Reference Library

Soilworks products are the industry’s top standard due to our insistence on creating high performance soil stabilization and dust control products that stand up to rigorous testing – both in the lab and in the field. Our commitment to quality and performance has led to our involvement and testing in hundreds of real-world situations. The following library of reports, presentations, specifications, approvals and other similar documents provide you, our customer, the transparency and dependable assurance that is expected from Soilworks.

APS Sun Valley to Morgan Transmission Line Project (TPD1306136)

Summary

The APS Sun Valley to Morgan 500/230kV Transmission Line Project Final Environmental Impact Statement (EIS) addresses dust control and soil stabilization measures necessary for utility corridor construction in Arizona’s desert environment. The report highlights the need for mitigation strategies to prevent soil erosion, dust emissions, and habitat degradation along the transmission line right-of-way.

To ensure environmental compliance and minimize dust pollution, the project can benefit from Soiltac, a biodegradable synthetic copolymer, which enhances soil stability and reduces airborne particulates on construction access roads and exposed soil areas. Additionally, Durasoil, a non-water-dependent synthetic fluid, is ideal for long-term dust suppression along high-traffic utility maintenance roads, preventing dust migration and ensuring regulatory compliance with BLM and EPA air quality standards. These dust control solutions support sustainable energy infrastructure development while maintaining air quality and soil integrity. Contact Soilworks for tailored dust control and soil stabilization solutions for utility corridors, energy infrastructure, and large-scale construction projects.

CHAPTER 6 DRAFT EIS COMMENTS AND

RESPONSES

6.1 INTRODUCTION

This chapter provides public comments received by the BLM in response to publication of the Draft EIS, and the BLM’s responses to those comments. The information contained in this chapter did not exist in the Draft EIS. Underlining was used throughout this Final EIS to indicate where text revisions were made between the Draft and Final EIS; however, no underlining was used in Chapter 6 as the entire chapter would be underlined and difficult to read.

Public comments were sought on the Sun Valley to Morgan 500/230kV Transmission Line Project Draft EIS. The comment period commenced with the publication of the NOA in the Federal Register on November 9, 2012 and ended on February 8, 2013.

A total of 1,279 comment letters and emails were received. This included one special interest group form letter (i.e., email campaign) and five other email form letters originating from individual interested parties; and the oral comments presented at the Draft EIS Public Hearings. All comments on the Draft EIS that were received, were read, and given careful consideration, with necessary changes incorporated into this Final EIS. Each written comment or oral statement presented at the public hearings was analyzed and specific comments related to the analysis contained in the Draft EIS were extracted.

6.2 RESPONSE TO COMMENTS

In responding to comments, every effort was made to address all questions, concerns, and other points presented by the commenter. Table 6.1-1 presents all of the specific comments that were received on the Draft EIS. It includes the comment letter number, commenter name, the specific comment, and the BLM’s response to the comment. Information contained in comment letters that had no specific relevance to the analysis in the Draft EIS is not included in Table 6.1-1. In some cases, entire comment letters did not contain information relevant to the analysis; entries in Table 6.1-1 for these letters indicate in the “Comment” column that the content was unrelated. The initial occurrence of form letters was considered for comments, with all subsequent copies referenced back to the initial occurrence. A list of interested parties participating in form letter campaigns is provided in Appendix 6A, which includes the individuals name and which form letter they submitted. Two petitions were also received; these are included in the Project Record.

Not all comments in Table 6.1-1 resulted in text changes that appear in the Final EIS. The “Response” provided by BLM, in many cases, refers to information already contained in the Draft EIS, or provides an explanation and/or clarification as to why a text change to the document was not required.

The following is a list of comment type codes that were used to indicate each comments associated resource or concern.

AIR	Air Quality Concern
AR	Access Routes Concern
CE	Cumulative Effects concern
CUL	Cultural Resources Concern
EJ	Environmental Justice Concern
GEN	General Concern
GEO	Geology & Minerals Concern
GHG/CC	Greenhouse Gas/ Climate Change concern
INFO	Information Request
LAW	Legal Concern
LU	Land Use Concern
M&M	Mitigation and Monitoring Concern
NEPA	NEPA Concern
NOISE	Noise concern
OHV	Off Road Vehicle Recreation Concern
OPP ALT2/3	Opposes Alternative 2 and 3
OPP ALT3	Opposes Alternative 3
OPP ALTS	Opposes all alternatives
OPP FL	Opposes use of federal lands
OPP MUC	Opposes multi-use corridor south of SR74
OPP PA	Opposes Proposed Action/Preferred Alt
OPP RMPA	Opposes RMP Amendment
OPP SAR	Opposes Sub-alternative Route
OPP UR	Opposes Unidentified Route
OREC	Other Recreation Concern
PH	Public Hearing Concern
PH&S	Public Health & Safety Concern
PR ROW	Previous ROW
RAN	Range Concern
RENE	Renewable Energy Concern

RIP	Riparian Concern
RNA	Recommends a New Alternative
SAAA	Supports Another Action Alternative
SDA	Supports a Dismissed Alternative
SOC	Socioeconomics Concern
SOIL	Soils Concern
SR74	Supports route along SR74 without indicating which side (north or south)
SRMA	Special Recreation Mgmt Area Concern
SSS	Special Status Species Concern
SUP NA	Supports No Action
SUP PA	Supports Proposed Action/Preferred Alt
SUR	Supports Unidentified Route
TRAN	Transportation Concern
UC	Content unrelated to analysis
VEG	Vegetation Concern
VIS	Visual Resources Concern
WLF	Wildlife Concern
WTR	Water Concern

Table 6.2-1 Public Comments and BLM Response

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Maricopa County Board of Supervisors	1.1	SUP PA	“We…support the Proposed Action in its Environmental Impact Study…the Proposed Action strikes the appropriate balance and sufficiently avoids Lake Pleasant Park and Castle Hot Springs Road…We believe that by selecting the Proposed Action as its Preferred Alternative, the BLM can simultaneously protect the interests of the County and its residents …, while also facilitating a transmission line that … is needed for electric reliability and renewable energy.”	Statement of preference.
Maricopa County Board of Supervisors	1.2	REC	“…the route determined for the Sun Valley to Morgan line should attempt to minimize impacts to Lake Pleasant Regional Park, and in particular, the primary ingress and egress from the Lake, Castle Hot Springs Road.”	The visual impacts to Lake Pleasant Regional Park and Castle Hot Springs Road are analyzed in Section 4.14. Alternative 3, described in Section 2.5.3, would place the transmission line along the Carefree Highway alignment and would minimize visual impacts to SR 74 and Castle Hot Springs Road.
Maricopa County Board of Supervisors	1.3	RENE	“Maricopa County…acknowledges the importance of renewable energy transmission by allowing above ground electric transmission lines for 69kV or greater along SR 74.”	This information is stated and acknowledged in Section 3.14.1 of the EIS.
Maricopa County Board of Supervisors	1.4	VIS	“The actual placement of the transmission line, consistent with the Proposed Action and the ACC decision will allow visual impacts to be minimized and mitigated.”	The statement is supported by analysis in the EIS in Section 4.14.
Thomas and Donna Huey	2.1	SR74	“We definitely support the placement of these lines along state route 74 and encourage the final selection of this route for the project.”	Statement of preference.
John & Barbara O’Donnell	3.1	OPP PA	“We are writing you to express our opposition to moving the High Voltage power lines proposal to the north side of SR 74.”	Statement of preference.
Braulio & Tania Santana	4.1	SUP PA	“In order to preserve the safety and property value of our community we as a Vistancia property owners support the Certificated Route (North of State Route 74) as the route to implement this project.”	Statement of preference.
Bruce Brown	5.1	VIS	“…scenic drives within easy travel time of the greater Phx area become fewer and fewer…Now, the threat of power lines along one of the few easily accessed scenic drives from the city is proposed. This route has always been a treat,… a experience not easily found this close to the ever encroaching city.”	The impact of the proposed transmission line on visual resources, and specifically the visual resources of SR 74, is analyzed in Section 4.14.
Bruce Brown	5.2	RNA	“There already exists a corridor of power lines that follow Rte 303, to the south of Rte 74…move the lines to the south of Rte 74.”	Section 1.2 of the EIS states, “The 500kV transmission line would increase the reliability of the electrical infrastructure in Arizona by providing another 500kV source to the Pinnacle Peak Substation. This would be in addition to the sources from the Northern Navajo and Four Corners generating stations that can be subject to system outages or wildfires along transmission lines. The co-located 230kV transmission line would serve future load that is expected to develop in currently undeveloped areas…”
Charlotte and Tom Wright	6.1	SUP PA	“We sincerely appreciate your efforts at locating the power lines north of State Route 74…”	Statement of preference.
Charlotte and Tom Wright	6.2	OPP ALT3	“…and not within the northern portion of the Vistancia community.”	Statement of preference.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Donald and Mary Roberts	7.1	OPP PA	“I am writing to … express opposition to the Line Siting Committee’s decision to place major utility lines along State Route 74.”	Statement of preference.
Donald and Mary Roberts	7.2	VIS	“Any proposed High Voltage Utility towers would be highly detrimental to the pristine and environmentally sensitive lands along this designated Scenic Corridor.”	The impact of the proposed transmission line on visual resources and the mitigation to minimize impacts, and specifically the visual resources of SR 74, is analyzed in Section 4.14.
Donald and Mary Roberts	7.3	OREC	“Diamond Venture’s Alternate Route 3 North …poses an even greater threat to the enjoyment of tens of thousands of people in the region who utilize the Federal BLM lands for recreational and travel purposes.”	Impacts to recreation from the Proposed Action/Preferred Alternative on BLM lands are analyzed in Section 4.9. Mitigation measures to minimize impacts are also included in this section.
Donald and Mary Roberts	7.4	OPP RMPA	“The Bureau of Land Management has spent over 6 years revising the Resource Management Plan in this area to further restrict and protect its environment, sensitive habitat and recreational use. No utility lines were requested or identified during that process. The National Environmental Policy Act (NEPA) was enacted to help protect Federal lands that are owned by the Citizens of the United States from greedy self-interests. The BLM NEPA public process is certain to highlight and elevate the intense opposition to degradation of these environmentally-sensitive Federal Lands.”	Environmental impacts of the Proposed Action/Preferred Alternative are analyzed in Chapter 4. Mitigation measures for various resources are also listed in Chapter 4 to minimize potential impacts. These measures are also summarized in Section 2.9. Because no utility corridors were envisioned in the area of the ACC certificated route on BLM lands north of SR 74, the BLM proposes to amend the RMP to establish a utility corridor, as described in Sections 1.3.2 and 2.4.
Donald and Mary Roberts	7.5	NEPA	“NEPA requires that other alternatives must be taken if they are viable.”	The NEPA does not provide direction as to which alternatives may, or should be, selected and implemented. Section 1505.2, Record of Decision in Cases Requiring Environmental Impact Statements indicates that a record of decision shall, “Identify all alternatives considered by the agency in reaching its decision, specifying the alternative or alternatives which were considered to be environmentally preferable. An agency shall identify and discuss all such factors including any essential considerations of national policy which were balanced by the agency in making its decision and state how those considerations entered into its decision.”
Donald and Mary Roberts	7.6	LU	“The last few scenic, easily accessible, critical desert habitats in the entire region should not be compromised for the benefit of those few who would profit or benefit from this line siting at the expense of the general public.”	Statement of opinion. Wildlife habitat within the project area is discussed in Sections 3.16 and 4.16.
Donald and Mary Roberts	7.7	VIS	“State Route 74 has both Scenic Corridor designation and BLM land on both sides of the road.”	The impact of the proposed transmission line on visual resources and the mitigation to minimize impacts, and specifically the visual resources of SR 74, is analyzed in Section 4.14.
Donald and Mary Roberts	7.8	GEN	“I am deeply concerned about this project destroying the pristine desert land that surrounds us.”	Environmental impacts of the Proposed Action/Preferred Alternative to desert resources are analyzed in Chapter 4, along with a description of mitigation measures and other measures proposed to reduce potential impacts.
Donald and Mary Roberts	7.9	LU	“…Federal land that belongs to everyone…should be preserved for the future posterity of all our children and grandchildren.”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
Michael Jordan Marion Jordan	8.1	OPP PA	“…we do not approve any changes to the original plan for high power structures.”	Statement of preference.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Michael Jordan Marion Jordan	8.2	VIS	“…this would create an unsightly appearance to the desert in front of our land…”	The impact of the proposed transmission line on visual resources and the mitigation to minimize impacts, and specifically the visual resources north of SR 74, is analyzed in Section 4.14.
Michael Jordan Marion Jordan	8.3	SAAA	“South of 74 was the best way to carry out the power lines since there is absolutely no homes or construction on that side.”	Statement of preference.
Denise Lacey Senior Planner, Maricopa County Dept. of Transportation	9.1	TRAN	“…proposed transmission line is in close proximity to, adjacent to, or in line with planned roadways. Specifically these roadways include Dove Valley Road/Parkway, Wild Rose Parkway (243 & 251 Avenues), Sun Valley Parkway, Patton Road, and Deer Valley Parkway. All of these roadways will require 200 feet of right-of-way to accommodate future travel.”	The interaction of the proposed project and planned future roadways is addressed in Section 4.19.13, which analyzes the cumulative impacts to transportation and traffic. Text has been added to this section addressing possible conflicts between the ROW for the proposed project and ROW requirements for future transportation infrastructure. The proposed transmission line has been located near the outside edge of the transportation corridor on the north side of SR 74 which would tend to minimize most potential conflicts with anticipated ROWs for future highway development.
Denise Lacey Senior Planner, Maricopa County Dept. of Transportation	9.2	TRAN	“MCDOT has previously expressed concerns regarding impact to future roadway widening due to utility conflicts and repeats that concern with this project.”	The interaction of the proposed project and planned future roadways is addressed in Section 4.19.13, which analyzes the cumulative impacts to transportation and traffic. Text has been added to this section addressing possible conflicts between the ROW for the proposed project and ROW requirements for future transportation infrastructure. The proposed transmission line has been located near the outside edge of the transportation corridor on the north side of SR 74 which would tend to minimize most potential conflicts with anticipated ROWs for future highway development.
Denise Lacey Senior Planner, Maricopa County Dept. of Transportation	9.3	LU	“We encourage any approval to require equal cooperation in sharing right-of-way (roadway and utilities) thereby limiting impact to the environment by decreasing overall right-of-way requirements.”	The ROW north of SR 74 would be within a BLM-designated transportation corridor.
Nancy Santori	10.1	OPP PA	“…the proposed route…is a pristine, beautiful area which I have enjoyed hiking in, and I don’t want to see it spoiled by development of any kind.”	Statement of preference.
Jim and Claudia Thomson	11.1	SUP PA	“We strongly agree with the conclusion pertaining to the preferred alignment north of State Route 74 as chosen by BLM.”	Statement of preference.
Brent & Rose Dubberstein	12.1	SR74	“We only support alignment with (SR) 74.”	Statement of preference.
Dan Gainor	13.1	SUP PA	“My wife and I are in total support of the proposed amendment and wish we could be at the public hearing to voice our support for the amended route.”	Statement of preference.
Jerry and Theresa Moon	14.1	SUP PA	“We are in full support of the Certificated Route regarding the APS power line.”	Statement of preference.
Robert Dreebin	15.1	INFO	“Where can I get a map of the proposed power line and where it goes?”	Dennis Godfrey replied with map location on 12.11.12.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Anonymous	16.1	PH	“It was extremely difficult and at times impossible to hear the speakers. It would have been nice to be able to hear all views since we took the time to come out this evening. Very disappointing. Very poor planning.”	Technical difficulties were unexpected and unforeseen. All of the comments on the DEIS are included in the FEIS in Chapter 7.
Butch Pendergast	17.1	SUP PA	“I endorse the proposed route.”	Statement of preference.
Diane Arnold	18.1	SOC	“Trilogy at Vistancia remained stable through the recession/financial crisis. Homeowners would be very offended should the power lines go through its community, and they could potentially move to other locations outside of Peoria.”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10.
J.K. and Diane Arnold	19.1	SOC	“Power lines within view of Trilogy will not only greatly depreciate property values and tax revenue, but will alienate a very stable segment of Peoria residing in Vistancia.”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values and tax revenue.
Kathleen Johnson	20.1	SR74	“We support the power line on State Route 74.”	Statement of preference.
Mark Johnson	21.1	SR74	“Prefer power line go to Hwy 74 and not near Trilogy.”	Statement of preference.
J. Richard Stravolo Marie L. Stravolo	22.1	OPP ALT3	“We voiced our objection to the original planned location of the transmission lines.”	Statement of preference.
J. Richard Stravolo Marie L. Stravolo	22.2	PH&S	“Our concerns were with the potential health problems that could result from such close proximity to our residences…”	Impacts to Public Health and Safety from all alternatives are analyzed in Section 4.7. Under Alternative 3, the proposed transmission line would be over one mile away from existing residences.
J. Richard Stravolo Marie L. Stravolo	22.3	SOC	“…and to the obvious decline in the fair market value of our homes.”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values from Alternative 3.
J. Richard Stravolo Marie L. Stravolo	22.4	SUP PA	“We also understand that BLM has proposed that the route, in fact, be installed to the North of Route 74. We strongly approve of this location.”	Statement of preference.
Sheila Sparr Rick Sparr	23.1	OPP ALT3	“We don’t want any power lines in view of our Trilogy neighborhood.”	Statement of preference.
Sheila Sparr Rick Sparr	23.2	SOC	“We don’t want our property…to be depreciated…”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values from Alternative 3.
Ron Aames	24.1	SUP PA	“I…strongly support the proposed APS Sun Valley to Morgan 500/230 kV transmission line project.”	Statement of preference.
Suzanne Otterbacher	25.1	SR74	“We support lines along 74…”	Statement of preference.
Suzanne Otterbacher	25.2	SOC	“…so as to not disrupt the value of the homes in Trilogy which provide a major tax base for Peoria.”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values and tax revenue.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Theodore Manos Donna Doe	26.1	SUR	“Why not just run your power lines along existing power lines to the south!”	Section 2.7 identifies other utility corridors (specifically the West Wing in Section 2.7.7) and provides rationale for why those alternatives were not carried forward for detailed analysis.
Theodore Manos Donna Doe	26.2	LU	“Protect BLM land”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
Theodore Manos Donna Doe	26.3	OPP ALT3	“Avoid Route #3”	Statement of preference.
Donald Dolphin	27.1	OPP PA	“I do not see the need for an additional route which will destroy the view along St. Rt. 74…”	The impact of the proposed transmission line on visual resources and the mitigation to minimize impacts, and specifically the visual resources of SR 74, is analyzed in Section 4.14.
Donald Dolphin	27.2	GEN	“I can’t help but wonder if the real reason for this project is to provide power for the so-called ‘Inland Port’ that Santa Fe railroad is planning for Grand Ave and Dove Valley Road.”	Section 1.2 of the EIS provides APS’ objectives for the proposed project.
John Smejkel	28.1	OPP UR	“I do not approve! I have a problem with these towers literally in my back yard.”	Statement of preference.
M. Milic	29.1	PH	“Gov’t agency – no show – ie Luke, City of Surprise, Peoria”	Cooperating agencies were in attendance at various meetings and were appraised of the venues of all the meetings.
M. Milic	29.2	GEN	“Not plain where its going – street names – N & South & East & West need to be plain on mailings”	The comment referred to contents of mailings and not the EIS itself.
M. Milic	29.3	INFO	“Needs to be informed”	Project contact information was distributed at the public hearings as well as the project website.
M. Milic	29.4	SDA	“Bury the lines”	Section 2.7.10 explains why undergrounding the proposed transmission line was not carried forward for detailed analysis.
M. Milic	29.5	SOC	“Notify anyone show property value is affected”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values. Neither the BLM nor APS could notify property owners of affects to valuation from the transmission line because effects are estimated for analysis purposes only and are not absolute; best available studies were reviewed and referenced in the EIS related to this issue.
M. Milic	29.6	INFO	“Phone #s & Email of who to contact to stop it”	Project contact information was distributed at the public hearings as well as the project website.
David G. Gulino, Land Development Services	30.1	INFO	“Please add me to the mailing list.”	Added to the mailing list by Galileo on 12.13.12
The Pinalto Family	31.1	PH&S	“We live in the WestWing Mountain neighborhood in N. Peoria and are very concerned about the potential health risks that a nearby APS Sub-Station will cause. The location of proposed APS Sub- Station is too close to our neighborhood…”	Impacts from the construction of the Sun Valley Substation are beyond the scope of analysis for this EIS.
Constance and Donald McGuigan	33.1	SR74	“We only support alignment of the APS transmission lines with SR74.”	Statement of preference.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Kathleen and Robert Enserro	46.1	OPP ALT3	“I live in Trilogy of Vistancia and do not [want] the power lines in our backyard or near vicinity.”	Statement of preference.
