Control Number: 51301

Item Number: 2

Addendum StartPage: 0 VC/VEO 0

i :,9 I 'j }l

APPLICATION OF -NEW MEXICO POWI ' CLCRM COMPANY TO AMEND ITS CERTIFICATE OF

CONVENIENCE AND NECESSITY FOR THE

PROPOSED GREENBELT-CATTAIL-CHEROKEE

138-kV TRANSMISSION LINE PROJECT IN

GALVESTON COUNTY, TEXAS

DOCKET NO. 51301

Submit seven (7) copies of the application and aH attachments supporting the application. If the application is being jiledpursuant to 16 Tex. Admin. Code § 25.101(b)(3)(D) (TAC) or 16 TAC § 25.174, include in the application aU direct testimony. The application and other necessary documents shall be submitted to:

Public Utility Commission of Texas Attn: Filing Clerk 1701 N. Congress Ave. Austin, Texas 78711-3326

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/Lth,/ Standard Application for a Certificate of Convenience and Necessity for a Proposed Transmission Line and Application for a Certificate of Convenience and Necessity for a Proposed Transmission Line Pursuant to 16 TAC § 25.174

DOCKET NO. 51301 APPLICATION OF TEXAS-NEW MEXICO POWER COMPANY TO AMEND ITS CERTIFICATE OF CONVENIENCE AND NECESSITY OF THE PROPOSED GREENBELT-CATTAIL-CHEROKEE 138KV TRANSMISSION LINE PROJECT IN GALVESTON COUNTY, TEXAS

Table of Contents Prepared September 25,2020

Attachments 1. Environmental Assessment and Alternative Route Analysis 2. Estimated Costs 3. Confidential Schematic of TNMP Existing Transmission System and Proposed Construction 4. Aerial-Photograph-Based Map 5. Cross-Reference of Segment Parcel List 6. Texas City Franchise Agreement 7. Direct Written Notice, to Landowners, Pursuant to Rule 22.52 8. List of Landowner Names to Whom Notice was Provided Pursuant to Rule 22.52 9. Direct Written Notice, to County and Municipal Authorities, Pursuant to Rule 22.52 10. List of County and Municipal Authorities to Whom Notice was Provided Pursuant to Rule 22.52 11. Direct Written Notice to Utilities Pursuant to Rule 22.52 12. Direct Written Notice to the Department of Defense Siting Clearinghouse 13. Newspaper Notice Pursuant to Rule 22.52 14. Direct Written Notice to Gas Pipelines 15. List of Gas Pipelines to Whom Notice was Provided 16. Direct Written Notice to Texas Office of Public Utility Counsel ("OPUC") Pursuant to Rule 22.52 17. Direct Written Notice to Texas Parks and Wildlife Pursuant to Rule 22.52 18. Confidential TNMP Texas City Transmission Improvement Project 19. Executed Standard Generation Interconnection Agreement 20. ERCOT's Recommendation on the Project 21. Chris Gerety Affidavit

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Note: As used herein, the term "Joint application" refers to an application for proposed transmission facilities for which ownership will be divided. All applications for such facilities should be filed jointly by the proposed owners of the facilities.

1. Applicant (Utility) Name: Texas-New Mexico Power Company ("TNMP")

Certificate Number: 30038

Street Address: 577 N. Garden Ridge Blvd., Lewisville, TX 75067

Mailing Address: Same as above.

2. Please identify all entities that will hold an ownership interest or an investment interest in the proposed project but which are not subject to the Commission's jurisdiction.

TNMP will hold the sole ownership interest in the project.

3. Person to Contact: Christopher Gerety Title/Position· Director of System Engineering and Land Services Phone Number: (409) 949-5605 Mailing Address: 702 36th St. N Texas City, TX 77590 Email Address: Christopher.Gei·[email protected]

Alternate Contact: Tommy Gauna Title/Position· Manager/Project Management Phone Number: (972) 353-5023 Mailing Address: 815 Office Park Circle, Lewisville, TX 75057 Email Address Tommy.Gauna(d,tnmp.com

Legal Counsel: Stephanie Sparks Phone Number: (214) 953-5962 Mailing Address 2323 Ross Ave., Ste. 600, Dallas, TX 75201 Email Address: ssparks@iw coin

4. Project Description: Name or Designation of Project: Greenbelt - Cattail - Cherokee 138kV Transmission Line project

Provide a general description of the project, including the design voltage rating (kV), the operating voltage (kV),the CREZ Zone(s) (ifany) where theprojectis located (al! or inparO, any substations and/or substation reactive compensation constructed as part of the project, and any series elements such as sectionalizing switching devices, series line compensation, etc. For HVDC transmission lines, the converter stations should be considered to beproject components and should be addressed in the project description.

TNMP proposes to construct two new double-circuit capable 138 kilovolt (kV) transmission lines in Galveston County. The proposed 138-kV transmission lines will connect the existing Greenbelt Substation to the proposed Cattail Substation Site, then the proposed Cattatl Substation Site to the existing Cherokee Substation. The western-most substation (Greenbelt

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Substation) is located at the northwest corner of the intersection of 27th Street South and 5th Avenue South. The eastern-most substation site (Cattail Substation Site) will be located northeast of the intersection of 6th Street South and 2nd Avenue South. The southern-most substation (Cherokee Substation) is located 0.15 mile southwest of the intersection of 14th Street South and TX 197 Loop South. The length of the proposed transmission line varies from 2.18 to 2.70 miles for the Greenbelt to Cattail Segment and varies from 1.58 to 1.89 miles for the Cattail to Cherokee Segment, depending on the route selected by the Public Utility Commission of Texas (PUC). Therefore, the total length of the proposed transmission line varies from 3.76 to 4.59 miles, depending on the route selected by the Public Utility Commission ofTexas (PUC)

If the project will be owned by more than one party, briejly explain the ownership arrangements between the parties and provide a description of the portion(s) that will be owned by each party. Provide a description oj the responsibilities of each party for implementing the project (design, Right-of-Way acquisition, material procurement, construction, etc.). TNMP will own, operate, and maintain all transmission line facilities, Including conductors, wires structures, hardware, and rights-of-way. TNMP will also own, operate, and maintain the substation facilities. TNMP will be responsible for implementing all aspects of the prOJect.

If applicable, identify and explain any deviation in transmission project components from the original transmission specifications as previously approved by the Commission or recommended by a PURA §39.151 organization. This provision is not applicable to the proposed project because it was not previously approved by the Commission, and it was not required to be submitted to a Public Utility Regulatory Act (PURA) §39.151 organization.

5. Conductor and Structures: Conductor Size and Type: 795 ACSS"Drake" Number of conductors per phase: 1 Continuous Summer Static Current Rating (A): 3204 Continuous Summer Static Line Capacity at Operating Voltage (MVA): 766 Continuous Summer Static Line Capacity at Design Voltage (MVA): 766 Type and composition of Structures : Steel Monopole Height of Typical Structures : 120 feet Estimated Maximum Height of Structures: 150 feet Explain why these structures were selected; include such factors as landowner preference, engineering considerations, and costs comparisons to alternate structures that were considered. Provide dimensional drawings of the typical structures to be used in the project.

The double circuit steel monopole structures were selected based on cost and engineering purposes. The monopole allows TNMP to reduce costs compared to "H" frame construction. Fewer materials are needed with the monopole construction and a smaller easement is required for monopole construction. These steel pole structures assist TNMP in meeting the PUC system hardening requirements.

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For joint applications, provide and separately identify the above-required information regarding structures for the portion(s) of the project owned by each applicant.

Not applicable. This is not a joint application.

6. Right-of-way: Miles of Right- of- Way : Approximately 3 . 76 to 4 . 59 miles , depending on the route chosen . Miles of Circuit : Approximately 3 . 76 to 4 . 59 miles , depending on the route chosen . Width of Right- of- Way : Varies from 40 to 80 feet . Percent of Right- of- Way Acquired : Approximately 30 - 51 %.

Forjoint applications, provide and separately identify the above-required iiiforntation for each route for the portion(s) of the project owned by each applicant.

Not applicable. This is not a joint application.

Provide a brief description of the area traversed by the transmission line. Include a description of the general land uses in the area and the type of terrain crossed by the line.

The proposed project is located in Texas City, Texas, in Galveston County. The majority of the study area is dominated by high intensity industrial development such as oil, gas, and petrochemical . Additionally, there is some residential, retail, and park land. The terrain can be characterized as a flat, urban landscape. The following table provides the link composition and route length for the proposed alternative routes:

Alternative Length Transmission Link Combination (miles) Line Routes Greenbelt to Cattail Segment GC-1 B-D-I-R 2.29 GC-2 B-D-K-L-O-Q-R 2.43 GC-3 B-E-G-J-L-O-Q-R 2.55 GC-4 B-E-G-M-N-O-Q-R 2.55 GC-5 B-E-F-G-C-H-S-N-O-Q-R 2.70 GC-6 B-E-F-C-H-T-U-Q-R 2.70 GC-7 A-C-H-T-U-Q-R 2.19 GC-8 A-F-G-M-N-O-Q-R 2.18 GC-9 A-C-H-S-N-O-Q-R 2.19 GC-10 A-F-G-J-L-O-Q-R 2.18 GC-11 A-F-G-J-K-I-R 2.28 GC-12 A-F-E-D-I-R 2.28 Cattail to Cherokee Segment CC-1 P-U-V-AB-AA-AD 1.59 CC-2 P-U-V-AB-AC-AD 1.58 CC-3 P-U-V-W-Z-AE-AD 1.85

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Alternative Length Transmission Link Combination (miles) Line Routes Greenbelt to Cattail Segment CC-4 P-U-T-H-C-Y-AE-AD 1.86 CC-5 P-U-T-H-X-Z-AE-AD 1.85 CC-6 P-O-N-S-H-X-Z-AE-AD 1.85 CC-7 P-O-N-M-G-F-Y-AE-AD 1.85 CC-8 P-O-L-J-G-F-Y-AE-AD 1.85 CC-9 P-O-N-S-H-C-Y-AE-AD 1.86 CC-10 P-U-V-W-X-C-Y-AE-AD 1.89

7. Substations or Switching Stations: List the name of ail existing HVDC converter stations, substations or switching stations that will be associated with the new transmission line. Provide documentation showing that the owner(s) of the existing HVDC converter stations, substations and/or switching stations have agreed to the installation of the required projectjacilities.

There are no associated HVDC converter stations associated with this project. TNMP will connect this project to its existing Greenbelt and Cherokee switching stations, and will add a terminal to the existing Texas City Main switching station and install of a 138/69kv autotransformer.

List the name of ali new HVDC converter stations, substations or switching stations that will be associated with the new transmission line. Provide documentation showing that the owner(s) of the new HVDC converter stations, substations and/or switching stations have agreed to the installation of the required project facilities.

TNMP is proposing to construct a new Cattail 138 kV switching station for this proJect. 8. Estimated Schedule:

Estimated Dates of: Start Completion 9/21/2021 3/18/2022 Right-of-way and Land Acquisition 9/21/2021 1/20/2022 Engineering and Design 9/21/2021 3/20/2022 Material and Equipment Procurement 3/19/2022 8/20/2022 Construction of Facilities 6/1/2022 8/20/2022 Energize Facilities ** The estimated scheduled above is based on several assumptions. The overall start dates will be dependent on the CCN application process and approval by the PUC. The dates shown above are based on typical durations for similar projects.

9. Counties: For each route, list aH counties in which the route is to be constructed.

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Galveston County, Texas. 10. Municipalities: For each route, list all municipalities in which the route is to be constructed.

Texas City, Texas.

For each applicant, attach a copy of the franchise, permit or other evidence of the Cio" k consent held by the utility, if necessary or applicable. If franchise, permit, or other evidence of the city's consent has been previously filed, provide only the docket number of the application in which the consent was filed. Each applicant should provide this information only for the portion(s) of the project which will be owned by theapplicant.

Texas City Franchise Agreement is attached as Attachment 6.

11. Affected Utilities: Identify any other electric utility served by or connected tofacilities in this application.

None.

Describe how any other electric utility wi!! be affected and the extent of the other utilities' existing facilities will be utilized for the project (vacant circuit positions, ROW, substation sites and /or equipment, etc.) and provide documentation showing that the owner (s ) of the existingfacilities have agreed to the installation of the required projectfacilities.

CenterPoint Energy owns facilities in the vicinity of the proposed project that will not be adversely affected by the proposed project.

12. Financing: Describe the method ofjinancing this project. For each applicant that is to be reimbursed for all or a portion of this project, identify the source and amount of the reimbursement (actual amount ifknown, estimated amount otherwise) and the portion(s) of the projectfor which the reimbursement will be made.

The facilities will be financed by TNMP's capital budget.

13. Estimated Costs: Provide cost estiniates for each route of the proposed project using the following table. Provide a breakdown of"Other" costs by major cost category and amount. Provide the information for each route in an attachment to this application. Transmission Substation Facilities Facilities

Right-of-way and Land Acquisition

Engineering and Design (Utility)

Engineering and Design (Contract)

Procurement of Material and Equipment (including stores)

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Construction of Facilities (Utility)

Construction of Facilities (Contract)

Other (all costs not included in the above categories) See Attach. 2 See Attach. 2 Estimated Total Cost

Please refer to Attachment 2 for estimated costs for Transmission and Substation Facilities estimated costs for each alternative route presented in this application. For joint applications, provide and separately identify the above-required information for the portion(s) of the project owned by each applicant. Not applicable. This is not ajoint application.

14. Need for the Proposed Project: For a standard application, describe the need for the construction and state how the proposed project will address the need. Describe the existing transmission system and conditions addressed by this application. For projects that are planned to accommodate load growth, provide historicalload data and load projections for at least five years. For projects to accommodate load growth or to address reliability issues, provide a description ofthesteadystateload flowanalysis thatjustijies the project. Forinterconnectionprojects, provide any documentation from a transmission service customer, generator, transmission service provider, or other entity to establish that the proposed facilities are needed. For projects related to a Competitive Renewable Energy Zone, the foregoing requirements are not necessary; the applicant need only provide a specific reference to thepertinent portion(s) of an appropriate commission order specifying that the facilities are needed. For all projects,provide any documentation of the review and recommendation ofa PURA §39.151 orgmtization.

This Project is needed to accommodate significant load growth and to ensure system reliability. PUC Substantive Rule 25.101(b)(3)(A)(i) addresses the available requirements that a utility can satisfy in order to establish the need for a new electric transmission line. Specifically, while in some cases the utility applicant must present an economic cost benefit study that includes an analysis that shows that the levelized ERCOT-wide annual production costs savings attributable to the proposed project are equal to or greater than the first-year annual revenue requirement of the proposed project, such requirement does not apply "to an application for a transmission line that is necessary to meet state or federal reliabihty standards, including: a transmission line needed to interconnect a transmission service customer or end-use customer[.]"

TNMP has an agreement with an industrial customer to provide transmission service for a large atnmonia and cogenei-ation facility (Plant) planned in Texas City, TX. The planned site for the Plant is within an area of Texas City where access to an existing transmission facility is limited to a 69 kV station. However, TNMP conducted reliability studies related to the Plant, which establish that TNMP cannot reliably interconnect the Plant with 69 kV service. Essentially, TNMP's studies indicate there will be several post- contingency transmission circuit overloads that would require curtailment of service to the Plant or other existing industrial loads if the Plant were interconnected with 69 kV service.

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To reliably serve the Plant, TNMP must interconnect the Plant with 138 kV service. A copy of the executed standard generation interconnection agreement between TNMP and the customer is provided in Attachment 19.

The proposed project addresses the need by extending 138 kV facilities to the immediate area of the planned site for the Plant. Specifically, a proposed Cattail 138 kV station will serve as a point of interconnection for the Plant and the proposed project loops the Cattail station into TNMP's 138 kV network. Looped 138 kV service to the Cattail station is required to avoid safety and environmental risks associated with N-1 loss of utility supply to a hazardous chemical production facility.

The existing transmission system description and steady state load flow analysis that Justifies the project are documented in Confidential Attachment 18 titled TNMP Texas City Transmission Improvement Project, which TNMP submitted to the ERCOT Regional Planning Group ("RPG") in April 2020 for ERCOT's review of the proposed project. ERCOT performed an Independent review of the RPG proposal and confirmed the reliability needs driven by the integration of the new load and cogeneration facility. ERCOT's recommendation of the project, dated September 2020, is provided in Attachment 20.

15. Alternatives to Project: For a standard application, describe alternatives to the construction oj this project (not routing options). Include an analysis of distribution alternatives, upgrading voltage or bundling of conductors of existing facilities, adding transformers, andfor utilities that have not unbundled, distributed generation as alternatives to the project. Explain how the project overcomes the insufficiencies of the other options that were considered.

The detailed alternatives analysis can be found in Confidential Attachment 18 (TNMP Texas City Transmission Improvement Project, which was submitted to ERCOT).

16. Schematic or Diagram: For a standard application, provide a schematic or diagram of the applicant's transmission system in the proximate area Of the project. Show the location and voltage of existing transmission lines and substations, and the location of the construction. Locate any taps, ties, meter points, or other facilities involving other utilities on the systemschematic.

A schematic of TNMP's existing transmission system and the proposed construction is included as Confidential Attachment 3.

17. Routing Study: Provide a brief summary oj the routing study that includes a description of the process of selecting the study area, identifying routing constraints, selecting potential line segments, and the selection of the routes. Provide a copy of the complete routing study conducted by the utility or consultant. State which route the applicant believes best addresses the requirements of PURA and PUC Substantive Rules.

A copy of the complete environmental assessment and routing study that was prepared by HDR, Inc. (HDR) is included as Attachment 1 of this application. The Environmental Assessment and Routing Study (EA) presents the analysis that was conducted by HDR and

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the land use and environmental data for all routes that were considered for this project.

The objective of the EA was to identify and evaluate an adequate number of geographically diverse alternative transmission line routes that comply with the routing criteria in PURA and the PUC's Substantive Rules, and ultimately recommend to TNMP the route that HDR determined best addresses the requirements of PURA and the PUC's Substantive Rules from a land use and environmental standpoint. TNMP and HDR utihzed a comprehensive transmission line routing and evaluation methodology to delineate and evaluate alternative transmission line routes.

The methodologies and assumptions that were used to conduct the Environmental Assessment and routing study for the TNMP Greenbelt-Cattail-Cherokee 138 kV Transmission Line Project are consistent with Section 37.056(c)(4)(A) through (D) of PURA, P.U.C. Proc. R. 22.52(a)(4), P.U.C. Subst. R. 25.101(b)(3)(B), and the Commission's policy of prudent avoidance. The methodology used to complete the routing study is summarized below.

TNMP retained HDR to prepare an EA to support this application for a Certificate of Convenience and Necessity (CCN) for the proposed project. TNMP provided HDR with the project endpoints. Using these endpoints and additional input from TNMP, HDR Identified the study area boundaries based on the location of the known endpoints and midpoint of the Greenbelt, Cattail, and Cherokee Substation Sites. The study area was defined, using these substation sites, to provide an area large enough to develop an adequate set of geographically diverse alternative routes. The northern boundary is parallel to and north, by approximately 0.15 mile, of farm-to-market road (FM) 1765/Texas Avenue. The southern boundary runs parallel to and south, by approximately 0.35 mile, of 5th Street on the west, then it redirects to the southeast before running parallel to and north of Industrial Canal Road. The western boundary runs parallel to and east, by approximately 0.03 mile, of 31th Street North. The eastern boundary runs along 2nd Street in the northeast corner and continues on that line after 2nd Street dead ends into 2'd Avenue South.

Field reconnaissance was conducted (February 20,2020, and June 30,2020), and preliminary evaluation criteria were developed. Based on data pertinent to the study area, the HDR planning team and TNMP also established criteria, consistent with PUC standards, for the resource analysis. Data were collected pertaining to land use, recreational and park areas, historical and aesthetic values, and environmental integrity. Available GIS coverage with associated metadata was reviewed, and relevant resource data were selected and mapped. Sensitive resource locations were identified on an environmental and land use composite constraints map.

HDR identified 31 feasible and geographically diverse preliminary transmission line links, and an in-person public meeting was conducted (June 30,2020) m accordance with P.U.C. Proc. R. 22.52 (a)(4). In addition, a virtual public meeting following a similar layout of the in-person public meeting was hosted online. Following the in-person public meeting and the virtual public meeting, no link modifications or additions were made. Upon confirming the preliminary transmission line links as alternative transmission line links, data were tabulated for the resulting alternative transmission line links.

These alternative transmission line route links were then organized into alternative transmission line routes. HDR and TNMP identified 12 forward progressing alternative transmission line routes for the Greenbelt to Cattail Segment and 10 forward progressing alternative transmission line routes for the Cattail to Cherokee Segment. From these possible alternative routes, HDR and TNMP evaluated combinations of the five highest ranked

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alternative transmission line routes from each of the segments, as well as two additional alternative transmission line route segment combinations, resulting in 27 alternative transmission line route segment combinations. The 27 proposed alternative transmission line routes utilize all of the alternative route links and also provide geographic diversity.

A comparative potential impact assessment of all of the alternative transmission line routes was completed, culminating in the recommendation of the proposed alternative transmission line routes, as well as the identification of the route that HDR believes best addresses the requirements of PURA and the PUC Substantive Rules.

Alternative Transmission Line Route GC-7 was selected by HDR as the route that best addresses the requirements ofPURA and PUC Substantive Rules from an environmental and land use perspective for the Greenbelt to Cattail Segment. This rationale was based on the resource specialist consensus method: • is one of the shortest routes, at 2.19 miles; • is using existing transmission line ROW or parallel to existing compatible cori·idors and apparent property boundaries (excluding pipelines) for 97% of its length; • has the fewest number of habitable structures within 300 feet, at 78; • crosses the fourth fewest parcels, at 148; and • has the fourth shortest length of ROW within the foreground visual zone of IH, US, and state highways, at 11,582 feet.

Additionally, Alternative Transmission Line Route GC-7 also: • crosses no parks/recreational areas; • has only one park/recreational area within 1,000 feet of the ROW centerline; • crosses no cropland; • crosses no pasture/rangeland; • crosses no land irrigated by traveling systems (rolling or pivot type); • crosses no farm-to-market roads; • has no commercial AM radio transmitters within 10,000 feet ofthe ROW centerline; • has no cemeteries within 1,000 feet of the ROW centerline; • has no FAA registered airports with no runway more than 3,200 feet in length within 10,000 feet of the ROW centerline; • is not within 200 feet of any oil or gas wells; • crosses no NWI mapped wetlands; • crosses no known/occupied habitat of federally endangered or threatened species; • crosses no upland woodlands; • crosses no bottomland/riparian woodlands; • crosses no 100-year floodplain; • crosses no open water; • crosses no streams; • does not parallel a stream; • crosses no archeological sites and is not located within 1,000 feet of any additional recorded archeological sites; • crosses no NRHP sites and is not located within 1,000 feet of any additional NRHP sites; • crosses no areas of high archeological site potential.

