10 July, 2014

Southline Transmission Line Project Attn: Ms. Frances Martinez, Realty Specialist

Bureau of Land Management Main Office 300 E. University Blvd., #120 Las Cruces District Office Tucson AZ 85705 TEL 520.629.0510 1800 Marquess Street FAX 520.623.3476

Las Cruces, NM 88005-3371 Dr Paul Green Executive Director 520.209.1801 [email protected] Re: Comments on Southline Transmission Draft Environmental Impact Statement

Dear Ms. Martinez:

Tucson Audubon appreciates the opportunity to provide comments on the Draft Environmental Impact Statement (DEIS) for the proposed Southline Transmission Line Project (Southline).

Tucson Audubon is a 501(c)(3) non-profit NGO established in 1949 and representing approximately 5000 households scattered throughout the southeastern Arizona region, primarily in Pima County. Tucson Audubon’s mission is to protect and promote the stewardship of the biodiversity of southeast Arizona by connecting people to their natural world through the study and enjoyment of birds. Tucson Audubon has partnerships with private and governmental entities and works to conserve and protect habitats where wildlife is at risk to the many factors that threaten its existence — including climate change and the degradation and fragmentation of watersheds and habitat caused by development. http://www.tucsonaudubon.org/

Tucson Audubon submits comments on behalf of its membership based on the potential adverse impacts to birds and other wildlife of the proposed construction and operation of the Southline Transmission Line. Our comments relate to the local, regional and hemispheric adverse impacts (direct, indirect, and cumulative) on special status species and unique and rare habitats, migratory species, resilience in the face of climate change, the

Printed on Recycled Paper sustainable health and economy of our region, and our quality of life. Specifically, we believe it is critical to set a direction for the region that focuses on the best available scientific and commercial information.

We support responsible development of renewable energy and efforts to increase energy efficiency, energy conservation, demand-side management and distributed generation. We support taking old and polluting coal plants offline, decreasing our dependence on oil from overseas, and creating new green jobs in the United States. We understand the need to distribute electricity generated through the development of sustainable sources to address the threats posed by climate change. A priority should be placed on better utilizing the existing grid through regional coordination and re-use of existing transmission lines as older fossil-fuel power plants are retired. New transmission development should be focused on upgrading existing infrastructure and co-locating with existing infrastructure wherever possible to facilitate renewable energy development and meet greenhouse gas reduction goals. However, we insist that our transition to a clean energy future does not come at the expense of cultural resources, remaining high quality wildlife habitats and pristine wild lands. We can and must ensure that the routing of transmission lines avoids culturally and biologically sensitive areas and minimizes the disturbance of significant natural areas and the corridors that connect them. We applaud the recent designation by the BLM of multiple areas in the west appropriate for the streamlining of development of industrial solar energy resources which were selected with extensive public and agency input to avoid potential conflicts with significant biologic, cultural, and historic resources. Nonetheless, some areas are inappropriate for development of any kind. We strongly advocate for utilization of the full mitigation hierarchy: avoidance, minimization, and compensatory off-site mitigation (in that order).

Tucson Audubon offers the following comments on the Southline Transmission Line proposal for your consideration. Unlike the SunZia proposal, Southline’s public process has been engaging, responsive, open and transparent. Southline appears economically feasible, would provide numerous opportunities to improve southern Arizona’s grid capacity and reliability and would, for the most part, follow existent rights-of-way, thus minimizing some but not all potential adverse impacts. We generally support the facilitated permitting and development of Southline as opposed to the SunZia proposal, however Southline is not without its own issues of concern.

All of the potential Southline routes would have significant impacts to numerous important resources and values along the 355-plus mile route and therefore, if Southline is approved, it is critical that Southline follows a route that has the lowest impacts and that the Final

www.tucsonaudubon.org | page 2 Environmental Impact Statement (FEIS) and Record of Decision (ROD) include a robust on and off-site written mitigation program detailing the mitigation obligations of the Bureau of Land Management (BLM), the Western Area Power Administration (Western), and the project proponent, Southline, LLC..

At this time we cannot support any specific routes. We continue to strongly advocate for the following: (1) obtaining segment-specific information on impacts, (2) the completion of inventories for Lands with Wilderness Characteristics (LWC) and the opportunity for public comment on the results prior to publication of the FEIS, (3) careful siting to avoid cultural resources, local boundaries of LWC, other wilderness-quality lands and sensitive wildlife habitats, and other avoidance and minimization measures, (4) written commitments to meaningful on and off-site mitigation in the FEIS and ROD, and (5) more details on the purpose and need for this project. Based on the information in the DEIS, it appears that Southline may provide some benefits to renewable energy development, but additional documentation is absolutely necessary. We would note that we find no documentation or discussion reflecting the decision-making process or justification for the particular segments or sub-routes proposed, which need to be fully addressed prior to a FEIS and ROD. The manner in which data is presented in the DEIS, mostly by entire Alternative routes rather than segments, has made evaluation and comparisons challenging. Developing and providing this information for all segments, which could be accomplished through GIS analyses of data already compiled for the DEIS, would allow for better analysis of Alternative route segments and help in the selection of a route with the least amount of resource impacts while identifying appropriate mitigation opportunities. After such an analysis, the lowest-impact route should be advanced as the preferred alternative in the FEIS. The agencies should address impacts by applying the full mitigation hierarchy including avoidance, minimization and compensatory, on and off-site mitigation.

As evidenced by the current SunZia proposal, there is potential for other transmission and energy development in the region. BLM must recognize the connected and cumulative effects that these projects have upon one another and include that analysis in the Final EISs of these plans. This information is critical to development of an appropriate suite of mitigation efforts.

The Final EIS should include a detailed discussion of the potential direct and indirect impacts of construction, operation, and maintenance of this project (including estimated quantification by route) specifically addressing:

www.tucsonaudubon.org | page 3 Direct loss (i.e. due to collision with motor vehicles during construction, electrocution, collision with power lines and guy wires, etc.)

Habitat loss Habitat degradation (erosion, invasive species, etc.) and fragmentation (roads and ROWs, etc.) Displacement of individuals Population loss and reduced breeding success Exposure to noise and human activity Increased predation risk (i.e. creation of raptor perches and/or of mammalian predator travel lands, increased nest parasitism, increased perching opportunities for avian predators on sensitive species, etc.)

Project proponents must be committed to, and budgeted for, the entire suite of mitigation efforts. These efforts must include all the steps in the mitigation hierarchy including avoiding impacts wherever possible, minimizing unavoidable impacts through the use of best management practices on-site, and off-setting remaining impacts through off-site, compensatory mitigation. The FEIS must include a mitigation program that fully addresses impacts to cultural resources, wildlife, wildlife habitat, and all other resources, functions and values.

BLM should follow Secretary Jewell’s October 2013 Secretarial Order 3330 (Improving Mitigation Policies and Practices of the Department of the Interior) and the recent report from DOI’s Energy and Climate Change Tucson Audubon k Force (A Strategy for Improving the Mitigation Policies and Practices of the Department of the Interior) and employ landscape-level mitigation to mitigate the detrimental effects the transmission line undoubtedly will have. Such landscape-level mitigation and all compensatory mitigation should be durable and identified, in a consistent and transparent process, prior to project approval. A landscape level assessment should be done using new and existing data including the Sonoran Rapid Ecoregional Assessment, Arizona and New Mexico’s State Wildlife Action Plans and associated Crucial Habitat Assessment Tools (Arizona’s is known as HabiMap), the Arizona Wildlife Linkages Assessment, Pima County’s Sonoran Desert Conservation Plan (SDCP) Conservation Lands System (CLS) and compensatory mitigation guidelines by category, Pima County’s Wildlife Connectivity Assessment http://www.azgfd.gov/w_c/conn_Pima.shtml and subsequent reports, critical habitat, Important Bird Area (IBA) designations and migratory bird flyways, and numerous other data sets herein incorporated.

www.tucsonaudubon.org | page 4 To enhance the durability of its mitigation and conservation decisions, BLM must expand its current approach to include other tools in addition to land use planning, including Rights of Way for Conservation, which could be issued to a state wildlife agency, FWS, or other appropriate entity; withdrawals of incompatible uses and retention of lands or withdrawals of incompatible uses and transfer of management authority to FWS or other appropriate entity; conservation easements; and cooperative agreements. Protection and management of public lands utilized for mitigation must be effective for at least as long as the impacts. Private lands may be purchased or protected, either by maintaining private ownership or by being transferred to federal or other appropriate management, with a suitable designation for durable and protective conservation management.

Any compensatory mitigation must be additional to agencies’ existing conservation obligations, and should focus on actions that demonstrably improve habitat, improve species’ populations, or reduce threats to wildlife or other resources and be guided by BLM’s own published Draft Regional Mitigation Manual and the recent Presidential Memorandum on improving siting, permitting and mitigation for transmission development.

Unfortunately, the DEIS is wholly inadequate in terms of off-site mitigation and should analyze, recommend, and commit in writing to specific measures that will be taken. It is unacceptable to wait until after the ROD is signed to identify and require specific off-site mitigation measures, especially when: Southline is a major electrical right-of-way project, one of the types of large development projects for which offsite mitigation (at the scale necessary) is appropriate; Southline is likely to affect resources, functions and values of high public importance; and Southline will most likely have permanent impacts that cannot be mitigated onsite.

Recommendation: The Agencies should demonstrate how the approaches used are consistent with the BLM Draft Regional Mitigation Manual, Secretarial Order No. 3330, the report from DOI’s Energy and Climate Change Tucson Audubon k Force (A Strategy for Improving the Mitigation Policies and Practices of the Department of the Interior), and the recent Presidential Memorandum on Transmission Siting, Permitting and Mitigation.

Conservation and Multiple Uses

The southwest is now the fastest growing area in the United States. In order to maintain ecosystem resilience upon which human health depends we must seek a balance between uses that will enable certain lands to be preserved in perpetuity. These priority lands must be identified using robust scientific methodology.

www.tucsonaudubon.org | page 5 The following segment regarding Pima County’s Sonoran Desert Conservation Plan (SDCP) was written in conjunction with the Coalition for Sonoran Desert Protection (CSDP). In 1998, Tucson Audubon was a founding member of the CSDP, which works to create a community where ecosystem health is protected, nature and healthy wild animal populations have value, and visitors, children and future generations can all drink clean water, breathe clean air, and find wild places to roam. The CSDP is committed to working toward science-based land use planning, focusing on Pima County’s national award winning conservation planning effort and its efforts to obtain an Incidental Take Permit (ITP) in association with the implementation of its draft Multi-Species Habitat Conservation Plan (MSHCP).

The county’s SDCP seeks to conserve the most ecologically valuable lands and resources across the region, while guiding growth into more appropriate areas. The SDCP addresses several elements of resource conservation, including cultural preservation, open space conservation, protection of parks and natural reserves, ranch conservation, and ecological conservation http://www.pima.gov/cmo/sdcp/maps.html. For example, the San Pedro River is identified as a “Priority Habitat and Corridor”, a “Proposed Nature Preserve”, an area of ranch preservation, cultural and environmental significance, and an “Important Riparian Area” (IRA). Both Davidson Canyon Creek and Cienega Creek are identified as IRAs and formally designated Outstanding Arizona Waters (OAWs). There are only 22 OAWs in the entire state of Arizona and the designation includes a “no degradation” standard. The Davidson Creek and Cienega Creek watershed provides one fifth of the groundwater recharge for the Tucson basin. http://www.pima.gov/cmo/sdcp/habitat.html.

The biological goal of the SDCP is “to ensure the long-term survival of the full spectrum of plants and animals that are indigenous to Pima County through maintaining or improving the ecosystem structures and functions necessary for their survival.” Objectives include:

“promote recovery of federally listed and candidate species to the point where their continued existence is no longer at risk; where feasible and appropriate, re-introduce and recover species that have been extirpated from this region; maintain or improve the status of unlisted species whose existence in Pima County is vulnerable; identify biological threats to the region’s biodiversity posed by exotic and native species of plants and animals, and develop strategies to reduce these threats and avoid additional invasive exotics in the future; identify compromises to ecosystem functions within target plant communities selected for their biological significance and develop strategies to mitigate them; and promote long-term viability for species, environments and biotic

www.tucsonaudubon.org | page 6 communities that have special significance to people in this region because of their aesthetic or cultural values, regional uniqueness, or economic significance.”

Conservation strategies entail:

“Focus future growth and associated infrastructure expansion in areas in closest proximity to existing urbanized areas, not in areas of highest biological richness. Significantly lower intensity of future land uses allowed in certain biologically sensitive areas near major washes, within ecologically rich habitats, adjacent to Saguaro National Park, and other sensitive areas of Pima County. Avoid or minimize future losses and fragmentation by a publicly supported land acquisition and conservation program. Open Space Acquisition funds and other private/public partnerships enable the acquisition of lands or conservation easements adjacent to the existing reserve system as well as ranches conserved through acquisition of development rights or conservation easements, thereby implementing the Ranch Conservation and Mountain Park Expansion Elements of the SDCP. Prioritize 26 percent of the CLS {Conservation Lands System} for conservation by the adoption of Habitat Protection Priorities in Eastern Pima County. This includes approximately 525,000 acres of biological core, important riparian areas, threatened and endangered species management areas, and special landscape elements. Pima County will continue to nominate and pursue acquisition of biologically sensitive lands for reclassification by the Arizona State Land Department under the Arizona Preserve Initiative, or through state land constitutional reform. Conserving important biological resources has become a very important part of future land use decisions.”