Robert and Amanda Wahl	49.1	SUP PA	“We are writing to you today to state our support for placing the proposed APS Sun Valley to Morgan Transmission Line on the North side of SR 74.”	Statement of preference.
Jacqueline Vogle Robert Vogle	53.1	SUP PA	“…we are urging you to consider placement of the APS power lines on the north side of SR74.”	Statement of preference.
Jacqueline Vogle Robert Vogle	53.2	LU	“SR 74 is slated to become a major transportation corridor, it seems that utilizing this area as a transportation/utility corridor would minimize environmental impacts to the area.”	The combined environmental impact of the Proposed Project with development of the transportation corridor is analyzed in Section 4.19 of the EIS.
Jacqueline Vogle Robert Vogle	53.3	LU	“Precedence has been established in placing power lines along transportation corridors such as Loop 303 and I-17.”	The EIS already acknowledges that the stretch along SR 74 was designated as a transportation corridor in Section 1.1.2 Section 1.3.2 details BLM’s purpose and need for the Project, including the need to amend the Bradshaw- Harquahala RMP to establish a utility corridor. The combined environmental impact of the Proposed Project with development of the transportation corridor is analyzed in Section 4.19 of the EIS.
Jacqueline Vogle Robert Vogle	53.4	SUP PA	“Placement of power lines along the north side of SR 74 is supported by Vistancia and Trilogy residents, City of Peoria officials and staff, Congressman Trent Franks, Congressman Ed Pastor, Congresswoman Gabrielle Giffords, Diamond Ventures, Arizona Governor Jan Brewer, Arizona Department of Transportation, Arizona State Land Department, Maricopa County and Maricopa Association of Governments, Cities of Surprise and Buckeye, Saddleback Heights and the Arizona Corporation Commission.”	Statement of preference.
Jacqueline Vogle Robert Vogle	53.5	GEN	“APS stated they would agree to abide by the certified route as approved by the ACC.”	Chapter 1 describes the ACC route in detail.
Jacqueline Vogle Robert Vogle	53.6	GEN	“The ‘Proposed Action Plan’ is fully supported by APS, local residents, city officials, Arizona Corporation Commissioners and congressional representatives who have all considered alternative routes and deem placement along the north side of SR 74 as the most logical location and on that will least affect families, pristine desert and wildlife.”	Statement of preference.
Jacqueline Vogle Robert Vogle	53.7	PH&S	“…the most pressing and paramount reason to place the lines on the north side of SR74 is to protect current and future home owners south of SR 74 from potential health risks. The United States National Council on Radiation Protection states, ‘There is a powerful body of impressive evidence showing that even low exposure to electromagnetic radiation has a long-term effect on health.’ Some effects listed in the report include sudden infant death, childhood leukemia, changes in brain chemistry, impairment of the immune system and inhibition of melatonin production which suppresses certain cancers. Considering the 500kV lines are the most powerful in existence, this statement is quite alarming.”	The effects of EMF are already analyzed for each alternative in Section 4.7.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Gene and Cheryl Sinkule John and Linda Foder Paul and Andrea Scheiner Michael and Natilie Heiger	54.1	SR74	“…we want to thank you for your hard work to resolve the placement of the transmission lines… for placement along Hwy 74.”	Statement of preference.
Art and Sandy Osier	55.1	VIS	“Please do not ruin our view by placing power lines in the area.”	The impact of the proposed transmission line on visual resources is analyzed in Section 4.14, along with proposed mitigation to minimize potential impacts. Figures and simulations in this section show the potential impacts to visual resources from various locations.
Art and Sandy Osier	55.2	SR74	“We only support SR74.”	Statement of preference.
Larry and Laura Pawlowski	56.1	SUP PA	“…[we] support APS placing their Sun Valley to Morgan 500/230kV Transmission line along the north side of SR 74/Carefree Hwy.”	Statement of preference.
Larry and Laura Pawlowski	56.2	OPP ALT3	“Please keep the power lines away from Vistancia!”	Statement of preference.
Laura Gainor	57.1	OPP ALT3	“I want to… thank BLM for… relocating the proposed route of this line away from Trilogy at Vistancia…”	Statement of preference.
Laura Gainor	57.2	SR74	” I want to… thank BLM for relocating the proposed route… along the Route 74.”	Statement of preference.
Dan Gainor	58.1	OPP ALT3	“I want to… thank BLM for… relocating the proposed route of this line away from Trilogy at Vistancia…”	Statement of preference.
Dan Gainor	58.2	SR74	” I want to… thank BLM for relocating the proposed route… along the Route 74.”	Statement of preference.
Mike Parkinson	61.1	SR74	“We only support alignment with (SR) 74…”	Statement of preference.
Mike Parkinson	61.2	OPP ALT3	“…and do not support any alignment in and around the Trilogy area.”	Statement of preference.
Steve and Irene Groch	62.1	VIS	“We are very concerned about having large visible power transmission lines near our property.”	The impact of the proposed transmission line on visual resources is analyzed in Section 4.14, along with proposed mitigation to minimize potential impacts. Figures and simulations in this section show the potential impacts to visual resources from various locations.
Steve and Irene Groch	62.2	SR74	“We only support alignment with (SR) 74.”	Statement of preference.
Robert Dreebin	63.1	INFO	“Where can I get a map of the proposed power line and where it goes?”	Dennis Godfrey replied on 12.11.12 directing commenter to BLM website.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Mark and Marlene Zebrowski	64.1	SR74	“We only support alignment with (SR) 74.”	Statement of preference.
Mark and Marlene Zebrowski	64.2	OPP ALT3	“Keep the power lines away from Trilogy…”	Statement of preference.
Mark and Marlene Zebrowski	64.3	GEN	“Why does this keep coming up?”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
Bryan and Patricia Stamp	67.1	OPP ALT3	“…we do not want high voltage transmission lines close to our existing homes.”	Statement of preference.
Bryan and Patricia Stamp	67.2	SR74	“Please use the alternative plan to put them by SR 74 where it is undeveloped and a low density residential area.”	Statement of preference.
Richard and Patricia Brown	73.1	SUP PA	“The proposed route for these power lines is the safest, is aesthetically superior, and has the least impact on property values.”	Statement of preference.
Wayne Carney	74.1	SOC	“What would your stockholders think about you spending their investment on running the power line across #74 for several miles and then back across the road to satisfy a developer?”	The opinion of APS’ stockholders regarding the value of the investment of the Proposed Action/Preferred Alternative is beyond the scope of the EIS analysis.
Wayne Carney	74.2	OPP PA	“…keep the line on the South side of the road.”	Statement of preference.
Mr. and Mrs. James Berg	75.1	SR74	“We only support alignment with (SR) 74.”	Statement of preference.
Mr. and Mrs. James Berg	75.2	OPP ALT3	“…we have moved to Trilogy because of it’s beauty and healthy atmosphere. We hope to live out our days here and will feel extremely disappointed if the power lines are brought in to our area.”	Statement of preference.
Mr. and Mrs. James Berg	75.3	PH&S	“With so much open land in the area, [we] do not understand why the lines must be places so near our homes, especially because of the potential health danger.”	Potential impacts for EMF are thoroughly analyzed in Section 4.7.
Ron Harris	76.1	INFO	“I was told the presentation info would be available on the BLM website…just curious what the timing is on availability…”	Dennis Godfrey replied that hearing info will be available on 12.17.12. Data is on website.
Kathy Allen	77.1	SR74	“My husband, Dennis, and I only support alignment with (SR) 74.”	Statement of preference.
Carol and Andy Rookwood	78.1	SUP PA	“We are so glad to hear that you have chosen the Certified Route as your preferred alternative for the power lines (north of State Route 74). We support that decision.”	Statement of preference.
Walter “Skip” Zahlmann	79.1	PH	“…This … is totally unacceptable as when no local, state or federal representative showed up at the Wittman hearing…”	Cooperating agencies were in attendance at various meetings and were appraised of the venues of all the meetings.
Walter “Skip” Zahlmann	79.2	PH	“…the people and residents of Wittman were not notified properly…”	Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project.
Walter “Skip” Zahlmann	79.3	PH	“…new and open hearings must be held so full disclosure regarding all aspects are made available to all concerned citizens.”	Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of public hearings were legally adequate.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Walter “Skip” Zahlmann	79.4	INFO	“who exactly are the people within the BLM –who will make the final decisions——————- I want the names and contact information”	Project contact information was distributed at the public hearings as well as the project website.
Walter “Skip” Zahlmann	79.5	PH	“who do we see and or contact about demanding a new hearing for the community of Wittman Arizona…. 4.] where do we send notice and a signed petition , and to whom, demanding additional hearings regarding the route through Wittman…”	Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of public hearings were legally adequate.
Walter “Skip” Zahlmann	79.6	INFO	“who are the representatives / congressman of Wittman Arizona who support –all the government representatives for Wittman local—State and federal.	Project contact information was distributed at the public hearings as well as the project website.
Walter “Skip” Zahlmann	79.7	SDA	“APS-was given literature that confirms the lines can be buried even for some long distances—- when the community of Wittman was told not possible for technical reasons—— simply not true”	Section 2.7.10 explains why Undergrounding the proposed transmission line was not carried forward for detailed analysis.
Walter “Skip” Zahlmann	79.8	SOC	” If one of the arguments made by Diamond Ventures and Sun Belt Holdings / Vistancia——- and they will be no closer than 2 miles—-and you accepted this reasoning————– how can the BLM than justify placing some of these towers within less than 100 yards of people’s homes in Wittman?”	The BLM decision on the proposed project would only apply to any BLM-managed public lands crossed by the proposed project and not land owned and managed by the Arizona State Land Department. The portion of the project that would affect people’s homes in Wittmann would not be on BLM-managed public lands and was proposed by the Arizona State Land Department. Other comments regarding private property impacts have resulted in changes and additions to Chapter 1, Section 1.1.2, clarifying the decision process of the State leading up to the ACC-certificated route. BLM did not design the route and therefore can or cannot justify the decision-making process for the route.
Robert Dreebin	80.1	INFO	“Where can I get a map of the proposed power line and where it goes?”	Dennis Godfrey replied on 12.11.12 directing commenter to BLM website.
Micah Rasner	81.1	OPP SAR	“I just recently learned about your proposal to erect these huge lines down Cloud Road in Wittmann and am outraged.”	Statement of preference.
Steve Speak	82.1	OPP PA	“I do not see placing an above ground powerline north of the highway a positive change…”	Statement of preference.
Steve Speak	82.2	VIS	“This is a prime travel way for people coming to Phoenix from Las Vegas and the powerline will totally destroy a tremendous scenic desert/mountain view these visitors will see.”	The impact of the proposed transmission line on visual resources and the mitigation to minimize impacts, and specifically the visual resources of SR 74, is analyzed in Section 4.14.
Steve Speak	82.3	OHV	“…the proposed powerline will result in the destruction of many miles of prime OHV single track trails in the Heiroglyphic Mountain OHV trail system. Specifically trails LP2, LP3 and LP1. These trails are an essential part of a loop trail system that was developed several years ago. Losing these trails not only results in the loss of the specific trail mileage but also destroys many more miles as these serve as integral parts of several trail loops. My family and many OHV friends use these trails almost every week so I do not want to see them destroyed.”	Several comments regarding impacts to OHV trails north of SR 74 resulted in clarifications made in Section 4.9, analysis of impacts to recreation, including OHV recreation. Access to OHV routes would not be lost under the Proposed Action/Preferred Alternative. In addition, additional mitigation for impacts to recreation has been included in Section 4.9.3.
Steve Speak	82.4	OHV	“…I think it is essential that the destroyed trails be fully replaced by an equal mileage of similar trails with the full costs of any environmental studies and trail construction to be paid by APS. Additionally, I would request that this work be done in parallel with the powerline installation so there are not several years of lost trail access before the new trails are constructed and put into use.”	Several comments regarding impacts to OHV trails north of SR 74 resulted in clarifications and additional information and analysis being made in Section 4.9, including OHV recreation. Access to OHV routes would not be lost under the Proposed Action/Preferred Alternative and single track trails would be protected. In addition, mitigation for impacts to recreation has been expanded in Section 4.9.3.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Barry Krayer	83.1	OPP PA	“I am upset that the BLM folded like a cheap suit under pressure from Diamond enterprises and a bunch of cry babies in Vistancia to site the power line north of Highway 74…”	Statement of preference.
Barry Krayer	83.2	OHV	“The power line will now destroy several miles of prime single track motorcycle trails that I have been riding for years (trails 1, 2, and 3). The least the BLM could do is make APS and Diamond pay to replace these popular trails somewhere at the Boulders OHV area.”	See response to Comment ID No. 82.4 above. Single-track motorcycle trails would not be destroyed under the Proposed Action/Preferred Alternative. Single-track trails would not be allowed to be used for construction access. In addition, while the centerline access route along the transmission line would be designated an Administrative Route, single-track trails intersecting the centerline would be allowed to cross the centerline access.
Thomas and Connie Kostelnik	85.1	SUP PA	“My wife and I are in complete support of the BLM’s Preferred Alternative…”	Statement of preference.
David and Nancy Field	86.1	OPP PA	“Any endorsement of the politically motivated route jumping north across SR 74 onto BLM land and running on that BLM land for 5 miles before again crossing back across SR 74 would be irresponsible.”	Statement of preference.
David and Nancy Field	86.2	NEPA	“Such a route could only be justified if there was no reasonable alternative.”	The NEPA does not provide direction as to which alternatives may, or should be, selected and implemented. Section 1505.2 of the NEPA, Record of Decision in Cases Requiring Environmental Impact Statements indicates that a record of decision shall, “Identify all alternatives considered by the agency in reaching its decision, specifying the alternative or alternatives which were considered to be environmentally preferable. An agency shall identify and discuss all such factors including any essential considerations of national policy which were balanced by the agency in making its decision and state how those considerations entered into its decision.”
David and Nancy Field	86.3	SOC	“Your study figures indicate it would be more expensive than the direct route on the south side of SR74.”	The commenter accurately presents information contained in the EIS.
David and Nancy Field	86.4	LU	“There is undeveloped private land on the south side that should be obtained for this project.”	Statement of preference.
David and Nancy Field	86.5	VIS	“A routing north of SR 74 would require a downgrade of the Visual Resource Management on 2,362 acres of BLM land and destroy one of the most scenic views in the area. Crossing the hi-way twice would also require impacting the east west views for travelers…”	The impact of the proposed transmission line on visual resources and the mitigation to minimize impacts, and specifically the visual resources of SR 74, is analyzed in Section 4.14.
David and Nancy Field	86.6	PH&S	“…as well as creating additional exposure and potential risks.”	Impacts to public health and safety from the transmission line crossing SR 74 were not identified as an issue or analyzed in the EIS as transmission lines routinely and safely cross roads and highways.
David and Nancy Field	86.7	SAAA	“The the proper routing for this Line should be Alternative 2 in your study. That routing is less expensive. has the least adverse visual impact and disturbs the least public land.”	Statement of preference.
Kathleen Heitkamp	87.1	OPP ALT3	“I am writing to support No Power Lines in Trilogy or Vistancia.”	Statement of preference.
Kathleen Heitkamp	87.2	SUP PA	“I support the preferred alignment of APS and the Arizona Corporation Commission, to move the power lines out of our community and onto public land (Bureau of Land Management) (State Route 74)…”	Statement of preference.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Susan and Rich Miller	88.1	SUP PA	“We are so happy that the BLM has identified the Proposed Action route crossing BLM lands.”	Statement of preference.
Susan and Rich Miller	88.2	SOC	“The Preferred route will minimize the socio-economic impact and help keep our property values…”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values. Additional information and analysis has been added to this section.
Robert and Patricia Plack	89.1	SUP PA	“This letter is to affirm our support for routing of power lines North of State Route 74…”	Statement of preference.
J.P. and Cherilyn Cook	90.1	SUP PA	“I’m writing in support of the Bureau of Land Management’s decision to create a utility corridor and utilize SR 74 as the Certified Route in support of APS placing their Sun Valley to Morgan 500/230kV Transmission line along SR 74/Carefree Hwy… placement along the north side of SR 74 as the most logical location and one that will least affect families, pristine desert and wildlife.”	Statement of preference.
J.P. and Cherilyn Cook	90.2	PH&S	“…protects current and future home owners south of SR 74 from potential health risks.	Potential impacts for EMF are thoroughly analyzed in Section 4.7.
J.P. and Cherilyn Cook	90.3	SOC	” Protects property values already negatively impacted by current economic conditions Maintaining or allowing for increasing property values will positively affect tax revenues which are currently suffering from current economic conditions Protecting property values maintains or increases funding revenue for schools throughout Peoria. We want to protect the vitality and future growth of our Master Planned community	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values and tax revenue.
J.P. and Cherilyn Cook	90.4	LU	” Precedence has been established in placing power lines along transportation corridors such as Loop 303 and I-17″	The EIS acknowledges that the stretch along SR 74 was designated as a transportation corridor in Section 1.1.2 Section 1.3.2 details BLM’s purpose and need for the Project, including the need to amend the Bradshaw- Harquahala RMP to establish a utility corridor. The combined environmental impact of the Proposed Project with development of the transportation corridor is analyzed in Section 4.19 of the EIS.
J.P. and Cherilyn Cook	90.5	VIS	“Power lines along a transportation corridor affects scenic views on a part-time basis; power lines along family communities affects scenic views 100% of the time”	The impact of the proposed transmission line on visual resources, and specifically the visual resources of SR 74, is analyzed in Section 4.14.
J.P. and Cherilyn Cook	90.6	VIS	“SR 74 is not officially designated as a scenic corridor”	The EIS clearly indicates that SR 74 is identified as a Scenic Corridor by Maricopa County, although it does not apply within the City of Peoria’s jurisdiction. See section 3.14.1.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
J.P. and Cherilyn Cook	90.7	LU	“SR 74 is slated to become a major transportation corridor; it seems that utilizing this area as a transportation/utility corridor would minimize environmental impacts to the area”	The EIS acknowledges that the stretch along SR 74 was designated as a transportation corridor in Section 1.1.2 Section 1.3.2 details BLM’s purpose and need for the Project, including the need to amend the Bradshaw- Harquahala RMP to establish a utility corridor in conjunction with the Proposed Action, Alternative 1, or Alternative 2. The combined environmental impact of the Proposed Project with development of the transportation corridor is analyzed in Section 4.19 of the EIS. This comment does not raise questions about the analysis or provide additional information for consideration.
J.P. and Cherilyn Cook	90.8	WLF	“Residents in Vistancia, Trilogy and Blackstone enjoy a multitude of wildlife in our community including coyote, javalina, roadrunners, bobcats, wild donkey, quail, rabbits and squirrels – surely alternative alignments in pristine desert will disturb these populations”	Impacts to wildlife and associated habitat (including sensitive species and their habitat) are analyzed and the mitigation to minimize impacts are both provided in Section 4.16.
J.P. and Cherilyn Cook	90.9	GEN	“Placement of power lines along the north side of SR 74 is supported…”	Statement of preference.
J.P. and Cherilyn Cook	90.10	GEN	“I respectfully request that BLM uphold your Resource Management Plan to allow placement of APS power lines on the north side of SR 74 described as the Certified Route.”	Statement of preference.
Walter “Skip” Zahlmann	91.1	PH	“…THIS IS A FORMAL REQUEST FOR ADDITIONAL MEETINGS…”	Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of public hearings were legally adequate.
Walter “Skip” Zahlmann	91.2	PH	“The turnout was not evidenced by considerable turnout-except those that were being paid to be there… not one single government person——- be they local, State, or Federal-being present at the Wittmann hearing-which did not include a single resident from Circle City—- “	Cooperating agencies were in attendance at various meetings and were appraised of the venues of all the meetings.
Walter “Skip” Zahlmann	91.3	INFO	“…please advise a.s.a.p.–who the people are and their contact information. If it is a committee—- I would want the names and contact information of the committee so these matters are directly informed to the proper people and the powers to be “	Project contact information was distributed at the public hearings as well as the project website.
Walter “Skip” Zahlmann	92.1	INFO	“Please get the information and reply to me the answers you get…”	Project contact information was distributed at the public hearings as well as the project website.
Walter “Skip” Zahlmann	92.2	PH	“NEW HEARINGS MUST BE HELD——————– “	Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of public hearings were legally adequate.
Walter “Skip” Zahlmann	93.1	PH	“why was the WICKENBURG SUN NOT NOTIFIED—————- AND OTHER LOCAL NEWSPAPERS IN THAT AREA THAT CONSIDER RT 74 A SCENIC HYW——- “	Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of and notifications for public hearings were legally adequate.
Walter “Skip” Zahlmann	93.2	SOC	“…the information about property going down at least 29% to upwards of 40% and maybe even more???????? and confirmed by one of the congressmen…”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values.
Walter “Skip” Zahlmann	93.3	INFO	“Do you have information on why Peoria made Quintero spend 8 to 10 million to bury their lines???”	Further discussion of this issue was provided in an email from Joe Incardine dated 1.28.13