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Alternative Transmission Line Route CC-2 was selected by HDR as the route that best addresses the requirements of PURA and PUC Substantive Rules from an environmental and land use perspective for the Cattail to Cherokee Segment. This rationale was based on the resource specialist consensus method: • is the shortest route, at 1.58 miles; • has the second-most length of ROW parallel to other compatible existing ROW (highways, public roadways, railways, etc.-excluding pipelines), at 3,734 feet; • has the most length of ROW parallel to apparent property lines, at 250 feet; • has the third highest percentage parallel to existing compatible corriders and apparent property boundaries (excluding pipelines), at 58% of its length; • has the third highest percentage using existing transmission line ROW or parallel to existing compatible corridors and apparent property boundaries (excluding pipelines), at 88% of its length; • has the fewest number of habitable structures within 300 feet, at 30; • crosses the second fewest parcels, at 35; • crosses the fewest number of transmission lines, at 5; • is within 2,000 feet of the fewest number of FM, microwave, and other electronic installations, at 35; • has the shortest length of ROW within the foreground visual zone of any park or public recreational area, at 2,108 feet; and • has the shortest length of ROW within the foreground visual zone of a farm-to- market road, at 2,631 feet.

Additionally, Alternative Transmission Line Route CC-2 also: • crosses no parks/recreational areas; • has no parks/recreational areas within 1,000 feet of the ROW centerline; • crosses no cropland; • crosses no pasture/rangeland; • crosses no land irrigated by traveling systems (rolling or pivot type); • crosses no farm-to-market roads; • has no commercial AM radio transmitters within 10,000 feet ofthe ROW centerline; • has no cemeteries within 1,000 feet of the ROW centerline; • has no FAA registered airports with no runway more than 3,200 feet in length within 10,000 feet of the ROW centerline; • has no heliports within 5,000 of the ROW centerline; • is not within 200 feet of any oil or gas wells; • crosses no known/occupied habitat of federally endangered or threatened species; • crosses no upland woodlands; • crosses no bottomland/riparian woodlands; • crosses no 100-year floodplain; • crosses no open water; • does not parallel a stream; • crosses no archeological sites and is not located within 1,000 feet of any additional recorded archeological sites; • crosses no NRHP sites and is not located within 1,000 feet of any additional NRHP sites; • crosses no areas of high archeological site potential.

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In addition to the factors utilized by HDR-and building on their recommendation-TNMP also evaluated each alternative transmission line route considering engineering, design, constructability, operation and maintenance, and estimated cost.

TNMP considers each of the alternative routes provided by HDR viable for the proposed project. TNMP agrees with HDR that Alternative Transmission Line Routes GC-7 and CC-2 provide the best balance ofrouting characteristics and best address the requirements of PURA and PUC Substantive Rules.

18. Public Meeting or Public Open House: Provide the date and location D,r each public meeting or public open house that was held in accordance with 16 TAC § 22.52. Provide a summary of each public meeting or public open house including the approximate number of attendants, and a copy of any survey provided to attendants and a summary of the responses received. For each public meeting or public open house provide a description of the method of notice, a copy of any notices, and the number of notices that were mailed and/or published.

A public meeting was held on June 30,2020, by appointment at the TNMP Office, located at 70236th Street North, Texas City, Texas, 77590. In addition to the letters and in-person public meeting, TNMP provided a Virtual Public Meeting that allowed members of the community to learn about the project and provide feedback through TNMP's website (www.tnmpcattail.com). Individual notification letters announcing the public meeting were directly mailed by TNMP to 481 landowners whose property iS located within 350 feet of each of the preliminary transmission line links. The notification letter was also mailed to 33 government officials and the Department of Defense. The public notice announced the location, time, and purpose of the meeting. Section 3.5.2.1 of the EA, Attachment 1, includes a detailed description of the public meeting and the responses received to the questionnaire. Copies of the Iandowner notice and the public notice are provided in Appendix B of the EA.

A total of five people signed lil at the in-person public meeting, and 17 participated ill the virtual public meeting. HDR personnel registered visitors and handed out a questionnaire and information packet. The virtual public meeting provided a similar experience in an online setting. The questionnaire solicited comments on citizen concerns as well as an evaluation of the information presented in the public meeting. Three questionnaires were submitted. A copy of the questionnaire can be found in Appendix B of the EA, Attachment 1.

19. Routing Maps: Base maps should be a full scale (one inch = not more than one mile) highway map of the county or counties involved, or other maps of comparable scale denoting sufficient cultural and natural features to permit location of aH routes in thefield. Provide a map (or maps) showing the study area, routing constraints, and aH routes or line segments that were considered prior to the selection of the routes. Identify the routes and any existingfacilities to be interconnected or coordinated with the project Identify any taps, ties, meter points, or other facilities involving other utilities on the routing map. Show all existing transmission facilities located in the study area. Include the locations of radio transmitters and other electronic insta!!ations, airstrips, irrigated pasture or cropland, parks and recreational areas, historical and archeological sites (subject to the instructions in Question 27), and any environmentally sensitive areas (subject to the instructions in

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Question 29).

The following study area, constraints, and routing maps are included in the EA, provided in Attachment 1 of this Application. Refer to:

Figure 2-1. Study Area Boundary Figure 2-2. Composite Constraints Figure 3-1. Preliminary Transmission Line Links Figure 3-2. Alternative Transmission Line Links Figure 5-1. Study Area Constraints Map

Provide aerial photographs of the study area displaying the date that the photographs were taken or maps that show (I) the location of each route with each route segment identified, (2) the locations of ali major public roads including, as a minimum, all federal and state roadways, (3) the locations of al! known habitable structures or groups of habitable structures (see Question 19 below) on properties directly affected by any route, and (4) the boundaries (approximate or estimated according to best available information if required) of all properties directly affected by any route.

Refer to Figure 5-1 of the EA, Attachment 1 Appendix D.

For each route, cross-reference each habitable structure for group of habitable structures) and directly affected property identified on the maps or photographs with a list of corresponding lando,vner names and addresses mid indicate which route segment affects each structure/group or property.

See Attachment 5.

20. Permits: List any and all permits and/or approvals required by other governmental agencies for the construction of the proposed project. Indicate whether each permit has been obtained.

Specific information concerning possible permits or approvals is discussed in greater detail in Section 1.3 of the EA, Attachment 1.

• Public Utility Commission of Texas (PUC): The proposed project requires approval ofa CCN by the PUC, which has not been obtained at this time. • United States Armv Corps of Engineers (USACE): The USACE has been directed by Congress to administer Section 10 of the Rivers and Harbors Act of 1899 (33 United States Code [U.S.C.] §403), and Section 404 of the Clean Water Act (CWA) (33 U.S.C. §1344). No streams within the study area are classified as "navigable waters of the U.S." under Section 10 ofthe Rivers and Harbors Act of 1899 according to the list published by the USACE Galveston District. Review of the National Hydrology Dataset (NHD) and National Wetland Inventory (NWI) maps indicates a small number of surface waters of the U.S. within the study area. Surface waters include riverine and lacustrine habitats associated with creeks, ditches, ponds, and small reset'voirs. NWI indicates that wetlands are located in the study area associated with water bodies and floodplains. Upon PUC approval of a route, additional coordination, jurisdictional wetland verifications, and permitting with the USAGE Galveston District for a Section 404 permit may be required. The construction of the transmission line willlikely meet the criteria of the Nationwide Permit (NWP) No. 12-Utility Line Activities, which

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applies to activities associated with any cable, line, or wire for the transmission of electrical energy, so that generally no further USACE permitting would be needed. If the proposed impacts of the project exceed the criteria established under NWP 12 or other regional conditions listed under the NWP, then a preconstruction notification or an Individual Permit will be required. • United States Fish and Wildlife Service (USFWS): The USFWS is charged with the responsibility of enforcement of federal wildlife laws and providing comments on proposed construction projects with a federal nexus under the National Environmental Policy Act (NEPA); and within the framework of several federal laws including the Endangered Species Act (ESA), Migratory Bird Treaty Act (MBTA), and Bald and Golden Eagle Protection Act (BGEPA). HDR reviewed the USFWS listed species for Galveston County, Texas and solicited Texas Natural Diversity Database (TXNDD) element occurrence records from the Texas Parks and Wildlife Department (TPWD). Upon PUC approval of a route, coordination with the USFWS Houston Ecological Services Field Office may be required to determine the need for any required species- specific surveys or additional permitting under Section 7 of the ESA and the MBTA. • Federal Aviation Administration (FAA): According to FAA regulations, Part 77, the construction of a transmission line requires FAA notification if any tower structure height exceeds the height of an imaginary surface extending outward and upward at one of the following slopes: o A 100:1 slope for a horizontal distance of 20,000 feet from the nearest point of the nearest runway of a public or military airport having at least one runway longer than 3,200 feet. o A 50:1 slope for a horizontal distance of 10,000 feet from the nearest runway of a public or military airport where no runway is longer than 3,200 feet in length. o A 25:1 slope for a horizontal distance of 5,000 feet from heliports. The PUC CCN application also requires listing private airports within 10,000 feet of any alternative route centerline. After PUC route approval, and if any of the FAA notification criteria are met for the selected route, a Notice of Proposed Construction or Alteration, FAA Form 7460-1, will be completed and submitted to the FAA Southwest Regional Office in Fort Worth, Texas at least 45 days prior to construction. • Texas Parks and Wildlife Department (TPWD): The TPWD is the state agency with the primary responsibility of protecting the state's fish and wildlife resources in accordance with the Texas Parks and Wildlife Code Section 12.0011(b). HDR solicited comments from the TPWD during the proJect scoping phase of the project, and a copy of this EA will be submitted to the TPWD when the CCN application is filed with the PUC. Once the PUC approves a route, additional coordination with the TPWD may be necessary to determine the need for any additional surveys, and to avoid or minimize any potential adverse impacts to sensitive habitats, threatened or endangered species, and other fish and wildlife resources. • Texas Commission on Environmental Oualitv (TCEO): The construction ofthe proJect may require a Texas Pollution Discharge Elimination System (TPDES) General Construction Permit (TX150000) as implemented by the TCEQ under the provisions of Section 402 ofthe CWA, and Chapter 26 of the Texas Water Code. The TCEQ has developed a tiered approach for implementing this permit that 1S dependent on the acreage ofground disturbance. A general permit (TXR150000) is not required for land disturbances of less than one acre that are not part of a larger common plan of development. o A Stormwater Pollution Prevention Plan (SWPPP) must be developed prior to and implemented during construction activities, accompanied with posting

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a site notice and sending notification to the Municipal Separate Sewer System Operator, if applicable. If more than five acres of land are disturbed, then the previous requirements mentioned above are necessary, and the submittal of a Notice of Intent (NOI) and Notice of Termination (NOT) are also required by the TCEQ. Once a route is approved by the PUC, the proposed disturbed surface area will be calculated, and appropriate conditions of the TXR150000 permit will be determined. o ASection 401 Water Quality Certificatefromthe TCEQmayalsoberequired if the project requires a USACE Individual Permit for proposed impacts to surface waters or wetlands as previously discussed. The TCEQ has the authority to review federally permitted or licensed activities that may result in a discharge of pollutants to the waters of the U.S. within the state ofTexas. • Texas Department of Transportation (TxDOT): The Texas Department of Transportation (TxDOT) has been notified of the proposed project. If the route approved by the PUC crosses TxDOT roadways, the project will be constructed in accordance with the rules, regulations, and policies of TxDOT. Best Management Practices (BMPs) will be used, as required, to minimize erosion and sedimentation resulting from the construction. Revegetation will occur within existing TxDOT ROWs as required under the "Revegetation Special Provisions" and contained in TxDOT Form 1023 (Rev. 9-93). Traffic control measures will comply with applicable portions of the Texas Manual of Uniform Traffic Control Devices. • Texas Historical Commission (THC): Cultural resources are protected by federal and state laws if they have some level of significance under the criteria of the National Register of Historic Places (NRHP) (36 Code of Federal Regulations [CFR] Part 60) or under state guidance (Texas Administrative Code (TAC), Title 13, Part 2, Chapter 26.7-8). Once a route is approved by the PUC, additional coordination with the THC will occur, if required, to determine the need for cultural resources surveys or additional permitting requirements. Even if no additional surveys are required, TNMP will implement an unanticipated discovery procedure during construction activities. If artifacts are discovered during construction, activities will cease, and TNMP will notify the State Historic Preservation Office (SHPO) for additional consultation. • Texas General Land Office (GLO): The GLO requires a miscellaneous easement for ROW within any state-owned riverbeds or navigable water. No easements are anticipated from the GLO as there are no navigable waters identified within the study area. • Galveston County Floodplain Administrator: Construction of the proposed transmission line is not anticipated to create any significant permanent changes in the existing topographical grades and should not significantly affect the stormwater runoff rates within the study area. Additional coordination with the Galveston County floodplain administrator may be required after PUC route approval to determine if any permits or mitigation are necessaty

21. Habitable structures: For each route list all single-family and multi-family dwellings and related structures, mobile homes, apartment buildings, commercial structures, industrial structures, business structures, churches, hospitals, nursing homes, schools, or other structures normally inhabited by humans or intended to be inhabited by humans on a daily or regular basis within 300 feet of the center·line if the proposed project will be constructed for operation at 230kV or less, or within 500 feet of the centerline iftheproposedprojectwill be constructed for operation at greater than 230kV. Provide a general description of each habitable

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structure and its distance from the centerline of the route. In cities, towns or rural subdivisions, houses can be identified in groups. Provide the number ofhabitable structures in each group and list the distance front the centerline of the route to the closest and the farthest habitable structure in the group. Locate aH listed habitable structures or groups of structures on the routing map.

The locations of habitable structures within 300 feet of the ROW centerline are listed and described with the approximate distance to the ROW centerline in Table 4-3 of Appendix C of the EA, Attachment 1, and are shown on Figure 5-1 of the EA (Appendix D).

22. Electronic Installations: For each route, list all commercial AM radio transmitters located within 10,000 feet ofthe center line of the route, and a!1 FM radio transmitters, microwave relay stations, or other similar electronic installations located within 2,000 of the center line of the route. Provide a general description of each installation and its distancefrom the center line of the route. Locate ali listed installations on a routing map.

There are no known AM radio transmitters located within 10,000 feet of the centerline ofany of the alternative routes.

Communication towers (FM radio transmitters, microwave relay stations, or other similar electronic installations) located within 2,000 feet of the centerline of alternative transmission line routes are documented in Table 4-3 of Appendix C of the EA, Attachment 1.

For additional information on electronic installations, see Sections 2.2.1.8.2,4.1.2.9.2, and 4.2.2.9.2 of the EA, Attachment 1.

23. Airstrips: For each route, list a!! known private airstrips within 10,000 feet of the center line of the project. List all airports registered with the Federal Aviation Administration (FAA) with at least one runway more than 3,200 feet in length that are located within 20,000 feet of the center line of any route. For each such airport, indicate whether any transmission structures wiH exceed a 100: I horizontal slope (one foot in height for each 100 feet in distance) from the closestpoint ofthe closest runway. List ali listed airports registered with the FAA having no runway more than 3,200 feet in length that are located within 10,000 feet of the center line of any route. For each such airport, indicate whether any transmission structures will exceed a 50:1 horizontal slope from the closest point of the closest runway. List all heliports located within 5,000 feet ofthe center line of any route. For each such heliport, indicate whether any transmission structures will exceed a 25:1 horizontal slopefrom the closestpoint of the closest landing and takeoff area ofthe heliport. Provide a general description of each listed private airstrip, registered airport, and heliport; and state the distance of eachfrom the center line of each route. Locate and identify a!1 listed airstrips, airports, and heliports on a routing map.

According to public records, no public airport is located within a 20,000-foot radius of the study area boundaries.

One heliport was observed or registered within 5,000 feet of the study area. This heliport is located within the western portion ofthe study area, near the intersection of 3rd Avenue South and 25th Street South.

For additional information on airports and/or atrstrips see Sections 2.2.1.7.3,4.1.2.8.2, and

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4.2.2.8.2 of the EA, Attachment 1.

Following approval of any of these proposed alternative routes by the PUC, TNMP will make a final determination of the need for FAA notification, based on specific route location and structure design. The result of this notification, and any subsequent coordination with FAA, could include changes in the line design and/or potential requirements to mark and/or light the structures.

24. Irrigation Systems: For each route identify any pasture or cropland irrigated by traveling irrigation systems (rolling or pivot type) that will be traversed by the route. Provide a description of the irrigated land and state howitwill be affected by each route (number and type ofstructures, etc.). Locate any such irrigated pasture or cropland on a routing map.

According to the results of the review of aerial photos and field reconnaissance, the proposed project does not cross any known cropland or pastureland irrigated by traveling irrigation systems, either rolling or pivot type.

25. Notice: Notice is to be provided in accordance with 16 TAC § 22.52.

A. Provideacopyofthewritten directnoticetoownersofdirectlyaffectedland. Attach a list of the names and addresses ofthe owners ofdirectly affected land receiving notice.

Example copies of the written direct notices, with attachments, mailed to owners of directly affected land are provided as Attachment 7 to the Application. Landowners of record for directly-affected land were determined by review of information obtained from the current county tax rolls, which is provided in Attachment 8. Notice was mailed to names and addresses ofthose landowners by first-class mail or, where the county tax rolls did not include an address, by priority mail to an alternative address, as set forth in TNMP's Affidavit of Notice.

B. Provide acopy ofthe written notice to utilities thatare located withinjive miles of the routes.

A copy of the written notice provided to CenterPoint Energy is provided as Attachment 11 to this Application.

C. Provide a copy of the written notice to county and municipal authorities, and the Department of Defense Siting Clearinghouse. Notice to the DoD Siting Clearinghouse should be provided at the email address found at http://www.a cq.osd.mil/dodsc/.

A copy of the written notice provided to county and municipal authorities is provided as Attachment 9 to this Application. The names and addresses of county and municipal authorities to whom the written notices were sent are provided in Attachment 10. A copy of the written notice to the Department of Defense Siting Clearinghouse can be found in Attachment 12.

D. Provide a copy of the notice that is to be published in newspapers of general circulation in the counties in which the facilities are to be constructed. Attach a

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list of the newspapers that will publish the notice for this application. After the notice is published, provide the publisher's a#idavits and tear sheets.

A copy ofthe notice that will be published in the newspaper of general circulation in the study area is provided as Attachment 13 . The newspaper is the Galveston County Daily News . Publisher ' s affidavits and tear sheets will be provided after the notice is published and the affidavits are received.

Additionally, a copy of the written notice provided to gas pipelines is provided as Attachment 14 to this Application. The names and address of the gas pipelines to whom the written notices were sent are provided in Attachment 15. The names and addresses of the gas pipelines were obtained from the Railroad Commission ofTexas website. A copy of the written notice provided to the Texas Office of Public Utility Counsel ("OPUC") is provided in Attachment 16.

For a CREZ application, in addition to the requirements of 16 TAC § 22.52 the applicant shall, not less than twenty-one (21) days before the filing of the application, submit to the Commission staff a "generic" copy of each type ofalternative published and written noticefor review. Staffs comments, if any, regarding the alternative notices will be provided to the applicant not later than seven days after receipt by Staff of the alternative notices, Applicant may take into consideration any comments made by Commission staff before the notices are published or sent by mail.

This provision is not applicable to the proposed project because it is not a CREZ project.

26. Parks and Recreation Areas: For each route, list all parks and recreational areas owned by a governmental body or an organized group, club, or church and located within 1,000 feet of the center line of the route. Provide a general description of each area and its distance from the center line. Identify the owner of the park or recreational area (public agency, church, club, etc.). List the sources used to identify the parks and recreational areas. Locate the listed sites on a routingmap.

There are three parks within 1,000 feet of Greenbelt to Cattail alternative transmission line routes, one of which is crossed by six of the GC alternative transmission line routes. There are no parks within 1,000 feet of the Cattail to Cherokee alternative transmission line routes. For more information on park and recreational areas see Sections 2.2.1.5, 4.1.2.6, and 4.2.2.6 of the EA, included as Attachment 1.

27. Historical and Archeological Sites: For each route, list a!! historical and archeological sites known to be within 1,000 feet of the center line of the route. Include a description of each site and its distance from the center line. List the sources (national, state or Ioca! commission or societies) used to identify the sites. Locate all historical sites on a routing map. For the protection of the sites, archeological sites need not be shown on maps.

HDR conducted a literature review and records search at the Texas Historical Commission and the Texas Archeological Research Laboratory at the University of Texas at Austin to identify known historical and archeological sites located within 1,000 feet of the proposed alternate routes. For more information regarding site descriptions and the evaluation of the historical and archeological sites see Section 2.4, Section 4.1.4, and Section 4.2.4 ofthe EA.

Based on this review, no historic sites have been previously recorded within 1,000 feet of the alternative transmission line routes.

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28. Coastal Management Program: For each route, indicate whether the route is located, either in whole or in part, within the coastal management program boundary as defined in 31 TAC §503.1. If any route is, either in whole or in part, within the coastal management program boundary, indicate whether any part of the route is seaward of the Coastal Facilities Designation Line as defined in 31 TAC §19.2(a)(21). Using the designations in 31 TAC §501.3(b), identify the type(s) of Coastal Natural Resource Area(s) impacted by any part of the route and/or facilities.

The proposed project is located wholly within the coastal management program boundary, as defined in 31 T.A.C. §503.1. As a result, all alternative transmission line routes are wholly within the coastal management program boundary, as defined in 3 1 T.A.C. §503.1. All of the alternative transmission line routes are seaward of the Coastal Facilities Designation Line as defined in 31 T.A.C. §19.2(a)(21); however, no impacts to Coastal Natural Resource Areas as defined in 31 T.A.C. §501.3(b) are anticipated. 29. Environmental Impact: Provide copies of any and all environmental impact studies and/or assessments of the project If no formal study was conductedfor thisproject, explain how the routing and construction of this project will impact the environment. List the sources used to identify the existence or absence of sensitive environmental areas. Locate any environmentally sensitive areas on a routing map. In some instances, the location of the environmentally sensitive areas or the location of protected or endangered species should not be included on maps to ensure preservation of the areas or species. Within seven days after filing the application for the project, provide a copy of each environmental impact study and/or assessment to the Texas Parks and Wildlife Department (TPWD) for its review at the address below. Include with this application a copy of the letter of transmittal with which the studies/assessments were or will be sent to the TPWD.

Wildlife Habitat Assessment Program Wildlife Division Texas Parks and Wildlife Department 4200 Smith School Road Austin, Texas 78744

Texas Parks and Wildlife Department 4200 Smith School Road Austin, Texas 78744

The applicant shall file an affidavit confirming that the letter of transmittal and studies/assessments were sent to TPWD.

