Transcript Exhibit($

0 MM-9

Ed - . V?? 't Undersbnd that there was another powecoutage of 23 hours at Silver BeU over the weekend. lust want to be sure you don't forget to put It in the assessment of radial lines for the Forest w6en you look at system outages. :I Cheers1 EXHIBIT MM-10 Water Resources Element

Introduction Sufficient water supplies, along with effective and efficient water management and conservation programs, are crucial for all communities. To assist in long-term water planning, A.R.S. 91 1-821(C) allows for an optional Water Resources element to be included in the County Comprehensive Plan. This element is not required for counties under 125,000 in population but was included in this Plan due to the critical importance of water in relation to growth potential in Santa Cruz County. The Water Resource element summarizes currently available water supplies, current and future water demands and the general impacts of future growth on water availability. This element does not includ,= new independent hydrogeologic studies. It does include recommendations for water management and conservation.

Past, Present and Future Trends The existing condition of water resources (e.g., rivers, streams, wetlands, etc.) provides base line data used to determine if future population growth will exceed water availability for the unincorporated County area and what regulations apply to manage that growth. The Arizona Department of Water Resources (ADWR) under two major programs regulates water resources in Santa Cruz County. The first and most complete authority, the Assured Water Supply Program was granted to ADWR in 1994 by creation of the Santa Cruz County Active Management Area (SCAMA). Maintaining a safe-yield condition and preventing long-term declines in local water tables are the management goals of the SCAMA (A.R.S. §45-562(C)). 0 The geographic area of the SCAMA is about 716 square miles in the Upper Santa Cruz Valley River Basin. It is concentrated around a 45-mile long reach of the Santa Cruz River extending from the Mexican border to a few miles north of the Santa Cruz County/Pima County border (see Figure 6 in Appendix V). Detailed information regarding water resource conditions, water use characteristics, regulatory programs, future conditions and recommendations regarding future water management strategies are contained in "The Third Management Plan for the Santa Cruz Active Management Area" adopted on December 13, 1999. Any future residential subdivision development within this region must occur under the SCAMA regulations and, therefore, it is an important planning issue.

For the remainder of the County outside of the SCAMA, ADWR authority is primarily focused through the Water Adequacy Program, described in A.R.S. 345-108.This program requires developers to obtain a determination from the state regarding the availability of water supplies prior to marketing lots. For new subdivisions outside of the SCAMA, a determination of water adequacy by ADWR is required before the County cin approve a plat. This can often be a determination that there is not adequate water for the development, but such a ruling does not prectude lot sales.

Groundwater Water consumption, both domestic and commercial, within Santa Cruz County consists solely of groundwater extraction. The Santa Cruz River basin is the largest groundwater recharge facility for areas west of Patagonia Lake and feeds such populated areas as Nogales, Rio Rico, and Tubac. The O'Donnell Canyon and Sonoita and Turkey Creek basins are used by the populated regions of Sonoita and Elgin. The Patagonia region is served solely by the Sonoita Creek basin.

The Santa Cruz River basin has an average annual groundwater production range of 51,500 to '55,300 acre-feet. This range was concluded by a study performed in 1997 by ADWR. The largest demand for groundwater in this region is riparian with an estimated annual

62 consumption of 25,800 acre-feet. Other additional demands consist of municipal, agricultural and 0 industrial. This region is regulated through the SCAMA management plan, as administered by ADWR, which requires the development of legislative and policy guidelines and educational programs relating to water resource use and conservation. Municipal water demand within the Santa Cruz River basin, is provided mainly by four large providers: City of Nogales, Rio Rico Utilities, Valle Verde Water Company and Arizona American Water Company (formerly Citizens Utilities).

I Total water demand by these providers is approximately 7,043 acre-feet based on 1997 data. Smaller providers account for an additional demand of 400 acre-feet. Industrial water demand is met by individual user wells and permitted annual volumetric allotments based on industrial classification and use. The Santa Cruz AMA requires additional conservation practices above general conservation requirements. These additionally regulated uses are: Turf-related Facilities (2 10 acres) Sand and Gravel Facilities (> 100 acre-feet per year) New Large Landscape Users (10,000 square feet) New Large Industrial Users (> 100 acre-feet per year) Industrial water demand fluctuates depending mostly on weather conditions. During 1997 industrial water denand was estimated at approximately 1,300 acre-feet.

Riparian uses currently make up the largest sector of demand. This demand consists of water consumed by dense vegetative tracts along the Santa Cruz River's effluent-dominated perennial reaches. Such tracts have increased in size overall from 6,200 acres in 1954 to 8,600 acres in 1995 based on preliminary estimates.

Agriculturai demand within the SCAMA consists largely of irrigated croplands provided through 0 Certificates of Irrigation Grandfathered Rights (IGRs) issued to farmers in the early 1980's.The estimated demand during 1997 for IGR was approximately 12,500 acre-feet, the second largest water demand sector after riparian use.

The Sonoita and Elgin area domestic water is supplied largely by shared-use and individual user wells. The Patagonia area industrial and most municipal water demand is provided by the Town of Patagoniz Estimates of agricultural and riparian water demand cannot be established for these regions diie to insufficien?data, however agricultural demands are provided solely by individual user wells.

Reclaimed Water Currently, ca diract rausa of wastewater treatment plant effluent has occurred to any significant degree.

Effluent frm:he ?JcgaIes Intcma;ional Wastewater Treatment Plant (NIWWTP), which serves the City, a poeicn of the most densely populated areas of Rio Rico, Peifa Blanca Highlands and part of Kino Sprirgs (Estancia Yerba Buena), is a major source of supply contributing to the maintenance of water leve!s downstream of the plant.

A comrnun'ty wastewater treatment facility is located in Patagonia. The Tubac Golf Resort (TGR) and Barrio de TL:bac developments both have centralized wastewater systems and utilize wetlands for treatmec! TCR reuses some of its effluent to irrigate the golf course. All other unincorporated regions are served via onsite systems (e.g., septic systems).

0 63 i-- Water Other Supplies Other known water supplies included allocations of the Central Arizona Project (CAP) water to Rio Rico and the City of Nogales. However, the cost of delivery facilities was prohibitive. Those allocations were transferred to the City of Scottsdale and are no longer available.

The City of Nogales may use up to 4,200 acre-feet of surface water from Patagonia Lake, although only for emergency use. Again, due to the anticipated cost to delivery this water, the city does not use this source.

Pefia Blanca Lake is not a viable source given recent contamination issues and the fact that the United States Forest Service and the Arizona Game and Fish Department own surface water rights.

Currently, within the SCAMA it is estimated by ADWR that municipal, agricultural and industrial demand for water is about 18,800 acre-feet annually. Using a population estimate of 30,000living within the SCAMA yields a consumption rate of approximately 0.63 acre-feet per year per person. Current inflow to the SCAMA is estimated by ADWR to be between 39,600 and 142,900 acre-feet per year. Utilizing a conservative inflow rate of 45,000 acre-feet per year and a consumption rate of 0.63 acre-feet per year results in a population estimate of approximately 71,000 persons in the SCAMA before safe-yield is jeopardized.

There is less data available for review outside of the SCAMA. In "A Comprehensive Plan for Northeast Santa Cruz County" (CPNSCC) (2002, Sonoita Crossroads Community Forum), a summary of certain available hydrogeologic reports was accomplished to evaluate water supply. The summary concluded that a multi-agency groundwater study should be completed in order to more accurately determine future availability of water supply. Based on review of the CPNSCC and other limited information it is believed that sufficient water supply exists for near-term needs outside of the 0 SCAMA. Adoption of the land use recommendations contained within this Comprehensive Plan and implementation of water resources policies in conjunction with conducting a detailed water resources evaluation for the area outside of the SCAMA will ensure adequate water supply for the Comprehensive Plan 10-year window.

WATER RESOURCES ELEMENT GOALS, OBJECTIVES AND POLICIES

GOAL 17: OUR AIR AND WATER ARE CLEAN AND MEET OR EXCEED ALL NATIONAL STANDARDS. With the advent of the Clean Water Act, Clean Air Act and Safe Drinking Water Act years ago, state and federal agencies were given the tools to begin to clean up our air and water. However, our location adjacent to areas ohside County jurisdiction makes achieving national air and water quality standards difficult. Appropriate land use decisions and sound development standards are important to ensure that the PMio and aquifer and surface water quality standards exceedances that exist are not aggravated. Close cooperation with state, federal and international agencies will also move the County toward meeting this goal,

Objective 17.1 Prevent the expansion of the Nogales Non-attainment Area (NNA).

Policy 7 7.7. I The County will develop ordinances requiring the use of appropriate dust control methods for clearing land for new development, roads, and other projects. Policy 7 7.1.2 The County will develop a mitigation plan that addresses dust pollution.

64 Objective 17.2 Encourage proper treatment and disposal of wastewater.

Policy 17.2.7 The County will restrict conventional septic systems in accordance with state law and regulation. Policy 17.2.2 The County will provide information to communities on methods to fund sewer systems (sanitary and improvement districts, Water Infrastructure Finance Authority, USDA Rural Development Agency, etc.)

Objective 17.3 Reduce stormwater runoff pollution.

Policy 17.3 1 The County will ensure that new developments comply with the Arizona Pollutant Discharge Elimination System permitting requirements.

GOAL 19: WATER SUPPLIES ARE PROTECTED AND CONSERVED. Water availability is key to our future. Because the County is susceptible to droughts, conservation and mariagsrllent of water are of major importance. In its review of new development as it applies land use regulations under its jurisdiction, the County can complement existing state and federal water macsgement regiilations administered by the Arizona Depadment of Water Resources (ADWR) and other authorities, both inside the Santa Cruz Active Management Area (SCAMA) and outside of the SCAMA. Within the SCAMA, the Santa Cruz River constitutes a renewable and variable source in addition t9 ctker water supplies. Outside the SCAMA, this source is unavailable and certain parts of the C0unt.y are believed to be more vulnerable to drought and other challenges for reconciling water supply with increased demand.

Objective 19.1 Review and encourage that conservation measures, reuse alternatives and 0 drought management practices be planned and implemented for all new land developments. Policy 19. I 1 The County will adopt the Wellhead Protection Program. Policy 19.1.2 The County will encourage and facilitate gray water reuse. Policy 19. '1.3 The County in coordination with AD WR will assess the water demand that will result from proposed new development added to the existing uses and how this will be served by idenfifiqd wter supplies.

Objective ,192 Encourage planned residential subdivision development to reduce wildcat subdivisions that involve lot splitting and proliferation of exempt wells.

Policy 79.2. The County will consider alternatives to denial of a rezoning application, when adverse watei L?onscquencesmay result. Policy 19.2.2 The County will work in association with other counties to develop legislation designed to iiihibrr the growth of wildcat subdivisions by providing reasonable and attainable alternatives for lar,rl 'Ji~i~elo,otric?.rtf.

Objective 19.3 Outside the SCAMA, develop watershed management plans that are consistent with existing state law.

Policy 19.3.Ir' The County will encourage the formation of Rural Watershed Associations that would work wiib AD WR to implement programs of water conservation and voluntary management of water rr?sources.

65 EXHIBIT MM-10 “Wildlife Ecology and Management, Santa Rita Experimental Range (1903-2003)” by Paul A. Krausman, Michael L Morrison, published in USDA Forest Service Proceedings RMRS-P-30.2003, pp. 59-67. Paul R. Krausman Michael L. Morrison

Wildlife Ecology and Management, Santa Rita Experimental Range (1903 to 2002)

Abstract: Thc Siuttu Rita Expcrimcntal Rungc (SRBR). cstnblishcd in 1903. is a natural Ihrutoty uscd to bcttcr undcrsturrd dactt gr;lsslmds. WC rcvicwcd thc litcmtun?to sumrnurizc studics that bvc hccn mnductcd on wildlifc ut SRER Frnm 1903 to 2002 and to providc raummcndau’ons on cxpmndinp contemporury rcncoluh ut SRER. Rcrfcarch rclutcd to wild vcnchratcs hiLC bccn lirnitcd to n fcw studics of rcptilcs. nvifnunn. and mnmmnls. Mnmmolim studics wcrcdominuLcJ by dcntmscarch. Pccr-rcvicwcd publicutioiisdominntcd thcrcfcrcnccs (n=45).followcdby tcchdcal hullctins(n= 12).th~s(n=P)anddis~tionfifnn9).~~nfcrcncc pm.ccdiogfi(nr3). rcpnn (nd).undothcr (n.13). Althoughrcrcrvchon wilndlifc hasbccn lirnitcd (ahout 0.8 publications pcr );cur)from I YO3 to 2W-. zcvonl works wcrc landmark rtudics dint Icd thc wny For futurc work (for cxumplc. wutcr rcquircmcnt studics. lifc history studics of smdl miunmds. studics of wyotcn. and disc- studicsh Thcrc has not bccn L) conwmtratcrl cf~onto continue wildlifc rcscivch at SHER. und sincc 1983. only tivu mi\nu.wripu hvc hccn puhlishcd. Wc raomincnd that land mtlciugcrs and dinhisttutors initintc invcntoy and monitoring of aH vcnchmtcs on SRER to gather ncw knowlcdgc. to quantify nbundntlcc trcnds. mid w assist with rcsoum rcscmh ~d mmagcmcnt. Acknowledgments: Y. Pcuysdyn and J. A. Birsoncttc rcvicwcd this mtlciusaipi. Funding to wnduct thc rcvicw wup providcd by thc School oC Kcncwublc Nuturd Kcswwcs and rhc Arizonu Agricultunl Expcrimcnt Station. Univcrsity OF Ari2~naTucson.

Introduction The Santa Rita Experimental Range (SRER) was estilblished in 1903 os a natural luboratory to better understand arid rangelands. It is the oldest research area mainruined by the USDA Forest Service. Although it was e..toblished ils P research site for range improvement in the Southwestern United States. only limited reseurch has been directed towiud wildlife. The history of SRER, location. und Fission are outlined by Medina (19%). The purpose ofour paper is to summarize the work that hwbeen conducted at SRER on wild vertebrutes. indicute the role those studies liuve on a better understanding of wildlife ecology and management, and make recommendutions for the future. We obtained information from the University of Arizona‘s digital urchiva (iig.urizona.edu/SRER). Medina‘s bibliography (1996). and literature searches conducted ut the Science Ljhruy. University of Arizonu. Most of the archival data supported the published materid and wa. not referenced aguin. Although the SRER was established in 1903. it was nearly 2 decadzs before the first mnuscript related to wildlife was published (Vorhies and Taylor 1922). In the subsequent 5 decades there were approximately 10 publications par decade. In the eighth decade of SRER (1973 to 1982). the iiurnber of publications peaked at 25. Since 1983. only five publications have been produced and inore than 5 are in press or in prrpwdtion. We are unuwwe of ongoing research on wildlife at SRER, Although wildlife i-esemh has heen limited @but0.8 publications per year) at SRER over the pat 100 years, much of the work published are landmark studies that created u framework for futum studies, were classicill works that are still used LLS

Paul R. Kruuman ixPmfcs.wrand ~:.urrchStimiirtufWildli~e~ndFiihhcriexScicnce in* Schul ofRenewubleNaiumI Ruourcer. Universiiy ofArizona. fucmn. tie alro WNCXw Awcciarc Dirrctoro~r\rizona’r’A~iculturulExperiment Swtion. rind Adjunct Pmfuaoral Texan Tech University. Lubbock. He h;u; worked vith large mammvln in arid envirunmcnu rcluld ut hnbilirc crolugy. mslomtion. and mitigution throughout the Seulhwert. and in Asia and Alrica. He is ul.w heavily involved in wildlife ducarion and adniiniutrution and is the cumnl cditorol Wildlifr Monogmph% Paul cornplcted a B.S. defrec in wology a1Ohio Slate University, an MS. degree in wildlifo acienco ut NrN Mexico Stae Univeniy. nnd a P1.D. dcprtc in wildlife science at the University or lduhu. Michael L. MawLon holds allilieccd positionm wilh rhc Desert RwrchInulitute RCM. NV. and Ihc University of Celibmia. His inteKJi. include wildlire ecology. hehitat mstomlion. and environmental education. tlc received his US. degree in zoology ltum Northern Arizona Unlvenity, an M.S. degree in wildlife fmm Texas A & M Univctrity. and a Ph.D.degree in wildlife Tmm Oregon Stacc University. In:MfCliuan.MitchelP.:F~olliou.P~(~F.;Wmil~ier.CIVITlonU..I~h.roordn.SnnlvRits ExpcrimmhlRange: 1W ywnl1903 ~02OO3)ofaccornplishrnenlf and concrihuuom; conference prorrodings; W Octohcr 30-Novcmkr I; Tucson, AZ Roc. RMRS-PJO. Ogdcn. UT: U.S. Dcpsvlment or Agriculturr. Forusr Service. Rocky Mounuin ReKorch Station. 1

Krausman and Morrison Wildlife Ecology and Management,Santa Rita ExperimentalRange (1903 to 2002) reference sources, provided data that are applicable to and Gould 1974; Russell and others1972.1973) on a20.3-ha wildlife in arid regions worldwide, or were part of larger study plot in SRER. studies toexaminedisease in desert mammals. Each of these Studies of quail included water requirements, productiv- appeared to be initiated by individuals who were aware of ity, diets. and life history traits (Gorsuch 1934). Whether or the SRER instead of any unified effort by SRER administra- not water supplied for wildlife influences populations has tors to direct wildlife research. For example. the early life been debated for years (Grinnell 1927; Rosenstcck and history studies were conducted by U.S. Biological Survey others 1999; Vorhies 1928). The controversy began over 50 biologists; the water-balance work. most coyote und dent years ago when biologists in Western States began to supply studies, and disease studies were directed by scientists water for game birds (MucGregor 1953). The first studies to affiliated with universities. Because ofthe locationof SRER examine the response of Gambel'squail (Callipeplngmbelii to the University of Arizona, it would be valuable to begin a gambeliiGambr1) to water sources providedumanagement research program with more direction in the next IO0 yeam activities were, in part, studied at SRER (Hungerford to maximite our ability to le- and provide more and better 1960a.b). information related to haw wildlife influences grasslands Water supplied by humiuis wa.. not important, as qu~l grazed by livestock and vice versa. The wildlife research maintainedbody moisturefrom succulent plants. Vitamin A conducted over the past 100 years has been limited to a few was im important part of the life history, and during dry studies of reptiles, avifauna, and mammals (dominated by years quail did not store enough vitamin A in their liver for rodents). Peer-reviewed publications dominated the refer- successful breeding. Rainfall. as it influenced vegetation, ences(n=45).followed by technical bulletins(n= 12). theses was the driving force for quail reproduction in southern (n= 9). dissertations (n= 9). conference proceedings (n = 3). Arizona, not waterprovided by humans (Hungerford 1960a.b. reports (n=3). andother (references inbooks,populsu papers, 1964). The importunce of vitamin A was first proposed by and mimeographs) (n = 3). In addition. projects were con- Vorhies (1928) more than 30 years earlier based on his ducted by mammalogy students from the University of studies of lagomorphs on SRER. Diet and physiological Arizona as piut of class requirements (Mslmmal Museum, studies (Hungerford 196Oa.b. 1962,1964) of quail supported University of Arizona, Tucson). The wildlife resesuch is Vorhies' observations. categorized as related to reptiles, avifauna. and mammals. Diets of scaled quail (Callipepla squnmntn Vigors) were studiedat SRER (Medina 1988).Thescaledquail alsoselected succulent fdduring dry seasons. Unfortunately, additional Reptiles studies of avifauna have not been conducted at SRER. Reptiles received the least amount of attention by ecolo- gists ut SRER. A distribution of rattlesnakes was based on Mammals 40 records of diamondbacks (Crotalus ntrox Baird and Girard). six records oftigerrattlesnakes (C. tigrisKennicott), Scientists haveconcentrated mammalian studies at SRER seven records of Mohave rattlesnakes (C. scutulatus on lagomorphs, rodents, coyotes (Canis Intrans Say), col- Kennicott). and nine records of blacktailed rattlesnakes (C. lared peccaries (Pecm' 'tajacu Linnaeus). and deer (Odo- mulossus Baird and Girard). Diamondbacks ranged from mileus spp). However. there are only limited data for each an elevation of 854 to 1,220111. Mohaverattlesnakes mnged group, and no central theme prevails. Because SRER is from an elevation of 854 to 1,373 m. and blacktails were primsvily grassland, several studies examined influences found in canyons from 1.28 1 to 1,464 m. The distribution of of range management practices (for example, mesquite tiger rattlesnakes overlapped the distribution of all the [Prosopis spp.] control) on wildlife. For example. the con- other rattlesnakes (Humphrey 1936). trol of mesquite (15 to 100 trees per 0.41 ha) caused a As mesquite was cleared from SRER in various treat- subsequent reduction of use by mourning doves (Zenaida ments.the Sonoraspotted whiptail (Cnemidupborussonorae macmura Linnaeus). white-winged doves (Zenaida asiuticn Lowe and Wright) was more abund+nt than in areus that Linnaeus), Gambel's quail. scaled quail, and desertcotton- contained undisturbed mesquite and mesquite with irregu- tails (Sylvilagus nudubonii Baird). The abundance of ante- larly shaped clearings (Germano 1978; Germano and lope jackrabbits (Lepus nlleni Mearns) and blacktailed Hungerford 1981). The studies of Germano (1978) and jackrabbits (L. cdifornicus Gray) did not change with German0 and Hungerford (1981) were pioneer studies in mesquite removal (McCormick 1975). Other studies were considering reptiles in landscape management plans in the very general and simply presented anecdotal sightings of Southwest. animals (Martin 1966).

Avifauna Lagomorphs Studies of birds ut SRER were limited. and seven of the 13 Some of the earliest studies of lagomorph.. were con- published works were related to quail. The other six articles ducted at SRER (Vorhies and Taylor 1933) with the use of included short notes on the first record of the pectoral treatment andcontrol mas.These early wildlife biologists sandpiper (Calidn'smelanotos Vieillot) for Arizona (Vorhies recognized the importance of examining species in their 1932). the life history and diurnal activity of the roadrunner habitat and understanding their value and relationships (Georoccyx californianus Lesson) (Calder 1968a.b). and diet with humans. The importance of considering human di- and nesting data for 20 to 55 Sonoran Desert birds (Russell mensions as a critical component of wildlife management 0 was raised by Leopold (1933). and Vorhies and Taylor

60 USDA Forest Service Proceedings RMRS-P-30.2003 .

Wildlife Ecology and Management, Santa Rita Experimental Range (1903 to 2002) Krausman and Morrison

(1933). Human dimensions have heen a central aspect of Abundance Indices-The Standard Minimum Method wildlife management ober since; As stated by Vcirhies and was a reliable technique to estimate small. ncxturnal ro- Taylor (1933: 579). "This is wild life management." Their dents' at SRER. except it required large, homogeneous publication came out the same year Leopold (1933) pub- sample areas (7.3 ha) and large grids in addition to the lished Game Management, and the monograph serves as a assumptions that accommodate the technique. These draw- niodel for the scientific inanagenient Leopold ( 1933) advo- backs ilre time consuming (Olding 1976; Oldirig and cated. Through their studies of lagomorphs, Vorhies and Cockruin 1977). which preclude the method as ii rapid Taylor (1933) determined life history traits, distribution, technique suitable for estimating small rodents. interactions with livestock. f6rage consumption. diseases Breeding population density (per 2.6 km') was tabulated and parasites, censusing techniques. habitat relationships, for SRER for selected species by L,eopold (1933: 233). Data predation, and management of mtelopt! and blacktailed for rodents were from Taylor (1930).hut estimates for other jackrabbits. Their monograph was one of the first in-depth species were subjectively estimated. studies of a game species conducted in the United States. Physiology-Most of the physiological studies of rodents Taylor and others (1935) also documented and demon- on SRER were related to water. Some heteromyid rodents strated ways that jackrabbits influenced vegetation. and conserve water through excretion of concentrated urine. argued that wild animnls should he considered in niain- Their maximum excretory ability ( 1.200 niN for electmlytes taining balanced rangelands. and 900 mN for chlorides) exceeds the limits for other Two studies followed Vorhies and Taylor (1933) that niamnials Schmidt-Nielsen and others 1948). Other expanded on their work. Forage consumed by jackrabbits (K. rodents such as white-throated woodrats cannot survive on was determined from experimental trials (Arnold 1947: dry food only, hut solved the water problem by consuming 46-49); jackrahhits consume as much as a 454-kg range succulent pliints (B. Schmidt-Nielsen and others 1948). cow consumes. Arnold and others ( 1943) also explored ways Further studies demonstrated the importance of the hn- to estimate lagomorph numbers with counts of fecal pellets. niidity in rodent burrows to survival. The humidity in The second study examined the growth, development, and burrows of kangaroo rats was higher than outside humidity forage requirements of young Californiaj~krahbits(Haskell and signithnt for their water balance (Schmidt-Nielsen and Reynolds 1947). These studies were conducted in a and Schmidt-Nielsen 1950a.h. 195 1 ). These studies were scientific manner, and thedata are still useful today (Brown some of the first that examined the water balance of desert and Krausman 2003). primarily due to the scientific ap- mammals and are still widely cited. proach adopted by early wildlife biologists. Lagomorphs on iMore recent studies have exanlined the survival of small SRER were also used as model to study water halance and a inanimalsfrom which blood wascollected(Swann andothers water requirements. 1997). The survival of inost rodents was not influenced due Early observations correlated moist diets one mecha- as to anesthetiznition and bleeding through the orbital sinus. nism to reduce dependency on free-standing water for the Pocket mice (Chartoclipus spp.) were the exception. and kangaroo rat [Dipodomys spectahilis Merriani), wood rat those that were bled had significantly lower s~irvivalrates (Nzotama alhigulu Hartley), round-tailed ground squirrel compared to controls (Swann and others 1997). SpermophiIu.9 tereticaudus Raird),andjackrahbits (Vorhies 1945). Later. more detailed studies of the physiology of Range Relations--Because of the economic value of jackrahbits were conducted, which determined that jackrab- SRER and its representation of desert grasslands in gen- bits reduced their dependency on free water in other ways: eral. managers were interested in animals that competed seeking shade. the insulation properties oftheir fur. use of with livestock for forage. One of the earliest studies was to

a clear sky as a radiation heat sink during niidllfternoon determine how ' much forage kangaroo rats consumed (when solar and reflected radiation are reduced), high blood (Vorhies and Taylor 1927,). Unfortunately, they miscalcu- flowr in the ears to permit heat loss. and developnient of a lated and later revised their figures (Vorhies and Taylor high lethal body temperature (45.4 "C)(Schmidt-Nielsen 1924). Kangaroo rats consunied forage equivalent to 18 and others 1966). The survival techniques described hy steers per year. However, because resources are often Schmidt-Nielsen and others ( 1966) were further applied to limited prior to summer rains, the forage destroyed by and studied for cottontails and jackrahhits (Hinds 1970). kangaroo rats would sirpport 336 cattle in one month The study by Hinds (1970) only used animals captured at during this critical period (Vorhies and Taylor 1924). Be- SRER; experimentation was conducted at the University of CIIUSF: rodents have suchan impact on range resources, it is Arizona, Tucson. important for managers to know how much they consume before estahlishing carrying capacity for livestock. Nunier- ous methods to determine rodent pressure on rangelands Rodents were established, hut how rodents interact with other More work has been conducted on rodents at SRER than uspectsofrangeland ecology are unknown and need further any other group of mammals. The studies ranged from notes research (for example, pressure on soil. relationship he- to studies on ecology and life history traits. tWeen rodents arid insects) (Taylor 1030). Only limited research occurred in the past. Notes-The note (Taylor and Vorhies 1923) that was Merriam kangaroo rats were identified as an agent of published described the capture of a pair of kangaroo rats. mesquite propagation. When harvested. inany seeds were This was a time in the evolution of natural history writing buried that germinated and develapedaway from the parent where unusual obcervations were published regularly. tree. The result was an increase of mesquite at the expense of grasslands (Reynolds and Glendening 1949).

