United States Department of the Interior Bureau of Land Management

IP Athos LLC’s Athos Renewable Energy Project

Environmental Assessment

October 2019

CACA-57730

Publication Index #: DOI-BLM-CA-D060-2019-0016-EA

U.S. DEPARTMENT OF THE INTERIOR BUREAU OF LAND MANAGEMENT PALM SPRINGS-SOUTH COAST FIELD OFFICE

Environmental Assessment

EA Number: DOI-BLM-CA-D060-2019-0016-EA Case File: CACA 57730

Title/Proposed Action Type:

IP Athos Renewable Energy Project Generation-Tie Line

Applicant/Proponent: IP Athos, LLC

Location of Proposed Action: Riverside County, California

USGS Topographic Maps: East of Victory Pass, Corn Spring, & Sidewinder Well

October 2019

IP Athos Renewable Energy Project Generation-Tie Line CONTENTS

Contents

Chapter 1: Introduction ...... 1-1 1.1 Introduction ...... 1-1 1.2 Purpose and Need ...... 1-1 1.3 Land Use Conformance Statement ...... 1-2 1.4 Relationship to Laws, Regulations, and Other Plans ...... 1-3 1.5 Internal and External Scoping and Issues Statements ...... 1-3

Chapter 2: Proposed Action and Alternatives ...... 2-1 2.1 Alternative 1: Proposed Action...... 2-1 2.2 Alternative 2: Gen-Tie Segment #1 Alternative Route Option ...... 2-5 2.3 Alternative 3: No Action Alternative ...... 2-5 2.4 Alternatives Considered but Eliminated from Detailed Analysis ...... 2-5 2.5 Applicant Proposed Measures and DRECP CMAs ...... 2-6

Chapter 3: Affected Environment and Environmental Effects of Action ...... 3-1 3.1 Introduction ...... 3-1 3.2 Air Resources ...... 3-12 3.3 Cultural Resources ...... 3-14 3.4 Environmental Justice...... 3-21 3.5 Geology and Soils ...... 3-24 3.6 Global Climate Change ...... 3-27 3.7 Lands and Realty ...... 3-29 3.8 Noise ...... 3-31 3.9 Paleontological Resources ...... 3-33 3.10 Public Health and Safety ...... 3-36 3.11 Recreation ...... 3-39 3.12 Social and Economic Resources ...... 3-42 3.13 Special Designations ...... 3-44 3.14 Travel and Transportation ...... 3-46 3.15 Vegetation and Wildlife Resources ...... 3-49 3.16 Visual Resources ...... 3-54 3.17 Water Resources ...... 3-58 3.18 Wetland/Riparian Areas ...... 3-61 3.19 Wildland Fire Ecology ...... 3-63

Tables Table 2-1 APMs for the Athos Gen-Tie Project ...... 2-6 Table 3.1-1 Past and Present Projects or Programs in the Proposed Action Area ...... 3-5 Table 3.1-2 Probable Future Projects in the Proposed Action Area ...... 3-8 Table 3.2-1 Proposed Solar Facility and Gen-Tie Line Maximum Daily Construction Emissions ...... 3-13 Table 3.3-1 Cultural Resources Within the Direct APE Determined Eligible for the NRHP ..... 3-16 Table 3.4-1 Racial Characteristics and Poverty Status ...... 3-22 Table 3.9-1 Distribution of Paleontological Sensitivity Throughout the Proposed Action Area ...... 3-34 Table 3.11-1 Recreation Areas and Special Designations with Recreational Opportunities ...... 3-39 Table 3.12-1 Socioeconomic Characteristics ...... 3-42

October 2019 i Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CONTENTS

Figures Figure 1-1 Project Vicinity Figure 1-2 DRECP Context Figure 2-1 Athos Solar and Athos Gen-Tie Project Figure 2-2 Proposed Gen-Tie Lines on BLM-Administered Land Figure 2-3 Typical 220 kV Gen-Tie Line Structures Figure 2-4 Typical 34.5 kV Medium Voltage Line Structures Figure 2-5 Gen-Tie Segment #1 Alternative Route Option Figure 3.1-1 Cumulative Projects Figure 3.9-1 Paleontological Sensitivity in the Project Area Figure 3.11-1 BLM Open Routes in Athos Renewable Energy Project Area Appendices Appendix A Acronyms and Abbreviations Appendix B Consultation and Coordination Appendix C List of Preparers and Contractors Appendix D Maps and Figures Appendix E References Appendix F Plan of Development Appendix G Regulatory Framework Appendix H Mitigation Measures and CMAs Appendix I CEQA Scoping Summary Report Appendix J Indirect Effects

October 2019 ii Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 1: INTRODUCTION

Chapter 1: Introduction 1.1 Introduction The Bureau of Land Management (BLM) has prepared this Environmental Assessment (EA) pursuant to the National Environmental Policy Act of 1969 (NEPA, 42 U.S.C. Section 4321), Council on Environmental Quality (CEQ) regulations (40 Code of Federal Regulations [CFR] Parts 1500–1508), and BLM NEPA Handbook H-1790-1. This EA evaluates the environmental effects of constructing, operating, maintaining, and decommissioning a proposed 34.5 kilovolt (kV) and/or 220 kV single-circuit generation interconnection (gen-tie) transmission line across land administered by the BLM to connect the proposed IP Athos Renewable Energy Project (Athos Solar), a utility-scale solar photovoltaic (PV) electrical generating and storage facility, to the statewide electricity transmission grid in the County of Riverside, California (see Figure 1-1, Project Vicinity). All figures referenced in this EA are provided in Appendix D.

1.1.1 Agency Roles and Responsibilities An application (SF-299) was received by BLM from IP Athos, LLC (Proponent or Applicant) for the IP Athos Renewable Energy Project Generation-Tie Line (Athos Gen-Tie/Proposed Action) and serialized CACA-57730. A Conditional Use Permit and Public Use Permit applications for the solar facility and gen-tie components on private land were also approved by the County of Riverside (Riverside County) on June 18, 2019. This EA is prepared by the BLM as the lead agency under the NEPA and Riverside County has prepared a separate Environmental Impact Report (EIR) as the lead agency under the California Environmental Quality Act (CEQA).

1.2 Purpose and Need 1.2.1 Proponent’s Purpose and Need The Proponent’s purpose for the proposed Athos Gen-Tie line is to interconnect and transmit the energy generated by the Athos Solar Project into the statewide electricity transmission grid. The Red Bluff Substation is surrounded by BLM-administered lands and the only means of connecting the solar facility to the existing substation is with a new right-of-way (ROW) that traverses BLM‐administered lands. The Proponent’s need for the Proposed Action is to:

 Assist with achieving renewable energy generation goals under the Clean Energy and Pollution Reduction Act of 2015 (Senate Bill 350) and greenhouse gas (GHG) emissions reduction goals of the California Global Warming Solutions Act of 2006 (AB 32), as amended by Senate Bill 32 in 2016;

 Bring living-wage jobs to eastern Riverside County;

 Minimize environmental impacts and land disturbance associated with solar development and associated gen-tie lines by siting the project on relatively flat lands in close proximity to established utility corridors, existing transmission lines with available capacity to facilitate interconnection, and road access;

October 2019 1-1 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 1: INTRODUCTION

 Further the purpose of Secretarial Order 3285A1, establishing the development of environmentally responsible renewable energy as a priority for the Department of the Interior; and

 Make the highest and best use of primarily disturbed land in and around a federal “Solar Energy Zone” and “Development Focus Area” to transmit affordable, wholesale solar electricity.

1.2.2 BLM’s Purpose and Need BLM’s purpose is to review and evaluate the Proposed Action and need is to respond to the ROW application submitted by the Proponent to construct, operate, maintain, and decommission a gen-tie line on public lands in compliance with Federal Land Policy and Management Act of 1976 (FLPMA, 43 United States Code [USC] Section 1761(a) (4)), BLM right-of-way regulations, and other applicable federal laws and policies.

1.2.3 Decision to be Made by BLM The BLM will decide whether to deny IP Athos, LLC’s right-of-way application, grant the right-of way, or grant the right-of-way with modifications. Modifications may include revising the proposed gen-tie routes or location of the proposed gen-tie facilities (43 CFR 2805.10(b)(1)).

1.3 Land Use Conformance Statement The solar facility site and a portions of the gen-tie are located on lands within Riverside County’s jurisdiction. The gen-tie lines would traverse mainly BLM-administered public lands within the Riverside East Solar Energy Zone (SEZ) of BLM’s Western Solar Plan (2012), which was carried forward and modified as a Development Focus Area (DFA) under the Desert Renewable Energy Conservation Plan (DRECP; 2016). The Western Solar Plan and DRECP amended the California Desert Conservation Area (CDCA) Plan to allow for development of solar energy generation and appurtenant facilities on public lands in this specific area (see Figure 1-2). As part of a DFA, the Project area has been designated as suitable for renewable energy development and energy accessory uses, and the proposed use would be compatible with the CDCA Plan, as amended, including utility corridors. A Plan Amendment would not be required for construction of the proposed Athos Gen-Tie lines (see LUPA-LANDS-8 [“[t]ransmission facilities may be located outside of designated corridors within DFAs without a plan amendment”] and DFA-LANDS-7 [“[t]ransmission facilities are an allowable use and will not require a plan amendment within DFAs”]).

A portion of the Athos Gen-Tie line would also be sited within the Section 368 Federal Energy Corridor as established by the Westwide Energy Corridor (WWEC) Final Programmatic Environmental Impact Statement (PEIS) and Record of Decision (2009). South of Interstate 10, the Athos Gen-Tie line would also cross the Chuckwalla Area of Critical Environmental Concern (ACEC) paralleling an existing gen-tie corridor for the Desert Sunlight Solar Farm and approved Palen Solar Project, Desert Harvest Solar Facility, and Eagle Crest Energy Project that connect to the existing Southern California Edison (SCE) Red Bluff Substation. In addition to the DRECP and WWEC, the Northern and Eastern Colorado Desert Management Coordinated Management (NECO) Plan also amends the CDCA and includes management of NECO routes within the

October 2019 1-2 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 1: INTRODUCTION project area. To the extent possible, existing routes should be utilized to provide access for maintenance of new ROWs.

The Proposed Action would comply with all applicable DRECP Conservation Management Actions (CMAs) (see EA Appendix H).

1.4 Relationship to Laws, Regulations, and Other Plans The Proposed Action would also comply with all applicable statutes and regulations. The statutes and regulations relevant to the various resource areas affected by the Proposed Action are identified in EA Appendix G.

1.5 Internal and External Scoping and Issues Statements Based on input received during the DRECP public scoping meetings, internal scoping, scoping under the CEQA (for solar facility and gen-tie components), and review of site-specific issues and resources affected, no additional public scoping meetings are proposed. Concerns expressed by the public and agencies on the potential impacts of the Proposed Action and solar facility components during the CEQA scoping period included the following resource areas: aesthetics, agricultural resources, air quality, biological resources, cultural and paleontological resources, hazards and hazardous materials, hydrology and water quality, land use, noise, property access, public services, and traffic and circulation (see EA Appendix I).

October 2019 1-3 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 2: PROPOSED ACTION AND ALTERNATIVES

Chapter 2: Proposed Action and Alternatives IP Athos, LLC (Proponent or Applicant), a subsidiary of Intersect Power, proposes to construct, operate, maintain, and decommission a 220 kilovolt (kV) generation interconnection transmission line and 34.5 kV medium voltage generation interconnection power line (Athos Gen-Tie or Proposed Action) across land administered by the BLM to connect to the IP Athos Renewable Energy Project (Athos Solar), a 500 megawatt (MW) utility-scale solar photovoltaic (PV) electrical generating and integrated energy storage facility, to the statewide electricity transmission grid.

The Athos Solar facility and Athos Gen-Tie line are located on a total of approximately 3,400 acres linking 7 groups of non-contiguous parcels in the Desert Center area of Riverside County (see Figure 2-1 in Appendix D). The renewable energy facility sites would occupy approximately 3,224 acres of largely disturbed (retired agricultural), privately-owned land1. The portion of the 220 kV and 34.5 kV gen-tie lines outside of the solar facility sites would be overhead or under- ground, and located within a 100-foot ROW on approximately 7 miles (approximately 90 acres) of Federal lands managed by the BLM, Palm Springs–South Coast Field Office. Temporary disturbance from pull and tensioning for an overhead line may extend outside of the 100-foot ROW into previously-surveyed areas, which would be covered under a short-term ROW. The remainder of the gen-tie facilities would traverse approximately 4 miles of privately-owned land, primarily within the solar facility sites2.

The power produced by the Athos Solar Project would be conveyed to the statewide power grid via the proposed interconnection to the SCE Red Bluff Substation, an existing substation located south of Interstate 10 (I-10) and approximately 1.1 miles south of the Athos Solar Project area3 on land administered by the BLM. Modifications to existing substation equipment would be performed by SCE within its existing fence line to accommodate the Athos Gen-Tie interconnection at Red Bluff Substation.

2.1 Alternative 1: Proposed Action IP Athos, LLC proposes to construct approximately 7 miles of 34.5 kV and/or 220 kV gen-tie transmission lines on BLM-administered land (in addition to 4 miles on private lands) in the following 4 segments (see Figures 2-1 and 2-2 in Appendix D). The proposed gen-tie would be constructed mainly overhead with some sections underground within a ROW up to 100 feet in

1 Since publication of the Draft EIR, IP Athos, LLC has committed to removing approximately 23 acres of the highest value, contiguous, undisturbed habitat in the Project area from development at the eastern end of Parcel Group F (17 acres of desert dry wash woodland and 6 acres of creosote scrub), as shown on the site plan in POD Appendix A in EA Appendix F. 2 Gen-Tie Segment #1 would cross 0.5 mile of land owned by the Metropolitan Water District of Southern California, which BLM retains a reversionary interest, otherwise it is treated as private land. In addition, Gen-Tie Segment #2 in Parcel Group E would cross a parcel of State-owned land under jurisdiction of the California State Lands Commission. Both parcels are considered within the private land component for this analysis, as they are subject to CEQA. 3 The term “Project area” refers to the proposed up to 500 MW solar PV facility, substations, battery storage area, and 11 miles of 220 kV and 34.5 kV gen-tie lines that would connect the solar facility to regional electric transmission grid at the Red Bluff Substation (approximately 3,400 acres). The term “solar facility site” is defined as the area within the Project area boundary consisting of 3,224 acres of privately-owned land across 7 groups of non-contiguous parcels on which the solar PV facility, substations, and battery storage area would be developed.

October 2019 2-1 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 2: PROPOSED ACTION AND ALTERNATIVES width. The underground segments of gen-tie line at 220 kV and/or 34.5 kV would minimize potential conflicts with existing and approved utilities and visual resources impacts:

 Gen-Tie Segment #1 (0.8 mile of 34.5 kV gen-tie line on BLM-administered land): Gen-Tie Segment #1 would extend for a total of 2.5 miles due south from the southern end of the northernmost group of solar facility parcels (Parcel Group A) to join Gen-Tie Segment #2 at the Athos Solar Project Substation in Parcel Group C. Gen-Tie Segment #1 would be constructed at 34.5 kV either overhead on wooden poles or underground in the proposed gen-tie access road.

 Gen-Tie Segment #2 (1.2 miles of 34.5 kV and 220 kV gen-tie lines on BLM-administered land): Gen-Tie Segment #2 would travel south from the Athos Solar Project Substation and switchyard across solar facility parcels in Parcel Group C to where it would join Gen-Tie #4 at the private solar facility substation, approximately 1.1 miles north of the Red Bluff Substation. Gen-Tie Segment #2 would be constructed at 220 kV overhead on tubular steel poles or wooden H-frame structures with 34.5 kV lines either underbuilt on the 220 kV structures or trenched underground in the proposed gen-tie access road.

 Gen-Tie Segment #3 (4 miles of 34.5 kV gen-tie line on BLM-administered land): Gen-Tie Segment #3 would extend west from the western end of the easternmost group of solar facility parcels (Parcel Group G) across BLM-administered land adjacent to the Palen Solar Project’s 230 kV transmission line into the Athos Solar Project Substation at the southern boundary of the south-central solar facility site parcel (Parcel Group F). Here Gen-Tie Segment #3 would join Gen-Tie Segment #4, approximately 1.1 miles north of the Red Bluff Substation. Gen-Tie Segment #3 would be constructed at 34.5 kV either overhead on wood poles or underground directly buried in the adjacent Project access road. Based on final engineering, short segments may be bored using directional drilling under the access roadway to avoid sensitive resources.

 Gen-Tie Segment #4 (1.1 miles of 220 kV gen-tie line on BLM-administered land): Gen-Tie Segment #4 would extend for 1.1 miles due south from the Athos Solar Project Substation located on the south-central solar facility site parcel (Parcel Group F), crossing Interstate 10 and terminating at SCE’s existing Red Bluff 500/230 kV Substation. Gen-Tie Segment #4 would be adjacent to the Desert Sunlight existing 220 kV transmission line. This segment would be constructed at 220 kV primarily overhead on steel poles. However, depending on final engineering, a short segment (up to 500 feet) of underground 220 kV line may be constructed in the proposed gen-tie access road from the Athos Solar Project Substation on Parcel Group F to cross under the existing Desert Sunlight and Desert Harvest ROWs on BLM-administered land before transitioning overhead and continuing south to the Red Bluff Substation.

For the overhead 220 kV or 34.5 kV gen-tie line, structure foundations would be excavated to an average depth of 13 feet and 9.5 feet, respectively, with a maximum depth of 35 feet, including concrete supports depending on final engineering. Gen-tie structures for the 220 kV line would be on average 110 feet tall. The typical height of the 34.5 kV poles would be approximately 55

October 2019 2-2 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 2: PROPOSED ACTION AND ALTERNATIVES feet, with diameters varying from 12 to 14 inches. The total number of gen-tie support structures, either wooden or steel, would be up to 80 structures on BLM-administered land depending on final engineering. A 3-phase single-circuit 34.5 kV and/or 220 kV conductor would be strung along the gen-tie structures, which would also be equipped with a ground wire and a telecom- munications fiber-optic cable to service the solar facility, gen-tie line, and ancillary facilities. The solar facility’s Supervisory Control and Data Acquisition System (SCADA) system, which provides remote monitoring of facility operation and/or remote control of critical components, would externally interconnect through the telecommunications system at the Red Bluff Substation. All structures would be lower than the 200-foot height standard that triggers Federal Aviation Administration Part 77 Obstruction Evaluation Consultation, so no aviation lighting is required.

See Figures 2-3 and 2-4 in Appendix D for a depiction of typical 34.5 kV and 220 kV gen-tie structures that may be utilized in the event that IP Athos, LLC is unable to coordinate double- circuit collocation with other solar developers in the area for Gen-Tie Segment #4.

Based on crossing arrangements with existing ROWs, portions of the Athos Gen-Tie may be constructed underground either at 34.5 kV and/or at 220 kV. If underground construction of the collector gen-tie lines occurs, the lines would be buried within existing access roads to utilize disturbance areas. The underground lines would be constructed using direct bury equipment or using ordinary trenching techniques, which typically include a rubber-tired backhoe excavator or trencher. Short segments would be bored using directional drilling in order to avoid sensitive resources and/or conflicts with existing underground utilities (see POD, EA Appendix F, Figure 9 in Appendix A of the POD).

Wire depths would be in accordance with local, State, and Federal requirements. An underground 34.5 kV electrical collector gen-tie line would likely be buried at a minimum of 36 inches below grade but could go as deep as 6 feet to avoid infrastructure of prior ROW holders (e.g., buried fiber-optic cable, water lines) or environmental resources. Up to 4 trenches would be excavated along the entire length of the proposed line, with each trench up to approximately 4 feet wide to accommodate direct buried cables. After excavation, cable rated for direct burial would be installed in the trench, and the excavated soil would be used to fill the trench and compressed to 90 to 95 percent maximum dry density or in accordance to final engineering. The total extent of cable trenching would occur entirely within access roads.

If a short segment (up to 500 feet) of underground 220 kV construction would be required to cross existing ROWs on BLM-administered land, a trench approximately 4 to 6 feet wide and approximately 6 feet deep would be excavated, and cables would be direct buried or possibly installed within a duct bank. Wire depths would be in accordance with local, State, and Federal requirements, and would likely be buried at a minimum of 36 inches below grade. The disturbed roadway surface (approximately 0.7 acres) would be restored.

As discussed above, short segments would be bored using horizontal directional drilling (HDD) in order to avoid sensitive resources. HDD is a highly specialized boring technique that is a trenchless method of conduit installation using a surface-launched drilling rig that installs the conduit via a pre-drilled, arc-like bore hole. Prior to construction, these areas, including a 30-foot buffer or as directed by BLM, would be identified, flagged, and taped off in the field for avoidance.

October 2019 2-3 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 2: PROPOSED ACTION AND ALTERNATIVES

For the purposes of NEPA analysis, this EA assumes a worst-case scenario of construction of a new gen-tie line overhead and/or underground.

Access Roads. The proposed gen-tie line would use the same access roads as the approved solar facility. Access to the Proposed Action site would be from State Route 177 (SR-177). BLM open routes and agricultural roads would be used and improved, as specified in the final engineering drawings. Figure 3.11-1 in EA Appendix D shows the existing BLM open routes.

The roadways would be up to 24 feet wide with an anticipated soil spillover of 2 feet on each shoulder during construction to accommodate large equipment access. They would be restored to pre-project conditions or as 12-foot wide double-track roads at the conclusion of construction. The proposed access roads on BLM-administered land are listed below and shown on Figure 2-1 (see EA Appendix D).

 Gen-Tie Segment #1 access road – 0.8 miles of new road construction over most of length.

 Parcel Group C to Parcel Group D access road – 0.1 miles of new road construction linking Parcel Groups C and D diagonally across a shared corner.

 Gen-Tie Segment #2 access road – 1.2 miles of new road construction.

 Gen-Tie Segment #3 access road – 3.8 miles along existing narrow access route. The existing road would need to be widened, requiring nearly four miles of road improvement. In areas of sensitive resources, the roadway would be improved, but not be widened. If the approved Palen Solar Project access route is constructed first, then IP Athos, LLC, would use the existing access road and would not need to improve the road.

 Gen-Tie Segment #4 access road – (<1 mile of BLM-administered land for spur roads and undergrounding): Existing Desert Sunlight gen-tie and access route to Red Bluff Substation. Spur roads would be required, but no new access road construction expected.

Water Requirements. Water for construction-related dust control and operations would be obtained from several potential sources, including a private on-site or off-site groundwater well, or trucked from an offsite water purveyor. During the construction phase, it is anticipated that a total of up to 75 acre-feet would be used for dust suppression (including truck wheel washing) and other purposes during the 6-month construction timeframe of the gen-tie lines. During construction, restroom facilities would be provided by portable units to be serviced by licensed providers. During operation, minimal water would be required for the gen-tie line (see Appendix N in the POD and EA Appendix F).

Construction Schedule and Workforce. Gen-tie construction would occur over a 6-month period generally during daytime hours and may be phased based on the anticipated 30-month construction of the proposed solar facility. Gen-tie work would begin with geotechnical borings at structure locations (2 field days) and approximately 2 months of testing and final design, followed by 3 months of construction activities on BLM-administered land. Once the gen-tie line is installed, restoration of temporary disturbance areas would take approximately 1 month in accordance with the Vegetation Resources Management Plan (see Appendix T in the POD, which is EA Appendix F) and other applicable Conservation and Management Actions (CMAs)

October 2019 2-4 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 2: PROPOSED ACTION AND ALTERNATIVES

(see EA Appendix H). The onsite total workforce for the gen-tie construction is expected to average approximately 20 individuals.

The Plan of Development (POD), included as Appendix F of the EA, contains the full details of all activities proposed including construction, restoration, operations and decommissioning.