The Conservation Lands System (CLS) is a part of the Environmental Element of Pima County’s Comprehensive Land Use Plan’s Regional Plan Policies, in compliance with Arizona law and Growing Smarter legislation, and provides one mechanism in the tool box to implement the county’s draft ITP and MSHCP. The DEIS fails to adequately evaluate Southline’s impacts and appropriate mitigation measures to important elements of this national award winning, regional conservation planning effort. We strongly disagree with the assertion that the Southline Transmission Line would not cause any impacts to Pima County’s Conservation Lands System because these areas already contain utilities. In the arid Sonoran Desert, “direct ground disturbance” can cause irreparable harm to Sonoran Desert cryptogrammic crust, flora and fauna. It can take decades for vegetation to re-establish itself if active restoration isn’t completed. An increase in “ambient noise levels” can also negatively impact local wildlife and

www.tucsonaudubon.org | page 7 their ability to forage, rest, and mate in their habitat, especially for smaller wildlife species with relatively small home ranges. The DEIS should be revised to include adequate mitigation for all impacts to Pima County’s CLS lands and CLS mitigation policies should be adhered to in full.

Important Riparian Areas (IRA) constitute the most biologically sensitive of CLS lands. They are “critical elements of the Sonoran Desert where biological diversity is at its highest... [They] are valued for their higher water availability, vegetation density, and biological productivity. They are also the backbone to preserving landscape connectivity.” http://www.pimaxpress.com/Documents/planning/ComprehensivePlan/PDF/Policies_Legend/Re gional%20Plan%20Policies%20%28pp.%2019-65%29.pdf. Pima County guidelines recommend a landscape conservation objective of 95% undisturbed natural open space for Important Riparian Areas.

Biological Core Management Areas are “those areas that have high biological values. They support large populations of priority vulnerable species, connect large blocks of contiguous habitat and biological reserves, and support high value potential for five or more priority vulnerable wildlife species.” Pima County guidelines recommend a landscape conservation objective of 80% undisturbed natural open space for Biological Core Management Areas.

Multiple Use Management Areas are “those areas where biological value are significant…[and] support populations of vulnerable species, connect large blocks of contiguous habitat and biological reserves, and support high value potential habitat for three or more priority vulnerable species.” Pima County guidelines recommend a landscape conservation objective of 66-2/3% undisturbed natural open space for Multiple Use Management Areas.

Special Species Management Areas (SSMA) are “areas defined as crucial for the conservation of specific native floral and faunal species of special concern to Pima County. Currently, three species are designated as Special Species: Cactus Ferruginous Pygmy-owl, Mexican Spotted Owl, and Southwestern Willow Flycatcher.” This designation is an overlay on top of the other CLS land designations. Pima County guidelines recommend at least 80 percent of the total acreage of lands within this designation shall be conserved as undisturbed natural open space and will provide for the conservation, restoration, or enhancement of habitat for the affected Special Species. As such, land use changes will result in 4:1 land conservation (i.e., four acres conserved for every one acre developed) and may occur through a combination of on- and off- site conservation inside the Special Species Management Area. The 4:1 mitigation ratio will be calculated according to the extent of impacts to the total surface area of that portion of any parcel designated as Special Species Management Area.”

www.tucsonaudubon.org | page 8 Finally, Critical Landscape Connections are another important component of the CLS. They are “broadly defined areas that provide connectivity for movement of native biological resources but which also contain potential or existing barriers that tend to isolate major conservation areas.” Significant local resources, including millions of dollars of open space purchases and infrastructure investments, have been spent on protecting Sonoran Desert wildlife linkages in recent years. The DEIS falls short in not requiring any significant mitigation for these impacts. Two of the Critical Landscape Connections are “across the I-10/Santa Cruz River corridors in the northwest” and “across the I-10 corridor along Cienega Creek in the east”, two areas traversed by the proposed Southline transmission line route.

The Interstate 10/Santa Cruz River Critical Landscape Connection is near the north end of the Tucson Mountains, a nominated Important Bird Area, in the vicinity of the Los Morteros Conservation Area, a 121 acre portion of an ancient Hohokam Ballcourt community complex comprised of 770 prehistoric cultural features, including 349 structures. The 1775-1776 expedition of Juan Bautista de Anza made a major encampment, called the Llano del Azotado campsite, along the Santa Cruz River in the area north of today’s Coachline Boulevard. This area is part of the Juan Bautista de Anza National Historic Trail, which Pima County, in conjunction with the National Park Service, is developing for public use. In the nineteenth century, the historic Point of the Mountains stagecoach station was established in this location, near present day Oasis Street and Coachline Boulevard.

The Davidson and Cienega Creeks form a Critical Landscape Connection between the Santa Rita Mountains Important Bird Area and the nominated IBA comprised of the Rincon Mountains and Saguaro National Park East, including the Saguaro and Rincon Wilderness Areas and the Cienega Creek Preserve. This modeled linkage also connects with the BLM’s Las Cienegas National Conservation Area. The Southline project would bisect multiple fee simple parcels purchased with Pima County voter-approved Open Space Bonds and their associated State land grazing leases, managed by the county for conservation, such as the Bar V Ranch.

Without further evaluation of the CLS and other components of the SDCP such as Pima County’s proposed MSHCP and ITP, the DEIS does not satisfy the federal mandate that a DEIS “shall include discussions of possible conflicts between the proposed action and the objectives of Federal, regional, State, and local (and in the case of a reservation, Indian tribe) land use plans, policies and controls for the area concerned.” 40 C.F.R. § 1502.16(c). Furthermore, the DEIS does not align with 40 C.F.R. § 1506.2(d) which states that, “To better integrate environmental impact statements into State or local planning processes, statements shall

www.tucsonaudubon.org | page 9

www.tucsonaudubon.org | page 10 discuss any inconsistency of a proposed action with any approved State or local plan and laws (whether or not federally sanctioned). Where an inconsistency exists, the statement should describe the extent to which the agency would reconcile its proposed action with the plan or law.”

Another aspect of the SDCP is cultural preservation. Tumamoc Hill (O'odham: Cemamagĭ Doʼag): Tumamoc is the O'odham word for "regal horned lizard" and the butte was a home to the ancient Hohokam people. It is the site of the earliest known trincheras village, consisting of 160 foundations of round stone structures, as well as large stone perimeter walls. Over 460 petroglyphs and a prehistoric garden beside the hill provide further evidence of Tumamoc’s importance. After the ancient Hohokam inhabitants moved away about 1,300 years ago, the site continued to provide resources to the Tohono O'odham, Akimel O'odham, and the Hopi. The Desert Laboratory was founded in 1903 and long term ecological monitoring began in 1906. Nine of the original plant observation areas are now the world's oldest permanent ecology study quadrats. Much of the framework of plant ecology generally, and desert ecology in particular, was formulated here. The Desert Laboratory was designated a National Historic Landmark by the Secretary of the Interior. Tumamoc is a nominated Important Bird Area, a National Environmental Study Site, an Arizona State Scientific and Natural Educational Area, and an Archaeological District on the National Register of Historic Places. We note that the DEIS does not adequately address Section 106 required surveys, documentation and mitigation of impacts to archaeologic, historic and other cultural resources such as those foreseeable at Tumamoc Hill or Los Morteros.

www.tucsonaudubon.org | page 11

Pima County has sought to find a balance between development and conservation where priority conservation and preservation lands are identified and conserved using robust scientific

www.tucsonaudubon.org | page 12 methodology. There is certainly precedence for this approach. Not all public lands have a “multiple use ethic.” Some are established in order to protect specific values, including natural hydro-geologic processes and wildlife. Wilderness areas, wildlife refuges, national parks, and national monuments are just a few of those areas, which have a more protective higher mandate than “multiple use.”

The Arizona Game & Fish Department’s (AZGFD) Strategic Plan for the Years 2007–2012, Wildlife 2012, states that the goals of its wildlife program are “to conserve and preserve wildlife populations and habitat; to provide compatible public uses, while avoiding adverse impacts to populations and habitat; to promote public health and safety; and to increase public awareness and understanding of wildlife resources.”

The National Park Service mission is to “preserve unimpaired the natural and cultural resources and values of the national park system for the enjoyment, education, and inspiration of this and future generations.” Portions of Saguaro National Park East, including the Saguaro Wilderness, the Coronado Forest and Rincon Wilderness Area, and Saguaro National Park West will be visually impacted by the proposed power line.

The mission of the BLM’s National Landscape Conservation System, which includes the Ironwood Forest National Monument and the Las Cienegas National Conservation Area (NCA), is “to conserve, protect, and restore these nationally significant landscapes that have outstanding cultural, ecological, and scientific values for the benefit of current and future generations.” Again, the protection of these attributes is prioritized over other activities.

The entire region enjoys the various diverse habitats within the Coronado National Forest’s multiple units, much of which is designated multiple use. Yet even the very definition of “multiple use” in the Multiple-Use Sustained Yield Act of 1960 recognizes “that some land will be used for less than all of the resources; and harmonious and coordinated management of the various resources, each with the other, without impairment of the productivity of the land, with consideration being given to the relative values of the various resources, and not necessarily the combination of uses that will give the greatest dollar return or the greatest unit output.”

The National Wildlife Refuge System Administration Act of 1966 mandates the standard of compatibility, i.e.: uses of refuge lands must be determined to be compatible with the purposes for which individual refuges were established. This standard was later clarified in the National Wildlife Refuge System Improvement Act of 1997: Conservation is the priority, then various compatible uses.

www.tucsonaudubon.org | page 13 Identified compensatory mitigation actions on public lands must be durable, meaning protection and management of public lands must be effective for at least as long as the impacts may persist. Recommended compensatory mitigation measures include:

• Protection of public lands through designation for conservation management, such as Areas of Critical Environmental Concern (ACECs) or management to protect Lands with Wilderness Characteristics (LWCs) with management plans for these areas that include comprehensive and measurable protections for the resources in question; • Purchase and protection of private lands, either maintained in private ownership or transferred to federal ownership, with a suitable designation for durable and protective conservation management; • Restoration activities, such as soil stabilization, fence removal or restoration of closed roads.

Recommendation: Agencies should use compensatory mitigation measures to off-set unavoidable impacts. Avoid, to the greatest extent practicable, and then minimize any impacts to OAWs, IBAs, ACECs, LWCs, RNCAs, NCAs, National Park Units, Pima County regulated riparian habitat and IRAs, Bio-core, SSMAs, or other SDCP designated areas, Wildlife Linkages and movement corridors, avian migratory pathways, Tucson Mountain Park, Tumamcoc Hill, and Los Morteros. Where impacts are absolutely unavoidable, project proponents must minimize and mitigate to the fullest extent.

Economic Impact Analysis

The DEIS has used a deficient economic analysis that examines only one side of the economic equation — the economic benefits of the proposed transmission line — while ignoring the negative economic impacts to other sectors. An in depth Economic Impact Analysis needs to be done using the best available scientific and commercial information.

IBAs such as the Upper and Lower San Pedro River and the Willcox Playa, the Sulphur Springs Valley and associated environs, Outstanding Arizona Waters such as Davidson and Cienega Creeks, Ironwood Forest National Monument, Saguaro National Park East and West, Tucson Mountain Park, Los Morteros and Tumamoc Hill, all represent well-known ecotourism hot-spots in the region. Home owners near parks and protected areas are repeatedly seen to have property values more than 20% higher than similar properties elsewhere.

www.tucsonaudubon.org | page 14 Birders in particular come from all over the world to bird these unique and special places. One such example is the annual Wings Over Willcox Birding and Nature Festival. If this ecotourism were reduced because of direct, indirect and cumulative impacts of the transmission line, this would directly, indirectly and cumulatively adversely impact the various communities, from San Simon to Willcox to Benson to Tucson and on to Red Rock, that benefit so much from ecotourism. Ecotourism is especially important for dispersed rural communities.

In short, the DEIS fails to adequately analyze the economic role of public lands, river valleys, playas and open spaces in supporting local economic health and it ignores existing research documenting the economic importance of protected public land resources. Income from tourism is a sustainable source of income, but requires that the resource is managed and protected. The proposed Southline transmission line has the potential to forever damage the sustainable economic engine and regional natural resources in the Willcox Playa area and could adversely impact other areas essential to local economies as well. The BLM should evaluate whether transmission lines in the view space and/or deaths of cranes caused by the lines would have a negative economic impact on the town or surrounding county. The DEIS does not adequately assess nor mitigate for these impacts.