USDA Forest Service Proceedings RMRS-P-30. 2003 61 Predators

in the 19'70s itnd early 1980s a series of studies on coyotes was cunducted it SRER. Home ranges (54 to 77 km2 for jiiveniirF), abundance, and behavior were documented (Oaiii?zr i376; C)aniier arid Smith 1980). During these stud- ie;s Dilrincr an(?_Fisher (1077) were the first to document 1ioniir.p by 3 inarked coyote. More detaited studies olcoyotes were conducted at SKER by Orewek (1980)and Pishcr 1 1980). Drewek (1980) exam- 0 ined barns r:mges, activity patterns. arid age distribution.

62 %DA Forest SRNiCE Procegdings RMRS-P-30.2003 Wildlife Ecology and Management. Santa Rita Experimental Range (1903 to 2002) Krausman and Morrison

Fisher (1980) examined how an abundant food source (such precisely estimate the parameters of herest (Morrisan and as carrion) influenced density, age distribution. weights, Marcot 1065; M&ison rind others 2002). ovulation rates, and litter skes of coyotes in three qudy There are numerous reitsons why establishing an orga- areas (no differences). Other diet studies were also con- nized and rigorous inventory and monitoring program would ducted (Short 1979). benefit an education and research mission at SRER. First. resource managers need to have reliable data upon which decisions can be based. Only ii comprehensive monitoring Ungulates program that involves all taxa can hope to provide an Collared peccaries and deer received some attention at understanding of the interactions between managelnent SRER. Collared peccary diets were examined and were decisions and wildlife responses. Second. there is the need to found not to he competitive for forage with livestock (Eddy provide students and potential researchers with a complete 1959. 19611. General life history data were also presented list of species composition. relative ahiiiidances. and distri- (Knipe 1957). Home ranges and movements of five mule bution to assist with teaching and research planning. Third. deer were examined (Rodgers 1977; Rodgers and others the University of Arizona and the Forest Service shouldhave 1978). These researchers concluded that disturbances by an interest in monitoring the influence of local. regional, and humans influenced breeding activity and normal niove- glohal changes in climate, air quality, human population ment patterns. impacts. and other factors on wildlife populations over time. Simply establishing a series of repeated sampling loca- Feeding trials for Coues white-tailed deer (OdOC0ildlJ.S virgimi:inus Coues) were conducted at SRER (Nichol 1936. tions (regardless of the specific methodologies used) is insuf- 1938). Nichol ( 1938) alsoexamined parasites,disease. water ficient, however, toaddress any questions regarding wildlife and salt consumption, reproductive patterns, and hybridiza- at SRER in a meaningful way. Specific and qunntifiable tion of mule deer and white-tailed deer. The study was objectives rnust be estahlished before successful monitoring initiated because the U.S. Forest Service was interested in can be accomplished; these objectives then drive the sani- appropriate allocation for livestock and wildlife. a contro- pling design, intensity of sampling, and statistical analyses. wrsy that still continues in Arizona. This wasone ofthe first A typical goal of monitoring is to identify trends in a resource studies addressing these topics in Arizona, and the work is of interest. Trends represent the sustained patterns in count still used as a reference. data that occur independently ofcycles. seasonal variations, Despite the importance of deer to Arizona. including and irregular fluctuations in counts. A common prciblem in hunting. no studies were found that examined harvests in trend detection. however, is that sources of"noise" in counts SRER. Some summary data were provided in a memo obscure the "signal" associated with ongoing trends. The (Yeager and Martin 1965; not seen, cited in Medina (1996) probability that a monitoring program will detect a trend in (hunt success) for the 1964 deer season. sample counts when the trend is occurring, despite the This array ofresearch has been instrumental inestahlish- "noise" in the count data, represents its statistical power. ing SRER as the natural laboratory it was designed to he. Although statistical power is central to every monitoring is However. scientists and administrators could be more ~WI- effort. it rarely assessed. Consequences of ignoring it cient with a directed approach for long-term research that include collection ofcount data insufficient to make reliable include inventory and monitoring. To our knowledge, the inferences about population trends. mdcollection of data in U.S. Department of Agriculture's Forest Service or the excess of what is needed (Gibbs 1995). University of Arizona administrators have not allocated The statistical power of population monitoring programs funds or a central mission in which continuous studies of must be estimated relative to ( 1) the number ofplots rnoni- wildlife could be conducted. Unless a central theme or tored, (2)the magnitude of counts per plot, (3) count varia- funding level is established. wildlife research at SRER will tion, (4'1plot weighting schemes, (5) theduration of nionitor- continue to be based on individual efforts. ing. (6)the interval of monitoring. (71 the magnitude and nature ofongoing population trends, and (8)the significance level associated with trend detection (Gibbs 1995). Because Inventory and Monitoring these factors interact in complex ways to determine the capacity ofa monitoring program to detect trends in popula- Inventory and monitoring are the most frequently con- tions. such basic questions of "how many plots should J ducted type of wildlife studies (Morrison and others 2002). nionitor"or "how often should I conduct surveys" rarely have They are done to gather new knowledge about an area. intuitive answers. Programs such as MONlTOR (Gibbs quantify trends in some animal or resource of interest, and 1995)'are designed to explore interactions aindng the many to assist with resource management. The goal of an inven- components of monitoring programs and to evaluate how tory is toquantify thecurrent composition. distribution, and each component influences the monitoring program's power perhaps abundance of a species of interest in an area. to detect trends. Monitoring is simply conducting repeated inventories to In general and certainly applicable to SRER, broad objec- quantify changes in composition. distribution, and aburi- tives for conducting monitoring are (Spellerberg 1991) to: dance overtime. In addition to the general pursuit of knowledge, inventory and especially monitoring we often nian- 1. Provide guidance to wildlife management and conservation dated by legislation, such as by the National Forest . Management Act 11976) and the Endangered Species Act 2. Better integrate wildlife conservation and manage- (1973). Unfortunately, both initial inventories and followup nient with other land uses. 3. Advance basic knowledge in addition to applied inonitoring are seldom conducted with sufficient rigor to know ledge.

USDA Forest Service Proceedings RMRS-P-30. 2003 63 Krausman and Morrlson Wildlife Ecology and Management, Santa Rita Expenmentai Range (1903 to 2002)

4. Track potential problems hefore they become real resource managers to be able to identify a S percent annual probl ems. change in abundance ofa species in 3 years, or can they wait to identify this change over 5 years? The answer will These ob,jectives are often addressed by conducting monitor- \'w depending on the species in question, Note that allowing for ing studies (Gray and others 19'96; Miller 1996) to: a 5 percent decline in ahundance over 5 years results in il 1. Determine wildlife use of a particular resources or cumulative loss of 29 peicent-a substantial decline for any area. species. 2. Evaluate effects of land use on populations orhabitats. Unfortunately, very little general guidance is in the litera- 3. Measure changes in population parameters. ture regarding appropriate initial sample sizes for a large- 4. Evaluate succehs of predictike models. scale. multispecies monitoring program. This isdue. in part, 5. Assess faunal chmges over time. to the rather recent general interest in statistical rigor being shown among many wildlife professionals. However. many Monitoring Elements. computer statisticpl packages are ROW available that allow I easy access to power analyses, Because there are so many : Key components of a monitoring-prograrr,at SRER should potential criteria thiit can appropriately he used for estab- include the: lishing monitoring parameters, and because the rarer species will require specialized sampling efforts, we cannot 1. Ability to link past, current, and any future research provide a cookbook answer for necessary sample sizes. Some activities with a systematic grid system (in other words, to studies on monitoring relatively conimon bird species have beable tolocate relativeto base nionitoniigsarnplingfraine~. shown, however. that 30 to SO points (us~iallycounted 3 2. Sampling frame developed around an attribute-based times each per season, most often in the breeding season)are <;IS vegetation system. adequate to detect a 5 percent annual change in abundance 3. Sampling protocol for rare species. such as adaptive within a S-year period. At SRER. however, it will not be cluster sampling, to be instituted in addition to the basic possible to place that many points within relatively rare sampling frame. vegetative types or plant associations. In such situations. it For example, a 500- by 500-in grid coordinate system becomes necessary to increase sampling intensity. and con- could be established across SRER. This spacing would be duct a more intensive type of nronitoring. to rigorously applicable for implementing a standard point-count meth- quantify change. With birds, for example, researchers often odology for birds because must counting protocols require supplement point counts with more intensive spot mapping an interpoint spacing ofgreater than or equal to 300 m. The procedures. actual spacing of grid points is actually irrelevant hecause the system would only exist as coordinates in ;I GIs Iilyer Rare Species and not physicitlly exist on the ground. Using the 500- by 500-m spacing and beginning at a random starting point in Management recommendations are sometimes made for one corner of SRER, points would be systeinatically spread rare species based on data from common species, although across the area. Additional points would also be randomly rare species are excluded from analyses due to sniall s~inple placed within each currently recognized vegetation type, siLes. In many cases, threatened or endangered species are while ensuring that adequate sampling occurred in rare "rare." If Ispecies only occurs in a very specialized habitat, types. For example, additional (nongrid)points would need it would he rare in that its only detections occur within to be established in linear (for example, riparian) and spatially clumped areas. Alternatively. if a species has a relatively small (for example, hackberry [Ckltis reticulatal large geographic range it may be considered rare because it woodland) types. A systematic placement of grid points is is only detected during a community assessment as it wan- recommended because there is no assurance that a cur- ders through a study wea. Lastly, species are considered rently recognized classification of vegetation would he of rare when ltral populations are composed of a few individu- adequate refinement for many applications. or that the ids per unit area, as is the case with most threatened and classification would be stable into the future. It is likely. endangered species (Queheillalt and others 2002). however, that certain vegetation cla Due to the great number of "rare" species in plant and ample, riparian, the major plant associations currently animal cornniunities, these communities are known to ad- recognized) will remain adequate upon which to base the here to lognormal species abundance distributions. in which generul allocation ofpoints. The value of points is that they a sniall number of species are common, only a few species are readily locatable using GPS, even if they serve as the reside in intermediate to low numbers, and most are unconi- starting point of a transect. mon (Harte and others 1999; Maim and Howe 2000; The number of points to be sampled should be based on Rosenberg and others 1995; Van Auken 1997). Frequently power analysis using the best available estimates of vh- used sampling designs, such as simple random sampling. ance associated with each parameter of interest. It is impor- stratified random sampling, and systematic random sum- tant to recognize that power analysis only provides an initial pling, are ineffective when applied to infrequently encoun- estimate of sample size. The final sampling effort must be tered species. and such sampling designs return numerous hased on an iterative process that updates the number of zero cuunts and decrease the accuracy of the studies using required samples as data are gathered. Power analysis these designs (Thompson 1992;Thompson and others 1998). requires that a magnitude of biological effect be established. The exclusion of species due to low detection rates leads to That is, what magnitude of change must be quantified with the erroneous inflation of relative abundance and density what level ofcertainty?For example, is it sufficient for SRER calculations of included species. In instances of special

64 USDA Forest Service Proceedings RMRS-P90.2003 Wildlife Ecology and Management, Santa Rita Experimental Range (1903 to 2002) Krausman and Morrison

status species (for example. legally threatened or endan- Eddy. T.A. 196 I. Focxis and fcding patterns of thc collwcd pwcary gered).elevateddensity estimates may lead to the biological in southcrn Arizona. Journal of Wildlifc Mnnagemcnt. 25(3): notion that a species is prevalent in sufiicient numbers when 348-257, Fishcr. A. K. 1980. lntlucrice of an ;hiidant supply of carrion 011 in fact its actual density is low. Also. iftheobjrct ofthe study population piramctcrs of thc coyotc. Tucson: University of Ari- is to compare relative abundances over successive years, zona. 80 p. Disscrtation. trends may appear for a species, which are due to the Gcrmluio,1). J.; Hungcrtord.C. K. 1 981. Kcptilc population chiuigcs number of species excluded from abundance calculations with mllnipulatiorioISonorandcscrt scrub. Grciit Basin Naturitl- ist. 41(1): 129-138. rather than true biological trends. Gcrmano, D. S. 1978. Rcspoiisc of sclcctcd wildlife to cncsquirc Because rare species are often spatially clumped. we rcmoval in dcscrtgrassland. Tucson: Univcrsity of Arizona. 60 p. recommend using one of the forms of adaptive sampling Thesis. methods-adaptive cluster sampling design. strip adaptive Cihhs, J. P. 1995. Monitor: software for cstimatirig thc power of cluster sampling, or stratified adaptive cluster sampling- population monitoring programs to dctcct trcnds in plant iind animal ahundance. Users manual. version 6.3. Ncw Haven, CT as descrihed by Thompson (I 993) to supplement the systeni- Yak University, Dcpartrncnt of Biology. atic arrangement of sampling points described above. Adap- Gorsuch, D. M. 1934. Lifc history ofthcGamhc1 quail in Arizona. tive cluster sampling is a two-stage sampling design in Tucson: UnivcrsityofArimna. Biological Scicncc Bullctin. 2: I-X9. which initial sampling plots are randomly selected and Gottcsman. A. B. 2002. Movcrncnts :uid hahirat usc oC the brush mouse. Tucson: University of Arizona. 50 p. Thcsis. monitored. Any of the initial plots containing animals are Grccn. K. H.; Young. R. C. 1993. Sampling to dctcct rare spccics. selected to have all adjacent plots monitored as well. This Ecological Applications. 3(2):35 1-356. process continues until adjacent plots no longer contain Grccnc, K. A,; Murphy. G.H. 1032. The intlucncc of two burrowing animals of interest (Krebs 1999; Momson and others 2001; rodcnts. Diptdurnrs spccf:rhi/is .spccfrrbili.s(kangaroo rat) and Thompson 1992). This method increases the probability of &'cotorna alhi~ulaalbigukr (pack rat). on dcscrt soils in Arizona. If. Physical cffccts. Fxology. 13(4): 359-363. encountering clumped species, and thus often increases Grccnc. R. A.; Rcyna-d, C. 1932. Thc influcncc of two burrowing sample sizes. rodcnts, Uipdomys specruhilis .spectubi/iq (knngaroo rat) and Statistical analyses with sinall sample sizes can be prob- Ncoforna u1hlgulil ulbigulu (pack rat). on dcscrt soils in Arizona. lematic. When samples we from highly variable popula- €kology. I3( I 1: 73-80, Grinncll. J. 1927. A critical factor in the cxistcncc of S)uthwcstcrn tions. statistical analyses often have low power. Although gamc birds. Scicncc. Ixvi: 528-529. beyond the scope of this paper, there are options for statis- Hartc. J.; Kinzig.A.;Grccn.G. 1999. Sclf-similarity in thcdistrihu- tical analyses with small sample sizes. Contingent upon the tion and abundancc of spccics. Scicncc. 284541 2): 334.336. specific situation and type of data being used, nonparamet- Haskcll. H. S.; Rcynolds. H. G. 1947. Growth. dcvclopmcntitl fwd ric tests can be employed or data transformed to allow the rcquircmcnts, and brceding activityof the Califbrnia jack rabbit. Journal of Mammalogy. 28(2): 13-136. use of parametric tests when working with small s;iniple Hinds, D. S. 1970. A comparative study of thcrmorcgulation and 0 siLes. watcr balance in hares aid ruhbitscrfrhc Sonorm Dcscrt. Tucson: Univcrsity of Arizona. I45 p. Disscrtation. Humphrey, K. R. 1936. Notes on altirudinal distribution ut'rattlc- References snakcs. Fxology. 17t2): 328-329. Hungcrford. C. R. 19603. The Factors affccting thc hrecding of Arnold. J. F. 1942. Foragc consumption and prcfcrcnccs of cxpcri- Gamhcl's quail Lophortyr gamhelii gamhclij Gumhcl in Arizona. mcntally-!id Arimna and antclopcjack rabbits. Tucson: Univcr- Tucson: Univcrsity of Arizona. 94 p. Disscrtation. sity of Arizona. Arizona Agricultural Bxperimcnt Station Techni- Hungerford. C. K. 196Oh. Waitcr rcquircmcnts of Gamhcl's quail. CUI Bulletin. 98: 5 1-86. North Arncrican Wildlife Confcrcnce. 25: 23 1-30. Arnold, J. P.: Kcynolds, H. G. 1943. Droppings of Arizona and Hungcrford, C. R. 1962. Adaptiitions shown in sclcction of food by antclopc jackrabbits and thc "pcllct ccnsus." Journal of Wildlifc Garnhcl quail. Condor. 64(3):2 13-219. Managcmcnt. 7(3): 322-327. Hungcrford. C. R. 1964. Vitamin A and productivity in Gatnhcl's Brown. C. F.; Krausrnan. P. K. 2(X)3. Mahitat chiuactcristics of 3 quail. Journal of Wildlife Managcmcnt. 28: 141-147. lcporid spccics in southcastern Arizona. Journal of Wildlife Kurnzi. A. J.;Morrison, M. I.; Swam, D. E.; Hardy, P. C.; Downard. Managcmcnt. 67(1): 83-89. G. T. 1999. A longitudinal study of Sin Nombrc virus prcvalcncc Caldcr, W. A. I968a. Thcdiunial activityofthc roadrunncr, G&~ccxcyx in rodcnts, southeustcrn Arizona. Erncrging Infwtious Discascs. cn1ihrni:mus. Condor. 70( 1 ): 84-85. 5(1): 113-1 17. Caldcr, W. A. 1968h. Therc really is a roadtunncr. Natural History. Knipc, T. 1957. Javelina in Ari~ono.Phocnix: Arizona Gamc and 77: 50--55. Fish Department. Wildlife Bullctin. 2: 1-96, Courtncy, M. W. 197 1. Effccts of rcmoval on rnovcmcnts within 1.imglcy. W. 1980. Hahitat prcfcrcnccs of Oncbmny,~Torridus populations of nocturnal dcscrt rodcnts. Tucson: [.!nivcrsity of (Muridac) in a dcscrt grassland. Southwcstcrn Naturalist. 25(2): Arizona. 32 p. Thcsis. 266-267. Courtncy, M. W. 1983. Effects of rcduccd intcrspccific intcructions Langlcy, W. 1978. Thc dcvclopmcnt of prcdatury hchuvior ,in on population dynamics in Mcniam's kangaroo rat, Dipodorn~/s Oncborn.v.s'Tom~dos(Coves). Tcmpc: Arizona Statc Unircrsi ty. mcm'umi. Tucson: University of AriLona. 73 p, Disscrtation. 170 p. Disscrtation. Danncr, D. A. 1976. Coyotc homc rmgc, social organizution, and Langlcy, W. 1981.Thecffcctofprcydcfcnscson thcattiickbchavior sccnt post visitation. Tucson: Univcrsity of Arizoria. 86 p. Thcsis. of the southern grasshopper Snouse (0ncboniy.s Tr,rridu.s 5. -%. Uauincr, D. A.: Fisher, A. H. 1977. Evidcwc of.homiiig hy ii cobotc Ticrpsychobgy. 56(2): 115-1 27. I. (Canis hrrms).Journal of Mamrn9hgy. S8(Z): 2M-215. kopold. A. 1933.Game Matiii&cmcnt.Ncw York: Charlcs Scribn,cr's ., ,' .- Danncr. D. A,; Smith. N. S. 1980. Coyotc homc rmgc. mrivcmcnt. Sons. 181 .p. ' . ' and rclativc abundancc ma- a cattlc fccd yprd. Journal of MaGrcgor. W. 1953. ib1 cviluation of California quail manhgc- Wildlifc Managcmcnt. M(2):484-487. mcnt. Western Association of State Gamc und Fish Commission- Drcwck. J.. Jr. 1980. Bchavior. populatio!i structure, parasitism, crs. 33: 157-160. and othcr aspects of coyote ecology in southern Arizona. Tucson: Miuna, G. G.; Howe, H. F. 2000. Inhcrcnt rarity in community University of Arizona. 261 p. Dissertation. restoration. Conscrvatibn Biology. 14(5): 1235-1 340. I Eddy, T. A. 1959. Foods of the collarcd pcccary Pccac.an' f@cu Martin. S. C. 1066. Will )ou scc any gamc today'? Progrcssivc .sonoriensis (htcarns) in southcrn Arizona. Tucson: University of Agriiculturc in Arizona. 18(4):30-3 1. Arizona. 102 p. Thcsis.

USDA Forest Service Proceedings RMRS-P-30. 2003 65 Krausman and Morrison Wildlife Ecology and Management, Santa Rita Experimental Range (1903 to 2002)

hicrormick. D. P. 1975. FKcct of mcsquitc control on small game Russell. S. M.; Gould. J. P. 1974. Population structure, foraging populatioiis. Tucson: University of Arizonn. 66 p. Thesis. hchavior. and daily inovcincnts of certain Sonoran Dcscrt hirds. Mcdina, A. L. 1988. Diets of scaled quail in southcrn Arizona. U.S. International Biological Progrim. Desert Biomc Rcsctuch Journal of Wildlifc M.inagcmcrit. 52(4): 753-757. Mcmorandum 74-27. 3: 129- 135. Mcditia, A. L. 1996. The Santa Riva Expcrimental Range: history Russcll, S. M.; Gould, P. J.: Smith, E. L. 1973. Population structure. and annotated bibliography (I 903-1988), Gcn. Tcch. Rep. RM- foriiging behavior aiddaily movements ofcertain Sonoran Desert GTR-276. Fort Collins. CO US. Department of Agriculture, hirds. U.S. International Biological Program. Dcscrt Biomc Rc- Forcst Scrvicc. Rocky Mountain E'orcst and Kanfe Expcrimcnt scarch Mcmorandum 73-27. 3: 2.3.2.10.-1-2.3.2.10-20. Station. 67 p. Russcll, S.; Smith, E.; Could, P.: Austin. G. 1973. Studies on -Momson. M. L.; Block. W. M.;Strickland, M. D.: Kcndall. W. L. Sonoran hirds. U.S. Intcrnationill Biological Program. Dcscrt 2001. Wildlife study design. Ncw York: Springer-Vcrlag. 210 p. fliomc Rcscarch Mcmorandum 72-31. 2.3.2.7.-1-2.3.1-.7.-13. Morrison. M. t..; Kucnzi, A. J.; Brown. C. I?%; Swann. D. E. 2002. Schmidt-Nielscn. R.; Schmidt-Niclscn, K. 1950a. Evaporativc wa- Habital use and abunduricc trcnds of rodcrits in southeastern ter loss in dcscrt rodciits in their natural habitat. Ecology. 3 l(1 j: Arizona. Southwestern Naturalist. 37(4): S 19-526. 75-85. Morrison. M. I..;blurcot, 8. G. 1995. An cvaluation of rcsourcc Schmidt-Niclscn,B.; Schmidt-Niclscn, K. I950h. Pulmon;wy water invcntory and monitoring programs used in National E'orcst loss in.dcscrt rodents. American Journiil of Physiology. 162(1): planning. Environmental Managcment. IWI): 147-1 56. 3 1-36. Nichol. A. A. 1938. Experimental feeding of dccr. Tucson: Univcr- Schmidt-Niclscn. B.; Schmidt-Niclscn.K. 195 1. Acornplctcaccounl sity of Arizona. Anmna Agricultural Expcrirncnt Station Tcchni- of thc water metaholism in kmgiuuu rats and an cxpcrimcntal cal Bulletin. 75: 1-39, verification. Journal of Cellular mid Comparative Physiology. Nichol. A. A. 1936. The cxpcrirnciital feeding of dccr. Transactions 38(2): 165-181. of thc Nodi American Wildlife Conference. I : 403410. Schmidt-Nielscn, B.; Schmidt-Nielscn. K.; Broknw. A.; Olding, R. J.. Jr. 1976. Estimation of dcscrt rodent populations Iry Schncidctinan. H. 1948. Watcr conservation in dcscrt rodcnta. intcnsivc rcmoval. Tucson: Univcrsity of AriLona. 60 p. Thesis. Journal of Ccllular and Compwativc Physiology. 320):33 1-360. Olding, R. J.; Cwkrum. E. I-. 1977. Estimation of desert rodcnt Schmidt-Niclscn, K.; Uawson, T. J.; Hammel, H. T.; Hinds, D.; populutions by intensive rcmoval. Journal of thc Arizona Acid- Jackson, D.C. 1966. Thc jack-rabbit-a study in its dcscrt sur- cmy of Science. 12: 94-108. vival. Hvidritdcts Skriftcr. 48: 125-142. Pctqszyn, Y. 1982. Population dynamics of nocturnal dcscrt ro- Schmidt-Nielscn.K.; Schmidt-Niclscn. B.; Schncidcrman, H. 1948. dciits: a nine year study. Tucson: University ot' Arizona. IO8 p. S:ilt excretion in dcscrt inammals. The Amcrican Journal of Dissertation. Physictlogy. 154~1):163-166. Pricc, M. V. 1976. The rolc of microhabitat in structuring dcscrt Short. H. L. 1979. Food habitsofcoyotcs in ascinidcscn grass-shruh rodcnt communitics. Tucson: University of Arizona. 72 p. habitat. Res. Note RM-364. Fort Collins, CO: U.S. Dcpitrtmcnt of Dissertatioii. Agriculture. Forcst Service. Rocky Mountain Forcst and Rangc Pricc. M. V. 1977. Validity of live trapping as a mcasurcofforaging Expcriincnt Station. 3 p. activity of Hctctomyid rodcnts. Journal of Mammalogy. 58(1 J: Spellcrbcrg. 1. F. 1991. Monitoring ccological changc. Ncw York: 107--I IO. Cambridge University Press. 334 p. Pricc. M. V. 1978. Thc rolc of microhubilat in structuring dcscrt Swann. D. E.: Kucmi. A. J.; Momson, M. L.; DcStcfano, S. 19Y7. rodent communities. Ecology. 5915): YIG-921. Hffccts of sampling hloodon survival ufsmall mammals. Journal Pricc. M. V.: Nickolas, M. W.; Bass. T. A. 1984. Effcctsofmoonlight ofMammalogy. 78C3): 909-913. a on micruhahitat usc by dcscrt rodcnls. Journal of Mammalogy. Tliylor. W. P. 1930. Mcthods oldctcrmiiiing rodcnt prcssurc on thc hS(2):353-356. rangc. Ecd~gy.110): 523-542. Qucheillalt, D. M.; Cain. J. W., 111; Taylor, D. E.; Morrison, M. L.; Taylor, W. P. 1935. Some anirnal relations to soils. Ecck~yy.l6(2): Hoover. S. L.: Tuatoo-Bartley. N.; Kugge, L.;<:hristophel-son. K.; 127-1 36. Hulst, M. D.; Hdo.M. R.: Kcough. H .I,. 2002. The exclusion ut' Taylor, W. P.: Vorhics. C. T. 1923. Kangaroo rats and scorpion mice rwc species from cornmuniry-lcvcl analyscs. Wildlifc Swicty on thc Santa Kita Rcscrvc. Arizona. Journal of Mammalogy. f(4): Bulletin. 30(3): 756-759. 255. Rcynolds, H. G. 1950. Relation of Mcrriitm kangarw rats to rangc Tuylor, W. P.; Vorhics, C. T.; Lister, P. B. 1935. The rclation ol'jxk vcpetation in southcrn Arizona. Ecology. 3 l(3f:456-463. rabbits to grazing in southern Arizona. JoumalofForcstry. 33(5): Rcyndlds, H.G. 1954. Somcintcrrclationsofthc Mdamkangmrat 490498. to vclvct mcsquitc. Journal of Range Mamagcincnt. 7(4): 176-1 80. Thvmpson, S. K. 1990. Adaptive cluster sampling. Journal of the Reynolds. f4. G. 1958. The ecology of the Meniam kangarm rat American Statistical Association. 85(4I 2): IOSOI-1059. (Dipc&my.s mem.ami Meanis) on the grazing larids of southern Thompson. S. K. I 99 I b. .4daptivc cluster sampling: designs with Arizona. Ecological Monographs. 28(2): 1 11-1 27. primary mdsccondary unils. Biometrics. 47(3): 1 103-1 I 15. Reynolds. H. C. 1960. Life history notes on Mcrriam's kangaroo rat Thompson, S. K. 1991a. Stratificd adaptive clustcr sampling. in southcrn Arizona. Journal of Mammalogy. 31(1 j: 48-58. Biomctrika. 78(2): 389-397. Reynolds, H. G.; Glcndcning, G. E. 1949. Memarn kangaroo rat a Thompson, S. K. 1992. Sampling. New York: John Wilcy & Sons,Inc. flictor in incsquitc propagation on southern Arizona rangc lands. 367 p. Journal of Rangc Management. 2(4): 193-197. Thompson. W. L.; White. G. C.: Guwan, C. 1998. Monitoring vcrtc- Reynolds, H. G.; Htlskcll, H. S. 1949. lifehistory notcson Price and hrate populations. Sun Dicgo. CA: Acadcinic Press. 365 p. Bailey pockct mice of southcrn Arizona. Journal of Mammalogy. Turkowski, F. J.; Vnhlc, J. R. 1977. Dcscrt rodcnt ahundancc in 30t2): 150-1 56. southern Arizona in rclation to rainfall. Res. Note RM-346. Fort Rodgers. K. J. 1977. Seasonal movement of mule deer on the Santa Collins, CO: U.S. Department of Agriculture. Rmst Service. Rita Experimental Range. Tucson: University of Arizona. 63 p. Rocky Mountain Forcst and Rangc Expcrimcnt Station. 4 p. Thesis. Van Aukcn. 0.W. 19Y7. Spccics rscncss aid commonness along Rodgcrs. K. J.; Ffolliott, P. F.; Patton. D. R. 1978. Home rangc and spatial and tcmpord gradients. Thc Southwestern Naturalist. movcmcnt of five mule dccr in u scmidcscrt gras-shrub commu- 43(4): 369-374. nity. Kas. Note. RM-355. Fort Collins, CO: U.S. Dcprutment of Vaughlui, P. J. 1972. Dispersal in a small mammal ppulatiori. Agriculturc. Forcst Scrvicc, Rocky Mountain Forcst and Kungc Tucson: Univcrsity of Arizonn. 61 p. Thesis. Experirncnt Station. 6 p. Vaughan. T. C. 1976. Effccts of wocxty vcgclzation removal on rodent Koscnhcrg, D. K.; Overton. W. S.; Anthony, K. C;. 1095. Estimation populations at SantaRita Experimental Kmgc, Arizona. Tucson: of aniinal abundaicc whcri capturc probabiljtics :rc low and Univcrsity of Arizona. 95 p. Dissertation. hctcrogcncous. Journal of Wildlife Managcmcnt. 59(2): 252-261. Vorhics. C. T. 1928. Do Southwestern quail rcquirc water? Amcri- Roscnstock, S. S.;Ballurd, W. R.; deVos, J. C., Jr. 1999. Bcnctits wid can Naturalist. 682: 446-452. impacts of wildlifc water dcvclopmcnts. Jourxiul of Range Man- Vorhics. C. T. 1932. First record of thc pectoral sandpiper for agement. 52(J): 302-31 I. Arizona. The Condor. 34(1): 46-47.