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Walter “Skip” Zahlmann	93.4	INFO	“Now the BLM is covered by Federal law under the freedom of information————— so you have to provide the information or say you do not have———– or was not provided the information so the blame goes back to the City…”	No formal FOIA request submitted. Request for information beyond the scope of the BLM.
Walter “Skip” Zahlmann	93.5	PH	“NEW HEARINGS ARE MANDATED TO HAPPEN”	Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of public hearings were legally adequate.
Walter “Skip” Zahlmann	94.1	PH	“…THAT ALONE FORCES NEW HEARINGS TO BE HELD”	Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of public hearings were legally adequate.
Walter “Skip” Zahlmann	94.2	LU	“…THERE ARE MANY QUESTIONS REGARDING THIS COMMERCIAL PROPERTY ON THE SOUTH SIDE OF 74—— THAT THE BLM IS SUGGESTING THEY WANT TO PROTECT AND USE 9 MILES OF BLM LAND”	Future use of private lands south of SR 74 is described in Section 3.6.3.4 of the EIS.
Walter “Skip” Zahlmann	94.3	LU	“THE JOB YOU ARE PAID TO DO –THAT YOU AND YOUR ORGANIZATION———- THE BLM-IS TO PROTECT LAND SET ASIDE FOR THE AMERICAN PEOPLE———- “	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
Walter “Skip” Zahlmann	94.4	PH	“HOLD NEW MEETINGS WHEN THE BLM HAS ALL THE ANSWERS TO EXTREMELY IMPORTANT QUESTIONS, ALL THE DETAILS AND ALL THE INFORMATION THAT ARE EXTREMELY IMPORTANT TO MAKE ANY FINAL DECISIONS THAT INVOLVE PEOPLES LIVES AND FUTURE, ALONG WITH COMMUNITIES THAT HAVE BEEN HERE FAR LONGER THAN VISTANCIA AND SUN BELT HOLDINGS AND DIAMOND VENTURES…….”	Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of public hearings were legally adequate.
Walter “Skip” Zahlmann	94.5	SOC	“When speaking to one congressman———- he confirmed the de-valuation of people’s homes and properties with regards to these towers—-of a minimum of 29% to 40% in value——– THIS IS A CONGRESSMAN—— now this information also was not brought out by the BLM and never mentioned until the Wittman meeting [29% was mentioned] and the BLM did not address this issue when mentioned-avoided it completely really “	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values.
Walter “Skip” Zahlmann	94.6	SDA	“…APS got up to say the technology was not available to bury lines———–NOT TRUE——- maybe for long distances— but lines of this size are being buried all over the world…”	Section 2.7.10 explains why undergrounding the proposed transmission line was not carried forward for detailed analysis.
Walter “Skip” Zahlmann	94.7	SOC	“Just exactly when —–not planned dates or proposed dates—————- Will Diamond Ventures and Sun Belt Holdings, and Vistancia————-when exactly will they— Diamond Ventures, Sun Belt Holdings and New Vistancia start their projects for Saddleback Heights, Vistancia, etc, etc the commercial properties and when do they see completion of these projects——– 100% completion of the master plans for ALL RESIDENTIAL AND ALL COMMERCIAL PROPERTIES FROM PRESENT DAY Vistancia to south of Route 74 ?????????? We know Sun Belt Holdings has drastically changed their original master plan commitments to the City of Peoria—such as going from 15,000 homes to less than 10,000 –maybe more so what are the new projections ?????????????”	The estimated completion date for development of private land is only relevant to the analysis in terms of reasonably foreseeable projects that contribute to cumulative impacts, which are analyzed in Section 4.19 of the EIS.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Walter “Skip” Zahlmann	95.1	SOC	“What is the cost for the original routing by the ACC –going on the south side of 74 to the Morgan sub station ?????? total estimated cost”	Information on the cost of the Alternative 2 route South of SR 74 is contained in the EIS in Section 2.5.3. Costs of development of the Project along any route, including those alternatives dismissed from detailed analysis (Section 2.7) are contained in the discussion of each alternative.
Walter “Skip” Zahlmann	95.2	SOC	“What is the cost for the routing using the Cave Creek line from Sun Valley following the canal up to Morgan ???????? total estimated cost”	See Comment ID No. 95.1.
Walter “Skip” Zahlmann	95.3	SOC	“What is the total cost using those 9 miles of BLM land by going over and back again to Morgan—- -one estimate for the 9 miles over and back is between 3 and 6 million in today’s dollars. APS costs ? ????”	See Comment ID No. 95.1.
Walter “Skip” Zahlmann	95.4	SOC	“What is the cost of the nine miles in terms of land costs—actual today’s dollars it would cost for this land—Plus the commercial property value along this 10 lane highway that is in work for that area.???? Land values ?????”	The requested land values are not relevant to the analysis on the EIS.
Walter “Skip” Zahlmann	95.5	SOC	” I have been informed by one of the congressman——— that the depreciation in land value will be between 29% and 40 %-. –Wittman and Circle City, Please confirm this information and from what source. ?????”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values. Sources are cited in the text of the EIS and are contained in the References section of Chapter 7.
Walter “Skip” Zahlmann	95.6	PH	“If you do not have the information that is extremely important and vital to any hearing especially new ones—— then the new hearings must be held when the City of Peoria, Diamond Ventures, and Sun belt Holdings along with Cathy Carlat answering a whole lot of questions——– and we have all the information, all the documents, all the details and all the information that is needed before any decision can be made– We have to start over”	The comment calls into question the procedures followed by the agency for public meetings and does not raise questions about the analysis or provide additional information for consideration in the EIS. Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of public hearings were legally adequate.
Walter “Skip” Zahlmann	95.7	SDA	“AS BURYING LINES HAS BEEN DONE WORLD WIDE AND IS BEING DONE——— APS HAS TO ALSO RE-FOCUS ON THAT ISSUE ALONG WITH THE COSTS OF ALL ROUTES TO THE MORGAN SUB STATION.”	Section 2.7.10 explains why undergrounding the proposed transmission line was not carried forward for detailed analysis.
Walter “Skip” Zahlmann	96	UC	Content Unrelated to analysis
Walter “Skip” Zahlmann	97.1	SDA	“IF THIS IS TRUE———— THAN YOU HAVE TO FORCE APS TO BURY THEIR LINES THAT ARE ON BLM LAND FOR SOME 9 MILES—- “	Section 2.7.10 explains why undergrounding the proposed transmission line was not carried forward for detailed analysis.
Walter “Skip” Zahlmann	97.2	PH	“THIS TOO IS INFORMATION THAT WAS NOT BROUGHT OUT IN ANY HEARINGS IN THE PAST— SO AGAIN A CALL FOR NEW HEARINGS IS MORE THAN JUSTIFIED.”	Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of public hearings were legally adequate.
Walter “Skip” Zahlmann	101.1	NEPA	“As you so clearly state below———– and I quote – “ the BLM had asked the City of Peoria to be a co-operating agency some time ago “. WE KNOW FOR A FACT THAT THEY HAVE NOT THESE PAST 2 TO 3 YEARS”	Section 1.4 of the EIS provides information on agencies that elected to participate as cooperators in the Project.
Walter “Skip” Zahlmann	101.2	SOC	” some of my questions that I have asked the BLM-pertain to APS and their estimated costs for the different routes and ultimately the increased costs to all the rate payers and for how many years, etc, etc,”	See Comment ID No. 95.1.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Walter “Skip” Zahlmann	101.3	SDA	“… they can be buried when we were told they cannot…”	Section 2.7.10 explains why undergrounding the proposed transmission line was not carried forward for detailed analysis.
Walter “Skip” Zahlmann	104.1	NEPA	“Let’s be clear as to what the term “ Cooperating Agency “ means in real terms————————————————————————— I am sure they –the City of Peoria and the City Council and a specific council member claim to be cooperating——————— we know they have not as we the public have been asking for details, documents, documentation, meetings, minutes ,etc, etc,—— but we also know for “A fact “ that they have lied, used people to lie for them, have used a congressman that has no representation here in Peoria, have possible illegal connections to people and companies , have refuse to inform the public of many issues that they have been asked for under Arizona law and that you—the BLM– have confirmed those FACTs in -that they have not provided you—the BLM-with all the information that is required and we continue to ask the City of Peoria, the City Attorney and this specific council member——-and they have refused for the past 18 months the information requested——————————————————————— as you have confirmed they have been doing and continue to do at the present time.”	See Comment ID No. 101.1.
Walter “Skip” Zahlmann	104.2	PH	“New hearings must be held so everything is brought out for the public to read and hear————- not just what the BLM and the City of Peoria thinks is all we should know is what they have decided we should know. We know for a fact-people in Wittman and Circle City and that surrounding area along with the Wickenburg area- and newspaper-were also not notified and you have 120 plus signatures stating that as fact.”	Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of and notifications for public hearings were legally adequate.
Walter “Skip” Zahlmann	104.3	PH	“You-the BLM tried to continue a meeting without it being recorded and documented. There were no local or Federal officials who represent the Wittman area and surrounding areas———————————————————————- to be involved—– but you and the BLM claim to have a congressman / person who represents no one from this area at all-on Board—– yet when I spoke to them-they wanted nothing to do with the situation and asked me why –as they do not represent anyone from this area————————————————————————— “	Cooperating agencies were in attendance at various meetings and were appraised of the venues of all the meetings.
Walter “Skip” Zahlmann	104.4	SOC	“…another congressman told us point blank—— that property values will decrease up wards of 40% and that was never mentioned by anyone at any meeting————————————————————————— “	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values.
Walter “Skip” Zahlmann	106.1	INFO	“who is / are the main persons within the ACC and APS regarding these power lines and their placement, the contact person or persons at the ACC and APS————————————————————————– regarding these many issues. Especially the routes and costs involved in the different route proposals especially the one using BLM land—- “	Joe Incardine responded to individual on 1.3.13 indicating that EIS has information. Gave contacts at APS.
Walter “Skip” Zahlmann	106.2	NEPA	“It has been told to me—- that at the first meeting I attended at the BLM about a year ago at the BLM offices-that the final decision was already made as to the route————————————————————————— and that was using BLM land———- If certain decisions had pre-empted any meetings held by you and the BLM with and other concerned parties, regarding the proposed different routes that now were supposedly under consideration, please let us know and who to contact at that level-“	The EIS indicates that the Proposed Action is the agency preferred alternative and appropriate NEPA has and is being done. The agency’s final decision will be documented in a Record of Decision, which will be issued subsequent to publication of the Final EIS.
Walter “Skip” Zahlmann	106.3	NEPA	“That the other proposed routes were never in consideration and that was not the focus on that meeting or any meeting after—- This is new news to me and many others.”	Chapter 2 of the EIS provides information on all alternatives that are either analyzed in detail in the EIS or were considered but eliminated from detailed analysis.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Walter “Skip” Zahlmann	106.4	NEPA	“From what has been going on and explained to the communities—- that the application to the BLM, by the ACC, can still be rejected, not to use BLM land-and force the route to the south side of Rte. 74 ????”	Table 1.5-1 provides information on the decisions to be made by the BLM with regard to the project. Section 2.6 describes the No Action Alternative.
Leigh Johnson, Park Planner, Maricopa County Parks & Recreation Department	107.1	VIS	“Figure 4.14-20b (Key Observation Point 16) simulates the power lines as seen from Roadrunner Campground inside Lake Pleasant Regional Park. This view may disrupt the recreational experience of visitors who routinely respond in our Visitor Use Surveys that they value open, undeveloped views of the surrounding landscape.”	Impacts of the transmission line on the recreation experience at Lake Pleasant Regional Park are analyzed in Section 4.9.2.2 and the impacts on the visual resources of the Park are analyzed in Section 4.14. Mitigation measures for impacts to visual resources are provided in Section 4.14.4.
Leigh Johnson, Park Planner, Maricopa County Parks & Recreation Department	107.2	VIS	“Figure 4.14-17b (Key Observation Point 20) simulates the power lines as seen from the intersection of Castle Hot Springs Road and SR 74 looking south. As previously stated, the view may have impacts on park visitors seeking refuge from everyday development.”	The impacts of the transmission line on the recreation experience at Lake Pleasant Regional Park are analyzed in Section 4.9.2.2 and the impacts on the visual resources of the Park are analyzed in Section 4.14. Mitigation measures for impacts to visual resources are provided in Section 4.14.4.
Leigh Johnson, Park Planner, Maricopa County Parks & Recreation Department	107.3	OPP RMPA	“Changing the VRM from Class Ill to Class IV is a concern for our park’s visitor experience as they drive to and visit Lake Pleasant Regional Park.”	The impacts of the transmission line on the recreation experience at Lake Pleasant Regional Park are analyzed in Section 4.9.2.2 and the impacts on the visual resources of the Park are analyzed in Section 4.14. Mitigation measures for impacts to visual resources are provided in Section 4.14.4.
Leigh Johnson, Park Planner, Maricopa County Parks & Recreation Department	107.4	LU	“the City of Peoria and Maricopa County have both developed scenic corridor guidelines to maintain the high quality views along the SR 74 corridor.”	The impact of the proposed transmission line on visual resources, and specifically the visual resources of SR 74, is analyzed in Section 4.14. Mitigation measures for impacts to visual resources are provided in Section 4.14.4. Section 3.14.1 describes the scenic guidelines for the City of Peoria and Maricopa County.
Leigh Johnson, Park Planner, Maricopa County Parks & Recreation Department	107.5	VIS	“If APS takes a vegetation management approach underneath these proposed power lines (as it did in 2009 on the east side of Lake Pleasant) by razing all standing vegetation, this will further erode the very views and experiences that residents and visitors expect to find in this area.”	The impacts of the transmission line on the recreation experience at Lake Pleasant Regional Park are analyzed in Section 4.9.2.2 and the impacts on the visual resources of the Park are analyzed in Section 4.14. Mitigation measures for impacts to visual resources are provided in Section 4.14.4. BMPs, monitoring, and Vegetation Management are all thoroughly described in the EIS. Additional details on proposed vegetation management has been added to Chapter 2 and a revised Vegetation Management Program is included in Appendix 2B.
Leigh Johnson, Park Planner, Maricopa County Parks & Recreation Department	107.6	VIS	“MCPRD prefers the use of self-rusting utility poles that may blend into the landscape and a vegetation management policy that keeps vegetation intact to preserve the scenic Sonoran Desert views and experiences.”	Statement of preference. BLM is working to minimize visual impacts through the use of available colors for proposed transmission line structures, as described in Section 4.19.4.
Thelds Williams, District 1 Councilwoman	108.1	SOC	“I feel strongly that the comments and concerns of surrounding property owners should be taken into consideration.”	All comments and concerns are reviewed, evaluated, and considered.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Walter “Skip” Zahlmann	109.1	SUP NA	“…the most important issue——— if, or better stated, when the BLM denies the use of their land as they should—— APS has already stated they will go back to the drawing board, contact the ACC and come up with new proposals to get to the Morgan substation-without the use of BLM land.”	Additional information has been added to the No Action Alternative write-up in Chapter 2 and the ACC process in Chapter 1.
Walter “Skip” Zahlmann	109.2	LU	“…WE HAVE NO OPTIONS TO GET BACK THIS BLM LAND EVER-“	Section 2.3.2 describes that a ROW would be issued to APS for 30 years. Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
Walter “Skip” Zahlmann	109.3	SOC	“…the rate payers will pay only once——– not twice by, first one– adding to the increase to rate payers, the second one the destruction of extremely valuable land by using BLM land that can never be gotten back for the American people. { I have asked for the estimated value and cost of this land to the American people????} It can never be replaced because of the area and setting where it exists and for hundreds-thousands of years. The true value cannot be calculated in dollars…………………………………………………………………………………………………………………………………………………. we all know that.”	Section 4.10 has been updated to include how APS increases rates and whether it would depend upon which alternative is selected. Section 4.10 also includes a discussion of the impacts of the project to non- market values, such as recreation.
Walter “Skip” Zahlmann	109.4	LU	“As neither agency-the ACC nor APS can force the use of BLM land———– there is land south of rte. 74, and it disturbs no one or anything———- and will eventually be disturbed by a 10 lane highway and commercial development———— keeping BLM land as it was intended to be used and for all Americans. Not special interest groups such as the City of Peoria, paid elected officials and politician’s, and their special interests in Diamond Ventures and Sun Belt Holdings.”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
Walter “Skip” Zahlmann	109.5	PH	“We are asking for new hearings and an extension to the comment period———— and that is solely based on that there is so much missing , so many lies and false information, missing info, hidden info, purposely not providing info, public official’s lying and purposely using people and misinformation, people not being notified properly, petitions being sent to you with new ones coming, and so forth and so on.”	Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of and notifications for public hearings were legally adequate.
Walter “Skip” Zahlmann	109.6	SSS	“we “briefly” discussed some, not all of Quintero———– and the issues it raises. You mentioned it was about 200 acres—I mentioning the possibility of 600 acres—- the cost being discussed—not knowing , the desert tortious being on their land………. plus whether the City of Peoria did the proper studies they were required to do, to all Sun Belt Holdings and Diamond Ventures to build where these tortoises are located.”	Impacts to wildlife and associated habitat (including sensitive species and their habitat) are analyzed in Section 4.16.
Walter “Skip” Zahlmann	109.7	INFO	“I have not forgotten the previous e-mails and request for copies and details and information that I have asked for from the BLM. The same goes for one of your cooperating agencies—the City of Peoria-which so far has not even responded or made available any copies, financials, information , any details and meeting records and written correspondence between the parties——– Certainly if they have sent you anything from what we have asked for and or discussed———- then either the City should be instructed to release them or the BLM has to make available all communications between these too cooperating agencies-regarding such things as Diamond Ventures, Sun Belt Holdings, commercial property, re-zoning along rte. 303, etc, etc and not just limited to what I am briefly mentioning in this reply to your e-mail.”	Joe Incardine responded on 1.9.13 indicating that a package with information would be sent via FedEx. Package with select public documents was sent to commenter on 1.9.13. Portions of the request for information were beyond the scope of the BLM.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Walter “Skip” Zahlmann	109.8	LU	“AGAIN THE BLM SHOULD NOT BE USED—– THE LAND HELD IN TRUST FOR ALL AMERICANS…”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
Walter “Skip” Zahlmann	109.9	PR ROW	“…BLM REFUSED ONCE BEFORE THE USE OF THIS LAND…”	This information is already contained in Chapter 1, Section 1.1.2.
Walter “Skip” Zahlmann	109.10	GEN	“THE ONLY PERSON MAKING ANY NEW LAND—–IS GOD——– AND BY ALL MEASURES HE HAS DECIDED TO BEGIN TO TAKE AWAY LAND AND MAYBE BECAUSE WE ARE NOT USING THIS EXTREMELY PRECIOUS COMMODITY PROPERLY…”	Unrelated content.
Walter “Skip” Zahlmann	109.11	LU	“…THIS BLM LAND CAN NEVER BE REGAINED. IT HAS TO BE SAVED”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
Walter “Skip” Zahlmann	109.12	INFO	“I are requesting copies of all documents, letters, all written communications, etc, etc , between all parties, (APS, BLM, individuals, the ACC, etc, etc,.) regarding the appeals process that the APS undertook when the BLM refused the use of the land held in trust for the American People back in 2010. We are requesting all the reasons why APS was refused , and what specifically was the basis for the appeal that APS gave to the BLM for making the appeal [all reasons] the actual communications between the parties and their lawyers. It is my understanding that there were a number of issues-one being that there was a lack of openness and lack of certain information on the part of the BLM in rejecting the use of BLM land, giving APS room to make the appeal———- intentionally or un-intentionally by the BLM.”	Joe Incardine responded on 1.9.13 indicating that a package with information would be sent via FedEx. Package with select public documents was sent to commenter on 1.9.13. Portions of the request for information were beyond the scope of the BLM.
Walter “Skip” Zahlmann	109.13	OPP PA	“as we know there are far less damaging routes that are available and far less costly and far less damaging to people, COMMUNITIES, and wild life.”	Sections 2.5.1, 2.5.2, and 2.5.3 of the EIS explain Alternative 1, 2, and 3 routes, respectively, in detail, and these alternatives are analyzed in Chapter 4. Alternatives considered but dismissed from detailed analysis are contained in Section 2.7.
Walter “Skip” Zahlmann	109.14	LU	“…the BLM as the guardian of this land held in trust for All the American people———— can deny any and all requests to use this land for other purposes [such as APS towers }, just based on the fact that this land is held in trust for ALL the American people—- and can also deny any appeal to overturn the original decision to refuse access and use of this 9 mile stretch of BLM land.”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
Walter “Skip” Zahlmann	109.15	INFO	“We also want copies of all communications between the parties——- meetings, notes, minutes, who attended, where and when———- when it was decided to change the decision to refuse use of this BLM land———- and now having before us the proposal to use this BLM land for other purposes other than what Congress and the people of the United States had intended.”	Joe Incardine responded on 1.9.13 indicating that a package with information would be sent via FedEx. Package with select public documents was sent to commenter on 1.9.13. Portions of the request for information were beyond the scope of the BLM.
Walter “Skip” Zahlmann	109.16	GEN	“…when was this BLM land set aside by congress for its protection and for the sole use by the American people———- the month and year and under what congressional act.”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
Tony Dudzinski	110.1	SUP PA	“…please request that the APS power lines be built north of the Vistancia community on the north side of State Route 74…”	Statement of preference.
Bernadine McCollum	111.1	OPP FL	“I do not think APS should get approval for the transmission line across 9 miles of Federal public lands, destroying this corridor of saguaro-studded desert.”	Statement of preference.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Bernadine McCollum	111.2	SAAA	“APS should use the southern alternative where land has already been disturbed.”	Statement of preference.
Bernadine McCollum	111.3	SDA	“A more cost effective solution would be for APS to run the line along the existing canal route.”	Analysis of the CAP Complete route is contained in Section 2.7.4.
Jack and Cora Williams	112.1	SR74	“Jack and I are very supportive of the APS lines going on the SR 74 as was told to us in previous meetings.”	Statement of preference.
Jack and Cora Williams	112.2	OPP ALT3	“We, are residents of Trilogy, believe it would have a great impact on our property values if the plan were changed to the Vistancia area”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values.
Walter “Skip” Zahlmann	113.1	PH	“NEW HEARINGS ARE MUST AS WELL AS A MUCH LONGER COMMENT PERIOD SO THIS AND MANY OTHER THINGS THAT WE ARE NOW JUST DISCOVERING –CAN BE FOCUSED ON IN THESE NEW MEETINGS—— AND COMMENT PERIOD.”	Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of public hearings were legally adequate.
Walter “Skip” Zahlmann	113.2	LU	“The Federal Land Policy and management Act of 1976-clearly states the criteria for land disposal by the BLM—- 1.] Scattered and Isolated tracts that are difficult or uneconomical to manage 2.] Tracts acquired for a specific purpose that purpose no longer needed 3.] Land where disposal will serve important public objectives. [ there being no other options available.} We know APS has many options—— “	The Proposed Project does not involve a proposal by the BLM to dispose of public lands.
Walter “Skip” Zahlmann	113.3	PH	“THERE IS SO MUCH THAT HAS NOT BEEN DICUSSED IN THESE SO CALLED OPEN PUBLIC HEARINGS THAT IT IS A TRAVESTY TO THINK THAT THE BLM CAN MAKE ANY OTHER DECISION OTHER THAN TO DENY THE APPEAL BY APS AND DENY THE USE OF BLM LAND.”	Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of public hearings were legally adequate.
Merl Schafer	114.1	VIS	“Somehow I fail to see how the addition of 165 foot towers to the landscape will fulfill ‘the county’s strong interest in preserving the attractive Sonoran Desert landscape that SR 74 traverses for much of its length.’”	The impact of the proposed transmission line on visual resources, and specifically the visual resources of SR 74, is analyzed in Section 4.14. Mitigation measures for impacts to visual resources are provided in Section 4.14.4. The EIS also addresses Maricopa County’s Scenic Corridor, which allows for high voltage transmission lines.
Merl Schafer	114.2	OPP PA	“It seems to me to fulfill this statement, the power lines either have to buried on the BLM land and the landscape restored, or reject this proposal from APS. I am absolutely sure that if anyone other than APS came to you with a proposal to build anything 165 feet tall, the length of the BLM property, it would be immediately rejected.”	Statement of preference. Section 2.7.10 explains why undergrounding the proposed transmission line was not carried forward for detailed analysis.
Merl Schafer	114.3	INFO	“Please respond to me the rational of allowing this atrocity on our public land north of SR 74.”	Rationale is provided in Chapters 1 and 2 of the EIS document.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Walter “Skip” Zahlmann	115.1	SAAA	“IF WE KNOW THIS LAND ON THE SOUTH SIDE OF RET 74 WILL BE CHANGED FOREVER———- DRASTICALLY CHANGED destroyed –THEN WHY NOT DRASTICALLY CHANGE ONLY ONE SIDE-THE SOUTH SIDE OF RTE 74-AS WE KNOW THIS WILL BE DONE AND SAVE THE NORTH SIDE OF RTE. 74 –THE BLM LAND”	Statement of preference.
Walter “Skip” Zahlmann	115.2	VIS	“PLUS WILL SAVE A CONTINOUS SCENIC VIEW GOING NORTH FROM RTE. 74—- AS BLM LAND CONTINUES FROM THE NORTH SIDE OF RTE 74 NORTH FOR SOME DISTANCE”	The impact of the proposed transmission line on visual resources, and specifically the visual resources of SR 74, is analyzed in Section 4.14.
Walter “Skip” Zahlmann	115.3	GEN	“…your mission as being part of the BLM-to protect natures gift , the land, the wild life, the environment, protecting the wild vegetation, all things that is the true mission of the BLM from day one when it was set up by Congress.”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
Walter “Skip” Zahlmann	115.4	SAAA	“AND LET APS FIND THE OTHER OPTIONS THAT THEY KNOW THEY HAVE———— THE SOUTH SIDE OF RTE 74 IS GOING TO BE DEVELOPED AND DESTROYED LET APS BE A PART OF THAT DESTRUCTION AND THE BLM BE A PART OF SAVING AS MUCH AS IT CAN “	Statement of preference.
Walter “Skip” Zahlmann	115.5	SOC	“IT WILL ALSO SAVE MONEY AND THE RATEPAYERS MONEY…”	Section 4.10 has been updated to include how APS increases rates and whether it would depend upon which alternative is selected and if APS would have to go back to the ACC to restart the process and/or request a modification to the route.
Sierra Club on behalf of Rosemary Kist	116.1	OPP FL	“Please reject siting the proposed Sun Valley to Morgan 500/230kV Transmission Line Project on public lands…”	Statement of preference.
Sierra Club on behalf of Rosemary Kist	116.2	OPP RMPA	“…do not amend the Resource Management Plan to accommodate this siting.”	Statement of preference.
Sierra Club on behalf of Rosemary Kist	116.3	LU	“Siting this line on our public lands north of SR74 is not in the best interests of the public and does not support the mission of the Bureau of Land Management (BLM).”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need, which is supported by FLMPA.
Sierra Club on behalf of Rosemary Kist	116.4	LU	” Instead, it primarily benefits one developer, while sacrificing important public resources.”	The process that sites transmission lines is the responsibility of the Arizona Corporation Commission (ACC). The ACC line siting process is a public process that allows the public to comment.
Sierra Club on behalf of Rosemary Kist	116.5	OPP PA	“I am disappointed that the BLM’s Preferred Alternative in the Draft Environmental Impact Statement is to site this line to the north of State Route 74. The information in the DEIS indicates that this route could have a tremendous negative impact on resources, including on sensitive desert tortoise habitat, recreation opportunities, scenic beauty, and more.”	Statement of preference.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Sierra Club on behalf of Rosemary Kist	116.6	OPP RMPA	“The Resource Management Plan (RMP), which was published only a couple of years ago, determined that a transmission line right-of-way is inappropriate for this area due to the negative impacts it would have. Less than a year after the RMP was finalized, however, the developer began pushing the BLM to change it to accommodate this line proposal. The BLM should say no to the developer and continue to manage these lands for their natural resource values.”	Statement of preference.
Sierra Club on behalf of Rosemary Kist	116.7	OPP PA	“I strongly recommend that the BLM reject this proposal and maintain that this area is off-limits to transmission lines.”	Statement of preference.
Sierra Club on behalf of Rosemary Kist	116.8	SUP NA	“Please select the No Action Alternative in the DEIS and do not amend the RMP.”	Statement of preference.
Sierra Club on behalf of Rosemary Kist	116.9	GEN	“The financial gain of a small group is an inappropriate consideration when the duty of BLM is to serve the greater good of the PUBLIC.”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need. The ACC is the agency that determines utility locations.
Walter “Skip” Zahlman	199.1	OPP FL	“The BLM has to refuse the use of their land.”	Statement of preference.
Walter “Skip” Zahlman	200.1	NEPA	“…I met with a congressman’s office this morning for 2 hours plus—they attempted to do the same thing-but interesting ——claimed that the first meeting I went to some maybe 1 or 18 months ago— things were pretty much decided already and really no need for any meetings to just look good and maybe follow the law-“	The EIS is clear in Section ES.10 that a Record of Decision will be prepared after publication of a Final EIS and required reviews.
Walter “Skip” Zahlman	200.2	PR ROW	“I have a flyer from the BLM that back in 2010-rejected the use of their land ——-period——– one of the issues now—- the issue now comes to the front was why that has changed.”	This information is already contained in Chapter 1, Section 1.1.2.
Walter “Skip” Zahlman	200.3	PH	“…we demand NEW MEETTINGS –PRIOR TO ANY DECISION THAT THE BLM PLANS TO MAKE—“	Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of public hearings were legally adequate.
Walter “Skip” Zahlman	200.4	INFO	“…EXPECT THE COPIES OF DOCUMENTS, DETAILS, MEETINGS, EVERYTHING INVOLVING THE CITY OF PEORIA, the APS, and the Acc, and the answers to all of our questions that we have raised so far—— We will also be asking for the documents and information , details, all letters being written to the BLM –that the BLM has used and plan to use in the decision making process.”	No formal FOIA request submitted. Request for information beyond the scope of the BLM.
Walter “Skip” Zahlman	200.5	SOC	“One example used was the loss of property values in the 29 to 40% range————— nowhere is this mentioned at all.”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values.
Walter “Skip” Zahlman	200.6	PH	“Regarding proper notice———- well we know you have signed petitions of some 150 names so far the Wickenburg newspapers, and we have contacted local newspapers in the Wittman and Circle City areas-and they too have no knowledge——- and we will be canvasing these areas of some 8,000 residents and those that are only part timers———— but have a legal right to be informed and of such matters.”	Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of and notifications for public hearings were legally adequate.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Walter “Skip” Zahlman	200.7	SDA	“We will be approaching the ACC , APS, as they for the record claimed-they do not have the technology to bury lines——–that is an outright lie— “	Section 2.7.10 explains why undergrounding the proposed transmission line was not carried forward for detailed analysis.
Walter “Skip” Zahlman	200.8	INFO	“You have all the emails and requests for copies, especially the from the City of Peoria, of letters, financials, pros, and cons——especially from the elected officials—— and all of those requests still stand-and are even more important now that there are numerous issues that have never been brought up brought out, some hidden, some lied about, some just plain false—–and now we need answers— “	Request for information beyond the scope of the BLM.
Walter “Skip” Zahlman	200.9	PH	“WE ARE REQUESTING NEW HEARINGS FROM THE BLM”	Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of public hearings were legally adequate.
Walter “Skip” Zahlman	200.10	PR ROW	“I will mention that back in 2010-the BLM rejected the use of their land—— AS YOU PLAINLY ADMIT——– “	This information is already contained in Chapter 1, Section 1.1.2.
Richard Kaufman	201.1	NEPA	“On P.1-17 your Table 1.7.1″Formal Scoping … ” does not include the June 8, 2011 5:30-8:00 PM scoping meeting which included a representative of the Az. St. Land Dept., the Manager of the Lake Pleasant Regional Park, a spokesman for the Sierra Club and numerous members of the Public. More severely showing the BLM bias against the Public is the Economic Strategies Workshop’s (P.1-18) and in Table 1.8.2 (P. 1-19) statement amending the RMP “would benefit developers”.”	The June 8, 2011 meeting was an Economic Strategies Workshop, which is discussed in the EIS in Section 1.8. Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The referenced text is stating the issue as it was raised during scoping and is not expressing bias against the public on the part of the BLM.
Richard Kaufman	201.2	NEPA	“BLM did not have a workshop for Maricopa County Taxpayers who fund Lake Pleasant Park where over 1.5-million folks enjoyed themselves 2011, thanks to our Public and the BLM’s cooperation for over 58 years.”	Maricopa County taxpayers were invited to and welcome at any of the formal scoping meetings listed in Table 1.7-1 of the EIS. Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project.
Richard Kaufman	201.3	GEN	“Industrializing the vicinity near the BLM lands, buffering the Park’s entrance and lands westward along SR74, shows us that BLM’s words are broken.”	The comment does not raise questions about the analysis or provide additional information for consideration.
Richard Kaufman	201.4	SOC	“BLM did not have a workshop for APS Customers who will pay for Sun Valley-Morgan as electric rates will increase. We are APS electric-bill payers and rising rates should not be decided by the BLM. Rates will increase much more if the Proposed Action or Alternate-1 is BLM’s decision, and the ACC’s political decision on SV-M will remain; ACC set up BLM politically. BLM will hurt the Public rate wise because the Proposed Action/Aiternate-1 already are too expensive for SV-M.”	Section 4.10 has been updated to include how APS increases rates and whether it would depend upon which alternative is selected and if APS had to go back to the ACC process.