Our natural resources provide food and shelter, flood control, water filtration, clean air, fish and wildlife habitat, recreational opportunities, aesthetic benefits, jobs, and a higher quality of life for all. Science has demonstrated the importance of these natural resources to our daily lives. The adverse impacts of climate change may stress some natural resources and systems to the point that they may struggle to adapt and provide ecosystem services. It is necessary to maintain and improve the overall health of our natural resources in order to maintain them for the health, welfare, and enjoyment of present and future generations.

Recommendation: The Final EIS should analyze economic impacts of disturbing crane and waterfowl populations at Willcox Playa, specifically possible financial losses to communities that could be caused by mortality to cranes and other migratory birds.

Watchable Wildlife Economics

One of the AZGFD’s recreation strategies is to “Identify, assess, develop and promote watchable wildlife recreational opportunities.” Audubon members enjoy birding, hiking, wildlife viewing, and photography and think it is critically important to protect wildlife habitat and ensure sustainable populations of the full spectrum of native wildlife species.

www.tucsonaudubon.org | page 15 You might be surprised to learn that birding leads ALL other recreational activities in promoting the economic growth of ecotourism in Arizona.

In a 2006 study, the Outdoor Industry Foundation reported that all outdoor wildlife-related recreational activities generated $730 billion annually for the United States economy, and of that, watchable wildlife generated $43 billion annually. They reported 66 million Americans participated in wildlife viewing, which supported 466,000 jobs. Estimated economic returns included retail sales averaging $8.8 billion, trip related expenditures of $8.5 billion, and state and federal tax receipts of $2.7 billion. The report is available at http://www.outdoorindustryfoundation.org./. Although much of this economic impact is due to outdoor recreation, other visitors may come to these areas for sight-seeing, for family gatherings, for educational benefits and for many other values not captured by the category of outdoor recreation.

Outdoor recreation, natural resources conservation and historic preservation in the United States all have measurable economic impacts. According to a 2011 study by the National Fish & Wildlife Foundation, http://www.nfwf.org/Content/ContentFolders/NationalFishandWildlifeFoundation/HomePage/Con servationSpotlights/TheEconomicValueofOutdoorRecreation.pdf a minimum estimate of the combined value of outdoor recreation, nature conservation and historic preservation shows that over 9.4 million jobs were created while $107 billion was generated by local, state and federal tax revenues resulting in a minimum total economic impact nationally of $1.6 trillion! Outdoor recreation sales (gear and trips combined) of $325 billion per year are greater than annual returns from pharmaceutical and medicine manufacturing ($162 billion), legal services ($253 billion), and power generation and supply ($283 billion).

The U.S. Fish & Wildlife Service contributed about $4.2 billion in economic activity and supported over 32,000 jobs through their management of 553 National Wildlife Refuges and thousands of smaller natural areas in the United States. One detailed study of visitation to National Wildlife Refuges (Caudill and Henderson, 2005) looked further into the impacts on the local communities around these reserves in 2004. In 2004, there were 36.7 million visitors who generated $1.64 billion of economic activity in regional economies. Caudill and Henderson went further into their analysis and showed that about two-thirds of the total expenditures were generated by non-consumptive activities and not fishing (27%) or hunting (5%), which illustrates the value these natural areas have for passive enjoyment of nature. The authors also conducted willingness-to-pay studies to determine the value of these refuges beyond what it actually cost

www.tucsonaudubon.org | page 16 them to visit. They found that visitors showed a consumer surplus of more than $1.3 billion, with $816 million of this amount attributed to non-consumptive visitation.

In Arizona, overall, 1.6 million people participated in some form of residential or non-residential watchable wildlife recreation in 2011. Total trip and equipment expenditures were calculated to be $848,690,708 and watchable wildlife recreation supported approximately 12,900 full and part-time jobs with salaries and wages estimated at $463.6 million.

Original expenditures made by watchable wildlife recreationists generate rounds of additional spending throughout the economy. This results in additional indirect and induced impacts that are commonly called the multiplier effect. Economic activity associated with both the direct spending and multiplier effects impacts is the total economic contribution resulting from the original expenditures. The total economic effect from 2011 watchable wildlife activities in Arizona was estimated at $1.4 billion.

2011 Economic Contributions of All Watchable Wildlife Recreation in Arizona, by County:

Cochise County - Retail Sales $14,190,743; Total Multiplier Effect $24,130,389; Salaries and Wages $7,651,115; Full & Part-Time Jobs 234; State & Local Tax Revenue $1,570,931; Federal Tax Revenue $1,769,276.

Graham County - Retail Sales $7,283,288; Total Multiplier Effect $12,292,101; Salaries and Wages $3,977,764; Full & Part-Time Jobs 105; State & Local Tax Revenue $806,268; Federal Tax Revenue $908,067.

Pima County - Retail Sales $179,459,718; Total Multiplier Effect $304,368,133; Salaries and Wages $97,947,943; Full & Part-Time Jobs 2736; State & Local Tax Revenue $19,866,395; Federal Tax Revenue $22,374,716.

Pinal County - Retail Sales $52,631,795; Total Multiplier Effect $89,450,156; Salaries and Wages $28,733,395; Full & Part-Time Jobs 812; State & Local Tax Revenue $5,826,399; Federal Tax Revenue $6,562,038. http://www.tucsonaudubon.org/images/stories/News/TUCSON AUDUBON-AZ-WildlifeWatching- Analysis-2011-130718.pdf

The annual Wings Over Willcox Birding and Nature Festival (WOW) alone has infused the local economy with about $2 million over the last 20 years, according to a study conducted by Dr. Gyan Nyaupane, an associate professor and graduate program director with ASU’s School of Community Resources and Development. He and local organizers are researching better ways

www.tucsonaudubon.org | page 17 to capture the economic impacts of walk-ins and others who do not register for the Festival https://scrd.asu.edu/news/2-million-infused-in-local-economy-in-20-years-of-wings-over-willcox.

Recommendation: Conduct economic studies to determine the value of and potential adverse impacts to the watchable wildlife and ecotourism activities along the proposed route and determine how best to enhance them or appropriately fully mitigate for them.

Ecosystem Services and Economics

The term “Ecological values” refers to clean air, clean and abundant water, fish and wildlife habitat and other values that are generally considered public goods. “Ecosystem services” include all the functions and natural processes performed by nature that would otherwise have to be paid for by people through the construction of facilities. These services include climate regulation, waste treatment, water supply, carbon sequestration, insect-borne disease vector control, nutrient cycling, habitat provision and many others that all help modulate and regulate climate, weather and various resources needed for human comfort, security and quality of life. Wetlands, forests, grasslands, river systems, and lakes all provide environmental services.

For example, the total value of ecosystem services provided by the acreage of natural habitats in National Wildlife Refuges in the United States totaled $32.3 billion/year, or $2,900 thousand/acre/year (Ingraham and Foster, 2008). In fact, the total amount of ecosystem services provided by these categories of natural land amount to about $1.6 trillion, which is more than 10% of the GDP in 2009 when land in the contiguous United States is tallied.

Consider birds, which contribute irreplaceable ecosystem services: according to the American Bird Conservancy’s 2007 report, “Birds play an important role in maintaining the ecosystems on which humans depend to maintain our quality of life and civilization. For example, birds eat billions of insects each year that left unchecked could decimate our crops. Birds also play an important role as pollinators, providing a fundamental service to agricultural production that simply cannot be replaced by other means. According to the Smithsonian Migratory Bird Center, birds eat up to 98% of budworms and up to 40% of all non-outbreak insect species in eastern forests. The value of this insect control has been estimated to be as much as $5,000 per year per square mile of forest.”

“Birds are also superb “canaries in the coal mine”, or indicators of environmental health and change. Rapid declines in bird numbers have alerted us to the harm being caused to humans and the environment by toxic chemicals. And birds, by virtue of their insect control services, can help prevent the spread of insect-borne diseases such as malaria and dengue fever, both

www.tucsonaudubon.org | page 18 formerly prevalent in the wetlands of the arid southwest. The knowledge we gain from birds directly affects our quality of life and our understanding of how economic development can be made more environmentally sustainable.” http://www.abcbirds.org/habitatreport.pdf

Maintaining sustainable rural and urban landscapes is important for the public health, safety, and quality of life of all Arizonans and New Mexicans. The results from the 2012 Colorado College State of the Rockies Conservation in the West poll find that Arizona and New Mexico voters across the political spectrum — from Tea Party supporters to those who identify with the Occupy Wall Street movement and voters in-between — support upholding and strengthening protections for clean air, clean water, natural areas and wildlife. Voters also view Arizona’s and New Mexico’s parks and public lands as essential to their state’s economy and quality of life. http://www2.coloradocollege.edu/stateoftherockies/conservationinthewestsurvey_media_covera g e.html

Sustainable forestry, agriculture and ranching practices can help to maintain and restore the vitality of our communities while also helping to preserve our culture, natural landscapes and ecosystems. It only makes common sense that it should be our general policy to support the maintenance, enhancement and restoration of ecosystem values and services throughout the state, focusing on the protection of land, water, air, soil and native flora and fauna upon which our human health and safety depend. The DEIS fails to adequately analyze or address these concerns.

Habitat Fragmentation and Connectivity

Un-fragmented landscapes are key indicators developed by biologists in assessing the conservation value of regions and sites and the imminence of the threats they face (Baker, 2010). Large blocks of habitat have the potential to sustain viable species populations and they permit a broader range of species and ecosystem dynamics to persist. The Southline DEIS does not adequately assess potential impacts caused by habitat fragmentation or impacts to wildlife linkages and movements as a result of this project.

Harvard’s Richard Forman pioneered studies showing that roadway and infrastructure construction and maintenance fragments habitat and can adversely impact flora and fauna by interruption of wildlife movement and migration, clearing of native vegetation, increased human and vehicular traffic in the area of impact, introduction of invasive species, light and sound impacts, and negative edge effects.

As the DEIS notes, roads cause habitat fragmentation and deaths to wildlife from collisions, and

www.tucsonaudubon.org | page 19 provide access for human activities, including off-road vehicular recreation. Because there will be an access road approximately every mile along the transmission line, this is a matter of concern for all species of plants and animals living in or near the ROW. BLM should require gating and methods to ensure that gates are not evaded, such as adjacent fencing and/or boulder placement, for all access roads, not only those associated with the Tucson shovel- nosed snake. Access roads and gates should be posted prohibiting off-road vehicle use and regular patrols with authority to cite people who have evaded the gates should be provided.

It is well documented that transmission lines cause significant and direct mortality of raptors (Banks 1979, Klem 1979, Churcher and Lawton 1987) (United States Fish & Wildlife Service {USFWS} BO for Las Cienegas 10/4/2002, pg. 72). Also problematic for small birds, herps and mammals is that the transmission line will create a continuous linear swath, which will eventually total hundreds of miles in collective length, where the towers will serve as a giant hunting perch for raptors. Raptors may perch on the towers and pick off anything that flies across or runs out into the open, denuded area. The towers and denuded area together are a potentially lethal combination that will seriously impact both resident and migratory bird species. Eventually raptors will likely habituate to areas along the line where the highest concentrations and/or movements of birds, herps and small mammals occur and exploit the height of the towers and lack of cover, resulting in a higher concentration of raptors nesting close to the line.

There is a strong likelihood that the access and maintenance roads will become travel corridors for illegal immigration, drug smugglers and all-terrain off-road vehicles resulting in significant disturbance to sensitive vegetative communities such as Pima pineapple cacti, old growth ironwood trees and saguaros, wildlife, the spread of exotic invasive species, and habitat fragmentation. The DEIS does not adequately analyze nor address remedies for these issues.

In The State of the Desert Biome, Nabhan and Holdsworth state, “…although once considered a non-consumptive use of the desert relative to mining, grazing and logging, recreation-related damage is now considered the second most pervasive impact upon threatened and endangered species in the Western United States (Rick Knight pers. Comm.) Off-road vehicle damage of vegetation, vandalism and illicit collecting of endangered plants - all incidentally associated with outdoor recreation - are collectively cited more frequently than any other pressures on threatened plants in the U.S./Mexico borderlands (Nabhan et al. 1989). In survey results of public land managers regarding the adverse impacts of recreational use of natural resources, soil erosion was the most frequently cited negative impact, followed by frequency of disturbance of understory vegetation, fuel-wood harvesting, disruption of nesting birds and disturbance of

www.tucsonaudubon.org | page 20 other landscape features, including riparian vegetation and dunes” (Nabhan and Holdsworth 1998, pgs. 24–25).

The Arizona Wildlife Linkages Working Group, comprised of the Arizona Department of Transportation (ADOT) and the Arizona Game and Fish Department (AZGFD) in conjunction with the FHWA, BLM, USFS-Tonto National Forest, USFWS, Northern Arizona University, Sky Island Alliance, and the Wildlands Project, created the “Arizona Wildlife Linkages Assessment Document” which includes a detailed written description of each linkage and the species

www.tucsonaudubon.org | page 21 associated with each one the Southline proposal traverses, hereby incorporated by reference. http://www.azdot.gov/Highways/OES/AZ_WildLife_Linkages/map.asp and http://environment.fhwa.dot.gov/integ/case_arizona.asp.