2.2 Alternative 2: Gen-Tie Segment #1 Alternative Route Option A route alternative for Gen-Tie Segment #1 has been developed due to challenges obtaining landowner easements on private land under the Proposed Action. Under this alternative, the 220 kV or 34.5 kV line would exit Parcel Group A approximately 0.2 mile east of its currently proposed location on Parcel Group A. The gen-tie alternative would head due south onto BLM- administered land for approximately 0.25 mile before turning southeast for almost 0.3 mile and south for 0.15 mile to enter private land (see Figure 2-5 in Appendix D). On private land, the alternative route would turn due west and travel 0.45 mile to rejoin Gen-Tie Segment #1 (see Figure 2-4 in Appendix D). The Alternative Gen-Tie Segment #1 Route Option would be approximately 0.65 mile longer (1.15 miles compared to 0.5 mile with this segment of the Proposed Action), but it would enable energy generated from the northernmost group of Project parcels to be transmitted to the SCE Red Bluff Substation should negotiations with landowners fall through.

2.3 Alternative 3: No Action Alternative Under the No Action Alternative, the construction of a solar generating facility and associated infrastructure, including the 220 kV and 34.5 kV gen-tie lines, would not occur. This alternative discusses existing conditions as well as what would be reasonably expected to occur in the foreseeable future if the approved Athos Solar Project is not constructed.

2.4 Alternatives Considered but Eliminated from Detailed Analysis To minimize disturbance and other environmental impacts, the proposed Athos gen-tie lines have been routed to most directly connect the Athos Solar Project substations and to parallel the gen-ties associated with other existing and proposed solar projects in the area to the maximum extent feasible. In addition, as part of the Proposed Action, IP Athos, LLC has considered design options that would install segments of 34.5 kV collector lines underground in the place of portions of the overhead gen-tie line to reduce potential conflicts with other existing and approved projects and operational visual impacts.

An alternative where the solar facility in addition to the gen-tie line would be sited on BLM- managed lands in the Desert Center area instead of private lands has also been considered. This alternative would be located within the Riverside East Solar Energy Zone (SEZ) of BLM’s Western Solar Plan and a Desert Renewable Energy Conservation Plan (DRECP) DFA. This alternative would require a BLM ROW Grant to allow for the construction and operation of solar facilities within BLM-managed lands. Siting the entire Athos project on BLM-managed lands would not likely reduce any potentially significant impacts from the proposed Athos Solar Project, as the Proposed Action is sited primarily on previously disturbed lands with minimal resource value. This alternative would likely have more severe biological, cultural, and visual resource

October 2019 2-5 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 2: PROPOSED ACTION AND ALTERNATIVES impacts, as it would likely be located on undisturbed lands. Also, it may not be feasible to find an alternative site on BLM-managed lands, because most of the land within the DFA and Developable Areas of the Riverside East SEZ is in use, proposed for other solar energy projects, or within mountainous areas. Siting the Athos Solar Project on BLM-administered land would not present significant environmental advantages over the proposed Action and has thus been eliminated from consideration.

Because of the existing and approved projects in the area, including other ROWs or easements, there are no other reasonable alternatives that would be substantially differ in route, design or effects than the alternatives already considered. Therefore, no other action alternatives are evaluated in this EA.

2.5 Applicant Proposed Measures and DRECP CMAs The Proponent has designed the gen-tie line to conform with the DRECP CMAs and proposes to employ applicable construction- and operation-phase CMAs identified in the DRECP ROD and Land Use Plan Amendment (LUPA) for the gen-tie line on BLM-administered land (EA Appendix H).

In addition to the CMAs, Table 2-1 provides a list of Applicant-proposed measures (APMs) specific for the Athos Gen-Tie Project. IP Athos, LLC commits to complying with these measures to reduce potential impacts during construction and operation.

Table 2-1. APMs for the Athos Gen-Tie Project APM Number Issue Area Biological Resources APM B-1 Wildlife Relocation. The Applicant will prepare and implement a Wildlife Relocation Plan to ensure that special-status wildlife species, including (but not limited to) desert tortoise, burrowing owl, and desert kit fox, are safely avoided or relocated off the Athos Gen-Tie and Athos Solar Project sites prior to construction. The Wildlife Relocation Plan will conform to USFWS guidelines for desert tortoise surveys, avoidance, and relocation, and to CDFW guidelines for burrowing owl and desert kit fox passive relocation, including scheduling to avoid disturbance to natal dens or burrows. The Wildlife Relocation Plan will specify methodology for pre-construction clearance surveys on the proposed solar facility and gen-tie routes; monitoring or tracking special-status species, burrows, or dens that may be located during the surveys; construction of off-site artificial burrows if needed; avoidance to allow for wildlife to safely move out of harm’s way, or methods for localized “out of harm’s way” or desert tortoise relocation; passive relocation methods for burrowing owl or desert kit fox; qualifications of field personnel who may handle desert tortoises; and follow-up monitoring of translocated animals. Transportation and Traffic APM T-1 Public Easement Access. All designated public roadway easements directly impacted by the solar facility will remain open to the public during construction and operation as not to preclude access to nearby properties.

October 2019 2-6 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 2: PROPOSED ACTION AND ALTERNATIVES

Table 2-1. APMs for the Athos Gen-Tie Project APM T-2 Alternative Routes. If any designated vehicle routes are temporarily impacted by project activities, the Proponent will develop alternative routes to allow for continued vehicular access. Traffic Safety Coordinator(s) will oversee the installation of proper signage to ensure safe public use of open routes and other recreation opportunities on public lands in the Athos Gen-Tie Project area.

October 2019 2-7 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 3: AFFECTED ENVIRONMENT AND ENVIRONMENTAL EFFECTS OF ACTION

Chapter 3: Affected Environment and Environmental Effects of Action 3.1 Introduction This chapter presents the affected environment and an assessment of the potential direct, indirect, and cumulative impacts of the Proposed Action and alternatives to construction of the 220 kV and 34.5 kV gen-tie line project located on BLM-administered lands (Athos Gen-Tie). Appendix G in this Environmental Assessment (EA) contains a brief discussion of the regulatory framework (i.e., Federal, state, and local laws and/or plans that are relevant to the EA). The impact analysis also considers the full implementation of all applicable Conservation and Management Actions (CMAs) in conformance with the DRECP. Additional mitigation measures (MM) have been identified for the Proposed Action for air resources, cultural resources, environmental justice, geology and soils, noise, paleontology, public health and safety, travel and transportation, vegetation and wildlife resources, visual resources, water resources, wetland- riparian resources and wildland fire ecology. Appendix H in this EA contains the full text of all required mitigation measures and the applicable DRECP CMAs.

The effects of the Athos Solar Project are considered indirect effects of the Athos Gen-Tie, as explained in Section 3.1 (Environmental Documents Used), and summarized in EA Appendix J (Indirect Effects).

3.1.1 Resources Not Present and/or Not Affected by the Proposed Action This section presents a description of the environment and social settings for all potentially affected resources. This chapter does not provide details about environmental resources that would not be affected by or that are not present within the Athos Gen-Tie (Proposed Action) vicinity. These include the resources listed below, each with an explanation for why they are not evaluated.

 Cooperative Management and Protection Areas: There are no Cooperative Management and Protection Areas in the Proposed Action area.

 Back Country Byways: There are no designated Back Country Byways that would be affected by the Proposed Action.

 Forest Reserves: There are no Forest Reserves on or near the Proposed Action.

 Livestock Grazing: There are no livestock grazing leases on or near the Proposed Action.

 Mineral Resources: There are no active mining claims, mineral leases, mineral materials sales, or mineral materials contracts within the Proposed Action area. Sand and gravel are the only known mineral resources present in the area. The 100-foot ROW could cross areas where BLM could potentially issue mineral materials contracts or free-use permits for this resource. However, similar resources are available on surrounding Federal lands, and the Proposed Action will not reduce or restrict the availability of sand and gravel resources beyond the individual pole locations. Thus, the Proposed Action would not infringe on any available mineral resources in the area.

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 National Monuments: There are no National Monuments on or near the Proposed Action. The 2016-designated Mojave Trails National Monument is about 20 miles north of the proposed gen-tie lines.

 Wild Horses and Burros: There are no Wild Horses and Burros Management Areas near the Proposed Action.

 Wild and Scenic Rivers: There are no Wild and Scenic Rivers near the Proposed Action.

 Wilderness Characteristics: There are no lands managed to protect wilderness characteristics located within a Development Focus Area. The nearest lands managed to protect wilderness characteristics are over 4 miles east of the Athos Gen-Tie Project with the approved Palen Solar Project situated in between.

3.1.2 Environmental Documents Used For a discussion of indirect effects of the Athos Solar Project, this EA relies on the IP Athos Renewable Energy Project Final EIR (Athos EIR) prepared by Riverside County, which analyzes the proposed solar facility and associated facilities under Riverside County’s jurisdiction (Riverside County, 2019). The Athos EIR can be found online on the County’s Athos Solar Project website at: https://planning.rctlma.org/Home/PlanningNotices/AthosRE.aspx

Indirect effects of the proposed solar facility and components under Riverside County’s jurisdiction are summarized in EA Appendix J.

3.1.3 Cumulative Scenario A cumulative impact is the impact on the environment that results from the incremental impact of a proposed action when added to other past, present, and reasonably foreseeable future actions regardless of which agency (Federal or nonfederal) or person undertakes such other actions (40 Code of Federal Regulations (CFR) Section 1508.7). Further, “[c]umulative impacts can result from individually minor but collectively significant actions taking place over a period of time” (40 CFR Section 1508.7). The CEQ recommends that agencies “look for present effects of past actions that are, in the judgment of the agency, relevant and useful because they have a significant cause-and-effect relationship with the direct and indirect effects of the proposal for agency action and its alternatives” (36 CFR Section 220.4[f]).

As with direct impacts, agencies evaluate the significance of cumulative impacts by considering their context and intensity. The intensity, or severity, of the cumulative impacts analysis considers the magnitude, geographic extent, duration and frequency of the effects (CEQ, 1997). The magnitude of the effect reflects the relative size or amount of the effect; the geographic extent considers how widespread the effect may be; and the duration and frequency refer to whether the effect is a one-time event, intermittent or chronic (CEQ, 1997). Varying degrees of information exist about projects within the cumulative scenario. Therefore, for resource areas where quantitative information is available, a quantitative analysis is provided. By contrast, where quantitative information is not available, a qualitative analysis is provided. Consistent with BLM Handbook H-1790-1, Section 6.8.3.1, if neither the Proposed Action nor alternatives would have

September 2019 3-2 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 3: AFFECTED ENVIRONMENT AND ENVIRONMENTAL EFFECTS OF ACTION direct or indirect effects on a resource or resource use or program area, the EA does not analyze potential cumulative effects related to that resource.

Assumptions for Analysis With the exception of climate change, which is a global issue, the BLM has identified the Cali- fornia desert as the largest area within which cumulative effects should be assessed for all disciplines. However, within the desert region, the specific area of cumulative effect varies by resource. For each resource, the geographic scope of analysis is based on the topography sur- rounding the Athos Gen-Tie Project site and the natural boundaries of the resource affected, rather than jurisdictional boundaries. The geographic scope of cumulative effects often extends beyond the scope of the direct effects, but not beyond the scope of the direct and indirect effects of the Proposed Action and alternatives.

This cumulative impact analysis considers other projects that have been recently completed, are currently under construction, or are reasonably foreseeable (e.g., for which an application has been submitted). The cumulative projects are presented in:

 Table 3.1-1, Past and Present Projects or Programs in the Proposed Action Area

 Table 3.1-2, Probable Future Projects in the Proposed Action Area.

Both short-term and long-term cumulative impacts of the Proposed Action and alternatives, in conjunction with other cumulative projects in the area, are evaluated in Chapter 3. Each resource analysis considers these projects and lists the projects included in their cumulative geographic scope in their respective sections. Figure 3.1-1 (Cumulative Projects: Existing and Foreseeable; see EA Appendix D) presents the location and extent of each cumulative project listed on the two tables (identified by letters and numbers) to the corresponding map.

The schedule and timing of the Proposed Action and other cumulative projects is relevant to the consideration of cumulative impacts. Each project in a region will have its own implementation schedule, which may or may not coincide or overlap with the construction schedule for Athos. This is a consideration for short-term impacts from the Athos Gen-Tie. However, to be conservative, the cumulative analysis assumes that all projects in the cumulative scenario are built and operating during the operating lifetime of the Athos Gen-Tie.

Past, Present and Reasonably Foreseeable Future Actions Desert Center Area Plan. As part of the Riverside County General Plan Update (2015), the County updated the Desert Center Area Plan. The Desert Center Land Use Plan reflects the limited development potential in this region. The Area Plan designates most of the area Open Space-Rural, with some Agriculture, rural residential, and other low-density residential and commercial opportunities. The Area Plan notes that future development on the private land should focus on infill and contiguous expansion of the existing communities at Desert Center and Lake Tamarisk but is likely to be limited (Riverside County, 2015). This information was taken into consideration by the authors when drafting the cumulative analysis as it indicates limited development on private land. Table 3.1-1 and Table 3.1-2 include the list of past and present actions in the Desert Center and Blythe region. These projects are shown on Figure 3.1-1.

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Table 3.1-1. Past and Present Projects or Programs in the Proposed Action Area Project Name; ID Agency ID Location Ownership Status Acres Project Description 1 West-wide Section Riverside BLM, DOE, U.S. Forest Approved by BLM N/A Designation of corridors on Federal 368 Energy County, Service and U.S. Forest land in the 11 western states, Corridors parallel to I-10 Service, additional including California, for oil, gas, and review of Region 1 hydrogen pipelines and electricity ongoing transmission and distribution facilities (energy corridors). One of the corridors runs along the southern portion of Riverside County. Overlaps with BLM Utility Corridor K in this region. 2 Blythe PV Project Blythe NRG Energy Operational 200 21 MW solar PV project located on 200 acres outside of Blythe. 3 McCoy Solar Blythe NextEra Operational 8,100 An up to 750 MW solar PV project Project located primarily on BLM- administered land about 13 miles north of Blythe. The Project includes a 16-mile gen-tie line. The first 250 MW began commercial operation in June 2016. 4 Genesis Solar North of I-10, 25 NextEra Operational 1,950 250 MW solar trough project on Energy miles west of 4,640 acres north of the Ford Dry Project Blythe and 27 Lake. Project includes six-mile miles east of natural gas pipeline and a 5.5-mile Desert Center gen-tie line to the Blythe Energy Center to Julian Hinds Transmission Line, then travel east on shared transmission poles to the Colorado River Substation.

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Table 3.1-1. Past and Present Projects or Programs in the Proposed Action Area Project Name; ID Agency ID Location Ownership Status Acres Project Description 5 Blythe Solar Power Blythe NextEra Portion operational. 4,100 485 MW solar PV project located 2 Project Currently under miles north of I-10 and 8 miles west construction of the City of Blythe on BLM- administered land. A 230 kV gen-tie line connects the solar energy generating facility to the SCE Colorado River Substation. 6 Desert Sunlight 6 miles north of NextEra Operational 4,400 550 MW solar PV project located on Solar Desert Center BLM-administered land. The project Project includes a 230 kV transmission line that extends south from the Solar Farm site and interconnects with the Red Bluff Substation. 7 SCE Red Bluff Southeast of SCE Operational 75 220/500 kV substation interconnects Substation Desert Center with renewable projects near Desert Center to the existing DPV2 trans- mission line. 8 Devers–Palo Verde From Palo SCE Operational N/A Existing 500 kV transmission line No. 1 Transmission Verde, Arizona, to parallel to I-10 from Arizona to the Line Devers SCE Devers Substation, near Palm Substation near Springs. DPV1 loops into the SCE Palm Springs Colorado River Substation located 10 miles southwest of Blythe. 9 Devers–Palo Verde From Blythe to SCE Operational N/A Existing 500 kV transmission line No. 2 Transmission Devers parallel to I-10 from the SCE Line (also called Substation near Colorado River Substation to the Devers-Colorado Palm Springs Devers Substation, near Palm River Transmission Springs. Line) 10 Blythe Energy From Blythe to Blythe Energy, LLC Operational N/A Existing 230 kV transmission line. Project Julian Hinds Transmission Line Substation

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Table 3.1-1. Past and Present Projects or Programs in the Proposed Action Area Project Name; ID Agency ID Location Ownership Status Acres Project Description 11 SCE Colorado River Blythe SCE Operational 90 500/230 kV substation located Substation southwest of Blythe. The 500 kV switching station includes buses, circuit breakers, and disconnect switches. The switchyard is equipped with 108-foot-high dead- end structures. 12 Desert Renewable California Desert BLM Existing 10 The DRECP LUPA is an amendment Energy District million to the California Desert Conservation Plan1 Conservation Area (CDCA) for all BLM-administered public lands in the CDCA region. The plan will help provide effective protection and conservation of desert ecosystems while allowing for the appropriate development of solar, wind and geothermal energy projects. The DRECP designates 148,000 acres of Development Focus Areas in Riverside County. 13 NRG Blythe II Blythe NRG Operational 150 20 MW solar PV facility next to the NRG’s 21 MW Blythe Project that came online in spring 2017. 1 - The data shown on Figure 3.1-1 for the Development Focus Areas, ACECs, and National Land Conservation System (NLCS) was taken from the DRECP Final EIS. 2 - Project location information is not available and not depicted on the map in Figure 3.1-1 but all projects would be located on private land in the Blythe area. Source: NextEra, no date; CEC, 2018; DOE, 2018; BLM, 2018a; BLM, 2015; NRG, 2018.

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Table 3.1-2. Probable Future Projects in the Proposed Action Area Project Name; ID Agency ID Location Ownership Status Acres Project Description A Desert Southwest 118 miles Imperial Final EIR/EIS N/A Approximately 118-mile 500 kV Transmission Line primarily parallel Irrigation District prepared in 2005, transmission line from a new to the Devers– approved by the BLM substation/switching station near the Palo Verde in 2006. Construction Blythe Energy Project to the existing 500 kV line has not started. Devers Substation located approxi- mately 10 miles north of Palm Springs, California. B Palo Verde Mesa East of Blythe in Renewable Approved by 3,250 465 MW PV solar plant on 50 Solar Project the, near the Resources Riverside County in parcels totaling 3,250 acres, Neighbors Group August 2017. primarily on agriculture land. Gen-tie Boulevard Construction has not line is approximately 11.8 miles to started. interconnect to the Colorado River Substation. C Eagle Mountain Eagle Mountain Eagle Crest FERC License issued 2,527 1,300 MW pumped storage project Pumped Storage iron ore mine, Energy June 2014. Project acres designed to store off-peak energy to Project north of Desert Company approved by BLM in use during peak hours. The Center August 2018. captured off-peak energy would be Construction has not used to pump water to an upper started. reservoir. When the water is released to a lower reservoir through an underground electrical generating facility the stored energy would be added into the southwestern energy grid during “high demand peak” times, primarily on weekdays.

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Table 3.1-2. Probable Future Projects in the Proposed Action Area Project Name; ID Agency ID Location Ownership Status Acres Project Description D Rice Solar Energy Rice Valley, Rice Solar Approved by California 1,410 150 MW solar power tower project Project Eastern Energy, LLC Energy Commission, with liquid salt storage. Project is Riverside (Solar Reserve, BLM, and Western located on approximately 1,410 County LLC) Area Power acres and includes a power tower Administration approximately 650 feet tall and a (Western) in 2010. 10-mile-long interconnection with Construction has not the Western Parker-Blythe started. transmission line. E Desert Quartzite South of I-10, Desert Quartzite Draft EIS/EIR issued 3,770 450 MW solar PV facility with a Solar 8 miles LLC (First Solar) August 10, 2018. project substation, access road, and southwest transmission line, all located on of Blythe BLM-administered land. The project would interconnect to the SCE Colorado River Substation. F Crimson Solar South of I-10, Sonoran West Scoping complete 2,500 Up to 350 MW solar PV project 8 miles Solar Holdings, May 2018. Draft located on BLM-administered land. southwest LLC (Recurrent EIS/EIR expected out The project would interconnect to of Blythe Energy) for public review mid- the SCE Colorado River Substation. late 2019. G Blythe Mesa Solar East of Blythe Renewable Approved by 3,600 Up to 485 MW solar PV project Project Resources Riverside County in located outside Blythe on private Group May 2015. Decision land. The gen-tie line would cross Record for gen-tie BLM-administered land to reach the approved by BLM SCE Colorado River Substation. in August 2015. Construction has not started. H Desert Harvest North of Desert EDF-RE Approved by the BLM 1,208 150 MW solar PV project located Solar Project Center and Riverside County immediately south of the Desert in 2013. Currently Sunlight project. The gen-tie route under construction. would parallel the existing Desert Sunlight line to interconnect with the existing SCE Red Bluff Substation.

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Table 3.1-2. Probable Future Projects in the Proposed Action Area Project Name; ID Agency ID Location Ownership Status Acres Project Description I DC 50 Solar Project East of Desert NRG Solar SF299 and Plan of 450 Solar PV project located on 450 acres Center Desert Center, Development (POD) of private agriculture land, adjacent LLC submitted to BLM in to the Palen Solar Project. Gen-tie November 2012. line would cross BLM land to inter- connect to the SCE Red Bluff Substation. J Clearway Jupiter East of Desert Clearway SF299 form 1,800 Solar PV project located on 1,800 Solar Project Center Energy Group submitted to BLM in acres of land administered by the October 2014. BLM. Project would interconnect with the SCE Red Bluff Substation. K Clearway Arica East of Desert Clearway SF299 form 2,000 Up to 400 MW solar PV project Solar Project Center Energy Group submitted to BLM located on up to 2,000 acres of land in July 2016. administered by the BLM. Project would interconnect with the SCE Red Bluff Substation. L Victory Pass I, LLC East of Desert Clearway CUP application 1,200 200 MW solar PV project and Center Energy Group submitted to storage facility in the Chuckwalla Riverside County. Valley, entirely on private land. M Palen Solar Project East of Desert EDF Renewable Final Supplemental 3,400 500 MW solar PV project located Center Energy EIS/EIR published in 11 miles east of Desert Center on May 2018. Approved BLM land. Includes a 6 mile gen-tie by BLM in November line into the Red Bluff Substation. 2018. Currently under construction.

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Table 3.1-2. Probable Future Projects in the Proposed Action Area Project Name; ID Agency ID Location Ownership Status Acres Project Description —1 (eligible) Riverside Riverside In process. N/A In 2014, the County initiated the Renewable Energy County County eRED Planning program with Development funding from the Energy Commission. (eRED) Program The purpose of the program is to coordinate and encourage eligible renewable energy resource development at the General Plan level including a General Plan Amendment. —2 Paradise Valley Approximately GLC Notice of Preparation 5,000 A Specific Plan that would define Development – 30 miles west Enterprises, LLC of a Draft EIR (develop- and provide development standards Specific Plan of Desert Center published in October ment and implementation measures for No. 339 (8 miles east of 2015. Under footprint the community, or new town, of the city of environmental review. is 1,800 Paradise Valley. The project would Coachella) acres) develop approximately 1,800 acres of an approximately 5,000-acre site providing for 8,500 residential units, about 1.38 million square feet of non-residential land uses (commer- cial office, retail, hotels, light industrial and public facilities) and 110 acres of recreational trails and parks. Ten West Link From the Abengoa Notice of Intent to N/A A 500 kV transmission line from Transmission Line Colorado River Transmission & prepare an EIS Tonopah, Arizona, to Blythe, Substation Infrastructure, published in March California. It would span 114 miles, in Blythe LLC, and 2016. Draft EIS and with 83 miles of it on public lands California west Starwood Draft RMP managed by the BLM. All but 17 to Tonopah Energy Group Amendments was miles of the line would be in the Arizona Global, Inc. published August Arizona counties of Maricopa and 2018. La Paz with the remainder in Riverside County, California. 1 - Project does not include specific locations at this time. 2 - Project would be west of the region shown on Figure 3.1-1. Source: BLM, 2018b; BLM, 2018c; BLM, 2018a; Roth, 2018.