Richard Kaufman	201.5	SOC	“BLM missed Proposed Action/Alternate-1 additional millions in APS costs for crossing SV-M over the “10-lane wide freeway” SR74 will become as reported in the Draft- 20+ lanes wide for medians, shoulders, freeway lanes and spaces for the required safety-structures. Since APS will have to return for constructions as the freeway will be built in stages, millions, millions more, in costs APS will have. The Proposed Action and the Alternate-! each are way too costly. APS wants a SV-M construction once. Ratepayers want only one hearing raising electric bills.”	The potential impact of widening SR 74 is considered in the cumulative impacts to Socioeconomics in Section 4.19.11 and Transportation in Section 4.19.13. Given the estimated timeframe for the SR 74 expansion project (25 years or more in the future) any impacts to utility rates cannot be known.
Richard Kaufman	201.6	SUP NA	“We respectively select BLM’s “No Action Alternate” to be the Final EIS decision on SV-M.”	Statement of preference.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
See petition	202.1	PH	“Due to inadequate notification of the public hearing of the Proposed APS Sun Valley to Morgan 500/230KV Transmission Line Project and Proposed Resource Management Plan Amendment, the residents of the area that will be impacted by this project request another meeting.”	Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of and notifications for public hearings were legally adequate.
See petition	202.2	SOC	“The transmission line will have great, and long ranging effects on the community for health and safety, property value, recreational use, and the socioeconomic justice of that part of the community that has been identified as low income who were not represented.”	The EIS acknowledges the potential for significant impacts to public health and safety, recreation, EJ, and socioeconomics, and analyzes impacts to those resources in Sections 4.7, 4.9, and 4.10, respectively. Additional information was added to these sections as appropriate. The socioeconomics section analyzes impacts to low income communities.
See petition	203.1	PH	“Due to inadequate notification of the public hearing of the Proposed APS Sun Valley to Morgan 500/230KV Transmission Line Project and Proposed Resource Management Plan Amendment, the residents of the area that will be impacted by this project request another meeting.”	Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of and notifications for public hearings were legally adequate.
See petition	203.2	SOC	“The transmission line will have great, and long ranging effects on the community for health and safety, property value, recreational use, and the socioeconomic justice of that part of the community that has been identified as low income who were not represented.”	The EIS acknowledges the potential for significant impacts to public health and safety, recreation, EJ, and socioeconomics, and analyzes impacts to those resources in Sections 4.7, 4.9, and 4.10, respectively. Additional information was added to these sections as appropriate. The socioeconomics section analyzes impacts to low income communities.
Jeff Dixon	204a.1	SUP PA	“We as a community support the proposed route.”	Statement of preference.
Jeff Dixon	204a.2	OPP ALT3	“We don’t want to see power lines in the north end of our community.”	Statement of preference.
Jeff Dixon	204a.3	SOC	“The Draft EIS does recognize the decrease in property values. That’s very important. And it will have an impact on all the areas and the planned programming for the City of Peoria and others on private property. The proposed plan helps everyone.”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values.
Garrick Taylor	204b.1	SUP PA	“…the Arizona Chamber believes that the Sun Valley to Morgan Draft EIS preferred alternative, which includes a 200-foot electric transmission line right-of-way through approximately nine miles of BLM land, is consistent with the Department’s priorities and has minimal impacts, that can be mitigated, given its place next to existing and planned freeways.”	Statement of preference.
Garrick Taylor	204b.2	RENE	“The Sun Valley to Morgan line is an essential component of our region’s electricity service, providing powerful businesses and citizens alike. This line completes the reliability and redundancies of electric infrastructure around the Phoenix Metropolitan area, as well as provides the transmission opportunity to move solar and renewable energy to demand centers here in the southwest.”	Statement of agreement for information presented in Chapter 1.
Garrick Taylor	204b.3	SUP PA	“The Arizona Chamber supports the BLM’s DEIS recommendation for the preferred alternative.”	Statement of preference.
Walter “Skip” Zahlmann	204c.1	LU	“BLM land is land owned by the American people, not by Peoria, not by Vistancia, not by Trilogy, certainly not by any community. But, more importantly, it should never be used for a corporation by the name of Diamond Ventures.”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
Walter “Skip” Zahlmann	204c.2	VIS	“At no time during these meetings has Vistancia been going to be affected by these power lines…We were never going to see it. It doesn’t affect us.”	The impact of the proposed transmission line on visual resources is analyzed in Section 4.14.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Walter “Skip” Zahlmann	204c.3	PH&S	“Part of the argument…about all the health hazards and that, you know, if we keep going under these power lines, we’re going to grow an extra pair of legs…if the health issues that you have all raised, okay, are so important to you, now you’re saying: Let’s take this power line and cross over 74, a major highway, and …run it along BLM land…and you’re going to cross back down. So you’re forcing people on a major highway to go under these power lines that you all or some of you say is going to cause a second head or six fingers.”	Impacts to Public Health and Safety from all alternatives are analyzed in Section 4.7.
Walter “Skip” Zahlmann	204c.4	SOC	“What is it costing? I would like APS to tell us what it’s going to cost us to go along on the north — on the southern part, cross over 74, go nine miles across, and then cross back down. What is the cost going to be? Because every rate-payer, every citizen that uses APS, is going to have to pay for that cost. That’s an increase.”	Section 4.10 has been updated to include how APS increases rates and whether it would depend upon which alternative is selected.
Cathy Carlat	204d.1	GEN	“I would like to thank the Bureau of Land Management for their involvement and taking the time to do such a conclusive evaluation; taking into consideration environment and economic impacts, technical impacts; doing all of the things that they needed to do to perform their mission; producing a one-thousand page booklet that comes back to the preferred alignment…”	Statement of opinion.
Lynda Reithmann	204e.1	PH&S	“The issue is not whether or not we will be able to see the power lines. The issue is that there are serious health risks to these lines…the United States National Council on Radiation Protection that listed health effects from exposure to low levels of electromagnetic radiation. And these effects include sudden death –infant death syndrome, childhood leukemia, and Alzheimer’s.”	Impacts to Public Health and Safety under all alternatives are analyzed in Section 4.7. The information provided in this comment is consistent with information contained within the EIS.
Lynda Reithmann	204e.2	SOC	“…homes in close proximity to power lines decrease in value. Because of the poor economy, our property values have already seen a decrease, and we know that there will be eventual recovery from that. But our studies show that there will be no recovery when power lines are placed within communities.”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values.
Lynda Reithmann	204e.3	SUP PA	“we join forces…in supporting placement of the power lines along the north side of State Route 74…”	Statement of preference.
Lynda Reithmann	204e.4	OPP ALTs	“we continue to reject placement along the Alternative 2 and Alternative 3 alignments.”	Statement of preference.
David Field	204f.1	SOC	“…there’s a $3 million difference. $3 million more, to run that, that dangerous power line, across the highway, down along the north side, and then back across.”	The EIS acknowledges differences in construction costs between the alternatives.
David Field	204f.2	LU	“I do not understand why we are protecting the undeveloped private land, at the – the expense of the BLM land, which…is public land. I love that land up there. It’s a beautiful view…We’re never going to get new public undeveloped land. That’s disappearing. It’s disappeared too much in Arizona.”	Section 4.19.7.1 of the EIS describes the present and future development of lands within the cumulative effects area.
David Field	204f.3	SAAA	“We can run that power line, serve all the power it needs, run it on the south side of the highway, right along the highway. Protect BLM land. Protect the scenery.”	Statement of preference.
David Field	204f.4	SSS	“I don’t know how many of you have ever seen a desert tortoise…I have seen one…And I saw it, right up north of — of the land– of the road.”	Sections 3.16 and 4.16 provide information on the desert tortoise in the project area.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
David Field	204f.5	LU	“…we don’t need to tear that land up for the power line. The power line is going to serve public interest, housing interest, commercial development, everything else. It ought to stay on — on private land…”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
Sandy Bahr	204g.1	OPP PA	“The Sierra Club is very much opposed to the BLM’s proposal…to move the transmission line north of State Route 74.”	Statement of preference.
Sandy Bahr	204g.2	GEN	“It will open up sensitive habitat to additional degradation, as well as destroy the Phoenix corridor. “	Impacts to wildlife and associated habitat (including sensitive species and their habitat) are analyzed in Section 4.16. Mitigation measures are also addressed in the referenced section.
Sandy Bahr	204g.3	OPP PA	” We think that the BLM should reject the right-of-way application and also not change the Resource Management Plan, reject that, as well.”	Statement of preference.
Sandy Bahr	204g.4	RENE	“I’d love to see any bit of factual information that this transmission line would facilitate renewable energy. That is something that we look at very closely, and it’s a way to make things look better when — when they’re really not so great.”	The validity of the claim that the project would facilitate renewable energy would not change the proponent’s objectives or the BLM’s purpose and need for the project. Additional information on renewable energy has been added to Chapter 1.
Sandy Bahr	204g.5	OPP RMPA	“We think it’s inappropriate to change the RMP…”	Statement of preference.
Sandy Bahr	204g.6	SOC	“We think it’s inappropriate to…grant this right-of-way merely to advantage a developer who perceives that this transmission line will affect the value of his land or further benefit remote urban sprawl.”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
Sand Bahr	204g.7	LU	“As this proposal would affect public land, it’s supposed to be in the best interest of the public, rather than one individual private developer.”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
Sand Bahr	204g.8	GEN	“If the RMP is amended and the line is allowed to be built north of SR 74, we’re concerned that it will result in a significant degradation of the land and a diminished view, especially in light of the fact that the proposal would not only run along 74 but would actually cross it.”	The impact of the proposed transmission line on visual resources, and specifically the visual resources of BLM lands north of SR 74, is analyzed in Section 4.14. Mitigation measures for impacts to visual resources are provided in Section 4.14.4.
Sand Bahr	204g.9	LU	“This would nudge development further into the BLM lands and could result in a subsequent loss of interest by BLM to manage these lands for conservation.”	The EIS Table 1.5-1 explains the decisions to be made, and these decisions are specific to the future use of the public lands managed by the BLM.
Sand Bahr	204g.10	OPP PA	“…we urge BLM to reject this proposal.”	Statement of preference.
Donald Begalke	204h.1	NEPA	“I am very disappointed with the BLM’s Draft EIS because it has omitted scoping committee — scoping meeting, the invitation one that occurred on June 8th. And you don’t print the scoping material comments, at all. You just categorize it. That’s infuriating. That’s not right because we don’t have an opportunity to assess those.”	The June 8, 2011 meeting was an Economic Strategies Workshop, which is discussed in the EIS in Section 1.8. Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project.
Donald Begalke	204h.2	SOC	“I think your primary and your alternate routes are self-serving because you state, in the DEIS, that you want to protect developers. Why? Why one group over another group? Why a small minority over a large majority of APS customers? Why, over all of the millions of people that use the Lake Pleasant Regional Park–“	Section 1.1.2 has been revised to detail the Arizona Corporation Commission process that led to the development of the Proposed Action route. Section 2.2 details the development of the alternatives. Sections 2.5.1, 2.5.2, and 2.5.3 explain the rationale for development of the Alternative 1, 2, and 3 routes, respectively.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Donald Begalke	204h.3	REC	“…all of the millions of people that use the Lake Pleasant Regional Park –They’ve had 1.5 million more last year. Yet, in the Draft EIS, you only reported a 2006 total. Quite a difference over six years.”	In Section 3.10.6, 2010 data was used for visitation numbers, specific to Lake Pleasant Regional Park.
Donald Begalke	204h.4	NEPA	“BLM should not be involved in deciding the increase in the electric bills caused by a 500kV line and a 230 line. You should not be involved in a decision that should have been made in the community in October 20th, 2010.”	BLM’s purpose and need for action (and the legitimacy of BLM’s role in the process) are clearly documented in Section 1.3. Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
Donald Begalke	204h.5	SOC	“One very, very important part of the construction of the two lines north of State Route 74, is the cost, the very expensive cost of building high-powered transmission lines over a ten-lane-wide freeway that the Maricopa County Association of Governments plans for State Route 74.”	The potential impact of widening SR 74 is considered in the cumulative impacts to socioeconomics in Section 4.19.11 and Transportation in Section 4.19.13. Given the estimated timeframe for the SR 74 expansion project (25 years or more in the future) any impacts to utility rates cannot be addressed quantitatively.
Donald Begalke	204h.6	SUP NA	“I prefer the no-action alternative…”	Statement of preference.
Donald Begalke	204h.7	NEPA	“…the decision should lie with the Corporation Commission, on deciding these important items will — will fit customers, will fit recreationists, will fit educational opportunities for youth on the BLM lands adjacent to Lake Pleasant.”	BLM’s purpose and need for the project is clearly outlined in Section 1.3.
Harrianne Kopel	204i.1	SSS	“I would like to address the desert tortoise part of the program, seeing as the only time I’ve seen a desert tortoise was on the road, and it was not alive. I don’t know how you delineate where you’re going to prevent them from going across the road, but apparently they do.”	Sections 3.16 and 4.16 provide information on the desert tortoise in the project area.
Merl Schafer	205a.1	SOC	“The power lines…run along the — on the south side of 74. Then it crosses up over on the north side, runs along BLM land, and then drops back down south. Why would they do that? Because it’s cheap. Because the BLM land will give them the …land for pennies on the dollar…they’re going to…take the power line and put it on public land because they’re too cheap to go ahead and…pay the private price… Why is the government competing, unfairly, against the BLM and the commercial — the commercial land?”	The EIS already contains information about the cost of various alternatives in Sections 2.4, 2.5.1, 2.5.2, and 2.5.3.
Merl Schafer	205a.2	LU	“…on the BLM land, they’re going to have to put in these maintenance lines, now, for their towers. But you’re not allowed on that. This is public land, but you’re not allowed. The public service company is going to be allowed to go out and maintain their towers. But don’t you take your four- wheelers out there. Don’t take your sand rails. Don’t take anything out there. That’s only for commercial company, not for the public. Although it’s public land, and they’re protecting this land for us.”	More information on future maintenance activities has been added to Chapter 2 and recreational use allowed within the ROW has been clarified in the EIS. Additional recreation analysis and mitigation has been added to Section 4.9, including associated mitigation measures to reduce impacts.
Merl Schafer	205a.3	NEPA	“…we spent a lot of time here, last April, devising out all these other routes. And all of that was looked at by two independent groups, the environmental for the APS and the environmental for the government. And they all come up with the same thing. Nothing has changed. All of our ideas on all of that is put into the trash can, and they’re doing what they want to do.”	Section 2.7 explains that alternatives considered but eliminated from detailed analysis were developed in part through scoping meetings, then goes on to provide analysis of the ability of each alternative to meet the purpose and need for the project or the project objectives; or their technical and economical practicality and feasibility; or environmental reasonableness.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Merl Schafer	205a.4	NEPA	“Not a single thing changed from the last meeting. We drew 100 different maps, how they could reroute it, and all this other stuff. And you want to do it one more time? More input? What’s the input for? What do you do with our input?”	Numerous routes and potential alternatives were reviewed and evaluated. Section 2.7 explains that the alternatives considered but eliminated from detailed analysis were derived from public scoping meetings.
Bonnie Carmin	205b.1	OPP SAR	“I have property on Cloud. And my house is only about from here to the wall from Cloud. And so, if they put those big towers down 211 and turn on Cloud, like the sub-alternative is, they will be in my back yard…the State Land doesn’t want it to go anywhere else because it would ruin their value of their land. And it certainly would ruin the value of mine and also the aesthetic value…I just want them to know that going down Cloud is just not an option I can see because there’s people that live all along there. That transmission line would be…less than 200 yards from our houses.”	Statement of preference. No BLM land is involved in the Subalternative. The BLM decision on the proposed project would only apply to any BLM-managed public lands crossed by the proposed project and not land owned and managed by the Arizona State Land Department. The portion of the project that would affect people’s homes on Cloud Road would not be on BLM-managed public lands and was proposed by the Arizona State Land Department.
Bonnie Carmin	205b.2	PH&S	“I’m also concerned about the health issues if that transmission line is that close to a subdivision, where we have horses and people.”	Impacts to Public Health and Safety from all alternatives are analyzed in Section 4.7.
Ernest McCollum	205c.1	OPP PA	“They don’t need this power transmission line. I don’t know what the purpose of it is. They say they can’t go down the existing power line. Why? Because, if there’s an incident that creates a power outage on that line, then they still have this line. Well, if they’re separated by 50 yards on the other power line — I mean, the chances of lightning striking two times, right there in the same spot, is not very likely. So I don’t understand why they can’t use the existing power line that’s running down there.”	While redundancy is a consideration in the APS proposal, another consideration in the location of the transmission line is providing 230kV service in the north valley location, which could not be accomplished utilizing an existing ROW. Chapter 1 provides a description of the Background for this project.
Ernest McCollum	205c.2	WLF	“…the environmental impact on the wildlife coming through this — and it’s not just the BLM land; it’s all this other land out there — will affect the tortoises, the coyotes. And everything else is going to be affected out there. And the only thing they concentrated on was — was the tortoises. But what about the other wildlife that’s out there? They’re going to be affected also.”	Impacts to wildlife and associated habitat (including sensitive species and their habitat) are analyzed in Section 4.16.
Ernest McCollum	205c.3	LU	“APS comes along, all part of the government structure here, so they get to do what they want. But if I wanted to do something like that, if I wanted to put up a tower at my house with a windmill on it, I’d be told, “No,” by the County Government because it’s too high for the residential area, or something like that.”	The fairness of local government or application of decisions is beyond the scope of analysis of the document.
Tom Wilcox	205d.1	SOC	“…Quintero Golf Club…has been ranked in the top 100 modern golf courses in the United States, by Golfweek Magazine, nine straight years. There are currently 15 residences. They are all owned and occasionally occupied, I’d say. It’s mostly snowbirds. There is other construction preparing to go forward. Part of the selling point of all of this — And there’s over 100 million in this project already. Part of the selling point has been the pristine nature of the surroundings, being surround by BLM land.”	Statement of opinion.
Tom Wilcox	205d.2	VIS	“…when I get past Castle Hot Springs Road, all I see is native, beautiful Arizona desert. And to see these 150-foot-high towers running along one of the few stretches of highway, anywhere in metro Phoenix area, be ruined by this type of a — of a look, I think, would be an absolute crime.”	The impact of the proposed transmission line on visual resources, and specifically the visual resources of SR 74, is analyzed in Section 4.14.
Tom Wilcox	205d.3	WLF	“…two days ago, I saw two bobcats just flouncing across one of the fairways. Concerned for that kind of wildlife. Coyote. We’ve seen fox. Obviously, javelinas. Skunks, unfortunately. But beautiful wild birds and everything else.”	Impacts to wildlife and associated habitat (including sensitive species and their habitat) are analyzed in Section 4.16.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Tom Wilcox	205d.4	VIS	“It is an absolute pristine environment. And I, for one, personally — as well as on behalf of my property owners, on behalf of my club members, and on behalf of the public that play our golf course — would hate to see the experience ruined by this type of a happening on the way in.”	The impact of the proposed transmission line on visual resources, and specifically the visual resources of SR 74, is analyzed in Section 4.14.
John Thomson	205e.1	WLF	“…how many hawks and falcons do they expect to die on those poles?”	BMPs to address this concern are listed in Appendix 2A and potential impacts to raptors are analyzed in Section 4.16.
John Thomson	205e.2	SDA	“And how come they are not going underground? … Don’t tell me they’re not going to make their money back. It’s just going to take them a little bit longer.”	Section 2.7.10 explains why Undergrounding the proposed transmission line was not carried forward for detailed analysis.
John Thomson	205e.3	SOC	“…where I bought, when it was high. I paid a lot of money for that piece of property…A lot of money. The one — for an acre and a quarter. And now I’m going to see it go down from 20, 25, to 29 percent, after the — you know, after — during the recession. This is a nightmare.”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values.
John Thomson	205e.4	VIS	“It’s not only going to go in front of my house, on the side of my house, where my view is; I get to see it to the west and to the north of where I am.”	The impact of the proposed transmission line on visual resources is analyzed in Section 4.14.
John Thomson	205e.5	NEPA	“And I’d like to know what happened to the going over — over the CAP, okay, or even under the CAP? What happened to that? That’s — they had all the easements for that.”	Section 2.7.4 explains why the CAP Complete route was not carried forward for detailed analysis.
Richard Stallings	205f.1	PH&S	“High-voltage lines are –are not fit for humans to live close to. The — I live on Cloud Road. And I’m going to have a power line, right there, 100 feet from my house, because the easement is only 200 feet wide. So they can put it 100 feet from my property line, close to my house.”	Impacts to Public Health and Safety from all alternatives are analyzed in Section 4.7.
Richard Stallings	205f.2	NEPA	“Why…did they change the routing from the original designed-by-APS route, down the CAP Canal, the easement there, to somewhere where it had to pass through BLM land?”	Section 2.7.4 explains why the Cap Complete route was not carried forward for detailed analysis.
Richard Stallings	205f.3	SOC	“What’s the difference in the price of this proposal and the previous proposal that this changed from, and who’s going to pay the difference? … There was some proposal, going along the CAP Canal for part of the way and the existing utility right-of-way. There’s three power lines on it now or four? …And what’s the difference in the cost? The one that’s more direct to the Morgan Substation, Sun Valley, what’s the difference in cost, going that way and then this way, and who’s going to pay that difference?”	The cost of the alternatives analyzed in the EIS are provided in Chapter 2, along with the cost of each alternative considered but eliminated from detailed analysis (Section 2.7).
Daisy Anderson	205g.1	VIS	“I bought, out in Wittmann, so I would have beautiful sunsets. And I drive home, Happy Valley, and I see these beautiful 20, 30, whatever they are, K lines in the sunset. And I just go, ‘My gosh. If that’s coming to my back yard, I just don’t know what I’m going to do.’”	The impact of the proposed transmission line on visual resources is analyzed in Section 4.14.
Daisy Anderson	205g.2	SOC	“I’m a realtor. I sell the beauty of the sunset. And now I have to sell the beauty of the sunset in the transmission lines? And you already paid for your property. And I’m going to have to sell it.”	The impact of the proposed transmission line on visual resources is analyzed in Section 4.14. Mitigation measures for impacts to visual resources are provided in Section 4.14.4.
Kristina Jauch	205h.1	VIS	“I just moved here, not that long ago, to Wittmann, for the beautiful views. I do not want to see high power lines.”	The impact of the proposed transmission line on visual resources is analyzed in Section 4.14.
Kristina Jauch	205h.2	SOC	“And, now I’ve moved to Wittmann, and I find out: Yea, I get to deal with the corporate commission ruining my new property, based on high power lines.”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Kristina Jauch	205h.3	SDA	“And, again, it’s the year 2012. You can’t put the power lines underground?”	Section 2.7.10 explains why Undergrounding the proposed transmission line was not carried forward for detailed analysis.
Roxann Carlson	205i.1	PH&S	“I know, for a fact, EMFs cause cancer. We — I have personally purchased an EMF detector. You put it next to your microwave. And they tell you, ‘Don’t stand next to your microwave.’”	Impacts to Public Health and Safety from all alternatives are analyzed in Section 4.7.
Roxann Carlson	205i.2	VIS	“I came out here to live in this beautiful desert.”	The impact of the proposed transmission line on visual resources is analyzed in Section 4.14.
Walter Zahlmann	205j.1	OPP FL	“My argument here…is that BLM land should never be used for commercial — corporations.”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
Walter Zahlmann	205j.2	SOC	“If you’re going to move the line for a private corporation worth millions of dollars, then you can bury the lines to protect your values and your homes.”	Section 2.7.10 explains why Undergrounding the proposed transmission line was not carried forward for detailed analysis.
Susie Waggoner	205k.1	VIS	“Go underground. There is no reason to disrupt the beauty of Carefree Highway…”	Section 2.7.10 explains why Undergrounding the proposed transmission line was not carried forward for detailed analysis.
Susie Waggoner	205k.2	VIS	“…I drive home and I come down Carefree Highway and I look at that standing beautiful highway full of the saguaros. And, as the sun sets, I pull over and take pictures because it is beautiful. And to desecrate that is disgusting.”	The impact of the proposed transmission line on visual resources, and specifically the visual resources of SR 74, is analyzed in Section 4.14.
Susie Waggoner	205k.3	PH	“I live right here. There is no reason I didn’t hear from you before that. If your community outreach is in the paper, who the hell reads the paper? I’m not 90. I do everything online. The Arizona Republic charges you to read their stuff online now. That’s disgusting. Shame on you for not reaching out to the community that it’s going to impact.”	Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of and notifications for public hearings were legally adequate.
Susie Waggoner	205k.4	OPP RMPA	“…when I heard, earlier, that this is not conforming to BLM, if it’s not conforming, it’s for a reason it doesn’t conform. That’s because it’s not for the betterment of the land.”	Statement of preference.
Susie Waggoner	205k.5	SDA	“Bury it. Bury that damned power line.”	Statement of preference. Also, Section 2.7.10 explains why undergrounding the proposed transmission line was not carried forward for detailed analysis.
Ladona Stallings	205l.1	PH&S	“…my main issue is I live on Cloud Road. That’s my home. And this is going to go right in front of me. And, beyond how it’s going to look, I am extremely concerned about my health…If you put that there, then my house is absolutely worthless to me. I think, if you’re going to do that, you should condemn the property and pay for everybody’s out there, that you’re going to run this by, because you’re putting them at risk in their health.”	Impacts to Public Health and Safety from all alternatives are analyzed in Section 4.7.
Ladona Stallings	206a.1	EJ	“…the proposed line is — line is favored because it’s going away from the high-end Vistancia community in north Peoria. So that tells me that those of us that are going to have it in our neighborhood aren’t high-end or important enough…If you’re rich enough, a big corporation, got political influence, then it gets moved away from you. And then those of us who can’t fight it are just left out in the cold because we’re not important.”	Section 4.10 of the EIS has been revised to clarify socioeconomic and environmental justice impacts, and the relative proportion of impacts across communities.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Glen Collins	206b.1	SUP PA	“So I believe the BLM should issue this transmission line right-of-way on the proposed route. I believe that the 1967 line is an example of what will happen. The new power line will blend into the landscape of the new urban area. And our great-grandchildren, if they notice it, will accept it as a necessary support for their urban lifestyle.”	Statement of preference.
Franklin Schiller	206c.1	SR74	“I submit to you that the precedent has already been set. You have Route 74 going, smack-dab, right down the whole line of that. That’s already in there. I think it is beneficial to understand that everything has been done to try to minimize that effect by paralleling this existing disturbance going through the land.”	Statement of opinion.
Tiffany Sprague	206d.1	OPP PA	“I am astounded and, frankly, quite disappointed that the BLM has selected a preferred alternative that would allow this transmission line to be built on public lands, especially because, in the Resource Management Plan, it was determined that utility corridors were inappropriate for this area.”	Statement of preference.
Tiffany Sprague	206d.2	OPP RMPA	“It took years for the BLM to develop the Resource Management Plan. But less than two years after it was published, they’re willing to roll over and accept the first proposal to — to develop this area.”	Statement of preference.
Tiffany Sprague	206d.3	SUP NA	“I urge the BLM to choose either the no-action alternative or another alternative that would not allow these lands to be developed.”	Statement of preference.
Walter “Skip” Zahlmann	206e	UC	Content unrelated to analysis
Don Steuter	206f.1	LU	“Usually, when an area gets developed, when there’s a — there’s a project, a development of some sort, the threat, the danger, is that, eventually, the Bureau of Land Management loses interest in its lands. It becomes difficult to manage, for a variety of reasons.”	The EIS Table 1.5-1 explains the decisions to be made, and these decisions are specific to the future use of the public lands managed by the BLM.
Don Steuter	206f.2	VIS	“In 1993, Maricopa County convened a scenic-corridor task force…to take a look at Highway 74 and see what kind of recommendations we could come up with to preserve this corridor…74 was always a place that, when people from out of state came to visit me, it was one of my go-to places. I’d take them out along beautiful Highway 74, out towards Wickenburg, and show them some nice desert and show them what a nice place that we live in.”	The impact of the proposed transmission line on visual resources, and specifically the visual resources of SR 74, is analyzed in Section 4.14.
Don Steuter	206f.3	LU	“You’re talking now about a half-mile-wide corridor to the north of Highway 74. I mean, that’s as big a red flag as you can put out in front of somebody like — like us. I mean, that half-mile-corridor is going to – is going to end up getting developed.”	Changes in management of the BLM lands proposed in conjunction with the project are addressed in Table 1.5-1 and are analyzed throughout Chapter 4. The proposed management changes that would occur under the Proposed Action/Preferred Alternative include establishing a 200-foot wide single-use utility corridor north of SR 74, which would not allow for any additional development. The alternative multiuse corridor evaluated under Alternative 1(described in Section 2.5.1) would allow for additional future development within the corridor. Further, there is already an established 1/2-mile wide transportation corridor in this area.
Walter “Skip” Zahlmann	209.1	SSS	“FOR THE DESERT TORTOISE…IS THE BLM DEMANDING THE REQUIREMENT OF APS to purchase at least 600 acres…”	Mitigation measures specific to Sonoran Desert Tortoise specify procedures for compensation of habitat loss in Section 4.16.3.1 of the EIS.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Walter “Skip” Zahlmann	209.2	SSS	“…common sense will tell you that on the south side of Rte. 74…there has to be desert tortoise…”	Impacts to wildlife included desert tortoises, and associated habitat (including sensitive species and their habitat) are analyzed in Section 4.16.
Walter “Skip” Zahlmann	209.3	INFO	“THIS IS A FORMAL REQUEST FOR COPIES OF THE ENVIRONMENTAL STUDIES CONDUCTED BY THE CITY OF PEORIA REGARDING DESERT TORTOISE…THIS IS A FORMAL REQUEST FOR COPIES OF THE STUDIES MADE BY APS REGARDING THE DESERT TORTOISE…THIS IS A FORMAL REQUEST FOR COPIES OF THE STUDIES MADE BY STATE LANDS BEING USED REGARDING THE DESERT TORTOISE…”	Request for information beyond the scope of the BLM.
Walter “Skip” Zahlmann	209.4	PH	“NEW HEARINGS MUST BE HELD…”	Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of and notification for public hearings were legally adequate.
Walter “Skip” Zahlmann	209.5	SOC	“Loss of property values between 29 and 40% being given from another congressman as the correct figure..Never once discussed in an open hearing with the people who will be affected.”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values.
Walter “Skip” Zahlmann	210		Same exact letter as #115, just resubmitted
Walter “Skip” Zahlmann	211	UC	Content unrelated to analysis
Laura Saxon Morriston	212.1	PH	“Hold a new Public Hearing and Extended Comment Period. Due to inadequate notification for the public hearing of the Proposed APS Sun Valley to Morgan 500/230KV Transmission Line Project of December 12, 2012, at Nadaburg School and newly discovered information since that meeting, the residents of the area that will be impacted by this project find it absolutely necessary another public meeting be held. Our concerns that have not been addressed are as follows: 1. Improper notification of Wittmann, Circle City, and Morristown residents.”	Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of and notifications for public hearings were legally adequate.
Laura Saxon Morriston	212.2	INFO	” Our concerns that have not been addressed are as follows: 2.Continued refusal to provide Freedom of Information requests”	No formal FOIA requests were submitted.
Laura Saxon Morriston	212.3	PH&S	” Our concerns that have not been addressed are as follows: 3. Long range effects of Health and Safety”	Impacts to Public Health and Safety from all alternatives are analyzed in Section 4.7.
Laura Saxon Morriston	212.4	SOC	” Our concerns that have not been addressed are as follows: 4. Decrease of property values throughout the areas”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values.
Laura Saxon Morriston	212.5	WLF	” Our concerns that have not been addressed are as follows: 5. Unnecessary disruption of Endangered Species”	Impacts to wildlife and associated habitat (including sensitive species and their habitat) are analyzed in Section 4.16.
Laura Saxon Morriston	212.6	LU	” Our concerns that have not been addressed are as follows: 6. Conservation of pristine BLM land”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
Walter “Skip” Zahlmann	213	UC	Content unrelated to analysis