The Southline DEIS does not adequately assess impacts to these linkages and further analysis of potential impacts to these areas and to the various species that may utilize them is necessary. BLM only provides very general information, including the expected acreage to be affected within each linkage and the broad statement that impacts “would include habitat loss, degradation, and fragmentation as well as increased OHV access due to the presence of access roads” as well as “potential barriers to movement along the corridor” (p. 746). Such a broad summary does not provide adequate information on how species’ movements could be affected by this project. Further information and analysis is needed on how each area will be affected and on how the various species that use each of these corridors could be impacted.

As noted on p. 311 of the DEIS, other natural topographical features have been identified as animal movement corridors, although not all of these have been analyzed and modeled in linkage assessments. In order to better evaluate potential effects from this project, the BLM should also address possible impacts to these non-designated corridors and how these could affect wildlife movement.

The practice of clearing transmission corridors of all vegetation for fire suppression and transmission line maintenance will result in even more fragmentation of the proposed route, adversely impacting crucial wildlife movement corridors and connectivity. Species with very specific habitat requirements, limited movement ability, inability/unwillingness to cross open or disturbed spaces, etc., may experience significant movement restrictions. Depending on what parts of the corridors are affected – and to what degree the habitat is changed – the modified areas may no longer serve as functional corridors for some species. The BLM needs to further analyze potential impacts on corridor usage by a diversity of species as a result of this project.

The 2008 Western Governors Association Wildlife Corridors and Crucial Habitat Initiative (http://www.westgov.org/index.php?option=com_content&view=article&id=123&Itemid=68) incorporated the work of the Arizona Wildlife Linkages Working Group and is hereby incorporated by reference. The AZGFD map of fragmentation in Arizona is available from http://www.habimap.org/habimap, and is hereby incorporated by reference. BLM must more thoroughly assess cumulative impacts to wildlife species as a result of changes to movement corridors. As climate change, drought, human development, and other factors alter habitat availability, quality, and range, the ability for species to move is becoming increasingly

www.tucsonaudubon.org | page 22 important. As the DEIS indicates, numerous past, present, and reasonably foreseeable actions could affect both available habitat and movement ability. Cumulatively, these projects will result in major, adverse, long-term impacts that will continue to fragment habitat and create barriers to species movement, access to resources, and genetic interchange (p. 1092–1093). Movement corridors may cease to be functional for some species, resulting in population-level – perhaps even species-level – impacts. This is a significant impact that must be more thoroughly analyzed.

We conclude that the best available science mandates that we keep habitat and landscape level ecosystem functions as un-fragmented as possible, especially in any identified Wildlife Linkages, Critical Landscape Connections, the Davidson Canyon/Cienega Creek area, the San Pedro River Valley watershed, the Sulphur Springs Valley and the Willcox Playa area, or other resource sensitive areas for local, regional and hemispheric resident and migratory wildlife populations, unique habitats, resilience and ecosystem services. The DEIS analysis is totally inadequate when addressing these issues and their appropriate mitigation.

Recommendation: The FEIS should thoroughly analyze and quantify habitat fragmentation and the resultant adverse impacts to wildlife species and connectivity and document how the full mitigation hierarchy will be employed to address these foreseeable circumstances.

Soil Stability, Invasive Species & Changing Fire Regimes

Erosion and damage to highly erodible soils is likely given the potential impacts associated with miles of new roads and other construction related activities. According to the Redington NRCD, http://redingtonnrcd.org/attachments/Long_range_plan_20102016.pdf, “sediment pollution of streams and erosion of rangeland is a major problem…. Roads associated with recreation and utility construction/maintenance were the major source of erosion… and the number one cause of human-related gully erosion… The Natural Resource Conservation Service describes the erosion hazard for the Stagecoach, Sonoran and Pinaleno soils, which make up 85% of the area, as severe which indicates that significant erosion is expected. The numerical rating is .95 where 1.00 has the greatest negative impact… Excessive erosion from roads can overwhelm a river’s capacity to process sediment. Cross-country road construction increases unauthorized access to off-road vehicles. The clearing of vegetation and associated soil compaction from these roads counter the re-vegetation and rangeland improvement efforts currently taking place in the district (Baker, 2010).”

www.tucsonaudubon.org | page 23 Soil disturbance associated with access roads associated with design, construction and maintenance activities can potentially result in adverse water quality impacts. Sheet flow may form in these areas, leading to soil erosion and other damage to surrounding soils. Soil erosion and sedimentation can clog streams and threaten aquatic life. Removal of the tree canopy along stream crossings can increase water temperature, algal growth, dissolved oxygen depletion, and cause adverse impacts to aquatic biota.

Levick et al. 2008, describe the importance of intermittent and ephemeral water sources:

“Ephemeral and intermittent streams make up approximately 59% of all streams in the United States (excluding Alaska), and over 81% in the arid and semi-arid Southwest (Arizona, New Mexico, Nevada, Utah, Colorado and California) according to the U.S. Geological Survey National Hydrography DaTucson Audubon et…Ephemeral and intermittent streams provide the same ecological and hydrological functions as perennial streams by moving water, nutrients, and sediment throughout the watershed. When functioning properly, these streams provide landscape hydrologic connections; stream energy dissipation during high-water flows to reduce erosion and improve water quality; surface and subsurface water storage and exchange; ground-water recharge and discharge; sediment transport, storage, and deposition to aid in floodplain maintenance and development; nutrient storage and cycling; wildlife habitat and migration corridors; support for vegetation communities to help stabilize stream banks and provide wildlife services; and water supply and water-quality filtering. They provide a wide array of ecological functions including forage, cover, nesting, and movement corridors for wildlife. Because of the relatively higher moisture content in arid and semi-arid region streams, vegetation and wildlife abundance and diversity in and near them is proportionally higher than in the surrounding uplands. In the rapidly developing southwest, land management decisions must employ a watershed-scale approach that addresses overall watershed function and water quality…Consideration of the cumulative impacts from anthropogenic uses on these streams is critical in watershed-based assessments and land management decisions to maintain overall watershed health and water quality.”

The sensitive, salty soils and halophilic plants of the alkaline (mud) lakes associated with the Willcox Playa and surrounding region are important to feeding shorebirds and so are the margins of the playa and Cochise Lakes. In the list of “Additional Mitigation Measures” on pgs. 809-810 of the DEIS, there are no mitigation measures that address restoration of ground disturbances.

www.tucsonaudubon.org | page 24 Recommendation: The Final EIS should analyze the effects of disturbing soils around Willcox Playa and disturbance of soils sustaining halophytes should be avoided. Include additional mitigation measures requiring active restoration of ground-clearance/disturbance activities with a plant palette reflective of the local ecosystem.

Improper use of herbicides to control vegetation could result in runoff to streams and subsequent water quality and aquatic impacts. Construction and maintenance of roads associated with the proposed project can result in permanent loss of all habitats in the developed area, disruption of animal movement and dispersal, and creation of a continual disturbance that affects animal communities in the adjacent fragmented portions of their habitats throughout the life of the project. These linear impacts can become a vector for exotic invasive species, fire, and illegal activities such as drug smuggling.

Fire is a very real and significant threat in the arid southwest desert uplands and grasslands, especially so with the rapidly expanding invasion of the exotic invasive species, especially African buffelgrass, (Pennisetum ciliaris). “The cattle-related introduction and intentional sowing of African grasses in the Sonoran bioregion has not only affected the biotic composition of semidesert grasslands, but has profoundly changed vegetation structure, fire intensity and frequencies and migratory wildlife corridors within several subregions of the Sonoran Desert proper.” (Nabhan and Holdsworth 1998, pg. 2)

Van Devender and Dimmit (2000) state that the introduction of buffelgrass into fire-intolerant desert communities results in a permanent conversion to a buffelgrass savanna with reduced plant cover and diversity. In some cases the conversion to buffelgrass has been so complete that consequences are irreversible in the short term (Burquez et al. 1998, pg.21). Van Devender and Dimmit (2006) state that buffelgrass is “the most serious ecological threat to the palo-verde- saguaro-ironwood desert scrub in the Arizona Upland (AZU) subdivision of the Sonoran Desert” and that, “in time, buffelgrass fires could convert the Arizona Upland into a savanna-like landscape as saguaro (Carnegiea gigantea), foothill paloverde (Parkinsonia microphylla), ironwood (Olneya tesota), organ pipe cactus (Stenocereus thurberi), etc. are killed”.

www.tucsonaudubon.org | page 25

Map depicting buffelgrass distribution along roadways of southern Arizona and northern Sonora, Mexico. Source: Van Devender and Dimmit 2006

Buffelgrass invasion of grasslands and columnar cacti of the Sonoran desert biome result in unnatural fire regimes, as documented by a May 28, 2008 controlled burn of 160 acres of buffelgrass invaded land owned by the City of Tucson, in the Avra Valley. University of Arizona

www.tucsonaudubon.org | page 26 researcher Chris McDonald and local firefighters expressed surprise at the “extreme” fire behavior that burned at 1700 degrees and moved at approximately the speed of the wind over a relatively flat terrain. Many desert trees, shrubs, and cacti, including saguaros, are not fire adapted and cannot withstand fires.

Other problematic invasive species include but are not limited to blue panic (Panicum antidotale, a Federal Noxious Weed), Bermuda grass (Cynodon dactylon), Sahara mustard (Brassica tournefortii), another African grass, Lehman’s Lovegrass (Eragrostis lehmanniana), saltcedar (Tamarix ramosissima and closely related species), Russian olive (Elaeagnus angustifolia), Giant reed (Arundo donax), and invasive shrubs such as mesquite (Prosopis spp). Exotic species that are of greatest management concern are those that are highly invasive and that strongly modify their environment. Table 1 of Appendix H - Exotic Plant Species in Riparian Ecosystems of the US Southwest, from the 2002 Southwestern Willow Flycatcher Recovery Plan, has extensive information on invasive species of concern to riparian areas.

As the conversion of native to non-native plant communities is primarily a human-facilitated issue, and because many current fires are human-caused, the issue of fire in an environment of increasingly fragmented landscapes which facilitates invasive non-native plant communities is a legitimate threat to public health and safety and the survival of our ecosystem in general.

Recommendation: Avoid denuding ROWs and areas adjacent to drainages of vegetation and preserve in place native grasses, shrubs and scrub mesquite for soil stability and to avoid incursion and establishment of non-native, opportunistic and potentially fire prone invasive species. Gate and post all access roads and buffer with boulders to avoid trespass.

Pre-Construction Studies, Construction Activities, and Post Construction

The Southline DEIS Chapter 4, page 810, section on Unavoidable Impacts states “implementation of the proposed Project would result in both Project-related and cumulative unavoidable adverse impacts (short-term and long-term) to the wildlife in the area.”

Chapter 4, page 732 states, “Potential construction-related impacts from the proposed Project common to all wildlife groups would include the loss, degradation, and /or fragmentation of breeding, rearing, foraging, and dispersal habitats; collisions with and crushing by construction vehicles; loss of burrowing animals in burrows in areas where grading would occur, increased invasive and noxious weed establishment and spread; and increased noise/vibration levels. Construction-related impacts would be minor/negligible to moderate and short-term to long- term.”

www.tucsonaudubon.org | page 27 Despite these detrimental effects identified in Section 4.8.2 Wildlife, for many species the DEIS concludes that there is “no detectable effect on the viability of this species or contribution towards a downward population trend or listing of this species as threatened or endangered.” These assertions are generally made a) without substantiating evidence and b) without explanation of the decision process that led to the assertions.

For example, in Chapter 4, page 745, the DEIS assesses Sandhill Cranes and states “Within subroute 1.1 approximately 1,359.0 acres of migratory/stopover habitat occurs, of this area approximately 312.6 acres would be disturbed. Based on the amount of migratory/stopover habitat for this species in the analysis area, there would be no detectable effect on the viability of this species or contribution towards a downward population trend or listing of this species as threatened or endangered.” The amount disturbed is slightly less than one-quarter of the total amount of habitat in the area, which could be significant dependent on its location and quality, and the degree to which the cranes use it. The Final EIS should thoroughly document how the BLM decided that this habitat reduction would have no detectable effect, and should change the finding if appropriate.

Other species for which “no detectable effect “ is asserted include loggerhead shrike, white- faced ibis, 11 bat species, Gila monster, and others. In the case of each species or group of species where a finding of “no detectable effect” is made there should be justification, preferably with quantitative reference to total amount of habitat in the area or in the species range, or explicit reference to such justification elsewhere in the document or in published literature. Without substantiating information, the conclusion of “no detectable effect” for these species appears arbitrary and capricious.

Recommendation: Whenever the EIS states a conclusion about how the Project will affect wildlife, particularly when the conclusion is “no detectable effect,” the EIS should provide the scientific evidence and logical process used to reach that conclusion.