66 USDA Forest Service Proceedings RMRS-P-90.2003 Wildlife Ecology and Management, Santa Rita Experimental Range (1903 to 2002) Krausman and Morrison

Vorhics. C. T. 1945. Wntcr rcquircmcnts of.dcscrt animals in the rclation to $ruing in Ari~ona.Tucson: Llnivcrsity of Arizona. Southwcst. Tucson: University of ,\rizona. Arizona Agricultural Arizona Agricultural Experiment Station Technical Bullctin. 86: Expcrimcnt Station Tcchnical Bullctin. IO?: 187-525. 455-529. Vorhics. C. T.; Taylor. W. P. 1922. Lie history of the kangaroo rat. Wondollcck. J. T. 1978. Forngc-uca scpw.rution and ovcrlup in Dipxlornys spccccrhilis \ppccrabi/isMerriam. Bull. 1091.Washing- hctcrornyid rodcnts. Journal of Mammalogy. W(3): 5 I(b5 18. ton. UC. U.S. Dcpnrtment of Agriculture. 40 p. Wondollcck,J. T. 1975.Thc intlucnL.cofintcrsp~ificintcructionson Vorhics. C. T.: Taylor. W. P. 1924. Damagc hy kangaroo rats. thc t'oragc xcas of hctcrornyid rodcnts. Tucson: University of Journal of Mammalogy. S(2): 14.4. Arizona. 25 p. Thesis. Vorhics, C. T.;Taylor, W. P. 1933. The life histories and ccologgy ofjack Ycagcr.M.; hkutin.S.C. 1965. Rcsultsof1963dccrhunton IhcSnnta rahhits, Lcpiis :illmi arid Lcpus cdifomiws ssp., in rclation to KitliExpcrimcntal Rangc. Tcrnpc. .a:US. DcparlmcntofAgri;ricul- grazing in Arizona. Tucson: Univcrsity of Arimna. Arizonn Agricul- turc. Forcst Scrvicc. Kccky lvlountain Forcst and Rangc Expcri- rural Expcrirncnt Station Tcchuical Bulletin. 4% 47 1-58?. incnt Station. ;uid Arizona Gnmc and Fish Dcptu-tmcnt. 18 p. Vorhics. C.T.; Taylor. W. P. 1940. Life history and ccology of thc Ilvlimco. Nor seen\. Citcd in Mcdina 1096. uhitc-thmatcd wotxl rat. Neoroma nlhigula afhigula Hartlcy, in

USDA Forest Service Proceedings RMRS-P-30.2003 67 October 7,2009

Jaime Wood Environmental Planning Group 4 14 I North 32”d Street Suite 102 Phoenix, Arizona 85018 - RE: Rosemont 138kV Transmission Line Dear Ms. Wood:

The Town of Sahuarita is providing the following comments regarding the switchyard proposed and the transmission line segments proposed to serve the Rosemont Mine with the 138kV Transmission Line planned for a site east of Town limits. For the record, the Town does not support the larger Rosemont Mine project currently under NEPA review but recognizes that TEP is obligated to serve the user. 0 The Town recommends the proposed poles that will be replaced dong the existing 46kV transmission line be as low as possible in order to maintain the current scenic view along Line Segments 30,110 and 150. 0 The Town prefers the existing 46kV transmission line alignment that is located east of the Town of Sahuarita; the route includes Line Segments 30, 1 10, 150, 160 & 190. It is strongly recommended that the existing easements along roadway aiignments adjacent to Line Segments 160 & 190 be used for the proposed 138kV line in order to minimize disturbance to animal and plant life. The Town requests a map for the project that outlines the footprint, location and necessary infiastructure needed for the proposed switchyard at the intersection of Line Segment 20 and 30. 0 The Town encourages co-location on proposed 138kV poles to serve the hture areas east of Town limits in order to prevent firther disturbance of natural open space,

If you have any questions or would like to discuss the comments provided, please contact me or Orlanthia Henderson at 520-822-8852.

Planning & Zoning Director Town of Sahuarita

T .... THIS PAGE INTENTIONALLY LEFT BLANK EXHIBIT

KEITH BAGWELL PIMA COUNTY BOARD OF SUPERVISORS D(zcuIM ASSISTINT 130 W. CONGRESS STREET, 11“‘FLOOR ANDREA ALTAMIRANO TUCSON, ARIZONA 85701-1317 SPEW STAFF ISSISTANT ANNA HARPER TELEPHONE (520)740-8126 sP€u STAFF FsSrnIIyT ELiAS FAX (520)884-1152 RICHARD E-MAIL: [email protected] EVANCELINA QUlHUlS

COUNTY SUPERViSOR ~ DISTRICT 5 WEBSITE www.dstrict5.pirna.go.r CWURMAN OF THE BOARD %3J!4‘rn *=;:;;; sP€*kL STAFF AsssmNT EPG Inc. March 20,2009 4141 N. 32d St, Suite 102 Phoenix, Ariz. 85018-9960

To Whom it May Concern:

I write to put on the recod my opposition to the installation of an electric-power transmission line fiom any Tucson Electric Power Co. facilities to the site of a proposed Rosemont Copper Mine in the Santa Rita Mountains foothills southeast OfTucson.

My opposition to the proposed open-pit mine is based priman’Iy ou the severe environmental degradation it would entail as Pima County strives to maintain key elements of the unique Sonoran Desest habitat that drew here so many of the cuunty’s residents and that continues to fuel much of our critid tourism industry.

Scraping a path through pristine parts of this desert area, vital for the survival of numemus unique and rare animal and plant spscies, to erect another elecbic power line would !%her degrade the ana’s habitat values and should not be allowed to occur.

The Pima County Board of Supervisors, of which I am chairman, has passcd fbur resolutions, attached, in opposition to the Rosemont Mme proposal, and to actions attendant to its development that also are environmentally destructive.

The Rosemont site itself is m an amPima County has identified as containing important ecosys$ems that are desirable to the county fwprotection. Its dovMlstream impacts would be devastating to both the county’s Cienega Cretk Natural Reserve and to its tributary, Davidson Canyon, which is state-recognizedas Outscandmg Waters.

The Rosemont Mme proponents want to pump gmund water and move Central Arizona Project watcr fhnthe canal to other sites, altering and negatively impacting our precious regional water supplies.

This proposai to transmit elecb-ic power over and through sensitive desert habitats, across washes and canyons, and into forested areas to serve the mine’s needs promises Mer habitat loss and environmental degradation. It should be rejected.

Richard Elias Chaiian, Pima County Board of Supervisors

cc: Members of the Arizona Corporation Commission THIS PAGE INTENTIONALLY LEFT BLANK

Thursday, December 8,20ll 75centsplustar: $lea*- ..,I , .. ,'.$.%.. ' .,.. Rosemont

shows', %t new site

no plans to mine them,

ARIZONAONLY STAR Amapshowntopotentialinvestosby&semont Mine's parent company shows three copper "tar- gets" in areas lying west of the currently proposed open-pit mine site. E those additional areas were evenky minsd, thw would be visible to Green Valley, a stronghold The map appears on Augusta Rf!source ' COrplS website as an in- vestor presenta-

tion. I -i. ' But Gil claw Auw- ta's president and CEO, said Wednesday that the company has no plans to mine these arw, which lie &$or west of the ri-e in the santa fits Mountains. They sit directly west of the proposed mine that is now underping federal envi10-a ~~~u~tGo6hiectRos~orevie3-.- however;- lwagat the potential for future coppk mining east of that ridgeline, Clawen said. It 1s conducting electric;based, undergowd geophysical ex-

@ On StarNet Read more environment-related articles at ,tarne~wm/newJ/science/enviranment

Rosemont 138kV Transmission Line Project Future Land Use Exhibit A-3

Legend Land Use ICommercial Industrial Parks/Preservation Public Lands Pub lic/Q uasi- Pu blic I I Recreation Residential Santa Rita Experimenta Range Ut il it ies I! I! VacantNndeveloped

Status- rA Plat Approved y//1 Zoning Approved Conceptual/General/Comprehensive Plan hT Future Use under the Mining Act Rosemont Operations - NEPA Process Ongoing TUCSON ELECTRIC POWER COMPANY’S RESPONSES TO MR. MAGRUDER’S SECOND SET OF DATA REQUESTS DOCKET NO. L-OOOOOC-11-0400-00164 NOVEMBER 30,201 1 1 Magruder 2-1. Purchase Power Agreements. (a) Does TEP expect to sell its power by Company Agreements (or similar legal documents) with Rosemont Copper for power on the 138 kV Rosemont Copper transmission line? (b) Has an Agreement already been consummated, and it so, please provide a copy in your response. (c) Does TEP expect Rosemont Copper to pay the present rates as the other TEP mining customers, if not, please explain? (d) Does TEP expect rates that depend on the cost of copper, as with some other mining companies, or will a set rate schedule apply? RESPONSE: (a) No. Power will be provided to Rosemont via TEP’s Commission-approved retail tariffs, (b) No agreement has been consummated. (c) Rosemont will pay in accordance with Commission-approved retail tariffs. (d) See response to 2-l(c). RESPONDENT: Ed Beck WITNESS: Ed Beck

Arizona Corporation Commission (“Commission”) Tucson Electric Power Company (“TEP”) Certificate of Environmental Compatibility (“CEC”) Western Electricity Coordinating Council (“WECC”) North American Electric Reliability Corporation (“NERC”) Rosemont Copper Company (“Rosemont”) TUCSON ELECTRIC POWER COMPANY’S RESPONSES TO MR. MAGRUDER’S SECOND SET OF DATA REQUESTS DOCKET NO. L-OOOOOC-11-0400-00164 NOVEMBER 30,201 1

Magruder 2-2. Transmission Line Reliability. TEP’s response to Magruder DR 1-2 indicated that a radial line will be used for Rosemont Copper. (a) Can TEP provide proposals for backup transmission or generation capabilities for Rosemont Copper? (b) Does TEP agree, if the transmission line or if either substation fails, there will be no power available for mining by Rosemont Copper? If TEP does not agree, please explain. (c) The CEC Application states that TEP South Substation will provide power to the Tor0 switchyard. The South Substation is inside the 100-year flood plain. How will power be provided during the 1% annual chance that substation will be flooded? (d) Does component reliability (usually measured in MTBF, MTTR, Ao, etc. objective reliability engineering standards) enter into the decision making processes at TEP for transmission line conductors, insulators, utility poles, and fasteners, and if so, please describe how components are compared to determine which is more reliable than another? RESPONSE: Yes. If the transmission line, Rosemont Substation or the Tor0 Switchyard fails, power to Rosemont Copper would be interrupted. It will be provided as it always has been. A 100-year flood will not cause the substation to stop operating. Historically, TEP did not compare manufacturer product reliability data in making initial procurement decisions. Instead, TEP would trial the material, research its capabilities and discuss the product with other users. The Company also would stay in contact with other utilities at various meetings. At some conferences closed door discussions about reliability of various products occurred with a comparison of the various entities results. Afier the fact, TEP tracks failures and when failure trends develop the Company deals with them. TEP also asks for formal failure reports from manufacturers when the failure cause is not evident. The manufacturer’s failure analyses are then used in the decision- making process. RESPONDENT: Ed Beck WITNESS: Ed Beck

TUCSON ELECTRIC POWER COMPANY’S RESPONSES TO MR. MAGRUDER’S SECOND SET OF DATA REQUESTS DOCKET NO. L-OOOOOC-11-0400-00164 NOVEMBER 30,201 1

Zone Name Description Location

500-year floodplains. not been mapped by FEMA but may have been mapped by a local

(c) Yes, TEP anticipates a review by the Army Corps of Engineers will be required (TEP understands that Rosemont has included the off-site utilities in both their DEIS and the Preliminary Jurisdictional Delineation that they received from the Corps). TEP further understands and anticipates that Rosemont will include the transmission line impacts in its permit. As always, TEP will avoid waters of the US to the maximum extent practicable. For this project, TEP will most likely fall under Nationwide Permit 12 for Arizona Corporation Commission (“Commission”) Tucson Electric Power Company (“TEP”) Certificate of Environmental Compatibility (“CEC”) Western Electricity Coordinating Council (“WECC”) North American Electric Reliability Corporation (“NERC”) Rosemont Copper Company (“Rosemont”) TUCSON ELECTRIC POWER COMPANY’S RESPONSES TO MR. MAGRUDER’S SECOND SET OF DATA REQUESTS DOCKET NO. L-OOOOOC-11-0400-00164 NOVEMBER 30,2011

Utiiity Lines, and it will also likely be a formal notification because of the cultural resources and threatened and endangered species in the project area. RESPONDENT: Ed Beck WITNESS: Ed Beck

Magruder 2-4. The TEP Project Schedule What is the construction schedule, including major milestones, including public notifications, for the Tor0 Switchyard, the 138 kV transmission line and its structures, based on months after the Corporation Commission approves a CEC granted by the Line Siting Committee? Please provide the estimated number of months required for TEP, from start to finish (e.g., operational), for this project. Please describe what parts of this project will be completed by TEP personal and what parts will be “contracted”. Please provide a list of at least five potential transmission contractors that TEP might consider qualified and reasonable for this project. A TBD-selected contractor need not be on this list. Please describe the criteria TEP uses to select contractors to design, build, test and operate this transmission line project. The TEP response to Magruder DR 1-4 indicated there exists a MOU between TEP and Rosemont Copper “regarding Engineering and design for the Tor0 Switchyard.” Please provide a copy of this MOU. RESPONSE: The construction schedule for the project will be determined once a CEC is approved by the Commission. The schedule will incorporate any conditions that may be placed in the CEC. TEP anticipates that construction of the line will take approximately two months. Construction of the line has yet to be determined, which depends on ownership. The ownership of the line has not been determined and is dependent upon the route selected. The Tor0 Switchyard will be a TEP facility. Typically, TEP will contract out civil work for the site and the electrical construction will typically be completed by TEP personnel. Atkinson Power, Sturgeon Electric, Wilson Electric, Par Electric, and Klondyke Construction. For design, TEP has an alliance agreement in place with Sargent and Lundy (“S&L”) for design assistance. To the extent the design is not completed in-house it would be done by S&L. Relative to contractors for building and testing a line, TEP considers previous experience, safety performance, appropriate labor and equipment availability, and financial performance. All contractors must be preapproved as a service provider to TEP prior to submitting proposals on work. A contractor will not operate the line. It will be operated by TEP. Arizona Corporation Commission (“Commission”) Tucson Electric Power Company (“TEP”) Certificate of Environmental Compatibility (“CEC”) Western Electricity Coordinating Council (“WECC”) 0 North American Electric Reliability Corporation (‘“ERC”) Rosemont Copper Company (“Rosemont”) TUCSON ELECTRIC POWER COMPANY’S RESPONSES TO MR. MAGRUDER’S SECOND SET OF DATA REQUESTS DOCKET NO. L-OOOOOC-11-0400-00164 NOVEMBER 30,2011

(f) Objection: the MOU is confidential. Further, TEP objects to the request as irrelevant, outside the scope and not likely to lead to the production of relevant evidence. RESPONDENT: Ed Beck (parts a-e) and Regulatory Services (part f) WITNESS: Ed Beck (parts a-e) and N/A (part f)

Magruder 2-6. ROW Paralleling Santa Rita Road and Rosemont Copper 30-inch water pi pelin e. Re: Application p. 5, second para, second sentence, lines 3 to 5 (quoted above) and Figure (3-6, p. G-9. (a) Does TEP anticipate any other road construction, and if so, please describe where an why that location was chosen? (b) What types of TEP vehicles does TEP expect on the 14-foot service road during construction and operation, and their frequency of travel on this service road, both during and after construction? (c) Does consideration of installing the fence Northeast of the 14-foot service road so that perpendicular access from Santa Rita Road can be used instead of construction of a new road in the University of Arizona Sahuarita Experimental Range? (d) Will TEP modify its present plan to have a separate road outside the fence to having perpendicular access from Santa Rita Road to poles from inside the fence where the fence is outside of the ROW? If not, please explain, as this approach appears more environmentally friendly and cost less. RESPONSE: If the preferred route is selected, access for construction of the transmission line would be the service road shown with only very short spurs off to the service road at each pole location. The location of the service road was chosen to be consistent with the needs for construction of the pipeline. TEP will typically use rubber-tired vehicles for access to the line route for both construction and maintenance. The frequency of travel will be greater during construction with travel to and from each pole location for excavation, setting of the pole and then stringing of wire. The frequency after construction for TEP purposes will include an annual inspection of the line and as-needed should any maintenance be required. TEP’s plan to use a service road outside of the fence along Santa Rita road is predicated on a pipeline being constructed along the path where the service road is indicated. Construction of the pipeline will result in disturbance along the length of the linear route and will also require access for maintenance to the pipeline. In discussions with Arizona State Land and the SRER, the indicated service road was deemed to be the best choice. By putting the fence between the service road and Santa Rita Road use of the service road by other vehicles can be limited. See response to 2-6(c).

Magruder 2-7. Water Pipeline Safe Distance. (a) Will TEP consider effects of induced electrical currents on any underground ferromagnetic pipes in or near the transmission line ROW? (b) If so, what standard with TEP use to calculate the safe distance between the transmission line and underground ferromagnetic pipes? Please provide a copy of this standard and the calculations used to determine the safe distance. RESPONSE: (a) TEP will coordinate its design efforts with the engineer that designs the pipeline, but TEP understands that the impact to the pipeline due to any currents will be accounted for by the pipeline engineer. (b) N/A RESPONDENT: Ed Beck WITNESS: Ed Beck

Arizona Corporation Commission (“Commission”) Tucson Electric Power Company (“TEP”) Certificate of Environmental Compatibility (“CEC”) Western Electricity Coordinating Council (“WECC’) North American Electric Reliability Corporation (“NERC”) Rosemont Copper Company (“Rosemont”) TUCSON ELECTRIC POWER COMPANY’S RESPONSES TO MR. MAGRUDER’S SECOND SET OF DATA REQUESTS DOCKET NO. L-OOOOOC-11-0400-00164 NOVEMBER 30,201 1

Magruder 2-8. Distribution Power for water pumps. [Refl( 1) TEP’s Response to Magruder DR l.8.a states, “Rosemont and TRICO are responsible for this [water pump] circuit.” [Refl(2) The DEE MOP (Appendix, p. 5) states, “TEP will be the main electric utility service provider for the entire facility, including the fresh water system.” (a) Please explain the differences between these two statements. RESPONSE: (a) There is not a difference between the two statements. TEP is the main electric service provider for the entire facility. The Company will not be the sole provider, but will provide a very high percentage of the power. It will also supply the majority of the power to the well sites for the fresh water system. TRICO will supply a relatively small amount of power for some booster pumps along the water pipeline and a limited amount of the load at the mine itself. RESPONDENT: Ed Beck WITNESS: Ed Beck

Arizona Corporation Commission (“Commission”) Tucson Electric Power Company (“TEP”) Certificate of Environmental Compatibility (“CEC”) Western Electricity Coordinating Council (“WECC”) 0 North American Electric Reliability Corporation (“NERC”) Rosemont Copper Company (“Rosemont”) TUCSON ELECTRIC POWER COMPANY’S RESPONSES TO MR. MAGRUDER’S SECOND SET OF DATA REQUESTS DOCKET NO. L-OOOOOC-11-0400-00164 NOVEMBER 30,201 1

Magruder 2-9. Tor0 Switchyard Pima County Application. What is the status of any permit applications required by Pima County for the Tor0 Switchyard and when will public hearings be held? RESPONSE: The Tor0 Switchyard is part of the Application for the Project - subject to the jurisdiction of the Commission per ARS 4 40-360 et. seq. RESPONDENT: Regulatory Services WITNESS: N/A

Arizona Corporation Commission (“Commission”) Tucson Electric Power Company (“TEP”) Certificate of Environmental Compatibility (“CEC”) Western Electricity Coordinating Council (‘‘WECC’) North American Electric Reliability Corporation (“NERC”) Rosemont Copper Company (“Rosemont”) TUCSON ELECTRIC POWER COMPANY’S RESPONSES TO MR. MAGRUDER’S SECOND SET OF DATA REQUESTS DOCKET NO. L-OOOOOC-11-0400-00164 NOVEMBER 30,201 1

Magruder 2-10. Rosemont Copper’s Demand. (a) What conductor is planned for the 138 kV line? (b) What is the maximum capacity, in terms of MWs, under standard environmental conditions? RESPONSE: (a) The line will be constructed using a 954kcmil ACSS conductor, (b) The maximum capacity identified for this project is based on utilizing ANSUIEEE Std. 738-2002 method, as follows:

0 Continuous: 540 MVA, 2259 A @ 138 kV, 200OC conductor temperature; Emergency: 606 MVA, 2535 A @ 138 kV, 250 “C conductor temperature (temperature at which anti-corrosion component of steel stranding begins to degrade) Environmental Conditions: Ambient air temperature: 40.0 “C Wind speed: 8.8 ft/sec, 6.0 mph Wind angle to conductor: 45” Elevation: 2500 ft Latitude: 32”N Datemime: June 2 1, noon Emissivity: 0.70 Absorptivity: 0.90 Orientation: North-South RESPONDENT: Ed Beck WITNESS: Ed Beck

Arizona Corporation Commission (“Commission”) Tucson Electric Power Company (“TEP”) Certificate of Environmental Compatibility (“CEC”) Western Electricity Coordinating Council (“WECC”) 0 North American Electric Reliability Corporation (“NERC”) Rosemont Copper Company (“Rosemont”) TUCSON ELECTRlC POWER COMPANY’S RESPONSES TO MR. MAGRUDER’S SECOND SET OF DATA REQUESTS DOCKET NO. L-OOOOOC-11-0400-00164 NOVEMBER 30,201 1

Magruder 2-11. Power Agreements. (a) Does TEP have any cross-boundary agreements with TRICO that might involve this transmission line project? If so, please provide a copy of such agreements. RESPONSE: (a) TEP will have to enter an agreement with TRICO regarding the split of load at the mine. This agreement has not yet been negotiated. RESPONDENT: Ed Beck WITNESS: Ed Beck

TUCSON ELECTRIC POWER COMPANY’S RESPONSES TO MR. MAGRUDER’S SECOND SET OF DATA REQUESTS DOCKET NO. L-OOOOOC-11-0400-00164 NOVEMBER 30,201 1

Magruder 2-12. Lighting and Dark Skies. (a) Will TEP plan to have ANY lighting along the transmission at the Tor0 Switchyard? (b) If so, please describe the purpose of this lighting, its total wattage, and where it will be located? (c) If so, what kinds of light bulbs will be used and how will they be shaded when involved with transmission utility poles and the switchyard? (d) Will all of TEP’s lighting meet all the requirements of the Pima County lighting ordinances? If not, please explain what TEP will do to mitigate each case where such lighting exceeds these standards. RESPONSE: (a) TEP will have lighting at the T~i-0Swi:chyard for security andlor maintenance work at the facility at night. (b) The purpose is for personnel saf:ty when working in :he switchyard after dark. Please see response to 2-12(c) regarding n-attage. The lighting will b= located to best provide for the safety of personnel when the switchyard is designed. (c) The standard light fixture is a 250 W HPS for both wall mount and structure mount. The wall-mounted fixture is hooded on top with the diffuser directing light only out and down. The structure-mounted fixture is hooded on top and bottom, and is angled down to direct light down and away from the structure to light a large area. (d) Yes, the lamps in both fixture$ are enclosed to comply with Pima County lighting ordinances. RESPONDENT: Ed Beck WITNESS: Ed Beck

Arizona Corporation Commission (“Commission”) Tucson Electric Power Company (“TEP”) 0 Certificate of Environmental Compatibility (“CEC”) Western Electricity Coordinating Council (“WECC”) North American Electric Reliability Corporation (“NERC”) Rosemont Copper Company (“Rosemont”) TUCSON ELECTRIC POWER COMPANY’S RESPONSES TO MR. MAGKUDEK’S SECOND SET OF DATA REQUESTS DOCKET NO. L-OOOOOC-11-0400-00164 NOVEMBER 30,2011

Magruder 2-13. Unexploded Ordinance. Portions of the proposed 138 kV line go through the USAF bombing range. (a) What surveys have been completed by TEP to determine if there is unexploded ordinance along the proposed ROW s? (b) For an approved ROW, wit1 surveys for unexploded ordinance be conducted? If so, please describe. (c) What will the process Rosemont Copper will follow when unexploded ordinance is found? RESPONSE: (a) EPG conducted cultural surveys along the proposed routes and as part of their research identified that, during World War 11, Sahuarita was home to a bombing and gunnery range used to train Army Air Force aircrews. During their field survey, EPG personnel looked for signs of past activity, and a WWII-era aerial practice bomb was recorded. No additional indications of ordinance were located. (b) Surveys may be conducted but only to the extent TEP determines there are any concerns when engineers do field review. TEP will take all necessary safety precautions. (c) TEP is unable to answer on behalf of Rosemont. RESPONDENT: Ed Beck WITNESS: Ed Beck

Arizona Corporation Commission (“Commission”) Tucson Electric Power Company (“TEP”) Certificate of Environmental Compatibility (“CEC”) Western Electricity Coordinating Council (“WECC’) North American Electric Reliability Corporation (“NERC”) Rosemont Copper Company (“Rosemont”) ROSEMONT COPPER COMPANY DOCKET NO. L-OOOOOC-11-0400-00164 RESPONSE TO MAGRUDER’S SECOND SET OF DATA REQUESTS

December 9,20 11

Response provided by: Patrick Black

Title: Outside Counsel for Rosemont Copper Company

Company Name: Rosemont Copper Company

Company Response Number: Magruder -2.1

Q. Follow-ups on the First Data Reauest Set Responses.

2.1 .a Your response to Data Request 1-2 stated: “Outage events that originate at the Rosemont Substation will only impact Rosemont.” This is not 100% possible unless Rosemont has some secret capability unknown to the entire electricity industry. Thus, what is the estimated probability of the an outage failure at the Rosemont mine end of this transmission line based on specific and objective measure, such as MTBF, for the equipment being designed into the Rosemont Copper substation.