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Walter “Skip” Zahlmann	214	UC	Content unrelated to analysis
Trent Franks, Ed Pastor, Paul Gosar, Ann Kirkpatrick, David Schweikert, Ron Barber, Matt Salmon, Kyrsten Sinema	226.1	SUP PA	“We are writing in support of the Bureau of Land Management (BLM) selection of the Proposed Action as the Agency Preferred Alternative…”	Statement of preference.
Trent Franks, Ed Pastor, Paul Gosar, Ann Kirkpatrick, David Schweikert, Ron Barber, Matt Salmon, Kyrsten Sinema	226.2	GEN	“The Proposed Action establishes multi-use within the State Route 74 Designated Corridor; reduces potential transmission congestion and increases important redundancy and reliability of the electric grid around the Phoenix metropolitan area; expands opportunities for renewable energy use; and provides critical support and protection in the event of a natural disaster or threat to our national defense.”	Statement of preference.
Trent Franks, Ed Pastor, Paul Gosar, Ann Kirkpatrick, David Schweikert, Ron Barber, Matt Salmon, Kyrsten Sinema	226.3	LU	“We further stress that only the Agency Preferred Alternative (Proposed Action) is consistent with the local governmental plans including those of the City of Peoria, Arizona…”	The EIS evaluates the consistency of the EIS decisions with local government plans in several sections of Chapter 4, including Sections 4.6 and 4.14. The information contained in this comment is consistent with information provided in the EIS.
Priscilla Storm	234.1	INFO	“Are these in the DEIS? Can you please help me find them? If not, can you tell me what the acreage is-X,2? Miles around the Alternatives, put must be some overlap. Impacts are written as a % of carpus types of land within the Study Area.”	Joe Incardine responded on 1.22.13 via email with partial responses. Other responses in EIS.
Priscilla Storm	235.1	INFO	” ah-hah, found it – correct? Mapped?”	Discussion in provided in Chapter 2 of the EIS.
Thomas C Zimmerman	236.1	GEN	“The BLM’s (preferred) ‘Proposed Action’ route for SV-M and the ‘Alternate-1’ route are identical routes on BLM-managed lands North of State Route 74, and are equally the longest routes and most expensive routes to build. The corridor widths are the only difference, and why ‘Alt-1’s’ is 1/2 mile wide is very scary and the Draft wrongly provides no fill-in details.”	Section 2.5.1of the EIS explains Alternative 1 in detail, including the rationale for the alternative.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Thomas C Zimmerman	236.2	SOC	“The Draft provides that SR74 will become a 10-lane freeway, and deliberately omits the costs for two required very, very expensive ‘safety structures’ that must be built for high-voltage lines to cross a freeway. Additionally, as freeways in Az. Are constructed in stages, BLM fails to provide the additional construction costs for one time, two times, three times or …additional constructions – ??”	The potential impact of widening SR 74 is considered in the cumulative impacts to socioeconomics in Section 4.19.11 and Transportation in Section 4.19.13. Given the estimated timeframe for the SR 74 expansion project (25 years or more in the future) any impacts to utility rates cannot be addressed quantitatively. APS has planned for the location of the transmission line to essentially be situated outside of the proposed future SR 74 road expansion area based upon known information at this time. The transmission line structures at the crossings of SR 74 could potentially need to be moved in the future depending upon the ultimate design and build out of the SR 74 expansion.
Thomas C Zimmerman	236.3	SOC	“For the P.A. and the Alt-1 routes, the construction costs’ factors are 1.25 to 1.30. Will electric rate increases be 12.50%, 13.00% or how high?”	Section 4.10 has been updated to include how APS increases rates and whether it would depend upon which alternative is selected.
Thomas C Zimmerman	236.4	SOC	“Two routes in the Draft are “Alternate-2” and “Alternate-3”, both South of SR74, not on BLM lands, not crossing a freeway twice, not requiring special structures, not as long as the expensive BLM “P.A.” and “Alt.-1″. The constructions costs’ factors are 0.99 and 1.00. Electric rate increases might be 10.00% or lower. Electricity users reimburse the utility for all construction costs, and those reimbursements are rate increases on businesses, governments, school districts, residents, civic/social organizations and other-affected ratepayers.”	Section 4.10 has been updated to include how APS increases rates and whether it would depend upon which alternative is selected.
Thomas C Zimmerman	236.5	SAAA	“We do not want either of BLM’s expensive routes having highest construction costs’ factors. All parties agree SV-M is needed, but should be constructed at reasonable costs. BLM can only recommend either “Alt.-2” or “Atl.-3″.”	Statement of preference.
Thomas C Zimmerman	236.6	SUP NA	“Thus, BLM’s fifth option in the Draft is the “No Action Alternative”, and that is the preferred outcome on your Sun Valley-Morgan EIS process for the Public, for businesses, for local and Az. State governments, for school districts, for residents, for civic/social organizations and for other-affected ratepayers. Also, the “No Action Alternative” solution is chosen by business-taxpayers, employee-taxpayers and their families and all other taxpayers regarding the SV-M Line issue, and our taxes are paid to the federal government plus State and local governments, too.”	Statement of preference.
Thomas C Zimmerman	236.7	SUP NA	” Finally, many, many “positives” are on the BLM-managed Public Lands North of SR74. Keep them all undisturbed, and on track!!	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
Thomas C Zimmerman	236.8	SUP NA	“BLM’s mission for the Public is to manage and protect the Public Lands and all forms of life.”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
Thomas C Zimmerman	236.9	SUP NA	” If “Mother Nature” had a voice, she would tell the BLM that the Final EIS decision on Sun Valley-Morgan would be “No Action Alternative”!!!!!!!!!!!!!”	Statement of preference.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Priscilla Storm	237.1	INFO	” Is this correct interpretation of how DEIS impacts of transmission line on adjacent land are represented? ROW is 200′ wide There are 5,280 linear ft in mile There are 43,560 sq ft in acre Each mile is 24.24 acres of ROW Transmission line could undulate between edges of ROW DEIS states impacts to adjacent uses greatest 200′ from transmission line DEIS inference is that impact area is 400′ (if line is in middle of ROW + 200′) To be conservative, the zone of most direct, (from DEIS perspective)high impacts to adjacent area and land use is 600′ (transmission line moves within 200′ ROW, including to ROW perimeter) Is this what you intended the reader to discern? If I am wrong, can you clarify, thanks”	Joe Incardine provided info to commenter on 1.22.13 via email.
Priscilla Storm	238.1	INFO	“If ROW undulates to keep transmission line more or less in the center of the 200′, that could create isolated land fragments too. Different scenario than if ROW is basically straight and parallel or abuts property line and transmission micro-siting has line undulating with ROW.”	Discussion is provided in Chapter 2 of the EIS on why undulation might occur due to micro-siting efforts and attempting to minimize potential impacts.
Jack Sasser Mary Oliver Sasser	239.1	SUP PA	“We reside in the Vistancia Trilogy neighborhood and we fully support your preferred alternative, the Certificated Route/North of State Route 74.”	Statement of preference.
Trina and Wayne Fredrickson	240.1	OPP SAR	“Please accept this letter as our written objection to any transmission line being constructed along Cloud Road.”	Statement of preference.
Trina and Wayne Fredrickson	240.2	PH&S	“We are very concerned about the potential health hazards that the transmission lines would cause to ourselves, our neighbors, and our pets and livestock.”	Impacts to Public Health and Safety from all alternatives are analyzed in Section 4.7.
Trina and Wayne Fredrickson	240.3	NOISE	“Our other concerns are with regard to the noise that will be created by these large transmission lines and our property values.”	The impacts from and mitigation of noise generated by the proposed transmission line are analyzed in Sections 4.7.2.1 of the EIS. Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values.
Trina and Wayne Fredrickson	240.4	SOC	“Our property values would continue to plummet, going from bad to worse!”	The EIS analyzes impacts to private property values in Section 4.10.
Trina and Wayne Fredrickson	240.5	SUR	“If anything, our preference is that the lines be constructed further out on the School Trust Land and closer to Highway 74.”	Statement of preference.
Tim Kasovac	241.1	PH	“On P.1-17 your Table 1.7.1 “Formal Scoping…” does not include the June 8, 2011 5:30-8:00PM scoping meeting which included a representative of the Az. St. Land Dept., the Manager of the Lake Pleasant Regional Park, a spokesman for the Sierra Club and numerous members of the Public.”	The June 8, 2011 meeting was an Economic Strategies Workshop, which is discussed in the EIS in Section 1.8. Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of public hearings were legally adequate.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Tim Kasovac	241.2	SOC	“More severely showing the BLM bias against the Public is the Economic Strategies Workshop’s (P.1-18) and in Table 1.8.2 (P1-19) statement amending the RMP ‘would benefit developers.’”	Table 1.8-2 provides a summary of issues from Scoping, which includes the Economic Strategies Workshop. The issue referenced by this comment is that the process of amending the RMP should consider whether or not it is appropriate to amend the RMP in such a way that would benefit developers. The referenced text is stating the issue as it was raised during scoping and is not expressing bias against the public on the part of the BLM.
Tim Kasovac	241.3	PH	“BLM did not have a workshop for Maricopa County Taxpayers who fund Lake pleasant Park where over 1.5-million folks have enjoyed themselves 2011, thanks to our Public and the BLM’s cooperation for over 58 years.”	Maricopa County taxpayers were invited to and welcome at any of the formal scoping meetings listed in Table 1.7-1 of the EIS. Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of public hearings were legally adequate.
Tim Kasovac	241.4	LU	“Industrializing the vicinity near the BLM lands, buffering the Park’s entrance and lands westward along SR74, shows us that BLM’s words are broken.”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
Tim Kasovac	241.5	SOC	“Also, BLM did not have a workshop for APS Customers who will pay for Sun Valley-Morgan as electric rates will increase. We are APS electric-bill payers and rising rates should not be decided by the BLM. Rates will increase much more if the Proposed action or Alternate-1 is BLM’s decision, and the ACC’s political decision on SV-M will remain; ACC set up BLM politically. BLM will hurt the Public ratewise because the Proposed Action/Alternate 1 already are too expensive for SV-M.”	Section 4.10 has been updated to include how APS increases rates and whether it would depend upon which alternative is selected.
Tim Kasovac	241.6	SOC	“BLM missed Proposed Action/Alternate-1 additional millions in APS costs for crossing SV-M over the ’10-lane wide freeway’ SR74 will become as reported in the Draft – 20+ lanes wide for medians, shoulders, freeway lanes and spaces for the required safety structures. Since APS will have to return for constructions as the freeway will be built in stages, millions, millions more, in costs APS will have. The Proposed Action and the Alternate-1 are way too costly.”	The potential impact of widening SR 74 is considered in the cumulative impacts to socioeconomics in Section 4.19.11 and Transportation in Section 4.19.13. Given the estimated timeframe for the SR 74 expansion project (25 years or more in the future) any impacts to utility rates cannot be addressed quantitatively.
Tim Kasovac	241.7	SUP NA	“We respectively select BLM’s ‘No Action Alternative’ to be the Final EIS decision on SV-M.”	Statement of preference.
Walter ‘Skip’ Zahlmann	244	UC	Content unrelated to analysis
Walter ‘Skip’ Zahlmann	245.1	SSS	“be that these desert tortoises and their habitat are protected————– legally and by the Federal Government——- and that one could clearly argue that they live and have habitat on both sides of Rte 74—-be it land protected by BLM—- or land the City of Peoria wants to have commercially developed– ———-YOU–THE BLM MUST HAVE TAKEN INTO CONSIDERATION THESE PROTECTED TORTOISES AND THEIR HABITAT AS THE LAND USE BY APS HAS OPTIONS FOR BOTH SIDES OF THIS RTE 74″	Impacts to wildlife and associated habitat (including sensitive species and their habitat) are analyzed in Section 4.16.
Walter ‘Skip’ Zahlmann	245.2	SSS	“Again if the BLM allows the use on the north side———–which you once rejected————– are you and the BLM suggesting that the desert tortoise will just have to pack up and walk across this 10 lane hi-way only to find the same reception across the street on the south side and completely paved over.???? So the BLM is considering destroying the desert tortoise and its habitat————- ON BOTH SIDES NORTH AND SOUTH————— OF RTE 74″	Impacts to wildlife, including desert tortoises, and associated habitat (including sensitive species and their habitat) are analyzed in Section 4.16.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Walter ‘Skip’ Zahlmann	245.3	SSS	“yet now that the APS wants to use this land———- and a far greater amount, running some 9 miles on the north and south side of Rte 74-there is no damage to these desert tortoises and their habitat????? And at the same time you KNOW–the BLM KNOWS—— THAT THE LAND ON THE SOUTH SIDE, will totally destroy the desert tortoise and its habitat on the south side in the years to come—- ——SO THERE WILL BE NO DESERT TORTOISE ON EITHER SIDE OF RTE 74 IN THE YEARS TO COME. YOU JOB AND THAT OF THE BLM IS TO PROTECT THESE FEDERALLY PROTECTED TORTOISES AND THEIR HABITAT———-AND KNOWING WHAT YOU KNOW———— YOU ARE LEGALLY REQUIRED TO PROTECT THEM———— “	Impacts to wildlife, including desert tortoises, and associated habitat (including sensitive species and their habitat) are analyzed in Section 4.16.
Micah Rasner	246.1	OPP SAR	“I have a home on Caravaggio, which is the next road over from Cloud. I have just learned about this proposed high line, high tower, utility crossing down, proposed apparently, right down Cloud Road, which is just north of my house. I have great opposition to this…”	Statement of preference.
Robert and Linda Lindgren	264.1	SR74	“I live in Trilogy at Vistancia and I agree and support the power lines being put were they are to be located in the 7 mile corridor along SR74.”	Statement of preference.
John Cacciato	265.1	OPP ALT3	“I am a resident of Trilogy and like other residents am opposed to have the proposed power lines running through the native desert north of Vistancia.”	Statement of preference.
John Cacciato	265.2	SR74	“I am in favor of using the route along SR74.”	Statement of preference.
Karla Wilson	266.1	SUP PA	“I still prefer the Proposed Action, with the 200-foot wide right-of-way and single use corridor within the Arizona Corporation Commission certificated route. I understand that the RMP would need to be amended. The lines should go north of the 74 highway.”	Statement of preference.
Jack S. Tuber, D.O.	267.1	SAAA	“This letter is addressing the change in siting of the proposed Sun Valley to Morgan 500/230kV Transmission Line Project. It was originally to be placed south of SR-74 and this is still the most appropriate siting for this line.”	Statement of preference.
Jack S. Tuber, D.O.	267.2	OPP RMPA	“…only two years ago, the Resource Management Plan determined that siting the transmission line north of SR-74 was ‘inappropriate’ due to the negative impacts it would have.”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need. Chapter 1 also describes why an RMP amendment is needed.
Jack S. Tuber, D.O.	267.3	SOC	“Furthermore, the ‘northern’ route for the transmission line would increase costs for Arizona Public Service Company rate payers which includes me.”	Section 4.10 has been updated to include how APS increases rates and whether it would depend upon which alternative is selected.
Jack S. Tuber, D.O.	267.4	SOC	“It appears as though the BLM is considering and approving what is in the best interest of a single developer who will substantially gain financially from the proposal.”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
Jack S. Tuber, D.O.	267.5	SUP NA	“I strongly recommend that the BLM…select the No Action Alternative…”	Statement of preference.
Jack S. Tuber, D.O.	267.6	OPP RMPA	“Do not amend the RMP…”	Statement of preference.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Ladona Stallings	288	INFO	Left voice message with personal information, so she could be included on the Project Mailing List.	Provided information was included in the Project Record and added to the Mailing List.
Theodore Karsen	300.1	SUP PA	“I want to formally support the proposed APS power lines slated for BLM route along north side of SR74”	Statement of preference.
Vicki Fredrickson	310.1	SUP PA	“I am writing to express my support to allow APS to run their power lines along the 7-mile corridor on the north side of SR74.”	Statement of preference.
John Stephens	311.1	SUP PA	“I just wanted to let you know that my wife and I strongly support the BLM decision to locate the proposed APS power line along SR 74.”	Statement of preference.
Mark Shreffler	313-1	OPP PA	“Let the BLM stand firm in protecting the public land north of 74.”	Statement of preference.
Mark Shreffler	313-2	LU	“And please consider relaxing overly regulated rules of clearing land along the route. A right-of- way so absurdly wide seems wasteful. I have seen a photograph of a harmless saguaro cactus chopped down 70%.”	Appendix 2B, corresponding text in Chapter 2, and analysis related to vegetation management in Chapter 4 have been revised to specify management of saguaro cactus in the ROW in conjunction with construction, as well as ongoing maintenance activities.
Michael & Susan Barrena	325.1	SUR	“We support the proposed route for the power lines in Peoria, AZ through BLM land.”	Statement of preference.
Candace Hitchcock	326.1	SUP PA	” I am writing you to indicate my support for the agreed upon APS power line route on BLM land along the north side of SR74. This would keep the proposed power lines out of the native desert north of Vistancia.”	Statement of preference.
Wayne Hitchcock	327.1	SUP PA	” I am writing you to indicate my support for the agreed upon APS power line route on BLM land along the north side of SR74. This would keep the proposed power lines out of the native desert north of Vistancia.”	Statement of preference.
Niki and Betty Shrode	328.1	SUP PA	“My wife and I strongly support the placing of the APS Power lines on BLM property adjacent to SR74. They belong along the public right of way not through or close to or in view of residential developments.”	Statement of preference.
Kate Waite	329.1	SUP PA	“I just want to add my complete support for the selected route along the north side of SR74. As National Project Manager for the proposed APS power lines, I want to convey my agreement with the final proposed APS power lines along the seven miles corridor of SR74. This plan will keep the power lines out of the native desert north of Vistancia.”	Statement of preference.
Martin and Jo-Ellen Hirsch	330.1	SR74	” We support the 7 mile area along SR74 designated for power lines”	Statement of preference.
Neeta Steinbrook	331.1	SR74	“This email is to support keeping the proposed power lines on the BLM land along highway 74….. We are residents of Trilogy at Vistancia and adamantly oppose power lines near residential areas.	Statement of preference.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Roger Forsyth	332.1	SUP PA	” I would like to provide my support for the APS Sun Valley to Morgan Transmission line on BLM land north side of SR74.”	Statement of preference.
Bertina Wright and Jim Finch	333.1	SR74	“I live in Trilogy at Vistancia and am writing you to tell you of our support for the line to run through the land owned by the BLM along SR74.”	Statement of preference.
Walter Skip Zahlmann	335	UC	Content unrelated to analysis
Walter Skip Zahlmann	336	UC	Content unrelated to analysis
Niki and Betty Shrode	363.1	SR74	“My wife and I strongly support the placing of the APS Power lines on BLM property adjacent to SR74. They belong along the public right of way not through or close to or in view of residential developments.”	Statement of preference.
Neeta Steinbrook	364.1	SR74	“I am a resident of Trilogy at Vistancia and I adamantly oppose the placement of the proposed power lines anywhere near residential areas. I support the proposed route along highway 74 on BLM land. We here at Vistancia are united in our continued fight to keep these power lines away from our homes!”	Statement of preference.
Wayne Hitchcock	387.1	SUP PA	” I am writing you to indicate my support for the agreed upon APS power line route on BLM land along the north side of SR74. This would keep the proposed power lines out of the native desert north of Vistancia.”	Statement of preference.
Candace Hitchcock	388.1	SUP PA	” I am writing you to indicate my support for the agreed upon APS power line route on BLM land along the north side of SR74. This would keep the proposed power lines out of the native desert north of Vistancia.”	Statement of preference.
Nicholas Enoch, Lubin & Enoch, P.C.	389.1	SUP PA	“…we support the BLM’s Preferred Alternative, as identified in the Draft Environmental Impact Statement for the proposed Sun Valley to Morgan Project.”	Statement of preference.
Nicholas Enoch, Lubin & Enoch, P.C.	389.2	SOC	“IBEW Local 769 believes that the BLM’s prompt adoption of the ACC’s proposed alignment will be a helpful step in addressing one of Arizona’s largest ongoing problems, to wit, creating good jobs. With Arizona’s unemployment rate hovering around 8% (see Bureau of Labor Statistics: Economy at a Glance, http://www.bls.gov/eag/eag.az.htm, last visited Jan. 14, 2013), the proposed project will put Arizonans to work in fairly short order on a substantial infrastructure project that will both directly and indirectly create jobs here in Arizona.”	Impacts to Socioeconomics, including employment in Arizona, are contained in Section 4.10.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Nicholas Enoch, Lubin & Enoch, P.C.	389.3	LU	“By way of example, stakeholders, including the City of Peoria, City of Surprise, Town of Buckeye, Maricopa County, state agencies, federal elected officials, APS and large master-planned communities have supported the ACC-approved route as being the most consistent with existing land use and infrastructure plans, such as Peoria’s General Plan, which are in place. In the estimation of IBEW Local 769, the ACC-approved route approximately co-locates the proposed power line with an existing and approved Transportation Corridor, minimizing necessary environmental disturbance.”	Statement of preference.
Carl Pennella	390.1	SUP PA	” As a resident of Trilogy I support the power lines run north of SR74.”	Statement of preference.
Cindy Hagen	391.1	SUP PA	“As a resident of Trilogy, I support the decision for the APS power lines to be located north of Vistancia along SR74. This is the best solution to help preserve the natural beauty of the desert and enhance future development of the area.”	Statement of preference.
David W. Grounds, Dorn Homes, Inc.	392.1	SOC	“I am writing to contest the Bureau of Land Management’s position that high voltage transmission lines do not have a severe negative impact on the marketability and value of residential home sites. Additionally, I am challenging the Bureau’s willingness to honestly assess the negative cost implications to land owners with close proximity to high voltage power lines. I have 40 years of empirical evidence to ground my assessment.”	Section 4.10 analyzes potential impacts on property values from all alternatives.
David W. Grounds, Dorn Homes, Inc.	392.2	SOC	“…lots that aren’t adjacent or viewing the power lines have $26,500 to $39,500 more value than the power line lots. This is at least a 65% devaluation on land values due to power lines.”	The information provided by the commenter cannot be considered on par with the independent studies of property values in certain geographic areas contained in the literature review in Appendix 3A. Further, Section 4.10 analyzes potential impacts on property values from all alternatives.
David W. Grounds, Dorn Homes, Inc.	392.3	SOC	“In addition to massive discounts and land devaluation caused by high voltage electric lines, there are the carrying costs to developers. If the Bureau will take the time to assess the cost of capital to carry lots, it is staggering. Costs include real estate taxes, HOA dues, maintenance, use of capital, etc. The totals are in the thousands of additional dollars of losses per lot.”	The information provided by the commenter cannot be considered on par with the independent studies of property values in certain geographic areas contained in the literature review in Appendix 3A. Further, Section 4.10 analyzes potential impacts on property values from all alternatives.
David W. Grounds, Dorn Homes, Inc.	392.4	OPP ALT2/3	“We are opposed to Alternative 2 and Alternative 3 as they go through private land rezoned for Residential Subdivisions within Master Plans.”	Statement of preference.
David W. Grounds, Dorn Homes, Inc.	392.5	SUP PA	“We support the Proposed Action, which the ACC approved and is generally consistent with BLM’s Preferred Alternative.”	Statement of preference.
David W. Grounds, Dorn Homes, Inc.	392.6	SOC	“The Dept. of Interior is stating (and citing studies) that there is no lot price differential or home price differential between residential subdivision lots adjacent to high voltage transmission lines and those that are not. However, the fact that the difficult to sell lots are absorbed by the overall project and the full cost differential between the impacted and non-impacted lots is not reflected in the sales price.”	The literature review in Appendix 3A was revised to include new empirical studies, and Section 4.10 was revised to clarify that the value of lots adjoining a ROW would be affected.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
David W. Grounds, Dorn Homes, Inc.	392.7	SOC	“Other Considerations when dealing with High Voltage Power Lines: Larger lots need to be created to accommodate greater on-lot setbacks and increase the distance between home and unattractive element. Large lots next to transmission lines are often sold for the same price as small lots. More master developer and homebuilder marketing expenses are required to favorably position lots in less desirable locations within the subdivision. Reductions in lot premiums and bonus or discounts in home upgrades to incentivize sale of challenging lots. Carrying costs, interest expense on portion of debt associated with lots which do not move quickly, where there is slow absorption or velocity; lots next to unsightly areas sell last in the project and there is an associated interest expense with holding these lots until they sell. Delay in construction and occupancy of these homes and associated delay in development fees and sales and property taxes which are realized when the lots are sold, homes are constructed and occupied. Homes not adjacent or in proximity to undesirable, intrusive or unsightly land uses sell more quickly. Delay in coming on-line has an associated cost.”	Section 4.10 was revised to more fully capture the complexities and complications of marketing and selling lots adjoining ROWs.
Walter Skip Zahlmann	424	UC	Content unrelated to analysis
Walter Skip Zahlmann	425	UC	Content unrelated to analysis
Susan K. Strecker	426.1	SUP PA	“I am writing to express my support for the BLM plan to place the APS transmission line along the North side of SR 74 for 7 miles. The agreed upon route fits our community well.”	Statement of preference.
Steven R. Strecker	427.1	SUP PA	“I am writing to express my support for the BLM plan to place the APS transmission line along the North side of SR 74 for 7 miles. The agreed upon route fits our community well.”	Statement of preference.
Walter Skip Zahlmann	484	UC	Content unrelated to analysis
Walter “Skip” Zahlmann	485	UC	Content unrelated to analysis
Walter “Skip” Zahlmann	486	UC	Content unrelated to analysis
Steven L. Spangle, U.S. Fish & Wildlife Service	487.1	SSS	“P.2-13, last [paragraph] In order to protect the Sonoran desert tortoise (Gopherus morafki) and other species, we recommend that contained washout areas be designated for cleanout of concrete trucks and that those areas be cleaned up following completion of concrete work. Ponded water can be attractive to desert tortoise and may increase tortoise use of construction areas, increasing potential for crushing.”	The referenced subsection of Section 2.4.2.2 was revised to eliminate potential for ponding of water.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Steven L. Spangle, U.S. Fish & Wildlife Service	487.2	VEG	“P. 2-21, 4th [paragraph] While a “lush and stable shrub/grass/forb community” may be desirable from a transmission line right-of-way (ROW) perspective it may not be a realistic goal for some project segments supporting Sonoran Desert vegetation. We recommend that the Integrated Vegetation Management (IVM) plan be tailored to the area and type conversion be avoided. Short stature shrubs provide some stability in areas of poor soil development.”	The text in Section 2.4.3.4 and relevant sections of Appendix 2B have been revised to eliminate language that is inappropriate to desert vegetation communities.
Steven L. Spangle, U.S. Fish & Wildlife Service	487.3	SSS	“P. 3-187, 4th [paragraph] Critical habitat for southwestern willow flycatcher was designated January 3, 2013. We recommend that the related text be updated. A copy is available on our website at http://www.fws.gov/southwest/es/arizona.“	The suggested reference was reviewed and the text in Section 3.16.4.1 describing critical habitat was revised accordingly and the associated Figure was also revised.
Steven L. Spangle, U.S. Fish & Wildlife Service	487.4	GEN	“P. 4-187, 1st [paragraph] We recommend that the sentence “Desert washes are mainly present west of the Action Alternative routes (i.e., Hieroglyphic Mountain area), so any disturbance to these areas would be the same under all alternatives.” be reviewed for accuracy and clarity. The preferred alternative traverses a portion of the Hieroglyphic Mountains (see U.S.G.S. 7.5′ topographic sheet Baldy Mountain Quadrangle, Arizona- Maricopa County) and the route crosses several washes.”	This statement contained a typo (“….west of the Action Alternative routes” should be “…east of..”) which has been corrected to make the statement more accurate. The statement now reads: “Desert washes are mainly present east of US 60 (i.e., Hieroglyphic Mountain area). Disturbance to these areas would be very similar under all Action Alternatives; refer to Section 4.15 for a discussion of impacts to jurisdictional drainages.”
Steven L. Spangle, U.S. Fish & Wildlife Service	487.5	WLF	“P. 4-191, 1st [paragraph] The paragraph heading is “Electrocution Risk” but the 1st sentence discusses a potential for both electrocutions and collisions of raptors and other migratory birds following construction of the line. We recommend that collision risk along the length of the preferred alternative be reviewed and discussed in a separate paragraph. We recommend that the analysis consider guidance in “Reducing Avian Collisions with Power Lines” dated October 2012 prepared by the Avian Power Line Interaction Committee (APLIC). We also recommend that static wires on the transmission line crossing of the Agua Fria River on the eastern end of the project and adjacent to open water in the Central Arizona Project canal and the Hassayampa River at the western end of the project be marked with bird diverters to reduce the risk of avian collisions in those areas.”	The text in Section 4.16.2.1 was revised per comment, separating discussions of electrocutions and collisions, and conducting further analysis incorporating the suggested reference. Mitigation measures have been added. Further, information regarding the potential installation of bird diverters at the crossings of the Agua Fria River and the CAP has been added to the EIS in Chapter 2 and Chapter 4 in applicable sections.
Steven L. Spangle, U.S. Fish & Wildlife Service	487.6	WLF	“P. 4-195, 7th [paragraph] and P. 4- 235 8th [paragraph] We recommend addition of text incorporating APLIC collision guidance (cited above) following discussion of APLIC electrocution guidance.”	Reference to APLIC collision guidance is contained in Section 4.16.2.1; however, text was added to Section 4.16.3 as recommended by the comment.
Edmund J. Nightingale	488.1	SUP PA	“I am writing in support of the easement along the north side of SR 74 in order to keep more power lines from running through undeveloped parts of the desert.”	Statement of preference.
Ms. Xenia Valle	489.1	OPP PA	“Please reject siting the proposed Sun Valley to Morgan 500/230kV Transmission Line Project on public lands and do not amend the Resource Management Plan to accommodate this siting.”	Statement of preference.
Ms. Xenia Valle	489.2	LU	“Siting this line on our public lands north of SR74 is not in the best interest of the public and does not support the mission of the Bureau of Land Management (BLM). Instead, it primarily benefits one developer, while sacrificing important public resources.”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Ms. Xenia Valle	489.3	OPP RMPA	“The Resource Management Plan (RMP), which was published only a couple of years ago, determined that a transmission line right-of-way is inappropriate for this area due to the negative impacts it would have. Less than a year after the RMP was finalized, however, a developer began pushing the BLM to change it in order to accommodate this line proposal. The BLM should say no to the developer and continue to manage these lands for their natural resource values.”	Statement of preference.
Ms. Xenia Valle	489.4	SOC	“This alternative will also cost Arizona Public Service Company ratepayers more money. Again, this is to benefit one developer at the expense of the larger public.”	Section 4.10 has been updated to include how APS increases rates and whether it would depend upon which alternative is selected.
Ms. Xenia Valle	489.5	OPP PA	“I strongly recommend that the BLM reject this proposal and maintain that this area is off-limits to transmission lines and other development.	Statement of preference.
Ms. Xenia Valle	489.6	SUP NA	“Please select the No Action Alternative in the DEIS and do not amend the RMP.”	Statement of preference.
Randy Frantz Katy Frantz	493.1	OPP SAR	“In 2008 my wife and I retired and moved to Wittmann. We invested in a property on Caravaggio Lane when prices were still quite high. That money was our life savings $400,000.00. With the economy in trouble, we already lost a great deal of our property value. With the transmission line option to be installed along Cloud Road right behind our house, you will completely obliterate our retirement savings. We know that the economy will come back but the hideous electrical towers would be a permanent eye sore and unknown health hazard which will not attract anyone to live here.”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values. Further, the impacts from the Sub-alternative route are also analyzed throughout Chapter 4 for all resources.