BLM should vary the size of the Cumulative Effects Analysis Area (CEAA) as appropriate for individual species. The Cumulative Impacts section in Chapter 4, page 811, lists many projects either in or adjacent to the Project area that would contribute to cumulative effects. CEQ regulations for implementing NEPA analysis state that “Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time” (40 CFR 1508.7). Therefore it is essential that the BLM does a much better job of assessing the quantitative effect that contributing projects will have on population sizes and habitat acreage and quality.

www.tucsonaudubon.org | page 28 Doing an adequate job of assessing cumulative effects requires determining the appropriate CEAA. As the BLM states in Chapter 4, page 1090, “The geographic analysis area for cumulative impacts on wildlife resources could extend to the entire range of any wildlife species population that could be impacted by the proposed Project. The range of some of the migratory bird species occurs from North America to South America.” The solution taken in the DEIS is to use the same standard CEAA for wildlife as for other resources. But this will not be adequate for many wildlife species which may be patchily distributed and vulnerable throughout their range. Consider a hypothetical population of a rare migratory bird species that winters only at Willcox Playa and in summer flies north to a single area to breed. If these are the only two areas of habitat used by the population, to be meaningful an assessment of cumulative impacts should focus on both these areas. On the other hand, a plant restricted to some portion of the project area and surrounding area could be adequately assessed within the CEAA.

The conclusion based on the cumulative impacts for wildlife overall in Chapter 4, page 1093 states, “However, the cumulative impact of the construction and operation of the proposed Project would be moderate to major and long-term.” This, despite onsite mitigation efforts to minimize impacts.

Cumulative impacts present particularly grave concerns for many rare species. On a typical individual project, because the impacts are judged to be insignificant, the project goes forward. The cumulative effect of many such projects being approved is a downward trend in the population of one or more rare species. To avoid contributing to such a trend for the many ESA listed or other rare species in the Project area, the BLM should require a goal of no net habitat loss. This means that when acres of habitat are lost due, for example to siting transmission stations or roads, Southline should be required to conserve an equal or greater amount of like habitat, as close as possible to the impact, through purchase or easements. Utilizing this approach is similar to the compliance suggested by Pima County’s CLS guidelines and would make this project a flagship example of good conservation planning.

In order to make an appropriate habitat replacement, the number of individual animals (or plants) supported by the mitigation habitat must be equal or greater than the number of individual animals (or plants) killed by construction or operations and maintenance. This will require an adequate census of both the area disturbed by the project and the mitigation replacement habitat.

Recommendation: The BLM should develop criteria for which species need individual assessment on a scale larger than the standard CEAA, and such species should receive

www.tucsonaudubon.org | page 29 individual analysis for cumulative impacts. To prevent this project from contributing to cumulative decreases in habitat and population sizes, degraded or destroyed habitat should be offset by offsite mitigation of habitat of equivalent function and value.

Provisions for minimizing harm to vegetation and wildlife during construction are detailed in Chapter 4, pages 732-734. We commend the BLM for requiring preconstruction surveys in areas where Morafka’s desert tortoise (also known as Sonoran desert tortoise), Gila monster (Heloderma suspectum), and Tucson shovel-nosed snake (Chionactis occipitalis klauberi) would be expected to occur.

The construction of new transmission lines should, at minimum, require preconstruction detailed studies of bird behavior at the precise location(s) where construction is proposed in order to identify species that are particularly vulnerable, and which sites are intensively used. Those studies should be used to identify the optimum transmission line location and construction timing. Transmission lines and associated structures would then be located where impacts would be completely avoided or minimized. To the best of our knowledge, this has not occurred and should be done prior to the FEIS and ROD. Monitoring should continue through construction and for the life of the project and subsequent remediation.

PPM WILD-6 specifies that Southline would submit a Bird and Bat Conservation Strategy Plan to BLM and Western for approval. The Final EIS should require that Southline create a process to involve, at minimum, the Tucson Audubon Society, Arizona Audubon, and Bat Conservation International, and/or other citizen groups and scientists with expertise in the formulation of this plan.

Construction and maintenance activities should be conducted only during daylight hours to avoid noise and lighting issues during the night. If construction or maintenance work activities would continue at night, all lights should be shielded to direct light only onto the work site. The minimum wattage needed should be used and the number of lights should be minimized. Noise levels for day or night construction and maintenance should be minimized. All generators should be “whisper generators”, be in baffle boxes (a sound-resistant box that is placed over or around a generator), have an attached muffler, or use other noise-abatement methods in accordance with industry standards.

Birds of prey such as eagles, hawks, and owls frequently use power lines and support structures for perching and nesting, preying on species made vulnerable by the clearing of the ROW and the advantage of the excess height of the perch. Raptors can be electrocuted while

www.tucsonaudubon.org | page 30 using power lines, thus contributing to the cumulative mortality factors affecting these biologically important and environmentally sensitive birds. Standard techniques have been developed to prevent raptor electrocutions at electric distribution lines. This guidance is included in the publication Suggested Practices for Raptor Protection on Power Lines: The State of the Art in 2006 by the Avian Power Line Interaction Committee. The document may be requested from Edison Electric Institute at http://www2.eei.org/products_and_services/descriptions_and_access/suggested_pract.htm .

Raptors are sensitive to environmental disturbance and occupy an ecological position at the top of the food chain; thus, they act as biological indicators of environmental quality. The nesting season is considered the most critical period in the raptor life-cycle because it determines population productivity, short-term diversity, and long-term trends. Therefore serious attention should be paid to the raptor buffers as all raptors are protected under the Migratory Bird Treaty Act (MBTA). Raptor nest protective buffers (surface-disturbing and disruptive activities subject to seasonal limitations) proposed are inconsistent across the project and inadequate. Any activity that disrupts breeding, feeding, sheltering, and roosting behavior and causes, or is likely to cause, nest abandonment or reduced productivity is considered disturbance and is a violation of BGEPA. We encourage BLM to adopt the following protections - prohibiting surface- disturbing activities within 1 mile of Golden Eagle (GOEA) nests and 1 mile for Ferruginous Hawk nests. We support the specificity of “nests active within the past 7 years” and the inclusion of winter roost sites. We recommend a 1 mile buffer for ALL other raptors nests as well (BLM Special Status Raptors – Burrowing Owl, Swainson’s Hawk, Peregrine Falcon, and Northern Goshawk). We suggest retrofitting other transmission lines in the area to make them safe for raptors as partial mitigation for foreseeable mortalities.

Courtship, nest construction, incubation, and early brooding are higher risk periods in the life- cycles of raptors, when adults are more prone to abandon nests due to disturbance, and human activities resulting in disturbance to raptors can cause population declines. Seasonal restrictions and buffers around nest sites are intended to minimize disturbance to GOEA but year-round exclusion areas should also be considered for use. Given the growing concern for these long- lived, majestic birds, especially related to mortalities associated with wind farms and expanding transmission infrastructure, any development decisions that will impact GOEA must be placed within a regional population context much larger than the area immediately surrounding any proposed transmission project. BLM should develop a supplemental GOEA document for public review and comment. Areas 10 miles distant from the application area should be evaluated.

www.tucsonaudubon.org | page 31 Adequate buffers for GOEA should be in place and monitored to evaluate effectiveness. Compensatory mitigation for retrofitting of lethal power poles in the region should be considered for the first five years of operation. We note that spatial buffers for GOEA nests, as for Bald Eagles, should be a minimum of one mile.

The BLM should require that Southline continue monitoring surveys for all species of concern for the lifetime of the project to a) identify whether effects on these species will be more severe than envisioned in the EIS, b) to provide invaluable information on the actual effects of the project that can be used to improve the scientific accuracy of EIS’s for future transmission projects, and c) to allow for adaptive management and ongoing mitigation.

Birds at lower elevation appear to be influenced by local topography (Williams et al. 2001). Williams et al. (2001) observed that the lowest 300 meters of bird migration probably represented the densest stratum of nocturnal migrants. Mabee and Sanzenbacker (2008) reported that the majority of nocturnal passerine migrants fly below 600 meters above ground level. Avian migrants reacting to local terrain may result in concentrations of [bird] migrants over ridge summits or other topographic features of bird migration through mountain passes (Williams et al. 2001). Relative to other bird groups migrating over land, passerines tend to migrate at lower flight altitudes, whereas shorebirds and waterfowl tend to migrate at higher altitudes (Kerlinger 1995). Studies have shown that even specialized species such as neo- tropical migrants are using the entire watershed, not just the “green ribbon” created by the San Pedro River Valley (LSPRWA, 2006).

PPM WILD-5 specifies sensible measures to be taken near Willcox Playa to minimize impacts on migratory birds and raptors such as not moving active bird nests during breeding season. The BLM should require artificial nesting structures be built to replace any nest structures that are removed outside the breeding season.

Recommendation: Do not disturb active bird nests. Throughout the Project area, the BLM should consider requiring artificial nesting structures be built to replace any nesting structures (e.g. trees) that are removed outside the breeding season.

The Final EIS should analyze a new alternate route that avoids the Willcox Playa

Birds find power lines and towers difficult to perceive. Migratory birds, such as Sandhill Cranes (Grus canadensis) and Snow Geese (Chen caerulescens), are of particular concern. Collisions and consequent mortality from siting transmission lines adjacent to or spanning bodies of water, between heavily-used bodies of water and feeding areas (e.g. agricultural fields), and landscape

www.tucsonaudubon.org | page 32 contexts in which the overhead static wire is obscured or hard to see upon approach are all foreseeable circumstances and as such should be avoided via siting selection. The elevated risks posed by the DEIS agency preferred alternative near Willcox Playa is a foreseeable circumstance that is neither avoided nor adequately analyzed in the DEIS (see also the following section regarding mitigation to prevent mortality).

Due to wingspans of 6 to greater than 7 feet, flight heights ranging from altitudes of 500 to 12,000 feet, and the tendency to gather and move in large flocks, Sandhill Cranes are particularly susceptible to collisions with transmission lines. Cranes and other migratory birds may be attracted by sunlight reflecting off the shallow waters of the playa and associated wetlands and not perceive transmission wires in the immediate vicinity. Sandhill Crane flocks often have cumbersome flight patterns approaching or leaving the area at the height of the transmission wires, and this fact compounds the collision risk. Moreover, because they typically fly in large flocks that follow leaders, mass mortality events are likely if an entire flock flies into the lines.

The DEIS agency preferred alternative would directly and adversely impact the Willcox Playa Globally Important Bird Area, and would have direct, indirect and cumulative impacts upon migratory species by virtue of the playa’s close proximity to the project area. A high frequency of collisions is almost certain because, as noted in Chapter 2, page 160, cranes fly daily during October and March to and from agricultural fields to the southeast of the lake. Chapter 4, page 927 states, “Sandhill Cranes make a daily migration during wintering from Willcox Playa to the agricultural fields to the east. Subroute 2.1 would cross this area of daily migration and would lead to increased numbers of collisions of Sandhill Cranes and transmission lines/structures.”

The Environmentally Preferred Alternative Segment WC1 would put the line just south of Interstate 10 near the northwest corner of the Willcox Playa Globally Important Bird Area. This might lessen the number of daily flights across the wire, but there would still be significant danger because “When cranes take flight from the lake, they initially circle it before turning towards their preferred foraging areas…”(Chapter 4, page 764). Moreover, cranes would also be vulnerable when entering or leaving the playa to the north or west, for example during annual migrations.

www.tucsonaudubon.org | page 33

www.tucsonaudubon.org | page 34 The DEIS reflects a decision not to adopt WC1, eliminating it from further analysis because of conflicts with important habitat conservation areas by the AGFD in the “State Wildlife Action Plan” (AGFD 2012a) and FireScape planning efforts in the Dos Cabezas Mountains. Although we also have significant concerns regarding any route impacting the Dos Cabezas Mountains, the FEIS should provide more detailed information about all of the alternatives considered, criteria that were weighed and the decision process used in making this decision.

In the interest of avoiding foreseeable risks to the Willcox Playa Globally Important Bird Area as well as the Dos Cabezas Mountains (which comprises the northern end of the Chiricahua Mountains Globally Important Bird Area), we recommend developing and analyzing a new alternative that would site Southline to the north of Interstate-10 far enough away from the Willcox Playa to avoid crane mortality. For any alternative routes near Willcox Playa, BLM should analyze the comparative impacts of maintaining at least a one mile distance from the Willcox Playa Globally Important Bird Area boundary against the impacts of co-locating along the existing transmission along the playa and select the lower-impact alternative. Locating the route at least a mile away may give cranes and other waterfowl leaving or entering the lake adequate time and distance to gain proper altitude for takeoff or landing without hitting wires.