OBJECTION: This data request calls for information that is irrelevant and not calculated to lead to the discovery of admissible evidence.

2.1.b How is the company going to ensure their transmission system meets the NERC Reliability Criteria?

OBJECTION: This data request calls for information that is irrelevant and not calculated to lead to the discovery of admissible evidence.

2.l.c Your response to DR 1-2 indicated design substation detail is proprietary. What is the basis for this, in particular, the arrangements of protective devices, circuit breakers, and other such devices are essential necessary information to assure the public and regulators that this substation will not cause the Western Grid to fail. For example, will you share these details with WECC or NERC if requested?

OBJECTION: This data request calls for information that is irrelevant and not calculated to lead to the discovery of admissible evidence. Without waiving this objection, the internal design and operation of an industrial complex is considered proprietary because of security concerns and is not subject to the public’s scrutiny. The information necessary to assure compliance with utility performance and safety

2513853.1 1 requirements is provided on a confidential basis to the utilities, agencies and entities responsible for assuring compliance. As a general practice information regarding a retail customer’s owned substation is shared with the utility it interconnects with but seldom is information required by WECC or NERC. Rosemont will supply such organizations the information required to establish and assure on-going compliance.

2.1 .d Could you please clarifjl your response to DR 1-4 that the Rosemont Substation not start construction until after the Corporation Commission has approved a CEC? OBJECTION: This data request calls for information that is irrelevant and not calculated to lead to the discovery of admissible evidence.

2.1 .e What is the company’s estimated time in months from start to operational completion the substation?

OBJECTION: This data request calls for information that is irrelevant and not calculated to lead to the discovery of admissible evidence.

2.1 .f Your response to DR 1-5 seems to imply that the Line Siting Committee does not grant easements (rights-of-way) or similar interests in real property. Do you agree that the authority of a utility with an approved CEC has eminent domain for the specified property descriptions in an approved CEC?

OBJECTION: This data request calls for a legal conclusion. Without waiving this objection, Rosemont is in generally agreement with this statement.

2.1.e Do you agree that when a CEC grants a 100-foot Right of Way (ROW), within a 500-foot wide corridor, that the holder of that CEC can use eminent domain within any a continuous 100-feet width ROW (easement) and that this entire ROW shall be within the specified corridor in the CEC?

OBJECTION: This data request calls for a legal conclusion. Without waiving this objection, Rosemont is in generally agreement with this statement.

2.1.f Do you agree that the CEC line siting process, in general, applies to all land in the State of Arizona other than federal land? If not, please provide the basis of the disagreement?

OBJECTION This data request calls for a legal conclusion. Without waiving this objection, Rosemont is in generally agreement with this statement.

2.1.g Do you agree that the NEPA process, as in this case, applies only to federal land? If not, please provide the basis of the disagreement?

OBJECTION: This data request calls for a legal conclusion. Without waiving this objection, Rosemont does generally agree with this statement.

2513853.1 2 2.1.i Based on your response to 1Sa, can you cite any “mining” laws that specify that siting of transmission lines are not to be considered according to the ongoing NEPA or CEC processes in this case?

OBJECTION: This data request calls for a legal conclusion.

2.1 .j In your response to DR 1Sc, please explain or expand the last sentence, as worded it appears to be self-contradictory.

OBJECTION: This data request calls for a legal conclusion. Without waiving the objection, Rosemont does not agree that its response to DR 1.5~is self-contradictory.

2.1.k Your response to DR 1-6 appears to have missed the aim of this DR, specifically, by moving the fence to outside the transmission line, then the water line construction road (also to construct the transmission line) could be returned to a more natural setting and short perpendicular spurs to each utility pole would suffice to meet maintenance needs. With both water and power lines between the road and fence, both would be more easily accessible from Santa Rita Road and that a separate road, just for the occasional maintenance and surveillance needs, would not be necessary. With approximately 700- feet between poles and a 100-foot wide ROW,then much less “road” will be needed. IF a problem occurred with the water line, it would easily be accessible, no fences (and avoid long transits on the maintenance road) would need to be cut and with direct access from Santa Rita road available. Do you agree with these benefits Rosemont with less road maintenance, easier access, and less environmental impacts than one long-dusty road, rarely used with limited access?

RESPONSE: Rosemont does not either agree or disagree with the statement in the last sentence.

2.1.1 The high-voltage transmission line to pipeline impedance issue is not in the NESC. The Commission used the Canadian Natural Gas Association Technical Pub 105 previously; however, it only determines safe separation distance from the effects of natural gas flames in melting a transmission line. Several years ago, the National Academy of Science and Federal Office of Pipeline Safety worked this issue based on discussions I had with the Chairwoman of the FOPS. Please provide a better reference or a document where to determine the safe distance, based on induced electricity fiom a transmission line through the soil, for one touching the ferromagnetic water pipe.

RESPONSE: Rosemont does not possess any documents responsive to this request.

2.1.m Please provide an estimated cost for undergrounding the 138 kV line compared to an above ground line along the Preferred Alternative, and if there are significant cost differences for segments, please indicate. Ratios in the response are fine.

RESPONSE: Rosemont does not possess any information responsive to this request.

2513853.1 3 2.1 .n Your response to DR 1-8 was not clear. Will there be or rows of utility poles along Santa Rita Road? If there are two (assumed one distribution, one transmission?), was there consideration to combine both on the same pole? Will this solution involve both utility companies (TRICO and TEP)?

RESPONSE: Please see TEP Response to Magruder DR 1.8a.

2. I .o Your response to DR 1-9 implied that mining substations are not required to have a county substation permit. What organization then is responsible for the public good to ensure that “mining” substations are installed and operated properly to comply with federal, state and county laws involving the electrical system in this country? And if the company is not in compliance, what penalties may be considered or imposed?

OBJECTION: This data request calls for information that is irrelevant and not calculated to lead to the discovery of admissible evidence.

2.1 *p Your response to DF -1-10 implied that the DEIS and MOP had different electric demands. Will your company have this correct in the fdEIS? RESPONSE: Yes 2.1.q How was the 20-year life of this mine been chosen?

OBJECTION: This data request calls for information that is irrelevant and not calculated to lead to the discovery of admissible evidence.

2.1.1- What is the company’s estimated life of that the ore deposits in the Rosemont Mountains will be mined or has,

OBJECTION: This data request calls for information that is irrelevant and not calculated to lead to the discovery of admissible evidence.

2.1s Your response to DR 1-14 indicates that the company has a right to request electric power. Did your company request natural gas service, and if so, what was the response?

OBJECTION: This data request calls for information that is irrelevant and not calculated to lead to the discovery of admissible evidence.

2.1.t Your response to DR 1-15 implied that your company would not use environment management or energy efficiency processes, such as in the two ISOs referenced. What are your company’s plans and policies for environmental management and energy efficiency? Please provide a copy of these policies.

OBJECTION: This data request calls for information that is irrelevant and not calculated to lead to the discovery of admissible evidence.

2513853.1 4 0 ROSEMONT COPPER COMPANY DOCKET NO. L-OOOOOC-11-0400-00164 RESPONSE TO MAGRUDER’S FIRST SET OF DATA REQUESTS

December 9,201 1

Response provided by: Kathy Arnold

Title: VP Environmental and Regulatory Affairs

Company Name: Rosemont Copper Company

Company Response Number: Magruder -2.2

Q. Reliability.

2.2.a Will Rosemont Copper implementation of NERC standards, in particular, the critical infrastructure standards (CIPs) for this project? If so, please explain how these reliability standards will be met by the company, including in the design, build, operate and maintenance phases of operations. 2.2.b Does Rosemont Copper intend to use intelligence electronic devices (IEDs) in the design of the Rosemont Copper substation? If not, what will be used and if so, will IEDs be used to increase reliability? 2.2.c Will Rosemont Copper implement IEC 61850 at the Rosemont switchyard? If not, is there a hture plan to implement IEC 61850 and if so, does Rosemont intend to implement Edition 1 or Edition 2 IES 61850? 2.2.d Will the resultant SCADA system for this transmission line be interoperable with TEP?

OBJECTION [2.2.a,2.2.b,2.2.~,2.2,dj:

These data requests call for information that is irrelevant and not calculated to lead to the discovery of admissible evidence in this transmission line case.

2513853.1 5 ROSEMONT COPPER COMPANY DOCKET NO. L-OOOOOC-11-0400-00164 RESPONSE TO MAGRUDER’S FIRST SET OF DATA REQUESTS

December 9,201 1

Response provided by: Patrick Black

Title: Outside Counsel for Rosemont Copper Company

Company Name: Rosemont Copper Company

Company Response Number: Magruder -2.3

Q. Rosemont Copper Substation. The following pertain only to the Rosemont Copper Substation.

2.3.a Please describe existing plans of the state, local government and private entities for other . developments at or in the vicinity of the proposed substation site. 2.3.b Please describe any fish, wildlife and plant life and associated forms of life upon which they are dependent. 2.3.c Please provide the noise emission levels and interference with communication signals from the substation including the noise level in DBA at the prouert~line when all of the equipment, including pumps, are operating. 2.3.d Please describe any proposed availability of the substation site to the public for recreational purposes, consistent with safety considerations and regulations. 2.3.e Please describe the existing scenic areas, historic sites and structures or archaeological sites at or in the vicinity of the proposed substation site. 2.3.f Please describe the total environment of the area near the substation. 2.3.g Please describe the technical practicability of achieving a proposed objective and the previous experience with equipment and methods available for achieving a proposed objective. 2.3.h Please provide the estimated cost of all the substation facilities and site as proposed by the applicant and the estimated cost of alternative facilities and sites. 2.3.i Please provide a site drawing or layout of how this substation, walls, fences, screening 0 and setbacks will be placed on this site, including the location of the Rosemont water pumping equipment and pipeline(s). 2.3.j Please show in the site drawing in 2.4.j, and state if the setbacks, screening, and heights meet the requirements of Pima County Zoning Ordinance Section 18.07,040(A)5(a), (b) and (c). 2.3.k Please describe the substation notification process used to comply with Pima County Zoning Ordinance Section 18.07.040(A)5(d).

2513853.1 6 OBJECTION I2.3.a through 2.3.k pertaining to Rosemont Substation]:

These data requests call for information that is irrelevant and not calculated to lead to the discovery of admissible evidence in a transmission line case.

25 13853.1 7 xmar uocumenr nnp.//www.azieg.gov/rormaruocumenr.asp1inuoc=/ar~/431uu I3 I .nrm& I111e=43&uoc I - Arizona State Legislature Bill Number Seer&

Fimeth Leglalabre RrnRegd ar Session mange session printer hendly version Email a Member I Email Webmaster Senate House Legislative Council JLBC More Agencies Bills Committees CalendardNews

-15-151. Relative value of uses A. As be ween wo or more pending conflicting applications for the use of water from a iven water supply when the ca :city oftthe supply is not sufficient for all applications, preference shall be given% the director aciording to the regtive values to the ublic of the proposed use. 8. The relative values to &e public for the purposes of this section shall be: 1. Domestic and municipal uses. Domestic uses shall include gardens not exceeding one-half acre to each family. 2. Irrigation and stock watering. 3. Power and mining uses. 4. Recreation and wildlife including fish 5. Nonrecoverable water ktorage pursuant to section 45-833.01.

nf 1 17/1’ll~17.77 AI EXHIBIT

Marshall Magruder PO Box 1267 [Gj Tubac, Arizona 85646 6 December 2011

DOCKET Number: L-OOOOOC-11-0400-00164,Case No. 164.

To: John Foreman Chairman of the Arizona Power Plant and Transmission Line Siting Committee 1275 West Washington Street Phoenix, Arizona 85007

Arizona Corporation Commission Docket Control (Original and 25 copies) 1200 West Washington Street Phoenix, Arizona 85007

INITIAL PROPOSED CERTIFICATION OF ENVIRONMENTAL COMPATIBILITY AND CONDITIONS bY Marshall Magruder

References: (a) Committee Chairman’s Procedural Order of 10 November 2011 0 (b) TEP Proposed Form of Certification of Environmental Compatibility (CEC) of 2 December 2011

Summary. This is the Marshall Magruder response to ref (a), paragraphs 11 and 12. In general, the TEP proposed Form, Conditions, and Exhibits for the CEC in this case are satisfactory with the exceptions indicated below. Further, additional recommended changes to the CEC may result as additional information becomes available and the forthcoming proceedings.

1. Exceptions to the CEC Form Proposed bv TEP. a. Page 2, lines 1to 7. Add, for each appointed member, who they represent as: “Jeff McGuire Appointed member, represents agricultural interests” “Patricia Noland Appointed member, represents the general public” “Michael Palmer Appointed member, represents the general public” “David Richins Appointed member, represents incorporated cities and towns” “F. Ann Rodriquez Appointed member, represents counties” “Pa uI W a Ike r Appointed member, represents the general public” b. Page 3, line 8. Before “Santa Rita” add “University of Arizona” c. Page 4, line 3. Before the first “Arizona” add, U.S. Army Corps of Engineers,” since a section 404 permit is required.

0 Marshall Magruder Initial Proposed CEC and Conditions 6 December 2011 d. Page 4, line 5. Before “all” &i “applicable dark sky ordinances and standards,”, and renumber the following 3.4 and 3.5 to “3.5” and “3.6”. It is noted, this only if for this project, not the Rosemont Copper mine. e. Page 4, line 22. &i new sentence to read “All road constructed will be revegetated with native plant species that were removed outside of an authorized right-of-way. Further, clear cut vegetation management should not be used whenever less intrusive processes are allowable.” [Reference Case No. 1441 f. Page 4, line 24. Change “ten (10) years” to read “five (5) years if construction for this project has not started” because a Final EIS for the federal lands involved is only valid for five years, without a subsequent review and public participation. A Supplemental EIS may then be required. €5 Page 4, lines 25 to 27. Delete the last sentence because such an Application can be submitted to the Commission, and an extension or unlimited time maybe authorized without any public or Committee involvement. At present, there are dozens of “unlimited” or open-end CECs in existence, some nearly 40-years old, and obviously not current due to changes in the factors in A.R.S. 5 40-360 et seq. Construction of any such project may have serious unintended consequences decades after careful deliberations by the Committee and reviews by the Commission. An “open-ended“ CEC continuously and negatively impacts the real estate market. This is a general policy change that should be discussed, if for other no reason, then to use the same time period as a connected- NEPA action. [Reference Case No. 111 and many others] h. Page 6, line 8. Add new sentence, “The Applicant shall chose utility pole equipment that is designed to discourage raptors use within one (1)mile and inside the SRER.” This is to reduce the impacts of raptors on the 100-years of studies that involve environmental changes.

2. Exceptions to the CEC CONDITIONS Proposed bv TEP. CONDITION 3. Page 4, line 5. Before “all” &i “applicable dark sky ordinances and standards,”, and renumber the following 3.4 and 3.5 to “3.5” and “3.6”. It is noted, this only if for this project, not the Rosemont Copper mine.

CONDITION 6. Page 4, line 22. &i new sentence to read “All road constructed will be revegetated with native plant species that were removed outside of an authorized right-of-way. Further, clear cut vegetation management should not be used whenever less intrusive processes are allowable.” [Reference Case No. 1441

CONDITION 7. (1)Page 4, line 24. Change “ten (10) years” to read “five (5) years if construction for this project has not started” because a Final EIS for the federal lands involved is only valid for five years, without a subsequent review and public participation. A Supplemental EIS may then be required.

Marshall Magruder Initial Proposed CEC and Conditions 6 December 2011 (2) Page 4, lines 25 to 27. Delete the last sentence because such an Application can be submitted to the Commission, and an extension or unlimited time maybe authorized without any public or Committee involvement. At present, there are dozens of “unlimited” and open-ended CECs in existence, some nearly 40-years old, and obviously not current due to changes in the factors in A.R.S. 5 40-360 et seq and construction of any such project may have serious unintended consequences decades after careful deliberations by the Committee and reviews by the Commission. An “open-ended” CEC continuously and negatively impacts the real estate market. This is a general policy change that should be discussed, if for other no reason, then to have the same time period as a NEPA action. [Reference Case No. 111 and many others]

CONDITION 11. Page 6, line 8. Add new sentence, “The Applicant shall chose utility pole equipment that is designed to discourage raptors use within one (1)mile and inside the SRER.” This is to reduce the impacts of raptors on the 100-years of studies that involve environmental changes.

CONDITION 12. (1) Page 6, line 9. After “dull” add “gray or corten” to include both common pole finishes used by TEP. (2) Page 6, line 10. Add, new sentence, “The pole finish will be chosen to reduce the pole’s visual impacts based on the dulled-gray or corten finish that has the least contrast with the background. For utility poles within 3 miles of residential homes, community involvement is to be undertaken in order to resolve the community’s interest in the finish color; however, such involvement will not change the approved corridor without revising the CEC. For poles on federal lands, the federal land manager shall be requested to determine which pole finish to be used with the default being corten.”

CONDITION 13. Page 16, line 11. After “Management” add “, Army Corps of Engineers”

CONDITION 18. (1) Page 7, line 23. Delete “or” and insert a comma. (2) Page 7, line 23. Change “liquid pipeline” to “and ferromagnetic water pipelines, and fences”. The resultant study in (b) will access the effects of induced electricity and its human safety. Both water pipes and fences can transmit electricity induced from a transmission line. (3) Page 8, lines 1and 2. Change from “both” to “material” to “the Project is operational. If safety or “. It does not matter if a pipeline or fence is “operational” for it to carry electrical currents. Safety is a major concern and should be stated. (4) Page 8, line 3. Change “such” to “all human safety and” as this is one reason to accomplish this study. (5) Page 8, lines 6 to 10. Change to “(b) Perform a technical study to determine the amount of electrical current that can flow from the sited transmission lines to all pipes and fences in the

Marshall Magruder Initial Proposed CEC and Conditions 6 December 2011 Page 3 Y

approved utility corridor. This is to determine the amount of electricity induced will not harm humans or cause adverse effects on natural gas or petroleum products or how to mitigate the harm from effects. This study shall provide technical information that confirms that electrical current will not be transmitted from these transmission lines to all known pipes and metal fences within the corridor for this project at levels that will be hazardous to humans or to fence and pipe systems that cross or are in this corridor.” The present wording does not make sense. [Case No. 1111

CONDITION 21 Page 8, line 1. Change “granting” to “approving”. The Committee “grants” the Commission reviews and approves.

CONDITION 25. Page 9, line 20. Change “will” to “shall” to ensure this requirement is met.

CONDITION 26. (1) Page 9, line 26. Change “will” to “shall” to ensure this requirement is met. (2) Page 10, line 3. Add new sentence, “The Applicant shall provide a report within thirty (30) days after the ROD has been noticed in the Federal Register to the Commission Utilities Division Director and to this Docket to include all the required actions by the ROD. The Applicant will provide a plan and schedules for accomplishments. If there are any costs for the TEP ratepayers to carry out these actions, the Application shall include that and the estimated costs, in this report. If any of these actions are contrary to this CEC, the Applicant shall include that in this report. Depending upon the Utility Director’s review of this report, updates could be requested.”

RESPECTFULLY SUBMIITED on this 6thday of December 2011. n

LB4h\ LB4h\ Marshall Magruder PO Box 1267 Tubac, Arizona, 85646

Original and 25 copies mailed torno rrow to the Arizona Corporation Commission (Docket Control); 1copy to the Chairman of the Arizona Power Plant and Transmission Line Siting Committee And by electronically emailed to the Case No. 164 Master Distribution List this date.

Marshall Magruder Initial Proposed CEC and Conditions 6 December 2011 United States Department of the Interior National Park Service National Register of Historic Places Registration Form This form is for use in nominating or requesting determinationsfor individual properties and districts. See instructions in National Register Bulletin, How to Complete the National Register of Historic Places Registration form. If any item does not apply to the property being documented, enter "N/A for "not applicable." For functions, architectural classification, materials, and areas of significance, enter only categories and subcategories from the instructions. Place additional certification comments, entries, and narrative items on continuation sheets if needed (NPS Form 10-900a).

1. Name of Property Historic name Ce:wi Duag ("Long Mountain" in O'odham) Traditional Cultural Property Other nameskite number Santa Rita Mountains; Dzilenzho ("Beautiful Mountain" in Western Apache) - street & number Coronado National Forest, Nogales Ranger District - not for publication city or town Tucson (30 miles NW); Green Valley (20 miles W); Sonoita (e2 miles E) I Ivicinity state Arizona Code AZ county Pima code 019 zip code 85641 3. State/Federal Agency Certification

~ ____ ~~ 4s the designated authority under the National Historic Preservation Act, as amended, I hereby certify that this -nomination request for determination of eligibility meets the documentation standards for registering properties in the National Register of Historic Places and meets the procedural and professional requirements set forth in 36 CFR Part 60. In my opinion, the property meets -does not meet the National Register Criteria. I recommend that this property be considered significant at the following level(s) of significance: -national -statewide -x local

Signature of certifying officialKitle Date Coronado National Forest State or Federal agency/bureauor Tribal Government

In my opinion, the property - meets -does not meet the National Register criteria.

Signature of commenting official Date

Title State or Federal agencybureau or Tribal Government

1 Exhibit 0-1 4. National Park Service Certification I hereby certify that this property is:

-entered in the National Register - determined eligible for the National Register

-determined not eligible for the National Register -removed from the National Register

-other (explain:)

Signature of the Keeper Date of Action

5. Classification

Ownership of Property Category of Property Number of Resources within Property (Check as many boxes as apply.) (Check only one box.) (Do not include previously listed resourms in the count.)

Contributing Noncontributing Private building(s) buildings public - Local district sites public - State site structures structure 1 objects 1 Total

Name of related multiple property listing Number of contributing resources previously (Enter "N/A if property is not part of a multiple property listing) listed in the National Register

NIA %Kentucky Camp Historic District

6. Function or Use Historic Functions Current Functions (Enter categories from instructions.) (Enter categories from instructions.) DOMESTIC: camp, village site RELIGION: ceremonial sife COMMERCE: trade [archaeology) AG R ICU LTURElS U BS I STEN CE : processing RELIGION: ceremonial sife LANDSCAPE: natural features (mountain peaks, springs, drainages) RECREATION AND CULTURE: outdoor FUNERARY: graves and burials recreation AG RICULTURElSUBS ISTENCE: processing, EDUCATION: reseadh facility storage, agricultural field INDUSTRY/PROCESSING/EXTRACTION: processing site [stone, clay, minerals) LANDSCAPE: natural features (mountain peaks, springs, drainages)

2 Exhibit 0-1 0 DEFENSE: refuge

7. Description Architectural Classification Materials (Enter categories from instructions.) (Enter categories from instructions.) NIA foundation: walls:

roof: other:

Narrative Description

Summary Paragraph Ce:wi Duag (Long Mountain) and the uplands on either side of the ridgeline of the Santa Rita Mountains are a traditional cultural property (TCP) of the Tohono O’odham, constituting both a landscape imbued with cultural significance, a location of sacred sites, ancestral villages and ancestral remains, and a source of plant, animal, and mineral resources used to maintain the traditional O’odham culture. Archaeological investigations have documented occupation of the area beginning ca. 7,000 years ago (Huckell 1984a), with sites dating to the following archaeological periods: Archaic, Formative (including Hohokam), and Protohistoric, the latter with Sobaipuri Oodham and probable Apache occupations. In the Historic period and through the present day, O’odham and Apache peoples have used the area as a source of resources, a refuge, a locus of sacred sites, and a place to pursue personal vision quests. The TCP lies within the area that in 1976 was adjudicated as being ancestral lands of what was at that time known as the Papago Tribe, now known as the Tohono O’odham Nation (Nation). The TCP boundary follows the 4,500 foot elevation level,which demarcates uplands from the bajada on the west side of the range and are primarily managed by the Coronado National Forest (Forest) (Maps 1 and 2). The Nation and the Forest recognize that the Santa Rita Mountains are also important to other Native American tribes (Hopi, Zuni, Western Apache, and Chiricahua Apache) and to the Hispanic and local ranching communities.

Location and Setting: Ce:wi Duag (Long Mountain), now known as the Santa Rita Mountains, is a northeast-southwest-trending mountain range that forms the eastern side of the Santa Cruz River valley, south of Tucson, Arizona. The ridgeline also marks the western border of the “sky island grasslands,” which are bounded on the east by the Whetstone and Huachuca mountains; these mountains form the western boundary of the other major river system in central southern Arizona, the San Pedro River. This elevated area between the two major rivers provides an upland environment that is distinct from the Lower Sonoran Life Zone found below elevations of 4,500 feet in the Santa Cruz River valley and the desert areas to the west where most of the Tohono O’odham population lives today (see Map 1 for the location of the Nation’s San Xavier District). The principal Tohono O’odham reservation is ca. 20 miles west of the San Xavier District, and the Nation’s capital at Sells is an additional 20 miles west). The Lower Sonoran Life Zone is characterized by the Sonoran Desertscrub vegetation, while the TCP contains Semidesert Grassland and Madrean Evergreen Woodland biotic zones (Map 3) (Brown and Lowe 2008).

The TCP boundary roughly follows the 4,500-foot elevation contour that generally demarcates the lower elevation of the Upper Sonoran Life Zone (4,500-6,500 feet above mean sea level [amsl]) and the division between the bajada and the mountain on the west side of the range. The east side of the Santa Ritas slopes more gradually and contains a greater expanse of this Upper Sonoran Life Zone as rolling hills, grasslands, and watered valleys. Within this zone, the flora and fauna specific to the Madrean Woodland includes many species of particular importance to the O’odham: Emory oak, alligator juniper, Mexican pifion pine, mountain mahogany, walnut, sumac, Palmer and Parry agave, purple prickly pear, coralbean, tepary beans, other shrubs and grasses, white-tailed deer, and cottontail rabbits. Narrow strips of riparian plant communities border the major creeks within the TCP and contain Arizona sycamore, Freemont cottonwood, neatleaf 3 Exhibit 0-1 hackberry, velvet ash, wild grapes, and elderberry (Brown 1994; Brown and Lowe 2008; Griset 201 la). Yet higher, on the peaks of the Santa Rita ridgeline, is the Transition Zone (6,500-8,000 feet amsl), which contains Gambel oak, smooth sumac, maple trees, and until recently, bighorn sheep (Ayres 1984; Brown 1994; Friends of Madera Canyon 201 1). The plant resources of the Santa Rita Mountains are of traditional and continuing importance to the O’odham people in part because they are relatively rare on the Nation’s reservation lands and the other O’odham tribes (Ak Chin Indian Community, Gila River Indian Community, and Salt River Pima Maricopa Indian Community). These upland resources were an important component of the traditional territory of the O’odham, but were largely excluded when reservations were created in locations dominated by the Sonoran Desert.