Please see the Environmental Assessment and Routing Study for the Greenbelt-Cattail-Cherokee 138 kV Transmission Line Project included as Attachment 1. The EA includes environmental sources, routing maps with environmentally-sensitive areas identified, and information on protected and endangered species within or near the study area.

A copy of the EA will be mailed by first class mail to the TPWD for review within seven days after the Application is filed with the PUC. A copy of the transmittal letter to TPWD is provided as Attachment 17. An affidavit confirming that the letter of transmittal and a copy of the EA were sent to TPWD will be sent to the PUC.

30. Affidavit

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Attach a sworn affidavit from a qualified individual authorized by the applicant to verify and a#irm that, to the best of their knowledge, aH information provided, statements made, and matters set forth in this application and attachments are true ancl correct.

An affidavit is included as Attachment 21.

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ENVIRONMENTAL ASSESSMENT AND ROUTING STUDY FOR THE GREENBELT-CATTAIL-CHEROKEE 138 KV TRANSMISSION LINE PROJECT GALVESTON COUNTY, TEXAS

Prepared for:

Texas New Mexico Power Company 702 36th Street North Texas City, Texas 77590

Tlvl

Texas-New Mexico Power

Prepared by:

HDR, Inc. 17111 Preston Road, Suite 300 Dallas, Texas 75248

September 2020

Page 22 of 528 Attachment 1 - Greenbelt-Cattail-Cherokee Environmental Assessment and Routing Study Greenbelt-Cattail-Cherokee 138 kVTransmission Line Project

TABLE OF CONTENTS

List of Figures ...... w List of Tables...... vi Acronyms and Abbreviations...... viii

1.0 DESCRIPTION OF THE PROPOSED PROJECT 1-1 1.1 SCOPE OF THE PROJECT...... 1-1 1.2 PURPOSE AND NEED...... 1-1 1.3 AGENCY ACTIONS...... 1-3 1.3.1 Public Utility Commission of Texas...... 1-3 1.3.2 United States Army Corps of Engineers...... 1-3 1.3.3 United States Fish and Wildlife Service...... 1-4 1.3.4 Federal Aviation Administration...... 1-4 1.3.5 Texas Patl

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2 . 2 . 1 . 3 Urban and Residential Arpaq 9 -7 2.2.1.4 Industrial Areas...... 2-8 2.2.1.5 Recreation and Park Areaq 2-8 2.2.1.5.1 Federal and State Parks and Protected Areas...... 2-9 2.2.1.5.2 County and Local Parks...... 2-9 2.2.1.5.3Wildlife Viewing Trails...... 2-9 2.2.1.5.4 Conservation Easements...... 2-9 2.2.1.5.5 Private Recreation Areas...... 2-10 2.2.1.6 Cemeteries...... 2-10 2.2.1.7 Transportation/Aviation...... 2-10 2.2.1.7.1 Roadways...... „2-10 2.2.1.7.2 Railrnmrlq 2-10 2.2.1.7.3 Aviation...... 2-10 2.2.1.8 Uilities...... 2-11 2.2.1.8.1 Utility Linpq 2-11 2.2.1.8.2 Communication Towers...... 2-11 2.2.1.8.3WaterWells...... 2-12 2.2.1.8.4 Oil and Gas FacilitiAR 2-12 2.2.1.9 Schools...... 2-12 2.2.1.10 Planned Land I Iqp. 2-13 2.3 AESTHETIC VALUES ...... 2-14 2.4 CULTURAL RESOURCES AND HISTORICAL VALUES ...... 2-15 2.4.1 Cultural Background ...... 2-16 2.4.1.1 Paleoindian Period (ca. 10,000-5,000 B.C.)...... 2-16 2.4.1.2 Archaic Period (ca. 5,000 B.C.-A. D. 100)...... 2-16 2.4.1.3 Early Ceramic Period (ca. A.D. 100-600)...... 2-18 2.4.1.4 Late Prehistoric Period (A.D. 600-1500) ...... 2-18 2.4.1.5 Protohistoric and Early Historic Period (A.D. 1500-1700)...... 2-18 2.4.1.6 Historical Context of Texas City...... 2-19 2.4.2 Records Re\Aew ...... 2-20 2.4.2.1 Official Texas Historical Markers...... 2-20 2.4.2.2 Geology, Soils, and Landforms...... 2-21 2.5 ENVIRONMENTAL INTEGRITY...... 2-21 2.5.1 Ecological Region...... 2-21 2.5.2 Physiography and Geology...... 2-22 2.5.2.1 Physiography...... 2-22 2.5.2.2 Geological Hazards...... 2-22 2.5.3 Vegetation...... 2-24

ii

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2.5.3.1 Vegetation Types...... 2-24 2.5.3.2 Aquatic and Hydric Habitats...... 2-26 2.5.4 Soils...... 2-28 2.5.4.1 Prime Farmland Soils...... 2-29 2.5.5 Water Resources...... 2-29 2.5.5.1 Surface Waters...... 2-30 2.5.5.2 Floodplains...... 2-30 2.5.5.3 Groundwater...... 2-30 2.5.5.4 Special Status Waters...... 2-31 2.5.5.5 Future Surface Water Demlopments ...... 2-31 2.5.6 Wildlife and Fisheries...... 2-32 2.5.6.1 Wildlife inthe Area...... 2-32 2.5.6.2 Fisheries inthe Area...... 2-37 2.5.7 Threatened and Endangered Species...... 2-38 2.5.7.1 Wildlife Species...... 2-39 2.5.7.2 Plant Species...... 2-44 2.5.7.3 TPWD Species of Concern and Sensitive Vegetation Communities...... 2-44 3.0 ALTERNATIVE TRANSMISSION LINE ROUTE IDENTIFICATION 3-1 3.1 ROUTING STUDY METHODOLOGY...... 3-1 3.1.1 Base Map Development...... 3-2 3.1.2 Study Area Delineation...... „...... „...... 3-2 3.1.3 Evaluation Criteria...... 3-2 3.2 DATA COLLECTION AND CONSTRAINTS MAPPING...... 3-4 3.3 RESOURCE ANALYSIS...... 3-6 3.4 OPPORTUNITIES AND CONSTRAINTS ANALYSIS ...... 3-6 3.4.1 Existing Linear Corridors...... 3-7 3.4.2 Apparent Property Boundaries...... 3-7 3.4.3 Roadway ROWs ...... 3-7 3.4.4 Existing Transmission Line ROWs...... 3-7 3.5 ALTERNATIVE TRANSMISSION LINE ROUTE IDENTIFICATION...... 3-7 3.5.1 Preliminary Transmission Line Links...... 3-7 3.5.2 Public Involvement Program ...... 3-8 3.5.2.1 Public Meeting...... 3-8 3.5.2.2 Comments from Agencies, Officials, and Organizations...... 3-12 3.5.3 Modifications and Additions to Preliminary Transmission Line Links...... 3-13

3.5.4 Altemati~e Transmission Line Routes...... 3-13 4.0 POTENTIAL IMPACTS OF THE ALTERNATIVE ROUTFR 4-1

111

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4.1 GREENBELT TOCATTAIL SEGMENT...... 4-1 4.1.1 Impacts on Community Values and Socioeconomics...... 4-1 4.1.1.1 Community Values...... 4-1 4.1.1.2 Socioeconomics...... 4-1 4.1.2 Impacts to Land Use and Recreational and Park Areas...... 4-2 4.1.2.1 Altemati~e Transmission Line Route Length...... 4-2 4.1.2.2 Compatible ROW...... 4-3 4.1.2.3 Agricultural Land...... 4-5 4.1.2.4 Residential Land...... 4-6 4.1.2.5 Commercial and Industrial Land...... 4-7 4.1.2.6 Parks and Recreational Areas...... 4-7 4.1.2.7 Cemeteries...... 4-8 4.1.2.8 Transportation...... 4-8 4.1.2.8.1 Roadways...... 4-8 4.1.2.8.2 Aviation...... 4-8 4.1.2.9 Uilities...... 4-8 4.1.2.9.1 Utility Lines...... 4-8 4.1.2.9.2 Communication Towers...... 4-9 4.1.2.9.3WaterWells...... 4-10 4.1.2.9.4 Oil and Gas Facilities...... 4-10 4.1.3 Impacts to Aesthetic Values...... 4-10 4.1.4 Impacts to Cultural Resources and Historical Values...... 4-12 4.1.4.1 Archeological Sites...... 4-14 4.1.4.2 Summary...... 4-14 4.1.5 Impacts to Environmental Integrity...... 4-14 4.1.5.1 Physiography and Geology...... 4-14 4.1.5.2 Vegetation...... 4-15 4.1.5.2.1 Endangered and Threatened Plant Species...... 4-15 4.1.5.2.2 Commercially or Recreationally Important Plant Species...... 4-15 ...... 41.5.3 Soils 4-16 4.1.5.4 Water Resources...... 4-17 4.1.5.4.1 Surface Waters...... 4-17 4.1.5.4.2 Floodplains...... 4-18 4.1.5.4.3 Groundwater...... 4-18 4.1.5.5 Wildlife and Fisheries...... 4-19 4.1.5.5.1 Threatened and Endangered Species...... 4-20 4.2 CA1TAIL TO CHEROKEE SEGMENT...... ,...... 4-20 4.2.1 Impacts on Community Values and Socioeconomics...... 4-20

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4.2.1.1 Community Values...... 4-20 4.2.1.2 Socioeconomics...... 4-21 4.2.2 Impacts to Land Use and Recreational and Park Areas...... 4-21 4.2.2.1 Alternatim Route Length...... 4-20 4.2.2.2 Compatible ROW...... 4-22 4.2.2.3 Agricultural Land...... 4-24 4.2.2.4 Residential Land...... 4-25 4.2.2.5 Commercial and Industrial Land...... 4-26 4.2.2.6 Parks and Recreational Areas...... 4-26 4.2.2.7 Cemeteries...... 4-26 4.2.2.8 Transportation ...... 4-26 4.2.1.8.1 Roadways...... 4-26 4.2.1.82Aviation...... 4-27 4.2.2.9 Uilities...... 4-27 2.2.2.9.1 Utility Lines...... 4-27 4.2.2.9.2 Communication Towers...... 4-28 4.2.2.9.3WaterWells...... 4-28 4.2.2.9.4 Oil and Gas Facilities...... 4-28 4.2.3 Impacts to Aesthetic Values...... 4-28 4.2.4 Impacts to Cultural Resources and Historical Values...... 4-31 4.2.4.1 Archeological Sites...... 4-32 4.2.4.2 Summary ...... 4-32 4.2.5 Impacts to Environmental Integrity...... 4-33 4.2.5.1 Physiography and Geology...... 4-33 4.2.5.2 Vegetation...... 4-33 4.2.5.2.1 Endangered and Threatened Plant Species...... 4-33 4.2.5.2.2 Commercially or Recreationally Important Plant Species...... 4-33 4.2.5.3 Soils ...... 4-34 4.2.5.4 Water Resources ...... 4-35 4.2.5.4.1 Surface Waters...... 4-35 4.2.5.4.2 Floodplains...... 4-36 4.2.5.4.3 Groundwater...... 4-36 4.2.5.5 Wildlife and Fisheries...... 4-37 4.2.5.5.1 Threatened and Endangered Species...... 4-38 5.0 ROUTE SELECTION 5-1 5.1 ROUTE EVALUATION...... 5-1 5.2 HDR'S ENVIRONMENTAL EVALUATION...... 5-1 5.2.1 Methodology...... 5-1

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Page 27 of 528 Attachment 1 - Greenbelt-Cattail-Cherokee Environmental Assessment and Routing Study Greenbelt-Cattail-Cherokee 138 kVTransmission Line Proiect

5.2.2 Greenbelt to Cattail Segment...... 5-2 5.2.3 Cattail to Cherokee Segment...... 5-5 5.3 SELECTION OF THE ROUTES WHICH BESTADDRESS THE REQUIREMENTS OF PURA AND PUC SUBSTANTIVE Rl Il FS 5-9 6.0 LIST OF PREPARERR 6-1 7.0 REFERENCES CITFn 7-1 Appendices: A Agency Correspondence B Public Meetinglnformation C Environmental Data for Link Evaluation (Table 4-1) and Environmental Data for Route Evaluation (Table 4-2) and Habitable Structuresand OtherLand Use Features intheVicinityoftheAIternati\e Transmission Line Routes (Table 4-3) D Study Area Constraints Map (Figure 5-1)

List of Figures

Figure 1-1 Project Vicinity Map...... 1-2 Figure 1-2100-Year Floodplain Map...... 1-6 Figurel-3 Single Circuit 138 kV Delta Single Steel Pole...... 1-9 Figure 1-4 Single Circuit 138 kV Vertical Stacked Single Steel Pole...... 1-10 Figure 1-5 Two Circuit 138 kV Single Steel Pole with Distribution Underbuild...... 1-11 Figure 1-6 Two Circuit 138 kV Vertical Stacked Single Steel Pole with Distribution Underbuild...... 1-12 Figure 2-1 Stu* Area Boundary...... 2-2 Figure 2-2 Composite Constraints...... 2-6 Figure 2-3 Cultural Resources Planning Regions...... 2-17 Figure 2-4 Physiographic Regions of Texas...... 2-23 Figure 2-5 Vegetational Areas of Texas...... 2-27 Figure 2-6 Biotic Provinces of Texas...... 2-33 Figure 3-1 Preliminary Transmission Line Links...... 3-9 Figure 3-2 Alternative Transmission Line Links...... 3-15 Figure 5-1 Study Area Constraints Map...... (Appendix D)

List of Tables

Table 2-1 Population Trends...... 2-4 Table 2-2 Leading Occupationsin Galveston County, Texas...... 2-4 Table 2-3 Top Employing Industries in Gabeston County, Texas...... 2-5 Table 2-4 Water Wells within the Study Area...... 2-12 Table 2-5 General Cultural Chronology for Southeast Texas...... 2-16

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Page 28 of 528 Attachment 1 - Greenbelt-Cattail-Cherokee Environmental Assessment and Routing Study Greenbelt-Cattail-Cherokee 138 kV Transmission Line Project

Table 2-6 Previously Recorded Official Texas Historical Markers within the Study Area...... 2-21 Table 2-7 Vegetation Types Mapped inthe Study Area...... 2-24 Table 2-8 Mapped Soil Units within the Study Area...... 2-28 Table 2-9 Amphibian Species Potentially Occurring withinthe Study ArPA 2-32 Table 2-10 Reptilian Species Potentially Occurring withinthe Study Area...... 2-34 Table 2-11 Year-Round Resident Bird Species Potentially Occurring within the Study Area....._...... 2-35 Table 2-12 Winter Resident Bird Species Potentially Occurring within the Study Area...... 2-36 Table 2-13 Summer Resident Bird Species Potentially Occurring within the Study Area...... 2-36 Table 2-14 Mammalian Species Potentially Occurring within the Study Area...... 2-37 Table 2-15 Fish Species Potentially Occurring withinthe Stu* Area...... 2-38 Table 2-16 Threatened, Endangered, and Candidate Species Listed for Galveston County, Texas..... 2-40 Table 2-17 TPWD Species of Greatest Conservation Need for Galveston County, Texas...... 2-44 Table 3-1 Land Use and Environmental Evaluation Criteria ...... 3-3 Table 3-2 Link Composition of the Alternative Transmission Line Routes...... 3-14 Table 4-1 Endronmental Data for Link Evaluation...... (Appendix C) Table 4-2 Environmental Data for Route Evaluation...... (Appendix C) Table 4-3 Habitable Structures and Other Land Use Features in the Vicinity of the Alternative Routes...... (Appendix C) Table 5-1 HDR's Ranking of the Greenbelt to Cattail Altemati\,e Transmission Line Routes...... 5-2 Table 5-2 HDR's Ranking of the Cattail to Cherokee Altemati\,e Transmission Line Routes ...... 5-6

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Page 29 of 528 Attachment 1 - Greenbelt-Cattail-Cherokee Environmental Assessment and Routing Study Greenbelt-Cattail-Cherokee 138 kVTransmission Line Project

Acronyms and Abbreviations

ACSR Aluminum conductorsteel-reinforced AM Amplitude Modulation ASARCO American Smeltingand Refining Company BEG Bureauof EconomicGeology BGEPA Bald and Golden Eagle Protection Act BMP Best Management Practices CCN Certificateof Convenience and Necessity CFR Codeof Federal Regulations Commission Public UtilityCommissionof Texas, also PUC CR County Road CWA Clean WaterAct EA Environmental Assessmentand Routing Study EMST Ecological Mapping Systemof Texas ESA Endangered SpeciesAct ESSS Ecologically Significant Stream Segment ETJ Extraterritorial jurisdiction EO Executive Order FAA Federal Aviation Administration FCC Federal Communications Commission FEMA Federal Emergency Management Agency FM Farm-to-Market Road FM Frequency Modulation FWS U.S. Fish and Wildlife Service GIS Geographic Information Systems HDR HDR, Inc. H-GAC Houston-Galveston Area Council HPA High probabilityarea IPaC Information for Planningand Consultation ISD IndependentSchooIDistrict kV Kilovolt LM Land mobile MBTA Migratory Bird Treaty Act ME Miscellaneouseasement NCED National Conservation Easement Database NEPA National Environmental PolicyAct NESC National Electrical SafetyCode NHD National Hydrography Dataset NHL National Historical Landmark NHPA National Historic Preservation Act NOI Notice of Intent NOT Notice of Termination NPS National Park Service

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Page 30 of 528 Attachment 1 - Greenbelt-Cattail-Cherokee Environmental Assessment and Routing Study Greenbelt-Cattail-Cherokee 138 kVTransmission Line Proiect

NRCS Natural Resources Conservation Service NRHP National Registerof Historic PIaces NWI National Wetland Inventory NWP Nationwide Permit OPGW Opticalgroundwire OTHM Official Texas HistoricaIMarker PADUS Protected Areas Dataset puc Public Utility Commission of Texas, also Commission PURA Public Utility Regulatory Act RIP Record, Investigate, and Protect program ROW Right-of-way RRC RailroadCommissionofTexas SGCN Species of greatest conservation need SH State Highway SHPO State Historic Preservation Office SWPPP Storm Water Pollution Prevention Plan TAC Texas Administrative Code TARL Texas Archeological Research Laboratory TASA Texas Archeological Site Atlas TCEQ Texas Commissionon EnvironmentaIQuality TGLO Texas General Land Office THC Texas HistoricaICommission THSA Texas Historical Sites Atlas TIGER Topographicallylntegrated GeographicEncodingand Reference TMDL Total Maximum Daily Load TNMP Texas-New Mexico Power Company TPDES Texas Pollution Discharge EIimination System TPWD Texas Parksand Wildlife Department TWDB Texas Water Development Board TxDOT Texas Departmentof Transportation TXNDD Texas Natural Diversity Database U.S. United States USACE U.S. Army Corps of Engineers U.S.C. United States Code USCB United States Census Bureau USDA U.S. DepartmentofAgriculture USDOD U.S. Departmentof Defense Siting CIearinghouse USEPA U.S. Environmental ProtectionAgency USGS U.S. Geological Survey

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Page 31 of 528 Attachment 1 - Greenbelt-Cattail-Cherokee Environmental Assessment and Routing Study Greenbelt-Cattail-Cherokee 138 kV Transmission Line Proiect

1.0 DESCRIPTION OF THE PROPOSED PROJECT 1.1 SCOPE OF THE PROJECT Texas-New Mexico Power (TNMP) proposes to construct approximately three miles of new transmission line in Galveston County, Texas. See Figure 1-1 for a map of the area of the project vicinity. The Greenbelt-Cattail-Cherokee 138 kV Transmission Line Project, the subject of this Environmental Assessment and Routing Study (EA), will connect the existing Greenbelt Substation to the proposed Cattail Substation Site, then the proposed Cattail Substation Site to the existing Cherokee Substation. The western-most substation (Greenbelt Substation) is located at the northwest corner of the intersection of 27th Street South and 5th Avenue South. The eastern-most substation site (Cattail Substation Site) will be located northeast of the intersection of 6th Street South and 2nd Avenue South. The southern-most substation (Cherokee Substation) is located 0.15 mile southwest of the intersection of 14th Street South and TX 197 Loop South.

TNMP retained HDR, Inc. (HDR) to prepare this EA to support the application for a Certificate of Convenience and Necessity (CCN) forthe proposed project. This EA discusses the environmental and land use constraints identified within the study area, documents routing methodologies and public involvement, and provides an evaluation of alternative routes. This document provides information in compliance with the requirements of Section 37.056(c)(4)(A)-(D) of the Texas Utilities Code (Public Utility Regulatory Act or PURA), the Public Utility Commission of Texas (PUC or Commission) CCN application form, and PUC Substantive Rule 25.101. The EA may also be used to provide information for local, state, or federal permitting activities that may be required for construction of the proposed project.

To assist HDR with the evaluation of the proposed project, TNMP provided HDR with the project nodes, information regarding the need, construction practices, and right-of-way (ROW) requirements.

1.2 PURPOSE AND NEED Texas City is home to a number of petrochemical facilities and other industrial power users. The Electric Reliability Council of Texas (ERCOT), the regional transmission organization responsible for overseeing the adequate supply of electricity for 80 percent of Texas, designated this project to further develop electric reliability in the region. This transmission line project will directly support the area's economic development and ensure reliable electric service.

1-1

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1.3 AGENCY ACTIONS Numerous federal, state, and local regulatory agencies have rules and regulations regarding the routing process and potential impact assessment associated with construction of high voltage electricaltransmission lines. Thissection describesthe major regulatoryagenciesand issuesthat are involved in planning and permitting of transmission lines within the state of Texas. HDR solicited project scoping comments from various regulatory agencies during the development of this document. Records of correspondence are provided in Appendix A.

1.3.1 Public Utility Commission of Texas The PUC regulates the routing of transmission lines in Texas under Section 37.056(c)(4)(AHD) of PURA. The PUC regulatory rules and guidelines for routing transmission lines include:

• PUC Substantive Rule 25.101(b)(3)(B) • Policy of prudent avoidance • PUC Procedural Rule 22.52(a)(4) • CCN application requirements

This EA has been prepared by HDR in support of TNMP's CCN application forthis project to be filed at the PUC for approval.

1.3.2 United States Army Corps of Engineers The United States Army Corps of Engineers (USACE) has been directed by Congress to administer Section 10 of the Rivers and Harbors Act of 1899 (33 United States Code [U.S.C.] §403), and Section 404 of the Clean Water Act (CWA) (33 U.S.C. §1344). Under Section 10, the USAGE regulates all work or structures in or affecting the course, condition, or capacity of navigable waters of the United States (U.S.). The intent of this law is to protect the navigable capacity of waters important to interstate commerce. Under Section 404 of the CWA, the USACE regulates the discharge of dredged and fill material into "waters of the U.S.," including associated wetlands. The purpose of Section 404 is to protect the nation's waters from indiscriminate discharge and to minimize the potential adverse impacts and degradation of the "waters of the U.S." and aquatic ecosystems.