It is our understanding that there is an existing high-voltage transmission line (between 220kV and 315 kV) running along the agency-preferred route along the southeast side of the playa, and an existing transmission line below 115 kV running along the southwest side of the playa that the route there would follow. It is also our understanding that the project applicant intends to begin the upgrade portion of the project at the Apache Substation which is located near the southwest corner of the playa. It is our estimation that the presence of existing transmission lines and the applicant’s desire to connect to the Apache Substation to begin the upgrade portion of the line are the reasons behind the alternative routes analyzed in the DEIS, and the reason why BLM did not analyze an alternative north of I-10 connecting to the Adams Tap Substation, despite the fact that such an alternative would better avoid impacts to the Willcox Playa. We have not previously requested a meeting with BLM and the project applicant to discuss these questions, but we would appreciate having such a meeting soon to discuss whether an alternative north of I-10, connecting at the Adams Tap substation, would meet the applicant and BLM’s purpose and need while also significantly reducing impacts to the Willcox Playa. Tucson Audubon Society wishes to participate in any meetings regarding the Playa IBA.

Recommendation: The Final EIS should include a full analysis of another alternate route north of Interstate 10 to avoid the Willcox Playa Globally Important Bird Area entirely. We would

www.tucsonaudubon.org | page 35 appreciate the opportunity to meet with BLM and the project applicant to discuss whether such an alternative would meet the applicant’s and BLM’s purpose and need while significantly reducing impacts to Willcox Playa.

Serious consideration should be given to burying portions of the line.

As stated above, we have significant concerns regarding the alternatives in the DEIS that run along the edges of the playa. To address these concerns, the FEIS should include analysis of burying the line for any alternatives that run within one mile of Willcox Playa. If the analysis shows that burying the line would have significantly lower impacts, BLM should require that the line is buried in those areas.

The DEIS states that the Proponent proposed measures to design the transmission lines and structures in accordance with “Reducing Avian Collision with Power Lines” (APLIC 2012) would minimize the potential for bird collisions with transmission lines or poles. This publication lists “burying the lines if feasible and warranted” as one mitigation option (Figure 5.1, page 54).

Recommendation: the FEIS should analyze burying the line for any alternatives that run within one mile of the Willcox Playa IBA boundary. If the analysis shows that burying the line would have significantly lower impacts, BLM should require that the line is buried in those areas.

The EIS should require scientific study of potential crane mortality and identify effective mitigation measures

The Final EIS should include more complete scientific analysis by experts to predict likely crane mortality and to verify the efficacy of mitigation measures like line markers.

We are concerned about the DEIS’s treatment of waterfowl and Sandhill Crane mortality caused by collision with wires. Given that tens of thousands of Sandhill Cranes use the Willcox Playa as a wintering ground, many deaths from collisions are likely. We commend the BLM for citing in the Operation and Maintenance section, Chapter 4, page 748 a 2007 study that estimated that 165 to 219 Sandhill Cranes had been killed by colliding with two 69-kV power line arrays at the Lillian Rowe Sanctuary. However, the next two lines of the DEIS do not appear to make sense and need clarification: “While the proposed transmission lines would be larger than the 69-kV lines in the study there would be more lines. As such it would not be possible to quantify the potential impacts on Sandhill Cranes.”

The DEIS appears to imply that larger lines would be less deadly, presumably because they are easier for the birds to see, but there is no cited justification for this assumption. The first

www.tucsonaudubon.org | page 36 sentence in the above excerpt goes on to state that Southline would use more lines than the Lillian Rowe Sanctuary, implying that this factor could elevate kill levels above those at Lillian Rowe. However, there is no conclusion as to whether this would have population-level impacts. The next section on migratory birds also notes there may be “an elevated risk of collision events,” but concludes without supporting evidence that “That risk would still be unlikely to reach population-level impacts.” This appears in contradiction to Chapter 4, page 810, which states “The residual impacts to Sandhill Cranes at the Willcox Playa would be reduced, but any mortality would be a significant impact.”

There are many studies showing that powerline collisions are a major source of mortality for some species, and in some cases power-line mortality has been the single greatest identified cause of death. In the absence of quantitative information on bird strikes caused by lines of this size and number, there is no justification for BLM’s conclusion that there are no significant impacts. The report states, again without supporting citation, that “The risk of collision of Sandhill Cranes and other birds with the proposed transmission line in the Willcox Playa area would be minimized through utilization of line marking devices. With mitigation, impacts on Sandhill Cranes would be minor/negligible to moderate and long-term.” To support this assertion, the BLM-Western must provide evidence that these marking devices will be effective, in other words the BLM should provide evidence for the frequency of bird-wire collisions that occur per flight for a marked transmission line of this type. Unclear language like “risk of collision … would be minimized” needs to be replaced with a clear, science-based estimate of the amount of reduction. From the existing language it is not clear whether line markers would reduce collisions by 90 percent or 1 percent, something critical to knowing whether or not line markers would provide adequate mitigation.

Prior to finalizing the EIS, the BLM should contract with scientific experts to model for each alternative the potential number of collisions between cranes and other migratory waterfowl based on number and location of birds, number of daily flights over the power lines, and number of likely collisions (based on data from Wings Over Willcox observations and similar installations). These projects should include scenarios with different types of mitigation, including a variety of types of line markers.

Recommendation: Prior to making a decision about the route near Willcox Playa, the BLM should contract for scientific experts to characterize crane flight behaviors, likely mortality, and effective mitigation measures.

www.tucsonaudubon.org | page 37 The Final EIS should analyze cumulative impacts for cranes.

Although this section of our comments focuses on Willcox Playa, other sections of the line may also kill cranes, for example where it crosses the Sandhill Crane migratory flyway and a wintering site near Columbus, New Mexico (Chapter, 4, page 748), thereby contributing to cumulative mortality.

Recommendation: The Final EIS should include a full analysis of cumulative crane mortality throughout the Project area.

Birds and Important Bird Area (IBA) Designation

The purpose of the Important Bird Area Program is to identify a network of sites that maintain the long-term viability of wild bird populations while engaging the public to conserve those areas of critical habitat. IBA designation is particularly relevant to protecting those critical habitats utilized by birds during some part of their life cycle (breeding, feeding, nesting, molting and migrating) as well as conserving the general biodiversity of wildlife species. Migration and molt are very taxing on birds and, for some species, migration is the time of greatest mortality.

To date, of the 2596 Important Bird Areas encompassing 367,724,987 acres identified nationally, only 621 have been prioritized as Global Important Bird Areas (283,351,085 acres) http://netapp.audubon.org/IBA/. These sites include Important Bird Areas significant for more than 65 globally threatened species. Global Important Bird Areas are determined through a prioritization process which involves the review of identified State-level Important Bird Areas by the U.S. IBA Technical Committee — they represent high priority sites for conservation actions. http://aziba.org/?page_id=32 and http://www.audubon.org/bird/iba/prioritizedibas.htm.

Tucson Audubon established and, in partnership with Audubon Arizona, continues to implement the Arizona component of the Global Important Bird Areas (IBA) Program, initiated in 1982 by BirdLife International. Arizona IBA Program offices work with diverse partners on issues and specific projects for the conservation of Important Bird Areas in Arizona to promote win-win objectives for people, wildlife, communities, and sustainable economies. The Audubon network as thus far established 45 Important Bird Areas within Arizona, fourteen of which have Global IBA status, covering over 4,174,774 acres of habitat

www.tucsonaudubon.org | page 38 www.tucsonaudubon.org | page 39

http://netapp.audubon.org/IBA/State/US-AZ. Each is established using strict standards and scientific data and is peer reviewed by an independent panel of scientists. IBA Science Committee members in Arizona are from the Arizona Game and Fish Department (AZGFD through the Arizona Bird Conservation Initiative), the Sonoran Joint Venture, the Intermountain West Joint Venture, Arizona State Parks, the U.S. Forest Service (FS), the U.S. National Park Service (NPS), the U.S. Bureau of Land Management (BLM), and the U.S. Fish and Wildlife Service (FWS), as well as representatives from various non-governmental organizations, colleges, and universities. Although Global Important Bird Area status carries no regulatory authority, it does bring biological information and habitat protection importance awareness to the public’s attention, as well as bringing quantitative data and habitat information to governments and agencies, assisting in science-based land use and land management planning in order to conserve high value wildlife resources at the state, hemispheric and even global levels.

Tucson Audubon and Audubon Arizona have partnered with the AZGFD to gather scientific data to identify and set science-based priorities for habitat conservation and to promote positive action to safeguard and protect significant bird habitats. Tucson Audubon leads the Avian Science Initiative while maintaining the Arizona IBA Bird Survey Database and website http://aziba.org.

Southline, as proposed in the preferred alternative, will unquestionably adversely impact the Willcox Playa Global IBA where avian species will find power lines and towers difficult to perceive and therefore migratory species will be subject to collision and mortality. It may also, depending on the route chosen in the FEIS, negatively impact other nominated or designated IBAs and migratory flyways.

Chiricahua Mountains IBA

Identified as a Globally Important Bird Area in October of 2009, this Cochise County IBA is managed by the Coronado National Forest and encompasses the large “sky island” Chiricahua Mountain range in southeastern Arizona, part of a chain of mountains spanning from the Sierra Madre range in central Mexico into southeastern Arizona. The Chiricahua range is almost 40 miles long by 20 miles wide. The IBA extends from 5000 feet elevation, at the ecotone between grassland and oak, to the top of Chiricahua Peak at 9795 feet.

Here Rocky Mountain avifauna meet northern Sierra Madrean avifauna, as well as a mixing of Sonoran, Chihuahuan, and Great Basin desert avifauna. Some 375 bird species are known to

www.tucsonaudubon.org | page 40 inhabit the Chiricahua Mountains IBA (Taylor 1997). Sierra Madrean species reach the northernmost extension of their ranges within this IBA. Of particular ornithological importance is the great number of Mexican species whose northern summer breeding range occurs only in the southern “sky island” mountains of Arizona: Elegant Trogon (Trogon elegans), Whiskered Screech-Owl (Otus trichopsis), Violet-crowned Hummingbird (Amazilia violiceps), Sulphur- bellied Flycatcher (Myiodynastes luteiventris), and Mexican Chickadee (Poecile sclateri found only in the Chiricahua and Animas Mountains in the U.S.). The Elegant Trogon population is the second largest in the United States after the population within the Huachuca Mountains IBA. In addition to Violet-crowned, fourteen other species of hummingbirds have bred in this IBA including Lucifer (Calothorax lucifer), Costa’s (Calypte costae) and Broad-billed (Cynanthus latirostris). This IBA supports 33 (breeding or resident) Species of Conservation Status, most notably a high percentage of the state population of: Whiskered Screech-Owl, Arizona Woodpecker (Picoides arizonae), Buff-breasted Flycatcher (Empidonax fulvifrons), Grace’s Warbler (Dendroica graciae), and possibly Crissal Thrasher (Toxostoma crissale). Within the last decade or so, Short-tailed Hawks (Buteo brachyurus) have nested within this range. Historically, Thick-billed Parrots (Rhynchopsitta pachyrhyncha) occupied the Chiricahua Mountains and the habitat remains little changed. Though twenty-six birds were reintroduced in 1986, the reintroduction attempt failed, apparently due to the inexperience of the individuals released and predation by raptors.

Chiricahua Mountains IBA GIS Map - zoomed out

The most notable species of Global Concern is the Mexican Spotted Owl (Strix occidentalis). Species of Continental Concern include Montezuma Quail (Cyrtonyx montezumae) and Yellow- eyed Junco (Junco phaeonotus). Additional species include Golden Eagle (Aquila chrysaetos), Peregrine Falcon (Falco peregrinus), Elf Owl (Micrathene whitneyi), Bell’s Vireo (Vireo bellii), and Lucy’s Warbler (Vermivora luciae). The range also includes mammals such as jaguarundis,

www.tucsonaudubon.org | page 41 and trees such as the Apache pine. Numerous perennial springs and streams occur within the range, although none flow out of the mountains into the surrounding Chihuahuan desert scrub.

Lower San Pedro River IBA

Recognized as a Globally Important Bird Area in February of 2008, the Lower San Pedro River serves as a corridor between the Sky Islands of the Madrean Archipelago in northern Sonora, Mexico and southern Arizona in its southernmost reaches and, to the north, Arizona’s Central Highlands. The Lower San Pedro River IBA comprises 51.2 square miles or 32,762 acres and is owned and managed by a mixture of private and public entities including the BLM, the Salt River Project, the Bureau of Reclamation, The Nature Conservancy, Pima County, and private landowners.

The river is not only a major north-south corridor between varied habitat types and ecoregions; it represents a ribbon of water and riparian vegetation in an otherwise arid environment. The river thus exhibits remarkably high biodiversity, both in resident and migratory species.