Physical Description: The Santa Rita Mountains are situated along the western edge of the Mexican Highlands Subprovince of the Southern Basin and Range physiographic province. The Basin and Range Province was formed by tectonic activity 75 to 55 million years ago, with subsequent volcanism and high-angle faulting ca. 25 million to 16 million years ago. After the last tectonic activity 5 million years ago, the area continued to be shaped by deposition, erosion, and limited fault activity up to the present. Granitic stocks and plugs are partly overlain by marine and nonmarine sedimentary rocks, volcanic rocks, and basin-fill deposits. The ridgeline ranges from 3,450 to 9,453 feet above sea level, is ca. 28 miles long, and has four natural passes between the Santa Cruz River Basin on the west and the Cienega Basin to the east. The TCP boundary encompasses Mt. Fagan at the north end of the range (6,189 feet amsl), trending southwest to the highest peak, Mt. Wrightson at 9,456 feet amsl, and to an unnamed peak ca. 5,000 feet amsl at the south end of the range just outside the Forest boundary (see Map 1). Other notable landforms include Elephant Head (5,607feet amsl), a granitic prominence that projects westward from the ridgeline (see protrusion at far right of Ce:wi Duag profile in Photos 1 and 2d). Creeks are intermittent and formed by water from springs, seeps, and torrential summer monsoons. Major creeks on the east side of the ridge flow northeastward into Davidson Canyon Creek, which empties into Pantano Wash, the Rillito River, and ultimately into the Santa Cruz River in the far northwestern Tucson Basin. Streams on the south side of the range flow into Sonoita Creek, a major tributary of the Santa Cruz River, and water on the west side of the ridge flows through narrow canyons directly into the Santa Cruz River. In addition, the upland area contains the greatest concentration of springs compared to the lowlands and these are considered sacred in and of themselves, and they are often the location of mineral deposits used for ceremonies (Map 4; Griset 201 1a).

The TCP boundary encompasses 141,572 of the 148,448 acres in the Santa Rita unit of the Forest’s Nogales Ranger District. Private inholdings within the TCP boundary constitute 11,391 acres that are excluded from the proposed district; therefore, the total acreage of the TCP is 130,181, all administered by the Forest.

Significant Features: Facing southeast from the contemporary O’odham community of San Xavier del Bac (or Wa:k), the landform that dominates the terrain is that of Ce:wi Duag, Long Mountain (Photo 2). Although individual mountain peaks are also important to the O’odham, e.g., Baboquiviri Peak south of Sells in the main portion of the Nation, for the San Xavier District, Ce:wi Duag dominates the landscape and frames each and every day with its distinctive profile. That profile changes as one moves from the north to the south, and it may have had other names for the Sobaipuri Oodham who lived along the Santa Cruz River prior to the incursion of the Spanish in the seventeenth and eighteenth centuries. Those villages were abandoned in the eighteenth century due to Spanish pressure to relocate to the missions, the threat and reality of Apache raiding, and/or the occupation of traditional lands by Hispanic people. Wa:k was the only original Oodham village remaining in the Santa Cruz River valley by 1900. The distinctive outline of Ce:wi Duag represents many different levels of meaning for the O’odham. The high elevations trap the rain that feeds the rivers of this desert land and provide viewpoints that were/are used for personal vision quests (Steere 2009). The mountains contain sacred springs and natural resources that are not available in the lowlands yet are integral to O’odham traditional way of life. Equally important are the remnants of villages and human remains of O’odham ancestors. Baboquiviri Peak, a sacred peak and home of Elder Brother on the Nation, can be seen from the heights of Ce:wi Duag (Photo 3).

Historic Appearance: The overall appearance of Ce:wi Duag and its physical integrity as a place of traditional and cultural importance are little changed from pre-European contact times. In contrast, the appearance of the mountains on the west side of the Santa Cruz River valley has been drastically altered by the excavation of large open-pit mines and deposition of extensive waste rock and tailings materials. The mining activities that began in the 1870s in the Santa Rita Mountains were relatively small-scale, including placer mining for silver and gold, small hard-rock exploratory pits and tunnels. The most intensive operations were the late nineteenth-early twentieth century copper mines and smelters at Rosemont and Helvetia (Photos 3 and 4; Photo 3 is a similar view today). Both of these smelters were in operation less than 10 years. Comparatively small waste rock piles are visible at the entrances to shafts. Depletion of wood for fuel for smelters and the 4 Exhibit 0-1 influx of miners and ranchers, as well as the overgrazing caused by cattle in the nineteenth century allowed mesquite and juniper to invade denuded areas that likely contained greater densities of oak in the past. Non-native grasses have also invaded the area. Dirt roads were created to transport supplies to the mining towns and ranches. Many of these roads likely followed trails that had been used for centuries by Native American people. In the early 1930s, the Civilian Conservation Corps built small check dams to control water within the Forest, as well as bridges and culverts along the major dirt roads. All of the mining towns have since disappeared; structural foundations, waste-rock deposits, slag heaps, and trash scatters remain as markers of their locations.

Current Condition: The Forest assumed management of much of the land on and around Ce:wi Duag in 1902 with the establishment of the Santa Rita Forest Reserve. Improved management of livestock grazing reduced the pervasive overgrazing of the late nineteenth century; however, increasing amounts of brushy vegetation, especially mesquite, and non-native grasses have continued to occur. A number of cattle ranches established in the late nineteenth-early twentieth century around the perimeter of the mountains continue to operate with livestock grazing occurring throughout the uplands. No paved road crosses the Santa Rita ridgeline. Dirt roads remain the primary means of travel through the TCP. Mining shafts and tailings are scattered on the upper slopes-the largest are remnants from hardrock mining that was particularly active between 1885 and 1920, and vegetation has obscured some of the former scarification. The Whipple Observatory was constructed in the 1960s on Mt. Hopkins, the second highest peak in the Santa Rita Mountains. The observatory and its access road are among the most visible modern developments on the mountains.

New impacts have been caused by the influx of off-road vehicles and the hundreds of hunters who flock to the area during hunting seasons. The Arizona Trail, an improved hiking trail, crosses the eastern border of the TCP and attracts additional hikerskampers.

In spite of these changes, the profile of Ce:wi Duag remains as it has from the earliest occupations, as do many of the critical locations and resources. The TCP meets the standard of integrity of relationship with the Tohono O'odham, particularly those living at the San Xavier District.

8. Statement of Significance Applicable National Register Criteria Owned by a religious institution or used for religious (Mark "x" in one or more boxes for the criteria qualifying the property purposes. for National Register listing.) B removed from its original location. A Property is associated with events that have made a significant contribution to the broad patterns of our history. C a birthplace or grave. -B Property is associated with the lives of persons D acemetery. LI significant in our past. H E a reconstructed building, object, or structure. C Property embodies the distinctive characteristics c] of a type, period, or method of construction or F a commemorative property. of rewesents the work a master. or Dossesses hiahI ariistic values, or represents a significant G less than 50 years old or achieving significance and distinguishable entity whose components lack within the past 50 years. individual distinction. D Property has yielded, or is likely to yield, information important in prehistory or history. .'

Criteria Considerations (Mark "x" in all the boxes that apply.) a Property is: A

5 Exhibit 0-1 Areas of Significance (Enter categories from instructions.) Archaeology: Prehistoric, Historic - Aboriginal Significant Person (Complete only if Criterion B is marked above.) Ethnic Heritage: Native American TCP: ongoing use

Cultural Affiliation O’odham Also: Apache, Hopi and Zuni Period of Significance

7,000 BP - present ArchitectlBuilder

Significant Dates

Period of Significance The O’odham view Ce:wi Duag as having always been part of their culture, from time immemorial. They make no artificial distinctions such as are commonly made by archaeologists who identify different settlement patterns or tool assemblages as distinct “cultures” or “periods,” or by historians who name and divide time into periods of influence. The O’odham have always been here, they are part of the land, and the land is part of them (Joaquin 2008). They adapted as conditions changed, and as they continue to do today. Ce:wi Duag is a physical manifestation, a distinct place in their cosmology. For the O’odham living at Wa:k, now known as San Xavier del Bac, Ce:wi Duag is where the sun rises each day.

Statement of Significance Summary Paragraph Ce:wi Duag is a traditional cultural place that is important to maintaining the traditional worldview and life ways of the Tohono O’odham. It is recommended eligible for listing in the National Register under Criterion A for its association with the broad sweep of O’odharn history from the Archaic period more than 7,000 years ago to the present, and for its role in maintaining the cultural practices necessary to keep the culture vital. Its unaltered profile is part of the O’odham cultural landscape that daily affirms the O’odham worldview. It retains physical integrity as well as spiritual integrity. It is the location of ancestral villages, ancestral human remains, sacred sites, and critical natural resources. Ce:wi Duag is also recommended eligible under Criterion D as it has yielded important information about the distribution of Archaic sites in southern Arizona, and Hohokam villages in upland areas (an unanticipated discovery of archaeological investigations in the 1980s; see Ferg et al. 1984; Huckell 1984a, 1984b). The data from these archaeological investigations confirm the oral tradition of the O’odharn. The area is likely to yield additional information important in southern Arizona prehistory and history. A recent survey of the same area that was investigated in the 1980s revealed additional sites and new loci within previously recorded sites (Barr et al. 2010; Ezzo et al. 2010). Narrative Statement of Significance

Criteria A: Ethnic Heritage - Native AmericanflCP Aboriginal O’odharn occupied a large portion of southern Arizona and northern Sonora from the San Pedro River on the east to the Growler Mountains on the west; and from the Gila River and Phoenix Basin on the north, south to the Rio de la Concepcion in northern Sonora. The O’odharn believe they have always been here and charged with caring for this land:

...the land has always been us, and we have always been a part of this land. We are a part of this land. And that goes way back in our creation story of how we got here and how these lands are supposed to be taken care of; how this stewardship was awarded to the people living in these lands, to manage these lands the way they see fit (Joseph Joaquin, Tohono O’odham elder and NAGPRA Representative, 2008).

6 Exhibit 0-1 United States Department of the Interior National Park Service I National Register of Historic Places Registration Form NPS Form 10-900 OMB No. 1024-0018 (Expires 5/31/2012)

Ce:wi Duag, Tohono O’odham Traditional Cultural Property Pima County, Arizona Name of Property County and State Archaeological evidence from the excavations conducted during the ANAMAX-Rosemont project confirms occupation of the eastern slope for at least 7,000 years, with a particularly intense occupation between A.D. 850 and 1050. With the intrusion of the Spanish from the south and the Apache from the north in the eighteenth century, O’odham became concentrated in villages and missions along the Santa Cruz River, abandoning permanent settlements to the east along the San Pedro River and the sky islands. Although permanent residence in the Santa Ritas was abandoned, the mountains were routinely visited to collect the upland resources integral to daily Oodham life and to use the heights for personal quests. Historic-period O’odham followed a seasonal round that brought them to the uplands at different times throughout the year to collect sorrel greens and tubers from cattail and wild onions in February; agave hearts and cholla buds in ApriVMay; yucca flowers and hedgehog cactus in late May; sotol flowers/stalks/seeds in June; leaves of purslane, amaranth, lambsquarters, and careless weed after the rains begin in July, and on into August; acorns, elderberries, and prickly pear fruit in AugusVSeptember; madrone berries, walnuts, piiion nuts, and wild grape in September; tepary beans in October; and juniper, sumac, and buckthorn berries throughout the fall (Griset 201 1a:Table 4.2). Deer were and continue to be hunted in the fall; cottontails are hunted year round.

Agave and acorns were the two most important upland wild foods aboriginally and historically because they could be gathered in quantity, stored for later use, and used as an important item of barter with other tribes. Agave hearts were baked in large earth ovens near where they were collected, then mashedjdried, and transported for storage at the principal village. Acorns were gathered, transported, and then processed at the principal village. Although agricultural crops, especially corn, were grown throughout the Southwest as early as 2000 B.C., wild foods have always provided a substantial portion of the diet. The uplands also provided firewood. Ce:wi Duag was also the source of optimal stone and plant materials for making tools and baskets, as well as clays for making pots.

In the late nineteenth century, as the O’odham became more dependent on a cash economy, the uplands provided new ways of using traditional resources to generate cash or barter. O’odham family groups, likely from San Xavier District, traveled to mining camps in April and May, where they collected the local residual clays from mountain exposures and made water jars to be sold to the miners and shopkeepers at the camps. Residual clays produce porous clay bodies 0 ideally suited for water jars; in hot climates, as the water transpires through the jar wall and evaporates, it cools the water. One example is documented by a photograph (Photo 5) from Greaterville, a mining camp on the east side of the Santa Ritas (see Map 1). The photograph has two labels: 1) “A band of these Papagos come every year to make pottery a mile or so from the camp where the clay is suitable,” and 2) “Taken May 1896, Barcelo & Verdugo store. Papago Indians who come once a year to sell pottery. They have been dancing here for provisions, etc.” (Arizona Historical Society, Tucson, Mrs. Mary E. Anderson Collection). Similar examples are known from the mining towns of Bisbee, Tombstone, and Fairbank in the San Pedro River valley in the late nineteenth century (Griset 201 la). Sherds from Papago red water jars were also uncovered during archaeological excavations at Historic period sites near Old Rosemont (Ayres 1984), which is within the TCP. Elders interviewed at San Xavier in 201 1 continue to associate the Santa Ritas as the place to get good red clay for water jars (Griset 201 1b).

Unlike many Native American groups, the O’odham have maintained a strong basket-making industry to the present day which provides a significant source of income as well as the baskets needed for specific ceremonies, e.g., the Basket Dance, and nawait i’ita, the Rain Ceremony (Bahr et al. 1994:123). The Santa Ritas are a good source of beargrass for making traditional O’odham basketry as well as a source of other plants for medicinal and ceremonial purposes (Griset 201 1b).

With the creation of the Forest Reserve in 1902 and the erection of fences and no trespassing signs by ranchers beginning in the late nineteenth century, O’odham felt constrained against gathering resources in the mountains. Elders stated that they or their family members were driven off of federal land when they tried to collect materials (Griset 201 1b). With the issuance of Executive Order 13007 (1996) directing federal agencies to accommodate access to sacred sites

7 Exhibit 0-1 United States Department of the Interior National Park Service / National Register of Historic Places Registration Form NPS Form 10-900 OMB No. 1024-0018 (Expires 5/31/2012)

Ce:wi Duag, Tohono Oodham Traditional Cultural Property Pima County, Arizona Name of Property County and State and the Forest’s own policies (Farm Bill 2008, Public Law 110-234, Title Vlll: Cultural Heritage and Cooperation Authority), the Forest’s official position is to facilitate access for tribal groups for traditional and cultural purposes, and for gathering forest products for traditional and cultural purposes.

Documentation of the use of the heights by individuals for spiritual quests is less concrete, as is often the case with sacred rites and sites. It is documented that the Santa Ritas are viewed by the O’odham as a place of refuge, as when they safely fled the Santa Cruz River valley after revolting against the Spanish in 1751 (Garate 1999:19).

Criteria D: Archaeology - Prehistoric//fistoric/Aboriginal Archaeological evidence gathered during 1980s excavations conducted for the proposed ANAMAX copper mine on the east slope of the Santa Ritas resulted in data that changed the perception of the Hohokam occupation of central southern Arizona (Ferg et al. 1984). Prior to those excavations, the Hohokam were depicted as an agricultural culture located in broad river valleys that allowed irrigation of crops and consolidation of populations into large villages; upland areas were seen as loci of resources that were procured seasonally and brought back to the valley villages. The eastern slope of the Santa Ritas provided evidence of permanent villages along its creeks, spaced to take advantage of floodplain agriculture, with larger villages providing ceremonial centers, as evidenced by the presence of a ballcourt at one. Another site was interpreted as possibly representing a Mogollon-influenced residence, but the sample was too small to make any definitive statements. Archaic period settlement was documented, but no evidence of Paleoindian occupation was found, nor the Apache use of the area that was recorded in historic documents. Given the rich record discovered during the previous investigations and many sites yet uninvestigated, it is likely that this area has additional information to add to our documentation and understanding of southern Arizona prehistory. Recent resurvey of the ANAMAX area on the eastern slope discovered additional sites, including probable villages, as well as additional loci at sites investigated in the 1980s (Barr et al. 2010; Ezzo et al. 2010).

Developmental History/Additional Historic Context Information Human occupation of southern Arizona spans at least 12,000 years, from the time of Pleistocene biggame hunters to the present. Occupation was neither continuous nor homogeneous; periods of social conflict and environmental challenges caused population shifts and episodic abandonment of settled areas. At all times, peoples of diverse ethnic and social identities resided in southern Arizona. Although there is no direct evidence of occupation of Ce:wi Duag and scant evidence of occupation of the Tucson Basin or the Santa Cruz River valley during the Paleoindian period (9,5004,000 B.C.),mammoth-kill sites are reported from the San Pedro River valley ca. 40 miles to the east. And, Pleistocene faunal remains are reported from the adjacent Davidson Canyon area just east of the Ce:wi Duag boundary (Huckell 1980). Archaic or Preceramic period (8,000 B.C.-A.D. 200) hunter-gatherers left ephemeral traces of their use of the area in the form of resource procurement and processing sites and campsites-usually characterized by the presence of distinctive dart points. Recent evidence from the Tucson Basin has demonstrated that corn and pottery were introduced into southern Arizona much earlier than previously thought, as early as 2,100 B.C. (Diehl 2005), making this a transition between the Archaic hunting pattern and the broad regional agricultural cultures that are labeled by archaeologists as Hohokam within central and south central Arizona, and as Mogollon in southeastern Arizona east of the San Pedro River.

The densest Native American occupation of southern Arizona occurred during the Hohokam period (A.D. 200-1450), characterized by a profusion of regional decorated pottery styles beginning around A.D. 650. Populations moved from small pit house villages to larger population centers along the major drainages; these include residential compounds, ceremonial structures, and extensive irrigation systems. Ballcourts are found at the principal centers and are replaced after A.D. 800 by platform mounds that may indicate a new religious system that united most of central and southern Arizona. The only reported ballcourt site in the Santa Rita Mountains is in the Rosemont area. Ceramic assemblages from sites on the eastern side of Ce:wi Duag document influences from the Tucson Basin/Santa Cruz River valley Hohokam and from the Mogollon to the east and the Trincheras to the south.

Ca. A.D. 1400-1450, the Hohokam archaeological culture changes dramatically in southern Arizona. The large river valley settlements were abandoned, and a greatly reduced population settled once again in small villages or moved away. The cause or causes of this depopulation are unknown; speculation ranges from environmental degradation, major floods that destroyed the complex irrigation systems, and/or nutritional stress as the impetus. The Protohistoric period (A.D. 1450-1700) was a time of flux. Forays were made from the small valley villages to upland areas for localized resources. Ephemeral house sites are found atop older Hohokam villages in the uplands (Huckell1984b). By A.D. 1700, Apache

8 Exhibit 0-1 United States Department of the Interior National Park Service / National Register of Historic Places Registration Form NPS FOm 10-900 OMB NO. 1024-0018 (Expires 5/31 120 12)

Ce:wi Duag, Tohono Oodham Traditional Cultural Property Pima County, Arizona e Name of Property County and State bands were moving into the area from the north and east and Spanish soldiers, missionaries, prospectors, and ranchers made repeated visits from the south as they sought to occupy the area. The Historic period (A.D. 1700-1960) consists of three sub-periods (Spanish, Mexican, and American), named for each foreign power that assumed control of the area that would become southern Arizona. By the late eighteenth century, Sobaipuri O’odham who had been living along the San Pedro River were threatened by Apache raiding and encouraged by the Spanish to relocate to O’odham villages along the Santa Cruz River, leaving much of the area east of the Santa Rita ridgeline unoccupied other than by people passing through or collecting seasonal resources.

The Tohono O’odham people were confined to reservations in the late nineteenth/early twentieth centuries: San Xavier was the first reservation established in 1874, followed by Gila Bend (1882), Papago (1916) and Sells (1917); these are now consolidated under the Nation. Nevertheless, Native people continued to travel beyond the reservation to obtain the resources and conduct the activities that are integral to their traditional culture.

Previous Archaeological Research in the Area Nearly 100 archaeological surveys have been conducted within the Ce:wi Duag boundary, mostly small surveys related to construction of roads utilities, development of water supplies and quarries, or Forest projects. In total, 425 historic properties have been recorded within the TCP boundary: 303 are prehistoric, 109 date to the Historic period, 10 are multi- component and contain both historic and prehistoric resources, and three are not classified to time period. The most extensive surveys have been conducted on the east side of the ridgeline. In the mid-I 970s in anticipation of the construction of the proposed ANAMAX copper mine near the former mining camp of Rosemont, more than 5,000 acres were surveyed, selected sites were tested, and 33 Native American and 30 Historic period properties were subjected to data recovery excavations (Ferg et al. 1984; Huckell 1984a). None of these were individually evaluated for their eligibility for listing in the National Register of Historic Places. The ANAMAX mining project did not go forward, and the excavated archaeological sites were never backfilled. The archaeological collections have been curated at the Arizona State Museum; the human remains and associated funerary objects were repatriatedto the Nation in 2009. Much of this same area was resurveyed in 2009 and 2010 in anticipation of the proposed Rosemont Copper Project (Barr et al. 2010; Ezzo et al. 2010) and its attendant power transmission corridors on the east side of the ridge (Sheehan et al. 2010; Swanson et al. 2010).

Archaeological surveys and limited excavation have shown that pre-European contact archaeological sites are common along the gentle east slope of the mountains as far south as Gardner Canyon. Fewer archaeological sites are known from the west side of the mountains, which is dominated by steeper mountain slopes than the east side. Known occupation sites are concentrated along the larger drainages where they leave the mountains. Very few sites have been found in the upper elevations of the mountains, in large part because steep terrain precludes long-term habitation.

Ethnohistoric investigations relevant to the Santa Rita Mountains have been made for the Rosemont area on the east side (Griset 201 la), for the Montosa Canyon area on the west front of the mountains (Senior 2001), and west of the TCP boundary for the Tumacacori uplands (Gillespie 2004). The totality of these separate and scattered surveys, excavations, and ethnohistoric reviews of areas within the TCP confirm the importance of the area to the Oodham and the Tohono O’odham in particular. Other tribes claim affiliation based on prehistoric trade (Puebloans represented by the Hopi Tribe and Pueblo of Zuni), use of the area as a transportation corridor and resource collecting area (Western Apache, especially San Carlos Apache Indian Tribe, and Chiricahua represented by the Fort Sill and Mescalero Apache tribes), and Yaqui use of Box Canyon as a location where medicine men retreated to prepare for ceremonies (Senior 2001).

The archaeological and ethnographic investigations to date within the area have helped refine our understanding of the longer, complex history of this region that is situated at the crossroads of many cultural influences.

9. Major Bibliographkal References Bibliography (Cite the books, articles, and other sources used in preparing this form.)

Ayres, James E. 1984 Rosemont: The History and Archaeology of Post-1880 Sites in the Rosemont Area, Santa Rifa Mountains, Arizona. Archaeological Series No. 147, Vol. 3. Cultural Resource Management, Tucson.

Bahr, Donald, Juan Smith, William Smith Allison, and Julian D. Hayden 1994 The Short SwhY Time of Gods on Earth: The Hohokarn Chronicles. University of California Press, Berkeley. 9 Exhibit 0-1 United States Department of the Interior National Park Service / National Register of Historic Places Registration Form NPS Fo~10-900 OMB No. 1024-0018 (Expires 5/31/2012)

Ce:wi Duag, Tohono O’odham Traditional Cultural Property Pima County, Arizona Name of Property County and State

Barr, David M. R., India S. Hesse, S. Jerome Hesse, Jennifer E. Hider, Suzanne Griset, Eric S. Petersen II, and David B. Tucker 2010 ArchaeologicalSurvey of Alternatives to the Proposed Rosemont Copper Mine, Pima County, Arizona. Cultural Resources Report 10- 344. SWCA Environmental Consultants, Tucson.

Brown, David E. (editor) 1994 Biotic Communities, Southwestern United States and NorthwesternMexico. University of Utah, Salt Lake City.

Brown, David E.,and Charles H. Lowe 2008 Biotic Communities of the Southwest Map. Digitized by The Nature Conservancyin Arizona, 2004, revised 2008. Available at: htto://aaic.az.aov/~ortaI/dataList.do?sort=theme&dataset=37 Accessed: September 13,2011.

Diehl, Michael W. 2005 Epilogue: “Farmaging” during the Early Agricultural Period. In Subsistence and Resource Use Strategies of Early Agricultural Communitiesin Southern Arizona, edited by Michael W. Diehl, pp 181-184. Anthropological Papers No. 34, Center for Desert Archaeology, Tucson.

Euo, Joseph A., Stephanie M. Whittlesey, Dennis Gilpin, Eric S. Petersen II, and Suzanne Griset 2010 Archaeological Survey of the Proposed Rosemont Copper Mine. Pima County, Arizona. Cultural Resources Report 09-35. SWCA Environmental Consultants. Tucson.

Ferg, Alan, Kenneth C. Rozen, William L. Deaver, Martyn D. Tagg, David A. Phillips, Jr., and David A. Gregory 1984 Hohokam Habitation Sites in the Northern Santa Rita Mountains. Archaeological Series No. 147, Vol. 2. Cultural Resource Management Section, Arizona State Museum, University of Arizona, Tucson.

Friends of Madera Canyon 201 1 Sky Islands. Available at: htto://w.friendsofaderacanvon.ora/skv islands.html Accessed: May 11, 201 1.

Garate, Donald T. 1999 Pedro de la Cruz - Alias, Chihuahua - Conspirator, Scapegoat, Victim. Manuscript in author‘s possession.

Gillespie, William B. 2004 Tumacacori Uplands Ethnohistory and Traditional Uses Overview, Coronado National Forest, Nogales Ranger District. Draft manuscript on file, Coronado National Forest.

Griset, Suzanne 2008 Notes of June 17,2008 Rosemont Mine Tribal Consultation and Ethnohistory Meeting at Tohono O‘odham Nation’s Museum, Topawa, June 16, 2008, On file, Coronado National Forest, Tucson.

201 la Tribal Consultation and Ethnohistorical Research for the Proposed Rosemont Copper Mine on the East Slope of the Santa Rita Mountains, Pima County, Arizona. Cultural Resources Report 09-238. SWCA EnvironmentalConsultants, Tucson.

201 1b Notes of October 3,201 1 TCP Consultation Meeting at San Xavier Elders Center. On file, Coronado National Forest, Tucson.

Hastings, James Rodney, and Raymond M. Turner 1965 The Changing Mile: An Ecological Study of Vegetation Change with Time in the Lower Mile of an Arid and Semiarid Region. University of Arizona Press, Tucson.

Huckell, Bruce B. 1980 The ANAMAX-Rosemont Testing Project. Review Draft. Cultural Resource Management Section, Arizona State Museum, University of Arizona, Tucson.

1984a The Archaic Occupationof the Rosemont Area, Northem Santa Rita Mountains, SoutheasternArizona. Archaeological Series No. 147, Vol. 1. Arizona State Museum, University of Arizona, Tucson.

1984b Sobaipuri Sites in the Rosemont Area. Ch. 3 in MiscellaneousArchaeological Studies in the ANAMAX-Rosemont Land ExchangeArea, by Martyn D. Tagg, Richard G. Ervin, and Bruce B. Huckell, pp. 107-130. Archaeological Series No. 147(4). Cultural Resources Management Division, Arizona State Museum, University of Arizona, Tucson.

Joaquin, Joseph 2008 Transcript of Testimony by Joseph Joaquin and Shane Anton, September 16,2008 Tour of the Rosemont Copper Project by Members of the Four Southern Tribes. Manuscript on file, Heritage Resources Division, Coronado National Forest, Supervisors Ofice, Tucson.

Senior, Louise M. 2001 An Ethnohistoric Overview and Traditional Cultural Properties Inventoryof the Proposed Veritas Project, Coronado National Forest. Cultural Resources Report 00-368. SWCA EnvironmentalConsultants, Tucson.

10 Exhibit 0-1 United States Department of the Interior National Park Service / National Register of Historic Places Registration Form NPS Form 10-900 OM8 NO.1024-0018 (Expires 5/31/2012) Ce:wi Duag, Tohono Oodham Traditional Cultural Property Pima County, Arizona Name of Property County and State

Sheehan, Michael S., Steve Swanson, and Steven Shelley 201 0 A Cultural Resource Survey for the Rosemont Project Utility Corridor, Pima County, Arizona. Cultural Resource Services Technical paper No. 201 0-001. EPG, Phoenix.