No streams within the study area are classified as "navigable waters of the U.S." under Section 10 of the Rivers and Harbors Act of 1899. Reviewof the National Hydrology Dataset (NHD) and National Wetland Inventory (NWI) maps indicated numerous surface waters of the U.S. within the study area. Surface waters include riverine and Iacustrine habitats associated with ephemeral

1-3

Page 34 of 528 Attachment 1 - Greenbelt-Cattail-Cherokee Environmental Assessment and Routing Study Greenbelt-Cattail-Cherokee 138 kVTransmission Line Project streams, ditches, ponds, and small reservoirs. Upon PUC approval of a route, additional coordination, jurisdictional wetland verifications, and permitting with the USACE Galveston District for a Section 404 permit may be required. The constructionof the transmission line will likely meet the criteria of the Nationwide Permit (NWP) No. 12-Utility Line Activities, which applies to activities associated with any cable, line, or wire for the transmission of electrical energy, so that generally no further USACE permitting would be needed. If the proposed impacts of the project exceed the criteria established under NWP 12 or other regional conditions listed under the NWP, then a preconstruction notification or an Individual Permit will be required.

1.3.3 United States Fish and Wildlife Service The United States Fish and Wildlife Service (USFWS) is charged with the responsibility of enforcing federal wildlife laws and providing comments on proposed construction projects with a federal nexus under the National Environmental Policy Act (NEPA); and within the framework of several federal laws including the Endangered Species Act (ESA), Migratory Bird Treaty Act (MBTA), and Bald and Golden Eagle Protection Act (BGEPA). HDR reviewed the USFWS-listed species for Galveston County to identify potential species of concern for this project.

Upon PUC approval of a route, coordination with the USFWS Houston Ecological Services Field Office may be required to determine the need for any required species specific surveys or additional permitting under Section 7 of the ESA and the MBTA.

1.3.4 Federal Aviation Administration According to Federal Aviation Administration (FAA) regulations, Part 77 (FAA, 2010), the construction of a transmission line requires FAA notification if any tower structure height exceeds the height of an imaginary surface extending outward and upward at one of the following slopes:

• A 1 00:1 slope for a horizontal distance of 20,000 feet from the nearest pointof the nearest runway of a publicor military airport having at least one runway longer than 3,200 feet. • A 50:1 slope for a horizontal distance of 10,000 feet from the nearest runway of a public or military airport where no runway is longer than 3,200 feet in length. • A 25:1 slope for a horizontal distance of 5,000 feet from heliports.

ThePUC CCN applicationalsorequireslisting privateairports within 10,000 feet of anyalternative route centerline. After PUC route approval, and if any of the FAA notification criteria are met for the selected route, a Notice of Proposed Construction or Alteration, FAA Form 7460-1, will be

1-4

Page 35 of 528 Attachment 1 - Greenbelt-Cattail-Cherokee Environmental Assessment and Routing Study Greenbelt-Cattail-Cherokee 138 kVTransmission Line Project completed and submitted to the FAA Southwest Regional Office in Fort Worth, Texas at least 45 days prior to construction.

1.3.5 Texas Parks and Wildlife Department The Texas Parks and Wildlife Department (TPWD) is the state agency with the primary responsibility of protecting the state's fish and wildlife resources in accordance with the Texas Parks and Wildlife Code Section 12.0011(b). HDR reviewed Texas Natural Diversity Database (TXNDD) element occurrence records from the TPWD and reviewed the TPWD-listed species for Galveston Countyto identifypotential speciesof concern forthis project. HDRsolicited comments from the TPWD during the project scoping phase of the project, and a copy of this EA will be submitted to the TPWD when the CCN application is filed with the PUC. Once the PUC approves a route, additional coordination with the TPWD may be necessary to determine the need forany additional surveys and to avoid or minimize any potential adverse impacts to sensitive habitats, threatened or endangered species, and other fish and wildlife resources.

1.3.6 Galveston County Floodplain Management Flood Insurance Rate Maps, published bythe Federal Emergency Management Agency(FEMA), and USACE technical reports were reviewed to determine storm surge and floodplain boundaries within thestudyarea. The mapped 100-year floodplainsaretypicallyassociatedwiththe unnamed ephemeral streams within the study area (Figure 1-2). The 100-year floodplain represents a 1Iood event that has al% chance of being equaled or exceeded for anygiven year. Construction ofthe proposed transmission line is not anticipated to create any significant permanent changes in the existing topographicalgradesand should notsignificantly affectthe stormwater runoffrates within the study area. Additional coordination with the Galveston County floodplain administrator may be required after PUC route approval to determine if any permits or mitigation are necessary.

1.3.7 Texas Commission on Environmental Quality The construction of the project may require a Texas Pollution Discharge Elimination System (TPDES) General Construction Permit (TXR150000) as implemented by the Texas Commission on Environmental Quality (TCEQ) underthe provisions of Section 402 of the CWA and Chapter 26 of the Texas Water Code. The TCEQ has developed a tiered approach for implementing this permitthat is dependent on theacreage of ground disturbance. A general permit (T)

1-5

Page 36 of 528 Attachmen , *-Greenbelt-C,ttail-Cherokee Envjroninentai:Assessmentagg'#ie,~tn~gst4®gm

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A Section 401 Water Quality Certificate from the TCEQ may also be necessary if the project requires a USACE Individual Permit for proposed impacts to surface waters or wetlands as previously discussed. The TCEQ has the authority to review federally permitted or licensed activities that may result in a discharge of pollutants to the waters of the U.S. within the state of Texas.

1.3.8 Texas Historical Commission Cultural resourcesare protected by federal and state laws if they have some level of significance under the criteria of the National Register of Historic Places (NRHP) (36 Code of Federal Regulations [CFR] Part 60) or under state guidance (Texas Administrative Code (TAC), Title 13, Part 2, Chapter 26.7-8). The Texas Historical Commission (THC) was contacted by HDR to identify known cultural resources within the study area boundary. HDR also reviewed Texas Archeological Research Laboratory(TARL) records for known Iocationsof archeological sites and the THC's online, restricted-access Texas Archeological Sites Atlas (TASA) and Texas Historical Sites Atlas (THSA) for the locations of recorded cemeteries, NRHP properties, and Official Tens Historical Markers (OTHMs). Once a route is approved by the PUC, additional coordination with the THC will occur, if required, to determine the need for cultural resources surveys or additbnal permitting requirements. Even if no additional surveys are required, TNMP will implement an unanticipated discovery procedure during construction activities. If artifacts are discovered during construction, activities will cease, and TNMP will notify the State Historic Preservation Office (SHPO) for additional consultation.

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Page 38 of 528 Attachment 1 - Greenbelt-Cattail-Cherokee Environmental Assessment and Routing Study Greenbelt-Cattail-Cherokee 138 kVTransmission Line Project

1.3.9 Texas Department of Transportation The Texas Department of Transportation (TXDOT) has been notified of the proposed project. If the route approved by the PUC crosses TXDOT roadways, the project will be constructed in accordance with the rules, regulations, and policies of TXDOT. Best Management Practices (BMPs) will be used, as required, to minimize erosion and sedimentation resulting from the construction. Revegetation will occur within existing TXDOT ROWs as required under the ' Revegetation Special Provisions" and co nta i ned i n TXDOT Fo rm 1 023 ( Rev . 9 - 93 ) . T raffic co ntrol measures will comply with applicable portions of the Texas Manual of Uniform Traffic Control Devices.

1.3.10 Texas General Land Office The Texas GeneraILand Office (TGLO)requiresamiscellaneouseasement(ME) for ROWwithin any coastal submerged lands (tidally influenced), state owned riverbeds, and navigable strearrs (non-tidal). Although none have been identified in the study area, an ME will be required if the approved project crosses areas meeting these criteria.

1.4 DESCRIPTION OF PROPOSED DESIGN AND CONSTRUCTION 1.4.1 Structure Design In general, TNMP proposes to utilize single-circuit (see Figure 1-3 and Figure 1-4) and double- circuit(see Figure 1 -5 and Figure 1-6) monopoles for construction ofthe 138 kVtransmission line. These structure types were selected based upon construction and life cycle economics, future system planning, and maintenance requirements. Tangent and dead-end monopoles will require a designed concretedrilled pier foundation composed of a full length anchor bolt cage filled with concrete. Anticipated typicaldead-endstructureheightsare 100 feetaboveground, whiletangent structure heights are proposed at 95 feet above ground. However, both structure heights may vary from 50 to 150 feet depending on route alignment, topography, and requirements for minimum clearances.

The tangent structures consistof three braced post insulators, each supporting a bundled 795 kilo circular mils (kcmil) aluminum conductor steel-supported (ACSS) "Drake" conductor. The static wire proposed is a single 72 count optical ground wire (OPGW) affixed to the apex of the pole. Each phase includes a bundled 795 kcmil ACSS "Drake" conductor and a static wire (OPGW) placed on top of the structure. The typical span lengths proposed are 300 feet with variances between 100 and 600 feet based on route alignment, topography, and minimum clearances. 1-8

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1.4.2 Surveying Surveying of the proposed transmission line ROW is required to locate the centerline of the proposed ROW, structure centers, structure references, project substation boundaries, ROW boundaries, access roads, and temporary work areas.

1.4.3 Clearing Clearing of natural vegetation may be needed in areas where new ROW is acquired. If a SWPPP is required, it will be implemented along the approved route prior to the start of clearing. Mechanized cutters and hand tools will be used to remove impeding vegetation to ground level.

1.4.4 Structure Placement Specialized wide-track vehicles and line trucks with trailers will be used to transport construcbn materials along the ROW to the structure locations.

For galvanized steel poles being installed on concrete drilled pier foundations, the concrete foundations will be installed several weeks before the steel poles are erected to allow the foundations to cure and reach their maximum strength. The steel poles will be delivered and set next to the proposed structure location shortly before structure erection. The structures will be assembled on-site, and a large crane would then set the steel pole by aligning the baseplate directlyonto the exposed anchorbolts of a fullycured and finished concrete drilledpier foundation.

1.4.5 Conductor and Static Wire Installation Once the structures have been erected, the stringing and clipping-in of conductors and static wires v\All begin. Outages on the rerouted transmission line are a possibility during the conductor and static wire installation. However, additional outages on other lines that will be crossed during the install are not anticipated. Each road crossing will have temporary guard poles installed for public protection while stringing in the newconductors.

1.4.6 Cleanup Cleanup operations will be performed as construction activities are completed. Cleanup includes removal of debris, unused materials, and trash. Any necessary soil stabilization and reestablishment of vegetative cover will also occur during cleanup, following the procedures dictated in the SWPPP, if required. Pre-construction contours will also be restored following construction.

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Page 44 of 528 Attachment 1 - Greenbelt-Cattail-Cherokee Environmental Assessment and Routing Study Greenbelt-Cattail-Chet"okee 138 kVTransmission Line Project

2.0 DESCRIPTION OF STUDYAREA HDR, with inputfrom TNMP, identified the study area boundary based on thelocation of thethree substation locations (the existing Greenbelt and Cherokee substations and the proposed Cattail Substation Site) (Figure 2-1). The study area was defined to provide an area large enough to develop an adequate set of geographically diverse alternative routes. The western-most substation (i.e., GreenbeltSubstation) islocated atthe northwestcornerofthe intersedion of27th Street South and 5th Avenue South. The line will traverse east to the proposed Cattail Substation Site, located northeast of the intersection of 6th Street South and 2nd Avenue South. Fromthere, the line will traverse southwesttothe southern-mostsubstation (i.e., Cherokee Substation), which is located 0.15 mile southwest of the intersection of 14th Street South and TX 197 Loop South. Thenorthern boundaryisparalleltoand north, byapproximately 0.15 mile, offarm-to-market road (FM) 1765/Texas Avenue. The southern boundary runs parallel to and south, by approximately 0.35 mile, of 5th Street on the west then it redirects to the southeast before running parallel to and north of Industrial Canal Road. The western boundary runs parallel to and east, by approximately 0.03 mile, of 31 th Street North. The eastern boundary runs along 2nd Streetin the northeast comer and continues on that line after 2nd Street dead ends into 2nd Avenue South.

The following chapter provides information regarding the resources within the study area, including information included in the PUC CCN application requirements:

• Public meeting orpublicopen house; • Approval or permits required from other governmental agendes; • Brief description of the area traversed; • Habitable structures within 300 feetof the centerline for a 138 kV transmission line; • Amplitude Modulation (AM), Frequency Modulation (FM), microwave, and other eledronic installations in the area; • FAA-registered airstrips, private airstrips, and heliports located in the area; • Irrigated pasture or croplands utilizing center-pivot or othertraveling irrigation systems; • Parks and recreation areas; and • Historical and archeological sites.

HDR collected this information and also evaluated the study area for environmental, cultural, and community resources and values. These data were obtained through desktop review, field reconnaissance (February 18, 2020 and June 2, 2020), and public and agency involvement.

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HDR mailed consultation letters to local officials and participated in TNMP's project public open house (in-person and virtual) meeting to obtain insight into these factors. All identified factors were reviewed and used to describe the community values, socioeconomics, land use, recreational and park areas, aesthetic values, resources and historic values, and environmental integrity of the study area.

2.1 COMMUNITYVALUES AND SOCIOECONOMICS 2.1.1 Community Values The term "community values" has not been formally defined for regulatory purposes bythe PUC butis included asa consideration fortransmission Iinecertification under Section 37.056(c)(4)(A- D) of PURA. In several dockets, the PUC and the PUC Staff (Staff) have used the following as a working definition: the term "community values" may be interpreted as a shared appreciation of an area or other natural resource by a national, regional, or local community. To further articulate these values, HDR participated in TNMP's project public open house meeting (in-person and virtual) to collect information regarding community values directly from the public.

Community values are generally associated with recreational areas or resources and the aesthetic environment of an area. These values are evaluated, in depth, in the subsequent sections of this chapter.

2.1.2 Socioeconomics The following is a description ofthe socioeconomicpattems relatedto populationand employment in Galveston County, Texas. The trend analysis is based upon the most recent U.S. Census Bureau (USCB) and Texas Water Development Board (TWDB) data including 2010 Census (USCB, 2020a) and TWDB 2021 Regional Water Plan Population Projections (TWDB, 2020).

2.1.2.1 Population Trends Galveston County has increased in population between 2010 and 2020. Table 2-1 presents population data forthe state of Texas and Galveston County. Galveston County has experienced an 18% increase in population between 2010 and 2020 (USCB, 2020a and TWDB, 2020). The TWDB projections indicate a population increase of 10% from 2020 to 2030 and an increase of 7% from 2030 to 2040 (TWDB, 2020), thus a population increase of approximately 18% over the next two decades in Galveston County. Table 2-1 presents the past populationtrends and future population projections for Galveston County and the State of Texas.

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Table 2-1 Population Trends State/County Census Projections 20101 20202 20302 20402 State of Texas 25,145,561 29,695,345 33,913,233 38,063,056 Galveston County 291,309 343,570 377,373 403,820 'USCB, 2020a; 'TWDB,2020

2.1.2.2 Employment According to the 2018 American Community Survey 1-Year Estimates, there were 265,834 employed persons overthe age of 16 in Galveston County, andtheunemploymentrate was 7.1% (approximately 18,874) in 2018 (USCB, 2020a). The major occupations in Galveston County in 2018 are listed under the category of management, business, science, and art occupations, followed by production, transportation, and material moving occupations (USCB, 2020a). Table 2-2 presents the number of persons employed within each of the top six occupation categories during 2018 in Galveston County, Texas.

Table 2-2 Leading Occupations in Galveston County, Texas

Occupations Total for Galveston County (2018)

Sales and related occupations 16,572

Management occupations 16,434

Office and administrative support occupations 14,203

Educational instruction, and library 11,730 occupations

Production occupations 10,612

Construction and extraction occupations 10,210 USCB, 2020a

In 2018, the six industries employing the most people in Galveston County were educational services, and health care and social assistance; retail trade; manufacturing; professional, scientific, management, and administrative and waste management services; arts, entertainment and recreation, and accommodation and food services; and construction. Table 2-3 presents the number of persons employed in each listed industry in 2018 (USCB, 2020a).

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Table 2-3 Top Employing Industries in Galveston County, Texas

Industries Total for Galveston County (2018)

Health care and social assistance 23,382

Educational services 17,996

Retail trade 16,199 Manufacturing 15,904

Construction 13,791 Accommodation and food services 11,039

Professional, scientific, and technical 10,730 services USCB, 2020a

2.2 LAND USE AND RECREATIONAL AND PARK AREAS 2.2.1 Land Use Most of the study area is dominated by high intensity industrial development (Figure 2-2). All of the land use types found within the study area are described further below.

2.2.1.1 Land Jurisdiction Land jurisdiction is defined as the control maintained by major Iandholders or land managers. Jurisdiction does not necessarily represent ownership. Potential conflicts could arise from crossing jurisdictional boundaries that were evaluated in this study. For example, a 138 kV transmission line crossing publicly held land may cause a conflict with ongoing planning processes or a land management plan. In orderto establish the existing land jurisdiction in the study area, a Geographic Information System (GIS) was used to evaluate land use informatbn obtained from interpretation of aerial photographs, United States Geological Survey (USGS) topographical maps, county appraisal district information, and reconnaissance surveys.

The entire study area is located within the jurisdictional boundary of Galveston County and within the city limits of Texas City, Texas. Additionally, the western portion of the study area is located within the extraterritorial jurisdiction (ETJ) of the City of La Marque, Texas. This is an area extending one mile in all directions from the corporate boundary of the City and its extensions. The ETJ is outside the City's corporate limits, but within its ultimate planning area, and this enables the City to regulate the subdivision of land.

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2.2.1.2 Agriculture The land cover in the study area is largely considered to be urban high intensity and urban low intensity (MRLC, 2016). Based on field observations, most of the study area is dominated by industrial use and lacks any form of agriculture. There are no wells within the study area used for agriculture (TWDB, 2019).

Agriculture is a significant segment of the economythroughout Texas, and Galveston County has an active agricultural sector. According to the USDA's National Agricultural Statistics Service's 2017 Census of Agriculture, the total market value for agricultural products sold for Galveston County was $9,233,000. Of this $9,233,000, crop sales accounted for approximately 49%, while livestock sales accounted for 51%. The number of farms in Galveston County numbered 633 totaling 73,125 acres in 2017, representing an 18% decline in acreage compared to 2012. Of the 73,125 acres of agricultural land in Galveston County, 71% is used for grazing cattle, and 23% is used for crops. The top crop products in Galveston County in 2017 were forage (hay), nursery stock crops, vegetables, pecans, cattle and calves, layers, and horses and ponies (USDA, 2017),

In 1995, an amendmentto the Texas Constitution, Article 8, Section 1-d-1 established the current qualifications for open-space land tax appraisal (Agriculture and/or Wildlife Exemption). This allows for qualifying land under management forwildlife habitat, agricultural production, ortirrber harvest to be taxed based on productive value ratherthan market value (TPWD, 2020d). While there is no database to identify land utilizing this incentive, properties within the study area likely do not qualify.

2.2.1.3 Urban and Residential Areas The urbanand residentialclassificationrepresentsconcentrationsof surfacedisturbing land uses, which include habitable structures and other developed areas characterized with low, medium, and high intensities. The various levels of development include a mix of residential, institutional, commercial, and industrial land uses.

The PUC definition of a habitable structure wasused forthis routing study. PUC Substantive Rule 25.101(a)(3)defines habitablestructuresas"structures normallyinhabited byhumansorintended to be inhabited by humans on a daily or regular basis. Habitable structures include, but are not limited to, single-family and multi-family dwellings and related structures, mobile homes, apartmentbuildings, commercial structures, industrialstructures, residentialstructures, churches,

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Page 51 of 528 Attachment 1 - Greenbelt-Cattail-Cherokee Environmental Assessment and Routing Study Greenbelt-Cattail-Cherokee 138 kVTransmission Line Proiect hospitals, nursing homes, and schools." Habitable structures in the study area were identified using aerial photographs and reconnaissance surveys from public points of view.

In general, Low, Medium, and High Intensity developed areas are identified using aerial photograph interpretation and reconnaissance surveys. These classifications are described below:

• Low Intensity areas typically include rural settings with single-family housing units.

• Medium Intensityareas typically include single-family housing unitsthat are grouped in residential subdivisions and may include peripheral commercial structures.

• High Intensityareas include highlydeveloped areas where people reside orwork in high numbers. Examples include apartment complexes and commercial or industrial parks.

The study area is located in an industrial-dominated area in the central portion of Galveston County, Texas. There are three medium intensity residential areas located in the study area: the northwestern corner of the study area, along FM 1 765 between 21St Street North and 2gth Street North; along the northern boundary of the studyarea along FM 1765 between 2nd Street North and 21St Street North; and in the northeastern cornerof the study area, south of FM 1765 and east of 14th Street North. All other areas within the study area are high intensity areas consisting of industrial complexes. There are no low intensity areas of development in the study area.

2.2.1.4 Industrial Areas The City of Texas City land use dataset identifies that most of the study area is classified as an industrial area or industrial transition zone (City of Texas City, 2011). Based on photo interpretation, industrial areas within the study area have been identified to facilitate various oil and gas, transportation, and municipal businesses.

2.2.1.5 Recreation and Park Areas Recreational, park, and preservation areas were identified through state, federal, and local agency websites, county documents, and reconnaissance surveys. This category primarily includes existing areas that are:

• Dedicated as park land or open space by a governmental body, or an organized group, club, or church.

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• Recognized as nationally or regionally significant preservation or recreation areas. • Formally designated unique or undisturbed natural areas.

2.2.1.5.1 Federal and State Parks and Protected Areas The United States Geological Survey's (USGS) Protected Areas Dataset (PADUS) was reviewed to identify any recreational or park areas within the study area. No state or national parks, trails, historic landmarks, or other public recreation lands were identified within the study area (NPS, 2020 and USGS, 2016).

2.2.1.5.2 County and Local Parks A review of the Environmental Systems Research Institute (ESRI) parks dataset indicated that there are six local parks in the study area (Figure 2-2; ESRI, 2018). Of these six, only two are listed on the City of Texas City website as city-owned public parks-Insley Park (called Eastside Park on ESRI's dataset) and Firefighter Park(City of Texas City, 2014). Both of these parks have greenspace and basketball facilities. Braslau Park, listed on the ESRI dataset but not on the City of Texas City website, has a sign identifying it as Braslau Park owned by the City. Braslau Park contains a playground. Bremond Park, listed on the ESRI dataset but not on the City of Texas City website, appears to be a city park. The parcel is owned by the City (TNRIS, 2020) and there is a sign that says "all motor vehicles prohibited on park". The final two parks listed on the ESRI dataset are Nuckols Park and Trahan Park. Neither appearto still be parks. They are not listed on the City's website, andthe parcelsareowned byprivate companies. Additionally, Nuckols Park is now a parking lot. For the purposes of this EA, Nuckols Park and Trahan Park will be omitted.