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3.2 Air Resources 3.2.1 Affected Environment The Proposed Action would be located within the jurisdiction of the South Coast Air Quality Management District (SCAQMD) in the Mojave Desert Air Basin (MDAB), which is the geographic scope of analysis.

Criteria Air Pollutants. Air quality is determined by measuring ambient concentrations of certain criteria air pollutants. These pollutants are called “criteria” air pollutants because ambient air quality standards have been established for each of them to meet specific public health and welfare criteria. The criteria pollutants are ozone, respirable particulate matter (PM10), fine particulate matter (PM2.5), carbon monoxide (CO), nitrogen dioxide (NO2), sulfur dioxide (SO2), and lead. Reactive organic gases (ROG), including volatile organic compounds (VOC), are regulated as precursors to ozone formation.

Sensitive Receptor Land Uses. Land uses that are sensitive to air pollution are: residences, schools, daycare centers, playgrounds and medical facilities. There are scattered residences in the Athos Gen-Tie Project area, namely near State Route 177 (SR-177)/Rice Road. The Lake Tamarisk community is about 1.5 miles west of the site, and the nearest school is the Eagle Mountain School, over 7 miles northwest of the Project site. See also the Athos Air Quality Technical Report, which is included in Appendix I of the POD (EA Appendix F).

The boundary of the Joshua Tree National Park Federal Class I area is 0.9 miles (1.4 km) away from northeast of the edge of the northernmost solar facility parcels, and the nearest gen-tie lines for the solar facility would be approximately 2.5 miles from Joshua Tree National Park.

3.2.2 Direct and Indirect Effects All construction- and operation-related emissions are quantified based on the best available forecast of activities. This analysis uses the California Emissions Estimator Model (CalEEMod; version 2016.3.2) software developed by the California Air Pollution Control Officers Association (CAPCOA). The emissions quantification details appear in the Air Quality Technical Report included in the POD (EA Appendix F).

Characterizing the potential impact of criteria air pollutant emissions relies on thresholds recommended by SCAQMD for construction and operation emissions (SCAQMD, 2015). Because there are no Federal nonattainment or maintenance designations in the MDAB portion of Riverside County, Federal agency actions in the MDAB portion of Riverside County are not subject to Federal general conformity review requirements.

To ensure that projected impacts are minimized, it is assumed that construction activities would occur on the Athos Gen-Tie line and the Athos Solar facility simultaneously.

Alternative 1: Proposed Action Air quality attainment planning anticipates growth that includes the construction of some new infrastructure, such as the gen-tie lines for the solar facility. Therefore, the proposed gen-tie lines would not conflict with or obstruct implementation of the applicable air quality plan.

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The proposed overhead gen-tie lines for the solar facility would not require grading, and the installation of poles or structures and the associated conductors would be likely to occur concurrently with that of the proposed solar facility. In addition, construction of the access road segments would include grading, grubbing, compacting subsurface soils and contouring surface soils; however, minimal grading is anticipated. Trench excavation would be required for any 220 kV and/or 34.5 kV underground segments. The construction-phase emissions for the proposed gen-ties are included within those quantified for the solar facility, within Year 3 of solar facility development.

Table 3.2-1 summarizes the maximum daily construction emissions, with and without potential mitigation.

Table 3.2-1. Proposed Solar Facility and Gen-Tie Line Maximum Daily Construction Emissions (lb/day)

Construction Sequence VOC NOx CO SO2 PM10 PM2.5 Year 1: Solar Facility, Site Preparation 55.4 562.0 351.2 0.9 338.3 76.7 Year 2: Solar Facility, PV System Installation 61.4 498.0 445.7 1.4 474.5 76.7 Year 3: Solar Facility, PV System Installation; 66.9 513.2 499.0 1.6 500.1 81.9 plus Gen-Tie Maximum Daily Emissions, without 66.9 562.0 499.0 1.6 500.1 81.9 Mitigation

Construction Sequence with Mitigation VOC NOx CO SO2 PM10 PM2.5 Year 1: Solar Facility, Site Preparation 19.2 99.3 351.0 0.9 79.3 22.1 Year 2: Solar Facility, PV System Installation 32.4 131.9 527.8 1.4 105.9 23.6 Year 3: Solar Facility, PV System Installation; 36.2 138.6 586.6 1.6 119.5 27.1 plus Gen-Tie Maximum Daily Emissions, with Mitigation 36.2 138.6 586.6 1.6 119.5 27.1 SCAQMD Significance Thresholds (lb/day) 75 100 550 150 150 55 Source: Air Quality Technical Report (AQTR) included in the POD (EA Appendix F). As part of the overall solar facility development activity, construction of the gen-ties would contribute to construction-phase maximum daily emissions exceeding the SCAQMD regional thresholds of significance for NOx, PM10, and PM2.5 if no Project-specific mitigation measures are implemented. Mitigation for NOx, PM10, and PM2.5 involves controlling the exhaust emissions from off-road equipment and taking a variety of steps to control fugitive dust. Requirements in the mitigation build on the lessons learned from other prior and nearby projects and contain specifications to establish a clearly defined plan for dust control and air quality agency oversight. For example, the BLM’s mitigation monitoring plan for Desert Sunlight Solar Farm, supporting the 2011 Record of Decision for that project, did not include a plan for fugitive dust control. However, having learned from the Desert Sunlight construction process, the requirements in mitigation for the Proposed Action are much more comprehensive than the controls adopted for Desert Sunlight and are likely to be more effective at avoiding excessive dust concentrations. Mitigation for fugitive dust includes the review and approval of the dust control plan by the local air quality management district to ensure its effectiveness.

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Substantial or adverse levels of localized ground-level concentrations of criteria pollutants and toxic air contaminants would not be likely to occur with gen-tie construction because the pollutants would be emitted from dozens of individual pieces of equipment from locations widely spread across the corridors of the gen-tie segments. Mitigation for dust control and control of engine exhaust emissions would ensure that the concentrations of air pollutants and the impact to visibility in Joshua Tree National Park would not be significant. See EA Appendix H for the full text of all mitigation measures.

Mitigation Measure (MM) AQ-1 (Fugitive Dust Control Plan) would mitigate the particulate matter impact caused by dust emissions during construction by implementing a suite of effective dust control practices, such as using soil stabilizers or watering exposed areas (2 times/day or as needed) throughout construction.

MMAQ-2 (Control On-Site Off-Road Equipment Emissions) would mitigate the NOx, PM10, and PM2.5 in diesel exhaust emissions by requiring use of the newest off-road equipment achieving the most-stringent Tier 4 engine emissions standards. The measure would exclude certain equipment from this standard if a good faith effort demonstrates that a Tier 4 engine is not available for a particular item of equipment.

Alternative 2: Gen-Tie Segment #1 Alternative Route Option The Gen-Tie Segment #1 Alternative Route Option would avoid going through parcel Assessor Parcel Number (APN) 807-191-031. All remaining features of the gen-tie line and solar facility would remain the same as with the Proposed Action. Similar to the Proposed Action, the Gen- Tie Segment #1 Alternative Route Option would not result in construction-phase emissions of NOx at a significant level with implementation of mitigation. Overall, air quality impacts from this alternative would be similar to those of the Proposed Action.

Alternative 3: No Action Alternative The No Action Alternative would not develop the solar facility and gen-tie line, and it would avoid all new construction and/or operational activities. It would not result in a change in emissions of any air pollutants. Therefore, the No Action Alternative would have no air quality impacts.

3.2.3 Cumulative Effects The geographic extent for cumulative effects is the MDAB. The construction-phase emissions related to the proposed gen-tie lines would be likely to occur concurrently with those of other cumulative projects nearby and would contribute to the adverse effects of other cumulative projects to result in a cumulative adverse effect to air quality. The mitigation recommended for the proposed solar facility (Mitigation Measures AQ-1 and AQ-2) would be necessary to reduce this impact during construction of the gen-ties.

3.3 Cultural Resources 3.3.1 Affected Environment Information presented in this section was gathered from a review of seven Athos Project (Athos Gen-Tie and Athos Solar) reports that present the results of: record searches (Dyste et al., 2018;

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Hanes et al., 2019a); archaeological inventories (Dyste et al., 2019; Hanes et al., 2019b); an ethnographic overview (Hanes, 2019a); a geoarchaeological study (Onken, 2019); and research and excavation associated with the evaluation of resources for the National Register of Historic Places (NRHP) and California Register of Historical Resources (CRHR) (Hanes, 2019b; Hanes et al., 2019a).

The BLM defined the Area of Potential Effects (APE) for direct and indirect effects to historic properties and cultural resource identification efforts in consultation with consulting parties and consistent with Stipulation IV(A) of the DRECP Programmatic Agreement (PA).The Direct APE totals 3,662.29 acres, including: the 3,228-acre utility-scale solar PV electrical generating and storage facility; an approximately 8 mile-long, 300-foot-wide gen-tie corridor, and 450-foot-wide areas for all pull and tensioning sites; 100-foot-wide corridors for all access roads; and all laydown and staging areas. The BLM defined the Indirect APE to be a 1-mile buffer around the Direct APE.

A BLM Class I records search and literature review was conducted to compile and synthesize existing information about all previously recorded cultural resources within the APE. BLM defined the Records Search Area to be a 5-mile-wide area surrounding the Direct APE, encompassing approximately 140,452 acres. Results of the records search indicate a total of 26 previous archaeological inventories have been conducted since 1977 within the Record Search Area. Ten of the archaeological inventories included portions of the Direct APE. In total, approximately 11.4 percent (408 acres) of the Direct APE has been previously inventoried. The records searches also identified 1,372 (959 isolates and 413 archaeological sites or built-environment resources) previously recorded cultural resources in the Records Search Area, 67 of which (25 historic archaeological sites, 4 built-environment resources, and 38 isolates) are in the Direct APE.

The archaeological inventory identified 75 cultural resources in the Direct APE including 6 built environment resources, 31 archaeological sites and 38 isolates. The non-isolate resources include 1 prehistoric ceramic scatter, 1 multicomponent archaeological site and 35 historic-era resources, 13 of which are WWII-era resources associated with the Desert Training Center/ California-Arizona Maneuver Area (DTC/C-AMA) described below. The 75 resources were evaluated to determine if they qualify for listing in the NRHP. Of those, 1 built environment resource and 2 archaeological sites were determined eligible for listing on the NRHP, as listed in Table 3.3-1.

The Direct APE lies within the boundaries of the Desert Training Center/California-Arizona Maneuver Area (DTC/C-AMA). The DTC/C-AMA was established in the 1940s to prepare U.S. troops for possible deployment to North Africa. DTC/C-AMA sites in the Athos Project vicinity are remnant features of the Chuckwalla Valley Maneuver Area, which saw 10 separate training events in 1942. BLM has determined several sites associated with the DTC/C-AMA eligible for the NRHP. Of the site types identified within the DTC/C-AMA, the Direct APE contains airfields, maneuver areas, campsites, and their constituent features such as foxholes, fighting positions, tank tracks, refuse deposits, and associated dispersed artifacts. The BLM is currently working on a NRHP Multiple Properties Documentation Form (MPDF) for the DTC/C-AMA Discontiguous District. However, this process is still underway and at this point BLM cannot evaluate any individual resources as contributing or non-contributing elements to the proposed Discontiguous District.

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Table 3.3-1. Cultural Resources Within the Direct APE Determined Eligible for the NRHP Project Site # Site Type NRHP Eligibility Elements CA-RIV-9481H DTC/C-AMA 18th Ordnance Previously Determined Eligible Gen-Tie Battalion Campsite Criterion A (SHPO Concurrence Segment #3 2017); Eligible Criterion D CA-RIV-9857H Historical Segment of U.S. Previously Determined Eligible Gen-Tie Highway 60/70 Criterion A (SHPO Concurrence Segment #4 2011) AE-3752-064H DTC/C-AMA maneuver area Eligible Criteria A and D Parcel Group F (35 foxholes, 7 mechanically excavated fighting positions)

3.3.2 Direct Impacts and Direct Effects This section describes and evaluates the direct effects to historic properties under Section 106 of the National Historic Preservation Act (NHPA) and direct impacts to more broadly defined cultural resources under NEPA, related to the Athos Solar and Athos Gen-Tie Projects (Proposed Action), the Gen-Tie Segment #1 Alternative Route Option, and the No Action Alternative.

National Historic Preservation Act In accordance with 36 CFR 800.5 effects to historic properties (more narrowly defined than cultural resources) are considered adverse if the undertaking may alter characteristics of the property that may qualify the property for inclusion in the NRHP, or if the undertaking diminishes the integrity of the property’s location, design, setting, materials, workmanship, feeling, or association. Consideration is given to all qualifying characteristics of a historic property. Under the NHPA, the term “effect” “means alteration to the characteristics of a historic property qualifying it for inclusion in or eligibility for the National Register” (36 CFR 800.16(i)).

Adverse effects to historic properties are typically considered permanent as these resources are finite and effects, particularly to archaeological sites, cannot be reversed. However, indirect effects to historic properties can be temporary, if projects do not permanently impact the characteristics of a historic property that qualify it for inclusion in the NRHP.

National Environmental Policy Act Under NEPA, direct impacts and indirect impacts (discussed in Section 3.3.3) to cultural resources are those that are more clearly and immediately attributable to the implementation of proposed or alternative actions.

 Direct impacts are those “which are caused by the [proposed or alternative] action and [which] occur at the same time and place” (40 CFR 1508.8(a)). Direct impacts to cultural resources are caused by project development, construction, and co-existence.  Indirect impacts are those “which are caused by the [proposed or alternative] action and are later in time or farther removed in distance, but are still reasonably foreseeable” (40 CFR 1508.8(b)).

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The conclusions regarding impacts to specific resources under NEPA and the conclusions under NHPA Section 106 for adverse effects to the same resources may differ, especially with respect to mitigation. NEPA (Sections 1502.14(f), 1502.16(h), 1508.14) requires that mitigation measures be considered even for impacts that are not significant.

Alternative 1: Proposed Action The cultural resources analysis uses the Direct APE to analyze direct impacts to both historic properties and cultural resources. The Direct APE encompasses the entire Athos Renewable Energy Project area, including the Athos Gen-Tie (Proposed Action) and Athos Solar Project.

Three cultural resources present within the Direct APE are eligible for the NRHP, and are therefore, considered historic properties. CA-RIV-9857H (Highway 60/70) would be spanned by Gen-Tie Segment #4 and would not be directly affected. CA-RIV-9481H (18th Ordnance Battalion Campsite) is located along Gen-Tie Segment #3. MM CR-8 (Environmentally Sensitive Areas [ESA]) would avoid direct effects (Section 106) and significant direct impacts (NEPA) to this resource either by micro-siting the aboveground transmission line structure and access road outside of the site boundaries or using directional boring to place underground gen-tie cables below the eligible site without impacting its surface. This avoidance strategy also includes the use of the access road without expansion along Gen-Tie Segment #3 and the identification, flagging, and avoidance of the resource as an ESA. WWII-era site AE-3752-064H (DTC/C-AMA maneuver area) is located within Parcel Group F. Implementation of MM CR-8 would avoid direct effects (Section 106) and significant direct impacts (NEPA) to this resource through re- design of the solar facility and project substation (SS4) to avoid the resource and through the identification of this resource as an ESA. In short, direct adverse effects to historic properties and direct impacts to all known significant cultural resources would be avoided.

A geoarchaeological assessment of the Direct APE using satellite imagery, historical aerial imagery, geological information, and field reconnaissance was conducted. This information was used to create a site sensitivity model for the Direct APE which indicates that the majority of the project area (73 percent) has a moderate potential for subsurface archaeological resources, and therefore a moderate potential for post-review discoveries.

Implementation of MM CR-8 and the following standard measures to address post-review discoveries and unanticipated adverse effects would reduce the impacts on BLM-administered lands: MM CR-1 (Project Cultural Resources Staff), MM CR-2 (Monitoring and Discovery Plan), MM CR-3 (Authority to Halt Construction), MM CR-4 (Cultural Resources Worker Environmental Awareness Program), MM CR-5 (Monitoring for Cultural Resources), MM CR-6 (Cultural Resources Reporting), MM CR-7 (Curation of Cultural Resources Collections) and MM CR-9 (Chuckwalla Valley Maneuver Area). See EA Appendix H for the full text of mitigation measures that would be implemented on BLM-administered public land only.

Alternative 2: Gen-Tie Segment #1 Alternative Route Option The Gen-Tie Segment #1 Alternative Route Option would be longer than the proposed Gen-Tie Segment #1. Similar to the Proposed Action, no known resources present within the Direct APE along the Alternative Route Option are considered historic properties under Section 106 or

October 2019 3-17 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 3: AFFECTED ENVIRONMENT AND ENVIRONMENTAL EFFECTS OF ACTION significant resources. However, the amount of proposed ground disturbance under the Alternative Route Option would be slightly greater than under the Proposed Action. Therefore, the impacts for the Alternative Route Option would be similar, but the potential to impact unknown subsurface archaeological resources or adversely affect unknown historic properties would be slightly greater than the Proposed Action due to slightly greater ground disturbance. However, the mitigation measures for the Proposed Action would be applicable to the Gen-Tie Segment #1 Alternative Route Option.

Alternative 3: No Action Alternative The No Action Alternative would not result in any new construction and/or operational activities or any new associated ground-disturbing activities. The impacts to historic properties and significant cultural resources associated with the Proposed Action would not occur under the No Action Alternative.

3.3.3 Indirect Effects Information presented in this section was gathered from a review of reports that presented the results of record searches (Dyste et al., 2018; Hanes et al., 2019a) and an indirect effects/impact analysis (Hanes, 2019b). The BLM defined the Indirect APE to be a 1-mile buffer around the Direct APE. An indirect effects analysis to assess visual, auditory, and atmospheric effects to historic properties was conducted in order to determine if construction, operation, and maintenance, and decommissioning of the proposed Athos Project (solar facility and gen-tie lines) could have an indirect impact on historic properties. While auditory and atmospheric intrusions are possible, the primary indirect effect/impact is expected to be associated with visual impacts associated with the introduction of a large industrial facility and associated gen- tie lines to the landscape. This indirect effects/impact analysis focuses primarily on visual line- of-sight concerns. A visual analysis was performed utilizing four key observation points (KOPs) photographed in the spring of 2019 to which simulations of the proposed Athos solar facility and gen-tie design were added. A visual intrusion into a site’s viewshed is considered an adverse effect and a significant impact if it alters the characteristics that qualify a site for eligibility to the NRHP “in a manner that would diminish the integrity of the property’s location, design, setting, materials, workmanship, feeling, or association” (36 CFR 800.5[a]).

Research to identify resources that would be subject to indirect effects/impacts focused on known historic properties whose eligibility criteria include characteristics that could be subject to visual, auditory, or atmospheric intrusions. Thirteen (13) historic properties were identified in the indirect effects APE: 1 historic road segment (U.S. Route 60/70, CA-RIV-12372H), 1 prehistoric trail segment (CA-RIV-53T, Coco- Maricopa Trail, Segment D), 1 prehistoric petroglyph district (CA-RIV-1383, North Chuckwalla Petroglyph District) and a cluster of 10 prehistoric sites with rock ring and cleared circle features.

A segment of U.S. Route 60/70 (CA-RIV-12372H) is located in the Indirect APE. It has been determined eligible to the NRHP under Criterion A for contributing to evolving transportation routes in the west. A visual analysis concluded that visual changes introduced by the Athos Project, including the solar facility and gen-tie lines, would be in kind with the current nature and scale of existing visible developments. In addition, setting is not an important element to integrity

October 2019 3-18 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 3: AFFECTED ENVIRONMENT AND ENVIRONMENTAL EFFECTS OF ACTION for the roadway with regard to its eligibility. As such, the Athos Project does not compromise the integrity of location and association that do contribute to its eligibility under Criterion A. Overall, the proposed Athos Project would have no adverse indirect effects or significant indirect impacts to CA-RIV-12372H.

CA-RIV-53T (Coco- Maricopa Trail, Segment D) was determined eligible for the NRHP under Criterion A for the ability to clearly evoke and represent broad patterns in prehistory and history and under Criterion D for the ability to yield more information important for understanding the prehistoric and ethnographic use of Chuckwalla Valley of southern California regarding intertribal trade of commodities and use of the landscape. The proposed Athos Project would be a prominent addition within the viewshed of the CA-RIV-53T(d). However, the Athos Project component design is consistent with the existing visual elements of form, line, color, and texture in the existing landscape. Visual changes introduced by the Project would be in kind with the current nature and scale of existing visible developments and would not constitute a dominant addition. Therefore, the Athos Project does not significantly compromise the integrity of setting, location, design, feeling, materials, and workmanship that contribute to trail segment’s eligibility under Criterion A. As such, the proposed Athos Project would have no adverse indirect effects or significant indirect impacts to CA-RIV-53T.

CA-RIV-1383 (North Chuckwalla Petroglyph District) includes boulders exhibiting petroglyphs, in addition to rock rings, cleared circles, and trails. This resource is eligible for the NRHP under Criterion C as the petroglyphs embody distinctive characteristics of style, type, design, and method of construction and under Criterion D likely yield information important in prehistory relevant to current research questions for the Chuckwalla Valley. Setting as part of its viewshed is not a critical element of its integrity. Based on the visual analysis, the proposed Athos Project would be a prominent addition within the viewshed of the Petroglyph District. However, the Athos Project does not create a substantial visual intrusion upon the Petroglyph District as setting is not a significant element of integrity to the Criteria C and D values. Therefore, the Project’s presence does not compromise the integrity of location, design, feeling, materials, and work- manship that contribute to the district’s eligibility. Overall, the proposed Athos Project would have no adverse indirect effects or significant indirect impacts to CA-RIV-1383.

A cluster of 10 relatively small prehistoric-period sites containing rock ring and cleared circle features (CA-RIV-10916, -10917, -10918, -10919, -10920, -10921, -10922, -10923, -10924, and -10928) are present in the Indirect APE. One site, CA-RIV-10916, was previously determined eligible for the NRHP under Criteria C and D, with SHPO concurrence. For the purpose of the Athos Project only, the remaining 9 sites were assumed eligible for the NRHP under Criterion C as the sites embody a distinctive and consistent type or method of construction maintaining an integrity of location, design, and materials and Criterion D for their potential to contribute to our understanding of prehistory in the region, and the prehistory of religion, and ritual and belief. Based on the visual analysis, the proposed Athos Project would be a prominent addition within the viewshed of these 10 resources. However, the Athos Project does not create a substantial visual intrusion upon these resources as setting is not a significant element of integrity to the Criteria C and D values. Therefore, the Project’s presence does not compromise the integrity of location, design, feeling, materials, and workmanship that contribute to the

October 2019 3-19 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 3: AFFECTED ENVIRONMENT AND ENVIRONMENTAL EFFECTS OF ACTION district’s eligibility. Overall, the proposed Athos Project would have no adverse indirect effects or significant indirect impacts to these resources.

3.3.4 Cumulative Effects The regulations implementing Section 106 of the NHPA contemplate close coordination between the NEPA and NHPA processes (36 CFR 800.8), and expressly integrate consideration of cumulative concerns within the analysis of a proposed action’s potential direct and indirect effects by defining “adverse effect” to include “reasonably foreseeable effects caused by the undertaking that may occur later in time, be farther removed in distance or be cumulative” (36 CFR 800.5(a)(1)). When the results of cultural resources pedestrian surveys are not available for projects included in the cumulative analysis, calculating the number of cultural resources likely destroyed by construction per acre is considered an acceptable quantitative cumulative analysis method, and is used below. Central to this method is the understanding that cultural resources are a non-renewable resource. The average number of resources per acre is calculated by using the survey results from recent, nearby projects (estimated number of cultural resources 0.019 per acre; estimated number of historic properties 0.002 per acre). See the Palen Solar Project Final Supplemental Environmental Impact Statement/Environmental Impact Report/Land Use Plan Amendment (Section 4.4, Cultural Resources) for a detailed discussion of this method (BLM, 2018).