Sims, Bill 1976 Oral Interpretationof Rosemont, Arizona, between 1900-1920. Anthropology 21 1 Paper, University of Arizona, Tucson. Manuscript on file with James Ayres, Tucson.

Steere, Peter 2009 Interview of Peter Steere, Tohono Oodham Tribal Historic Preservation Officer, by Suzanne Griset, September 9,2009, at SWCA Environmental Consultants, Tucson.

Swanson, Steve, Dustin Sunderman, Benjamin Snow, and Cara Lonardo 201 0 A Cultural Resources Survey of the 46kVAlternative and Additional Areas for the Rosemont Pmject 738kV Line, Pima County, Arizona. EPG, Phoenix.

Previous documentation on file (NPS): Primary location of additional data: -preliminary determination of individual listing (36 CFR 67 has been -State Historic Preservation Office requested) OtherState agency -previously listed in the National Register -x Federal agency -previously determined eligible by the National Register Local government -designated a National Historic Landmark -University recorded by Historic American Buildings Survey # -Other recorded by Historic American Engineering Record # Name of repository: Coronado National Forest recorded by Historic American Landscape Survey #

Historic Resources Survey Number (if a assigned): 10. Geographical Data

Acreage of Property 130,181

UTM References Provided in NAD 83, N. E, S, W points of the TCP boundary

1 12 525495 3531547 3 12 518094 3489832 Zone Easting Northing Zone Easting Northing

2 12 531014 3506944 4 12 504398 3505379 Zone Easting Northing Zone Easting Northing

Verbal Boundary Description The TCP boundary encompasses as much of the land above the 4,500 foot elevation on the Santa Rita Mountains as is within the Forest, excluding any private lands. This includes Mt. Fagan at the north end of the range, and goes southwestward. The TCP boundary follows the 4,500-foot elevation or the Forest boundary as applicable. The TCP ’. boundary incorporates the majority of the westward projection of the range which includes the two highest peaks, Mt. Wrightson and Mt. Hopkins. On the east side of the ridge, the slope is gentler and all of the land within the Forest boundary is above the 4,500-foot elevation, hence the eastern boundary parallels that of the Forest

Boundary Justification The boundary follows the 4500-foot amsl elevation as closely as possible because this is the demarcation of the Upper Sonoran Life Zone from the Lower Sonoran Life Zone. The TCP contains the upland natural resources, elevated heights and viewpoints, and springs that are important to ceremonial activities. The O’odham reside in Sonoran and Chihuahuan Desertscrub communities; Ce:wi Duag is primarily Madrean Evergreen Woodland. The boundary also incorporates significant ancestral villages and remains. 11 Exhibit 0-1 United States Department of the Interior National Park Service / National Register of Historic Places Registration Form NPS Fo~10-900 OMB NO. 1024-0018 (Expires 5/31/2012)

Ce:wi Duag, Tohono O'odham Traditional Cultural Property Pima County, Arizona Name of Property County and State

11. Form Prepared By name/title Dr. Suzanne Griset, SWCA Environmental Consultants and William Gillespie, Coronado National Forest organization Coronado National Forest date October 10,201 1 street & number 300 West Congress Street telephone (520) 388-8392 city or town Tucson state AZ zip code 85701 e-mail

Additional Documentation Submit the following items with the completed form:

Map 1: Location of the Ce:wi Duag TCP. 0 Map 2: Land ownership relative to the TCP boundary. 0 Map 3: Biotic communities. 0 Map 4: Springs located in the TCP.

Photographs: Photographs are keyed to Map 1. Ce:wi Duag Traditional Cultural Property, near Tucson, Pima County, Arizona

No. Description View Facing Date Photographer 1 View of Cewi Duaa from Mission San Xavier del Bac ESE Auaust- 6,201 1 Suzanne Griset (Santa Cruz River yn foreground) 2a-d Panorama of Ce:wi Duag (4 images, left to right) E to SE August 6,2011 Suzanne Griset (Mt Fagan at left, Mt. Wrightson highest peak, Elephant Peak at right)

3 Former location of Helvetia mining camp wsw August 6,201 1 Suzanne Griset (Taken from Old Dick Mine; Baboquiviri Peak visible as conical peak in far background)

4 Helvetia mining camp W ca. 1889 Unknown (Photograph from Hastings and Tumer 1965:Plate 29a)

5 O'odham dancers in front of Greaterville store. Unknown May 1896 Unknown (Arizona Historical Society Photo No. 3622)

Property Owner: (Complete this item at the request of the SHPO or FPO.)

Name Coronado National Forest street & number 300 West Congress Street telephone 520-388-8392 city or town Tucson state Arizona zip code 301

Paperwork Reduction Act Statement: This information is being collected for applications to the National Register of Historic Places to nominate properties for listing or determine eligibility for listing, to list properties, and to amend existing listings. Response to this request is required to obtain a benefit in accordance with the National Historic Preservation Act, as amended (16 U.S.C.460 et seq.). Estimated Burden Statement: Public reporting burden for this form is estimated to average 18 hours per response including time for reviewing instructions, gathering and maintaining data, and completing and reviewing the form. Direct comments regarding this burden estimate or any aspect of this form to the Office of Planning and Performance Management. US. Dept. of the Interior, 1849 C. Street, NW, Washington, DC.

12__ Exhibit 0-1 United States Forest Coronado National Forest 300 W,Congress USDA Departmetit of Sesvice Supervisor's Office Tucson, Arizona 85701 Agriculture Plione (520) 388-8300 FAX (520) 388-8305 Deaf & Hearing hapaiscd 711

File Code: 2360/1950 Date: October 13,201 1

Mr. James Garrison Arizona State Historic Preservation Officer Arizona State Parks 1300 W Washington Phoenix, AZ 85007

Dear Mr.Garrison:

Eiiclosed please find a National Register No1nination form that serves as R Deterinination of Eligibility for tlie Cmvi Dung Traditional Cuitural Property on the Coronado National Forest. Ce:wi clrcrig, or Long Mountain, is the O'odllani name for the Santa Rita Mountains, south of Tucson in Pima and Santa Cruz Counties, As you know, the Coronado National Forest is in the process of evaluating the environiiiental effects of the proposed development of an open-pit copper mine in the northern Santa Rita Mountains. During the course of consulting with tribes about Rosemont Copper's proposal, representatives of the Tohono O'odham Nation indicated that they believe the Santa Rita Mountain range, or Ce:rvi Drrcrg warrants recognition as 3 place of continuing traditional and cultural importance to the O'odiiam people. The Forest asked Dr. Suzanne Griset of SWCA Itic. to assist in preparing a Deteimhation of Eligibility for the proposed TCP. With this document, we hase attempted to apply National Register eligibility criteria to this candidate historic property. We respectfully request that your staff review this document and provide us with your opinion on the eligibility of TCP and with any suggeslions or recommendations you myhave. Please contact Forest Archaeologist William Gillespie (wpillespie @fs.fed.us,520-388-8392) if you liave questions or continents.

Sincerely,

Enclosures: photos, registration form, and 1 CD '

Caring for tlie Land arid Serving People Prinled on Recycled Paper a United States Department of the Interior National Park Service National Register of Historic Places Registration Form Thls form is for use in nominating or requesting determinations for indivldual properties and districts. See instructions In National Regfster Bulletin, How to Complete the Nat/onal Reglsfer of Hislorlc Places Reglslmflon Form. if any item does not apply to the properly being documented, enter "/A' for 'not applicable.' For functions, architectural classification, materials, and areas of significance, enter only categories and subcategories from the instructions. Place addltlonal certification commentst entries, and narrative items on continuation sheets If needed (NPS Form 10-900a). 1. Name of Property Historic name Ce:wi Duag ("Long Mountain" in O'odham) Traditional Cultural Property Other narneslsite number Santa Rita Mountains; Dzii enzbo ("Beautiful Mountain" In Western Apache) street & number Coronado National Forest, Nogales Ranger District - not for publication city or town Tucson (30 miles NW); Green Valley (20 miles W); Sonoita (<2 miles E) I lvlcinity state Arizona Code AZ county Pima code 019 zipcode 85641 3. StatelFederal Aaencv Certification

As the designated authority under the National Historic Preservation Act, as amended, I hereby certify that this __ nomination request for determination of eligibility meets the documentation standards for registering properties in the National Register of Historic Places and meets the procedural and professional requirements set forth in 36 CFR Part 60. In my opinion, the propertyx meets -does not meet the National Register Criteria. I recommend that this property be considered significant at the following level(s) of significance: -national -statewide -x local

Coronado National Forest State or Federal agencybureau or Tribal Government In my opinlon, the property - meets -does not meet the National Register criteria.

Signature of commenting official Date

Title State or Federal agencyhureau or Tribal Government

1 4. National Park Service Certlficatlon I hereby certify that this properly Is:

-entered In the National Regfster -determined ellgible for the National Register

Idetermined not eligible for the Natlonal Register -removed from the National Reglster -other (exptaln:)

Signalure of the Keeper Date of Action

5. Classification

Ownership of, Property Category of Property Number of Resources within Property (Check as many boxes as apply.) (Check only one box.) (Do not include previously listed resources in the count.)

Contrlbutlng Noncontributing Private building(s) buildings

public - Local district I sites public - State site 'I ,1 structures

Name of related multlple property listing Number of contrlbutlng resources previously (Enter "/A' If property is not part of a multiple property tisting) listed in the National Register

NIA 1-Kentucky Camp Historic District

6. Function or Use Historic Functions Current Functions (Enter categories from instructions.) (Enter categories from Instructions.) DOMESTIC: camp, village site RELIGION: ceremonial site COMMERCE: trade (archaeology] AGRICULTURE/SUBSISTENCE: processing RELIGION: ceremonial site LANDSCAPE: natural feafures (mountain peaks, springs, drainages) FUNERARY graves and burials RECREATION AND CULTURE: outdoor recreation AGRICULTURE/SUBSISTENCE: processing, EDUCATION: research facility storage, agriculfural field INDUSTRYIPROCESSING/EXTRACTION: processing site (stone, clay, minerals) LANDSCAPE: natural feafures (mountain peaks, springs, drainages) DEFENSE: refuge

2 n

I ..

7. Descrlptlon Architectural Classification Materials (Enter categories from Instructions.) (Enter categories from instructions.) N/A foundation: walls:

roof: other:

Narrative Descrlptlon

Summary Paragraph Ce:wi Duag (Long Mountain) and the uplands on either side of the ridgeline of the Santa Rita Mountains are a traditional cultural property (TCP) of the Tohono O'odham, constituting both a landscape imbued with cultural significance, a location of sacred sites, ancestral villages and ancestral remains, and a source of plant, animal, and mineral resources used to maintain the traditional O'odham culture. Archaeoiogical investigations have documented occupation of the area beginning ca. 7,000 years ago (Huckeil 1984a), with sites dating to the following archaeological periods: Archaic, Formative (including Hohokam), and Protohistoric, the latter with Sobalpuri O'odham and probable Apache occupations. In the Historic period and through the present day, Oodham and Apache peoples have used the area as a source of resources, a refuge, a locus of sacred sites, and a place to pursue personal vision quests. The TCP lies within the area that in 1976 was adjudicated as being ancestral lands of what was at that time known as the Papago Tribe, now known as the Tohono Oodham Nation (Nation). The TCP boundary follows the 4,500 foot elevation levellwhich demarcates uplands from the bajada on the west side of the range and are primarily managed by the Coronado National Forest (Forest) (Maps 1 and 2). The Nation and the Forest recognize that the Santa Rita Mountains are also Important to other Native American tribes (Hopl, Zuni, Western Apache, and Chlricahua Apache) and to the Hispanic and local ranching communities.

Location and Setting: Cewi Duag (Long Mountain), now known as the Santa Rita Mountains, is a northeast-southwest-trendingmountain range that forms the eastern side of the Santa Cruz River valley, south of Tucson, Arizona. The ridgeline also marks the western border of the "sky island grasslands," which are bounded on the east by the Whetstone and Huachuca mountains; these mountains form the western boundary of the other major river system in central southern Arizona, the San Pedro River. This elevated area between the two major rivers provides an upland environment that is distinct from the Lower Sonoran Life Zone found beiow elevations of 4,500 feet in the Santa Cruz River valley and the desert areas to the west where most of the Tohono O'odham population lives today (see Map I for the location of the Nation's San Xavier District). The principal Tohono O'odham reservation is ca. 20 miles west of the San Xavier District, and the Nation's capital at Sells is an additional 20 miles west). The Lower Sonoran Life Zone is characterized by the Sonoran Desertscrub vegetation, while the TCP contains Semidesert Grassland and Madrean Evergreen Woodland biotic zones (Map 3) (Brown and Lowe 2008).

The TCP boundary roughly follows the 4,500-foot elevation contour that generally demarcates the lower elevation of the Upper Sonoran Life Zone (4,500-6,500 feet above mean sea level [amsl]) and the division between the bajada and the mountain on the west side of the range. The east side of the Santa Ritas slopes more gradually and contains a greater expanse of this Upper Sonoran Life Zone as rolling hills, grasslands, and watered valleys. Within this zone, the flora and fauna specific to the Madrean Woodland includes many species of particular importance to the O'odham: Emory oak, alligator juniper, Mexican piAon pine, mountain mahogany, walnut, sumac, Palmer and Parry agave, purple prickly pear, coralbean, tepary beans, other shrubs and grasses, white-tailed deer, and cottontail rabbits. Narrow strips of riparian plant communities border the major creeks within the TCP and contain Arizona sycamore, Freemont cottonwood, neatleaf hackberry, velvet ash, wild grapes, and elderberry (Brown 1994; Brown and Lowe 2008; Griset 201 la). Yet higher, on the peaks of the Santa Rita ridgeline, is the Transition Zone (6,500-8,000 feet amsl), which contains Gambel oak, smooth sumac, maple trees, and untii recently, bighorn sheep (Ayres 1984; Brown 1994; Friends of Madera Canyon 201 I), The plant resources of the Santa Rita Mountains are of traditional and continuing importance to the O'odham people in part 3 I because they are relatively rare on the Nation’s reservation lands and the other Oodham tribes (Ak Chin Indian Community, Gila River Indian Community, and Salt River Pima Maricopa Indian Community). These upland resources were an important component of the traditional territory of the O’odham, but were largely excluded when reservations were created in locations dominated by the Sonoran Desert.

Physical Description: The Santa Rita Mountains are situated along the western edge of the Mexican Highlands Subprovince of the Southern Basin and Range physiographic province. The Basin and Range Province was formed by tectonic activity 75 to 55 million years ago, with subsequent volcanism and high-angle faulting ca. 25 million to 16 million years ago. After the last tectonic activity 5 million years ago, the area continued to be shaped by deposition, erosion, and limited fault activity up to the present. Granitic stocks and plugs are partly overlain by marine and non-marine sedimentary rocks, volcanic rocks, and basin-fili deposits. The ridgeline ranges from 3,450 to 9,453 feet above sea level, is ca. 28 miles long, and has four natural passes between the Santa Cruz River Basin on the west and the Cienega Basin to the east. The TCP boundary encompasses Mt. Fagan at the north end of the range (6,189 feet amsl), trending southwest to the highest peak, Mt. Wrightson at 9,456 feet amsl, and to an unnamed peak ca. 5,000 feet amsl at the south end of the range just outside the Forest boundary (see Map 1). Other notable landforms include Elephant Head (5,607feet amsl), a granitic prominence that projects westward from the ridgeline (see protrusionat far right of Ce:wi Duag profile in Photos 1 and 2d). Creeks are intermittent and formed by water from springs, seeps, and torrential summer monsoons. Major creeks on the east side of the ridge flow northeastward into Davidson Canyon Creek, which empties into Pantano Wash, the Rillito River, and ultimately into the Santa Cruz River in the far northwestern Tucson Basin. Streams on the south side of the range flow into Sonoita Creek, a major tributary of the Santa Cruz River, and water on the west slde of the ridge flows through narrow canyons directly into the Santa Cruz River. In addition, the upland area contains the greatest concentrationof springs compared to the lowlands and these are consideredsaqe in and of themselves, and they are mineral deposits used for ceremonies (Map 4;@et------201’la), 4 p [/LW./Le bo c)( “3 d Ykd- yb> &),I ,7 ddJ6, hot. The TCP boundary encompasses 141,572 of the 148,448 acres in the Santa Rita unit‘of the(Porest’s District. Private inhoidings within the TCP boundary constitute 11,391 acres that are excluded from therefore, the total acreage of the TCP is 130,181, all administered by the Forest.

Significanf Features: Facing southeast from the contemporary O’odham community of San Xavier del Bac (or Wa:k), the landform that dominates the terrain is that of Ce:wi Duag, Long Mountain (Photo 2). Although individual mountain peaks are ais0 important to the Oodham, e.g., Baboquiviri Peak south of Sells in the main portion of the Nation, for the San Xavier District, Ce:wi Duag dominates the landscape and frames each and every day with its distinctive profile. That profile changes as one moves from the north to the south, and it may have had other names for the Sobaipuri O’odham who lived along the Santa Cruz River prior to the incursion of the Spanish in the seventeenth and eighteenth centuries. Those villages were abandoned in the eighteenth century due to Spanish pressure to relocate to the missions, the threat and reality of Apache raiding, and/or the occupation of traditional lands by Hispanic people. Wa:k was the only original O’odham village remaining in the Santa Cruz River valley by 1900. The distinctive outline of Ce:wi Duag represents many dilferent levels of meaning for the O’odham. The high elevations trap the rain that feeds the rivers of this deserf land and provide viewpoints that were/are used for personal vision quests (Steere 2009). The mountains contain sacred springs and natural resources that are not available in the lowlands yet are integral to O’odham traditional way of life. Equally important are the remnants of villages and human remains of O’odham ancestors. Baboquiviri Peak, a sacred peak and home of Elder Brother on the Nation, can be seen from the heights of Ce:wi Duag (Photo 3).

Historic Appearance: The overall appearance of Ce:wi Duag and its physicai integrity as a place of traditional and cultural importance are little changed from pre-Europeancontact times. In contrast, the appearance of the mountains on the west side of the Santa Crut River valley has been drastically altered by the excavation of large open-pit mines and deposition of extensive waste rock and taitings materials. The mining activities that began in the 1870s in the Santa Rita Mountains were relalively small- scale, including placer mining for silver and gold, small hard-rock exploratory pits and tunnels. The most intensive operations were the late nineteenth-early twentieth century copper mines and smelters at Rosemont and Helvetia (Photos 3 and 4; Photo 3 is a similar view today). Both of these smelters were in operation less than 10 years. Comparatively small waste rock piles are visible at the entrances to shafts. Depletion of wood for fuel for smelters and the influx of miners and ranchers, as well as the overgrazing caused by cattle in the nineteenth century allowed mesquite and juniper to invade denuded areas that likely contained greater densities of oak in the past. Non-nativegrasses have also invaded the area. Dirt roads were created to transport supplies to the mining towns and ranches. Many of these roads likely followed trails that had been used for centuries by Native American people. In the early 1930s, the Civilian ConservationCorps built small check dams to control water within !he Forest, as well as bridges and culverts along the major dirt roads. All of the mining 4 .- towns have since disappeared; structural foundations, waste-rock deposits; siag heaps, and trash scatters remain as 0 markers of their locations. Current Condition: The Forest assumed management of much of the land on and around Ce:wi Duag in 1902 with the establishment of the Santa Rita Forest Reserve. Improved management of livestock grazing reduced the pervasive overgrazing of the late nineteenth century; however, increasing amounts of brushy vegetation, especially mesquite, and non-native grasses have continued to occur. A number of cattle ranches established in the late nineteenth-early twentieth century around the perimeter of the mountains continue to operate with livestock grazing occurring throughout the uplands. No paved road crosses the Santa Rita ridgeline. Dirt roads remain the primary means of travel through !he TCP. Mining shafts and tailings are scattered on the upper slopes-the largest are remnants from hardrock mining that was particularly active between 1885 and 1920, and vegetation has obscured some of the former scarification. The Whipple Observatory was constructed in the 1960s on Mt. Hopkins, !he second highest peak In the Santa Rita Mountains. The observatoryand its access road are among the most visible modern developments on the mountains.

In spite of these changes, the profile of Ce:wi Duag remains as it has from the earliest occupations, as do many of the critical locations and resources. The TCP meets the standard of integrity of relationshipwith the Tohono O'odham, particularly those living at the San Xavier District.

8. Statement of Significance Applicable National Register Criteria (Mark 'x' in one or more boxes for the criteria qualifying the property D acemetery. for National Reglster listing.) E a reconstructed building, object, or structure. A Property is associated with events that have made a 0 significant contribution to the broad patterns of our history. F a commemorative property. Property is associated with the lives of persons significant in our past. G less than 50 years old or achieving significance within the past 50 years.

C Property embodies the distinctive characteristics of a type, period, or method of construction or represents the work of a master, or possesses high artistic values, or represents a significant and distinguishable entity whose components lack individual distinction.

D Properly has yielded, or is likely to yield, informatlon important in prehlstory or history.

Criteria Considerations (Mark 'x' In ail the boxes that apply.) Property is:

A Owned by a religious institution or used for religious R purposes. .H B removed from its original tocation. C a birthplace or grave. 5 Areas of Significance a(Enter categories from instructions.) Archaeology: Prehistoric, Historic - Aboriginal Significant Person Ethnic Heritage: Native American (Complete only if Criterion B is marked above.) TCP: ongoing use

Cultural Affiliation O‘odham Also: Apache, Hopi and Zuni Period of Significance

7,000 BP - present Arch1tectlBuilder

Significant Dates

Period of Significance The Oodham view Ce:wi Duag as having always been part of their culture, from time immemorial. They make no artificial distinctions such as are commonly made by archaeologists who identify different settlement patterns or tooi assemblages as distinct “cultures” or “periods,” or by historians who name and divide time into periods of influence. The O’odham have always been here, they are part of the land, and the land is part of them (Joaquin 2008). They adapted as conditions changed, and as they continue to do today. Ce:wi Duag is a physical manifestation, a distinct place in their cosmology. For the O’odham living at Wa:k, now known as San Xavier del Bac, Ce:wiDuag is where the sun rises each day.

Statement of Significance Summary Paragraph Ce:wi Duag is a traditional cultural place that Is important to maintaining the traditional worldview and life ways of the Tohono O’odham. It is recommended eligible for listing in the National Register under Criterion A for its association with the broad sweep of O’odham history fromthe Archaic period more than 7,000 years ago to the present, and forits role in maintaining the cultural practices necessary to keep the culture vital. Its unaltered profile is part of the O’odham cultural landscape that daily affirms the Oodham worldview. It retains physical4ntegrity as well as’spiritual integrity. It is the location of ancestral villages, ancestral human remains, sacred sites, and critical natural resources. Ce:wi Duag is also recommended eligible under Criterion D as it has yielded important information about the distribution of Archaic sites in southern Arizona, and Hohokam villages in upland areas (an unanticipated discovery of archaeological investigations in the 1980s; see Ferg et at. 1984; Huckell1984a, 1984b). The data from these archaeological investigations confirm the oral tradition of the O’odham. The area is likely to yield additional information important in southern Arizona prehistory and history. A recent survey of the same area that was investigated in the 1980s revealed additional sites and new foci within previously recorded sites (Barr et al. 2010; Ezzo et al. 2010). Narrative Statement of Sfgnificance Criteria A: Ethnic Heritage - Native AmericanRCP Aboriginal O’odham occupied a large portion of southern Arizona and northern Sonora from the San Pedro River on the east to the Growler Mountains on the west; and from the Gila River and Phoenix Basin on the north, south to the Rio de la Concepcion in northern Sonora. The O’odham believe they have always been here and charged with caring for this land: ...the land has always been us, and we have always been a part of this land. We are a part of this land. And that goes way back in our creation story of how we got here and how these lands are supposed to be taken care of; how this stewardship was awarded to the people living in these lands, to manage these lands the way they see fit (Joseph Joaquin, Tohono O’odham elder and NAGPRA Representative, 2008).

6 United States Department of the Interior National Park Semlce I NallonJ Register of Historic Places Registration Form - NPS Form 10-900 OlBNO. 1024Q018 (Ewires 6/3112012) Ce:wi Duag, Tohono O’odham Traditional Cultural Property Pima County, Arizona Name of Property County and State Archaeological evidence from the excavations conducted during the ANAMAX-Rosemont project confirms occupation of the eastern slope for at least 7,000 years, with a particularly intense occupation between A.D. 850 and 1050. With the intrusion of the Spanish from the south and the Apache from the north in the eighteenth century, O’odham became concentrated in villages and missions along the Santa Cruz River, abandoning permanent settlements to the east along the San Pedro River and the sky islands. Although permanent residence in the Santa Ritas was abandoned, the mountains were routinely visited to collect the upland resources integral to daily O’odham life and to use the heights for personal quests. Historic-periodO’odham followed a seasonal round that brought them to the uplands at different times throughout the year to collect sorrel greens and tubers from cattail and wild onions in February; agave hearts and cholla buds in AprillMay; yucca flowers and hedgehog cactus In late May; sotol flowers/stalks/seeds in June; leaves of purslane, amaranth, lambsquarters, and careless weed after the rains begin in July, and on into August; acorns, elderberries, and prickly pear fruit in AugusVSeptember; madrone berries, walnuts, piRon nuts, and wild grape in September; tepary beans in October; and juniper, sumac, and buckthorn berries throughout the fall (Griset 201 1a:Table 4.2). Deer were and continue to be hunted in the fall; cottontails are hunted year round.

Agave and acorns were the two most Important upland wild foods aboriginally and historically because they could be gathered in quantity, stored for later use, and used as an important item of batter with other tribes. Agave hearts were baked in large eadh ovens near where they were collected, then mashed/dried, and transported for storage at the principal village. Acorns were gathered, transported, and then processed at the principal village. Although agricultural crops, especially corn, were grown throughout the Southwest as early as 2000 B.C., wifd foods have always provided a substantial portion of the diet. The uplands also provided firewood. Ce:wi Duag was also the source of optimal stone and plant materials for making tools and baskets, as well as clays for making pots.

In the late nineteenth century, as the O’odham became more dependent on a cash economy, the uplands provided new ways of using traditional resources to generate cash or barter. O’odham family groups, likely from San Xavler District, traveled to mining camps in April and May, where they collected the local residual clays from mountain exposures and made water jars to be sold to the miners and shopkeepers at the camps. Residual clays produce porous clay bodies Ideally suited for water jars; in hot climates, as the water transpires through the jar wall and evaporates, it cools the water. One example is documented bya photograph (Photo 5) from Greaterville, a mining camp on the east side of the Santa Ritas (see Map 1). The photograph has two labels: 1) “A band of these Papagos come every year to make pottery a mile or so from the camp where the clay is suitable,” and 2) “Taken May 1896, Barcelo & Verdugo store. Papago Indians who come once a year to sell pottery. They have been dancing here for provisions, etc.” (Arizona Historical Society, Tucson, Mrs. Mary E. Anderson Collection). Similar examples are known from the mining towns of Bisbee, Tombstone, and Fairbank in the San Pedro River valley in the late nineteenth century (Griset 201 la). Sherds from Papago red water jars were also uncovered during archaeological excavations at Historic period sites near Old Rosemont (Ayres 1984), which Is within the TCP. Elders interviewed at San Xavier in 201 1 continue to associate the Santa Ritas as the place to get good red clay for water jars (Griset 201 1b).

Acorns provided another means of generating income. The Tucson newspaper reported “A large number of Papago Indians were in the city peddling acorns and ollas” (Arizona Daily Star, July 29, 1887). Another account is provided by Floyd Daniels who lived near the mining camps of Greaterville, New Rosemont, and Helvetia as a child from I901 to 1912, then as a miner at New Rosemonf for several months in 1917 (see Map 3); he recalled Papago coming to the area in the early 1000s for acorns and wood for their own use or to sell (Sims I97614-1 5). O’odham now in their 50s, OS, and 70s recall collecting acorns with their grandparents in the mid-twentieth century (Bernard Siquieros cited in Griset 2008; Griset ZOIIb). Unlike many Native American groups, the O’odham have maintained a strong basket-making industry to the present day which provides a significant source of income as well as the baskets needed for specific ceremonies, e.g., the Basket Dance, and ndwail Ma, the Rain Ceremony (Bahr et at. 1994:123). The Santa Ritas are a good source of beargrass for making traditional O’odham basketry as well as a source of other plants for mediclnal and ceremonial purposes (Griset 201 1b).