Randy Frantz Katy Frantz	493.2	LU	“There is absolutely no reason for these lines to be put in residential areas. There is a vast amount of open land in the area if there is, in fact, a need that they be installed at all.”	Statement of preference.
Randy Frantz Katy Frantz	493.3	SDA	“Why not go underground and avoid the conflict as well as avoiding the destruction of beautiful landscape? Not to mention less maintenance for APS.”	Section 2.7.10 explains why undergrounding the proposed transmission line was not carried forward for detailed analysis.
Randy Frantz Katy Frantz	493.4	PH	“It is also unbelievable that most of the residents in this area were not informed of this project and yet they are the ones it most impacts. Many of the people that learned about it from word of mouth still did not know about the public hearings.”	Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of and notifications for public hearings were legally adequate.
Elva Lotter	495.1	LU	“It was my impression for a long time that the area North of Rt. 74 was pretty much sacrosanct. It was to be preserved because of its wildlife and sensitive habitats to say nothing of scenic beauty. Of course, some of this was self-reinforcing! The longer that the area was preserved and protected, the more it became differentiated from surrounding areas. The net effect is still that the area is uniquely important to the environment.”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need. Chapter 1 also describes why an RMP amendment is needed.
Elva Lotter	495.2	OPP FL	“Please do not allow the Sun Valley to Morgan Project to go through our public lands.”	Statement of preference.
Elva Lotter	495.3	OPP RMPA	“…in 2010 your Resource Management Plan stated that transmission lines were inappropriate due to the sensitive resources. Please, do not amend your plan!”	BLM finds that for consideration of the Proposed Action. Alternative 1, and Alternative 2, the RMP would require amendment to comply with the FLPMA as explained in Section 1.3.2. Section 2.10 describes the rationale for why the BLM is selecting the Proposed Action as the Agency Preferred Alternative.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Elva Lotter	495.4	SUP NA	“Putting the Sun Valley to Morgan Line North of Rt. 74 is bad for the environment & expensive for rate-payers. The preferred alternative should be the No Action Alternative.”	Statement of preference.
Ladona Stallings	496.1	SOC or EJ	“It has become very clear by statements made at the public hearings of December 11th, 12th, and 13th, that the designated ROW which places the transmission line across BLM land was chosen to alleviate economic impact to the community of Vistancia, and the future planned developments of various corporations. Even when this transmission line would be no closer than two to six miles from Vistancia. By giving this financial consideration to the above mentioned groups it has now placed the transmission line along areas: Wittmann, Circle City, and Morristown, and literally in our front yards, not two to six miles.”	Section 4.10 of the EIS has been revised to clarify socioeconomic and environmental justice impacts, and the relative proportion of impacts across communities. For clarification, the ACC, by placing the certificated route north of SR 74 (away from the community of Vistancia) did not place the route in proximity to Wittmann, Circle City, and Morristown; any shift away from Vistancia did not result in a shift toward Wittmann, Circle City, and Morristown. The portion of the route that would affect Wittmann, Circle City, and Morristown is not related to the decision to design the route north of SR 74.
Ladona Stallings	496.2	OPP FL	“I therefore request that you deny any ROW across BLM land.”	Statement of preference.
Ladona Stallings	496.3	SDA	“The hope of the impacted communities is that your refusal will cause the ROW to return to the south side of Highway 74. And since the wealthy among us who did not care what happened to others will decide to choose another route such as the West Wing Corridor.”	Statement of preference.
Ladona Stallings	496.4	SOC	” Regarding the APS Sun Valley to Morgan transmission line, I can only feel that placing the line on your sub alternative along Cloud Rd. is an injustice to this community. As you told me that your first, and preferred route was to go directly north along state land on the west boundary towards highway 74. By using this route you minimized the impact to the local resident areas while maintaining maximum undivided use of state land. You also stated that a single land owner, a Mr. Anderson, objected. By checking public records I find that this property is owned by BM3 North Holdings LLC, since you stated a Mr. Anderson was the owner, I will assume that BM3 North Holdings is a corporation owned by Mr. Anderson. You also stated that there are no homes or development on Mr. Anderson’s land. Therefore; the route was moved to the current ROW placing it about one mile from Cloud Rd. and this community. I find it unconscionable that you could consider his property value for future development while destroying our values. Ours are existing residences. I am finding articles where a transmission line of 500 kV has made it impossible for home owners to sell their property. If you would provide me with your e-mail address I will forward one of these articles to you. We already know that this designated ROW was chosen so that it would not impact the property values of Vistancia, and future development by corporations in north Peoria. Again, how unjust is it to destroy our investments, and in many cases our retirement lives by placing the transmission line along Cloud Rd. I hope you will reconsider the use of the sub alternative route so our lives our not so horribly impacted. I will be contacting the ACC also to request that the transmission line not be sited along Cloud Rd. This placement would put the ROW about 200 Ft. from my front door, and as close to my neighbors properties. It would be even closer to our properties north boundaries.”	This comment was taken from a letter to the ASLD, which was an attachment to a comment letter on the Draft EIS. When the comment refers to “you” or “your” it is referring to the ASLD. Statement of preference. Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values and tax revenue. The BLM decision on the proposed project would only apply to any BLM-managed public lands crossed by the proposed project and not land owned and managed by the Arizona State Land Department. The portion of the project that would affect people’s homes in Wittmann would not be on BLM-managed public lands and was proposed by the Arizona State Land Department.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Ladona Stallings, et al.	496.5	PH	“Due to inadequate notification for the public hearing of the Proposed APS Sun Valley to Morgan 500/230KV Transmission Line Project of December 12, 2012, at Nadaburg School and newly discovered information since that meeting, the residents of the area that will be impacted by this project find it absolutely necessary another public meeting be held.”	Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of and notifications for public hearings were legally adequate.
Ladona Stallings, et al.	496.6	GEN	“Our concerns that have not been addressed are as follows: Improper notification of Wittmann, Circle City and Morristown residents. 2. Continued refusal to provide Freedom of Information requests 3. Long range effects of Health and Safety. 4. Decrease of property values throughout the areas. 5. Unnecessary disruption of Endangered Species. 6. Conservation of pristine BLM land.”	The EIS provides a complete analysis of most of the concerns: Notification of Wittmann, Circle City, Morristown and surrounding residents is addressed in Section 5.2. Addressing Freedom of Information Act requests is beyond the scope of the EIS. Impacts to property values are addressed in Section 4.10 Impacts to endangered species are addressed in Section 4.16. The BLM’s mission is explained in Section 1.5.2, and impacts to land use on BLM-managed public land are addressed in Section 4.6.
Mary & Philip Marquardt	497.1	OPP PA	“As registered Arizona voters, we need to go on record as opposed to the Proposed Sun Valley to Morgan Transmission Line.”	Statement of preference.
Donald Begalke	500.1	GEN	“BLM’s NOI process is very, very inferior considering the ACC SV-M decision including controversies regarding the NE 9-10 miles of proposed line segment route on BLM-managed Public Lands and regarding the extremely, very large portion of Maricopa County’s 4.500,000+ population being non-recipients on associated matters.”	Statement of opinion.
Donald Begalke	500.2	PH	“Using APS to advertise SV-M Public Scoping Meetings Is a huge disgrace because they’re agency announcements. BLM doing own work would have resulted justly/better for the Maricopa County Public.”	Sections 1.7 and 5.2 describe the Public Scoping and Public Involvement activities that have been conducted for this project. The number of and notifications for public hearings were legally adequate.
Donald Begalke	500.3	GEN	“APS had objected to the ACC decision because they do not want to build a high-voltage line over a 10-lane wide freeway (foot-noted in the DEIS) that is a future replacement for SR74. Additionally, the ACC action has caused a construction delay of SV-M, and each delay causes construction costs’ increases. Since the BLM had to complete the B-H RMP before accepting APS’s forced application for an EIS, that additional delay also adds to increased APS construction costs.”	Statement of opinion.
Donald Begalke	500.4	OREC	“My scoping presentation regarded the 55+ years BLM and Maricopa County residents and government had, and LPRP [Lake Pleasant Regional Park] became a reality and had continued to grow as county taxpayers/volunteers’ efforts so that over 1.5-million users enjoyed It in 2010. I also stated SR7 4 was important to folks’ experiences at the park, and also to surrounding and buffering BLM-managed Public Lands were westward for recreations and educations. In the SV-M DEIS, BLM fails to explain why in 2013 they used 2006 stats on LPRP users ?? That is deceptive and/or uninformed due to lack of BLM research for the DEIS!!”	Park user data for LPRP was from 2010 (Section 3.10.6). The 2006 recreation data was general Maricopa County recreation user data from two specific studies, one conducted as part of the 2008 SCORP and one conducted by Arizona State University. Revising the numbers would update the data and improve the accuracy of the EIS, however it does not change the analysis contained in it.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Donald Begalke	500.5	NEPA	“In Vol.1 a page is unnumbered and titled “Abstract”. While reading the Abstract paragraphs, discouragement was felt because BLM had “the cart before the horses” – ? When can the reader of EIS options understand because BLM had not presented the entire two volumes yet? Whether read from hard copies or on a PC, does BLM expect anyone to read the entire DEIS after not providing the Public the DEIS details before the options?”	An Executive Summary is also provided in the beginning of the EIS.
Donald Begalke	500.6	GEN	“…then a person reaches the Public Scoping Meetings Section and Table 1.7-1 on Page 1-17. The Scoping Meeting of June 8, 2011 is not included at all. We were at the BLM Training Center the eve of June 8, 2011 and folks made their 5-minute scoping comments, and departed at the end”. Arriving on P.1-18, the last paragraph reveals “on June 8, 2011, an Economic Strategies Workshop was also conducted •••• “. What??!!”	Information described in Section 1.7 was reviewed for accuracy and is correct. Information regarding the Economic Strategies Workshop was moved from Section 1.8 to 1.7.
Donald Begalke	500.7	GEN	“In Table 1.8-2 we find the words ”would benefit developers”! That is BLM’s bias or politics when they should be neutral!!”	Table 1.8-2 provides a summary of issues from Scoping, which includes the Economic Strategies Workshop. The issue referenced by this comment is that the process of amending the RMP should consider whether or not it is appropriate to amend the RMP in such a way that would benefit developers. The referenced text is stating the issue as it was raised during scoping, and is not expressing bias or politics on the part of the BLM. Socioeconomic impacts of all alternatives are analyzed in Section 4.10.
Donald Begalke	500.8	GEN	“Last week I had a telephone conversation with the BLM’s Ms. Kathleen Depukat who alleged the ESW [Economic Strategies Workshop] was the same meeting as the scoping comments were. Really? In review of Mr. lncardine’s words to me, he stated the scoping individuals would be “invited”, meaning the .June 8, 2011 meeting was never announced to nor Intended for the Public. Hiding events is dirty politics. At the “scoping meeting” ever presentation was oral. For an EWC, the duties are verbal, written and charted, and that combination did not occur as there were no “round tables” for small groups to strategize.”	Sections 1.8 and 5.2.2 describes the details of the Economic Strategies Workshop that was held for this project.
Donald Begalke	500.9	GEN	“Also on P.1-18 is a scoping comments table with one-to-two words per category except for those “unclassifiable”, AKA “nonsubstantive”. The whole table is nonsubstantive because the DEIS commenter has no categories’ statements nor details to read, and the commenter should not assume anything about what’s in the table. Let’s talk about “scenes/visuals” (as a category). We should read specifics of Ss/Vs. We have none in DEIS Table 1.8-1. Are there public statements or questions about transmission towers? No!! Do scoping commenters know about different transmission structures? Is the high-voltage electric line an objection? Did any scoping commenter present the abilities of developers to minimize views with anything objectionable associated with a SV-M line? Which commenters spoke or wrote about monopoles, and would that be from a “pro” or “anti” stance? APS plans to use monopoles in constructing SV-M, and diameters of such poles are far less blocking than the erector-towers with T· bars at the top; thus, viewing monopoles from distances is “more pleasing to the eyes”. Who asked about the color of the monopoles? Where are the answers in the DEIS to public·scoping comments and/or concerns on Ss/Vs?”	Section 1.8 provides a summary of issues identified during scoping. A detailed presentation of scoping comments and issues is available in the Scoping Report, which is available on the BLM Project website (see http://www.blm.gov/az/st/en/prog/energy/aps-sunvalley.html), as noted on page 1-18 of the EIS.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Donald Begalke	500.10	GEN	“Additionally, the Phoenix metro has multitudes of varied high-voltage lines bringing electric energies to an enlarged community area and to neighborhoods. Folks have seen them for decades, and adjusted to them. In the DEIS where are BLM’s reference locations of such that anyone could travel to for viewing/reviewing established electric lines?”	BLM does not recommend specific locations where parties could view established electric lines, as the context for the infrastructure could affect how it is perceived. However, the EIS does include visual simulations of the proposed line to assist the reader in getting a good idea how it would look from various locations in the project area.
Donald Begalke	500.11	SOC	“Diamond Ventures, against APS’s SV-M routes, successfully made a land-swap deal with the BLM a few years ago; the U.S. Public lost severely in the transaction. Now Diamond has the prime land and is complaining about SV-M affecting land values? Nonsense!!”	The comment does not raise questions about the analysis or provide additional information for consideration.
Donald Begalke	500.12	LU	“Regarding SR74, some of the Public has read Maricopa County’s Article 2201-F, the criteria establishing preservation of natural cultures and landscapes plus scenic qualities along the highway. Has BLM? That is substantive, but it is not in the DEIS!”	Section 4.14 references the Maricopa County Scenic Corridor; however, the scenic corridor is not applicable within City of Peoria, see Section 3.14.1. The BLM uses VRM classifications as described in Section 3.14 and visual impacts described in Section 4.14.
Donald Begalke	500.13	OREC	“Further, neither “P.A.” nor “Alt.-1” protect the LPRP and adjacent Public Lands that provide buffering to the west of the park’s main entrance and buffering that’s very necessary to help the “desert tortoises”…”	The impacts of the transmission line on the recreation experience at Lake Pleasant Regional Park are analyzed in Section 4.9.2.2 and the impacts on the visual resources of the Park are analyzed in Section 4.14. Impacts to desert tortoise are analyzed in Section 4.16.
Donald Begalke	500.14	SSS	“The tortoises should be protected from future multi-event years SV·M maintenance disturbances. Desert tortoises have suffered tragedies of harassments to killings elsewhere, and are candidates to be protected, and the BLM-managed Public Lands north of 74 can be a refuge for additional tortoise families.”	Impacts to desert tortoises are analyzed in Section 4.16.
Donald Begalke	500.15	OREC	“Back to Lake Pleasant Park, as the metro continues northward toward SR74, the population will grow and more land will be needed for an expanded park with BLM’s management of our Public Lands as users and activities at LPRP both increase. BLM’s DEIS has not addressed additional park concerns.”	Although BLM is not cognizant of any potential expansion of Lake Pleasant Regional Park, there could be a Recreation and Public Purposes Act request or other land request that could be made as pressures for recreation increases in this area.
Donald Begalke	500.16	LU	“The “Alt.-1” route is even more scarier than all stated above regarding the “P.A.” route. The “corridor” of 1/2-mile wide is the huge problem. Details what will be inside the corridor are not in the DEIS – ??”	It is currently unknown what additional utilities could be within an expanded corridor, since BLM has not received any applications. Section 2.5.1 indicates that the multiuse corridor could be used for co-location of future utilities within the corridor, consolidating similar land uses and future NEPA would be required for any future actions.
Donald Begalke	500.17	TRANS	“Since MAG decides freeways for our metro, freeway evidences should be in the DEIS and not just footnotes for a 10-lane wide freeway to replace SR74. The true width of a 10-lane wide freeway will include lanes for shoulders, medians, bridges’ structures, ramps et al; thus the total width could be 22-24 lanes wide. Thus, “Alt.-1″ should never have been an option in this APS application, DEIS, for a SV-M transmission line. Having MAG’s freeway on Public Lands N. or 74 is horrible, BLM!! MAG has no application to the BLM for anything.”	Additional Information on MAG’s conceptual plan has been added to the cumulative impacts section.
Donald Begalke	500.18	SOC	“The DEIS’s “Alternate-2” and “Alternate-3” options are less expensive than the “P.A.” or the “Alt.- 1” routes. “Alt.-2” and “Alt.-3″ are not on lands managed by the BLM, but are already inside the metro-community’s lands like all of APS’s original SV-M routes to the APP&TLSC and to the ACC. In this tragic economy APS, who planned SV-M routes more cost-effective, and APS’s electric- ratepaying Customers need the lowest-costing SV-M.”	Section 4.10 has been updated to include how APS increases rates and whether it would depend upon which alternative is selected.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Donald Begalke	500.19	NEPA	The DEIS “No Action Alternate” should be amended to include a ROW across the BLM-managed lands near the Sun Valley Substation and to include a ROW across the “key-figured” BLM land just south of SR74 to assist the ACC and APS select a final routing for SV·M. If those two BLM parcels require any RMPs, please, amend for the Final DEIS also.	The No Action alternative cannot add a ROW because it would then be an action alternative. The commitment of BLM-managed public lands suggested by the comment would be the same as Alternative 2.
Donald Begalke	500.20	SAAA	I respectively urge the BLM to set aside any biases and politics in these SV·M matters, and allow an amended “No Action Alt.” be renamed and become the Final EIS decision for the APS and for their electricity-paying Customers.	The No Action alternative cannot add a ROW because it would then be an action alternative. The commitment of BLM-managed public lands suggested by the comment would be the same as Alternative 2.
Walter “Skip” Zahlmann	502	UC	Content unrelated to analysis
Cheryl Eckhardt, Environmental Compliance Specialist, National Park Service	503.1	LU	“There may be Land and Water Conservation Fund (LWCF) projects within or near the study area that could be affected by this project. We recommend you consult directly with the official who administers the LWCF program in Arizona to determine any potential conflicts with Section 6(f)(3) of the LWCF Act (Public Law 88-578, as amended). This section states: “No property acquired or developed with assistance under this section shall without the approval of the Secretary (of the Interior), be converted to other than public outdoor recreation uses. The Secretary shall approve such conversion only if he finds it to be in accord with the then existing comprehensive statewide outdoor recreation plan and only upon such conditions as he deems necessary to assure the substitution of other recreation properties of at least equal fair market value and of reasonably equivalent usefulness and location.”	No Land and Water Conservation Fund projects have been identified within the study area and attempts to reconfirm this have been made. If such projects are identified at a later date, all appropriate coordination with the applicable agencies and APS will take place.
Howard Brown	504.1	OPP FL	“I strongly oppose installing the 500K power line on Public Land.”	Statement of preference.
Howard Brown	504.2	SAAA	“Please run the line along the South side of SR74. The visual impact will be only marginally more then the Northern route on BLM land and this location will not encumber our valuable public lands. As our beautiful valley builds out, public lands will become more and more critical to the ongoing quality of life in Arizona.	Statement of preference.
Mark Hammons, Vice President/General Mgr Vistancia Land Holdings, LLC	510.1	SUP PA	“We appreciate your work on this project and support the approval of the Preferred Alternative (Proposed Action).”	Statement of preference.
Mark Hammons, Vice President/General Mgr Vistancia Land Holdings, LLC	510.2	OPP ALTS 2&3	“…we oppose the consideration of Alternatives 2, 3, and the Sub Alternative.”	Statement of preference.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Mark Hammons, Vice President/General Mgr Vistancia Land Holdings, LLC	510.3	SOC	“Most of the points revolve around the inappropriate approach of analyzing the private land impacts of Alternative 3 as simply effecting raw land. In contrast to BLM land that is intended to remain in its current state indefinitely, or other private land with no near-term plans to develop, this land has been planned, entitled, and invested in through past and ongoing infrastructure. According to John Bums Real Estate Consulting (report attached) the 2012 sales pace of this community ranked 29th in the nation, and increased its standing from the previous year’s rankings.”	Revisions have been made to the EIS indicating that “undeveloped land” is not “raw land” and that developments on private lands are in various stages and generally describing a range of effects to developments.
Mark Hammons, Vice President/General Mgr Vistancia Land Holdings, LLC	510.4	SOC	“Ongoing Vistancia Development The built portion of the Vistancia community currently stops approximately 1.5 miles south of the Alternative 3 alignment. However, design and infrastructure improvements are underway to advance development to the north. On January 15, 2013, public bids were received to build a $5.5 million bridge, kicking off the next phase of development. This work will commence in February and be completed in the middle of 2013. Current construction schedules anticipate infrastructure being installed within the Alternative 3 alignment in the second half of this year and homes going under construction within 3/4 of a mile from this alignment in early 2014. This next phase of improvements also includes parcels designated for a future public school and park, both located approximately Y2 mile from the Alternative 3 alignment. The National Environmental Policy Act (NEPA) requires the EIS to analyze the impacts of the Alternatives on past, present and reasonably foreseeable future actions RFF A or reasonably foreseeable development RFD. A current impact is defined as one that occurs between the start of construction and 10 years. The Vistancia community is rapidly expanding into the areas deemed as raw land in the DEIS, which must be considered in your analysis of this land.”	Revisions have been made to the EIS indicating that “undeveloped land” is not “raw land” and developments on private lands are in various stages and generally describing a range of effects to developments.
Mark Hammons, Vice President/General Mgr Vistancia Land Holdings, LLC	510.5	PH&S	“EMF Exposure Although page 4-67 states that effects of EMFs are ” … equivalent among alternatives, when compared to levels defined by the ICNIRP … “, this 2,000 mG exposure limit is not an appropriate benchmark. As noted on page 3-71, the ACGIH provides that individuals with pacemakers should not exceed exposure levels above 1,000 mG. Given the increased level of residential development planned near Alternatives 2 and 3, and the likelihood of those developments containing additional age restricted communities (as Vistancia already does), applying this more restrictive exposure level should be evaluated and could show Alternatives 2 and 3 having a negative public health impact.”	Potential impacts for EMF are analyzed in Section 4.7. It is currently unknown if and when future development would occur and how close to the transmission line any development would occur and what age the potential residents would be.
Mark Hammons, Vice President/General Mgr Vistancia Land Holdings, LLC	510.6	REC	“Recreational Page 4-87 mistakenly states that future recreational development is unknown where Alternative 2 crosses land identified for future recreation (and is thus a negligible effect). That land within the Saddleback Heights community is shown as open space I golf course, so this should be stated as a more significant effect as noted on page 4-88 in relation to the Alternative 3 conflicts with the Vistancia golf course.”	Analysis under the heading of “Other Recreation” in Section 4.9 was revised to analyze the indirect effect of the transmission line crossing lands that would be used for open space/golf course.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Mark Hammons, Vice President/General Mgr Vistancia Land Holdings, LLC	510.7	SOC	“Home Values Page 3-102 limits home price values and increases in values to 2009. This focus on pricing in the middle of the recent economic recession, and lack of regard for the record Phoenix area home price appreciation rates experiences in the recent few years, is inconsistent with the intent of this report. According to a December 26, 2012 release on the S&P/Case-Shiller Home Price Indices, the average home price in the Phoenix market in October of 2012 had increased 21.7% from where it was one year prior. A more recent article (also attached), notes that prices have increased annually by nearly 23% in Phoenix. The 2009 pricing data used in the DEIS is already outdated.”	Home values are not used for any impact analysis in Section 4.10. Changes in the real estate market would not change the impact of the transmission line on home values. Regardless of the present value of any property, the addition of the transmission line would affect the value of the property on a percentage basis, as described in the cited source contained in the literature review in Appendix 3A.
Mark Hammons, Vice President/General Mgr Vistancia Land Holdings, LLC	510.8	SOC	“Land Values When looking at land values and property tax generation in Alternatives 2 and 3 (see pages 4-1 05 and 4-1 08), the report takes a short term look at today’s developed conditions and 2011 tax rates. This generalized impact on raw land values irresponsibly ignores the more sophisticated and long term plans and underwriting of the master plan communities impacted by these routes. Although there may typically be a relatively small impact on vacant land values, the ripple effect of how decreased home values would limit oyerall developability in some of these impacted master plan communities has not been captured in the report. In the case of Alternative 3, the impacted land with Vistancia and Saddleback Heights contains drastic topography that significant increases development costs. With the increased impact on home pricing (mentioned on page 4-91), home values would not be expected to justify development for the foreseeable future. This would then force property currently entitled for development to remain vacant indefinitely. In the case of the Vistancia Community, infrastructure and services have been sized and installed for the ultimate build out conditions and this forced reduction in densities would cause us as the developer to more heavily allocate the cost of those improvements to fewer units, inhibiting continued development in general.”	The potential impact on taxes would be a cumulative impacts issue, and Section 4.19.11 is revised as applicable. The effect of potentially inhibiting development because of the value of the property/homes being reduced by the presence of the transmission line would be an indirect effect and is addressed in Section 4.10, as applicable.
Mark Hammons, Vice President/General Mgr Vistancia Land Holdings, LLC	510.9	SOC	“Other Socioeconomic Impacts While the DEIS attempts to analyze this project’s impact on home values and property taxes, it does not look at other economic implications of the home construction process and spending habits of new home owners. Reducing buildable units as described above will eliminate or defer millions of dollars of infrastructure improvements along with the associated permit fees and sales taxes paid for that work. Each single family building permit pulled within the Vistancia community pays an impact fee of $11,657 in addition to several thousand dollars in other building permit and connection fees. Additional jobs and economic benefit is created during the construction process of each home. According to research from the National Association of Home Builders, during the first two years of closing on a house, a typical buyer of a new single family detached home tends to spend on average $7,400 more than a similar home owner who does not move. Impacting land that is planned for near-term development as occurs in Alternatives 2 and 3 reduces a number of additional economic benefits to the area including fees to the municipality, job creation, sales tax revenues, and retail sales.”	The effect of potentially reducing the money homeowners would spend locally and the associated economic generation would be a cumulative effect and is addressed in Section 4.19, as applicable.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Mark Hammons, Vice President/General Mgr Vistancia Land Holdings, LLC	510.10	SOC	“Property Taxes On page 4-105, the report states that “the net effect on property tax revenue under Alternative 2 would be beneficial, major, and long-term. These benefits would accrue to taxing entities and the beneficiaries of those taxes.” Basing the long-term impact on the 2011 tax revenues is inconsistent. Speaking specifically of the Vistancia project, the impacted property is currently taxed under agricultural status, the ultimate build out of residential homes will create an exponentially higher tax base in a long-term analysis. · Furthermore, this property is part of a Community Facilities District (CFD), whereby bonds have been issued to fund master utilities infrastructure improvements, with the repayment source of those bonds being the property’s projected tax base at build out. A proper long-term comparison of build out conditions vs. the assessed value of a power line will likely show a negative impact of property tax revenues and may have a devastating impact on the special taxing district at Vistancia. The lower build out tax rates, potential undermining of the CFD, and fewer homes being built (as mentioned in the previous section) all have a negative impact on taxing entities and the beneficiaries of those taxes.”	Impacts to property taxes and repayment of bonds that would result from implementation of Alternatives 2 and 3 would be a cumulative socioeconomic impact and Section 4.19.11 is revised as applicable.
Mark Hammons, Vice President/General Mgr Vistancia Land Holdings, LLC	510.11	VIS	“Visual Impacts Page 4-162 states that “within the portions of the route unique to Alternative 3, the contrast would be weak and the table on page 4-171 states that the long term visual impact on these portions of the route is Negligible. These conclusions are based upon a view shed analysis containing a majority of Key Observation Points (KOPs) proximate to the Preferred Alternative. Only two KOPs from the view shed analysis were taken to the step of simulated views of the line along the Carefree Highway Alignment, and each of these locations was more than a mile from this alignment.”	Due to private land, access issues, and the currently undeveloped nature of the areas adjacent to Alternative 3, limited KOPs in this area were deemed adequate for impact analysis.
Mark Hammons, Vice President/General Mgr Vistancia Land Holdings, LLC	510.12	VIS	“Although the report makes claims about long term impacts, it has not taken into consideration improvements that have occurred over the past couple years, or those that will be occurring in the next few months/years. Photos used for this analysis were taken in 2008, since which time, additional parcel development has occurred that will already bring Vistancia residents approximately ~ mile closer to this alignment. Throughout 2013, bridge and roadway construction will bring KOPs nearly adjacent to the Carefree Highway alignment bisecting Vistancia and Saddleback Heights. The long-term claims of this report are unfounded because by 2014, Visual Impact ratings for Alternative 3 will increase to levels experienced by the Preferred Alternative (minor, moderate, and even strong and domineering).”	Visual impact analysis was conducted for present conditions. The cumulative impacts discussion for visual resources is in Section 4.19.15 addresses potential future visual impacts.
Walter “Skip” Zahlmann	511	UC	Content unrelated to analysis
Robert T Wanless, Director, Business Development, M+W U.S., Inc.	531.1	SUP PA	“I am writing again to express my continued support for the Proposed Action…”	Statement of preference.