The Lower San Pedro River is characterized by a well-developed cottonwood-willow gallery forest riparian habitat interspersed with old growth mesquite (Prosopis juliflora woodlands known as bosques. The largest intact mesquite bosque community in Arizona is located on 14 miles of the San Pedro River beginning south of the community of San Manuel and ending north of the community of Mammoth. The uplands at the southern end of the IBA are Chihuahuan Desert Scrub typified by Creosote Bush (Larrea), Black Brush and Yucca (Yucca Elata). Saguaro (Cereus gigantea), Foothill and Blue Palo Verde (Cercidium microphyllum and C. floridum), Ocotillo (Foquieria splendens), and a variety of cacti and small shrubs cover the uplands further north. Mesquite, Catclaw Acacia (Acacia greggii), Burrobush (Hymenoclea monogyra), and Desertbroom (Baccharis sarothroides) line xeric washes, while Goodding Willow (Salix gooddingii), Fremont Cottonwood (Populus fremontii), Velvet Ash (Fraxinus velutina), and Netleaf Hackberry (Celtis reticulata) cluster along wetter drainage ways. Interspersions of Sonoran Desert grassland are typified by grama grasses (Boutaloua spp.), Three-awns (Aristida spp.), and Mulenberghia spp.

Duncan and Slagle (2004) describe the San Pedro River as one of the most significant perennial undammed desert rivers in the United States, providing important habitat for almost 400 species of migratory birds, and approximately 80 species of mammals and 40 species of reptiles and amphibians. The river corridor also provides habitat for 100 species of butterflies

www.tucsonaudubon.org | page 42 and 20 species of bats. Beaver have migrated down river from the Upper San Pedro River Riparian National Conservation Area IBA.

The American Bird Conservancy’s report on the “Top Twenty Most Threatened Bird Habitats in the United States” lists Southwestern Riparian Habitat as the fifth most threatened in the nation. This increasingly rare habitat type, epitomized by the San Pedro River watershed, is described as occupying only a tiny fraction of the land area while supporting the largest concentrations of animal and plant life, and the majority of species diversity in the desert southwest, a designated “hotspot” of biological diversity. The report states “The scarcity of water in the Southwest makes rivers and streams particularly important for sustaining the region’s communities. This dependence places a severe strain on natural ecosystems. Achieving riparian habitat conservation depends on public agency buy-in to broad-scale land management plans and the successful provision of incentives to private property owners to restore their degraded land. Riparian areas take time to recover… Currently, though, efforts to restore riparian areas are being considerably outpaced by the rate at which they are being lost, making these vibrant ecosystems an ever-rarer feature of the Southwest.” http://www.abcbirds.org/newsandreports/habitatreport.pdf.

The Arizona Partners in Flight Bird Conservation Plan states, “Riparian woodlands comprise a very limited geographical area that is entirely disproportionate to their landscape importance, recreational value, and immense biological interest (Lowe and Brown 1973). It has been estimated that only 1% of the western United States historically constituted this habitat type, and that 95% of the historic total has been altered or destroyed in the past 100 years (Krueper 1993, 1996)… Riparian woodlands are among the most severely threatened habitats within Arizona…. Maintenance of existing patches of this habitat, and restoration of mature riparian deciduous forests should be among the top conservation priorities in the state”. http://www.azgfd.gov/pdfs/w_c/partners_flight/APIF%20Conservation%20Plan.1999.Final.pdf.

Riparian woodlands in the desert southwest are an extremely important resource because, while they constitute less than one percent of the desert landscape, they typically support more than fifty percent of the breeding birds. Indeed, the positive effects of even a degraded riparian area in central Arizona extend up to one km into the adjacent uplands (Szaro and Jakle 1985). Riparian woodlands also provide shelter and critical food resources for dozens of species of migratory birds that stop in these woodlands during their spring and fall migrations.

Of ornithological significance, this River’s forest is host to 345 species of birds, including 13 species of breeding raptors, and is a major north-south migratory pathway for neotropical birds

www.tucsonaudubon.org | page 43 such as Gray Hawk (Asturina nititda=Buteo nitidus) and the rare Western Yellow-billed Cuckoo (Coccyzus americanus occidentalis) which is pending federal listing under the Endangered Species Act. Bell’s Vireo (Vireo bellii) is a Global Species of Conservation Concern; Abert’s Towhee (Pipilo aberti) is a Continental Species of Conservation Concern; and the IBA Site is Important to Special Status Avian Species such as the SW Willow Flycatcher (Empidonax trailli extremus - Federally Listed in Arizona), Gray Hawk, Western Yellow-billed Cuckoo, Bell’s Vireo, Northern Beardless-Tyrannulet (Camptostoma imberbe), Lucy’s Warbler (Vermivora luciae), Abert’s Towhee, and Brewer’s Sparrow (Spizella breweri). The IBA contains >40% of the Arizona breeding population of both SW Willow Flycatcher and Mississippi Kite (Ictinia mississippiensis) and >30% of the Arizona breeding population of Gray Hawk, qualifying as Significant Concentrations of Birds. The high importance of the Lower San Pedro River for the recovery of the Southwestern Willow Flycatcher contributed to its designation as critical habitat for the species. There are also significant numbers and density of Landbirds such as Bell’s Vireo and Yellow Warbler (Dendroica petechia). The IBA also contains Low Elevation Riparian River Habitat, a Rare, Unique, or Exceptional Representative Habitat/Ecological Community.

Raptors that nest on the lower San Pedro River include Gray Hawk, Mississippi Kite, Common Black Hawk (Buteogallus anthracinus), and Zone-tailed Hawk (Buteo albonotatus). Western Yellow-billed Cuckoos nest in numbers on the Lower San Pedro River. Gray Hawk, Zone-tailed Hawk, Common Black Hawk, and Mississippi Kite are represented on the entire reach. Levy (1971) documented up to 10 Mississippi Kite nests and Corman and Gervais-Wise (2005) describe the Lower San Pedro River as being the Arizona breeding population stronghold and supporting the majority of nesting sites for this species in Arizona. Corman and Gervais-Wise describe the Gray Hawk as “locally common” along segments of the San Pedro River.

Lower San Pedro River IBA GIS Map – zoomed out

State Species of Conservation Concern: Western Yellow-billed Cuckoo, Belted Kingfisher (Ceryle alcyon), Red-naped Sapsucker (Sphyrapicus nuchalis), Olive-sided Flycatcher

www.tucsonaudubon.org | page 44 (Contopus cooperi), Southwestern Willow Flycatcher, Tropical Kingbird (Tyrannus melancholicus), Thick-billed Kingbird (Tyrannus crassirostris), Western Purple Martin (Progne subis), Gray Hawk, Common Black Hawk, Zone-tailed Hawk, and Mississippi Kite.

San Pedro Riparian National Conservation Area IBA

Recognized as a Globally Important Bird Area in May of 2013, the approximately 56,000+ acres of the San Pedro Riparian National Conservation Area IBA (Upper San Pedro) is located in Cochise County and owned and managed by BLM. This IBA is located between the U.S./Mexico international border and St. David, Arizona. The riparian area, where some 40 miles of the Upper San Pedro River meanders, was designated by Congress as the first Riparian National Conservation Area on November 18, 1988 and is the best example of a desert riparian ecosystem in the United States.

The primary purpose for the special designation is to protect and enhance the desert riparian ecosystem, a rare remnant of what was once an extensive network of similar riparian systems throughout the American Southwest. One of the most important riparian areas in the United States, the San Pedro River runs through the Chihuahuan Desert and the Sonoran Desert in southeastern Arizona. The Upper San Pedro is home to 84 species of mammals, 14 species of fish, 41 species of reptiles and amphibians, 100 species of butterflies, 20 species of bats and 100 species of breeding birds. It also provides invaluable habitat for 250 species of migrant and wintering birds and contains archaeological sites representing the remains of human occupation from 13,000 years ago.

Of greatest ornithological relevance, the combination of the Lower San Pedro and San Pedro Riparian National Conservation Area IBAs comprise one of the four major north-south migratory bird corridors of the southwestern United States, along with the Rio Grande, Santa Cruz, and the Colorado River. Bird densities during migration average >40 birds per hectare, and can reach 75 to 100 birds per hectare. Greatest in abundance in migration are the Yellow Warbler (Dendroica petechia) and Wilson’s Warbler (Wilsonia pusilla), but also using the corridor are Osprey (Pandion haliaetus), Common Black-Hawk (Buteogallus anthracinus), Olive-sided Flycatcher (Contopus cooperi), Gray Flycatcher (Empidonax wrightii), and MacGillivray’s Warbler (Oporornis tolmiei). This IBA supports the largest breeding population of Gray Hawks (Asturina nitida) in the U.S., (40% of the population), and the largest Western Yellow-billed Cuckoo (Coccyzus americanus occidentalis) population in the U.S. The IBA supports migrating

www.tucsonaudubon.org | page 45 Southwestern Willow Flycatchers (Empidonax trailli extremus) which nest further downstream in great abundance. Two warbler species nest in tremendous number in this IBA, Lucy’s Warbler (Vermivora luciae) within the mesquite bosque habitat, and Yellow Warbler within cottonwood/willow habitat. Green Kingfisher (Chloroceryle americana) nest in the river banks with as many as 7 pairs in a given year. Botteri’s (Aimophila botterii - estimated 200 pairs) and Cassin’s Sparrow (Ammodramus cassinii - estimated 500 pairs) nest in the adjacent bunchgrass habitat in exceptionally high numbers. Other nesting Species of Conservation Status (SCS) include, Abert’s Towhee (Pipilo aberti - very abundant), Elf Owl (Micrathene whitneyi), Gilded Flicker (Colaptus chrysoides) , Northern Beardless-Tyrannulet (Camptostoma imberbe), Tropical Kingbird (Tyrannus melancholicus), Crissal Thrasher (Toxostoma crissale), and Varied Bunting. Belted Kingfisher (Ceryle alcyon - SCS) and Red-naped Sapsucker (Sphyrapicus nuchalis - SCS) can be found regularly over-wintering along the river. Historically, both the Aplomado Falcon (Falco femoralis) and Cactus Ferruginous Pygmy-owl (Glaucidium brasilianum cactorum) nested in the San Pedro River valley. Mississippi Kite (Ictinia mississippiensis) are breeding just north of the RNCA (10 individuals). The primary Species of Global Conservation Concern is Bell’s Vireo (Vireo bellii). State Species of Conservation Concern include Western Yellow- billed Cuckoo, Cassin’s and Botteri’s Sparrow, migration Flycatcher. This IBA also qualifies for Species in rare/unique habitat and for breeding raptors (Gray Hawk, Mississippi Kite).bottleneck Spring Warblers such as Wilson’s and Yellow Warbler, and the Olive-sided Flycatcher. This IBA also qualifies for Species in rare/unique habitat and for breeding raptors (Gray Hawk, Mississippi Kite).

San Pedro River Riparian National Conservation Area IBA GIS Map – zoomed out

www.tucsonaudubon.org | page 46 Scientists from the Environmental Protection Agency (EPA), the New Mexico State University (NMSU) and others have recently modeled the San Pedro River watershed, mapping metrics reflecting ecosystem services and biodiversity features using U.S. Geological Survey Gap Analysis Program data, including land cover, land stewardship, and deductive habitat models for terrestrial vertebrate species http://fws-case-12.nmsu.edu/case/es/. The San Pedro River watershed supports significant biodiversity, especially avian, and significantly surpasses even the Middle Rio Grande River in biodiversity.

It is widely understood that the human condition is intrinsically linked to the quality of the environment and the services it provides. Ecosystem services, i.e., "services provided to humans from natural systems," have become a key issue of this century in resource management, conservation, human well-being, and environmental decision analysis.

Metrics are derived from species-of-greatest-conservation-need, threatened and endangered species, harvestable species (i.e., upland game, big game), total species richness, and taxon richness.

www.tucsonaudubon.org | page 47

www.tucsonaudubon.org | page 48

San Pedro River watershed maps Courtesy of Dr. William Kepner, EPA

Mapping and quantifying ecosystem services have become strategic national interests for integrating ecology with economics in order to help explain the effects of human policies and the subsequent impacts on both ecosystem function and human welfare.

www.tucsonaudubon.org | page 49

Biodiversity Metrics for Southwest Region portrayed as a Radar Graph May 2011 Courtesy of Dr. William Kepner, EPA

Based on the recent biometrics study illustrated above, the San Pedro watershed's extraordinary ecosystem services provide tremendous biodiversity at the confluence of four different ecosystems. The entire river is a "Keystone" Transition Zone. In short, the San Pedro River watershed is a unique biological area of global significance, a true jewel in our southwestern region, that all should work to protect in perpetuity. We note that the area chosen for bisecting the San Pedro River Valley migratory pathway is north of I-10 in an area of primarily scrub mesquite.

Recommendation: Preserve in place as much of the native plant community, especially scrub mesquite, as possible and avoid clearing the entire ROW. Clear only the area required for travel and construction, minimizing impacts to the greatest extent possible.

Willcox Playa/Cochise Lakes IBA

www.tucsonaudubon.org | page 50 Recognized as a Globally Important Bird Area in October of 2011, the heart of this roughly 74 square mile, 47,343 acre IBA is the massive Willcox Playa, a broad alkaline lakebed fringed with semi-desert grassland (primarily saltgrass and sacaton) and mesquite, jointly owned by the City of Willcox, State and Federal agencies.