With the creation of the Forest Reserve In 1902 and the erection of fences and no trespassing signs by ranchers beginning In the late nineteenth century, O’odham feit constrained against gathering resources in the mountains. Elders stated that they or their family members were driven off of federal land when they tried to collect materials (Griset 201 Ib). With the issuance of Executive Order 13007 (1996) directing federal agencies to accommodate access to sacred sites and the Forest’s own policies (Farm Bill 2008, Public Law 110-234, Title VI11: Cultural Heritage and Cooperation Authority), the 7 Untted Stales Department of the interior National Park Service I National Register of Historlc Places Registratton Form NPS Form 10.900 OMB No. 10241xJ16 (Expires ~~/2012) Ce:wi Duag, Tohono O'odham Traditional Cultural Property Pima County, Arizona Name of Property County and State The Historic period (A.D. 1700-1 960) consists of three sub-periods (Spanish, Mexican, and American), named for each foreign power that assumed control of the area that would become southern Arizona. By the late eighteenth century, Sobaipuri O'odham who had been living along the San Pedro River were threatened by Apache raiding and encouraged by the Spanish to relocate to O'odharn villages along the Santa Cruz River, leaving much of the area east of the Santa Rita ridgeline unoccupied other than by people passing through or collecting seasonal resources.

The Tohono O'odham people were confined to reservations in the late nineteenth/early twentieth centuries: San Xavier was the first reservation established in 1874, followed by Gila Bend (1882), Papago (1916) and Sells (1917); these are now consolidated under the Nation. Nevertheless, Native people continued to travel beyond the reservation to obtain the resources and conduct the activities that are integral to their traditional culture.

Previous Archaeological Research in fhe Area Nearly 100 archaeological surveys have been conducted within the Cewi Duag boundary, mostly small surveys related to construction of roads utilities, development of water supplies and quarries, or Forest projects. In total, 425 histork properties have been recorded within theTCP boundary: 303 are prehistoric, 109 date to the Historic period, 10 are multi- component and contain both historic and prehistoric resources, and three are not classified to time period. The most extensive surveys have been conducted on the east side of the ridgeline. In the mid-I 970s in anticlpation of the construction of the proposed ANAMAX copper mine near the former mining camp of Rosemont, more than 5,000 acres were surveyed, selected sites were tested, and 33 Native American and 30 Historic period properties were subjected to data recovery excavations (Ferg et al. 1984; Huckell 1984a). None of these were individually evaluated for their eligibility for listing in the National Register of Historic Places. The ANAMAX mining project did not go forward, and the excavated archaeologicalsites were never backfilled. The archaeological collections have been curated at the Arizona State Museum; the human remains and associated funerafy objects were repatriated to the Nation in 2009. Much of this same area was resurveyed in 2009 and 2010 in anticipation of the proposed Rosemont Copper Project (Barr et al. 201 0; Ezzo et al. 2010) and its attendant power transmission corridors on the east side of the ridge (Sheehan et al. 2010; Swanson et al. 2010). Archaeological surveys and limited excavation have shown that pre-European contact archaeological sites are common along the gentle east slope of the mountains as far south as Gardner Canyon. Fewer archaeological sites are known from the west side of the mountains, which is dominated by steeper mountain slopes than the east side. Known occupation sites are concentrated along the larger drainages where they leave the mountains. Very few sites have been found in the upper elevations of the mountains, in large part because steep terrain precludes tong-term habitation.

Ethnohistoric investigations relevant to the Santa Rita Mountains have been made for the Rosemont area on the east side (Griset 201 la), for the Montosa Canyon area on the west front of the mountains (Senior 2001), and west of the TCP boundary for the Tumacacori uplands (Gillespie 2004). The totality of these separate and scattered surveys, excavations, and ethnohistoric reviews of areas within the TCP confirm the importance of the area to the O'odham and the Tohono O'odham in particular. Other tribes claim affiliation based on prehistoric trade (Puebloans representedby the Hopi Tribe and Pueblo of Zuni), use of the area as a transportationcorridor and resource collecting area (Western Apache, especially San Carlos Apache Indian Tribe, and Chiricahua represented by the Fort Sill and Mescalero Apache tribes), and Yaqui use of Box Canyon as a location where medicine men retreated to prepare for ceremonies (Senior 2001).

9. Major BibliographicalReferences Bibliography (Cite the books, articles, and other sources used in preparing this form.)

Ayras, James E. 1984 Rosemonf: Tl~eHistory and Archaeology of Post-1880 Siles in the Rosenionl Area, Sanfa UNa Mountains, Arizona. Archaeological Series No. 147, Vol. 3. Cultural Resource Management, Tucson.

Bahr, Donald, Juan Smh, Willlam Smlth Allison, and Julian D. Hayden 1994 The Short Swift Time of Gods on Earfh: The Hohokam Chronicles. University of Californfa Press, Berkeley.

9 Unlted States Department of the Interior National Park Sbrrlce I National Reglster of Hlstoric Places Reglstratlon Form . NPSForrn10-900 OMB NO. 1024-0018 (Explres 6/31/2012) Ce:wi Duag, Tohono O'odham Traditional Cultural Property Pima County, Arizona 0 Name of Property County and State Barr, Dadd M. R., lndla S. Hesse, S. Jerome Hesse, Jennifer E. Hider, Suzanne Qrlset, ric S. Petersen and David B. Tucker 2070 Archaeological Survey of Alternalives lo the Proposed Rosemont Coppel tine, Pima Cou y. Adzona. Cultural Resources Report IO- 344. SWCA Environmental Consultants, Tucson.

Brown, David E. (editor) 1994 B/otlc Communlties, Southwestern United Stales and Northweslern Mexico. Unlversity of Utah, Salt Lake City.

Brown, David E., and Charles H. Lowe 2008 Biollc Communities of the Southwest Map. Digltlzed by The Nature Conservancy In Arizona, 2004, revised 2008. Avallable at: htl8;//aalc.az.aov/~~al/dataLlsi.do?sorl=theme&dataset~37Accessed: September 13,2011.

Dlehl, Michael W. 2005 Epilogue: 'Farmaglng" during the Early Agrlcuitural Period. In Subsistence and Resource Use Slrategles of Early Agdculfural Communit/es In Southern Arizona, edited by Mlchael W.Dlehf, pp 181-184. Anthropological Papers No. 34, Center for Desert Archaeology, Tucson.

Ezzo, Joseph A,, Stephanie M. Whitllesey, Dennis Gllpln, Edc S. Petersen it, and Suzanne Griset 2010 Archaeological Survey of lhe Proposed Rosemont Copper Mine, Pima County, Arfzona. Cultural Resources Report 09-35, SWCA EnvironmentalConsultants, Tucson.

Ferg, Alan, Kennelh C. Rozen, Wllltam L. Deaver, Martyn 0.Tagg, David A. Phllllps, Jr., and David A. Gregory 1984 Hohokam Habitation Sites in the Northern Sank Rita Mountains. ArchaeologlcalSeries No. 147, Vol. 2. Cultural Resource Management Section, Arizona State Museum, Unlverdty of Arizona, Tucson.

Friends of Madera Canyon 201 1 Sky Islands. Avallable at: bttp:/lwww.friendsofmaderacanvon.ora/skv lslands,hlmlAccessed: May I1,201. f .

Ciarate, Donald T. 1999 Pedro de la Cruz -Allas, Chihuahua - Conspirator, Scapegoat, Vlctrm. Manuscript In author's possession.

Glllespie, William B. 2004 Tumacacori Uplands Ethnohlstory and Tradltlonal Uses Ovewiew, Coronado Natlonal Forest, Nogales Ranger District. Draft manuscript 0 on flle, Coronado National Forest.

Griset, Suzanne 2008 Notes of June 17,2008 Rosemont Mine Tribal Consultation and Ethnohlstory Meeting at Tohono O'odham Nation's Museum, Topawa, June 16,2008, On Me, Coronado National Forest, Tucson.

201 la Tribal Consultationand Elhnohlstorlcal Research torthe Proposed Rosemont Copper #/ne on the East Slope of fhe Sanfa RNa Mountains, Pima County, Arlzona. Cultural Resources Report OD-238. SWCA Environmental Consuttants, Tucson.

201 lb Notes of October 3,201 I TCP Consultation Meetlng at San Xavier Elders Center. On file, Coronado National Forest, Tucson.

Hastlngs, James Rodney, and Raymond M. Turner 1965 The Changing Mile: An Ecologtcal Study of Vegetallon Change wilh Time in the Lower Mile of an Artd and Semiatid Region. Unlversky of Arizona Press, Tucson.

Huckell, Bruce B. I980 The ANAMAX-Rosemonf Testlng Project. Review Draft. Cultural Resource Management Section, Arizona State Museum, UnlversiIy of Arizona, Tucson.

1084a 738 Archaic Occupallon of fhe Rosemont Area, Northern Sanfa Rita Mountains, SoutheasfernArizona. Archaeologlcal Series No. 147, Voi. 1. Arizona State Museum, University of Arizona, Tucson.

1984b Sobalpuri Sites In the Rosemont Area. Ch. 3 in Mlscellaneous Archaeological Studies in the ANAMAX-Rosemont Land Exchange Area, by Martyn D. Tagg, Richard G. Ervin, and Bruce B. Huckell, pp. 107-130. Archaeological Series No. 147(4). Cultural Resources Management Divislon, Arizona Stale Museum, Unlverslly of Arizona, Tucson.

Joaquln, Joseph 2008 Transcript of Testimony by Joseph Joaquln and Shane Anton, September i6,2008 Tour of the Rosemont Copper Project by Members of the Four Southern Tribes. Manuscrlpt on flte. Heritage Resources Division, Coronado National Forest. Supervisors Office, Tucson.

Senlor, Louise M. 2001 An Elhnohlstoric Overview and Tradiiionai Cultural Properties Inventory of the Proposed Verilas Project, Coronado National Forest. Cultural Resources Report 00-368. SWCA EnvironmentalConsuitants, Tucson.

10 United States Department of the interior National Park Senrice / National Register of Hfstoric Places Registratton Form NPS Form 10-900 OMB No. 1024.0018 (Expires 6/31/2012) Ce:wi Duag, Tohono Oodham Traditional Cultural Properly Pima County, Arizona Name of Property County and State Sheehan, Michael S.. Steve Swanson, and Steven Shelley 2010 A Cultural Resource Survey for fhe Rosemont Project Utility Corridor, Pima County, Arizona. Cultural Resource Services Technical paper No. 2010-001. EPG, Phoenix.

Sims, Bfll 1976 Oral Interpretationof Rosemont, Arizona, between 1000-1g20. Anthropology 21 1 Paper, University of Arfzona, Tucson. Manuscript on file with James Ayres, Tucson.

Steere, Peter 2009 interview of Peter Steere, Tohono O'odham Tribal Historic Preservation Officer, by Suzanne Grlset, September 9,2009, at SWCA Envlronmental Consultants, Tucson.

Swanson, Steve, Dustin Sunderman, Benjamin Snow, and Cara Lonardo 201 0 A Cultural Resources Survey of the 46kVAlternafive and AddiNonal Areas for the RosemonfProlecf 138kV Line, Pima Counly, Arizona. EPG, Phoenlx.

Previous documentation on file (NPS): Prlmary location of additional data: -preliminary determination of indlvldual llsttng (30 CFR 67 has been StateHistoric Preservation Office requested) -Olher State agency -previously listed In the National Register -x Federal agency previouslydetermined eligible by the National Register -Local government designated a Nationat Historic Landmark -University -recorded by Histodc American Buildings Survey # -Other recordedby Historic American Engineering Record # Name of repository: Coronado National Forest recorded by Historic American Landscape Survey #

Historic Resources Survey Number (if assigned):

10. Geographical Data

Acreage of Property 130,181

UTM References Provided in NAD 83, N, E, S, W polnts of the TCP boundary

1 12 525495 3531547 3 12 518004 3489832 Zone Easting Northing Zone Easting Northing

2 12 531014 3506944 4 12 504398 3505379 Zone Easting Northing Zone Easting Northing

Verbal Boundary Description The TCP boundary encompasses as much of the land above the 4,500 foot elevation on the Santa Rita Mountains as is within the Forest, excluding any private lands. This includes Mt. Fagan at €henorth end of the range, and goes southwestward. The TCP boundary follows the 4,500-foot elevation or the Forest boundary as applicable. The TCP boundary Incorporates the majority of the westward projection of the range which includes the two highest peaks, Mt. Wrightson and Mt. Hopkins. On the east side of the ridge, the slope is gentler and all of the land within the Forest boundary is above the 4,500-foot elevation, hence the eastern boundary parallels that of the Forest

Boundary Justification The boundary follows the 4500-foot amsl elevation as closely as possible because this is the demarcation of the Upper Sonoran Life Zone from the Lower Sonoran Life Zone. The TCP contains the upland natural resources, elevated heights and viewpoints, and springs that are important to ceremonial activities. The Oodham reside in Sonoran and Chihuahuan Desertscrub communities; Ce:wi Duag is primarily Madrean Evergreen Woodland. The boundary also incorporates asignificant ancestral villages and remains. United States Department of the Interior National Park Sixvice I Natlonal Reglster of Historic Places Reglstration Form ' NPS Fo~10-900 OM8 NO. 1024*0018 (Expires 6/31/2012) Ce:wi Duag, Tohono O'odham Traditional Cultural Property Pima County, Arizona Name of Property County and State

11. Form Prepared By

name/title Dr. Suzanne Griset, SWCA Environmental Consultants and William Gillespie, Coronado National Forest organization Coronado National Forest date October IO, 201 1 street & number 300 West Congress Street telephone (520) 388-8392 city or town Tucson state AZ . zipcode 85701 e-mail [email protected]: wni1lespieQfs.fed.us

Additional Documentation Submit the following items with the completed form:

Map 1: Location of the Ce:wi DuagTCP. Map 2: Land ownership relative to the TCP boundary. I Map 3: Biotic communities. Map 4: Springs located in the TCP.

~~ Photographs: Photographs are keyed to Map I. Ce:wi Duag Treditlonal Cultural Property, near Tucson, Pima County, Arizona

No. Description View Facing Date Photographer 1 View of Ce:w/ Duag from Mission San Xavier del Bac ESE August 6,201 1 Suzanne Griset (Sanfa Cruz River In foreground)

2a-d Panorama of Ce:W Due9 (4 images, left to rfghf) E toSE August 6,2011 Suzanne Griset (Mt Fagan at left, Mt. Wrightson highest peak, Elephant Peak at right)

3 Former location of Heivetia mining camp wsw August 6,2011 Suzanne Griset (Taken from Old Dick Mine; Baboqulviri Peak visible as conical peak In far background)

4 Heivetia mining camp W C&. 1889 Unknown (Photograph from Hastlngs and Turner 1965:Piate 29a)

5 Oodham dancers in front of Greatenrille store. Unknown May I896 Unknown (Arizona Historical Society Photo No. 3622)

Property Owner: (Complete this Ifem at the request of Ule SHPO or FPO.) Name Coronado National Forest street & number 300 West Congress Street telephone 520-388-8392 city or town Tucson state Arizona ZIP code 85701

Paperwork Reduction Act Statement: This Information Is being collected for applications to the National Register of Historic Places to nominate properties for listing or determine eligibility for listing, to list properties, and to amend existing listings. Response to this request is required to obtain a benefit in accordance with the National Historic Preservation Act, as amended (16 U.S.C.460 et seq.). Estimated Burden Statement: Public reporting burden for this form is estimated to average 18 hours per response including time for reviewing instructions, gathering and maintaining data, and completing and reviewing the form. Direct comments regarding thls burden estimate or any aspect of thls form to the Office of Planning and Performance Management: US. Dept. of the interior, 1849 C. Street, NW, Washington, DC.

12 ,.: ,.: 1 c "Managing and conserving Arizona's natural, cultural and recreatlonal reeources" b b LI L "1

Arizona State Parks

Tucson, A285701

ATTN: William Gillespie, Forest Archaeologist. . ,

Janice K. Brewer RE: Determination of Eligibility for the Ce:wi Duag (Santa Rita Mountains) Traditional Governor Cultural Property in Pima County; Coronado National Forest; SHPO-2011-1316(95119) State Parks Board Members Dear Supervisor Upchurch: * Chair Thank you for consulting with us regarding the above referenced project. Pursuant to rracey Westerhausen Phoenix 36 C.F.R. Part 800, the implementing regulations of Section 106 of the National Historic Preservation Act, we have reviewed the determination of eligibility (DOE) for Ce:wi Duag Walter D. Armer, Jr; as a Traditional Cultural Property and have the following comments: Vail Reese Woodfing 1. We commend the Coronado National Forest (CNF) for making the determination Tucson that Ce:wi Duag is eligible for inclusion in the National Register of Historic Places Larry Landry as a Traditional Cultural Property (TCP). Phoenix .. . 2. We. are inclined to concur with the CNF's determination;'however, we need more,.. . Alan Everett Sedona information regarding the CNF's consultationswith the Tohono O'odham an!,. . ' :. other tribes regarding the preparation of the DOE in order for us to complete our-

William C. Scalzo review. Neither the cover letter nor the DOE'nomination.foa contains adequate ' . Phoenix information regarding.tribal consultations for +e TCP DOE; The DOE ~,, . Maria Baier documentation references Susanne Griset's 20'1: 1 Tribal Consultation and State Land Ethnohistorical Research.for the Proposed Rosemont Copper Mine on the ,East' .. Commissioner Slope of the Sunta Rita Mouritains, Pima County,Arizona. -Ifthisdocument. Renee E. Bahl ,summarizesthe CNF's .effortsto cpnsufwith eibes regarding the-Ce:wiDuag TCP

Executive Director DOE, then it should have been provided with the DOE or summarized in& , . ..;

.nomination. Fudhermore, Griset's document has not been submitted to our office ' Arizona State Parks 1300 W. Washington for review and comment. Phoenix, AZ 85007 .. Tel & TTY: 602.542.4174 3.. We would al.so like the CNF to provide us with more information regarding tribal' AZStateParks.com perspectives on the boundary of the TCP. Wehnderstand the practicality of using 800.285.3703 from theCNF administrative boundary as the boundary for the TCP;.however, tribal, :. (520 & 928) area codes perspectives on boundaries typically don't coincide with arbitraky adininistrative. General Fax: boundaries. We would l&e to know whethefthe relevant tribes concur.with CNF's 602.542.4180 determination ojthe boundary of the TCP. Based upon our review of the,draft .. Environmental Impact Statement for the .proposed development of the Rosemont Copper mine, it appears that the Tohono O.'odham support houndaries that.follow ' . : the CNI: administrative boundary. This information, including supporting '. documentation, should have been included within.. the DOE nomination form. .. Exhibit 0-2 “Managing and conserving Arizona’s natural, cultural and recreational resuurce~”

4. It is our opinion that the TCP DOE could be further developed, especially in terms , of tribal traditional use, contemporary use, and the sacred component of ihhe TCP. We understand that the tribes might be sensitive with public disclosure of certain information; however, if tribes did have concerns regarding sharing information, then that should have been made clear within the cover letter that accompanied the DOE nomination form. ta-k Parks 5. On page 2 of the nomination form under “5. Classification”, the “Category of Property” should be ccsite”and not ccobj.ect.’’Please revise.

We look to receiving the information that we requested above regarding the CNF’s consultations with tribes regarding its determination that Ce:wi Duag is a TCP eligible for Janice K. Brewer inclusion in the National Register. If you have any questions or concerns, then please do Governor not hesitate to call me at (602) 542-7120, or e-mail me at elaurila@azstateparI

cey Westerhausen Phoenix kilter D. Armerg, Compliance Specialisflkchaeologist Arizona State Historic Preservation Office eese Woodllng 9 Tucson Larry Landry Phoenix Alan Everett Sedona William C. Scalzo Phoenix Maria Baier . State Land Commissioner Renee E. Bahl Executive Director

arizona State Parks - 1300 W. Washington Phoenix, AZ 85007 h TIY 602.542.4174 AZStateParks.com 800.285.3703 from :O & 928) area codes General Fax: . 602.542.41 80

Exhibit 0-2 @9 .-...... __ 2 -, -, I 0 I' +

.IC" .I

3 P P ---7 I

BEFORE THE

2 ARIZONA POWER PLANT AND TRANSMISSION LINE SITING COMMITTEE

3 N THE MATTER OF THE APPLICATION IF TUCSON ELECTRIC POWER Docket No. L-OOOOOC-11-0400-00164 4 :OMPANY FOR A CERTIFICATE OF ZNVIRONMENTAL COMPATIBILITY Case No. 164 5 iUTHORIZING THE CONSTRUCTION OF 1 138 kV TRANSMISSION LINE AND TOHONO O’ODHAM NATION’S 6 SSOCIATED FACILITIES FROM THE WRITTEN TESTIMONY OF PETER ’ROPOSED TOR0 SWITCHYARD, STEERE 7 SECTION 29, TOWNSHIP 17 SOUTH, (Amended redacted in accordance with MNGE 14 EAST TO THE ROSEMONT the Chairman’s ruling of December 8, 8 WBSTATION, SECTION 30, TOWNSHIP 201 1) 8 SOUTH, RANGE 16 EAST, EACH 9 ,OCATED WITHIN PIMA COUNTY, iRIZONA. 10

11 1. Please state your name and position.

Peter Steere. I am the Tribal Historic Preservation Officer for the Tohono 0 l2 Nation and I also manage the Cultural Affairs Office. 13 2. How long have you been in that position? Fourteen years. 14 3. What is your background? 15 I received my Bachelor of Arts in Anthropology in 1970 from the University of Montana. 16 Following that, I received a Master of Arts in Anthropology in 1972 from University of Montana. Thereafter, I obtained a Master of Library Science from the University of 17 Arizona in 1987. Overall, I have spent thirty five years performing cultural resource work, survey and excavation projects, report preparation, and National Register 18 nomination work. I have worked in Montana, Idaho, Wyoming, North and South Dakota, Arizona and New Mexico. I also worked as an archeologist with the U.S. Forest Service 19 from 1977-1980. I have performed cultural resource work and land claims research for other tribes throughout the years, including Crow, Blackfoot, Flathead, and Cree. 20 4. Could you briefly describe the duties of a Tribal Historic Preservation Officer? 21 As a Tribal Historic Preservation Officer, I am responsible for all Section 106 compliance 22 under the National Historic Preservation Act on the Nation and also on the Tohono O’odham traditional use lands as defined by the United States Indian Lands Commission. I am also responsible for performing Archeological Resource Protection Act 23 investigations, to assist with cases being prosecuted by the U.S. Attorney’s Office. I am e 24

-1- responsible for Native American Graves and Repatriation Act compliance, including repatriations from sites and museums in Arizona and from museums throughout the 2 o1 United States. I also review all National Environmental Policy Act documents for projects that could affect the interests of the Nation. I also work with the Forest Service 3 to carry out the purposes of the American Indian Religious Freedom Act regarding sacred sites on Forest Service land. Our office also coordinates and trains Nation members to be 4 cultural resource monitors for projects that affect cultural resources on and off the Nation.

5 5. Could you give a brief synopsis of the history of the Tohono O’odham?

6 The cultural history of the Tohono O’odham in the Tucson Basin spans a period of over 10,000 years. The subsistence pattern of people living in the Tucson Basin has been 7 greatly influenced by the desert environment for most of that period. I’ll next give a brief overview of each of the periods of use by Tohono O’odham ancestors. 8 Paleoindian Period (1 1,000 BC to 7500 B.C.) 9 The earliest use of the Tucson Basin was during the Paleoindian period that dates back over 10,000 years, a time when the climate was much cooler and wetter than today. This 10 period was marked by small groups of highly mobile hunter and gatherers who traveled from different campsites in search of food and other resources. The most common types 11 of sites left by these hunters were mammoth, mastodon and bison kill sites. The Clovis fluted spear point is one of the most diagnostic artifacts from this time period, and they have been found at sites in the Tucson Basin. A Rancholabrean faunal site was recorded in Section 27 as part of a survey for the Anamax mining project in 1976. This site is located in the Rosemont Mine Project Area. Vance Haynes of the University of Arizona :: suggested that this site bears a close geomorphological relationship to known Paleoindian 14 sites in the San Pedro Valley, therefore it is possible that evidence of human use of this . area during the Paleoindian Period may be present at this site. 15 Archaic Period (7500 B.C. to 1200 B.C.) 16 Climate change associated with the end of the last glacial period marks the transition from the Paleoindian to Archaic Period. The climate in the Tucson Basin became drier 17 and warmer, approximating the climate of today. Archaic Period people collected wild plants and hunted smaller mammals. Early Archaic sites are known from the Tortolita 18 Mountains (Ruelas Canyon). Middle Archaic Period sites are reported from the bajadas in the Tucson Basin including the Santa Rita Mountains. Archaic sites are known from the 19 Rosemont Mine project area and from the Tucson Electric Power Rosemont 138 kV utility corridor. 20 Early Agricultural Period (1200 B.C. to A.D. 100) 21 The Early Agricultural Period was previously known as the late Archaic. It begins with the introduction of domesticated plants into the Southwest. Cultivation in the Tucson 22 basin was in place by 1,200 B.C. and by 400 B.C. large agricultural communities were established along the Santa Cruz River and some of its tributaries. Recent archaeological excavations near the Tucson sewage treatment plant have demonstrated that extensive canal irrigation had started by this time.

-2- Sites from this time period are characterized by small round pithouses with large storage pits. Larger communal structures also have been reported from this time period. Artifacts 2 o1 include specialized projectile points types as well as a variety of groundstone and flaked stone tools and shell artifacts. The presence of marine shell and exotic lithic materials 3 types such as obsidian not found in the Tucson Basin indicate that trading networks were established. 4 Early Ceramic Period (A.D. 100 to A.D. 500) 5 Ceramic artifacts including pottery and figurines were first seen in the Tucson Basin area in the Early Agricultural Period. Extensive widespread use of ceramic objects occurs in 6 the Early Ceramic Period. Pithouse styles change during this period. Larger structures may have served for ceremonies and community meetings. Emphasis on agricultural 7 crops and increasing diversity of crops becomes common including beans, maize, cotton, squash and agave. Canal irrigation systems expand and continued trade in exotic trade 8 items such as turquoise, shell and obsidian increases with expanding trade networks.

9 The Hohokam (A.D. 500 to A.D. 1450) Characterized by the introduction of redwares and decorated ceramics including red-on- 10 brown in the Tucson Basin and red-on-buff in the Phoenix Basin, the Hohokam tradition becomes well-established in the Tucson Basin. The Hohokam sequence is divided into 11 many phases and periods (Pre-Classic, Classic and Post Classic). Ceramic types and styles, tool types and ornaments made from shell and rocks and minerals vary over time. Changes in architecture and social organization also change over time. Large community platform mounds, walled compounds and ball courts occur in this period. By 1450 A.D. :: the Hohokam tradition changes and many of the characteristics disappear. Many of the cultural sites in the proposed Rosemont Mine Project Area and the TEP Rosemont Utility 14 Corridor are from the Hohokam Period.