2.2.1.5.3 Wildlife Viewing Trails A review of the TPWD Upper Texas Coast - Great Texas Coastal Birding Trail (TPWD, 2020e) indicated that the study area falls within the Texas City Loop Wildlife Trail area, though it does not contain any of the individual trails. The Wildlife Trail with the closest proximity to the study area is the Texas City Dike Wildlife Trail located approximately 0.5 mile from the northeast comer of the study area and 0.8 mile from the nearest proposed transmission line link.

2.2.1.5.4 Conservation Easements A review of the National Conservation Easement Database (NCED) indicated that no non-profit or publicly held conservation easements are within the study area (NCED, 2019).

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2.2.1.5.5 Private Recreation Areas Potential recreational opportunities, including hiking, walking, and off-road bicycle and vehicle driving, may occur on private propertieswithin the study area. These facilities are not necessarily considered to be open to the general public.

No private recreational properties were identified within the study area.

2.2.1.6 Cemeteries No cemeteries were identified within the study area (THC, 2020 and ESRI, 2019).

2.2.1.7 Transportation/Aviation 2.2.1.7.1 Roadways The existing transportation system within the study area includes SH, FM, and local roads. According to the USCB Topographically Integrated Geographic Encoding and Reference system (TIGER), there are over 100 uniquely named roads within the study area (USCB, 2020b). This includes SH-197, FM 1765, and numerous other named and un-named local roads (Figure 2-2; USCB, 2020b and TXDOT, 2018).

The TXDOT's "Project Tracker" contains detailed information by county for every project that is or could be scheduled for construction. It was reviewed to identify any state roadway projeds planned within the study area. There is no current or planned construction within the study area (TXDOT, 2019). The 2012 City of Texas City Strategic Plan does not indicate any upcoming projects within the study area (City of Texas City, 2012).

2.2.1.7.2 Railroads Several railroads are located in the study area. Theseare Texas Central Railroad rails that are mostly located within the oil and gas refineries atthe southeast end of the study area. Additional Texas Central Railroad rails exitthe study area to the north paralleling 10th Street and to the west just south of 5th Avenue (TXDOT, 2016b).

2.2.1.7.3 Aviation According to FAA regulations, Part 77 (FAA, 2010), the construction of a transmission line requires FAA notification if tower structure height exceeds the height of an imaginary surface extending outward and upward at one of the following slopes:

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• A 1 00:1 slope for a horizontal distance of 20,000 feet from the nearest pointof the nearest runway of a publicor military airport having at least one runway longer than 3,200 feet. • A 50:1 slope for a horizontal distance of 10,000 feet from the nearest runway of a public or military airport where no runway is longer than 3,200 feet in length. • A 25:1 slope for a horizontal distance of 5,000 feet for heliports.

The PUC CCN application also requires the listing of private airports ~thin 10,000 feet of any alternative route centerline.

According to public records, no public airport is located within a 20,000-foot radius of the study area boundaries (FAA, 2020; TXDOT, 2016; BTS, 2019).

One heliport wasobserved orregistered within 5,000 feetofthe studyarea. This heliportislocated within the western portion of the study area, nearthe intersection of 3rd Avenue South and 25th Street South.

2.2.1.8 Utilities 2.2.1.8.1 Utility Lines Existing utility corridors, easements, and ROWs were identified withinthe studyareaand mapped using GIS. These linear features are considered potential paralleling opportunities. There are multiple 138 kV and 69 kV transmission lines located within the studyarea. These Iinesareevenly distributedthroughoutthe studyarea, runningparalleltoroadwayssuch as SH-197 and FM 1765. Existing transmission lines were mapped based on photo interpretation and information from TNMP. TNMP also operates the distribution line system within the study area, which extends along the roadways and through other portions of the study area.

2.2.1.8.2 Communication Towers Communication tower location information was obtained from the Federal Communication Commission (FCC)(FCC, 2019). Thisincludes48 privateland mobile (LM) communication tomrs and one registered antenna structure. These structures are located throughout the study area. However, the highest concentration is located in the eastern portion of the study area east of Ski- 197.

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2.2.1.8.3 Water Wells Reviewof the TWDB (2019) waterwell data indicated 27 waterwells located within the studyarea (Table 2-4). These wells are concentrated in the southeast portion of the study area, generally associated with industrial use. Of the 27 wells, most are owned by private entities. See the table below for more information about well usage.

Table 2-4 Water Wells within the Study Area Primary Use Well Type Owner Number Industrial Withdrawal of Water Texas City Refining Co. 3 Unused Withdrawal of Water Texas City Refining Co. 4 Industrial Withdrawal of Water Texas City Refinery 1 Unused Withdrawal of Water Stone Oil Co. 1 Industrial Withdrawal of Water Republic Refining Oil Co. 2 Industrial Withdrawal of Water Pan American Refining Co. 3 Unused Withdrawal of Water Pan American Refining Co. 1 Unused Withdrawal of Water Monsanto Chemical Co. 2 Industrial Withdrawal of Water Marathon Oil Co. 3 Unused Withdrawal of Water Knox Process Co. 1 Public Supply Withdrawal of Water City of Texas City 2 Unused Withdrawal of Water B. Ashworth 1 Industrial Withdrawal of Water Amoco Oil Co. 1 Unused Withdrawal of Water Amoco Chemical Co. 1 Unused Withdrawal of Water Unknown 1 TWDB, 2019

2.2.1.8.4 Oil and Gas Facilities Data was obtained from the Railroad Commission of Texas (RRC) website (RRC, 2019) for existing oil and gas wells, pipelines, and support facilities. There are three oil and gas wells located within the study area; all three are labeled as dry wells that have been plugged. A high density of pipelines, owned by numerous companies, traverse the study area in all directions. The highest concentration of pipelines is located in the southeastern portion of the study area where refineries are present (Figure 2-2).

2.2.1.9 Schools The study area is located within the Texas City Independent School District (ISD). No existing or planned schools were identified within the study area (TEA, 2020).

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2.2.1.10 Planned Land Use The planned land uses reflect objectives and policies regarding land use goals and plans, including conservation easements, managed lands, and proposed developments. Communities typically prepare comprehensive land use plans to provide strategic direction for the individual community. The websites for the City of Texas City and Houston-Galveston Area Council (H- GAC) were reviewed. A Land Use Plan has been developed for the City of Texas City (the Plan).

The Plan indicates that a portion of the study area immediately south of Texas Avenue is within an Industrial Transition Zone. Accordingto the Land Use Plan, any proposed development within the Industrial Transition Zone should be limited to nonresidential uses. This zone will require enhanced performance standards (i.e., setbacks, parking, landscaping, and screening). The intent for the enhanced performance standards is to provide reasonable aesthetics and visual screening to the industrial land uses south of 5th Avenue South (City of Texas City, 2011). Any project routethroughthiszone would require implementationof performance standardsapproved for development within this zone.

The southern portion of the study area is within the Industrial Zone. The Industrial Zone is limited to intensive industrial, manufacturing and maritime related uses non-adjacent to residential neighborhoods. This portion of the study area is entirely developed with industrial uses, except for one block between 10th and 14th Streets, which appears to be developed as residential and likely pre-dates the surrounding industrial development. According to the Plan, future expansion of heavy industrial uses should be limited to Shoal Point, the ship channel district and remaining undeveloped Iandsto the south of the existing petrochemical facilities (City of Texas City, 2011).

Theportion ofthestudyareaimmediately northandadjacentto TexasAvenueis within a planned Revitalization Corridor. Revitalization Corridors arethe areas of City of Texas City where prompt action is needed to prevent or reverse deterioration, specifically along Texas Avenue and 6th Street. These corridors are characterized by dilapidated structures, fair to poor housing conditions, incompatible mixture of land uses and declining numbers of housing units, and small businesses (City of Texas City, 2011). Project routes through the Revitalization Corridornorth of Texas Avenue would need to conform to the City's goals for revitalization.

The remaining portion of the study area north of Texas Avenue is within an Established Neighborhood land use. An Established Neighborhood is a built-up area of the City generally characterized by satisfactory structural housing conditions and neighborhoods mostly free from

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Page 57 of 528 Attachment 1 - Greenbelt-Cattail-Cherokee Environmental Assessment and Routing Study Greenbelt-Cattail-Cherokee 138 kV Transmission Line Proiect blighting influences such as mixed land use patterns, abandoned buildings, and street layouts inappropriate for residential development. These predominantly residential neighborhoods may include undeveloped tracts that will become residential (City of Texas City, 2011). Any project route in these areas should be carefully reviewed, and located adjacent to designated major thoroughfares and/or activity corridors.

2.3 AESTHETIC VALUES Section 37.056(c)(4)(C) of PURA incorporates "aesthetic values" as a consideration when evaluating proposed electric transmission facilities. There are currently no formal guidelines provided for managing visual resources on private, state, or county-owned lands located within the study area. For the purposes of this study, the term aesthetics is defined by HDR to include the subjective perception of natural beauty in a landscape and measurement of an area's scenic qualities. The visual inventory was conducted by describing the regional setting. Aerial photograph interpretation and reconnaissance surveys were used to describethe regional setting and to determine the landscape charactertypes forthe area. Forthis study, the potential visual impacts considered for the project were limited to line-of-sight views within the immediate foreground (one-half mile, unobstructed) from points located on major roads, commercial and residential collector streets, and park areas.

Consideration of the visual environment includes a determination of aesthetic values (where the major potential effect of a project on the resource is considered visual) and recreational values (where the location of a transmission line could potentially affect the scenic enjoyment of the area). HDR considered the following criteria that combine to give an area its aesthetic identity:

• Landform and topography (hills, valleys, etc.) • Prominence of water in the landscape (rivers, lakes, etc.) • Vegetation variety (woodland, meadows) • Diversity of scenic elements • Degree of human development or alteration • Overall uniqueness of the scenic environment compared with the larger region

The study area is primarily urban development, with predominant land uses including residential, commercial, and industrial. Overall, the study area viewscape consists of typical urban views and is largely absent of water features. Although the City has zoned the immediate area south of

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Texas Avenue as an industrial transitional area with the purpose of screening views of the industrial zone, the industrial region comprises more than half of the study area. No known designated high-qualityaesthetic resources, views, orscenicroads, highways, ortraveltrailswere identified within the studyarea. Although some undeveloped portionsof the study area may be visuallyappealing, overall, the aesthetic qualityof the study area is not distinguishable from that of other adjacent urban areas within the region. Basedon these criteria, the studyarea exhibits a low degree of aesthetic quality for the region.

2.4 CULTURAL RESOURCES AND HISTORIC VALUES Section 37.056(c)(4)(A-D) of PURA incorporates historical values as a consideration when evaluating proposed electric transmission facilities. The THC and TARL maintain records of known cultural resources (archaeological, architectural, and cemeteries) and of previous field investigations. Information from the THC and TARL databases was reviewed, and shapefiles showing the locations of all previously documented archaeological resources were requested in order to identify potential cultural resources constraints within the study area. Cultural resources include districts, sites, buildings, structures, or objects important to a culture, subculture, or community for scientific, traditional, religious, or other reasons. Forthis study, cultural resources have been divided intothree major categories: archaeological resources, architectural resources, and historic cemeteries.

Archeological Resources are locations where human activity has measurably altered the earth or left deposits of physical remains (e.g., burnt rock middens, stone tools, petroglyphs, house foundations, bottles). Archaeological resources can date to eitherprehistoric times orthe historic era.

Architectural Resources include standing buildings (e.g., houses, garages, churches, government buildings, industrial buildings, warehouses, and commercial buildings including restaurants, gas stations, and hotels), landscapes (parks), and intact structures (oil and gas- related infrastructure, port-related structures, railroad tracks, and roads).

Cemeteries are places of intentional human interment and may include large public burial grounds with multiple burials, small family plots with only a few burials, or individual grave sites. In some instances, cemeteries may be designated as Historic Texas Cemeteries. Historic Texas Cemeteries include cemeteries that have been officially added to the THC records and are recognized with a Texas Historical Marker. Othercemeteries may have been documented as part

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Page 59 of 528 Attachment 1 - Greenbelt-Cattail-Cherokee Environmental Assessment and Routing Study Gree nbelt-Cattail-Cherokee 138 kV Transmission Line Proiect of the THC's Record, Investigate, and Protect (RIP) program and have been assigned a designation number (e.g., C-0249).

2.4.1 Cultural Background The APE falls within the Southeast Texas archaeological region (see Figure 2-3; Ricklis, 2004). The regional chronology is divided into six basic periods: Paleoindian, Archaic, Early Ceramic, Late Prehistoric, Protohistoric, and Historic (Table 2-5).

Table 2.5 General Cultural Chronology for Southeast Texas. Period Date Range Paleoindian ca. 10,000-5,000 B.C. Archaic 5,000 B.C.-A. D. 100 Early Ceramic A.D. 100-600 Late Prehistoric A.D. 600 -1500 Protohistoric & Early Historic A.D. 1500-1700 Historic A. D. 1700 -1800 RicMis, 2004

2.4.1.1 Paleoindian Period (ca. 10,000-5,000 B.C.) The Paleoindian period is the oldest widely accepted human occupation of the Americas. This period is characterized by generally coolerand wetter climates than present, due to the effeds of glaciation. Paleoindian sites generally consist of Iithic scatters and represent campsites, quarries, and hunting/butchery sites. In the region, the Paleoindian period is divided into Early and Late periods. Patterson's (1995) chronology includes Early Paleoindian (10,000-8,000 B.P) and Late Paleoindian (8,000-5,000 B.P.). These periods are characterized by diagnostic Ianceolate projectile points such as Clovis and Folsom points made of high-grade Iithic materials. Later Paleoindian occupation isrepresented byfindssuchas San Patrice and Scottsbluffpoints(Ricklis 2004).

2.4.1.2 Archaic Period (5,000 B.C.-AD. 100) The Archaic period is divided into Early, Middle, and Late periods, and Patterson's (1995) chronology includes Early Archaic (5,000-3,000 B.P.), Middle Archaic (3,000-1,500 B.P.), and Late Archaic (1,500 B.P.-A.D. 100). These periods are based chronologicallyon diagnosticdart point styles . Many Archaic sites are characterized as shell middens , with Rangia cuneata ( gulf wedge elam) being a commonly sourced species. The Archaic period in Texas is generally described as being pre-ornon-horticulturaland Iackingceramicand bow-and-arrowtechnologies.

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PLAINS t I JU]--

»EASTERN

TRANS-PECOS

CENTRAL & SOUTHERN

PROJECT AREA

CULTURAL RESOURCES PLANNING REGION BOUNDARY CULTURAL RESOURCES F-1 COUNTY BOUNDARY PLANNING REGIONS 0 50 100 MILES TNMP GREENBELT-CATTAIL-CHEROKEE 138 KV TRANSMISSION LINE PROJECT TNMP

Teas-New Mevco Power FIGURE 2-3

PATH O \10210662_10189_TNMP_TEXAS_CITY_GCNIMAP_DOCSIIGUREIEMTE ASCII FIG2 3 CULTURALRESOURCE_PLANNINGREGIONS_8*11 MXD · USER 8JANIK · DATE 8/5/2020 2-17 Page 61 of 528 Attachment 1 - Greenbelt-Cattail-Cherokee Environmental Assessment and Routing Study Greenbelt-Cattail-Cherokee 138 kVTransmission Line Project

There was an increase in faunal and macro-botanical remains at inland Archaic sites, and there was use of poorer quality and more local Iithic sources duringthis period. This evidence suggests that groups were less mobile and adapted to patterns of hunting-and-gathering subsistence practices (Ricklis 2004).

2.4.1.3 Early Ceramic Period (AD.100-600) The Early Ceramic period ranges from A.D. 100-600 according to Patterson's (1995) chronological framework. In this region, the ceramic technology disseminated from the coastal areas to inland areas over several centuries. The earliest pottery has a Tchefuncte cast characterized by thick vessel walls, poorly wedged, contorted, and untempered paste. The earliestpottery servesasatime marker forthe Early Ceramic period; however, there are currently no indications that the introduction of pottery altered everyday life. The evidence points to a fundamental continuity in settlement and subsistence patterns (Ricklis, 2004).

2.4.1.4 Late Prehistoric Period (AD. 600-1500) Patterson (1995) chronologically places the Late Prehistoric period from A. D. 600-1500. This period is associated with the introduction of the bow-and-arrowalong with arrow points. It also involves the appearance of bison bone faunal assemblages along with more technologically complexlithictoolassemblages. Duringthisperiod,therewasa significantshifttobisonand large game hunting along with the processing of meat and hides. Bison kill sites were present in the region toward the end of the Late Prehistoric period. Ceramics also underwent technological and stylistic modifications similar to ceramics found in the neighboring coastal Louisiana area, suggesting that there was increased contact with peoples to the east (Ricklis, 2004).

2.4.1.5 Protohistoric and Early Historic Period (AD. 1500-1700) The Protohistoric period falls within A.D. 1500-1700 according to Patterson (1995). This period marks the presence of contact with Euro-Americans on the upper Texas Gulf Coast. The basic subsistence and mortuary practices during this period did not differ greatly from those during the Late Prehistoric period with a primary reliance on fishing and hunting, and single primary interments (Ricklis, 2004). However, there appears to be an increase in variety of arrow point types, ending the complete dominance of the Perdiz point during the Late Prehistoric period (Ricklis, 2004). Despite this minor difference, there does not appear to be a major change in material culture during the Protohistoric period. The paucity of many types of European goods within burialsin the region indicatesthatthe native peoples had limited accessto European goods

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(Ricklis, 2004). During the Early Historic period, access to these European goods became more common as fur traders traversed the area setting up trading posts (Ricklis, 2004). With the introduction of diseases from Europe, this period experienced a dramatic decline in native populations (Ricklis, 2004).

2.4.1.6 Historical Context of Texas City The proposed project location is in the southeast section of incorporated City of Texas City in Galveston County. The study area includes corridors along FM 1765 and 5th Avenue South/4th Avenue South between 31st Street and 2nd Street, and along TX 197 Loop South through the chemical and oil and gas-related businesses near the Industrial Canal and Port of Texas City.

European exploration of the Galveston area began as early as the sixteenth century, but settlement was catalyzed during the fight for Mexican Independence in the 1810s. U.S. Army veteransand volunteerscoming from Louisiana joined membersof the Mexican Republican Arnv and used Galveston Island and Bolivar Peninsula, just northeast of Galveston Island, as jumping- off points for various excursions (Kleiner, 2019). By 1817, Galveston Island had approximately 1,000 inhabitants, but settlement on the mainland was minimal, with only Campbell's Bayou, established by U.S. Navy veteran and privateer James Campbell and his family, as an identified community by the late 1 830s (Hamilton, 2010). The Campbell's Bayou inlet is located along the boundary of present-day City of Texas City, south of the project area.

Settlement in the vicinity of Shoal Point, atthe eastern edge of what is now City of Texas City Cat the base of the Texas City Dike fishing pier and boat launch), began in the late 1830s with the Bowes Wilcox family. Shoal Point did not require a school until c. 1870 when the increasing number of children in the community merited construction of a one-room schoolhouse (Moore Memorial Public Library [MMPL], 2011).

Interest in Galveston as a port had been growing rapidly, spurring a population increase from 4,177 in 1850 to 29,084 in 1890 (Population.us 2016). Thisgrowth led entrepreneurial investors to explore the coastline for additional port options. Investors from Duluth, Minnesota purchased 10,000 acres near Shoal Point in 1891-1892, renamed the community Texas City, and soon after formed the Texas City Improvement Companyto platthe newtownsite (MMPL, 2011). Thetown's population was 250 in 1893 when its post office was established (Benham, 2010).

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In 1893, Texas City developers had a railroad spurconstructed fromthetown to reachthe junction of the Galveston, Houston & Henderson Railroad and the Galveston, Harrisburg & San Antonio Railway lines while also receiving permission from the federal government to build a channel to the Gulf of Mexico in 1893. By 1894, Texas City welcomed its first shipment(Benham, 2010). The rail provided a connection to Houston for goods to reach markets nationwide via the Southern Pacific and Santa Fe lines. The town expanded rapidlythereafter, addinga depot, hotel, docks, and a rail pier (MMPL, 2011).

2.4.2 Records Review Forthis study, HDR personnel consulted several sources of information, with the overall goal of identifying prehistoricand historicarchaeological sites, historic properties, and historiccemeteries that fall within the study area. Data sources included the site atlas and database maintained by the THC, the NRHP database maintained by the NPS, soil maps and soil map unit descriptions produced by the Natural Resources Conservation Service (NRCS) and its predecessors, and geological data provided by the USGS for Galveston County. Historical markers were also included in the search, as they often denote locations of historical interest not reflected in other data sources. This work also included analysis of geological, soil, and Iandform data to identify high probability areas for as-yet-undocumented archaeological sites.

The THC's Archaeological Sites Atlas was consulted to determine if any archaeological sites are recorded within the study area, as well as their status for eligibility for and listing as historic properties. These records indicate 3 Official Texas Historical Markers are present in the study area. No previous cultural resources surveys, archaeological sites, NRHP-listed properties, historic-age structures, and/or NRHP-listed district have been recorded within the study area.

2.4.2.1 Official Texas Historical Markers The THC records indicate that 3 Official Texas Historical Markers are present within the study area (Table 2-6). All three markers denote two historic structures and one historic railway integral to the development of Texas City. The Texas City Terminal Railway Company (Atlas ID #5167011578) is a 4.5 mi (7.2 km) historictrack that runs fromthe markersouthwest through the project area. Details are provided in Table 2-6.

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Table 2-6 Previously Recorded Official Texas Historical Markers within the Study Area Date Comments / Identifier Title Address Erected Recommendations Booker T 5167000204 701 Second City Avenue 1997 - Washington School Texas City Historic railway 5167011578 1301 Loop - 197 S. at Dock Terminal Railway Road 1996 which runs through Company project area 5507015269 First Texas City Refinery 1994 - THC, 2020

2.4.2.2 Geology, Soils, and Landforms Most of the studyarea is underlainbythe Beaumont Formation of Holocene and Pleistoceneage, with portions underlain by Fill and Spoil of Holocene age (USGS, 2020). These soils generally include silty clay Ioam and Ioamy soils. See Section 2.5.4 for a more thorough discussion of the soils in the study area. Landforms within the study area include mainly flats and meander scrolls. High probability areas for cultural resources include areas within 300 feet of water sources and meander scrolls.

2.5 ENVIRONMENTAL INTEGRITY Resource inventory data were collected for physiography, geology, soils, surface waters, wetlands, and ecological resource areas. These data were mapped within the study area utili ~ng GIS layers. Additionaldata collectionactivities consisted of fileand record reviews conducted with the various state and federal regulatory agencies, a reviewof published literature, and reviewof various maps and aerial photographs. Maps and data layers reviewed included USGS 7.5 minute topographic maps, Bureauof Economic Geology (BEG) Geologic Atlas maps, NWI maps, FEMA floodplain maps, TPWD Ecological Mapping System of Texas (EMST), USFWS Critical Habitat maps, Texas Natural Diversity Database (TXNDD) observation records, TXDOT county highway maps, and county appraisal district land parcel boundary maps.