For the cumulative analysis of cultural resources, the relevant geographic scope was defined as equivalent to the Record Search Area which includes a 5-mile-wide area surrounding the Direct APE, encompassing approximately 140,452 acres. Together, existing actions summarized in Table 3.1-1 disturbed an estimated 19,065 acres, or 14 percent of the cumulative study area (140,452 acres) and impacted 362 (38historic properties) of the estimated 2,669 cultural resources. Reasonably foreseeable actions within the cumulative study area as summarized in Table 3.1-2 would disturb 28,915 acres, or 21 percent of the cumulative study area (122,440 acres) and may impact 534 (58historic properties) cultural resources.

When combined with the impacts to cultural resources from past, present and reasonably foreseeable future actions, direct impacts associated the Project would contribute approximately 1 percent of the cumulative impacts within the cumulative analysis study area (34 of an estimated 2,669 cultural resources impacted). A total of 37 archaeological sites and built-environment resources are present within the Direct APE. Seventeen (17) of these resources are WWII-era historic resources associated with the DTC/C-AMA Chuckwalla Valley Maneuver Area. Three of these resources are eligible for the NRHP (including two associated with DTC/C-AMA Chuckwalla Valley Maneuver Area), but they would be avoided resulting in no direct adverse effects and no significant direct impacts.

The destruction of 15 DTC/C-AMA Chuckwalla Valley Maneuver Area resources not eligible for the NRHP as a result of the Project, contributes in a small but measurable way to cumulative impacts to DTC/C-AMA resources in the region. Cumulative impacts to the DTC/C-AMA resources would be addressed through MMCR-9 (Chuckwalla Valley Maneuver Area). MM CR-9 would address the loss of data potential through cumulative impacts to 15 resources that are associated with DTC/C-AMA Chuckwalla Valley Maneuver Area, by ensuring that these

October 2019 3-20 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 3: AFFECTED ENVIRONMENT AND ENVIRONMENTAL EFFECTS OF ACTION resources were documented in detail and incorporated into a summary report presenting evidence of DTC/C-AMA activities in the Chuckwalla Valley. These documents would assist BLM in better understanding the Chuckwalla Valley Maneuver Area, the potential for effects or impacts to the resource in the future, and will allow BLM to consider whether the maneuver area should be included in the MPDF for the DTC/C-AMA Discontiguous District, currently in preparation. With implementation of MM CR-9, the Project would not result in cumulative impacts to these WWII- era resources.

Construction activities associated with the Athos Project in combination with other projects along the I-10 corridor and eastern Riverside County could contribute to the progressive loss of sensitive cultural resources. However, with the implementation of MM CR-1 through CR-9, the Athos Project would either avoid all adverse effects to historic properties and significant impacts to cultural resources or would result in the recovery of important historical information. Mitigation plans for any foreseeable projects would require federal standards of professional qualification for cultural resources specialists, and monitoring plans that ensure rigorous study of historic properties and cultural resources finds would be beneficial to our understanding of the past. The loss of cultural resources, even those not eligible for the NRHP, combined with impacts from other projects over time could result in cumulative impacts; however, the minor impacts associated with the Athos Project would be addressed by MM CR-9 (Chuckwalla Valley Maneuver Area), which would generate positive results associated with scientific study of cultural resources.

3.4 Environmental Justice Executive Order (EO) 12898 was issued on February 11, 1994 and requires that all Federal agencies analyze the effects of their decisions on human health and environmental conditions in minority and low-income communities and to develop strategies to address environmental justice. The agencies are required to identify and address any disproportionately high and adverse human health or environmental effects of their programs, policies, and activities on minority and/or low-income populations. In addition, in accordance with CEQ Guidance, Federal agencies must evaluate if any identified significant impacts (as defined by NEPA) are disproportionately borne by identified environmental justice population of concern. In the absence of a high and adverse resource impact, however, no disproportionate impact to a community of concern (i.e., environmental justice impact) would occur. The following analysis addresses these considerations.

3.4.1 Affected Environment The primary affected environment geographic scope would be areas within close proximity of the proposed gen-tie right-of-way (ROW). Beyond that distance, most direct physical effects would diminish and residents’ daily interaction with the Proposed Action would likely be relatively limited in the affected area. However, visual and social effects of the gen-tie line could extend beyond the immediate area.

Census data on race and income were used to identify both minority populations and populations living below the Federal poverty limit. The entire gen-tie ROW and overall Athos Solar Project study area is located within Census Tract 469.

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Minority Populations According to the CEQ, minority individuals are defined as members of the following groups: American Indian or Alaskan Native; Asian or Pacific Islander; Black, not of Hispanic origin; or Hispanic (CEQ, 1997). Table 3.4-1 presents the minority population of the affected study area and comparative geographies. The populated area nearest the site is the community of Desert Center, represented in the U.S. Census as the Desert Center Census Designated Place (CDP). In addition to Desert Center, environmental justice data is shown for the City of Blythe and Riverside County as a whole.

Table 3.4-1. Racial Characteristics and Poverty Status Proportion of the Total Total Total (Percent) Population Living Below the Geographic Area Population Minority1 Poverty Level Census Tract 469 1,632 1,046 (64.1%) 26.2% Desert Center CDP 189 92 (48.7%) 33.9% City of Blythe 19,675 14,296 (72.7%) 23.7% Riverside County 2,323,892 1,458,261 (62.7%) 16.5% 1- All Population Other Than Non-Hispanic White Source: U.S. Census Bureau, 2018

As shown in Table 3.4-1, Census Tract 469 contains a minority population greater than 50 percent, as well as the City of Blythe, and Riverside County as a whole. However, the nearby community of Desert Center does not contain minority populations exceeding 50 percent of the total population.

Low-Income Populations Unlike the CEQ guidance (1997) on minority populations, this guidance does not contain a quantitative definition of what proportion of low-income individuals defines a low-income population. In the absence of guidance, this analysis relies on the density used to identify a minority population as “meaningfully greater” than the general population. Thus, if the population of individuals living under the poverty line is 150 percent or more than that of the general population, this analysis considers that community to be a low-income population of concern. Based on this methodology, only the community of Desert Center is considered to be an area containing low-income population of concern for the purposes of this analysis.

3.4.2 Direct and Indirect Effects The Athos Gen-Tie Project effects on Native Americans and cultural resources are specifically addressed in Section 3.3 (Cultural Resources) and Cultural Resources Technical Report, POD Appendix E in EA Appendix F, and are therefore, not specifically addressed within this section beyond that population which is included within U.S. Census data utilized for this analysis. The remaining direct effects of the Proposed Action and its alternatives are as follows:

Alternative 1: Proposed Action Based on the environmental impacts identified within this document, the environmental justice review determined that the Proposed Action (construction and operation) would not result in

October 2019 3-22 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 3: AFFECTED ENVIRONMENT AND ENVIRONMENTAL EFFECTS OF ACTION disproportionate adverse effects to identified environmental justice populations. While some temporary and permanent adverse impacts associated with the Proposed Action could occur to minority or low-income persons living in closed proximity to the work area, these persons are not considered to be disproportionately burdened by these impacts because they would mostly be temporary during construction. Long-term visual impacts would be evident over a greater geographic area (compared to other impacts, such as dust from construction) as the desert landscape would allow views of the overhead gen-tie line from approximately 10 to 15 miles away, therefore, a larger population would be subjected to any adverse effects so there would not be a disproportionate burden. Furthermore, no significant and adverse public health and safety impacts are anticipated associated with the Proposed Action. This determination includes the consideration of proposed mitigation measures and the absence of significant numbers of minority or low-income population within close proximity of the ROW (the distance at which most environmental effects would occur). Based on a desktop survey of the site (Google Earth), an estimated five habitable structures are located within 2,000 feet of the gen-tie. For these reasons and considering the rural and remote character of the area and the low population living near the gen-tie line, the Proposed Action would not result in any disproportionate adverse impacts on low-income or minority populations.

Alternative 2: Gen-Tie Segment #1 Alternative Route Option Alternative 2 would result in identical overall environmental justice impacts as those discussed above under the Proposed Action as it would not substantially alter the affected population or result in any new adverse effects.

Alternative 3: No Action Alternative Under the No Action Alternative, construction of the gen-tie line would not occur. Minority or low- income populations would not be affected.

3.4.3 Cumulative Effects While construction is limited in duration, many of the typical impacts from construction of the projects listed in Tables 3.1-1 and 3.1-2 could result in nuisances to minority and low-income communities. These impacts do not typically result in unavoidable disproportionate impacts to disadvantaged communities because they can be managed through best management practices and mitigation. Once operational, the Proposed Action in conjunction with projects listed in Section 3.1 are likely to result in adverse visual impacts through the loss of open desert landscape which could be considered to disproportionately affect adjacent minority populations and low-income populations within Desert Center. Therefore, the Proposed Action would contribute to a cumulative impact on environmental justice areas of concern. It should also be noted that the cumulative development of renewable energy and electrical transmission projects in the area may amplify negative social values of some residents toward renewable energy facilities, because comments have been received on other renewable energy projects and planning efforts in the California desert stating that rural areas are subjected to the adverse effects of such facilities while the generated power is primarily used by distant urban areas.

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Beneficial economic and tax base impacts would occur during construction of the Proposed Action and projects listed in Tables 3.1-1 and 3.1-2 from expenditures on worker wages and salaries, as well as from procurement of goods and services required for construction of the Athos Gen-Tie and Athos Solar facility and sales taxes generated from goods and services purchased by workers. Similar beneficial economic and tax base impacts would occur during facility operations from expenditures on wages and salaries, procurement of local goods and services, and the collection of sales and income taxes (although on a smaller scale, as the permanent workforce is smaller than during construction). Adjacent communities, including the residents of Desert Center, are expected to realize a portion of these benefits from all projects within the geographic extent for cumulative effects.

3.5 Geology and Soils 3.5.1 Affected Environment The geographic scope of geological resources and soils is a 1,000-foot buffer around the Proposed Action which corresponds with impacts resulting from geologic hazards being localized in nature, despite geologic hazards being felt for great distances.

Geology. The Proposed Action is located within the Mojave Desert Geomorphic Province in Southern California. Geologic structures within this Province trend mostly northwest, in contrast to the prevailing east-west trend in the neighboring Transverse Ranges Geomorphic Province to the west. The Mojave Desert Province extends into lower California and is bounded by the Garlock Fault to the north, the San Andreas Fault to the west and Nevada and Arizona borders to the east. Surficial geologic units in the region consist mainly of Alluvium deposits (Qvf), with some Pleistocene non-marine deposits (Qoa) and some surficial deposits of Dune sands. Nearby subsurface borings encountered loose to very dense sand with variable amounts of silt, clay, gravel, and cobbles. In general, these deposits are capped by a gravel lag or desert pavement with desert varnish. The area is underlain by the Chuckwalla Valley groundwater basin, and recent groundwater levels are approximately 70 feet below ground surface. (CGS, 2014; Terracon Consultants, Inc., 2018)

The Proposed Action is in a seismically active area; the nearest fault is the San Andreas (Coachella fault), which is approximately 30 kilometers (18.6 miles) away. The mean magnitude for the region is between 6.64 and 6.72 with a peak ground acceleration of between 0.301g and 0.341g (Terracon Consultants, Inc., 2018). The site is not located within an Alquist-Priolo Earthquake Fault Zone. The Riverside County GIS website shows the region within a liquefaction hazard zone mapped as low to moderate, but the subsurface conditions and depth to ground- water would indicate that the potential for liquefaction at the site is low (Terracon Consultants, Inc., 2018). A seismic settlement analysis was performed for the Athos Solar project calculated from a depth of 0 to 50 feet below the ground surface, and total and differential settlement for dry sands is estimated to be less than 0.25 inches.

Soils. The soil under the proposed Athos Gen-Tie corridor is primarily sand and sandy clay loam. Sandy soils are a loose granular soil resulting from the erosion of siliceous and other rocks and usually containing only small amounts of organic matter. Onsite soils are not considered expansive due to their non-plastic nature. Wind erosion is moderate to high.

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Geomorphology. Geomorphology is the study of the landforms and relief patterns that make up the earth’s surface. The Proposed Action site is located within the Chuckwalla Valley, a region of active sand migration and deposition. Aeolian processes play a major role in the creation and establishment of sand dune formations and habitat. The gen-tie line connecting Parcel Groups A and C would cross an active wash that is important as a sand source, as well as for sand transport and stabilizing moisture. The remainder of the gen-tie lines (approximately 6 miles) would not be located within a geomorphic zone of active sand migration and deposition.

3.5.2 Direct and Indirect Effects Evaluation of potential geologic and soil-related impacts were based on the Geotechnical Report (Terracon Consultants, Inc., 2018). It is assumed that structures are designed in accordance with applicable requirements of the California Building Code and the County of Riverside Municipal Code. It is assumed that the Applicant will perform a geotechnical review of the engineering plans prior to construction as recommended in the geotechnical report.

Alternative 1: Proposed Action The Proposed Action could expose people or structures to adverse effects involving geologic hazards. These include damage to the gen-tie poles, underground cables, or other nearby structures due to strong seismic ground shaking or seismic-related ground failure. The gen-tie line is not expected to be affected by rupture along a known earthquake fault, liquefaction, or landslides.

Since most of the gen-tie line route has nearly level to gently sloping topography, no grading would be required for the overhead line; some light grubbing may be required to temporarily clear vegetation from an approximately 12,500-square-foot area (0.3 acres) where the structure would be erected and in some work areas. In addition, the construction of the access road segments would include grading, grubbing, compacting subsurface soils and contouring surface soils; however, minimal grading is anticipated. Any underground gen-tie line would require trench excavation that would be backfilled and restored following cable installation. These activities would expose soil and increase the potential for wind and water erosion. Mitigation Measures AQ-1 (Fugitive Dust Control Plan) for the gen-tie line, along with adherence to the Stormwater Pollution Prevention Plan (SWPPP) best management practices, which would be developed prior to construction, would reduce the effect, see EA Appendix H for the full text of MM AQ-1.

Desert Pavement. On BLM-administered land, desert pavement occurs in Gen-Tie Segments #2, #3 and #4. Less than 3,000 feet of the Athos Gen-Tie would cross desert pavement and/or desert varnish. The Athos Gen-Tie line would likely require between 3 to 6 poles to span this length, requiring between 100 to 220 square feet of permanent disturbance. Poles would be micro-sited to reduce any effects to these geologic features. If the Gen-Tie Segment #3, which crosses desert pavement, is built as a medium voltage underground line, the underground line would be located in an existing road, reducing effects to desert pavement. The extent of desert pavement in the Athos Gen-Tie area has been mapped to ensure that the erosional and ecological disturbance from the Proposed Action would not exceed the 10 percent disturbance

October 2019 3-25 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 3: AFFECTED ENVIRONMENT AND ENVIRONMENTAL EFFECTS OF ACTION cap set by DRECP CMA LUPA-SW-9. Therefore, the Athos Gen-Tie will be constructed in compliance with DRECP CMA LUPA-SW-9 (see EA Appendix H).

Sand Transport. The gen-tie connecting Parcel Group A and Parcel Group C (Gen-Tie Segment #1) would cross an active wash that is important for aeolian systems. Because the gen-tie line has a limited footprint, it would not impede the wash flow and would not impact the wash as a sand source, by significantly blocking sand transport, and/or by affecting stabilizing moisture. If installed underground, the gen-tie line would be buried such that it would not become exposed by scour (see MM WR-1), and thus, it would not affect the wash or sand transport.

Alternative 2: Gen-Tie Segment #1 Alternative Route Option The Gen-Tie Segment #1 Alternative Route Option would be located east of the proposed gen- tie and would be approximately 0.65 miles longer. Because of the proximity between the Route Option and the proposed Gen-Tie Segment #1, the impacts due to geological risk and soil erosion would be the same. The longer route would require additional towers and associated ground disturbance so would result in slightly more erosion. The geomorphological resources would be the same. The mitigation measures for the Proposed Action would be applicable to the Route Option.

Alternative 3: No Action Alternative The No Action Alternative would not result in any new construction and/or operational activities or any new associated ground-disturbing activities. The No Action Alternative would not expose people or structures to adverse effects involving a potential rupture of a known earthquake fault, seismic ground shaking, ground failure, or landslides. It would not result in increased erosion and sediment runoff nor be located on expansive soils.

3.5.3 Cumulative Effects The geographic extent for cumulative effects to geological resources and soils is a 1,000-foot buffer around the Proposed Action which corresponds with impacts resulting from geologic hazards being localized in nature, despite geologic hazards being felt for great distances. Tables 3.1-1 and 3.1-2 list past, present, and probably future projects in the region that could impact geology and soils. The Clearway Jupiter, LLC Project, Clearway Arica Project, Victory Pass I, LLC, and Palen Solar Project would all be adjacent to the gen-tie line, see maps in Appendix D, Figure 3.1-1.

While the geologic risks could impact the infrastructure of the past, present, and reasonably foreseeable projects, it would be unlikely to be destroyed in a manner that would combine with the seismic impacts to adjacent projects and cause injury to a nearby person. As such, the geologic effects would not combine to result in a cumulative effect. The Proposed Action is adjacent to other large solar projects that would require substantial ground disturbance. While each project’s soil disturbance could result in offsite water and wind erosion, each project has or would undergo an environmental review under NEPA and CEQA and would be required to abide by existing regulations that would reduce wind and water erosion and eliminate it from

October 2019 3-26 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 3: AFFECTED ENVIRONMENT AND ENVIRONMENTAL EFFECTS OF ACTION leaving the site. It would not combine with the erosion from nearby projects and would not create a cumulatively substantial effect.

The gen-tie line would not combine to result in an impact to the sand migration zone because it would be further removed from the sand transport and would not block sand or water feeding the sand migration zone. 3.6 Global Climate Change 3.6.1 Affected Environment The geographic scope of climate change is global.

Physical Setting. The global climate depends on the presence of naturally occurring GHG to provide what is commonly known as the “greenhouse effect” that allows heat radiated from the Earth’s surface to warm the atmosphere.

Human activity directly contributes to emissions of six primary anthropogenic GHGs: CO2, CH4,

N2O, hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). The standard definition of anthropogenic GHG includes these six substances under the 1997 Kyoto Protocol (UNFCCC, 1998). The most important and widely occurring anthropogenic GHG is

CO2, primarily from the use of fossil fuels as a source of energy.

Effects of GHG Emissions. Changing temperatures, precipitation, sea levels, ocean currents, wind patterns and storm activity provide indicators and evidence of the effects of climate change. The primary observed changes in California’s climate include increased annual average air temperatures, more-frequent extremely hot days and nights, and increasing severity of drought. Impacts to physical systems affected by warming temperatures and changing precipitation patterns show decreasing snowmelt runoff, shrinking glaciers, and rising sea levels. Impacts to terrestrial, marine, and freshwater biological systems, with resulting changes in habitat, agricul- ture, and food supply are occurring in conjunction with the potential to impact human well-being (OEHHA, 2018).

See also the Air Quality Technical Report, which is included in Appendix I of the Athos Gen-Tie POD (EA Appendix F).

3.6.2 Direct and Indirect Effects Diesel fuel and gasoline would be used in mobilizing the heavy-duty construction equipment and vehicles for transporting crews and materials during construction of the gen-tie line. Combustion of these fossil fuels produces CO2 emissions that would be the primary contributor to the GHG emitted during construction. All construction- and operation-related emissions have been quantified based on the best available forecast of activities and using the California Emissions Estimator Model (CalEEMod; version 2016.3.2) software developed by the CAPCOA. The emissions quantification details appear in the Air Quality Technical Report included in the POD (EA Appendix F).

As shown in the Air Quality Technical Report, the GHG emissions associated with gen-tie construction activities would overlap with those emitted during solar facility construction. The

October 2019 3-27 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 3: AFFECTED ENVIRONMENT AND ENVIRONMENTAL EFFECTS OF ACTION effects of the Athos Solar Project (considered indirect effects to the Athos Gen-Tie Project) are explained in Section 3.1 (Environmental Documents Used), discussed in Appendix I of the POD, Air Quality and Greenhouse Gas Emissions Report, and summarized in EA Appendix J (Indirect Effects). The quantified GHG emissions demonstrate that the construction of the proposed or alternative gen-tie line and the solar facility would emit minor quantities of GHG emissions, and the indirect effects include operation of the solar facility that would produce renewable power and avoid GHG emissions from fossil fuel-fired resources that would otherwise be used to meet electricity demand.

Alternative 1: Proposed Action The gen-tie lines are a necessary component of the Athos Solar Project to connect the solar facility’s parcel groups and substations to the regional energy grid and ultimately deliver the supply of energy produced by the solar facility. The activities related to construction and operation of the gen-tie lines would generate minor quantities of GHG emissions at a rate of less than the SCAQMD threshold of 10,000 MTCO2e per year (SCAQMD, 2015). The gen-tie and the solar facility would have the combined direct and indirect effects of a net GHG reduction through the production of renewable power by the solar facility.

The activities related to construction and operation of the gen-tie lines would be required to comply with California Air Resources Board (ARB) rules and regulations to reduce GHG emissions, including SF6 control, if gas-insulated switchgear would be used at the solar facility substations, and would cause no other potential conflict with any applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions.

Alternative 2: Gen-Tie Segment #1 Alternative Route Option Similar to the Proposed Action, the Gen-Tie Segment #1 Alternative Route Option would have the combined direct and indirect effects of a net GHG reduction through the production of renewable power by the solar facility, and this alternative would not result in any conflict with any applicable GHG management plan, policy, or regulation.

Alternative 3: No Action Alternative The No Action Alternative would not develop the solar facility or gen-tie line, and it would avoid all new construction and/or operational activities. It would not result in a change in GHG emissions or any conflict with any applicable GHG management plan, policy, or regulation. It would also not result in the construction of new renewable energy generation resources. Therefore, the No Action Alternative would have no GHG impacts.

3.6.3 Cumulative Effects This impact assessment describes the proposed Athos Solar and Athos Gen-Tie Projects’ contribution towards global climate change through their GHG emissions. Because the direct environmental effect of GHG emissions is to influence global climate change, GHG emissions are inherently a cumulative concern, and there is no separate cumulative impacts analysis for global climate change.

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3.7 Lands and Realty Land use is defined by current land activities, land ownership, zoning (where applicable), and land use designations in adopted land use plans and policies. Land use is also affected by legal guarantees or limitations on land use, such as those provided by easements, deeds, ROW, claims, leases, licenses, and permits. BLM-administered lands are not zoned, but they may be encumbered by easements, ROWs, mining claims, and permits.

3.7.1 Affected Environment The BLM’s Lands, Realty and Cadastral Survey Program manages a wide range of public land transactions, such as purchases and acquisitions; sales and exchanges; withdrawals; leases and permits; ROW authorizations; and, cadastral survey services. Each year, thousands of people and companies apply to the BLM to obtain a ROW grant on public land. A ROW grant is an authorization to use a specific portion of public land for a specific project, such as electric transmission lines, communication sites, roads, trails, fiber optic lines, canals, flumes, pipelines, and reservoirs.

The existing ROW grants and ROW requests that would be crossed or adjacent to the gen-tie lines, which encompass the geographic scope of analysis, are:

 Desert Sunlight gen-tie line – existing;  SCE Red Bluff Substation – existing;  SCE 161 kV transmission line – existing;  Sprint underground telephone cable – existing;  Private access road – existing;  CALTRANS drainage easements – existing;  AT&T telephone cable – existing;  Desert Southwest Transmission Line – approved;  Desert Harvest gen-tie line – approved;  Eagle Crest Energy gen-tie line and FERC withdrawal area – approved;  Palen Solar Project gen-tie line – approved;  Clearway Arica Project and gen-tie line – proposed;  Clearway Jupiter LLC, project and gen-tie line – proposed;  Victory Pass I, LLC gen-tie line – proposed;  Desert Center Communication Site Serving the SCE Red Bluff Substation – existing;  3 SCE 12 kV Transmission Lines – existing;  Blythe Energy, LLC 230 kV transmission line – existing;  2 SCE 500 kV transmission lines – existing;  3 Southern California Gas underground gas lines – existing;  SCE 12 kV distribution line – existing.