The Southline proposal would directly adversely impact the Willcox Playa IBA and surrounding habitats, and would contribute direct, indirect and cumulative impacts to migratory species by virtue of its proximity to the project area and circumstances where avian species find power lines and towers difficult to perceive and therefore subject to collision for migratory species such as Sandhill Cranes (Grus canadensis), Snow Geese (Chen caerulescens), and other migratory species. Avoiding spanning bodies of water or placing lines between heavily-used bodies of water and landscape contexts in which the overhead static wire is obscured or hard to see is a foreseeable circumstance not adequately addressed in the DEIS. Due to wingspans of 6 feet to 7 feet 3 inches, flight heights spanning altitudes of 500 to 2,500 feet on up to 12,000 feet, and the tendency to gather and move in large flocks, Sandhill Cranes more be attracted by sunlight reflecting off the shallow waters of the playa and associated wetlands, or the “La Playa Mirage effect”, and not perceive transmission wires in the immediate vicinity. The flock’s pattern of circling and somewhat cumbersome flight patterns approaching or leaving the area may further compound the potential for direct mortality.

www.tucsonaudubon.org | page 51 The playa is seasonally flooded to a shallow depth. Outlying this playa are the satellite lakes/wetlands of Cochise Lakes (or aka Lake Cochise), alkali flats, and Willcox Playa Wildlife Area containing Crane Lake. The Playa itself is a former bombing range, owned by the Department of Defense and administered by the U.S. Army Corps of Engineers. While it is not actively managed, it is posted no trespassing. On the upper east side of the playa is the AZGFD managed Willcox Playa Wildlife Area, consisting of 555 acres. The purpose of the Wildlife Area is primarily for optimizing waterfowl habitat and providing for hunting opportunities. There are ten “pot hole” ponds, and one 30-acre impoundment at the Wildlife Area. Over-wintering Sandhill Cranes (Grus canadensis) and migratory and wintering shorebirds, waterfowl, and waterbirds use the playa, the Wildlife Area (Crane Lake), and Cochise Lakes, for roosting, resting, and feeding. Sandhill Cranes depend heavily on the surrounding agricultural lands of the broader Sulphur Springs Valley for feeding, particularly in surrounding fields of waste corn.

The site is important to special status avian species such as Swainson’s Hawk (Buteo swainsoni), Scaled Quail (Callipepla squamata), Chestnut-collared Longspur (Calcarius ornatus) and Cassin’s Sparrow (Aimophila cassinii). It supports significant concentrations of shorebirds (greater than100) and cranes (greater than 2000). Willcox Playa and Crane Lake, within the northern portion of the Sulphur Springs Valley, support the second largest over-wintering concentration of Sandhill Cranes (Grus canadensis) in Arizona, typically 4,000 to 9,000 birds (White Water Draw is the area with the largest number of over-wintering cranes - 10,000-22,000

Sandhill Crane by Glenn Seplak and increasing). Crane numbers are typically 5,000 to 8,000 birds using the playa, and another 4,000 to 5,000 birds using Crane Lake (with much variability at Crane Lake). There are occasional years when crane numbers spike when a large number of birds (greater than

www.tucsonaudubon.org | page 52 13,000) from White Water Draw switch to roosting in this area (using either the playa or Crane Lake).

By the late 1940s the expansion of agriculture within the Sulphur Springs Valley (through the advent of groundwater pumping), provided the waste crop food base (corn) to attract Sandhill Cranes to over-winter in the valley. The wetter period of the mid 1980s brought large increases in crane numbers, and since then numbers have been steadily increasing at both White Water Draw and the Willcox Playa/Crane Lake. Cochise Lakes and an area of nearby alkaline lakes, also provide important habitat for a great number of bird species

Most significantly both in spring and late summer shorebirds can stop-over in very substantial numbers at both the playa and along Cochise Lakes (numbering 400-800 individuals at Cochise Lakes). These in-migration shorebird species using the playa and Cochise Lakes, include: Wilson’s Phalarope (Phalaropus tricolor) (April, May, July, August, September), Willet (Catoptrophorus semipalmatus) (April), Least Sandpiper (Caladris minutilla) (April, August, September), Western Sandpiper (Caladris mauri) (April, August, September), Long-billed Dowitcher (Limnodromus scolopaceus) (May, September), Black-necked Stilt (Himantopus mexicanus) (July, August, September), and American Avocet (Recurvirostra americana) (July, August, September), plus lesser numbers of other shorebird species (Killdeer (Charadrius vociferous), Marbled Godwit (Limosa fedoa), Spotted Sandpiper (Actitis macularia), Solitary Sandpiper (Tringa solitaria), Greater Yellowlegs (Tringa melanoleuca), Long-billed Curlew (Numenius americanus), Baird’s Sandpiper (Caladris bairdii), Pectoral Sandpiper (Caladris melanotos), Stilt Sandpiper (Caladris himantopus), and Red-necked Phalarope (Phalaropus lobatus). Small numbers of some shorebirds occasionally breed within the IBA, including American Avocet (Recurvirostra americana) and rarely Snowy Plover (Charadrius alexandrines) (Audubon WatchList 2007-Yellow, AZGFD Species of Greatest Conservation Need 2006).

One waterbird species, the White-faced Ibis (Plegadis chihi), is notably abundant also during migration (April) reaching numbers occasionally in the low 100s (~300). Cochise Lakes support many species of ducks and grebes. Ducks over-winter on the lakes in large flocks, primarily composed of American Wigeon (Anas Americana) (low 100s), Northern Shovelor (Anas clypeata) (low 100s), and Green-winged Teal (Anas crecca) (15-50+). In the spring months of March and April and again in the fall months of September and October, large numbers of waterfowl pass through and use Cochise Lakes, including: Ruddy Duck (Oxyura jamaicensis) (low 100s), Lesser Scaup (Aythya affinis) (occasionally 100+), Ring-necked Duck (Aythya collaris) (less than 50), and Cinnamon Teal (Anas cyanoptera) (less than 50). In rare very wet

www.tucsonaudubon.org | page 53 winters, waterfowl in huge numbers (greater than15,000, half of which are Green-winged Teal) come to feed and rest within the playa. Mallard (Anas platyrhynchos) “Mexican” ducks nest within the Willcox Playa Wildlife Area. Small numbers of Pied-billed Grebe (Podilymbus podiceps), and rarely Eared Grebe (Podiceps nigricollus) may also nest.

The sensitive, salty soils and halophilic plants of the alkaline (mud) lakes are important to feeding shorebirds and so are the margins of the playa and Cochise Lakes. Peregrine Falcon (Falco mexicanus) and Merlin (Falco columbarius) are frequently in the IBA in the winter preying on the duck and shorebird community.

Scaled Quail (Callipepla squamata) (Audubon WatchList 2007-Yellow), Cassin’s Sparrows (Aimophila cassinii) (AzPIF Priority 1999), Bendire’s Thrashers (Toxostoma bendirei) – very rare (IUCN Vulnerable, Audubon WatchList 2007-Red), and Swainson’s Hawks (Buteo swainsoni) (Audubon WatchList 2007-Yellow) nest on the perimeter of the playa. Occasionally, flocks of Chestnut-collared Longspurs (Calcarius ornatus) (March, October <100) (Audubon WatchList 2007-Yellow), and McCown’s Longspur (Calcarius mccownii) (National PIF WatchList 2004, Homer Hansen personal communication), over-winter and/or pass through during migration, foraging in the grasslands within this IBA.

The Willcox Playa is located in the Sulphur Springs Valley, an internationally recognized destination for birding ecotourism particularly highlighting raptors. Approaching their 22ncd year, the annual Wings Over Willcox Birding and Nature Festival generates visitors from all over the world and documents the species present in January http://www.wingsoverwillcox.com/species.asp. In addition to geese and cranes, the valley hosts the largest concentration of wintering hawks in the United States, providing winter habitat for 14 species of raptors, including Great Horned Owl (Bubo virginianus), Northern Harrier (Circus cyaneus), Prairie Falcon (Falco mexicanus), Bald (Haliaeetus leucocephalus) and Golden Eagle (Aquila chrysaetos), Harris's (Parabuteo unicinctus), Ferruginous (Buteo regalis), Red-tailed (Buteo jamaicensis), and Rough-legged (Buteo lagopus) Hawk. Ferruginous Hawks are regularly seen around colonies of Botta's Pocket Gophers (Thomomys bottae), their favorite prey.

www.tucsonaudubon.org | page 54 Willcox Playa Cochise Lakes IBA GIS Map - zoomed out

The DEIS states that the need for the proposed action arises from the Federal Land Policy and Management Act of 1976’s (FLPMA) establishment of a multiple use mandate for the management of federal lands. 43CFR 2801.2 specifies that BLM activities be done in a manner that: a) protects the natural resources associated with public lands and adjacent lands, whether private or administered by a governmental entity; b) prevents unnecessary or undue degradation to public lands; c) promotes the use of rights-of-way in common, considering engineering and technological compatibility, national security, and land use plans; and d) coordinates, to the fullest extent possible, all BLM actions under the regulations in this part with state and local governments, interested individuals, and appropriate quasi-public entities.

BLM is required to “minimize adverse impacts on the natural, environmental, scientific, cultural, and other resources and values (including fish and wildlife habitat) of the public lands involved.” 43 U.S.C. §1732(d)(2)(a). Unfortunately, the DEIS appears to have done just the opposite of what FLPMA mandates when considering the Willcox Playa Global IBA.

The proposed Southline Transmission project would significantly and adversely increase human disturbance of wildlife using the playa through direct mortality caused by collisions with power lines, through associated OHV use, and through increased predation rates caused by inadvertently enhancing local predator populations and/or by displacement of nesting, roosting, molting or foraging bird populations.

www.tucsonaudubon.org | page 55 Global IBA Summation:

As long ago as November 1988, the AZGFD found that 90 percent of the Arizona’s riparian habitat had been lost in Wildlife Views (AZGFD 1988). Some 80 percent of vertebrate species in the arid southwest region are dependent on riparian areas for at least part of their life cycle; over half of these cannot survive without access to riparian areas (Noss and Peters 1995). Arizona and New Mexico have lost 90 percent of pre-settlement riparian ecosystems (Fig 3e, Noss et al. 1995). Under Executive Order 11990, Federal agencies are required to minimize the destruction, loss, or degradation of wetlands, and preserve and enhance their natural and beneficial values. These habitats should be conserved through avoidance, or mitigation should occur to ensure no net loss of wetlands functions and values. BLM best management practices (BMPs) for wetlands must be used during construction, upgrades, and rebuilding of any proposed transmission lines and towers and support structures for transmission lines must be located outside the limits of the 100-year floodplain consistent with Executive Order 11988 on Floodplains. Construction and maintenance, not to mention public access and use, associated with placement and maintenance of a transmission line in or adjacent to riparian areas will degrade watershed hydro-geological processes and habitat in resources already imperiled by a decadal, if not historic, drought and climate change.

Therefore, we have grave concerns regarding the proposal to locate any portion of the transmission line within, or adjacent to, any wetland or riparian area. The San Pedro River watershed, the Willcox Playa and the Sulphur Springs Valley are all critical migratory and breeding corridors for millions of birds (4 million + annually), especially riparian dependent species, including some very sensitive species. This crucial portion of the Pacific flyway provides stop-over habitat for migrating avian species from the tip of South America to the Arctic. Recognized as supporting exceptional levels of biodiversity (400 bird species recorded), the San Pedro River watershed supports over half and nearly two-thirds of the avian diversity in the U.S. It contains high-quality examples of imperiled natural communities: the Fremont Cottonwood-Gooding Willow riparian community and old growth Mesquite bosques. These values conspire to designate the Upper and Lower San Pedro River and the Willcox Playa area as three of only fourteen Important Bird Areas in Arizona having “Global” status.

The Willcox Playa and the entire San Pedro River Valley watershed has been the focus of conservation and mitigation for many groups and agencies for decades. Roadways, towers and infrastructure construction and maintenance will lead to fragmentation of the habitat, reducing the value, functions, and biodiversity of the region. The Southline proposal, as described in the

www.tucsonaudubon.org | page 56 DEIS, would undermine and destroy much of the conservation work, partnerships, and mitigation activities that have taken place in the past to preserve the rare habitat of the Willcox Playa and would bisect the extremely important and bio-diverse north-south migration corridor of the San Pedro River Valley.

A new power line corridor, with multiple high towers, access roads, and habitat clearance, would severely compromise the significant Willcox Playa Globally Important Bird Area. BLM’s multiple use goals would be made a mockery of by this development, for it would destroy the extraordinary ecosystem function and services of this unique area, together with a range of other values and uses that these habitats support such as the economic contribution of the annual Wings Over Willcox Birding and Nature Festival. In short, both the Willcox Playa and the San Pedro River watershed are unique biological areas of global significance, true jewels in our region that we all should work to protect in perpetuity from various and diverse threats – some out of our control to influence and some, like this proposal, within our ability to avoid, minimize, and fully mitigate.

Respectfully submitted,

Christina McVie Dr. Paul Green Conservation Chair Executive Director

www.tucsonaudubon.org | page 57