2.5.1 Ecological Region Within the Level Ill Ecoregions, the study area is located in the Western Gulf Coastal Plain (USEPA, 2013). The Western Gulf Coastal Plain is a relatively flat strip of land, generally 50 to 90 miles wide, adjacentto the Gulf of Mexico. The principal distinguishing characteristics of this ecoregion are its relatively flat topography and mainly grassland potential natural vegetation. Inland from this region, the plains are older, more irregular, and have mostly forest or savanna- type vegetation potentials. Largely because of these characteristics, a higher percentage of the

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Page 65 of 528 Attachment 1 - Greenbelt-Cattail-Cherokee Environmental Assessment and Routing Study Greenbelt-Cattail-Cherokee 138 kVTransmission Line Proiect land is in cropland than in bordering ecological regions. Rice, grain sorghum, cotton, and soybeans are the principal crops. Urban and industrial land uses have expanded greatly in recent decades, and oil and gas production is common. The study area is located on West Galveston Bay in the North Humid Gulf Coastal Prairies Level IV Ecoregion (Griffith et al., 2007).

2.5.2 Physiography and Geology 2.5.2.1 Physiography As shown in Figure 2-4, the study area is located within the Gulf Coastal Prairies Physiographic Region of Texas. This is a large physiographicregionthatextendswestward along the coast from the Sabine River, reaching inland 30 to 60 miles. The Gulf Coastal Prairies extend alongthe Gulf of Mexico from the Sabine to the Lower Rio Grande Valley. The Gulf Coastal Prairies are bound by the Interior Coastal Plains to the north and the Gulf of Mexico to the south. Young deltaic sands, silts, and clays erode to nearly flatgrasslands that form almost imperceptible slopes to the southeast. Treesare uncommon except locally along streams and in oak mottes. (BEG, 1996)

Geologic formations occurring within the study area include primarily Holocene and Pleistocene aged Beaumont Formation with some Holocene aged Fill and Spoil in the southeastern portion of the study area (USGS, 2020). Descriptions of these mapped geologic formations are provided in the following sections.

The Beaumont Formation isdominantly clay and mud of low permeability. It has high to very high shrink-swell potential, low shear strength, and poor drainage. Geologic units include interdistributarymuds, abandoned channel-fill muds, and overbank fluvial muds. The Filland Spoil unit is composed of material dredged for raising land surfaces above alluvium and barrier-island deposits and for creating land (USGS, 2020)

2.5.2.2 Geological Hazards The majority of the study area is composed of clays and muds that were marine deposits. As such, the main geologic hazard would be shrink-swell potential of the soils (USGS, 2020). No known karst geology or other karst features are known within the study area or region (TSS, 2020). The structural and stratigraphic characteristics of the Gulf Coast Basin can facilitated slumping toward the center of the basin in the form of Iistric normal faulting. No historical coal mining activities have occurred within the region or currently occur within the study area (RRC, 2020).

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L F _NRZJ.

PROJECTAREA

~ PHYSIOGRAPHIC REGION BOUNDARY 1- HIGH PLAINS PHYSIOGRAPHIC REGIONS 2 NORTH CENTRAL PLAINS OF TEXAS 0 50 100 3·GRAND PRAIRIE MILES 4 BLACKLAND PRAIRIES 5 INTERIOR COASTAL PLAINS TNMP GREENBELT-CATTAIL-CHEROKEE 6 GULF COASTAL PRAIRIES 138 KVTRANSMISSION LINE PROJECT 7 EDWARDS PLATEAU TNMP 8 CENTRAL TEXAS UPLIFT 9 TRANS-PECOS BASIN & RANGE Teas NewMe*jc/Powef FIGURE 2-4 ~ COUNTY BOUNDARY

PATH O \102,0662 10189 TNMP_TEXAS CITY CCN\MAP DOCS,FIGUREIEAIE; ASCII_Fm_4_PHYSIOGRAPHIC_REGIONS_8xll MiD · USER BJANIK · DATE 8/5/2020 2-23 Page 67 of 528 Attachment 1 - Greenbelt-Cattail-Cherokee Environmental Assessment and Routing Study Greenbelt-Cattail-Cherokee 138 kVTransmission Line Proiect

Review of the TCEQ State Superfund Site, Landfill, and Leaking Petroleum Storage Tank (LPST) databases indicated 18 listed LPST sitesand no Superfund sites or Iandfills within the study area (TCEQ, 2020a, 2020b, and 2020c). Review of the Environmental Protection Agency Superfund Site database did not indicate anylisted sites within the study area in Galveston County (USEPA 2020).

2.5.3 Vegetation 2.5.3.1 Vegetation Types The study area is located within the Gulf Prairies and Marshes vegetational areaof Texas (Figure 2-5, Gould et al., 1960). According to the EMST, there are four vegetation types and four additional non-vegetational cover types for the study area (Elliot et al., 2014, TPWD, 2020a); however, the non-vegetational cover types mapped make up more than 98 percent of the study area.

Terrestrial habitatswithin the study area include salt and brackish Iowtidal marsh, coastal prairie, salty prairie, non-native rose shrubland, and open water. The landscape is dominated by urban highand Iowintensityground cover. Based on field reconnaissance and aerial interpretation, the EMST mapped types accurately represent the vegetation and covertypes in the study area. Table 2-7 includes the vegetation types and a brief description of the mapped vegetation communities. Table 2-7 Vegetation Types Mapped inthe Study Area Vegetation Type Vegetation Type Description Texas Coast Salt and Brackish Tidal Marsh These marshes occupy relatively low-lying, coastal situations on Ie,el Iandforms influenced by tidal fluctuations. Some sites are only influenced by storm tides, or tides resulting from extreme wind emnts. The composition of these marshes is primarily influenced by the frequency and duration of tidal inundation. Salinityonsomemarshes, particularlyinthesouth, is maintained bysaltsprayfrom prevailing southeasterly winds. Low marshes are regularly flooded and representative examples are dominated by Spartina alterniflora ( smooth cordgrass ), Juncus roemerianus (b \ ackrush ), or Avicennia germinans (b \ ack mangrove ). Significant areas of Avicennia germinans ( black mangrove ) become more frequent toward the south , whileextensiveareas of Spartina a / temif/ ora ( smooth cordgrass ) become rare south of Corpus Christi Bay. Areas of decreased frequency and/or duration of tidal inundation are often referred to as high, or irregularly flooded, marsh. These marshes may be dominated by species such as Spartina patens (marshhay cordgrass), Distichlis spicata (saltgrass), Schoenoplectus robustus (sturdy bulrush), Schoenoplectus americanus (three-square bulrush), Sporobolus virginicus (seashore dropseed), Monanthochloe Iittoralis (shoregrass), and Spartina spartinae (Gulf cordgrass). Shrubs, subshrubs, and forbs, such as Batis maritima (saltwort), Borrichia frutescens (sea ox-eye daisy), Sesuvium portulacastrum (shoreline seapurslane), Salicornia spp. (glassworts), Suaeda Iinearis (annual seepweed), Limonium spp. (sea-Iavenders), and Lyciumcarolinianum (Carolina wolfberry)arecommonly encountered in these marshes. Some irregularly ftooded sites may become shrub-dominated with species such as Iva frutescens (shrubby sumpweed) or Baccharis halimifolia (eastern baccharis). In the south, extensi\,e areas are dominated by Borrichia frutescens (sea ox-eye daisy) and these often occur at very slightly lower elevations and higher salinities than nearby Spartina spartinae (Gulf cordgrass)

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Table 2-7 Vegetation Types Mapped inthe Study Area Vegetation Type Vegetation Type Description salty prairie. These Borrichia flats may be very infrequently flooded, perhaps only under extreme storm tide conditions. Other species that may be encountered in these situations include Maytenus phyllanthoides (gutta-percha), Prosopis reptans (tornillo), Monanthochloe Iittoralis (shoregrassj Distichlis spicata (saltgrass), and Batis maritima (saltwort). The aspect dominant on these sites is dealy Borrichia frutescens (sea ox-eye daisy). Coastal: Salt and Brackish Low This systemincludes Marshesfrequently inundated bytides and often Tidal Marsh (0.2%) dominated by smooth cordgrass (Spartina alterniflora) Texas-Louisiana Coastal Prairie This mid- to tallgrass prairie occupies Pleistocene surfaces of the Texas and Louisiana coast, on non- saline soils of level to gently rolling topography. It is dominated by graminoid species, such as Schizachyrium scoparium (little bluestem), Sorghastrum nutans (Indiangrass), Paspalum plicatulum (brownseed paspalum), Panicum virgatum (switchgrass), Andropogon gerardii (big bluestem), Sporobolus compositus(tall dropseed), Paspalumsetaceum(thin paspalum), Fimbristylispuberula (hairy fimbry), Dichanthelium oligosanthes (fewflower panicgrass), Rhynchospora spp. (beaksedges), Paspalum floridanum (Florida paspalum), Muhlenbergia capillaris (Gulf muhly), Tridens strictus (Iongspiketridens), Boutelouacurtipendula (sideoatsgrama), Andropogon glomeratus (bushybluestem), and Tripsacum dactyloides (eastern gamagrass). Axonopus spp. (Carpetgrasses), Sporobolus indicus (rat-tail smutgrass), Andropogon virginicus (broomsedge bluestem), Bothriochloa Iaguroides ssp. torreyana (silver bluestem), and Nassella Ieucotricha (Texas wintergrass) may be particularly noticeable on over-grazed sites. Non-native graminoids that may be conspicuous to dominantcomponents include Cynodon dactylon (bermudagrass), Cyperus entrerianus (deep-rooted sedge), Bothriochloa ischaemum var. songarica (King Ranch bluestem), Dichanthium spp. (old world bluestems), Lolium perenne (Italian ryegrass), Schedonorus phoenix (tall fescue), Paspalum notatum (bahiagrass), and Paspalum dilatatum (dallisgrass). Forbs that may often be encountered include Liatris spp. (gayfeathers), Sabatia campestris (meadow pink), Ambrosia psilostachya (western ragweed), Euphorbia bicolor (snow-on-the-prairie), Solidago spp. (goldenrods), Rudbeckia hirta (Blackeyed Susan), Ruellia humilis (low wild petunia), Asclepias viridis (green milkweed), Chamaecrista fasciculata (partridge pea), angustifolius (narrowleaf sunflower), Euthamia spp. (goldentops), Ratibida columnifera (Mexican hat), Symphyotrichum ericoides (heath aster), Silphium Iaciniatum (compass plant), Baptisia spp. (wild indigos), Iva angustifolia (narrowleaf sumpweed), Eryngium yuccifolium (button snakeroot), Boltonia diffusa (smallhead doll's daisy), and Neptunia Iutea (yellow neptunia). Woody species may invade this typically herbaceous mgetation, including Rosa bracteata (Macartney rose), Acacia farnesiana (huisache), Triadica sebifera (Chinese tallow), Baccharis halimifolia (baccharis), Celtis Iaevigata (sugar hackberry), and Prosopis glandulosa (honey mesquite). Gulf Coast: Coastal Prairie (0.6%) This system occupies as described above. Texas Saline Coastal Prairie This systemoccupiessaline soils, generallynear-coast, on level topography of the Beaumont Formation. Sites may be nearly monotypic stands of Spartina spartinae (Gulf cordgrass). Other graminoids that may be present to abundant include Schizachyrium scoparium (little bluestem), Andropogon glomeratus (bushy bluestem), Panicum virgatum (switchgrass), Muhlenbergia capillaris (Gulf muhly), or Sporobolus indicus (rat-tail smutgrass). Spartina patens(marshhaycordgrass), Aristida oligantha(oldfield threeawn), Paspalum hartwegianum (Hartweg paspalum), Sporobolus virginicus (seashore dropseed), Paspalum vaginatum (seashore paspalum), and Distichlisspicata(saltgrass)may becommon, particularly on lower, somewhat wetter sites. Forbs are generally uncommon, but may include species such as Borrichia frutescens (sea ox-eye daisy), Solidago sempervirens (seaside goldenrod), Iva angustifolia (narrowleaf sumpweed), Euthamia spp. (goldentops), or other species more common to the non-saline soils nearby, or the salt marsh that may also be nearby. Microtopographic highs in the form of pimple mounds often have species more characteristic of less saline adjacent habitats. Shrubby species may invade the prairie, commonly including species such as Iva frutescens (shrubby sumpweed), Prosopis glandulosa (honey mesquite), Acacia farnesiana (huisache), Lycium carolinianum (Carolina wolfberry), Tamarix spp. (salt cedar), and Baccharis halimifolia (baccharis).

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Table 2-7 Vegetation Types Mapped inthe Study Area Vegetation Type Vegetation Type Description Gulf Coast: Salty Prairie Occurs where the Texas Saline Coastal Prairie system is lacking (<0.1%) significant shrub comr Mainly Natural Azonal Mapped Types Azonal types are those types that are widespread and not particularly characteristic of any region or naturally occurring \,egetation type. This maybeduetodisturbance, where wide-ranging speciesadapted to disturbed conditions predominate. In other areas, land management may have resulted in invasion of widespread species such as juniper or mesquite. Azonal types may also be used to refer to general physiognomic types that are not ascribable to particular naturally occurring systems. This Axonal type throughout the Gulf Prairies and Marshes. Rosa bracteata (Macartneyrose)is the most common dominant ofthis type, but a variety of mainly invasive shrub types may occur, including species such as Acacia farnesiana (huisache), Baccharis spp. Non-nati~e Invashe: Rose (baccharis), Triadicasebifera (Chinesetallow), Celtislaevigata(sugar Shrubland (0.1%) hackberry), Ulmus crassifolia (cedar elm), and Ilex vomitoria (yaupon). Sparse tree cover with species such as Quercus fusifomiis (plateaulim oak), Quercus virginiana (coastal lim oak), Quercus nigra (water oak), Celtis Iaevigata (sugar hackberry), and Fraxinus pennsylvanica (green ash) may also occur. Elliott et al , 2014

For the purpose of this EA, emphasis was placed on obtaining known locations of unique vegetative communities that have been previously documented within the study area. A GIS shapefile and element occurrence report of known occurrences of sensitive vegetative communities was requested from the TXNDD on March 20, 2020. TPWD (2020b) has no documented occurrences of unique or unusual vegetation communities or associations in the study area or within five miles of the study area.

2.5.3.2 Aquatic and Hydric Habitats Aquatic habitats within the study area are limited and have artificial or intermittent water. Vegetation supported byaquatichabilats, such asemergentwetlandsand surfacewater, includes floating-Ieaved plants, emergent plants, and grasses (USACE, 2010).

Mapped wetland information was derived using NWI (USFWS, 2020) and NHD (USGS, 2019a) maps. NWI maps are based on topography and interpretation of infrared satellite data and cobr aerial photographs and are classified underthe Cowardin System (Cowardin et al., 1979). These maps are typically conservative estimates of wetlands, primarily because the hydrology of the area has likely been modified by ground disturbing activities, such as farming, channelized streams, orinstallation of Ieveesand drainages. NWI maps identify fourpotentialwetland features within the study area, in addition to freshwater ponds and riverine systems (USFWS, 2020). NI-D

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%-t -4 - J X/tj 105 -t { j-

1 f l /tlf LlPROJECT AREA 6

N ~ VEGETATIONALAREA BOUNDARY - PINEYWOODS - GULF PRAIRIES AND MARSHES VEGETATIONAL AREAS POST OAK SAVANNAH OF TEXAS 0 50 100 4 - BLACKLAND PRAIRIES MILES CROSS TIMBERS AND PRAIRIES 6 SOUTH TEXAS PLAINS TNMP GREENBELT-CATTAIL-CHEROKEE EDWARDS PLATEAU 138 KV TRANSMISSION LINE PROJECT 8 - ROLLING PLAINS TNMP 9 - HIGH PLAINS 10- TRANS-PECOS lexa,+Iew Mexico Power FIGURE 2-5 ] COUNTY BOUNDARY

PATH O \10210662 10189_TNMP_TEXAS_CITY_CCNWIAP_DOCSIAGUREIEAWE ASCITY FIG2 5 VEGETATIONALAREAS 'Xll MXD . USER BJANIK . DATE /5/2020 2-27 Page 71 of 528 Attachment 1 - Greenbelt-Cattail-Cherokee Environmental Assessment and Routing Study Greenbelt-Cattail-Cherokee 138 kVTransmission Line Proiect classified a majority of the lake/pond and reservoir habitats as artificial, with one being intermittent, and all of the stream/river features as intermittent (USGS, 2019a).

2.5.4 Soils The Web Soil Survey, published by the NRCS for Galveston County was reviewed (NRCS, 2020) to identify and characterize the soils occurring within the study area.

Soil map units identified within the study area are provided in Table 2-8. A soil map unitconsists of one or more major soil series and other minorsoils. Table 2-8 also indicates if any mapped soil series are considered hydric and/or prime farmlands (NRCS, 2020).

Thesoil map unitsoccurring withinthe studyarea include Edna loam, 0 to i percentslopes; Edna- Aris complex, 0 to 1 percent slopes; Francitas-Urban Land complex, 0 to 1 percent slopes, rarely flooded; Kemah-Urban Land complex; and Verland silty clay Ioam, rarely flooded. The dominant soil unit, Francitas-Urban land complex, O to 1 percent slopes, rarely flooded, is found on flats in the south part of the study area, which is heavily industrialized. The next most common soil map unit is the Kemah-Urban land complex. This soil unit occurs on meander scrolls across the northern portion of the study, more in the residential area. The Edna-Aris complex, 0 to 1 percent slopesoccursinthecenterofthestudyarea inan industrializedarea. Theseareclayeyand Ioarny soils on flats. The Verland silty clay Ioam, rarely flooded soil map unit is found in the northwest cornerof the study area. This is a Ioamy soil on meander scrolls. The Edna Ioam, 0 to 1 percent slopes soil unit occurs near the northwest corner of the study area and is a Ioamy soil. All of the soils in the study area are somewhat poorly drained and range from 0 to 36 inches to the water table (NRCS, 2020).

Table 2-8 Mapped Soil Units within the Study Area

Percent Prime Hydric Farmland Soil Map Unit Description of Study Soil Area Soil Galveston County Loamy and clayey; \,ery deep; somewhat poorly Yes (of Edna Ioam, 0 to 1 Yes drained; mry slow 0.5 statewide percent slopes permeability; nearly level (5%) importance) flats Loamy and clayey; very Edna-AMs deep; somewhat poorly to Yes Yes (of complex, 0 to 1 9.2 statewide percent slopes poorly drained; nearly level (5%) importance) flats

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Table 2-8 Mapped Soil Units within the Study Area

Percent Prime Hydric Soil Map Unit Description of Study Farmland Soil Are a Soil Galveston County Francitas-Urban clayey; very deep; Land complex, 0 somewhat poorly drained; to 1 percent 50.2 Yes No slopes, rarely very slow permeability; (54%) flooded nearly level flats Loamy and clayey; deep; Kemah-Urban somewhat poorly drained; 30.8 No No Land complex very slow permeability; nearly Ie,el uplands Loamy and clayey; very Verland silty clay deep; somewhat poorly Yes Yes (of Ioam, rarely drained; very slow 5.2 statewide flooded permeability; nearly level (3%) importance) flats Water --- 4.1 - NRCS, 2020

2.5.4.1 Prime Farmland Soils The Secretary of Agriculture, within U.S.C. §7-4201(c)(1)(A), defines prime farmland soils as those soils that have the best combination of physical and chemical charaderistics for produdng food, feed, forage, fiber, and oilseed crops. They have the soil quality, growing season, and moisturesupplyneededtoeconomicallyproducesustained highyieldsofcrops whentreated and managed, including water management, according to acceptable farming methods. Generally, farmlands of statewide importance include those that are nearly prime farmland and that economically produce high yields of crops when treated and managed according to acceptable farming methods. According to the NRCS-Web Soil Survey (NRCS, 2020), no soils mapped within the study area are designated as prime farmland. Theentire study area is in an urban area with no farmland.

Typically, the NRCS doesnotconsiderpowerlinestobea conversionof prime farmlands because the site can still be used for farming after construction, and these projects are normally exempt from the Farmland Protection Policy Act.

2.5.5 Water Resources Water resources evaluated in this study include surface water and groundwater. Information on water resources within the study area was obtained from a variety of sources, including the

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TWDB, USGS topographical maps (USGS 2019b, 2019c), TPWD, TCEQ, FEMA, and aerial photographs (Bing, 2019)

2.5.5.1 Surface Wate rs Thestudyarea is located withinthe San Jacinto-Brazos Riverbasin (TWDB, 2016), approximately 20 miles south of the San Jacinto River and abutting Galveston Bay. The local watershed within the studyarea is Dickinson Bayou Watershed (HUC 12 : 120402040200), draining 240,607 acres into Galveston Bay.

Surface waters andtheirassociated wetlandslocated within the study area are potentiallysubject to USACE regulations as "waters of the U.S." under Section 404 of the CWA. No streams within the study area are classified as "navigable waters of the U.S." under Section 10 of the Rivers and Harbors Act of 1899 according to the list published by the USACE Galveston District.

2.5.5.2 Floodplains Available floodplain and floodwaydata were digitized from FEMA Firmpanels. The 100-year flood (1% flood or base flood) represents a flood event that has a 1% chance of being equaled or exceeded foranygiven year. FEMA-mapped 100-yearfloodplainaccounts for 39.75 acres (1.9°/o) of the study area (FEMA, 1991). Mapped floodplains can be seen on Figure 1-2.

2.5.5.3 Groundwater The Gulf Coast aquiferis the major groundwater aquifer(TWDB, 2006 and 2011) within the study area. The Gulf Coast is the principal aquifer for the Gulf of Mexico coastline from the Louisiana borderto the borderof Mexico (TWDB, 2011). It consists of several aquifers including the Jasper, Evangeline, and Chicot aquifers. These aquifers are composed of discontinuous sand, silt, clay, and gravel beds. Thickness ranges from 700 feet in the south to 1,300 feet in the north, with freshwater averaging about 1,000 feet. The aquifer is used for municipal, industrial, and irrigation proposes. There are no minor aquifers in the study area (TWDB, 2017).

Review of the TWDB (2019) water well data indicated 27 water wells used for withdrawal of water located within the study area. Two of these wells are owned by the City of Texas City forpublic water supply with an average depth of 705 feet. There are 13 wells used for industrial purposes that have an average depth of 839 feet. The 12 remaining wells are unused. No wells within the study area are used for irrigation, livestock, domestic, or recreational purposes. Review of the

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USGS topographic maps (USGS 2019b, 2019c) and the literature did not indicate any springs within the study area (Brune, 2002; Heitmuller and Reece, 2003).