COMMENTOR NAME

COMMENT ID NO.

COMMENT TYPE

COMMENT

RESPONSE TO COMMENT

Robert T Wanless, Director, Business Development, M+W U.S., Inc.

531.2

RENE

“Solar project development is critically dependent on access to transmission lines. This is especially evident in Arizona where proposed solar projects have clustered in areas such as the Palo Verde Hub and Kingman where transmission capacity is readily available. Achieving greater use of Arizona’s significant solar resources– and the associated jobs and environmental benefits– will depend upon some amount of new transmission development. The need for new transmission to support renewable energy in the West and Southwest has been widely recognized by many state and federal agencies, including the Arizona Corporation Commission, the Western Governors Association, and the Department of Energy. Given the large public benefits these transmission projects can offer, some of this development should undoubtedly occur on BLM land.

Among the benefits transmission offers are the jobs the solar industry creates for Arizona. For instance, I recently worked on a project to install a 21MW system in Gila Bend, AZ for Arizona Public Service. This project provided roughly 400 local full time engineering and construction jobs during the 9-month development period. For this project we collaborated with McCarthy Builders in Tempe, AZ who were hired for the system’s installation and subcontracting work. In addition to project development, our project supported work for the utilities for interconnection and system operations. Beyond employment from projects supported by the transmission line, there are direct jobs created in its construction. As noted in the DEIS, the proposed project will create 758-783 jobs at the peak of construction (DEIS, p 4-92). These jobs come at a critical time when Arizona is still in recovery from a major recession. In addition to these jobs created, the DEIS should also acknowledge how these potential jobs might be affected by a delay or denial of the Proposed Action.”

Additional information addressing this comment has been added to Section 4.10.2.4.

Robert T Wanless, Director, Business Development, M+W U.S., Inc.

531.3

RENE

“In deliberating this phase of the project approval process, I urge the BLM to thoroughly consider the fact that the Proposed Action has already met approval by the Arizona Corporation Commission (“ACC”). If the Proposed Action in the DEIS is delayed or denied, it would send the project “back to square one” since it would need another ACC approval. In addition to the jobs impacted directly, this could cause cumulative jobs forgone since future solar developers would have less confidence in Arizona as a place to do business. Meanwhile, solar projects currently in development would suffer significantly due to the limited transmission capacity available on the system. As the DEIS points out, over 1500 MWs of solar energy are in development at the Delaney substation and could be at risk if adequate transmission is not built. Delaying these projects from coming online would only extend Arizona’s reliance on conventional energy sources like coal, and all the attendant environmental consequences they bring.”

Section 4.10.2.4, the No Action Alternative was revised to include discussion of the need for APS to return to the ACC process, and address potential indirect socioeconomic effects of that action.

COMMENTOR NAME

COMMENT ID NO.

COMMENT TYPE

COMMENT

RESPONSE TO COMMENT

Robert T Wanless, Director, Business Development, M+W U.S., Inc.