Additionally, 1.1 miles of the Proposed Action would be located in the BLM Designated Utility Corridor K, as identified in the CDCA Plan. The CDCA Plan designated utility Corridor K for “multi-modal use,” allowing for new electrical gen-tie towers and cables of 161 kV or above. Utility Corridor K overlaps with Section 368 Federal Energy Corridor 30-52 in the Record of Decision for the West-Wide Energy Corridor (WWEC) PEIS. Energy Corridor 30-52 is identified

October 2019 3-29 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 3: AFFECTED ENVIRONMENT AND ENVIRONMENTAL EFFECTS OF ACTION for “multi-modal use,” which allows for electricity transmission and distribution facilities. Section 368 corridors are identified with a numeric designation and are often overlain on locally designated corridors, as is the case with the east-west Section 368 two-mile-wide Corridor 30-52 overlying BLM Designated Utility Corridor K; Figure 3.1-1 illustrates the corridor.

Finally, a number of applicable plans, laws and regulations control the use of BLM lands included in the Proposed Action area (see POD Appendix G, Regulatory Framework). These include the Federal Land Policy and Management Act (FLPMA) and its implementing regulations and the California Desert Conservation Area (CDCA) Plan, as amended by the Northern and Eastern Colorado Desert Coordinated Management (NECO) Plan, the Western Solar Plan and the DRECP.

3.7.2 Direct and Indirect Effects This section reviews the existing ROW and other uses to identify whether the Proposed Action conflicts with existing or proposed lands and realty requests on BLM land.

Development of the solar facility on private lands must not be inconsistent with the County General Plan and the Land Use Ordinance. Evidence that the Athos Solar Project meets these requirements is provided in the County’s EIR (Riverside County, 2019).

Alternative 1: Proposed Action Approximately 1.1 miles of the Proposed Action would be located in the BLM Designated Utility Corridor K. This corridor was designed wide enough to accommodate many transmission lines or other linear infrastructure and has the capacity to accommodate the 11 existing and proposed lines. The Red Bluff Substation was sited specifically to accommodate the development of renewable energy in the Desert Center area.

Due to potential gen-tie line crossings, all the gen-tie lines would be required to adhere to existing requirements for transmission lines including abiding by clearance rules set by the California Public Utility Commission. IP Athos, LLC is also proposing to underground portions of the gen- tie line at 220 kV and/or 34.5 kV to minimize potential crossing conflicts with existing and approved lines. Additionally, MM LR-1 (Prior ROW Coordination Plan) is required to minimize impacts to existing ROW holders as required by the BLM.

Alternative 2: Gen-Tie Segment #1 Alternative Route Option The Gen-Tie Segment #1 Alternative Route Option would avoid going through parcel APN 807-191-031. All existing ROW along the gen-tie line would remain the same and the acreage of the alternative that would fall within the BLM Corridor K would be the same. Because the crossing of existing and proposed ROW would not change, this alternative would have the same effects to lands and realty as the Proposed Action.

Alternative 3: No Action Alternative The No Action Alternative would not develop the gen-tie line or require new construction and/or operational activities. It would not cross or be adjacent to any existing or proposed ROW and no impacts would occur.

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3.7.3 Cumulative Effects Within the Desert Center region, the cumulative effects of the Proposed Action would be those that are physically adjacent to it (see Tables 3.1-1 and 3.1-2). The impacts of the cumulative projects, all of which are proposed in areas planned or zoned for transmission, would be the same as those of the Proposed Action. The ROW could result in conflicts where the solar projects, gen-tie lines, or transmission lines cross one another and could come in contact, however, as each ROW holder is subject to permitting by the BLM or County, they will be required to coordinate with other ROW holders, both existing and proposed, to ensure they do not interfere with other ROW holders. With new ROWs proliferating the Athos Gen-Tie Project area, implementing the DRECP CMA LUPA-BIO-16 and BLM’s regulations under FLPMA encourage activities would reduce impacts by reusing or collocating new transmission facilities with other existing facilities. Because of the required coordination, the projects would minimally result in cumulative impacts to lands and realty.

3.8 Noise 3.8.1 Affected Environment The geographic area included within this analysis includes areas extending approximately 0.5 miles from the boundary of the Proposed Action work sites for noise and 200 feet from the boundary of the work sites for vibration.

Existing Noise Environment. Ambient noise measurements were not conducted for this analysis because the environmental setting can be described from information drawn from previous studies in the area. The noise environment of the Athos Gen-Tie Project area depends on the proximity of the receiver to noise from vehicular traffic on SR-177 or I-10. Locations away from these highways experience very low levels of noise. The setting for noise also includes the Chuckwalla Raceway, built in 2010, which offers use of the track for a fee and hosts motor sports events primarily on weekends. The raceway owns the Desert Center Airport located onsite, which is infrequently used.

In 2009, ambient noise levels were measured at two isolated residences near the easternmost Athos Solar Project site parcels. For these residences more than 1.5 miles from I-10, the daytime average noise levels were found to be 43 dBA Leq, and nighttime average noise levels were 34 dBA Leq (CEC, 2010).

Noise Sensitive Receptors. In the Riverside County Noise Ordinance and Noise Element, “noise-sensitive” land uses include but are not limited to residences, passive recreation areas, schools, hospitals, rest homes, places of worship and cemeteries (Riverside County, 2015).

The residences nearest to the Athos Solar Project boundaries and gen-tie lines include:

 Residences approximately 100 feet east and 1,500 feet west of Parcel Group A.

 Cabins and recreational vehicle (RV) trailer parking at the Chuckwalla Valley Raceway approximately 750 feet south of Parcel Group B, and agriculture and rural residences 1,400 feet north of Parcel Group B.

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 Residences at 25750 Rice Road and 25950 Rice Road, and the Green Acres Mobile Home Park, which would be surrounded by Parcel Group C.

3.8.2 Direct and Indirect Effects Analysis of noise and vibration levels was performed through quantitative estimates of expected noise levels, review of agency policies and regulatory requirements, and qualitative analyses for issues that do not readily lend themselves to quantitative evaluation. Quantitative analyses were prepared to address noise and vibration from use of construction equipment onsite, noise from construction-related traffic, and noise from facility operations.

Alternative 1: Proposed Action Construction of the gen-tie structures, installation of poles and conductors, and underground excavation would include a line truck, crane, excavator, or possibly a helicopter. The maximum intermittent noise levels from a typical construction work spread at each gen-tie pole site would be dominated by the heavy-duty equipment, such as a truck-mounted auger or concrete mixer. With the anticipated equipment at the gen-tie construction spreads and brief overhead helicopter operations, construction would generate noise at levels up to 84 dBA. Typical noise levels and details on quantification appear in the Athos Solar Project EIR.

The proposed gen-tie route could pass near isolated residences. Gen-tie construction noise would result in a readily perceptible, but temporary, increase in daytime environmental noise. Construction noise would only affect locations near the construction crews that would move from site to site along the gen-tie line. To ensure consistency with the Riverside County Noise Ordinance, Mitigation Measures N-1 (Construction Restrictions) and N-2 (Public Notification Process) would ensure that construction activities outside of daytime hours would be limited to light-duty equipment and vehicles, and a construction notification process would be established. (See EA Appendix H for the full text of all mitigation measures.)

Alternative 2: Gen-Tie Segment #1 Alternative Route Option The Gen-Tie Segment #1 Alternative Route Option would avoid going through parcel APN 807-191-031. All remaining features of the gen-tie line and solar facility would remain the same as with the Proposed Action. Compared with the Project, the route of this gen-tie option would bring additional construction noise closer to residences near Parcel Group A. Overall noise impacts from this alternative would be similar to those of Proposed Action, and mitigation identified for the Proposed Action would be applicable to this alternative.

Alternative 3: No Action Alternative The No Action Alternative would not develop the solar facility and gen-tie line, and it would avoid all new construction and/or operational activities. It would not result in any change in ambient noise levels or generate noise from any new sources. Therefore, the No Action Alternative would have no noise impacts.

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3.8.3 Cumulative Effects The geographic area included within this analysis includes areas extending 0.5 miles from the boundary of the Proposed Action work sites for noise and 200 feet from the boundary of the work sites for vibration. The proposed gen-tie line would be built near projects that occur in the geographic scope for noise and vibration that would contribute to the Athos Gen-Tie project’s cumulative effects. The noise and vibration effects of the equipment used for construction of the proposed gen-tie line and the cumulative projects may or may not overlap spatially and temporally. As with the proposed solar facility, cumulative noise impacts of the gen-tie would be reduced through compliance with local laws and regulations and implementation of mitigation measures and feasible noise controls to protect sensitive receptors from noise generated by the Proposed Action.

Noise sources attributable to cumulative projects may cause adverse effects within approximately one mile of a construction site including truck routes, but the region of greatest influence is typically within 0.5 miles. The cumulative projects within 0.5 miles that would create noise include the EDF Palen Solar Project, Clearway Jupiter solar application, Clearway Arica Solar Project application, and the Victory Pass I, LLC gen-tie application. The areas of potential overlap of gen-tie noise and vibration and cumulative project construction-related effects would not be likely to create a cumulative noise or vibration impact at residences near the Proposed Action, and no cumulative effects would be likely from gen-tie noise or vibration.

3.9 Paleontological Resources 3.9.1 Affected Environment A Paleontological Resource Technical Report (Applied Earthworks, 2018a; also included in EA Appendix F [Athos Gen-Tie Project POD]) was prepared for the Athos Gen-Tie Project. The following geological units are present in the Athos Gen-Tie Project area, which is the geographic scope of analysis.

 Dune Sands (Qs) – Holocene era, deposits are too young to include fossilized material, may overlie significant fossiliferous geologic units at shallow depths.

 Alluvium (Qal/Qa) – Holocene era, deposits do not typically yield significant and intact fossil material, may overlie significant fossiliferous geologic units (older Pleistocene alluvium) at shallow depths.

 Other Surficial Deposits (Qc, Qco) – Pleistocene era, significant fossils have been found elsewhere in conglomerate, fossils may preserve well in pink clays.

 Subsurface Deposits (Qpb, Qp) and Paleosols – Older Pleistocene era, do not occur at the surface in the Athos Gen-Tie Project area but may occur at unknown depths, known to be fossiliferous and red where interstratified with basalt flows.

Most impacts on paleontological resources are direct and result from ground-disturbing activities. Indirect impacts include the unauthorized collection of fossils and other paleontological resources resulting from increased access to the resources (e.g., access by construction personnel, other visitors, etc.).

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Previous Research. The Natural History Museum of Los Angeles County and University of California Museum of Paleontology’s online database searches yielded no records for previously identified vertebrate localities within the Athos Gen-Tie Project area. The closest fossil localities have kangaroo rat, pocket mouse, tortoise, horse, camel, and llama fossils. In addition, there has been an influx of paleontological information associated with the large energy projects proposed and under construction in the Chuckwalla Valley. In particular, during the construction of the Desert Sunlight Project paleontological field monitors recognized 23 fossil localities: 13 significant and 10 nonsignificant. The specimens included carapace fragments of desert tortoise and poorly preserved tortoise shell fragments, skeletal remains of reptiles (e.g., gopher snake, horned lizard, and desert iguana), birds (e.g., finch), mammals (e.g., saber-toothed cat, bighorn sheep, kit fox, camel, llama, rabbit, gopher, kangaroo rat, ground squirrel, harvest mouse, and pocket mouse), and undetermined bones.

Field Studies. A pedestrian survey for Athos Solar Project was conducted in May 2018 and the Athos Gen-Tie in March 2019. Only one fossil specimen, a non-significant indeterminate vertebrate bone fragment, was observed. Paleontological monitors also examined subsurface geology exposed as part of geotechnical trenching at 33 of 40 locations on private land. The findings support the regional surface geology as mapped by previous scholars and allow a refinement in paleontological sensitivity determinations for the Athos Gen-Tie and Athos Solar Project area.

3.9.2 Direct and Indirect Effects Evaluation of potential paleontological impacts was based on the Paleontological Resource Assessment. Using information obtained from the desktop studies and field studies paleonto- logical sensitivity rankings were assigned to the Athos Gen-Tie Project area. These rankings are based on: (1) resource potential of geologic units found at the ground surface, (2) resource potential of geologic units thought to be present at unknown depths, and (3) likelihood of encountering those subsurface geologic units. See Figure 3.9-1 for the specific locations of sensitive units.

Table 3.9-1. Distribution of Paleontological Sensitivity Throughout the Proposed Action Area Class 2—Low Class 3—Moderate Class 4—High Class U—Unknown Potential (acres) (acres) (acres) (acres) 996.1 1140.4 1,453.2 71.7

Alternative 1: Proposed Action Sediments potentially containing significant paleontological resources are present along all gen- tie lines, but particularly Gen-Tie Segments #1 and #3. Ground disturbance associated with the Proposed Action could result in adverse effects to surficial and buried paleontologically sensitive geologic rock units. However, disturbance along the overhead gen-tie line would be limited to the areas where structures are installed. Underground construction would be primarily in existing roadways and would be less than 10 feet deep. In addition, Mitigation Measures (MM) P-1 (Project Paleontological Staff), MM P-2 (Paleontological Mitigation and Monitoring Plan), MM

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P-3 (Authority to Halt Ground Disturbance), MM P-4 (Paleontological Worker Environmental Awareness Program), MM P-5 (Construction Monitoring for Paleontological Resources), MM P-6 (Paleontological Reporting), and MM P-7 (Curation of Paleontological Materials) would reduce the impacts, see EA Appendix H for the full text.

Alternative 2: Gen-Tie Segment #1 Alternative Route Option The Gen-Tie Segment #1 Alternative Route Option would be longer than the Proposed Action. Overall, the amount of proposed ground disturbance would be slightly more than the Proposed Action. Therefore, the impacts for the Alternative Route Option would be similar, but with slightly greater ground disturbance the potential for impacts would likewise be slightly greater than for the Proposed Action. However, the mitigation measures for the Proposed Action would be applicable to Alternative 2.

Alternative 3: No Action Alternative The paleontological impacts associated with the Proposed Action would not occur under the No Action Alternative. There would be no direct or indirect impacts associated with the destruction of sensitive paleontological resources.

3.9.3 Cumulative Effects All projects in the cumulative scenario that would be located on the same geologic units within eastern Riverside County are considered within the geographic scope of analysis with respect to cumulative impacts on paleontological resources. Tables 3.1-1 and 3.1-2 list past, present, and probable future projects in the region that could impact paleontological resources. The California Clearway Jupiter solar application, Clearway Arica Solar application, Victory Pass I, LLC application, and Palen Solar Project would all be adjacent to the gen-tie line and the gen-ties of the Desert Harvest, Desert Sunlight and Palen Solar Projects would also parallel the Athos Gen- Tie near the Red Bluff Substation.

Paleontological resources have been documented in the general area of the Athos Gen-Tie Project, and fossils are likely to continue to be unearthed during project construction in addition to the other major ongoing and foreseeable solar and energy projects in eastern Riverside County. For the Proposed Action, Mitigation Measures P-1 through P-7 and similar monitoring, curation, and reporting measures being required to be implemented on other major infrastructure projects would minimize cumulative impacts to paleontological resources. It is anticipated that other foreseeable projects would follow similar procedures. Overall, if significant fossils are uncovered and appropriately documented and curated during construction of these major infrastructure projects, there could be an overall net gain to the science of paleontology by allowing fossils that would not otherwise have been found to be recovered, identified, studied, and preserved.

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3.10 Public Health and Safety 3.10.1 Affected Environment The geographic scope considered for cumulative impacts from health, safety, and hazardous materials is the area extending one mile from the gen-tie lines. One mile is the American Society of Testing and Materials standard search distance for hazardous materials. A Phase I Environmental Site Assessment was completed for the Proposed Action (Stantec, 2018). It did not identify any specific potential environmental contamination along the gen-tie lines although environmental contamination was identified on the nearby private parcels and munitions and explosives of concern and unexploded ordinance are a potential risk throughout the area due to past military training exercises. There are no mapped occurrences of naturally occurring asbestos minerals near the site (USGS and CGS, 2011).

The private Desert Center Airport is approximately 0.5 miles from Gen-Tie Segments #1 and #2. The private airport is part of the Chuckwalla Valley Raceway and is in use for airplane, helicopter, and skydiving operations.

Electric voltage and electric current from transmission lines create electromagnetic fields (EMF). Possible health effects associated with exposure to EMF have been the subject of scientific investigation since the 1970s. However, exposure to EMF has repeatedly not been recognized as an environmental impact to be analyzed. In 2015, the European Commission Scientific Committee on Emerging and Newly Identified Health Risks reviewed electromagnetic fields in general. It found that, overall, epidemiologic studies of extremely low frequency fields show an increased risk of childhood leukemia with estimated daily average exposures above certain levels, but no mechanisms have been identified and there is no support from experimental studies that explains these findings (NIH, 2018). As such, there are not defined or adopted standards for defining health risks from EMF.

3.10.2 Direct and Indirect Effects The hazardous materials analyzed include those potentially existing on the site and those that would be used as part of construction, operations and maintenance, and decommissioning identified in the Health, Safety, and Noise Plan (Appendix O of the POD [EA Appendix F]) and the Hazardous Materials Management Plan (Appendix P of the POD [EA Appendix F]). Potential existing hazards were assessed based on review of informational State hazard databases and maps for the parcels comprising the Athos Gen-Tie and Athos Solar Project area.

Alternative 1: Proposed Action The Proposed Action is not anticipated to produce, use, store, transport, or dispose of extremely hazardous substances (those governed pursuant to Title 40, Part 335 of the CFR). During construction of the Proposed Action, small amounts of hazardous materials, such as fuels and greases to fuel and service construction equipment. The fuels would be stored in locked temporary aboveground storage tanks or sheds within a fenced and secure temporary staging area at the Athos Solar Project site. Storage procedures would be dictated by a Hazardous Materials Management Plan.

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All weed and insect control on BLM-administered lands would be in accordance with the BLM- approved Integrated Weed Management Plan (see Mitigation Measure BIO-4 in EA Appendix H), which would reduce the potential for exposure of people to pesticides or herbicides.

The risk of accident conditions involving the release of hazardous materials into the environment that could create a significant hazard to the public or the environment is low. A Hazardous Materials Management Plan that would be developed that would contain storage procedures and spill prevention measures. In addition, a Stormwater Pollution Prevention Plan or equivalent document would reduce potential impacts from spills to surface water quality. The implementation of MM PHS-1 (WEAP) would further reduce the effects from accidental releases of hazardous materials into the environment.

The Proposed Action is near the Palen Pass maneuvering area and the historic World War II training camps. During construction, maintenance, and closure and decommissioning activities, land disturbance activities could unearth unexploded World War II-era and more recent vintage munitions which would pose a safety risk to the construction workers. MM PHS-2 (UXO, Identification, Training and Reporting Plan; identified as HAZ-3 in the Athos EIR) would require the Applicant to prepare a plan that would formalize unexploded ordnance (UXO) training, investigation, removal, and disposal. The plan would include a training program outline and materials, qualifications of the trainers, identification of available experts to respond to any notifications, and a work plan for recovery of any ordnance. Implementation of the plan would ensure that potential UXO risk would be reduced.

The proposed Gen-Tie Segments #1 and #2 would be located within two miles of the Desert Center Airport and the gen-tie structures would be within an area that is considered Compatibility Zone E for an airport in the Riverside County Airport Land Use Compatibility Plan1. However, the Desert Center Airport was purchased by the Chuckwalla Valley Raceway and is no longer included in the Riverside County Circulation Element. Because the Desert Center Airport is no longer part of the General Plan and does not have an influence area, this review is not required. The owners of the airport, Chuckwalla Valley Raceway, are aware of the Proposed Action and would coordinate any landings at the airport including advising any planes as to the potential nearby structures such that there would be no significant adverse effects to the airport or on public safety.

Access to the gen-tie line segments would be provided from SR-177. The gen-tie line would use the same access roads as the solar facility, see Figure 2-1. Should any local roadways be temporary closed during construction, APM TRA-2 (Construction Traffic Control Plan) would require the Proponent to develop alternative routes allowing for continued vehicular access. Traffic Safety Coordinator(s) will oversee the installation of proper signage to ensure safe public use of open routes on public lands in the Athos Gen-Tie Project area. MM TRA-1 (Construction Traffic Control Plan) is also proposed to provide specificity regarding the means to reduce potential impacts from any temporary travel lane disruptions and requires the Construction Traffic

1 Compatibility Zone E is defined as the area wherein 10 to 15 percent of near-airport accidents occur and where concern for risks applies to uses for which potential consequences are severe (e.g. very-high-intensity activities in a confined area). For uses in Compatibility Zone E, Riverside County Airport Land Use Commission review is required for objects greater than 100 feet tall.

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Control Plan be reviewed and approved by Riverside County Department of Transportation and Caltrans to reduce or avoid adverse impacts to emergency response. Operation of the gen-tie line is not expected to require any temporary lane closures that could restrict the movements of emergency vehicles and would not impair the implementation of or physical interference with an adopted emergency response plan or emergency evacuation plan, see POD Appendix H, Traffic Impact Assessment, in EA Appendix F.

Alternative 2: Gen-Tie Segment #1 Alternative Route Option Gen-Tie Segment #1 Alternative Route Option would be located east of the proposed gen-tie and would be approximately 0.65 miles longer. Because the Route Option is located in the same general vicinity and would require a similar workforce and construction and operation activities, the impacts due to hazards and hazardous materials from the gen-tie lines would be the same as for the Proposed Action and would require implementation of the same mitigation measures.

Alternative 3: No Action Alternative The No Action Alternative would not result in any new construction and/or operational activities or any new associated ground-disturbing activities. The No Action Alternative would not expose people, the environment, or structures to any hazards and hazardous materials and would not introduce risks associated with accidental spills of hazardous materials, impacts to aviation, or impacts to emergency response in the area.

3.10.3 Cumulative Effects The geographic scope considered for cumulative impacts from health, safety, and hazardous materials is the area extending one mile from the gen-tie lines. Tables 3.1-1 and 3.1-2 list existing and reasonably foreseeable projects in the region. The DC 50 Solar Project; Clearway Jupiter Solar Project; Victory Pass I, LLC Project; Clearway Arica Project, and Palen Solar Project are projects that would all be within one mile from the Proposed Action.

The cumulative risk of transport, use, and disposal of hazardous materials during construction would be limited to the areas where concurrent construction is occurring or where concurrent roads are being used for construction traffic. All the cumulative solar projects would share the access roads near Gen-Tie Segment #4, all but Victory Pass I, LLC would also share some or all of the access road for Gen-Tie Segment #3. Operation and maintenance of the Proposed Action would involve periodic and routine transport, use, and disposal of minor amounts of hazardous materials, primarily petroleum products (fuels and lubricating oils) and motor vehicle fuel. Existing regulations and standard measures such as a WEAP would ensure that the combined risk due to hazards and hazardous materials from the cumulative projects within the geographic scope of analysis would be reduced.

Construction of the Proposed Action could encounter previously un-discovered hazardous mate- rials sites or UXO. While other cumulative projects would also have the potential to uncover hazardous materials of UXO, they would only combine to create a cumulative effect if the hazardous materials were discovered near each other and at the same time which is unlikely. Therefore, the risk of a cumulative effect is low.

