starts at ground level and extends to exo-atmospheric. WSMR has aheavily used airfield (Stallion) in the northwest comer of the range. The airfield is used bymanned and unmanned aircraft, many ofwhich are developed by "Other GovernmentalAgencies" and allied nations. Additionally, SVLF site on the western border has also been usedto launchVAS. Some of these VAS have very slow climb rates, making 200 ft power lines evena few miles away a significant concern. Also, WSMR tests and uses cruise missiles as targets forair defense system testing. These weapon systems and targets can fly as low as 20 ft AboveGround Level. Power lines at 200 ft pose potential hazards that would require circumscription oftest events. Again, even with a reduced test footprint, the potential for unintended events is aconcern.WSMR stands ready to support RETA in developing a realistic statewide transmissionnetwork for New Mexico. We thank-you for the opportunity to provide our input on thisimportant advancement and look forward to further collaboration.

Sincerely,

Q ~ ( 1 / J 1 Chiefof Staff


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US A

White

un a mpac on


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Purpose

Provide Analysis Of SunZia Transmissio

Impacts To WSMR Military Mission

US A


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Background Information

BLM is lead for Environmental Impact Study (E WSMR is a coope

Electronic Compilation Comments at July 28, 2010

Documents

Transcript of Electronic Compilation Comments at July 28, 2010