15 The Protohistoric Period (A.D. 1450-A.D. 1692) The Protohistoric Period is not well known. When Spanish explorers and missionaries 16 entered the area in the period from the early 1500s to the 1690s they encountered O’odham speaking peoples in the Santa Cruz and San Pedro Valleys as well in the 17 western desert lands stretching toward Yuma. In the areas west of the Santa Cruz River Valley the Spanish encountered the Tohono O’odham and on the San Pedro and Santa 18 Cruz River Valleys, the Spanish encountered the Sobaipuri people. Both of these groups spoke O’odham, classified by linguists as part of the Piman group of languages. 19 Archaeologist Deni Seymour in her new book: “Where the Earth and the Sky are Sewn Together: Sobaipuri-O’odham Contexts of Contact and Colonialism,”provides a great 20 deal of new information on the Protohistoric Period. Four Sobaipuri sites and several Tohono O’odham sites are located in the Rosemont Mine Project Area. 21 The Tohono O’odham Nation regard all of these sites from the periods described above, 22 occurring in the TEP Rosemont Utility Corridor and the Rosemont Mine Project Area as representing ancestors. These sites are regarded as sacred locations where the remains of 23 ancestors are often buried. 0 24

-3- 6. Please describe what a Traditional Cultural Place is. 2 0’ A Traditional Cultural Place is a legal designation pursuant to the National Register of Historic Places. The National Register of Historic Places contains a wide range of 3 historic property types. Buildings, structures, sites, landscapes, and individual objects can all be included in the Register if they meet the criteria set out in the National 4 Register’s Criteria for Evaluation. A traditional cultural property is generally eligible for inclusion in the National Register due to its association with cultural practices or beliefs 5 of a living community that are either rooted in that community’s history or are important in maintaining the continuing cultural identity of the community. 6 The National Register of Historic Places contain a wide range of historic property types 7 that reflect the diversity of the Nation’s history and culture. The National Register defines “culture” as those traditions, beliefs, practices, lifeways, arts, crafts and social institutions 8 of any community be it prehistoric or historic, be it Native American or a local ethnic group or the Nation as a whole. One type of cultural significance a property may possess 9 is a “traditional cultural significance.”

10 Traditional in this context refers to beliefs, customs, and practices of a community of people that have been passed down through generations, orally or through practice. The 11 traditional cultural significance of an historic property can be an individual site, district, a multiple resource area or a traditional cultural property and is derived from the role the property plays in a community’s historically rooted beliefs, customs and practices. A location such as Ce:wi Duag (Santa Rita Mountains) associated with the traditional :: beliefs of a Native American group can relate to its origins, cultural history or the nature of the world. 14 Sometimes traditional cultural properties can be hard to recognize. They may be a cliff 15 face, a lake, a stretch of river, a neighborhood or in this case a mountain or mountain range such as the Santa Ritas. 16 The 1980 amendments to the National Historic Preservation Act directed the Secretary of 17 the Interior to preserve and conserve the intangible elements of our cultural heritage and to recommend ways to preserve, conserve and encourage the continuation of the diverse 18 prehistoric, historic, ethnic and folk cultural traditions that underlie and are a living expression of American heritage. 19 It is important to avoid ethnocentrism when evaluating a traditional cultural property. 20 Euroamerican society tends to emphasize objective observation of the physical world. It may not be possible to use such observations for evaluating a traditional cultural 21 property. There may be nothing observable to an outsider about a traditional cultural place regarded as sacred by a Native American group. 22

-4- 7. At TON Exhibit 1, there is an application to designate Ce:wi Duag as a TCP. Could you please describe the application generally and the significance of Ce:wi Duag to 2 0’ the Nation?

3 Ce:wi Duag is the O’odham name for the Santa Rita Mountains. Ce:wi Duag (long mountains) has been nominated by the Coronado National Forest at the request of the 4 Tohono O’odham Nation to the National Register of Historic Places as a Traditional Cultural Property. The Arizona State Historic Preservation Office has reviewed and 5 concurs with this nomination. See Exhibit marked TON-2.

6 The land and landscape as well as the specific locales and resources of the Ce:wi Duag Traditional Cultural Property continue to hold special significance as part of the cultural 7 heritage, both past and present of the Tohono O’odham Nation. The archaeological sites of the Archaic, Hohokam and Protohistoric periods represent the ancestors of the Tohono 8 O’odham. Many of these sites represent the burial places of ancestors that should not be disturbed and are regarded as sacred, a view held by many tribes. 9 The Ce:wi Duag contains many other types of culturally significant locations not 10 recorded by the archaeological surveys. These sites include: vision quest locations, basket material collecting locations, plant medicine collecting areas, clay location collection 11 areas, mineral locations for certain paints and springs to name a few. All of these sites :: will be impacted by the Rosemont Mine and the Project. 14

16 significant concern as well as the visual impacts on the Ce:wi Duag Traditional Cultural 17 Property.

18 8. At TON Exhibit 2, there is a letter from the Arizona Historic Preservation Office. Could you please describe the significance of the letter. 19 The significance of the letter from the Arizona State Historic Preservation Office lies in 20 its concurrence with the determination of eligibility of the Ce:wi Duag Traditional Cultural Property to the National Register of Historic Places. Under Section 106 of the 21 National Historic Preservation Act of 1966 (as amended), it is the responsibility of the state historic preservation office to provide an evaluation of any property recommended 22 for a determination of eligibility or nominated to the National Register.

23 0 24

-5- 9. At TON Exhibit 3, there is a map of the proposed TCP area overlaid with the 0’2 Project map. Could you please describe the significance of this exhibit? The importance of this map is that it shows the Ce:wi Duag Traditional Cultural Property 3 overlain on the Project area, which lies in the visual image of this significant cultural area. The map further shows how the Traditional Cultural Property will be impacted by 4 the construction of the power lines and the Rosemont mine project. The impact of these two projects on the cultural resources of the Nation in this area is simply unacceptable. 5 10. What are your concerns, overall, regarding the cultural impact on the Nation of this 6 Project?

7 The Project will have adverse impacts on individual cultural resource sites, adverse impacts to sensitive cultural areas, and adverse impacts upon the cultural and natural 8 landscape of Ce:wi Duag. With respect to individual resource sites, the EPG report sets out that every proposed route will either disturb or destroy up to ten cultural resource 9 sites, many of which are likely to have human remains. The cultural resource sites are both Hohokam and from the Archaic period, which the O’odham consider to be their 10 ancestors. These sites are quite culturally important to the O’odham and their damage and/or destruction is unacceptable. 11 With respect to sensitive cultural areas, there are additional sites within the Project area that are significant for cultural reasons that are not identified as cultural sites in the cultural resources survey. These areas include vision quest sites, sacred springs, 0 :: basketmaking/material collecting sites, acorn collecting sites, and collecting sites for plant medicine. These sites, despite not being addressed in the cultural resources survey, 14 are very important to Tohono O’odham. O’odham continue to use some of these sites to this day and their damage, destruction, or disturbance will have a significant cultural 15 impact.

16 With respect to the cultural and natural landscape of Ce:wi Duag, the entire area proposed for consideration as a TCP is an important cultural area for the O’odham. The 17 erection of Dower Doles. lines. and substations will have a Significant adverse imDact on

19 It is hrther unclear whether a significant number of saguaro will be removed as a result 20 of this Project. However, if numerous saguaro will be removed as a result of this Project, then the Nation has cultural concerns as the saguaro is a culturally sensitive plant. 21 11. Now, turning specifically to the proposed alternative routes associated with the 22 Project, please describe the cultural impacts of the Proposed Route.

The Proposed Route will have significant adverse impacts on Ce:wi Duag, which is eligible for listing on the National Register of Historic Places. These impacts include my

-6- overall concerns, as was discussed in Question 10. Regarding cultural resources specific 0’ to the Proposed Route, there are seven cultural resource sites on the Proposed Route that 2 are likely to be destroyed or disturbed. Two of the sites are likely to have prehistoric human remains, which are Hohokam. The Hohokam are considered by the O’odham to 3 be ancestors and thus their burial sites are considered sacred. Additionally, one historic site with human remains is likely to be disturbed or destroyed. One spring will also be 4 negatively impacted. Springs are special and sacred places for the Tohono O’odham. Finally, there are long-term cumulative impacts that are simply not addressed. These 5 include construction roads and access roads, increased use of and access to the area, which are likely to negatively impact on the integrity of the cultural and natural resources 6 of the area over time.

7 12. Please describe the cultural impacts of Alternative 1.

8 Alternative Route 1 will have significant adverse impacts on Ce:wi Duag, which is eligible for listing on the National Register of Historic Places. These impacts include my 9 overall concerns, as was discussed in Question 10. Regarding cultural resources specific to Alternative Route 1, there are six cultural resource sites on Alternative Route 1 that are 10 likely to be destroyed or disturbed. Three of the sites are prehistoric Hohokam sites, which are ancestral to O’odham. One spring will also be adversely impacted. Springs 11 are special and sacred places for the O’odham. Finally, there are long-term cumulative impacts that are simply not addressed. These include construction roads and access roads, increased use of and access to the area, which are likely to negatively impact on l2 the integrity of the cultural and natural resources of the area over time. 0 13 13. Please describe the cultural impacts of Alternative 2. 14 Alternative Route 2 will have significant negative impacts on Ce:wi Duag, which is 15 eligible for listing on the National Register of Historic Places. These impacts include my overall concerns, as was discussed in Question 10. Regarding cultural resources specific 16 to Alternative Route 2, there are ten cultural resource sites on Alternative Route 2 that are likely to be destroyed or disturbed. Four of the sites are prehistoric Hohokam sites that 17 may have human remains. The Hohokam people are the ancestors of the O’odham. There is also one historic site that may have human remains. One spring will also be 18 negatively impacted. Springs are special and sacred places for the O’odham. Finally, there are long-term cumulative impacts that are simply not addressed. These include 19 construction roads and access roads, increased use of and access to the area, which are likely to negatively impact on the integrity of the cultural and natural resources of the 20 area over time.

21 14. Please describe the cultural impacts of Alternative 3.

22 Alternative Route 3 will have significant adverse impacts on Ce:wi Duag, which is eligible for listing on the National Register of Historic Places. These impacts include my overall concerns, as was discussed in Question 10. Regarding cultural resources specific to Alternative Route 3, there are nine cultural resource sites on Alternative Route 3 that

-7- are likely to be destroyed or disturbed. Five of the sites are prehistoric Hohokam sites that are likely to have human remains. The Hohokam people are the ancestors of the .’2 O’odham. One spring will also be negatively impacted. Springs are special and sacred places for the O’odham. Finally, there are long-term cumulative impacts that are simply 3 not addressed. These include construction roads and access roads, increased use of and access to the area, which are likely to negatively impact on the integrity of the cultural 4 and natural resources of the area over time.

5 15. Please describe the cultural impacts of Alternative 4.

6 Alternative Route 4 will have significant adverse impacts on Ce:wi Duag, which is eligible for listing on the National Register of Historic Places. These impacts include my 7 overall concerns, as was discussed in Question 10. Regarding cultural resources specific to Alternative Route 4, there are six cultural resource sites on Alternative Route 4 that are 8 likely to be destroyed or disturbed. Five of the sites are prehistoric Hohokam sites that are likely to have human remains. The Hohokam people are the ancestors of the 9 O’odham. One spring will also be negatively impacted. Springs are special and sacred places for the O’odham. Finally, there are long-term cumulative impacts that are simply 10 not addressed. These include construction roads and access roads, increased use of and access to the area, which are likely to negatively impact on the integrity of the cultural 11 and natural resources of the area over time.

16. Describe the cumulative impact on cultural resources of this Project. 0 l213 - - 14

16 The adverse effects on the cultural landscape of Ce:wi Duag and the destruction of sacred sites, springs, shrines, vision quests, medicine plants, basket materials, clay pits for 17

19 The Tohono O’odham Nation strongly recommends that a Certificate of Environmental Compatibility not be approved for any of the alternative routes of the Project. 20

22 ::

-8- 0’2 18. What impact, overall, will this Project have on the cultural 3 resources of the Nation? - 4 As stated above, the Project will have an = adverse impact on the cultural resources of the area that are regarded as sacred locations 5 - 6

10 Traditional Native American cultures, including that of the O’odham speaking peoples of Central and Southern Arizona, have defined geography through myth, ritual, ceremonies 11 and spirit power. The land is respected along with the traditions it sustains. One of the most significant concepts of Native American cultures is that the land is alive. Every form of land is the location of different spirit beings. Their presence gives life to and sanctifies the land. Since the land can be viewed as consisting of living beings, then most l2 0 13 Native American cultures have a tradition of special relationships with the land. This view stresses the interrelationships among all things in the land. The land is viewed with 14 respect and reverence. The land reciprocates by providing for the people by sharing its resources. 15 The mountains, hills, valleys and springs of the Ce:wi Duag Traditional Cultural Property 16 in the Santa Rita Mountains provide plant medicine, basket making materials, clays for pottery, soils and rocks for paint pigments, isolated locations for vision quests, sacred 17 springs for water and the homes and resting places of ancestors. As Janet McCloud, a direct descendant of Nisqually Chief Seattle and spokesperson for Nisqually fishing 18 rights spoke: “if an area is destroyed, marred or polluted, my people say the spirits will leave and the animals, birds and plants will disappear when the spirits leave.” I believe 19 that this concept is applicable to this Project, in connection with the Rosemont Mine. No place can be singled out for preservation while the surrounding landscape which gives 20 the place its significance is destroyed. The Application of this Project fails to recognize that the sacred lands of Ce:wi Duag are essential 21 to Native American religious practice. Protecting and avoiding a few cultural- sites while -destroying the large parts of Ce:wi Duag does little to solve this problem, since all the 22 spirits and places of the land are all interconnected.

While the Tohono O’odham Nation strongly opposes the granting of a Certificate of :: Environmental Compatibility for the Project, if such a Certificate is approved then the

-9- I

1 Tohono O’odham would request that TEP avoid ail cultural sites, have cultural monitors fiom the Tohono O’odham Nation working with the archaeologicd and construction a2 crews working on the power line and design the power line to minimize visual impacts to the Ce:wi Duag Traditional Cultural Property. 3 19. If the Committee ultimately recommends to grant the Certificate of Environmental 4 CompatibiIity over the objections of the Nation, are there any conditions that you would like to see? 5 Yes, I would like TEP to avoid all cultural resources. Additionally, TEP should be 6 required to have a Tohono O’odham Nation cultural monitor on site during all construction activities. The Ce:wi Duag Traditional Cultural Property should not be 7 adversely impacted by the proposed Rosemont Mine and this Project.

10 Tribal Historic Presemation Officer 11

12 * 13 Respectfu1ly submitted this 5F day of December, 201 1, 14

1s TOHONO O’ODHAM NATION OFFICE OF ATTORNEY GENERAL 16

17 Laura Berglan, dssidAttorney General 18 P.O. Box 830 Sells, Arizona 85634 Telephone: (520) 383-3410 19 Fax: (520) 383-2689 laura.berdan62tomtion-nsn. gov 20 Pursuant to A.A.C.R14-3-204, the original 21 and twenty-five (25) copies of the foregoing Request will be filed December 5,2011, with: 22 Docket Control Ariina Corporation Commission 23 400 W.Congress, Ste. 218 Tucson, Arizona 85701 24

- 10- r

1 A copy of the foregohg Request will be emailed or mailed that same date to: e2 John Foreman Assistant Arizona Attorney Generd 3 Chairman, Arizona Power Plant and Transmission Line Siting Committee 1275 W.Washington 4 Phoenix, Arizona 85007

5 Emailed on December 5,201 1 to: Mi Rothwell ARothwelImep.corn 6 Bev Everson [email protected] Charlotte Cook cklott&,empirefagm. org 7 Chelsa Johnson C_OhSO~@,epe;az.com E. Bakken 8 Ed Beck Elizabeth Webb Julia Fonseca 9 Katie Chaban Lawrence Robertson, Jr. 10 Lauren Weinstein Laurie Woodd 11 Marc Jerden Marshall McGruder Patrick Black 12 Paula Perrera Robert Iljuris * 13 Tim Hogan Jenny Neeley 14 Jason Gellman Matt Derstine Mary Ippolito 15 Peter MacIvaine Susan Ellis susan.ellis@azap; .m 16 Kim Rso [email protected] Robert Metli [email protected] 17 Sandy Whitehouse [email protected]

@ 24

-11- BEFORE THE

2 ARIZONA POWER PLANT AND TRANSMISSION LINE SITING COMMITTEE

3 N THE MATTER OF THE APPLICATION 3F TUCSON ELECTRIC POWER Docket No. L-OOOOOC-11-0400-00164 4 30MPANY FOR A CERTIFICATE OF ZNVIRONMENTAL COMPATIBILITY Case No. 164 5 4UTHORIZING THE CONSTRUCTION OF 4 138 kV TRANSMISSION LINE AND TOHONO O’ODHAM NATION’S 6 4SSOCIATED FACILITIES FROM THE PROPOSED CONDITIONS OF ’ROPOSED TOR0 SWITCHYARD, CERTIFICATE OF 7 SECTION 29, TOWNSHIP 17 SOUTH, ENVIRONMENTAL UNGE 14 EAST TO THE ROSEMONT COMPATIBILITY 8 SUBSTATION, SECTION 30, TOWNSHIP 18 SOUTH, RANGE 16 EAST, EACH 9 LOCATED WITHIN PIMA COUNTY, 4RIZONA. 10

11 Pursuant to the Procedural Order issued November 10,2011, the Tohono O’odham

Nation (“Nation”) submits the following proposed conditions to the Certificate of Environmental‘ a l2 13 Compatibility (“CEC”), should the Committee recommend that the CEC be granted:

14 1. Applicant shall engage the services of a Tohono O’odham Nation cultural monitor

15 that shall be present during all construction activities.

16 2. Applicant shall avoid all cultural resource sites.

17 Respectfidly submitted this 5th day of December, 201 1. 18

19 TOHONO O’ODHAM NATION OFFICE OF ATTORNEY GENERAL 20 By: /s/ Laura Beralan 21 Jonathan Jantzen, Attorney General Laura Berglan, Assistant Attorney General 22 P.O. Box 830 Sells, Arizona 85634 Telephone: (520) 383-3410 Fax: (520) 383-2689 a 23 laura.beralan@,tonation-nsn.gov 24

-1- Exhibit 0-5 ursuant to A.A.C. R14-3-204, the original .' nd twenty-five (25) copies of the foregoing 2 .equest will be filed December 5,20 1 1, with: locket Control 3 Jizona Corporation Commission 00 W. Congress, Ste. 218 4 ucson, Arizona 85701

5 , copy of the foregoing Request will be.emailed r mailed that same date to: 6 ihn Foreman ssistant Arizona Attorney General 7 Ihairman, Arizona Power Plant and Transmission Line Siting Committee 275 W. Washington 8 hoenix, Arizona 85007 ;mailed on December 5,201 1 to: 9 Ji Rothwell ARothwellG3,tep.corn 10 lev Everson beverson@,fs.fed.us lharlotte Cook charlotte@,empirefagan.org 11 lhelsa Johnson ciohnson@,epgaz.com l. Bakken ebakken@,tep.com :d Beck ebeck@,teP.com llizabeth Webb vailazB,hotmail.com 0 l2 ulia Fonseca Julia.F&seca@,pima. qov 13 Latie Chaban kchaban@,rddaw.com ,awrence Robertson, Jr. tubaclawver@,aol.com 14 .amen Weinstein lweinst@,epgaz.com .aurie Woodall law@,ktZaline.com narc Jerden mi eden@,tep.com 15 darshall McGruder marshal1@,magruder .orq 'atrick Black pblack@,fclaw.com 16 'aula Perrera paula.pirrera@,pcao.pima. gov tobert Harris azrwill@,gmail.com 17 Tim Hogan thogan@,aclpi.or g, enny Neeley j ennv@>kjislandalliance.org ason Gellman jgellm%@,rdp-law .com 18 vlatt Derstine mderstine@,rdp-law.com vlary Ippolito mippolito@,rdp-1aw.com 19 'eter MacIvaine eier .maciivaine@,azag.gov Susan Ellis :usan.ellisQ,azag. gov 20 Gm Rego info@,azhighwavs83.com Xobert Metli rimetli@,mungerchadwick.com deadlass14@,msn.com 21 Sandy Whitehouse

Is/ April Foltz By: April Foltz 23 e 2r

-2- Exhibit 0-5 SIERRAPhone: (602) 253-8633 Fax: (602) 258-6533 Email: -__ CLUB FOUNDED 1892

December 12,201 1

Mr. John Foreman, Chairman Arizona Power Plant and Transmission Line Siting Committee 1200 W. Washington Street Phoenix, AZ 85007

Re: Tucson Electric Power Company Application for a Certificate of Environmental Compatibility for Construction of a 138kV Transmission Line, Docket Number L-OOOOOC- 11-0400-001 64, Case Number 64

Dear Chairman Foreman and Members of the Committee:

I am submitting written public comments on the proposed Tucson Electric Power Company (TEP) transmission line on behalf of the Sierra Club's Grand Canyon (Arizona) Chapter and our 12,000 members, many of whom are TEP customers.

The Sierra Club's mission is "to explore, enjoy, and protect the wild places of the eartlq to practice and promote the responsible use of the earth's ecosystems and resources; and to educate and enlist humanity to protect and restore the quality of the natural and human environments." Formed in 1966, the Grand Canyon Chapter is one of more than 60 Sierra Club chapters throughout the country. The Sierra Club and our members have a significant interest in this proposed project as the proposed route not only cuts through an important wildlife area, but it also is being proposed to serve one of the most destructive mining projects in the state, one that is universally opposed by conservation organizations and much of the community in Tucson and surrounding areas.

We oppose granting this Certificate of Environmental Compatibility Construction of a 138kV Transmission Line from the proposed Tor0 Switchyard to the Rosemont Substation.

The Sierra Club is opposing this project it could help to further facilitate one of the most destructive mining proposals in our state - the Rosemont Copper Project. It is inappropriate to review the line in a vacuum; it should be considered relative to the overall potential impact. Additionally, this line will be unnecessary when the mine is rejected.

According to the Draft Environmental Impact Statement (DEIS) for the Rosemont Copper Project, dated September 201 1, the proposed action would result in the direct loss or conversion of more than 6,000 acres of habitat and would indirectly affect more than 145,000 acres. It will affect natural springs and riparian areas, destroy regional connectivity for wildlife, and negatively affect at least nine federally listed endangered species, including seven animal species - Chiricahua leopard frog, Gila chub, Gila topminnow, jaguar, lesser long-nosed bat, ocelot, and southwestern willow flycatcher - and two plant species - Pimapineapple cactus and Huachuca water umbel. I.

As was noted by intervenors, the Arizona Game and Fish Department has raised significant concerns regarding the project and stated in a July 8,2008, letter from Joan E. Scott, Habitat Program Manager for Arizona Game and Fish to Beverly Everson, Geologist for Coronado National Forest.

“Ourpreliminary review indicates that despite any and all mitigation measures, this project will result in signiJcant adverse impacts to wildlge, wildlge habitat, and wildlife recreation. We believe that the project will render the northern portion of the Santa Rita Mountains virtually worthless as wildlqe habitat and as a functioning ecosystem, and thus also worthlessfor wildlqe recreation. Furthermore, the project has great potential to impact wildlge and habitat offthe forest. ’’

The proposed transmission line itself would negatively affect wildlife habitat and would present additional opportunities for spread of non-native invasive plant species, both directly during construction and indirectly as another transmission line effectively creates another road and invitation to off-road vehicle abuse.

Cultural resources could also be negatively affected by the transmission line and would certainly be negatively affected by the Rosemont Mine, including the town site of Helvetia and its cemetery, as well as Native American prehistoric sites.

The Rosemont Mine would also degrade air quality in the area and could contribute to violations of the federal health-based standards for ozone in Pima County. Emissions of oxides of nitrogen (NOx) from I the mine, which contribute to ozone formation, could cause exceedances of the standard at Saguaro National Park East, which has some of the higher ozone levels in the county. Pima County is already close to exceeding the current ozone standard and will likely exceed the proposed new standards. Adding any emissions to the current levels is foolish and puts at risk the health of the people in the county.

Overall, we strongly object to the mine and to this proposed transmission line to facilitate it. We ask that you consider the overall and cumulative impacts and that you reject this Certificate of Environmental Compatibility.

Thank you for the opportunity to comment.

Chapter Director Sierra Club - Grand Canyon Chapter

Printed on Recycled Paper THE STATE OF ARIZONA COMMISSIONERS CHAIRMAN. ROBERTR WOODHOUSE. ROLL NORMANW FREEMAN. CHINO VALLEY GAMEAND FISH DEPARTMENTJACK F HUSTED.SPRlNGERVlLLE J.W. HARRIS.TUCSON 5000 W. CAREFREEHIGHWAY ROBERT E. MANSELL,WINSLOW PHOENIX, AZ 85086-5000 DIRECTOR LARRY D VOYLES (602) 942-3000 WWW AZGFD.GOV REGION v, 555 N. GREASEWOODROAD, TUCSON, AZ 85745

Mr. Ed Beck Director of Transmission Policy and Contracts Tucson Electric Power 80 E Broadway Blvd. Tucson, AZ 85701

RE: Docket No. L-OOOOOC-11-0400-00164, line siting case 164

Dear Mr. Beck:

Upon review of Case No. 164, Application for a Certificate of Environmental Compatibility, Rosemont 138kV Transmission Line Project, the Arizona Game and Fish Department provides for your consideration the following comments: The Department strongly recommends that wherever possible, project alternatives follow existing utility corridors, roadways, or other previously disturbed areas. Significant portions of each of the alternative alignments for the proposed Rosemont 138kV Transmission Line Project (the Project) incorporate this approach. The Preferred Route in particular would be adjacent an existing, maintained public roadway for the majority of the alignment. Additionally, access for construction and maintenance of the proposed transmission line along the Preferred Route would be via a 14-foot (typical) service road shared with the proposed Rosemont Mine water pipeline. Tucson Electric Power (TEP) has stated that the water pipeline would require booster pumps at several locations, requiring additional electric distribution facilities which could be consolidated with the Project along either the Preferred or Alternative 1 routes. If neither of these routes along Santa Rita Road were chosen, there would still remain a need for electric distribution along the water pipeline alignment, thus requiring construction of distribution facilities. Alternative Routes 2,3, and 4 would involve considerably more wildlife habitat disturbance than either the Preferred or Alternative Route 1. Although these three alternative routes could consolidate the existing 46kV line on the same structures as the proposed Rosemont transmission line, each would require clearing additional habitat to improve and widen the existing access road. Alternative Routes 2 and 3 would also require improvements to Helvetia Road south of Santa Rita Road and spur roads to tower locations along this road. Alternative Route 4 would require construction of 4.1 miles of transmission line through steep, mountainous terrain where no such structures currently exist, and construction and/or upgrade of the access road for the majority of this route. The Preferred Alternative represents the minimum disturbance of all the proposed alternative routes, primarily through its siting along an existing roadway and collocation within a shared utility corridor. It is the Department’s position that the Preferred Route represents the most

AN EQUAL OPPORTUNITY REASONABLEACCOMMODATIONS AGENCY Mr. Ed Beck December 10,2011 Page 2 satisfactory location for the proposed transmission line. To a lesser degree, Alternative Route 1 may also be acceptable. The Department appreciates that TEP has made clear to the Rosemont Copper Company and the public that the transmission line will be built only if the mine is approved. Arizona Game and Fish is in the process of preparing comments to the Rosemont Mine Draft Environmental Impact Statement (EIS). The proposed transmission line is a connected action to the Rosemont Mine Project, and any adverse effects must be fully disclosed in the EIS. As the state agency responsible for the conservation, enhancement, and restoration of Arizona’s diverse wildlife resources and habitats, the Department’s objective is to identify especially sensitive and unique habitats and work with project proponents to avoid and minimize negative impacts, and when possible enhance and/or improve habitat conditions. The Department has produced a number of wildlife-friendly guidelines and can provide additional expertise to TEP in regard to wildlife connectivity, habitat management, and mitigation strategies. Please contact me at 520-388-4447 or kterpening@,a,azafd.gov for any questions regarding this letter.

cc (via electronic mail): Shannon Breslin, Manager, Land Department, TEP Cheryl Hall, Senior Environmental Planner, Land Department, TEP Lauren Weinstein, Principal, EPG, Inc. Laura Canaca, Project Evaluation Program Supervisor, AGFD John Windes, Habitat Program Manager, Region V, AGFD Raul Vega, Region V Supervisor, AGFD Linda Pollock, Assistant Attorney General