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The only cumulative project within Compatibility Zone E for the Desert Center Airport that could potentially combine with impacts from the Proposed Action is the Clearway Project. While the Desert Center Airport does not have an official zone of influence, it is anticipated that the Chuckwalla Valley Raceway would be aware of the Clearway Project and would coordinate with the applicant to ensure no impacts would occur to pilots. Therefore, it would not combine to result in a cumulatively substantial effect to airports.

3.11 Recreation 3.11.1 Affected Environment The Proposed Action is located in eastern Riverside County on BLM-administered lands that is identified as a DFA in the DRECP Land Use Plan Amendment. DFAs are areas designated as suitable for renewable development. In eastern Riverside County, which is the geographic scope for the analysis, the BLM administers many other lands for recreational opportunities, as identified in Table 3.11-1.

According to the BLM Recreation Management Information System Report 23(c), between October 1, 2015 and September 30, 2016, the total Visitor Days for Eastern Riverside County recreation area was 842,319; most of which was dispersed use (775,200 visits). The most attractive recreational area is Joshua Tree National Park, two miles north of the gen-tie line. The main recreational users of the area are residents from Desert Center and Blythe, or visitors stopping for short periods while traveling along I-10 (BLM, 2018).

Table 3.11-1. Recreation Areas and Special Designations with Recreational Opportunities Direction from Approximate Recreation Area Proposed Action Distance (miles) Size (acres) Chuckwalla Special Recreation south Crossed by Gen-Tie Seg #4 228,480 Management Area Palen-Ford Playa Dunes ACEC north, east, 1 (from Gen-Tie Seg #4) 41,370 and south Chuckwalla Desert Wildlife Management south Crossed by Gen-Tie Seg #4 514,400 Area ACEC Palen Dry Lake ACEC southeast 4.8 (from Gen-Tie Seg #4) 3,630 Chuckwalla Mountains Wilderness south 1.5 (from Gen-Tie Seg #4) 99,550 Palen-McCoy Wilderness northeast 3.15 (from Gen-Tie Seg #4) 236,490 Corn Springs ACEC southwest 4.5 (from Gen-Tie Seg #4) 2,470 Alligator Rock ACEC west 5 (from Gen-Tie Seg #4) 7,750 Desert Lily Preserve ACEC northwest 1.2 (from Gen-Tie Seg #1) 2,060 Joshua Tree National Park* northwest 2 (from Gen-Tie Seg #1) 1,017,750 Joshua Tree Wilderness* northwest 2 (from Gen-Tie Seg #1) 549,500 Little Chuckwalla Mountains Wilderness southeast 17 (from Gen-Tie Seg #4) 28,030 Chuckwalla Valley Dune Thicket ACEC southeast 15.5 (from Gen-Tie Seg #4) 2,270 Corn Springs Campground southwest 6.5 (from Gen-Tie Seg #4) 9 units Bradshaw Trail Back Country Byway south 17 (from Gen-Tie Seg #4) 65 miles Source: BLM, 2018. * Managed by the National Park Service.

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Off-Highway Vehicle Routes. The CDCA Plan and Northern and Eastern Colorado Desert Coordinated Management Plan Amendment state that vehicle access is among the most important recreation issues in the desert. The Desert Center region has Off-Highway Vehicle (OHV) open routes. Observations by BLM staff and Law Enforcement Rangers report that use is relatively low, not exceeding 300 visits per year (BLM, 2018). Gen-Tie Segment #1 crosses BLM Route DC 540 and DC 529; Gen-Tie Segment #2 crosses BLM Routes DC 511 and DC 378 and follows BLM Route DC 510 for 2,100 feet and DC 379 for 2,800 feet; and Gen-Tie Segment #3 follows BLM Route DC 379 for 4 miles and crosses Route DC 511. The BLM open routes across the Proposed Action area are shown on Figure 3.11-1.

3.11.2 Direct and Indirect Effects This section analyzes potential effects of the Proposed Action related to recreation and assesses the impacts to known recreational uses. The CDCA Plan and NECO Plan Amendment, which includes a detailed inventory and designation of open routes for motorized-vehicle use, were reviewed to determine impacts to open routes.

Alternative 1: Proposed Action The gen-tie line is located on private land and BLM-administered land designated as a DFA. South of the I-10, approximately 0.15 miles of Gen-Tie Segment #4 cross the Chuckwalla ACEC and is adjacent to the Chuckwalla Special Recreation Management Area (SRMA) within an existing utility corridor. Table R-5 in the NECO Plan Amendment summarizes the route designations for the Proposed Action area by Field Office and USGS Map Name. The Proposed Action will take place on USGS Maps: Victory Pass, which has 104 miles of designated routes; East of Victory Pass, which has 54 miles of designated routes; and Corn Springs, which has 77 miles of designated routes. Under Alternative 1, no routes are proposed to be permanently closed, and less than 5 miles of trails may be affected by construction traffic or temporarily (up to several weeks) closed during underground installation of Gen-Tie Segment #3 in the existing roadway. During this time, use of BLM Routes DC 378, DC 511 and DC 502, among others, may provide alternative east-west access pending final engineering and construction plans. Given the Applicant Proposed Travel and Transportation Measures which can be reviewed in Section 2.5 or Table 2-1, the gen-tie line would not result in direct loss of recreation nor would it affect access to designated OHV routes. Any temporary alternate routes determined during final engineering that would be implemented as part of APM TRA-2 will comply with DRECP CMA LUPA-REC-6 (see EA Appendix H). Once the access on the designated route is reestablished, all signage shall be removed.

The Proposed Action would introduce a new 34.5 kV and 220 kV transmission line, which would be visible from nearby lands designated as ACEC, SRMA, and Joshua Tree National Park wilderness. All views would include existing transmission and solar infrastructure or approved transmission and solar infrastructure. The gen-tie construction would be of short duration and the visual change would be mitigated as 5 of the 7 miles of the gen-tie would parallel or collocate with existing or approved transmission lines and utilize appropriate design features as determined by the BLM Authorized Officer. Additionally portions of the gen-tie line may be constructed underground in Gen-Tie Segment #3 as well as a short length (up to 500 feet) of Gen-Tie

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Segment #4, which would eliminate operational visual impacts of the Athos Gen-Tie to recreational viewers in these areas. With effective compliance with applicable DRECP CMAs listed in Table H-1 in EA Appendix H, no mitigation measures are required for the direct effects of the Athos Gen-Tie Line.

Alternative 2: Gen-Tie Segment #1 Alternative Route Option The Gen-Tie Segment #1 Alternative Route Option would move the gen-tie east to avoid parcel APN 807-191-031. It would impact the same number and miles of open routes because there are no open routes that cross this portion of the gen-tie line. There is no difference between the proposed Gen-Tie Segment #1 and the alternative for recreation.

Alternative 3: No Action Alternative The No Action Alternative would not develop the gen-tie line or require new construction and/or operational activities. It would not result in direct or indirect impacts to recreation or the closure or isolation of designated OHV routes and would have no impacts to recreation.

3.11.3 Cumulative Effects The cumulative geographic scope for recreation is the Desert Center region because the direct and indirect impacts to recreation would be additive they could result in direct loss of recreation and indirect impacts to the same resources. Within this area there is one existing utility solar facility (Desert Sunlight) and six approved or proposed projects (Desert Harvest, DC 50, Clearway Jupiter, Clearway Arica, Victory Pass I, LLC, and Palen), see Tables 3.1-1 and 3.1-2.

If all the solar projects were developed, loss of the local Desert Center OHV routes would be significant because all routes except Route DC 511 (the utility access road) and Route DC 952 (protected from impact by the Palen Solar Project mitigation) would be re-routed or closed. The contribution to the cumulative loss of OHV routes by the Proposed Action would be minimal, because any closure associated with the gen-tie would be limited in duration and alternate access would be provided.

If all the solar projects were developed, they would result in almost 20,000 acres of solar development in the Desert Center area which would substantially change the region and the vistas from nearby recreational facilities prized for their isolation. Recreationists looking for solitary experiences would potentially look for other areas to recreate which would increase the use of other parks or wilderness areas. Because of the large amount of wilderness and solitary recreational areas in Eastern Riverside County and in the California desert and the limited use of the recreational areas near the Proposed Action, it is unlikely that recreationists who leave the Desert Center area for elsewhere in California would increase the use of such areas such that substantial physical deterioration of the region would occur or be accelerated. While some of the BLM-administered land may be used for recreation, the direct and indirect cumulative loss of recreational lands would be minimal compared with the land available for recreation.

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3.12 Social and Economic Resources This section discusses whether implementation of the Proposed Action and alternative would promote population growth, affect existing housing availability, alter local economic trends and employment, and/or generate social change or disruption. The analysis is based on existing population, housing, and local workforce data, as well as baseline social conditions gathered during public outreach meetings held on previous renewable energy and transmission line projects in the area and the Athos Solar Project scoping meeting held in June 2018.

3.12.1 Affected Environment The entire gen-tie ROW and overall Athos Project study area (which includes the gen-tie and proposed solar facility site) is contained within Census Tract 469. The populated area nearest the site is the community of Desert Center, represented in the U.S. Census as the Desert Center CDP. In addition to Desert Center, select social and economic data is shown for the City of Blythe and Riverside County as a whole. Table 3.12-1 presents population, housing, employment, and income data for the Proposed Action area.

Table 3.12-1. Socioeconomic Characteristics Total Median Geographic Area Population Housing Employment Income Census Tract 469 1,632 1,220 Total Units 595 Employed $40,809 (53.5% Vacancy Rate) 39 Construction Trades (19.8% Unemployment Rate) Desert Center 189 213 Total Units 67 Employed $57,679 CDP (71.8% Vacancy Rate) 5 Construction Trades (0% Unemployment Rate) City of Blythe 19,675 6,331 Total Units 5,531 Employed $40,448 (21.2% Vacancy Rate) 292 Construction Trades (13.0% Unemployment Rate) Riverside County 2,323,892 820,300 Total Units 946,798 Employed $57,972 (14.0% Vacancy Rate) 81,190 Construction Trades (11.3% Unemployment Rate) Source: U.S. Census Bureau, 2018 As shown in Table 3.12-1, the local area (Census Tract 469 and Desert Center CDP) contain a high vacancy rate, which directly correlates these areas providing transient and temporary housing opportunities for seasonal residents (“snow birds”). While the immediately local labor force provides limited construction trade workers, Riverside County provides a strong construction labor force. Median income data shows Census Tract 469 and the City of Blythe being lower than that of Desert Center and Riverside County as a whole.

The geographic area of analysis would be areas within a 2-hour commute of the Proposed Action, as that would be the distance that temporary workers may migrate into local communities during construction.

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3.12.2 Direct and Indirect Effects

Alternative 1: Proposed Action Many temporary workers needed for construction of the gen-tie would reside within a 60- to 90- minute drive time of the Proposed Action area. This assumption is based on observations regarding worker commute habits during construction monitoring efforts for recent similar renewable energy and transmission projects in the California desert. As shown in Table 3.12-1, Riverside County contains a significant construction and trades workforce. However, it is likely that some construction workers would come from outside a reasonable commute area and seek temporary housing proximate to the work area. Given the existing numbers of available housing units and vacancy rates in these local communities (refer to Table 3.12-1), adequate rental housing is likely available for workers seeking temporary local housing. An increased demand from construction workers could affect transient housing availability for typical seasonal residents within these areas. However, impacts from such a temporary change are difficult to predict given that supply and demand are based on seasonal and other unpredictable variables.

The nature and magnitude of social impacts from temporary construction worker in-migration and construction activities on smaller rural communities are difficult to predict. While some degree of social disruption is likely to accompany short-term construction worker in-migration, there is insufficient evidence to predict the extent to which rural communities are likely to be affected, which population groups within each community are likely to be most affected, and the extent to which the social disruption is likely to persist beyond facility construction. The presence of construction workers and activities is expected to be most noticeable within the Desert Center area. However, it is not expected to create adverse long-term demographic shifts or social change. While local small communities (like Desert Center) host a rural lifestyle in low-populated, isolated, homogenous communities, construction would be temporary with many workers expected to commute from within the local workforce.

While operation would not generate a large number of permanent jobs, beneficial economic effects would occur from construction and operation of the Proposed Action. Local spending from the workforce would be an economic stimulator for local businesses. Additionally, local procurement of goods and services during construction and operation, and an increase in tax revenues is considered beneficial to the local communities. Important public benefits include short-term increases in local expenditures, payrolls, and sales tax revenues. These would positively affect the economy at both local and regional levels.

Alternative 2: Gen-Tie Segment #1 Alternative Route Option Alternative 2 would result in identical overall social and economic impacts as that discussed above under the Proposed Action, because it would not substantially alter the necessary construction workforce, affected local communities, or result in any new adverse impacts.

Alternative 3: No Action Alternative Under the No Action Alternative construction of the gen-tie line would not occur. Local communities would not be affected and the public benefits discussed under the Proposed Action would not occur.

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3.12.3 Cumulative Effects Construction of projects listed in Tables 3.1-1 and 3.1-2 would also bring temporary workers into local communities, so the geographic area of analysis would be areas within a 2-hour commute of the Proposed Action. Many of the identified projects involve the construction of new utility components that may require a short-term influx of workers with specialized skills. As shown in Table 3.12-1, there is available housing in the area, considering a higher number of transient housing units are available during the summer months. It should be noted many cumulative projects listed are already operational. However, there is a possibility that the Proposed Action could combine with other foreseeable renewable energy projects to create a greater demand for housing should the construction time frames overlap. The most likely projects on BLM land with the potential for overlapping schedules are the Desert Harvest Project with an average workforce of 100 people and Palen Solar Project with an average workforce of 566 people (BLM, 2012; BLM, 2018).

The influx of temporary construction workers within the local communities affected by the Proposed Action would create short-term demographic shifts or social change. While the development of future cumulative projects could contribute to a long-term in-migration of workers, it is not known whether any of these projects or other future projects would be constructed concurrently and affect the same local communities as the Proposed Action. Any community disruption associated with the Proposed Action would not persist beyond proposed construction activities. Consequently, the Proposed Action would not be expected to contribute to a cumulative disruption of local communities.

The development of future cumulative renewable energy and transmission projects is also expected to create economic effects within the Athos Gen-Tie Project area that are similar to the Proposed Action. This could include local spending from the workforce, local procurement of goods and services during construction and operation, and a potential increase in tax revenues, all of which could serve as an economic stimulator for local businesses and government. The beneficial effect of the Proposed Action on the local economy may combine with the effects of other projects to contribute to a cumulative economic impact. 3.13 Special Designations 3.13.1 Affected Environment The geographic scope for special designations consists of eastern Riverside County. The gen- tie lines would traverse mainly BLM-administered public lands within portions of the Riverside East SEZ and within a DRECP DFA. A portion of the gen-tie lines north and south of the I-10 corridor would also be sited within the Section 368 Federal Energy Corridor as established by the Westwide Energy Corridor Record of Decision. Gen-Tie Segment #4 would cross the Chuckwalla ACEC south of I-10, paralleling an existing overhead transmission corridor and within the aforementioned existing BLM utility corridor. Four wilderness areas are located within 20 miles of the Proposed Action: the Chuckwalla Mountains Wilderness, Palen-McCoy Wilderness, Joshua Tree Wilderness, and Little Chuckwalla Mountains Wilderness. They have no developed trails, parking/trailheads, or other visitor use

October 2019 3-44 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 3: AFFECTED ENVIRONMENT AND ENVIRONMENTAL EFFECTS OF ACTION facilities. Visitor use within the wilderness areas is very light although the BLM has no visitor use counts. (BLM, 2018). The Proposed Action does not cross the wilderness. Seven ACECs are located near the Proposed Action: Chuckwalla ACEC, Palen Dry Lake ACEC, Corn Springs ACEC, Alligator Rock ACEC, Desert Lily Preserve ACEC, and Chuckwalla Valley Dune Thicket ACEC. The Alligator Rock ACEC and the Corn Springs ACEC primarily protect cultural resources. The Chuckwalla and Desert Lily ACECs protect sensitive wildlife and plant species, while Chuckwalla Valley Dune Thicket and Palen Dry Lake ACECs protect both natural and cultural resources. The Palen-Ford Playa Dunes ACEC maintains essential fringe-toed lizard habitat and ecological processes. As discussed above, Gen-Tie Segment #4 would cross the Chuckwalla ACEC south of I-10, paralleling an existing overhead transmission corridor and within an existing BLM utility corridor. Under the DRECP LUPA, ACECs are managed using ground disturbance thresholds. The unit of the Chuckwalla ACEC where the gen-tie segment would cross is above the ground disturbance threshold (0.5 percent) identified in the DRECP LUPA. A SRMA is an administrative unit where existing or proposed recreation opportunities and recreation setting characteristics are recognized for their unique value, importance, or distinct- iveness. They are identified for directing available recreation funding and personnel to specific, structured recreation opportunities. They are managed to protect and enhance a targeted set of activities, experiences, benefits, and desired recreation. The DRECP LUPA has designated one SRMA less than 1,000 feet south of the Proposed Action on the south side of the I-10, the Chuckwalla SRMA. The primary activities for the Chuckwalla SRMA are motorized recreation touring and other activities that rely on motorized vehicles to access public lands.

3.13.2 Direct and Indirect Effects Evaluation of potential conflicts with Special Designations was based on a review of relevant planning documents and a review of the Proposed Action site and surrounding area. Alternative 1: Proposed Action As noted, the gen-tie line would traverse mainly BLM-administered public lands within portions of a SEZ and DFA. The Western Solar Plan and DRECP amended the CDCA Plan to allow for the development of solar energy generation on public lands in this specific area. As part of a DFA, the Proposed Action area has been designated as suitable for energy accessory uses and the proposed use would be compatible with the CDCA Plan. A Plan Amendment would not be required for construction of the proposed gen-tie lines (see LUPA-LANDS-8 [“[t]ransmission facilities may be located outside of designated corridors within DFAs without a plan amendment”] and DFA-LANDS-7 [“[t]ransmission facilities are an allowable use and will not require a plan amendment within DFAs”]).

Other than DFA and SEZ, the Proposed Action would cross the Chuckwalla ACEC and be adjacent to the Chuckwalla SRMA. Where the overhead gen-tie line enters these designations, it is within a designated utility corridor and a Section 368 Federal Energy Corridor. Designated utility corridors allow for transmission infrastructure without requiring a land use plan amendment. In the Chuckwalla ACEC, because the unit crossed by the gen-tie line is above the ground disturbance threshold, DRECP CMA ACEC-DIST-2 (see EA Appendix H) would require mitigation, such as restoration, at a 3:1 ratio for new ground disturbance. Gen-tie structures in

October 2019 3-45 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 3: AFFECTED ENVIRONMENT AND ENVIRONMENTAL EFFECTS OF ACTION the ACEC would cause new ground disturbance (estimated 2 structures with 72 square feet of permanent disturbance, pending final engineering). Access roads and other construction areas in the ACEC could use the existing infrastructure to limit new ground disturbance. The gen-tie line would not conflict with Federal policies, regulations, and goals.

While the gen-tie lines would have indirect effects on other nearby designations such as the ACECs or wilderness, they would follow existing corridors or approve transmission lines and views would be limited. With effective compliance with applicable DRECP CMAs listed in Table H-1 in EA Appendix H, no mitigation measures are required for the direct effects of the Athos Gen-Tie Line.

Alternative 2: Gen-Tie Segment #1 Alternative Route Option The Gen-Tie Segment #1 Alternative Route Option would avoid going through parcel APN 807-191-031. All remaining special designations along the gen-tie line would remain the same. Because the land use designations along and surrounding the gen-tie line would not change, this alternative would have the same effects to Special Designations as the Proposed Action.

Alternative 3: No Action Alternative The No Action Alternative would not develop the gen-tie line or require new construction and/or operational activities. It would not conflict with any special designations, but it also would not meet the DRECP goal of facilitating renewable energy.

3.13.3 Cumulative Effects The geographic scope of the cumulative effects analysis for special designations consists of eastern Riverside County. This is based on the jurisdictional boundaries within which the impacts of land use decisions of the Athos Solar Project and other projects described in Table 3.1-1 and 3.1-2 could be additive or synergistic.

Past and present projects occurring near the Proposed Action on private lands primarily include agricultural operations with some rural residences. Public lands have been and continue to be primarily undeveloped with some large-scale solar. Additionally, many solar renewable projects have been proposed on both BLM-administered land and private land. The projects on public land are in a DFA and the ones on private land are primarily on land designated as agriculture or open space. With appropriate permitting each project would not result in impacts to special designations and would be complying with the goals of renewable siting in DFAs. The unit within the Chuckwalla ACEC that includes the Athos Gen-Tie is above its ground disturbance threshold. Therefore, each of the 6 projects proposed within the ACEC would be subject to DRECP CMA ACEC-DIST-2 (see EA Appendix H) and would require mitigation, such as restoration, at a 3:1 ratio for new ground disturbance. The DRECP was designed to consider large-scale development of renewable energy projects, so achieving this would not result in a cumulative impact to special designations.

3.14 Travel and Transportation This section discusses the effects of the Proposed Action and alternatives on transportation facilities. Because the site is in a remote area, construction materials would be brought from long

October 2019 3-46 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 3: AFFECTED ENVIRONMENT AND ENVIRONMENTAL EFFECTS OF ACTION distances and many construction workers would travel from surrounding communities within Riverside County. Consequently, all Athos Gen-Tie Project–related traffic would utilize Interstate 10 (I-10) and SR-177 for regional travel. The “study area” for the surface transportation analysis would be the existing roadways and intersections with the potential to experience an increase in traffic volume and/or travel disruptions during construction, primarily I-10, SR-177, and local roadways (including those crossed by the proposed gen-tie line). The Transportation Impact Assessment provides the methodology, data, analysis, and findings for the surface transportation analysis, see Athos Gen-Tie POD Appendix H in EA Appendix F.

3.14.1 Affected Environment Key roadway facilities utilized by the Athos Gen-Tie Project include the following:

 Interstate 10: I-10 is a major east/west interstate freeway connecting Southern California to Phoenix, AZ and destinations further east. I-10 is a four-lane freeway with interchanges near the Proposed Action site at SR-177 and Corn Springs Road. The posted speed limit on I-10 is 70 mph. In the study area, I-10 carries roughly 26,000 average daily trips (ADT) and operates at level of service2 (LOS) A at both the intersections with SR-177 and Corn Springs Road.

 State Route 177: SR-177 (also known as Rice Road) is a north/south highway running between Desert Center/I-10 and State Route 62 (approximately 25 miles northeast of Desert Center). SR-177 is a two-lane road, and the posted speed limit is 65 mph. It carries approxi- mately 2,800 ADT. With an assumed maximum capacity of 1,900 vehicles per hour (Year 2010 Highway Capacity Manual), SR-177 operates at LOS A near the Proposed Action.

3.14.2 Direct and Indirect Effects

Alternative 1: Proposed Action Temporary construction trips would include those associated with worker commutes and equipment/material deliveries which are estimated to be 285 ADT during peak activity (265 passenger vehicles and 20 trucks). This is based on gen-tie line construction accounting for 25 percent of the total Athos Solar Project-related trips. Trips associated with the construction of the proposed gen-tie, are expected to generate a temporary 1.1 percent increase in ADT to I-10 and 10.2 percent increase in ADT to SR-177, which indicates that both roads would continue to operate at the existing Level of Service. However, large delivery truck trips could result in temporary delays on affected local roadways, which typically experience very low daily traffic volumes and delays. These delays would only be expected during large material deliveries, which could occur periodically throughout construction. Additionally, construction of the gen-tie would require overhead conductors be strung across public roadways and existing BLM open routes and agricultural access roads. During conductor stringing, roads and travel lanes could experience brief and temporary closures as overhead work is conducted. Additionally, under- ground construction of Gen-Tie Segment #3 in the existing roadway may cause its temporary closure.

2 LOS is an indicator of operating conditions on a roadway or at an intersection and is defined in categories ranging from A to F. LOS A represents the best traffic flow conditions with very low delay, and LOS F represents poor conditions.