2.5.5.4 Special Status Wate rs Under 31 TAC 357.8, TPWD has identified Ecologically Significant Stream Segments (ESSS) based on habitat value, threatened and endangered species, species diversity, and aesthetic value criteria. Reviewof the TPWD (2017) data did not indicate any designated ESSS within the study area. Additionally, there are no National Wild and Scenic Rivers within the study area (NWSRS, 2020).

Thestudyareais located withinthe boundaryofthe Texas Coastal Management Program(CMP). The PUC is a networked agency under the Texas CMP and has the authority to conduct a consistency review of its authorized activities. In accordance with 16 T.A.C. Section 25.102(b)(2), the project does not require a consistency review because the project is not located within a Coastal Barrier Resource System Unit or Otherwise Protected Area seaward of the Coastal Facility Designation Line and within a coastal wetland, critical dune area, Gulf beach, hard substrate reef, oyster reef, special hazard area, submerged aquatic vegetation, or tidal sand and mud flats.

In accordance with Section 303(d) of the CWA, the TCEQ identifies surface waters that do not meet current Total Maximum Daily Load (TMDL) and implements measures to bring the water quality within the TMDL standard. Review of the TCEQ (2019), 303(d) list did not indicate any stream segments within the study area that do not currently meet the water quality standards for designated uses.

2.5.5.5 Future Surface Water Developments In 1997, Senate Bill 1 was enacted to develop a regional approach for the development, conservation, and management of the state's water resources. Sixteen planning regions were developed, and each Regional Planning Group was charged with the development of a Regional Water Plan to be incorporated into the State Water Plan. The study area is within Region H, and a review of this plan did not indicate any evaluated, proposed, or potential new reservoirs within the study area (TWDB, 2016). However, TWDB water demand projections for Galveston County indicate a demand of 117,349 acre-feet in 2020(TWDB, 2018). Demand increases of 11.2% and

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13.8%, respectively, are expected overthe following two decades. Manufacturing and municipal use account for a vast majority of this demand.

2.5.6 Wildlife and Fisheries 2.5.6.1 Wildlife in the Area The study area is located on the southeastern edge of the Texan Biotic Province (see Figure 2- 6) (Blair, 1950). The Texan province includes the eastern region of central Texas from the Red River to the Gulf Coast of Texas, between Calhoun and Galveston counties. The plants and animals of this province are mostly species that are widely distributed in the oaks and prairies of the Gulf Coastal Plainof North America. Due to thedominanceof urbancovertypes, the following sections describe wildlife most likely to occur in an urban environment.

Amphibian species (frogs, toads, salamanders, and newts) that potentially occur within the study area are listed in Table 2-9. Frogs and toads may occur in all vegetation types, and salamanders and newts are typically restricted to moist habitats. None of the species listed are considered threatened or endangered under Section 7 of the ESA.

Table 2-9 Amphibian Species Potentially Occurring within the Study Area Common Name Scientific Name Frogs/Toads American bullfrog Rana catesbeiana Cope's gray treefrog Hyla chrysoscelis Crawfish frog Rana areolata Eastern narrow-mouth toad Gastrophryne carolinensis Gray treefrog Hyla versicolor Green treefrog Hyla cinema Gulf Coast toad Incilius nebulifer Northern cricket frog Acris crepitans Southern leopard frog Rana sphenocephala Spring peeper Psuedocris crucifer Strecker's chorus frog Pseudocris steckeri Woodhouse's toad Anaxyrus woodhousii Salamanders/Newts Eastern newt Notophthalamus viridescens Lessersiren Siren intermedia Small-mouthed salamander Ambystoma texanum LaDuc and Canatella 2020 (online)

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Reptiles(turtles, lizards, and snakes) potentiallyoccurring withinthestudyarea are listed in Table 2-10. These include those species thatare typicallyassociated with urban woodland and open habitats as well as species that may occur near relatively permanent water sources such as livestock ponds or perennial pools in streams (LaDuc and Cannatella, 2020 [online]). The presence of any species typically associated with water (e.g., turtles) would depend on the occurrence of these habitats within the study area. None of the species listed are considered threatened or endangered under Section 7 of the ESA.

Table 2-10 Reptilian Species Potentially Occurring w ithin the Study Area Common Name Scientific Name Turtles Eastern mud turtle Kinosternon subrubrum Pond slider Trachemys scripta Snapping turtle Chelydra serpentina Spiny soft-shelled turtle Apalone spinifera Texas river cooter Pseudemys texana Lizards Brown anole Anolis sagrei Common house gecko Hemidactylus frenatus Common five-lined skink Plestiodon fasciatus Green anole Anolis carolinensis Little brown skink Scincella Iateralis Mediterranean house gecko Hemidactylus turcicus Six-lined racerunner Aspidoscelis sexlineata Slenderglass lizard Ophisaurus attenuatus Snakes Coachwhip Masticophis flagellum Common gartersnake Thamnophis sirtalis Common kingsnake Lampropeltis getula Copperhead Agk istrodon contortrix Cottonmouth Agk istrodon piscivorus Dekay's brown snake Storeria dek ayi Diamond-backed watersnake Nerodia rhombifer Eastern hog-nosed snake Heterodon platirhinos Eastern ratsnake Pantherophis obsoletus Plain-bellied watersnake Nerodia erythrogaster Rough earthsnake Virginia striatula Rough greensnake Opheodrys aestivus Western rattlesnake Crotalus atrox Western ribbonsnake Thamnophis proximus Lauucand Cannatella (online), 2020

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Numerous avian species are potentially present in the study area, includingyear-round residents, as well as winter and summer residents, as listed in Tables 2-11, 2-12, and 2-13 (Lockwood and Freeman, 2014; Billerman et al. 2020; Houston Audubon Society 2006). Additional bird species include spring and autumn migrants, spring and summer breeding species, orwinter residents. Winter resident species that may potentially occur in the study area are listed in Table 2-12 (Lockwoodand Freeman, 2014; Billermanetal. 2020; Houston Audubon Society 2006). Summer residents that may potentially occur in the study area are listed in Table 2-14. The likelihood for occurrence of each species depends upon suitable habitat and season. The majority of birds potentially occurring in the study area have protection under the MBTA of 1918. None of the species listed are considered threatened or endangered under Section 7 of the ESA.

Table 2-11 Year-Round Resident Bird Species Potentially Occurring within the Study Area Common Name Scientific Name American crow Corvus brachyrhynchos Black vulture Coragyps atratus Blue jay Cyanocitta cristata Brown-headed cowbird Molothrus ater Carolina chickadee Poecile carolinensis Carolina wren Thryothorus Iudovicianus Common raven Corvus corax Cooper's hawk Accipitercooperii Downy woodpecker Picoides pubescens European starling Sturnus vulgaris Great blue heron Ardea herodias Great egret Ardea alba Greater roadrunner Geococcyx californianus Great horned owl Bubovirginianus Great-tailed grackle Quiscalus mexicanus House finch Carpodacus mexicanus House sparrow Passer domesticus Killdeer Charadrius vociferus Laughing gull Larus atricilla Mallard Anas platyrhynchos Mouming dove Zenaida macroura Northern cardinal Cardinalis cardinalis Northern mockingbird Mimus polyglottos Pied-billed grebe Podilymbus podiceps Red-bellied woodpecker Melanerpes carolinus Red-shouldered hawk Buteo Iineatus

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Table 2-11 Year-Round Resident Bird Species Potentially Occurring within the Study Area Common Name Scientific Name Red - tailed hawk Buteo jamaicensis Red -vvinged blackbird Agelaius phoeniceus Rock pigeon Columba livia Tufted titmouse Baeolophus bicolor Turkey vulture Cathartes aura White - winged dove Zenaida asiatica Lockwood and Freeman, 2014; Billermanetal 2020; Houston Audubon Society 2006

Table 2-12 Winter Resident Bird Species Potentially Occurring within the Study Area Common Name Scientific Name American kestrel Falco span/ erius American goldfinch Spinus tristis Cedar waxwing Bombycilla cedrorum Lincoln ' s sparrow Melospiza Iincolnii Northern shoveler Anas clypeata Osprey Pandion haliaetus Pinewarbler Dendroica pinus Ruby - crowned kinglet Regulus calendula Savannah sparrow Passerculus sandwichensis Vespersparrow Pooecetes gramineus White - crowned sparrow Zonotrichia Ieucophrys Yellow - bellied sapsucker Sphyrapicus varius Lockvood and Freeman,2014, Billermanetal.2020, Houston Audubon Society 2006

Table 2-13 Summer Resident Bird Species Potentially Occurring within the Study Area Common Name Scientific Name Barn swallow Hirundo rustica Blue-gray gnatcatcher Polioptila caerulea Chimney swift Chaetura pelagica Cliff swallow Petrochelidon pyrrhonota Common nighthawk Chordeiles minor Eastern kingbird Tyrannus tyrannus Painted bunting Passerina ciris Purple martin Progne subis Red-eyed dreo Vireo olivaceus Ruby-throated hummingbird Archilochus colubris Scissor-tailed flycatcher Tyrannus forficatus Summertanager Piranga rubra Yellow-crowned night heron Nyctanassa violacea White - eyed vireo Vireo griseus Lockwood and Freeman, 2014; Billerman et al. 2020, Houston Audubon Society 2006

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Mammals potentiallyoccurring in the study area are listed in Table 2-14 (Schmidly and Bradley, 2016). The occurrence of each species depends upon the availability of suitable habitat. None of the species listed are considered threatened or endangered under Section 7 of the ESA.

Table 2-14 Mammalian Species Potentially Occurring within the Study Area Common Name Scientific Name Big brown bat Eptesicus fuscus Bobcat Lynx rufus Brazilian free - tailed bat Tadarida brasiliensis Common raccoon Procyon Iotor Coyote Canis Iatrans Deer mouse Peromyscus maniculatus Eastern cottontail Sylvilagus flaridanus Eastern red bat Lasiurus borealis Eastern gray squirrel Sciurus carolinensis Eastern woodrat Neotoma floridana Evening bat Nycticeius humeralis Ful \,ous hanest mouse Reithrodontomys fulvescens Hispid cotton rat Sigmodon hispidus Hispid pocket mouse Chaetodipus hispidus Hoary bat Lasiurus cinereus Nine - banded armadillo Dasypus novemcinctus Norway rat Rattus norvegicus Striped skunk Mephitis mephitis Virginia opossum Didelphis virginiana White -footed mouse Peromyscus Ieucopus White - tailed deer Odocoileus virginianus Schmidly and Bradley 2016 (online)

2.5.6.2 Fisheries in the Area The study area is located v\~thin the West Galveston Bay sub-watershed of the San Jacinto - Brazos Riverbasin(USGS, 2019a)andisborderedtothesoutheast by Galveston Bay. Alsurface waters and wetland habitatwithinthestudyareaareassociated with urbanchannelized drainages or concrete storm drainsand are unlikely to support a high diversity of fish. Fish likely to be found in the study area are generalist species adapted to highly disturbed waters. The species with potential to occur in the study area are listed in Table 2-15.

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Table 2-15 Fish Species Potentially Occurring within the Study Area Common Name Scientific Name Black bullhead Ameiurus melas Blackstripe topminnow Fundulus notatus Bluegill Lepomis macrochirus * Bullhead minnow Pimephales vigilax Gizzard shad Dorosoma cepedianum Golden topminnow Fundulus chrysotus Green sunfish Lepomis cyanellus Inland silverside Menidia beryllina Pugnose minnow Opsopoeodus emiliae Red shiner Cyprinella Iutrensis Slough darter Etheostoma gracile Western mosquitofish Gambusia affinis UTA,2020 and Hendrickson and Cohen, 2015; * = non-native species

Fish species that may occur within the study area include those species specialized to low gradient streams and ditches (Hendrickson and Cohen, 2015).

Several species of turtles, snakes, and amphibians are also dependent on perennial surface waters for their habitat requirements. Several of these species will infrequently use terrestrial habitats to migrate between surface waters, but they primarily inhabit impounded and perennial surface waters.

2.5.7 Threatened and Endangered Species Data on special status species and unique vegetation resources within the study area were obtained from a variety of sources including the USFWS Information for Planning and Consultation (IPaC) database; TPWD county list of rare, threatened, and endangered species; and the TPWD TXNDD. Additional information was obtained from published literature and technical reports.

For the purpose of this environmental assessment, emphasis was placed on obtaining known locations of unique vegetative communities and critical habitat or known occurrences of special status species that have been previously documented within the study area. Special status species include those listed bythe USFWS asthreatened, endangered, proposed, or candidate; and those listed by TPWD as threatened, endangered, or as a species of greatest conservation need (SGCN). A GIS shapefile of known occurrences for listed species and sensitive vegetative

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The USFWS maintains a federal listing of all threatened, endangered, and candidate spedes for eachcounty. By definition, athreatenedspecies isdefined as Iikelyto become endangered within the near future throughoutall or a significant portion of its range. An endangered species is in danger of extinction throughout all or a significant portion of its range. Candidate species are those that have sufficient information on theirbiological vulnerability and threats to support listing as threatened or endangered, and are likely to be proposed for listing in the near future.

The ESA also provides for the conservation of "designated critical habitat," which is defined as the areas of land, water, and air space that an endangered species needs for survival. These areas include sites with food and water, breeding areas, cover or shelter sites, and sufficient habitatto provide for normal population growth and behavior forthe species. The primarythreat to many threatened and endangered species is the destruction or modification of habitat. According to the USFWS (2020) there is no "designated critical habitat" within the study area.

2.5.7.1 Wildlife Species Threatened, endangered, and candidate wildlife species lists from the USFWS and TPWD were reviewed for Galveston County, and the information is summarized in Table 2-16 (USFWS, 2020a) (TPWD, 2020c). Species not designated as federallythreatened or endangered are not afforded any regulatory protection under the ESA.

The USFWS and TPWD threatened and endangered species lists for Galveston County include 23 wildlife species. The species and a brief description of the habitat for each are listed in Table 2-16.

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Table 2-16 Threatened, Endangered, and Candidate Species Listed for Galveston County, Texas Species Legal Status Common Name Brief Habitat Description US FWS1 TPWD2 Scientific Name Birds Open prairies of mostly thick grass one to three feet tall; sandhill country with bunch Attwater's greater prairie grass, sage, and shinnery oak. From near chicken sea level to 200 feet along coastal plain on LE E Tympanuchus cupido uppertwo-thirds ofTexas coast; malesfomn attwateri communal display flocks during Iatewinter- early spring; booming grounds important; breeding February-July Beaches, sandflats, and dunes along Gulf Coast beaches and adjacent offshore islands. Algal flatsappear to bethe highest quality habitat; Sand flats oftenappeartobe preferred over algal flats when both are Piping plover available, but large portions of sand flats LT T Charadrius melodus along the Texas coast are available only during low-very low tides; Optimal site characteristicsappear to be large in area, sparsely vegetated, continuously available or in close proximity to secondary habitat, and with limited human disturbance Prefers the shoreline of coast and bays and Red knot also uses mudflats during rare inland LT T Calidris canutus rufa encounters; tidal flats and beaches, herbaceous wetland, and tidal flat/shore Found primarily near rivers and large lakes; nests in tall trees or on cliffs near water; Bald eagle communally roosts, especially in winter; - T Haliaeetus Ieucocephalus hunts live prey, scavenges, and pirates food from other birds Near coast on prairies, cordgrass flats, and White-tailed hawk scrub-live oak; further inland on prairies, T Buteo albicaudatus mesquite and oak savannas, and mixed savanna-chaparral; breeding March-May Lowland forested regions, especially swampy areas, ranging into open Swallow-tailed kite woodland; marshes, along rivers, lakes, T Elanoides forficatus and ponds; nests high in tall tree in clearing or on forest woodland edge, usually in pine, cypress, or various deciduous trees Salt, brackish, and freshwater marshes, pond borders, wet meadows, and grassy swamps; nests in or along edge of marsh, Black rail sometimes on damp ground, but usually on PT - Lateralus jamaicensis mats of previous years dead grasses; nests usually hidden in marsh grass or at base of Salicornia Historically, shortgrass plains and prairies, Eskimocurlew but more recently (1960s) in old fields, LE E Numenius borealis closely grazed pastures, burned prairies, and marshes; beaches and sand flats.

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Table 2-16 Threatened, Endangered, and Candidate Species Listed for Galveston County, Texas Species Legal Status Common Name Brief Habitat Description USFWS1 TPWD2 Scientific Name Nonbreeding: grasslands, pastures, plowed fields, and less frequently, marshes and mudflats Resident of the Texas Gulf Coast; brackish Reddish egret marshes and shallow salt ponds and tidal flats; nests on ground or in trees or bushes, - T Egretta rufescens on dry coastal islands in brushy thickets of yucca and prickly pear Prefers freshwater marshes, sloughs, and irrigated rice fields, but will attend brackish and saltwater habitats; currently confined to White-faced ibis near-coastal rookeries in so-called hog- - T Plegadis chihi wallow prairies. Nests in marshes, in low trees, on the ground in bulrushes or reeds, or on floating mats. Prefers to nest in large tracts of baldcypress (Taxodium distichum) or red mangrove (Rhizophora mangle¥, forages in prairie ponds, flooded pastures or fields, ditches, and other shallow standing water, including salt-water; usually roosts communally in tall Wood stork snags, sometimes in association with other - T Mycteria americana wading birds (i.e., active heronries); breeds in Mexico, and birds move into Gulf States in search of mud flats and other wetlands, even those associated with forested areas; formerly nested in Texas, but no breeding records since 1960 Mammals Lim in marine, brackish, and freshwater systems in coastal and riverine areas throughout their range; preferred habitats include areas nearthe shore featuring West Indian manatee underwater vegetation like seagrass Trichechus manatus and - _ -LE - _ E eelgrass. They feed along grass bed margins with access to deep water channels, where they flee when threatened. Inhabits tropical, subtropical, temperate, and subpolar waters worldwide; they will use both open ocean and coastal waters, Humpback whale sometimes including inshore areas such as LE E Megaptera novaeangliae bays , and are often found nearthe surface ; however, this species is rare in the Gulf of Mexico. Historically, lowland pine and hardwood Rafinesque's big-eared forests with large hollow trees. roosts in bat cavity trees of bottomland hardwoods, - T Col 'yrynchus rafinesqui concrete culverts , and abandoned man - made structures

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Table 2-16 Threatened, Endangered, and Candidate Species Listed for Galveston County, Texas Species Legal Status Common Name Brief Habitat Description USFWS1 TPWD2 Scientific Name Reptiles Inhabits tropical, subtropical, and temperate waters worldwide, including the Gulf of Mexico. Adults and jumniles occupy inshore and nearshore areas, Green sea turtle including bays and Iagoons with reefs and LT T Chelonia mydas seagrass . They migratefrom feeding grounds (open ocean) to nesting grounds (beaches/barrier islands), and some nesting does occur in Texas (April to September). Inhabit tropical and subtropical waters worldwide, in the Gulf of Mexico, especially Texas. Hatchling and juveniles are found in open, pelagic ocean and closely Hawksbill sea turtle associated with floating algae/seagrass LE E Eretmochelys imbriceta mats . Juveniles then migrate to shallower , coastal areas, mainly coral reefs and rocky areas, but also in bays and estuaries near mangroves when reefs are absent; seldom in water more than 65 feet deep. Inhabits tropical, subtropical, and temperate waters of the northwestern Kemp's ridley sea turtle Atlantic Ocean and Gulf of Mexico. Adults LE E Lepidochelys kempii are found in coastal waters with muddy or sandy bottoms. Inhabit tropical, subtropical, and temperate waters worldwide, including the Gulf of Leatherback sea turtle Mexico. Nesting is not common in Texas LE E Dermochelys coriacea (March to July) Most pelagicof the sea turtles with the longest migration Inhabits tropical, subtropical, and temperate waters worldwide, including the Gulf of Mexico. They migrate from feeding grounds to nesting beaches/barrier islands, and some nesting does occurin Texas (April to September). Beaches that Loggerhead sea turtle are narrow, steeply sloped, with coarse- LT T Caretta caretta grain sand are preferred for nesting. Juveniles and young adults spend their lives in open ocean, offshore before migrating to coastal areas to breed and nest. Foraging areas foradults include shallow continental shelfwaters. Aquatic: perennial water bodies; rivers, canals, lakes, and oxbows; also swamps, Alligatorsnapping turtle bayous, and ponds near running water; Macrochelys temminckii sometimes enters brackish coastal waters . T Females emerge to lay eggs close to the water's edge.

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Table 2-16 Threatened, Endangered, and Candidate Species Listed for Galveston County, Texas Species Legal Status Common Name Brief Habitat Description USFWS1 TPWD2 Scientific Name Terrestrial: Open habitats with sparse vegetation, including grass, prairie, cactus, scattered brush or scrubby trees; soil may vary in texture from sandy to rocky; Texas horned lizard Phrynosoma cornutum burrows into soil, enters rodent burrows, or - T hides under rock when inactive. Occursto 6,000 feet, but largely limited below the pinyon-juniperzone on mountains in the Big Bend area. Fish Only found in low salinity waters of estuaries orfreshwater tributaries within 30 Opossum pipefish miles of the coast, where they also Microphis brachyurus give - T birth. Young move or are carried into more saline waters offthe coast after birth. Different life history stages have different patterns of habitat use: young dependent upon shallow, eurahayline waters with red mangro\E lined shoreline; can tolerate a wide range of salinities, but will move in and out of protected areas (estuaries) due to changes in flow and salinity. Larger juveniles may occupy greater depth strata Smalltooth sawfish in areas further from shore as they Pristis pectinata LE E consistently occupy marine waters. Adult sawfish are encountered in various habitat types (mangrove, oyster reef, seagrass, and coral), in varying salinity regimes and temperatures, and at various water depths, feed on a variety of fish species. Adult female sawfish return to protected estuarine areas to give birth. USFWS, 2020©TPWD, 2020c LE- Federal-Listed Endangered,LT - Federal-Listed Threatened, E - State-Listed Endangered,T - State-Listed Threatened, PT-Proposed Threatened

Bird species currently federally listed for Galveston County include the Attwater's greater prairie chicken, piping plover, red knot, and eskimo curlew. The Attwater's prairie chicken and eskimo curlew require coastal prairie and marshes. The piping ploverand red knot require sand or mud flats, or shoreline along coastal bays and beaches. The TXNDD contains one record of the Attwater's greater prairie chicken approximately 4 miles north of the study area. However, the majority of coastal prairie, marsh, and shoreline habitat in the study is fully developed; therefore, no habitat is present for any listed bird species.

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Bird species currently state-listed for Galveston County include white-tailed hawk, swallow-tailed kite, bald eagle, reddish egret, wood stork, and white-faced ibis. The state-listed bird species require suitable trees/woodland for nesting and coastal marsh, tidal flats, wetlands, or open grasslands forforaging. Although TXNDD documented rookeries nearthestudyarea, nosuitable nesting or foraging habitat occurs in the study area due to the intense urban development.