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During this time, use of BLM Routes DC 378, DC 511 and DC 502, among others, may provide alternative east-west access pending final engineering and construction plans. In addition, APM TRA-2 (Construction Traffic Control Plan) would require the Proponent to develop alternative routes allowing for continued vehicular access for any designated route (see Table 2-1) temporarily impacted by construction activities. Traffic Safety Coordinator(s) will oversee the installation of proper signage to ensure safe public use of open routes and other recreation opportunities on public lands in the Athos Gen-Tie Project area. MMTRA-1 (Construction Traffic Control Plan) is also proposed to provide specificity regarding the means to reduce potential impacts from any temporary travel lane disruptions and requires the Construction Traffic Control Plan be reviewed and approved by Riverside County Department of Transportation and Caltrans to reduce or avoid adverse impacts to the affected circulation system.

Desert Center Airport is a private airport located within 0.5 miles of the nearest portion of proposed gen-tie line under the Proposed Action. Gen-tie structures and conductor spans would require review by the Federal Aviation Administration (FAA) to determine any potential hazard to air navigation. During their review, the FAA will identify if any features of the Proposed Action pose aviation hazards and recommend any safety devices or measures. Pending incorporation of FAA determinations into the Proposed Action, MM TRA-2 (Comply with FAA 7460-1 Determination Recommendations) is proposed to ensure that the Proponent would incorporate all FAA recommendations into final design of the gen-tie to ensure safety of navigable airspace.

The movement of heavy trucks and equipment on roadways providing access to gen-tie work areas could potentially result in damage to road surfaces, shoulders, curbs, sidewalks, signs, and light standards. Underground gen-tie line trenching would also potentially occur in roadways. MM TRA-3 (Repair Roadways and Transportation Facilities Damaged by Construction Activities) is proposed to ensure any damage and deterioration attributed to the Proposed Action would be repaired.

Alternative 2: Gen-Tie Segment #1 Alternative Route Option The altered gen-tie route associated with Alternative 2 would result in identical travel and transportation impacts as that discussed above under the Proposed Action as it would not substantially alter affected roadways, distance to Desert Center Airport, or the potential for roadway damage.

Alternative 3: No Action Alternative Under the No Action Alternative, construction of the gen-tie line would not occur. Transportation facilities would not be affected.

3.14.3 Cumulative Effects The geographic area included within this analysis includes the study roadways and intersections and I-10. For aviation safety, the geographic study area is 20,000 feet, because that is the area where there would be potential impacts to the Desert Center Airport.

Operation of the gen-tie line would result in negligible daily trips to study area roadways. Therefore, the cumulative impact analysis is limited to impacts generated during construction. If

October 2019 3-48 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 3: AFFECTED ENVIRONMENT AND ENVIRONMENTAL EFFECTS OF ACTION foreseeable projects identified in Tables 3.1-1 and 3.1-2 were developed at the same time, they would result in an increase in traffic and an increased risk of transportation hazards or damage to roadways. The Proposed Action’s contribution to cumulative impacts would be reduced with the implementation of MMTRA-1, which requires the Proponent to define the methods to maintaining close coordination with Riverside County Department of Transportation and Caltrans prior to and during construction to minimize cumulative impacts of multiple simultaneous construction projects affecting shared portions of the circulation system. Mitigation Measure TRA-3 would ensure that the Proposed Action would not have a cumulative contribution to roadway damage. Finally, FAA review of the proposed gen-tie line (Mitigation Measure TRA-2) would ensure no adverse cumulative contribution to safe navigation of airspace. The complete descriptions of mitigation measures discussed can be reviewed in Appendix H

3.15 Vegetation and Wildlife Resources 3.15.1 Affected Environment This description of the vegetation and wildlife resources of the Proposed Action is based on the Biological Resources Technical Report, Athos Renewable Energy Project, Riverside County, California (BRTR) prepared by Ironwood Consulting Inc. (Ironwood) in 2018 (POD Appendix D, EA Appendix F). The geographic extent for analysis includes the desert portion of Riverside County, as discussed under Cumulative Effects below.

Vegetation and Habitat. Within BLM lands, the gen-tie line would cross two natural vegetation communities: creosote bush scrub (106.6 acres) and desert dry wash woodland (58.0 acres); one distinct natural habitat type: desert pavement (16.4 acres); and former agricultural land recovering as creosote bush scrub (1.2 acres) and 11.7 acres of disturbed habitat. Sonoran creosote bush scrub occurs on well-drained, secondary soils of slopes, fans, and valleys and is the most widespread creosote bush scrub habitat of the Colorado Desert. Desert dry wash woodland is identified by BLM (2002) and CDFW (2010) as sensitive for several reasons including its association with channels and alluvial processes. The term desert pavement primarily describes soil and substrate conditions, rather than vegetation. It is sparsely vegetated.

Special-status Plants. Special-status plants are defined to include all BLM Sensitive Plants as well as all other plants included in the California Native Plant Society’s (CNPS) California Rare Plant Rankings (CRPR, see BRTR Section 3.1, Special Status Species Definition). Ironwood conducted focused special-status plant surveys in the spring of 2018 (a low rainfall year) on all portions of the proposed site and repeated the surveys in spring 2019 (an exceptional rainfall year) on all natural land portions of the Athos Solar and Athos Gen-Tie Project site. No listed threatened or endangered plant species were observed or have the potential to occur on the proposed ROW or in the vicinity. No BLM Sensitive plants were found on the site, although one BLM-Sensitive plant, Harwood’s eriastrum, has the potential to occur in windblown sand habitat on the gen-tie routes (small portions of Gen-Tie Segments #1, #2, #3, and #4; see BRTR Section 2.3, Soils). The following special-status plants were found along the Athos Gen-Tie line:

 Emory’s crucifixion thorn (Gen-Tie Segment #2; CRPR 2B.2, rare or endangered in California, common elsewhere)

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 Desert unicorn-plant (Gen-Tie Segment #1; CRPR 4.3, watch list)

 Harwood’s milk-vetch (Gen-Tie Segment #2; CRPR 2B.2, rare or endangered in California, common elsewhere).

None of these species is currently on the BLM Sensitive Species list.

Special-status Wildlife. Ironwood conducted full-coverage wildlife surveys in the fall of 2017 and spring of 2018 on all portions of the proposed ROW for desert tortoise, burrowing owl, elf owl, Gila woodpecker, and other species as appropriate. The surveys identified all wildlife species observed including desert tortoise, burrowing owl, and desert kit fox, as well as any sign including burrows and all evidence of wildlife use. The surveys found the following:

 Federally-and State-listed threatened desert tortoise (Gopherus agassizii) sign3 (inactive burrow, Gen-Tie Segment #3)

 California protected furbearer desert kit fox (Vulpes macrotis arsipus) (Gen-Tie Segment #1 and #2)

 California Protected Game Species burro deer (Odocoileus hemionus eremicus) scat (Gen- Tie Segment #4)

 State-listed threatened and USFWS Bird Species of Conservation Concern Swainson’s hawk (Buteo swainsoni) flyover near Gen-Tie Segment #3

The BRTR provides a compilation of special-status wildlife with potential to occur in the vicinity, and evaluates probability of occurrence for each species, based on vegetation, elevational and geographic ranges, and field survey results. In addition to the species identified above, the BLM Sensitive Species with the potential to be found along the gen-tie route are: Mojave fringe-toed lizard, several bat species (foraging only), golden eagle (foraging only), burrowing owl, mountain plover (winter only), Bendire’s thrasher, and migratory birds that may fly over or briefly visit on the site during seasonal migrations, such as Lucy’s warbler.

Wildlife Movement. Accessibility between habitat areas (i.e., “connectivity”) is important to long-term genetic diversity and demography of wildlife populations. In largely undeveloped areas, including the Chuckwalla Valley, wildlife habitat is available in extensive open space areas throughout much of the region, but specific barriers may impede or prevent movement. The landscape blocks identified in the Proposed Action vicinity are the Palen–McCoy Mountains to the northeast and the Chocolate Mountains to the southwest. These landscape blocks are connected by broad habitat linkages. The DRECP designates specific areas within the mapped habitat linkage for multiple species habitat connectivity (see figures of the BRTR in the POD Appendix D, of EA Appendix F).

3.15.2 Direct and Indirect Effects The analysis is based on the biological resources observed on the Proposed Action site and on the description of the Proposed Action. Several meetings were held among the applicant,

3 Desert tortoise ”sign” refers to evidence that a tortoise has been at the location, such as burrows, tracks, scats, carcasses, or other remains. Tracks scat, and burrows were observed on the Athos Gen-Tie ROW.

October 2019 3-50 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 3: AFFECTED ENVIRONMENT AND ENVIRONMENTAL EFFECTS OF ACTION wildlife agencies, and BLM biologists to discuss potential effects and applicable regulation. In addition, written and oral comments by agency biologists regarding the potential impacts to biological resources were reviewed to inform the analysis.

Alternative 1: Proposed Action Vegetation and habitat. Gen-tie construction would affect vegetation and habitat at discrete disturbance sites where towers or other work activities would be located and during underground trenching by removing or substantially altering the soils and vegetation. Construction would temporarily affect surrounding habitat by introducing noise, lighting, dust, and similar disturbance, possibly affecting wildlife behavior. Impacts to habitat value of the previously disturbed lands would be minor. Impacts to natural habitat, including desert dry wash woodland, would be minimized or offset by Mitigation Measures BIO-1 through BIO-5 (see EA Appendix H).

The principal indirect impact to undisturbed areas is the potential introduction of invasive weeds, which could degrade plant and wildlife habitat on and beyond the site boundaries if the weeds spread, see POD Appendix L (in EA Appendix F).

Special-status plants. There is a low potential that the gen-tie may affect one BLM Sensitive Plant, Harwood’s eriastrum (Eriastrum harwoodii, CRPR 1B.2), along small parts of Gen-Tie Segments #1, #2, #3, and #4 where potentially suitable windblown sand habitat is present. However, the species has not been recorded there during the project’s focused surveys. Construction of the gen-tie would minimally and temporarily alter soil conditions, and windblown sand would continue to move across the gen-tie line route. Permanent impacts would be minimal, and be limited to the areas of permanent structures and permanently maintained roadways within suitable habitat. The nearest known occurrences of Harwood’s eriastrum are in the natural dunes and sandfields several miles to the north and east of the gen-tie line routes.

Two Emory’s crucifixion thorn (Castela emoryi, CRPR 2B.2) were observed on Gen-Tie Segment #2. If impacts cannot be avoided, they would be considered locally substantial. Mitigation Measure BIO-6 (Emory’s crucifixion thorn mitigation) would reduce the potential impact by either (1) avoiding the plants or by (2) contracting with a qualified institution to salvage and translocate them off the site, or (3) conducting horticultural propagation and off-site introduction into suitable habitat. Two other special-status plants, Harwood’s milkvetch (Astragalus harwoodii, CRPR 2B.2,BLM Sensitive) and desert unicorn plant (Proboscidea althaeifolia, CRPR 4.3) were documented on the gen-tie routes. Both species have low conservation status and numerous occurrences throughout the region. Special-status plant surveys were completed in spring 2018 (a year of low rainfall) and spring 2019 (a year of exceptionally high rainfall). Based on these results, no other special-status plant species are expected to occur on the Athos Gen-Tie routes.

Desert tortoise. Most of the gen-tie routes are marginally suitable as desert tortoise habitat. No desert tortoises were found during field surveys in 2018, but prior surveys have identified desert tortoise sign on or near Gen-Tie Segments #3 and #4. There is a small potential that desert tortoise could be found on the gen-tie route during construction or O&M. If this occurs, implemen- tation of protection measures specified in Mitigation Measures BIO-7 and BIO-9 (EA Appendix H), as well as the Desert Tortoise Relocation and Management Plan (see POD Appendix M-2 in

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EA Appendix F) and compliance with the terms of the DRECP and the USFWS 2016 Biological Opinion for the DRECP would prevent injury or mortality.

Mojave fringe-toed lizard. Suitable or marginally suitable Mojave fringe-toed lizard habitat may be found on small portions of Gen-Tie Segments #1, #2, #3, and #4 (see BRTR Section 2.3, Soils). These areas are the same as potential habitat areas for Harwood’s eriastrum. Potential effects to the habitat would be temporary. Construction would have minimal impacts to soil conditions, and windblown sand would continue to move across the route. Site preparation for construction, or vehicle traffic during O&M, could cause Mojave fringe-toed lizard injury or mortality. This impact would be minimized through implementation of Mitigation Measure BIO-7 (Wildlife Protection).

Desert kit fox and American badger. Desert kit fox and American badger generally avoid human activities unless they are attracted by food or water subsidies. They are expected to avoid gen-tie construction and O&M activities and it is unlikely that an active mammal burrow would be located at any gen-tie work site. However, there is a small potential for either species to be present along the route during gen-tie construction; if present they could be subject to mechanical crushing of individuals or burrows by vehicles and construction equipment, habitat loss, and noise and disturbance to surrounding habitat. APM BIO-1 (Wildlife Relocation) requires implementation of a relocation plan to exclude desert kit fox and American badger and prevent injury or mortality. Mitigation Measures BIO-7 (Wildlife Protection) and BIO-9 (Desert kit fox and American badger relocation) would minimize potential of injury to desert kit fox and American badger.

Burro deer. Burro deer generally avoid human activities and no suitable sheltering habitat is present along the gen-tie route. However, burro deer could forage along the gen-tie route, or travel near work sites while moving to adjacent habitat areas. They are expected to avoid gen- tie construction and O&M, and no special measures are necessary to exclude them from work areas. Implementation of Mitigation Measures BIO-7 (Wildlife Protection) would minimize potential attraction or disturbance to burro deer. The gen-tie line would not interrupt burro deer access to water or suitable habitat areas.

Native birds and bats. Native birds and bats could use habitats along the gen-tie routes. During gen-tie construction they could be subject to habitat loss, noise and disturbance to surrounding habitat. Implementation of Mitigation Measures BIO-1 through BIO-5, would minimize adverse impacts to native vegetation thereby minimizing impacts to bird and bat habitat.

Collision. Bird collisions with structures typically occur when the structures are not visible (e.g., bare power lines or guy wires at night), deceptive (e.g., glazing and reflective glare), or confusing (e.g., light refraction or reflection from mist). Transmission lines, including the proposed gen-tie line, present collision hazards to birds. Based on mortality data for another project’s gen-tie within the Riverside East SEZ mortality of approximately 24 birds per year per kilometer of gen- tie is expected.

Electrocution. Large birds can be electrocuted by transmission lines if the bird’s wings simul- taneously contact conductors, or a conductor and a ground. Configurations less than 1 kV or

October 2019 3-52 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 3: AFFECTED ENVIRONMENT AND ENVIRONMENTAL EFFECTS OF ACTION greater than 69 kV, such as the gen-tie line, typically do not present an electrocution potential, based on conductor placement and orientation (APLIC, 2006).

Mitigation Measure BIO-11 (Bird and Bat Conservation Strategy) would require the Applicant to prepare a Bird and Bat Conservation Strategy (BBCS), see POD Appendix U, to monitor the death and injury of birds and implement an adaptive management program as necessary. Mitigation Measure BIO-13 (Gen-tie lines) requires design and construction of the gen-tie lines to avoid potential for electrocution and minimize potential for roosting on the structures or colliding with them. These measures would effectively minimize or mitigate adverse effects of collision or electrocution to the extent feasible.

Burrowing owl. During gen-tie construction burrowing owl could be subject to mechanical crushing of individuals or burrows by vehicles and construction equipment, habitat loss, and noise and disturbance to surrounding habitat. It is unlikely that an active burrow would be located at a gen-tie work site, but APM BIO-1 (Wildlife Relocation) requires development and implemen- tation of a relocation plan to exclude burrowing owls if needed and prevent injury or take. Imple- mentation of Mitigation Measures BIO-7 (Wildlife Protection) and BIO-12 (Burrowing owl avoidance and relocation) would prevent or minimize potential injury to burrowing owls.

Wildlife Movement. Many wildlife species are expected to move through the area. Gen-tie construction activities could temporarily dissuade wildlife from approaching due to noise and disturbance during construction. Once completed, the gen-tie line would have minimal effects on terrestrial wildlife movement. Even so, implementation of LUPA-BIO-COMP-1 (see EA Appendix H), on-site land dedication, and additional compensation required under Riverside County’s 2019 approval of the private land Athos Solar components (see EA Appendix J) would offset wildlife movement impacts (if any) of gen-tie construction or operation. However, the gen- tie structures and conductors could present a collision hazard for birds, including special-status species as well as common birds that are protected under state laws. Mitigation Measures BIO-11 (Bird and Bat Conservation Strategy) requires pre-construction surveys to identify active bird nests, and avoidance of disturbance or disruption nesting behavior, as well as implementation of a 2-year post-construction monitoring for bird injury and mortality and an adaptive management framework if mortality thresholds as identified in Section 8.2 of the Bird and Bat Conservation Strategy (see the Athos POD in EA Appendix F) are exceeded. Mitigation Measure BIO-13 (Gen-tie lines) requires mechanisms to visually warn birds such as permanent markers or bird flight diverters; avoid or minimize use of guy wires; and maintain sufficient distance between all conductors and grounded components to prevent electrocution.

Alternative 2: Gen-Tie Segment #1 Alternative Route Option The Gen-Tie Segment #1 Alternative Route Option would increase vegetation and habitat impacts of the gen-tie component, and consequently increase potential site-specific impacts to plants and wildlife, including special-status species. In general, impacts of the Gen-Tie Segment #1 Alternative Route Option would be quantitatively greater because it would cross a larger area of desert dry wash woodland. Mitigation Measures BIO-1 through BIO-14 identified for the Proposed Action would be applicable to minimize impacts

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Alternative 3: No Action Alternative Under the No Action Alterative, the gen-tie line would not be constructed. The BLM would continue to manage the public land sections of the proposed gen-tie route according to the existing land use designations. There would be no effects to vegetation and wildlife resources.

3.15.3 Cumulative Effects The geographic extent for this cumulative analysis includes the desert portion of Riverside County (Palm Springs to the Colorado River) because it consists of similar habitat over large areas and encompasses regional populations of species that could be directly or indirectly affected by the Proposed Action.

As the number of solar projects and other developments increase in the region, the cumulative effects to wildlife and vegetation resources increase. This analysis considers the current and foreseeable future projects identified in Tables 3.1-1 and 3.1-2. Individually, these projects would potentially contribute to reduced habitat availability and result in increased habitat fragmentation on both wide-ranging (e.g. desert tortoise) and localized habitat niche special- status species (i.e., Mojave fringe-toed lizards, Harwood’s eriastrum). Cumulatively, these projects would total more than 30,000 acres of development if constructed and include many miles of transmission lines. Through DRECP, there has been a regional planning that includes conservation within proposed BLM land designations as well as implementation of biological resource CMAs to reduce potential cumulative effects to natural communities. For the Athos Gen-Tie Project, this analysis presumes that Mitigation Measures BIO-1 through BIO-14 identified in the sections above, would be implemented for the Proposed Action to alleviate or reduce its project-specific impacts as well as its contribution to regional cumulative effects to vegetation and wildlife resources.

With implementation of the mitigation measures, the contribution to cumulative impacts to wildlife and vegetation resources from the proposed Athos Gen-Tie Project would not be considerable.

3.16 Visual Resources 3.16.1 Affected Environment The area surrounding the Athos Gen-Tie Project is lightly populated, and most of the lands making up the Athos Gen-Tie Project are undeveloped, consisting mainly of desert scrub (scattered creosote bushes), lakebed, and dunes that are predominantly intact on the Chuckwalla Valley floor (elevations from 495 to 797 feet above mean sea level). Several desert washes pass through or adjacent to the Athos Gen-Tie Project site, indicated primarily by associated vegetation (e.g., desert dry wash woodlands). The relatively flat landscape of the site has a low level of variety and distinctiveness, exhibiting limited variation in form, line, color palette, and texture that is common to the region. Potentially affected viewers, which define the geographic scope, include those in Lake Tamarisk Desert Resort and dispersed rural residences; recreational visitors to ACECs, National Conservation Lands, Wilderness Areas, and open public lands; and travelers along the main transportation corridors (I-10 and SR-177).

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Lands that would be crossed by the Proposed Action are located within a DFA per the 2016 DRECP LUPA, which assigns Visual Resources Management (VRM) Class IV to DFAs (BLM, 2016), which would include lands south of Interstate assigned VRM Class III. As defined in BLM Manual H-8410-1 Visual Resource Inventory (BLM, 1986a), the VRM Class IV management objective is: “…to provide for management activities, which require major modification of the existing character of the landscape. The level of change to the characteristic landscape can be high. These management activities may dominate the view and be the major focus of viewer attention. However, every attempt should be made to minimize the impact of these activities through careful location, minimal disturbance, and repeating the basic elements in the predominant natural features of the characteristic landscape.”

VRM Class III South of Interstate 10 management objective is: “partially retain the existing character of the landscape. The level of change to the char- acteristic landscape should be moderate. Management activities may attract attention, but should not dominate the view of the casual observer. Changes should repeat the basic elements found in the predominant natural features of the characteristic landscape.”

3.16.2 Direct and Indirect Effects The BLM’s VRM System was used to assess the potential effects of the Athos Gen-Tie Project. Under the VRM System’s visual contrast rating method (BLM, 1986b, 1984), a project (and alternatives) is analyzed for its effects on aesthetic or visual resources by comparing the landscape characteristics that would be created by the Athos Gen-Tie Project to the existing landscape characteristics and arriving at an assessment of visual contrast that would result from changes in landforms and water, vegetation, and structures. Contrast determinations were made from representative viewing locations or Key Observation Points (KOPs) in the field. Once the degree of anticipated contrast was determined, a conclusion on the overall level of change was made and compared to the applicable VRM Classification to determine conformance with the established VRM class Management Objectives. The Contrast Rating Data Sheets are presented in the POD Appendix J, which is EA Appendix F.

While the effects on visual resources are almost always direct, two exceptions include: (a) the Athos Gen-Tie Project’s indirect effect of contributing to the perceived industrialization of the landscape, as discussed in Section 3.16.3 (Cumulative Effects) below; and (b) the effects of the associated Athos Solar Project, as explained in Section 3.1.2 (Environmental Documents Used) and summarized in EA Appendix J (Indirect Effects).

Alternative 1: Proposed Action The Proposed Action would result in varying degrees of structural visual contrast depending on the viewing location and proximity to the line. From the six representative KOPs, contrast ratings ranged from weak (KOPs 1, 2, and 3) to moderate (KOPs 4 and 6) to strong (KOP 5). However, in all cases, the resulting levels of visual change were consistent with the applicable VRM Class IV objective. Additionally, linear viewpoint analyses were conducted for I-10 and SR-177. The line would be visible from I-10 for 17.1 miles and from SR-177 for 9.8 miles due to the open views

October 2019 3-55 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 3: AFFECTED ENVIRONMENT AND ENVIRONMENTAL EFFECTS OF ACTION and flat terrain. The line would appear visually dominant from one limited road segment where Gen-Tie Segment #1 would span SR-177 (see KOP 5 Contrast Rating in POD Appendix J in EA Appendix F). This brief episode of visual dominance would be consistent with the VRM Class IV objective. Overhead portions of the Proposed Action would introduce a new 34.5 kV and/or 220 kV transmission line, which would be visible from nearby lands designated as ACEC, National Conservation Lands, SRMA, and Joshua Tree National Park wilderness. The new and improved access and spur roads would be substantially screened from SR-177 views due to intervening vegetation and there would be no in-line views of the access/spur roads.

Chuckwalla and Alligator Rock ACECs (both VRM Class II) would be the closest sensitive land areas to the Proposed Action. Chuckwalla is located immediately north of the Athos Gen-Tie Project. Alligator Rock is located on the south side of I-10 in the Desert Center area. Although the Athos Gen-Tie Project features and associated visual contrast would be inconsistent with the VRM Class II management objectives, it is important to remember that the land areas actually crossed by the gen-tie facilities are primarily designated VRM Class IV (north of I-10), with which the Athos Gen-Tie would be consistent. For the few crossed lands designated VRM Class III (south of I-10), the proposed gen-tie line would parallel existing transmission lines into Red Bluff Substation.

All structures would be lower than the 200-foot height standard that triggers Federal Aviation Administration Part 77 Obstruction Evaluation Consultation, so no aviation lighting is required, and there would be no nighttime lighting associated with operation of the Proposed Action.

All views would include existing transmission and solar infrastructure or approved transmission and solar infrastructure and 5 of the 7 miles of gen-tie line on BLM land would be collocated with existing or approved transmission infrastructure and utilize appropriate visual design features and Best Management Practices (BMPs) described in “Reducing Visual Impacts of Renewable Energy Facilities on BLM-Administered Lands” as determined by the BLM Authorized Officer. Furthermore, the line is subject to the DRECP CMAs and would comply with the following CMAs (see EA Appendix H): LUPA-BIO-7, LUPA-AIR-1, LUPA-AIR-5, LUPA-VRM-1, LUPA-VRM-2, LUPA-VRM-3, DFA-VPL-VRM-1, DFA-VPL-VRM-2, and DFA-VPL-VRM-3. With compliance with the listed CMAs, no additional mitigation measures are required.

Potential undergrounding of Gen-Tie Segments #1 and #3 would eliminate (when viewed from KOPs 4 and 5) or reduce (when viewed from KOPs 2 and 6) the structural visual contrast of the gen-tie line. Similarly, with the undergrounding of Gen-Tie Segment #1, the overall visual prominence of the Athos Gen-Tie Project would be reduced when viewed from SR-177. Simulations of the visual impacts can be reviewed POD Appendix J in EA Appendix F, the impacts from undergrounding would be assumed to result in fewer poles and line in sight, but no changes to panels are anticipated. See EA Appendix J (Indirect Effects) for a discussion of the potential visual impacts of Athos Solar.

Overall, the underground option would result in a less adverse visual impact compared to the above ground option of the Proposed Action.

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Alternative 2: Gen-Tie Segment #1 Alternative Route Option This route option would connect to the northernmost solar arrays (Parcel Group A); follow a more circuitous alignment than the Proposed Action; and add approximately 0.65 miles of additional gen-tie line and access and spur roads. The resulting increase in structural complexity and form and line visual contrast would be visible to both northbound and southbound travelers on SR-177 for the same 9.8 miles as the Proposed Action. It would have the same impact to viewshed because it would be equally visible from ACECs, SRMAs, and the Joshua Tree National Park Wilderness. The overlapping alignment would result in increased view blockage of the lower elevations and alluvial fans of the background Coxcomb Mountains when viewed from northbound SR-177 in the vicinity of KOP 5. While the resulting visual effect would be slightly more adverse compared to the proposed route, the overall moderate-to-high visual change would still be consistent with the VRM Class IV objective. The additional access and spur roads would be substantially screened from SR-177 views due to intervening vegetation. Also, with the exception of the overlapping segment (which would exhibit the same level of visibility under both the proposed and alternative routes), there would be no in-line views of the access/spur roads. Therefore, the resulting visual effect of the access/spur roads would be the same as for the proposed route.

Like the proposed gen-tie line, this route option would be subject to compliance with the following DRECP CMAs (see EA Appendix H): LUPA-BIO-7, LUPA-AIR-1, LUPA-AIR-5, LUPA-VRM-1, LUPA-VRM-2, LUPA-VRM-3, DFA-VPL-VRM-1, DFA-VPL-VRM-2, and DFA-VPL-VRM-3. Therefore, no additional mitigation measures are required.

Alternative 3: No Action Alternative The No Action Alternative would not develop the gen-tie line or require new construction and/or operational activities. It would not conflict with any existing or future land use plans or zoning, nor would it conflict with the VRM Class III or VRM Class IV objective. This alternative would avoid the visually prominent span of SR-177 and Interstate 10. Therefore, this alternative would have no visual resources impacts.

3.16.3 Cumulative Effects The geographic extent for the consideration of cumulative effects is a one-mile area around the perimeter of the Athos Gen-Tie Project.

Although existing cultural modifications are visible along I-10 and in the Desert Center area (i.e., transmission lines; substations; pipelines; solar projects; 4-wheel drive tracks; scattered buildings, dilapidated structures, and roadside signs; and a few agricultural operations), the scale of the open panoramas imparts a general impression of a relatively unimpaired, isolated desert landscape. The cumulative scenario includes many large-scale solar plants and transmission lines whose scale and pervasiveness would have adverse cumulative effects. If all the projects were implemented, they would substantially degrade the visual character and scenic appeal of the landscape, resulting in the conversion of a relatively undeveloped landscape into a more industrialized one.

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As a result, either the Proposed Action or the Alternative Route Option, in combination with the 15 local energy projects and one regional energy project, would result in cumulative visual resources impacts when viewed by sensitive viewers along I-10 and SR-177, from nearby residences, and in the surrounding mountains and wilderness. For many I-10 travelers, the scenic experience would be substantially degraded due to the perceived industrialization of the landscape.

3.17 Water Resources This section describes the affected environment and environmental consequences (direct and indirect effects) of the Proposed Action on water resources, including surface water resources, groundwater, and water quality.

3.17.1 Affected Environment The Proposed Action is in the Chuckwalla Valley of Riverside County near the community of Desert Center, California. The site is part of an interior enclosed drainage system, meaning there is no outlet to the ocean. All surface drainage is to the Palen and Ford dry lakes. These are shallow lake beds which are dry most of the time due to the arid climate and infrequent rainfall. There are no perennial streams in the Chuckwalla Valley. There are several springs in the surrounding mountains. All are situated outside the Chuckwalla Valley Groundwater Basin (CVGB) and at higher mountain elevations. Groundwater depth at the site was estimated at 70 feet below ground surface but the nearby Palen Dry Lake could have groundwater as close as 8 feet below the ground surface. Some of the vegetation in this area could use this groundwater (see Water Supply Assessment included in the POD Appendix G in EA Appendix F).

The Proposed Action overlies the Chuckwalla Valley Groundwater Basin (CVGB), which covers an area of 940 square miles in the Palen and Chuckwalla Valleys and comprises the geographic scope of analysis. Total groundwater storage available to wells is estimated at 15,000,000 acre- feet (af) (CDWR, 2004).

Off-site stormwater flows at the site are from a series of desert washes originating from the nearby mountains. All the watercourses crossing the site exhibit characteristics of alluvial fans on which unconsolidated flow can unpredictably inundate wide areas. A preliminary drainage study (Westwood, 2018) shows that all four gen-tie segments could be subject to flooding. Gen-Tie Segment #1 could be subject to the most severe flooding, with 100-year flood depths ranging from approximately one to six feet over this entire segment. The remaining gen-tie segments would be partially subject to flooding at depths not exceeding one foot.

3.17.2 Direct and Indirect Effects The impact analysis is based on consideration of the Proposed Action description in the context of the affected environment described above and relies in part on the analysis described in the Environmental Impact Report for the Athos Renewable Energy Project (Riverside County, 2019).

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Alternative 1: Proposed Action Construction would require excavation and grading for access roads, excavation for structure foundations, installation of overhead structures, and underground line trenching. Disturbance of soil during construction could result in soil erosion and lowered water quality through increased turbidity and sediment deposition into local streams. Accidental spills or disposal of harmful materials used during construction could wash into and pollute surface waters or groundwater. Materials that could contaminate the construction area or spill or leak include lead-based paint flakes, diesel fuel, gasoline, lubrication oil, cement slurry, hydraulic fluid, antifreeze, transmission fluid, lubricating grease, and other fluids. Decommissioning activities would be similar to those of construction.

The local streams are normally dry such that should material spills occur during construction, these could easily be cleaned up prior to water being contaminated. Groundwater, located at 70 feet below ground surface, is well below the maximum depth of excavation of 35 feet, resulting in little likelihood that groundwater could be affected during construction. Fuel and greases for construction equipment would be stored in temporary aboveground storage tanks or sheds located on the Athos Solar Project site. The fuels stored on-site would be in a locked container within a fenced and secure temporary staging area.

Grading effects that could lead to soil disturbance will be minimized by the proposed grading plan, which will minimize the required volume of earth movement. Access road beds would be grubbed, graded, and compacted with minimal disturbance to topography. It is therefore antici- pated that existing drainage patterns will not be substantially altered (Riverside County, 2019). Compliance with DRECP objectives for surface water resources requires maintenance of dry wash morphology and function.

Development and adherence to an SWPPP in conformance with the California General Construction Storm Water Permit (See Regulatory Framework) will require best management practices to prevent and control erosion and siltation during construction, prevent, contain and mitigate accidental spills during construction, and prevent violation of water quality objectives or damaging beneficial uses. Compliance with Sections 401 and 404 of the Clean Water Act will also minimize this impact.

Potential threats to surface water quality during operation and maintenance would be minor. The gen-tie lines would require minimal maintenance consisting mainly of inspections and minor road repairs.

Construction water use for the gen-tie line is expected to be 75 acre-feet over a 6-month period, with negligible water used for operation of the gen-tie transmission lines. The water use for the solar facility is discussed in EA Appendix J (Indirect Effects). Although water will be obtained from the CVGB, the construction water use is far less than the total available groundwater and far less than the estimated 2,390 af annual CVGB surplus for current conditions estimated from likely basin inflow and outflow information (POD Appendix G in EA Appendix F). There is a negligible potential for groundwater, if extracted from onsite wells at the private solar facility, to be withdrawn from below the Colorado River Accounting Surface for construction of the gen-tie line (See the Regulatory Framework). As addressed in EA Appendix J (Indirect Effects), should

October 2019 3-59 Environmental Assessment IP Athos Renewable Energy Project Generation-Tie Line CHAPTER 3: AFFECTED ENVIRONMENT AND ENVIRONMENTAL EFFECTS OF ACTION this occur during construction of the Athos Solar Project or in tandem with the Proposed Action, EIR mitigation measures for the Athos Solar facility required under CEQA would ensure mitigation of impacts to the adjacent Palo Verde Mesa Groundwater Basin (Riverside County, 2019).

Springs in the area are all in the surrounding mountains outside and at higher elevations than the CVGB and would therefore be unaffected by withdrawals from the CVGB. Groundwater at the nearby Palen Dry Lake would not be adversely affected if as described in the Water Supply Assessment (WSA), the CVGB is currently in surplus which exceeds the Proposed Action demand. Should the CVGB be in deficit (depending on inflow assumptions; see Table 5 of the WSA), the deficit would far exceed the Athos Gen-Tie Project’s water use and the effect on groundwater levels at the Palen Dry Lake would already be occurring.

Though subject to flooding, the gen-tie being supported on poles or towers, would not be subject to flood damage except potentially by scour, which could result in partial collapse of the line. Mitigation Measure WR-1 (Scour Protection) would require that all structures using posts or poles for foundations be protected from scour from a 100-year flood event, which would reduce this impact. The towers would pose only a minor and local obstruction to flow and would not cause diversions to the detriment of adjacent property.

Alternative 2: Gen-Tie Segment #1 Alternative Route Option Alternative 2 impacts are identical to the Proposed Action impacts except the length of Segment #1 would be longer on BLM-administered land, as described in Chapter 2.

Alternative 3: No Action Alternative There would be no construction under the No Action Alternative. Therefore, there would be no impacts to water resources.

3.17.3 Cumulative Effects The Chuckwalla Hydrologic Unit, being a self-contained drainage area, comprises the geographic scope for the water resources cumulative analysis. The groundwater setting for cumulative projects is the same as for the Proposed Action. The surface water setting is the same or similar.

Those cumulative projects (Tables 3.1-1 and 3.1-2) that are within the Chuckwalla Hydrologic Unit are mainly solar energy projects and their associated transmission lines with impacts similar to those described for the Proposed Action. However, the accumulation of solar projects would have more substantial impacts than the gen-tie line or cumulative power lines in the area. These impacts include potential flood diversions, contamination of surface waters from construction over a far greater area, contamination of surface waters through operation of power-generating facilities, and higher groundwater use. The Proposed Action’s contribution to the cumulative impact would be minor. The cumulative groundwater use is described in the Water Supply Assessment (POD Appendix G in EA Appendix F). Further, each of the projects would be subject to DRECP CMAs (for projects on Federal land) and/or mitigation measures as part of their environmental reviews, and all would be subject to the regulations described in the regulatory framework. All would be required to demonstrate a sustainable water supply and to implement best management practices to reduce impacts to water quality and surface flows.

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3.18 Wetland/Riparian Areas 3.18.1 Affected Environment This description of the wetland and riparian areas of the Proposed Action is based on the BRTR prepared by Ironwood Consulting Inc. (Ironwood) in 2018 (POD Appendix D in EA Appendix F) and comprises the geographic scope of analysis for direct impacts to riparian areas.

There are no wetlands within the proposed Athos Solar or Athos Gen-Tie Project sites. Desert dry wash woodland is the riparian vegetation of regional episodic hydrologic systems of the regional desert and it is identified in the NECO Plan, DRECP and CDFW (2010) as a sensitive habitat type. No other sensitive natural communities are found on the solar facility site or along the gen-tie routes. The Proposed Action would cross approximately 40 acres of the riparian habitat (desert dry wash woodland). This community is synonymous with blue palo verde– ironwood (Parkinsonia florida–Olneya tesota) (microphyll) woodland alliance. This community is an open to relatively densely covered, drought-deciduous, microphyll (small compound leaves) riparian scrub woodland, often supported by braided ephemeral wash channels that change following every surface flow event. Desert washes are often identified as jurisdictional waters of the State (POD Appendix V in EA Appendix F).

Within the Athos Solar and Athos Gen-Tie Project sites, this vegetation community is dominated by an open tree layer of ironwood, blue palo verde, and smoke tree (Psorothamnus spinosus). The understory is a modified creosote scrub with big galleta grass (Hilaria rigida), brittlebush (Encelia farinosa), desert lavender (Hyptis emoryii), and occasional Russian thistle. No wetlands would be affected by the Proposed Action, and the site is not subject to Federal regulation due to its location within the Ford Dry Lake watershed, an intrastate basin not identified as jurisdictional waters of the U.S. by the U.S. Army Corps of Engineers.

Special status plants, Emory’s crucifixion thorn (Castela emoryi) are present, and animal species, burro deer (Odocoileus hemionus eremicus), Townsend’s big-eared bat (Corynorhinus townsendii), pallid bat (Antrozous pallidus), big free-tailed bat (Nyctinomops macrotis), Gila woodpecker (Melanerpes uropygialis), crissal thrasher (Toxostoma crissale) use this habitat for foraging or breeding and may be also be present along the gen-tie routes.

3.18.2 Direct and Indirect Effects The analysis is based on the biological resources on the Proposed Action site and on the description of the Proposed Action.

Alternative 1: Proposed Action Direct effects: Approximately 58.4 acres of desert dry wash woodland are mapped along the proposed gen-tie ROW. Construction of the gen-tie line would eliminate an estimated 11.6 acres for gen-tie tower sites, access roads and spurs, or other work sites. Gen-tie construction would affect desert dry wash woodland for access route construction or improvement, at discrete disturbance sites where towers or other work activities would be located, and during underground trenching by removing or substantially altering the soils and vegetation. Construction would temporarily affect surrounding desert dry wash woodland habitat by introducing noise, lighting,

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Indirect effects: The principal indirect impact to undisturbed areas is the potential introduction of invasive weeds, which could degrade desert dry wash woodland habitat on and beyond the site boundaries if the weeds spread, see POD Appendix L (in EA Appendix F).

The Proposed Action would comply with the DRECP CMAs applicable to desert wash woodland (DRECP CMAs LUPA-BIO-1, LUPA-BIO-13, LUPA-BIO-RIPWET-1, LUPA-BIO-SVF-1, and LUPA-BIO-SVF-6; see EA Appendix H) because the gen-tie is considered to be a minor incursion into the habitat.4 The Proposed Action effects to desert dry wash woodland would be minimized by implementation of Mitigation Measures BIO-1 (Biological Monitoring), BIO-2 (Worker Environmental Awareness Training), BIO-3 (Minimization of Vegetation and Habitat Impacts), BIO-4 (Integrated Weed Management Plan), and BIO-5 (Vegetation Resources Management Plan) would reduce the effect.

Alternative 2: Gen-Tie Segment #1 Alternative Route Option The Gen-Tie Segment #1 Alternative would cross 7.8 acres of desert dry wash woodland, whereas the proposed route in this segment would cross 5.9 acres of desert dry wash woodland. The Gen-Tie Segment #1 Alternative Route Option would be qualitatively the same as the proposed route (see Alternative 1 above), necessitating greater impacts to the vegetation for access and pole locations. Alternative 2 would directly affect approximately 0.4 acres more of desert dry wash woodland than Alternative 1. Mitigation Measures BIO-1 to BIO-5 identified for the Proposed Action would be applicable to reduce this impact.

Alternative 3: No Action Alternative Under the No Action Alternative, the BLM would continue to manage the public land sections of the proposed gen-tie route according to the existing land use designations. The proposed gen- tie line area would remain in its existing condition, with no new structures or facilities and no ground disturbance. As a result, no impacts to wetland and riparian resources would occur.

3.18.3 Cumulative Effects The geographic extent for this cumulative analysis includes the desert portion of Riverside County (Palm Springs to the Colorado River) because it consists of similar habitat areas and encompasses the home ranges of species such as those directly or indirectly affected by the Proposed Action.

This analysis considers the current and foreseeable future projects identified in Tables 3.1-1 (Past or Present Projects or Programs in the Project Area) and 3.1-2 (Probable Future Projects in the Project Area). Cumulatively, those projects would total more than 30,000 acres of development, and a couple hundred miles of transmission lines.

4 Although BLM no longer requires compensatory mitigation from public land users (per IM 2018-093), compensatory mitigation would be required for the Athos Project under CEQA. Therefore, the Proposed Action would meet the intent of DRECP CMA LUPA-BIO-COMP-1 outside of the NEPA process.

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The Proposed Action would affect the riparian habitat desert dry wash woodland and unvegetated ephemeral dry wash. Many of the existing and approved cumulative projects would directly affect desert dry wash woodland. Many future cumulative projects subject to DRECP criteria would include gen-tie routes that would be linear or minimal incursion impacts to desert dry wash woodland and unvegetated ephemeral dry wash due to the nature of the area and the large washes that cross it. The effects of the Proposed Action would contribute incrementally to the cumulative impacts to riparian habitat in the region, and would be reduced by Mitigation Measures BIO-1 through BIO-5 so that residual effects would be minimal. With implementation of the mitigation measures, the contribution to cumulative impacts to sensitive desert dry wash woodland habitat from the proposed Athos Gen-Tie Project would not be considerable.

3.19 Wildland Fire Ecology 3.19.1 Affected Environment The vegetation-fuel types in the Proposed Action area, primarily Sonoran creosote bush scrub, are not fire-adapted. Fire, particularly repeated wildfire, is harmful to these plant communities and tends to deplete the native woody shrubs that characterize and dominate these communities, allowing their replacement by exotic weedy annual plants (BLM, 2018). Although historically infrequent in the southwestern deserts, fire has increased in both frequency and extent in recent decades, generally due to increased vegetation fuel provided by the invasion of non-native annual grasses. The amount and extent of vehicle use and of disturbed areas are the primary variables in predicting changes to wildfire size and frequency (BLM, 2018).

The Proposed Action area is designated as a Federal Responsibility Area according to the California Department of Forestry and Fire Protection (CAL FIRE) and the fire severity level of the area is unzoned by CAL FIRE but identified as moderate by the County (CAL FIRE, 2007; Riverside County, 2016). All fire stations serving Local Responsibility Areas in Riverside County are dispatched by the CAL FIRE Riverside Unit/Riverside County Fire Department Emergency Command Center and are part of the “Integrated Fire Protection System,” under contract with the State. A response from BLM would be dispatched if the event occurred on Federal Responsibility Area lands.

Lake Tamarisk Fire Station in Desert Center (with one County paramedic assessment engine; 8 miles west of the Palen site); Blythe and Blythe Air Base in Blythe (with one County paramedic assessment engine; 50 miles east); Riverbend Volunteer Fire Department in Blythe (50 miles east) are closest to the Proposed Action. The geographic extent of analysis is from Desert Center to Blythe, as further discussed under Cumulative Effects.

3.19.2 Direct and Indirect Effects The analysis compares the existing risk of fire with the potential increase in risk with the imple- mentation of the Proposed Action and alternatives.

Alternative 1: Proposed Action Construction activities required for the Proposed Action would create the potential for wildfire. Wildfires could be caused by construction workers smoking, refueling and operating vehicles

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The Proposed Action area is not within an area of high/very high fire hazard. The proposed gen- tie line may be collocated but most likely a separate gen-tie power line would be used along with other existing and proposed high voltage transmission lines and could introduce a new obstruction that may impact fire suppression efforts. Compliance with all applicable wildland fire management plans and policies established by CAL FIRE, the Riverside County Fire Department, and BLM and implementation of a WEAP, as required under Mitigation Measure PHS-1, would reduce wildfire risks to nearby residents and the risk of loss, injury, or death involving wildland fires.

Alternative 2: Gen-Tie Segment #1 Alternative Route Option Gen-Tie Segment #1 Alternative Route Option would be located east of and would be approxi- mately 0.65 miles longer than the proposed Gen-Tie Segment #1. Because Route Option is in the same general vicinity as the proposed Gen-Tie Segment #1 and would require a similar workforce and construction and operation activities, the fire risk would be the same.

Alternative 3: No Action Alternative The No Action Alternative would not result in any new construction and/or operational activities or any new associated ground-disturbing activities from the gen-tie line. The No Action Alternative would not introduce risks associated with increased occurrences of wildland fires.

3.20.3 Cumulative Effects The geographic extent for the consideration of cumulative effects to wildland fire ecology is from Desert Center to Blythe. Although potential fires would not be constrained by political boundaries, the natural conditions and existing fire response infrastructure are such that it would be reasonable to assume that a fire could be contained within this area. The past, present and future projects that have the potential to combine with the Proposed Action to result in a cumulative effect include all the projects listed in Table 3.1-1 and Table 3.1-2, because they all would create fire risk from operation (if they are already constructed) or from construction and operation (if not yet constructed).

Potential cumulative impacts could occur for the entire duration of the Proposed Action, from the initiation of construction to site restoration. Any of the cumulative projects that would install and operate transmission lines and/or use gas or diesel-powered equipment (including motor vehicles) that could spark or otherwise provide an ignition source could result in fire risks that combine to cause or create a cumulative impact. The increased human presence and disturbance caused by construction and operation throughout the area that would occur as future projects are developed could advance the rate of invasion by non-native vegetation and, thereby, contribute to fire fuel- loading that would burn with higher flames and hotter temperatures leading to possible containment issues.

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Potential cumulative wildfire effects would occur over the course of 30 or more years, encom- passing the entire lifespan of the Proposed Action but the risk would be greatest during construction due to the numbers of workers and vehicles. The BLM and Riverside County Fire Department are expected to respond to a fire on the proposed site and other development sites and facilities along the I-10. The availability of prompt fire response would potentially be impacted by continual development along the I-10 corridor. County imposed fire services and solar (B-29) fees required as conditions of approval on some of the projects included in Section 3.1 would help to ensure that there are adequate emergency services available for response in the Athos Gen-Tie Project area. The County is reviewing the solar facility and gen-tie line both on private and public lands, and will determine any fees required to ensure the emergency services are adequate. Additionally, Mitigation Measure PHS-1 for the Proposed Action and Gen-Tie Segment #1 Alternative Route Option would help reduce the risk of fire by appropriately training the construction workers.

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