Five reptile species are currently federally listed for Galveston County, all sea turtles. The study area contains no suitable nesting beaches for sea turtles. Two state-listed reptiles have the potential to occur in Galveston County. The suitable habitat for alligatorsnapping turtle isdeep, perennial water such as rivers, bayous, and large streams. The Texas horned lizard prefers open habitats with sparse vegetation and loose or gravelly soil for burrowing. Due to the intensity of urban development, it is unlikely that the Texas horned lizard occurs in the study area.

2.5.7.2 Plant Species Threatened, endangered, and candidate plant species lists from the USFWS and TPWD were reviewed for Galveston County. Species not designated as federally threatened or endangered are not afforded any regulatory protection under the ESA. No plant species are listed by the USFWS and TPWD as threatened or endangered in Galveston County.

2.5.7.3 TPWD Species of Concern and Sensitive Vegetation Communities While notregulated underthe ESA, TPWD also lists SGCN and sensitive vegetation communities within the study area. TPWD generally recommends consideration for these species and avoidance of listed vegetation communities when routing linear utility corridors. Table 2-17 summarizes the TPWD SGCN species for Galveston County with a brief description (TPWD, 2020c).

Table 2-17 TPWD Species of Greatest Conservation Need for Galveston County, Texas Common Name State Brief Habitat Description Scientific Name Status Amphibians Woodhouse's toad Extremely catholic up to 5,000 feet, does very well Anaxyrus v\ oodhousii ( except for traffic ) in association with man . SU Terrestrial and aquatic: The terrestrial habitat is primarily grassland and can vary from pasture to Southern crawfish frog intact prairie; it can also include small prairies in the Lithobates areolatus areolatus middle of large forested areas . Aquatic habitat is any S3 body of water, but preferred habitat is ephemeral wetlands. Bi rds

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Table 2-17 TPWD Species of Greatest Conservation Need for Galveston County, Texas Common Name State Scientific Name Brief Habitat Description Status Forages during summer and migration over Franklin's gull agricultural fields, prairie, flooded pasture, marshes, S2N Leucophaeus pipixcan and estuaries. Open grasslands, especially prairie, plains, and Western burrowing owl savanna, sometimes in open areas such as vacant S2 Athene cunicularia hypugaea lots near human habitation or airports; nests and roosts in abandoned burrows. Fish Occupies estuaries and the edges of saltmarsh habitats along the Gulf Coast in salinities of 4-20 ppt Saltmarsh topminnow in Spartina dominated tidal creeks and wetlands; Sl Fundulus jenkinsi requires access to small interconnected tidal creeks for feeding and reproduction. This is an estuarine-dependent species that inhabits Southern flounder riverine, estuarine, and coastal waters, and prefers S5 Paralichthys Iethostigma muddy, sandy, or silty substrates. Insects Nesting sites include clumps of dry grass, old bird nests, abandoned rodent burrows, old mattresses, car cushions, or even in or under old abandoned American bumblebee buildings. Foraging worker bees use long tongue to SNR Bombus pensylvanicus pollinate ciovers and other flowers, collecting pollen and nectarthat they bring back to the hive to feed to the colony. Gulf dune grasshopper Coastal dunes and areas behind the dunes. Trimerotropis schaefferi S2? No common name Sand dunes with sparse vegetation in back of the S2? Heliastus subroseus beach along the Texas coast. Mammals Intimately associated with water; coastal swamps & Mink marshes, wooded riparian zones, edges of lakes. S5 Neovison vison Prefer floodplains. Big brown bat Any wooded areas or woodlands except south S5 Eptesicus fuscus Texas. Riparian areas in west Texas. Tricolored bat Forest, woodland, and riparian areas are important. S3S4 Perimyotis subflavus Caves are \,ery important to this species. Caves are rare in Texas portion of range; buildings and hollow trees are probably important. Historically, lowland pine and hardwood forests with large hollow Southeastern myotis bat Myotis austroriparius trees; associated with ecological communities near S4 water. Roosts in cavity trees of bottomland hardwoods, concrete cul\,erts, and abandoned man- made structures. Found in a variety of habitats in Texas. Usually Eastern red bat associated with wooded areas. Found in towns, S4 Lasiurus borealis especially during migration. Known from montane and riparian woodland in Hoary bat Trans-Pecos, and forests and woods in east and Lasiurus cinereus S4 central Texas. Roosts in buildings in east Texas. Largest maternity Mexican free-tailed bat roosts are in Iimestone caves on the Edwards Tadarida brasiliensis S5 Plateau. Found in all habitats, forest to desert.

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Table 2-17 TPWD Speciesof Greatest Conservation Need for Galveston County, Texas Common Name State Brief Habitat Description Scientific Name Status Generalist; open fields, prairies, croplands, fence Eastern spotted skunk/Plains rows, farmyards, forestedges and woodlands. Prefer spotted skunk wooded, brushy areas and tallgrass prairies. S.p. Spilogale putorius ssp. interrupta are found in wooded areas and S5 S.p. interrupta tallgrass prairies, preferring rocky canyons and outcrops when such sites are available. Includes brushlands, fence rows, upland woods, and Long-tailed weasel S5 Mustela frenata bottomland hardwoods, forest edges, and rocky desert scrub. Usually lives close to water. Mountain lion Rugged mountains and riparian zones. S2S3 Puma concolor Reptiles Habitats include open grassland, prairie, woodland edge, open woodland, oak savannas, Iongleaf pine Slenderglass lizard flatwoods, scrubby areas, fallow fields, and areas S3 Ophisaurus attenuatus near streams and ponds, often in habitats with sandy soil. Massasauga Quite common in gently rolling prairie occasionally S3S4 Sistrurus tergeminus broken by creek valley or rocky hillside. Eastern box turtles inhabit forests, fields, forest- brush, and forest-field ecotones. In some areas, they move seasonally from fields in spring to forest in Eastern box turtle summer. They commonly enter pools of shallow Terrapene carolina water in summer. Forshelter, they burrow into loose S3 soil, debris, mud, old stump holes, or under leaf litter. They can successfully hibernate in sites that may experience subfreezing temperatures. Ornate or western box turtles inhabit prairie grassland, pasture, fields, sandhills, and open woodland. They are essentially terrestrial but Ornate box turtle S3 Terrapene ornata sometimes enter slow, shallow streams and creek pools. For shelter, they burrow into soil (e.g., under plants such as yucca)orenterburrows made by other species. Coastal marshes, tidal flats, coves, estuaries, and Iagoons behind barrier beaches; brackish and salt Texas diamondback terrapin water; burrows into mud when inactive. Bay S2 Malaclemys terrapin Iittoralis islands are important habitats. Nests on oystershell beaches. Habitat consists of areas withsandyorgravelly soils, including prairies, sand hills, wide valleys, river Western hognose snake floodplains, bajadas, semi-agricultural areas, and S4 Heterodon nasicus margins of irrigation ditches; also thorn scrub woodlands and chaparral thickets. Seems to prefer sandy and Ioamy soils, not necessarily flat. Plants Awnless bluestem Coastal prairies on black clay; Perennial; Flowering Bothriochloa exaristata April-Dec; Fruiting April-Dec. S3 Coastal prairie grasslands of various types, from Coastal gayfeather salty prairie on low-lying somewhat saline clay Ioams S2S3 Liatris b racteata to upland prairie on nonsaline dayey to sandy Ioams; flowering in fall.

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Table 2-17 TPWD Speciesof Greatest Conservation Need for Galveston County, Texas Common Name State Scientific Name Brief Habitat Description Status Wet or saturated silty soils along brackish or Corkwood freshwater swamps and ponds and other low, poorly Leitneria pilosa ssp. pilosa drained sites ; flowers in early spring , fruiting as early S2 as May. Wet, silty clay Ioams on streamsides, in creek beds, irrigation channels and roadside drainage ditches; or Correll's false dragon-head seepy, mucky, sometimes gra,elly soils along riverbanks or small Physostegia correllii islands in the Rio Grande; or S2 underlain by Austin Chalk Iimestone along gently flowing spring-fed creeks in central Texas; flowering May-September. Known in Texas from a single historic collection from Galveston Island; elsewhere known from remnant Grand prairie emning primrose moisttodrytallgrass prairies on sandyorsilty Alfisols Oenothera pi/ose//a ssp. sessi/M over claypan on ancient river terraces of the SH Mississippi Alluvial Plain, and fragipan flatwoods; flowering May-June. On and around naturally barren or sparsdy vegetated saline slick spots or pimple mounds on Houston daisy coastal prairies, usually on sandy to sandy Ioam soils, occasionally in pastures and on roadsides in Sl Rayjacksonia aurea similarsoil types where mowing may mimic natural prairie disturbance regimes; flowering late September-November (--December) Sandy soils in moist prairies, incl. blackland/Fleming prairies, calcareous prairie pockets surrounded by Texas ladies'-tresses pines, pine-hardwood forest, open pinelands, Spiranthes brevilabrisvar. wetland pine savannahs / flatwoods , and dry to moist Sl brevilabris fields , meadows , and roadsides . Delicate , nearly ephemeral orchid, producing winter rosettes, flowers Feb-Apr. Historically endemic to SE coastal plain. Texas sunflower Helianthus praecox ssp. Sandy open areas along the upper Texas coast; S2 praecox Annual; Flowering April-Sept. Sandy to sandy [oam soils in relatively bare areas in Texas windmill grass coastal prairie grassland remnants, often on Chloris texensis roadsides where regular mowing may mimic natural S2 prairie fire regimes; flowering in fall. Near coast in sparse, low vegetation on a veneer of light colored silt or fine sand over saline clay along Threellower broomweed drier upper margins of ecotonebetween salty praities Thurovia triflora and tidal flats ; further inland associated with S2S3 Egetated slick spots on prairie mirna mounds; flowering September-November. Occurring mostly in tallgrass prairie of the southern Topeka purple-coneflower Great Plains, in blackland prairies but also in a variety S3 Echinacea atrorubens of other sites like Iimestone hillsides ; Perennial ; Flowering Jan-June; Fruiting Jan-May. Traub's rainlily Primarily sandy Ioam, open fields, coastal plains. Cooperia traubii Flowering early summer -- mid fall ( Jul -- Nov) S3 Source· TPWD, 2020c

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The TXNDD data includes documentation of one species of concern within the study area: plains spotted skunk (TPWD, 2020b). This TXNDD record is a historical record (prior to 1960) and is mapped with an estimated location with al0 kilometer radius. Due to the historical nature of the observation, suitable habitat may have been present duringthe time of the observation, but due to current urban development, the plains spotted skunk is unlikely to occur in the study area. Within a one-mile buffer of the study area, two additional observations of SGCN species have been documented-coastal gayfeather north of the study area and Texas diamondback terrapin south of the study area. Although the study area is adjacentto the bay, no suitable habitat for the terrapin occurs within the study area. Several small patches of coastal prairie occur within the study area. Due to the surrounding urban development, these areas have been invaded by non- native species. However, the coastal gayfeather may occur in one of these patches.

The remaining 12 TXNDD records within five miles of the study area include: the Topeka purple coneflower (one record), coastal gayfeather(five records), Grand Prairie evening primrose (one record), awnless bluestem (one record), Texas diamondback terrapin (three records), and southern crav\dish frog (one record). The few small patches of remaining coastal prairie may provide suitable habitat for the SGCN plants. Southern crawfish frogs are largely limited to tallgrass or outlier prairie, degraded grasslands, wooded regions along streams associated with grasslands, and pastures, although smaller breeding populations may be found in areas where prairie has been converted for agriculture. Some suitable degraded grasslands with wooded streams in the study may provide suitable habitat.

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3.0 ALTERNATIVE TRANSMISSION LINE ROUTE IDENTIFICATION 3.1 ROUTING STUDY METHODOLOGY This section describes the methodologies and assumptionsthat were used to conduct the EA for the Greenbelt-Cattail-Cherokee 138 kV Transmission Line Project. A base map was developed forthe HDR planning team and TNMP to delineate the study area boundaries. The HDR planning team was comprised of technical experts within each respective resource field. Initial field reconnaissance was conducted (February 20,2020), and preliminary evaluation criteria were developed. Based on data pertinentto the study area, the HDR planning team and TNMP also established criteria, consistentwith PUC standards, forthe resource analysis. Data were collected pertaining to land use, recreational and park areas, historical and aesthetic values, and environmental integrity. Available GIS coverage with associated metadata was reviewed, and relevant resource data were selected and mapped. Sensitive resource locations were identified on an environmental and land use composite constraints map. Feasible and geographically diverse preliminary transmission line links were developed, and a public meeting was conducted on June 30,2020, as well as a virtual public meeting. Following the public meeting, data were tabulated for the resulting alternative transmission line links, which were then organized into alternative transmission line routes. A comparative potential impact assessment of all of the alternative transmission line routes was completed, culminating in the recommendation of the alternative routes.

The study approach included the following major tasks: • Base Map Development • Development of Evaluation Criteria • Study Area Delineation • Data Collection and Mapping • Reconnaissance Surveys • Sensitivity Criteria and Analysis • Opportunities and Constraints Evaluation • Preliminary Transmission Line Link Identification • Public Involvement Program • Selection of Alternative Transmission Line Routes • Impact Assessment of Alternative Transmission Line Routes • Selection of Alternative Routes

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A detailed description of the methodologies used to completethis EA and routing study follows.

3.1.1 Base Map Development A project base map was prepared at a scale of 1:5,280 (1 inch = 440 feet). The base map is a singlesheetcovering the area betweenthe studyareaboundariesand was usedto initiallydisplay resource data for the study area. Resource data categories and factors that were determined appropriate within the study area were selected and mapped.

Data displayed on the base map include: • Major land jurisdictionsand uses • Major roads, including county roads, farm-to-market roads, U.S. highways, and state highways • Existing transmission line and pipeline corridors • Parks and recreational areas • Major political subdivision boundaries • Lakes, canals, creeks, and ponds

The base map provides a broad ovelviewof various resource locations indicating obvious routing constraints and areas of potential routing opportunities.

3.1.2 Study Area Delineation The study area (Figure 2-1) was defined to include feasible geographically diverse alternatives for the proposed 138 kV transmission line to connect the Greenbelt, Cattail, and Cherokee Substation Sites. Major physiographic features, jurisdictional boundaries, sensitive resources, land uses, and existing roadways and utility corridors helped to define thestudy area boundaries. The study area boundary was depicted on a study area map that was included with consultation letters, dated March 26,2020, that were sentto agencies and officials for comment on the projed (see Appendix A).

3.1.3 Evaluation Criteria Evaluation criteria were developed to reflect accepted practices for routing electrictransmission Iinesin Texas (see Table 3-1). Emphasiswasplacedonacquiring information identifiedin Section 37.056(c)(4)(A)-(D) of PURA, the PUC CCN application, and PUC Substantive Rule 25.101. Evaluation criteria were further refined based on data collection, reconnaissance surveys

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(February 20,2020 and June 30,2020), and public input. The routing activities were conducted with consideration and incorporation of the evaluation criteria. Routing activities included data collection, reconnaissance surveys, resource analysis, identification of routing opportunities and constraints, and identification of the preliminary transmission line links. Evaluation criteria data were collected, mapped, tabulated, and compared (Section 4) for each resulting alternative transmission line route and ultimately used as a basis forthe recommendation of the alternative routes (Section 5).

Table 3-1 Land Use and Environmental Evaluation Criteria LAND USE Length of altemati~e route (feet) Length of alternative route (miles) Number of habitable structuresl within 300 feet of ROW centerline Number of parcels crossed by alternative route Length of ROW using existing transmission line ROW Length of ROW parallel to existing transmission line ROW Length of ROW parallel to other compatible existing ROW (highways, public roadways, railways, etc. (excluding pipelines) Length of ROW parallel to apparent property lines Percentage of ROW parallel to existing compatible corndors and apparent property boundaries (excluding pipelines) Percentage of ROW using existing transmission line ROW or parallel to existing compatible corridors and apparent property boundaries (excluding pipelines) Length of ROW through parks/recreational areas Number of parks/recreational areas crossed by ROW centerline

Number of additional parks/recreational areas within 1,000 feet of ROW centerline

Length of ROW through cropland

Length of ROW through pasture/rangeland

Length of ROW through land irrigated by tra\,eling systems (rolling or pivot type)

Numberof transmission pipeline crossings

Numberof transmission line crossings Number of US and state highway crossings

Number of farm-to-market road crossings

Number of cemeteries within 1,000 feet ofthe ROW centerline Number of FAA registered airports with at least one runway more than 3,200 feet in length located within 20,000 feet of the ROW centerline Number of FAA registered airports having no runway more than 3,200 feet in length located within 10,000 feet of the ROW centerline

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Table 3-1 Land Use and Environmental Evaluation Criteria LAND USE Numberof private airstrips within 10,000 feet of the ROW centerline

Number of heliports within 5,000 feet of the ROW centerline

Numberof commercial AM radio transmitters within 10,000 feet of the ROW centerline Number of FM radio transmitters, microwave towers, and other electronic installations within 2,000 feet of the ROW centerline Number of recorded water wells within 200 feet of the ROW centerline

Number of recorded oil and gas wells within 200 feet of the ROW centerline AESTHETIC VALUES Estimated length of ROW within the foreground visual zone2 of US and state highways Estimated length of ROW within the foreground visual zone2 of farm-to-market roads Estimated length of ROW within the foreground visual zone2 of parks/recreational areas ENVIRONMENTAL INTEGRITY Length of ROW through upland woodlands Length of ROW through bottomland/riparian woodlands Length of ROW across mapped NWI wetlands Length of ROW across known habitat of federally listed endangered or threatened species Length of ROW across open water (lakes, ponds) Number of stream crossings Length of ROW parallel (within 100 feet) to streams Length of ROW across 100-year floodplains CULTURAL RESOURCES AND HISTORIC VALUES Number of archeological orhistorical sites crossed by ROW Numberof additional archeological or historical sites within 1,000 feet of ROW centerline Number of national register of historic places listed properties crossed by ROW Number of additional national register of historic places listed properties within 1,000 feet of ROW centerline Length of ROW across areas of high archeological site potential 1single-family and multi-family dwellings and related structures, mobile homes, apartment buildings, commercial structures, industrial structures, business structures, churches, hospitals, schools, or other structures normally inhabited by humans or intended to be inhabited by humans on a regular basis. 2one-half mile, unobstructed

3.2 DATA COLLECTION AND CONSTRAINTS MAPPING Once the study area boundary was identified, comprehensive data collection activities were initiated. A list of potentially interested regulatory agencies, elected officials, and organizations was developed to receive a project scoping letter. The purpose of the letter was to inform the various officials and agencies of the proposed projectand to give themthe opportunity to provide information regarding sensitive resources and potential issues within the study area. Various

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Federal, state, and local agencies andofficials contacted forthe Greenbelt-Cattail-Cherokee 138 kV Transmission Line Project include:

• Federal Aviation Administration Southwest-Regional Office • Federal Emergency Management Agency-Region VI Office • Natural Resources Conservation Service-State Office • United States Army Corps of Engineers-Galveston District • Department of Defense Siting Clearinghouse • Environmental Protection Agency-Region 6 Office • United States Fish and Wildlife Service-Region 6 Office • Texas Commission on Environmental Quality-Region 12 Office • Texas Department of Transportation-Houston District • Texas Department of Transportation-Division of Aviation • Texas Department of Transportation-Environmental Affairs Division • Texas Department of Transportation-Transportation Planning and Programming Division • Texas General Land Office • Texas Historical Commission • Texas Parks and Wildlife Department • Texas Parks and Wildlife Department- Wildlife Division • Railroad Commission of Texas • Texas Water Development Board • Houston-Galveston Area Council • Galveston County • City of Texas City • Texas City Independent School District

Available data were mapped to identify existing conditions and to determine potential conflicts that would result from the construction of the proposed 138 kV transmission line. Resource data

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3.3 RESOURCE ANALYSIS The composite constraints map was used as a foundation forthe resource analysis. Criteria Mere developed foreach resourceto establishconstraint parameters, which facilitated the identificatbn of preliminary transmission line links. The following definitions were considered:

• Resource Value: A measure of rarity, intrinsic worth, singularity, or diversity of a resource within a particular area. • Protective Status: A measure of the formal concern as expressed by legal protection or special status designation. • Presentand Known Future Uses: A measure of the level of potential conflict with land management and land use policies. • Hazards: A measure of the degreeto which construction andoperation of the transmission line could be affected by a known resource hazard.

Using this framework, overlays of individual resources were mapped to provide a visual representation of constraint areas, and potential routing opportunity areas were identified. Where feasible, identified constraintswere avoidedtotheextentpracticableto minimize potentialimpacts or conflicts.

3.4 OPPORTUNITIES AND CONSTRAINTS ANALYSIS In order to identify preliminary transmission line links, information gathered during the data collection task, review of agency comments and management plans, and internal review and discussions with the project team were used to determine routing opportunities and constraints within the study area. Routing opportunities were generally located within open, undeveloped areas, or parallel to existing linear corridors. For example, transmission lines, distribution lines, roadways, and property boundaries provide routing opportunities.

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3.4.1 Existing Linear Corridors Within the areas of opportunity, HDR identified existing linear corridor features as potential paralleling opportunities in accordance with the provisions of PUC Substantive Rule 25.101. Apparent property boundaries, roadways, and existing transmission lines were evaluated for potential paralleling opportunities. Data sources used to identify existing linear ROWs include aerial imagery, USGS topographical maps, additional available planning documents, and reconnaissance surveys.

3.4.2 Apparent Property Boundaries Apparent property boundaries and potential paralleling opportunities were identified using Galveston County Appraisal District maps and aerial photography.

3.4.3 Roadway ROWs HDR evaluated paralleling local roads and FMs.

3.4.4 Existing Transmission Line ROWs HDR evaluated utilizing existing TNMP transmission line corridors.

3.5 ALTERNATIVE TRANSMISSION LINE ROUTE IDENTIFICATION TNMP provided the locations of the Greenbelt, Cattail, and Cherokee Substation Sites. The preliminary transmission line links were subsequently developed between these three locations.

3.5.1 Preliminary Transmission Line Links Preliminary transmission line links were identified on an overlay of the composite environmental and land use constraints map. These links were developed based upon maximizing the use of routing opportunity areas while avoiding areas of high environmental constraints or conflicting land uses. Aerial photography was used as the background of the composite constraints overlay to identify optimal locations for the preliminary transmission line link centerlines. During the preliminarytransmission line Iinkdevelopmentprocess, the Iocationof residentialareas, habitat)Ie structures, industrial facilities, pipelines, surface water crossings, cultural resources, propery boundaries, agricultural land, and other sensitive resource areas were considered. HDR utilized the following to identify the preliminary transmission line links:

• Input received from scoping activities with local officials, regulatory agencies, and others.

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