531.4

“One of BLM’s five priorities is “encourag[ing] and facilitat[ing] renewable energy development- solar, wind, and geothermal- on the Nation’s public lands.” This commitment has been demonstrated through recent initiatives such as the Solar Programmatic Environmental Impact Statement (PElS) and the BLM’s participation in the Rapid Response Transmission Taskforce (RRTT). Secretary of the Interior Ken Salazar echoed this sentiment in his own words, “To build America’s clean energy economy we must update our transmission grid for the 21st century, so that we can efficiently move power from the new energy frontier to the places it is consumed.” We

believe that the Sun Valley to Morgan project is in alignment with the goals of the agency since it facilitates renewable energy development in Arizona and because it provides transmission necessary for delivering renewable energy.

Approving the DE IS quickly, via the Proposed Action, is the best way to uphold these goals. Indeed, we think the DEIS should acknowledge the recent actions the BLM has taken in pursuit of renewable energy development. One notable example was the decision to add a new solar energy zone in Arizona in conjunction with the Solar PElS. This modification reveals that the BLM’s plans are intended to be dynamic while tending toward more, not less, development of renewable energy– and supporting transmission lines — on public lands in accordance with the agency’s goals.

Furthermore, timely approval of these projects has been a priority for over a decade as established in Executive Order 13212 signed by President Bush which states the following: “For energy-related projects, agencies shall expedite their review of permits or take other actions as necessary to accelerate the completion of such projects.”

This is also in accordance with Secretary Salazar’s Order No. 3285, § 5: “Encouraging the production, development, and delivery of renewable energy is one of the Department’s highest priorities. Agencies and bureaus within the Department will work collaboratively with each other, and with other Federal agencies, departments, states, local communities, and private landowners to encourage the timely and responsible development of renewable energy and associated transmission while protecting and enhancing the Nation’s water, wildlife, and other natural resources.”

Moreover, the BLM has a long history of encouraging multiple use of its lands, and there could not be a more salient example of multiple use than a transmission line that is colocated in a transportation corridor (SR74), that will also facilitate solar projects, some of which may eventually be placed on BLM land.”

BLM acknowledges in Section 1.5.2 that the project is consistent with its multiple use mandate, executive direction, and agency priorities. Additional information has been added to Section 1.5.2.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Robert T Wanless, Director, Business Development, M+W U.S., Inc.	531.5	RENE	“The DEIS also discusses some existing or future solar energy generation facilities that could be impacted by the project: The Cotton Center Solar Plant, the Luke Air Force Base Solar Project, the Paloma Solar Project, and the Solana Generating Station. The value of these projects might be strengthened by a more robust transmission system that enables more opportunities for renewable energy delivery, however the DEIS provides no insight on this issue. We urge to BLM to elaborate on these issues in the FEIS. Furthermore, the DEIS alludes to potential environmental benefits from increased solar energy on the Arizona grid by discussing the current mix of energy resources: According to the EPA Clean Energy section, the fuel mix of the electricity generated in the Study Area (supplied by APS) results in C02 emissions of I ,253 lb per MWh compared to the national average of 1,293 lb per MWh (EPA 2007). The mix of power generating technologies in the WECC Southwest Region includes 40.2 percent coal, 36.2 percent natural gas, 14.8 percent nuclear, 5.9 percent hydroelectric, 2.7 percent other renewables, and 0.1 percent oil (EPA 2011d). Given Arizona’s reliance on fossil fuels, the environmental impact of the energy system could be reduced by the additional of more solar energy to the system. The Sun Valley to Morgan project facilitates this outcome, although it is not discussed in the DEIS. The FEIS should discuss these issues more thoroughly.”	Additional information was added to related sections, as applicable.
Robert T Wanless, Director, Business Development, M+W U.S., Inc.	531.6	RENE	“Above all, we stress that the Proposed Action should be approved in a timely manner so that the project can move forward to construction as soon as possible. However, if there are any improvements to be made to the DEIS, they may exist in the opportunity to better explain the economic and environmental benefits of the project. For instance, the Air and Climate impacts section does not consider the project’s ability to allow more solar energy, which could mitigate the air and climate impacts from fossil fuel energy. Furthermore, page 4-211 and 4-224 of the DEIS provide an indication of the existing or planned solar energy facilities that might benefit from this project, as well as future facilities that are in development (p 1-3). However, these descriptions are minimal and understate the future benefits the transmission facility may afford to solar developers. Because the grid is one large interconnected system, transmission additions in one area can allow more power to be transferred in remote locations where renewable energy is being generated. Moreover, the Sun Valley to Morgan line is in a strategic location since it represents a key link to California’s significant renewable energy market. Adding this transmission line could theoretically increase the ability for renewable energy development throughout Arizona to export to California.”	Section 4.19.3 was revised to include analysis of the cumulative effect of the transmission line and potential future renewable energy projects on air quality. Also, Section 4.19.11 was revised to reflect cumulative impacts to the socioeconomic environment from the transmission line in conjunction with future renewable energy projects.
Robert T Wanless, Director, Business Development, M+W U.S., Inc.	531.7	RENE	“In reviewing the DEIS, we note that considerable attention was paid to the impacts to certain selected economic activities, (e.g. OHV recreational use). This attention was in the form of extensive economic analysis, personal communications, and so on. We believe the DEIS should be improved to give other industries (e.g. solar energy, housing) similar attention to OHV in the FEIS.”	Considerable attention was given to OHV use in the EIS because this current recreational use is well documented within the study area. Other industries are discussed in Section 4.19, Cumulative Impacts.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Sierra Club on behalf of Lorna Falkenstein	586		See Letter 116 – Added introductory paragraph: “This has recently come to my attention and deserves your consideration where WE, the public are concerned with regard to this highly private consideration for development of land which has been originally set aside for public management of sensitive lands. Respect must be given this area as it is one of those highly sensitive areas for natural habitat. Even the least of our endangered and rapidly declining natural species needs and deserves our highest attention. These lands and the resources they contain are for future generations and it is also imperative to realize the necessity to preserve all that is within those lands with careful management and protection for all that is contained there.”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
Sierra Club on behalf of Brian Sowle	587		See Letter 116 – Added: “Public lands need protecting.”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
Walter “Skip” Zahlmann	647	UC	Content unrelated to analysis
Walter “Skip” Zahlmann	648	UC	Content unrelated to analysis
Walter “Skip” Zahlmann	649	UC	Content unrelated to analysis
Bill Conner	650.1	SUP PA	“I support the choice of the Proposed Alternative using the north side of Route 74, for some of the following reasons:”	Statement of preference.
Bill Conner	650.2	VIS	” If they put the lines on the Carefree Highway alignment, they will be visible from Trilogy and many parts of Vistancia.”	The impact of the proposed transmission line on visual resources, and specifically the visual resources north of SR 74, is analyzed in Section 4.14.
Bill Conner	650.3	LU	“State Route 74 is already designated as a transportation corridor. It makes sense to place power lines along an existing transportation corridor.”	Statement of preference.
Bill Conner	650.4	LU	” SR 74 is scheduled by ADOT to be expanded into a 6 lane highway. It will have 1,000 feet on each side of the road scraped for right-of-way. The APS lines would be installed adjacent to that 1,000 foot right-of-way.”	Statement of preference.
Bill Conner	650.5	GEN	“The PROPOSED ALTERNATIVE is supported by our Federal delegation, Arizona Department of Transportation (ADOT), Maricopa County, City of Peoria and many other stakeholders…The route along the north side of SR 74 was proposed by the Arizona State Line Siting Committee and then approved by the Arizona Corporation Commission.”	Statement of preference.
Bill Conner	650.6	GEN	“To build high-powered transmission lines through native desert is not environmentally reasonable.”	The EIS evaluates the environmental reasonableness of the alternatives considered, as well as those eliminated from detailed analysis, in Chapter 2.
Bill Conner	650.7	LU	“Anything other than the proposed route is not compatible with the City of Peoria’s General Plan and future developments along the south side of SR 74.”	Statement of opinion.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Bill Conner	650.8	LU	“Environmentalists can identify the north side of SR 74 as the southern boundary of BLM land, visually pronouncing that the BLM land to the north will be protected for generations to come.”	Statement of opinion.
Bill Conner	650.9	SUP PA	“We as citizens have participated for the past 3 years in the public process and now BLM has identified and supports the proposed alternative route, the route we, the Red Shirt Brigade, support.”	Statement of preference.
Joel Kirschbaum	651.1	SUP PA	“Please save our desert and Trilogy. Keep the power lines north along the route of the proposed major highway.”	Statement of preference.
Wayne Carney	654.1	OPP PA	” Please keep the power line south of highway #74 rather than in our pristine desert ! Future generations will thank you !”	Statement of preference.
Michael Banks	655.1	SUP PA	“…the DEIS surfaces an opinion that the preferred alternatives location that resides on the north side of SR 74. I support this location for several reasons.”	Statement of preference.
Michael Banks	655.2	LU	“This location is preferred as it is already designated as a transportation corridor as such, this is an ideal location with minimal impacts to surrounding communities.”	Statement of opinion.
Michael Banks	655.3	GEN	“The proposed alternative location is supported by the City of Peoria, ADOT, Maricopa County and many other stakeholders.”	Statement of opinion.
Michael Banks	655.4	LU	“Anything other than the preferred alternative locations is not in line with the City of Peoria’s general plan for the areas south of SR 74.”	Statement of opinion.
Michael Banks	655.5	VIS	“The visual impacts resulting from installation south of SR 74 could degrade property values of homeowners in the Trilogy and Vistancia Communities.”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values and tax revenue.
Ronald Friedman	656.1	SUP PA	” As well as many other residents in Trilogy at Vistancia I am in favor of the proposed alternative plan for the APS lines to be placed north of rte 74.”	Statement of preference.
Eleanor Hess	657.1	SUP PA	” I would like to see State Route 74(north side) used to house power lines. This route is used for transportation and it makes plain sense to place lines there. This would not infringe on any communities that object to the area that APS wishes to use. Route 74 is one that ADOT supports also. Just end this fight and and join the citizens that have been committed to this project for several years!!!”	Statement of preference.
John William Werner	658.1	SUP PA	“I am in support of the proposed alternative which is on the north side of state route 74. This proposed alternative is supported by ADOT, Maricopa County and the City of Peoria. SR 74 is designated by ADOT as a 6 lane highway so let’s put the line next to this highway. I ask you to vote for the proposed alternative.”	Statement of preference.
Brent & Rose Dubberstein	659.1	SUP PA	“My wife and I are in support of the PROPOSED ALTERNATIVE which is on the north side of State Route 74.”	Statement of preference.
Jackie Pendergast	660.1	OPP ALT3	“Please do not put the power line on the Carefree Highway alignment. It would look horrible and would devastate our property value. Locate the line along highway 74; that is the sensible place to have it.”	Statement of preference.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Bob and Diana Delivuk	661.1	SUP PA	” We are in support of the PROPOSED ALTERNATIVE which is on the north side of State Route 74.”	Statement of preference.
Robert E. “Butch” Pendergast	662.1	SR74	” The proposed APS power line should go along highway 74. That is the logical place for a power line. Conversely, putting power lines in or near residential areas should be avoided.”	Statement of preference.
Robert & Kathy Wrightson	663.1	SUP PA	“We are in support of the PROPOSED ALTERNATIVE on the north side of State Route 74. State Route 74 is already designated as a transportation corridor. It makes sense to place power lines along an existing transportation corridor.”	Statement of preference.
Ron Harkness	664.1	SUP PA	“I would like to make it known that the proposed alternate route on the north side of SR74 is the way to go. It would be reasonable to think that running the transmission lines along a existing corridor is more practical than to meander over native desert.”	Statement of preference.
Ron Harkness	664.2	VIS	“We also have the concern that these transmission lines will be an eye sore to the Vistancia area. With the economy being what it is, I don’t need another item to bring down the value of our properties.”	The impact of the proposed transmission line on visual resources, including Vistancia, is analyzed in Section 4.14.
Walter “Skip” Zahlmann	666	UC	Content unrelated to analysis
Denise & Chris Podschun	689.1	SUP PA	“I definitely support the Preferred Alternative location for the new APS lines along the north side of SR 74. Arizona has had enough difficulty in the housing market. We don’t need to add to that by having visual blight with those huge ugly power lines.”	Statement of preference.
Carole and Tom Maiello	690.1	SUP PA	“I am writing to express my support of the Preferred Alternative location for the APS lines along the north side of SR 74. This is the only option that makes sense, particularly for residents of Trilogy.”	Statement of preference.
Sally and John Chesterman	691.1	SUP PA	“As Trilogy at Vistancia residents, we send this message in support of the power lines preferred alternative location to be along the north side of SR 74.”	Statement of preference.
Walter “Skip” Zahlmann		UC	Content unrelated to analysis
Mark and Barbara Jacobsen	694.1	SUP PA	“My husband and I wish to take a moment to contact you to express our strong support for the Preferred Alternative location for the APS power lines along the north side of SR74. Given environmental concerns and the concerns of area residents, we believe that the proposed Preferred Alternative location is the right way to go.”	Statement of preference.
John & Mary Jo Packard	709.1	VIS	“It is unacceptable to have to suffer the visual impacts of the line if they are placed on the Carefree Highway alignment. We know such a move would make the lines visible from both Trilogy and many parts of Vistancia.”	Statement of preference.
John & Mary Jo Packard	709.2	LU	“As State Route 74 is already designated as a transportation corridor it makes more sense to take advantage of the situation and place the power lines along an existing corridor.”	Statement of opinion.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
John & Mary Jo Packard	709.3	LU	“SR74 is scheduled by ADOT to be expanded into a 6 lane highway. It will have 1000ft on each side of the road scaped for right-of-way. The APS lines should be installed adjacent to that 1000 ft right-of-way.”	Statement of opinion.
John & Mary Jo Packard	709.4	GEN	“It is not environmentally reasonable to build the high-powered transmission lines through native desert.”	Statement of opinion.
Donna Hanna	710.1	SUP PA	“As a Trilogy resident, I would like to comment on the State Route 74 as already being designated a transportation corridor. It only makes sense to place the APS power lines there. With the expansion of SR 74, APS will have plenty of space to install the necessary lines.”	Statement of preference.
Dorthea and Dennis Hallberg	711.1	SUP PA	” We strongly support the Preferred Alternative location for the APS lines along the north side of SR 74.”	Statement of preference.
Sierra Club on behalf of Francis Schilling	742		See Letter 116 – Added: “I have had my breath taken quite literally away so many times in my life by the natural beauty of our public lands and forests. No picture, no video, no second hand account and no great numbers of them could prepare one for the grandeur and the sheer immenseness of the beauty and majesty of those places. Those moments and that pristine majesty are priceless! What does it say about a country and its people that they would treat our natural public lands with such cavalier disrespect by allowing them to be used merely to quench the insatiable thirst of outrageous greed? Thus, I ask you to . . .”	Statement of opinion. Comment noted.
John Clemons	751.1	WLF	” As VP of the Arizona Desert Bighorn Sheep Society, I must say that the Society is for wind energy in concept. However, we would like the BLM and other officials involved with the NEPA process to be mindful of human encroachment issues and travel corridors between sheep mountain ranges.”	This is not a wind energy project. Section 4.16 analyzes impacts to wildlife. Bighorn sheep are not addressed as mapped habitat does not occur within the Study Area.
James E Jaenicke	752.1	SAAA	“Originally I supported Alternative 1 of the Draft Statement where the Transmission line would cross over to the north side of SR 74 onto BLM land and then cross back over SR 74 back onto BLM land. However, I now support Alternative 2 where the transmission lines stay on the south side of SR 74 instead of Alternative 1. The additional cost it takes to cross over SR 74 twice and use BLM lands is not prudent or efficient construction and seems just plain silly. It seems there may be ulterior motives for Alternative 1 such as a developer (Sunland) protesting the southern Alternative 2 route. This was brought up in a public meeting I attended and was presented as an argument. In either Alternative 1 or Alternative 2 the developers residential buildings will see the transmission lines. I recommend and support Alternative 2 as the best overall solution!	Statement of preference.
John McCain, United States Senator Jeff Flake, United States Senator	753.1	SUP PA	“We are writing in support of the Bureau of Land Management’s (BLM) selection of the Preferred Alternative…”	Statement of preference.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
John McCain, United States Senator Jeff Flake, United States Senator	753.2	LU	“We are pleased to know that BLM included U.S. Air Force – Luke Air Force Base as a cooperating agency in the DEIS and, as reflected in the Preferred Alternative, acknowledged the importance of not interfering with flight operations.”	Statement of preference.
John McCain, United States Senator Jeff Flake, United States Senator	753.3	GEN	“Luke Air Force Base is a vital component of our national security. We understand that the demands on our public lands are divers and complex, requiring a great deal of coordination with local governments and various stakeholders for BLM to balance multiple use demands. Therefore, we ask that you take into account the concerns of all parties, including the U.S. Air Force, and trust that the BLM’s final decision will be in the public’s best interest.”	Statement of preference.
Julie Hollman	754.1	SUP PA	” Please place powerlines north of SR74, not in Trilogy Vistancia!!!!”	Statement of preference.
Dean Sloggett	755.1	SUP PA	” We are in support of the PROPOSED ALTERNATIVE which is on the north side of State Route 74. If they put the lines on the Carefree Highway alignment, they will be visible from Trilogy and many parts of Vistancia. State Route 74 is already designated as a transportation corridor. It makes sense to place power lines along an existing transportation corridor.”	Statement of preference.
John and Linda Adkins	756.1	SOC	“…the addition of more lines would not only take away from the beauty of the landscape here at Trilogy/Vistancia; but would negatively impact our property values.”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values and tax revenue.
Cynthia Bartolone	757.1	SUP PA	“I am a Trilogy resident and want to state my opposition to the placement of APS power lines in a location other than north of SR 74.”	Statement of preference.
Cynthia Bartolone	757.2	OPP ALT3	“If they put the lines on the Carefree Highway alignment, they will be visible from Trilogy and many parts of Vistancia.”	Statement of preference.
Eric Anderson, Transportation Director, Maricopa Association of Governments	758.1	LU	“MAG has…consistently held the position on this project that transportation corridors should accommodate roadways as well as other transportation uses such as bike, pedestrian, pipelines, transmission lines, where appropriate and compatible with the roadway.”	Statement of preference.
Eric Anderson, Transportation Director, Maricopa Association of Governments	758.2	TRANS	“The preferred alternative states that a multiuse utility corridor would be established on BLM- managed public lands that would begin at the centerline of SR-74 and extend 0.5 -mile north, and also include the entire key-shaped block of BLM lands south of SR-74. It needs to be noted, that the SR-74 centerline will shift through this corridor to accommodate the ultimate SR-74 buildout concept that is proposed to include a 10 lane controlled access rural facility with a 60-foot wide open median. MAG supports the preferred alternative, however, details of the SR-74 expansion and the interaction of the proposed transmission line needs to be included in the EIS discussion to accurately portray the future transportation/utility corridor.”	Under the Proposed Action/Preferred Alternative, the multiuse corridor would exist only on the key shaped parcel of BLM-managed public land south of SR 74, not north of SR 74. Additional information provided by MAG regarding roadway expansion was incorporated into Section 4.19.13, cumulative impacts to Transportation.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Buddy Redoble	759.1	OPP ALT3	“…I would like to void my strong opinion in opposition to the idea that you and your group would consider running APS high-powered transmission lines and towers on the ‘Carefree Highway’ alignment.”	Statement of preference.
Buddy Redoble	759.2	LU	“ADOT has designated State Route 74 as a ‘Transportation Corridor’. It is also reported that the good folks at ADOT are scheduled to expand SR 74 into a ‘Six’ (6) land highway including a 1000 foot easement on each side. In other words the APS lines could be installed adjacent to that 1,000 foot right-of-way on SR74.”	Statement of preference.
Buddy Redoble	759.3	GEN	“…to run this project through native desert is not an environmentally reasonable or civically responsible act.”	The EIS evaluates the environmental reasonableness of the alternatives considered, as well as those eliminated from detailed analysis, in Chapter 2.
Buddy Redoble	759.4	VIS	“Speaking as a Trilogy resident, and on behalf of those neighbors in Vistancia, your idea of putting the lines and towers on the Carefree Highway alignment where they will be visible from Trilogy and many parts of Vistancia is completely unacceptable.”	Statement of preference.
Dennis Fisher and Peggy Fisher	760.1	SUP PA	” We wanted to add our names (Dennis Fisher and Peggy Fisher) to the many others who are in support of the Preferred Alternative location for the APS lines along the north side of SR 74. We live in Trilogy at Vistancia and do not want them in our area.”	Statement of preference.
Jack and Linda Hart	761.1	SUR	We strongly support the Red Shirt Brigade in their choice of an alternate route for the power lines proposed.	Statement of preference.
Cayce and Debbie Shannon	762.1	OPP ALT 3	” We just want to thank you for not allowing more power lines to go through Vistancia. Not only are they a visual issue, but also a health issue.”	Statement of preference.
Lynda Jefferson	763.1	SUP PA	“I am a resident of Vistancia; my family and I support the Preferred Alternative location for the APS lines along the north side of SR74.”	Statement of preference.
Gerald W. Lee	765.1	SUP PA	“As a medium length (2 1/2 years) Trilogy resident, I totally support moving the lines to the BLM lands along the north side of SR 74.”	Statement of preference.
Gerald W. Lee	765.2	VIS	“Although needed, the power lines are a blight against the beauty of the mountains. The current and future Trilogy residents would like an unimpeded view. It is bad enough we have to drive through the magnetic fields under the power lines crossing Vistancia Blvd.”	The impact of the proposed transmission line on visual resources, including Vistancia, is analyzed in Section 4.14.
Dorothy and Wayne Dennis	767.1	SUP PA	“Please note that we, as Trilogy residents support the Preferred Alternative location for the APS lines along the north side of SR 74.”	Statement of preference.
Ron Aames Peoria City Councilman	768.1	SUP PA	“As a member of the Peoria City Council, I express my support for the BLM Agency Preferred Alternative alignment for the proposed Arizona Public Service (APS) Sun Valley to Morgan 500/230 kV Transmission line. This alignment will least impact our citizens who live in northern Peoria, as hundreds of them have indicated at the public meetings you have held.”	Statement of preference.
Lee & Debra McNaught	769.1	SUP PA	Our family supports the Preferred Alternative Route for APS lines along the north side of SR 74.”	Statement of preference.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Paul R. Bernard	770.1	OPP ALT 3	“Please consider my request that no power lines be erected in the area of Trilogy or Vistancia. As a recent homebuyer here at Trilogy I feel that our property values will be adversely affected by unsightly towers and lines within close proximity and sight of our community. It is my understanding that an alternative is under consideration to have the power lines run parallel to Rte 74, a more sparsely populated area of Peoria. That proposal makes more sense to me as it will impact fewer homeowners.”	Statement of preference.
Wayne Hitchcock	771.1	SUP PA	“I am writing you to indicate my support for the agreed upon APS power line route on BLM land along the north side of SR74. This would keep the proposed power lines out of the native desert north of Vistancia.”	Statement of preference.
Dominic Bartolone	772.1	OPP ALT 3	“I am a Trilogy resident and want to state my opposition to the placement of APS power lines in a location other than north of SR 74. The power lines would blight our view of the mountains and desert and to avoid this should be placed on the north side of SR 74. To build high-powered transmission lines through native desert is not environmentally reasonable. If they put the lines on the Carefree Highway alignment, they will be visible from Trilogy and many parts of Vistancia. I am completely against this proposal and want to go on record as such. State Route 74 is already designated as a transportation corridor. It makes sense to place power lines along an existing corridor. SR 74 is scheduled by ADOT to be expanded into a 6 lane highway. It will have 1,000 feet on each side of the road scraped for right-of way. The APS lines would be installed adjacent to that 1,000 foot right-of-way. These are just some of the many reasons NOT to put these lines along the Carefree Highway but instead place them north of SR 74. Please recognize I did not move to this State and buy a home in a high class retirement community only to have to look at power lines right outside of my neighborhood.”	Statement of preference.
Tom & Myrna Van Thiel	773.1	SUP PA	“We are in support of the proposed alternative which is the north side of State Route 74.”	Statement of preference.
Herb & Sandra Cooley	776.1	SUP PA	“We support putting the proposed power lines along the northern side of SR74. Home owners in Trilogy/ Vistancia should not have these power lines visible from their communities when an already preferred alternative has been identified and is a designated transportation corridor.”	Statement of preference.
John Dimina, Jr. ABBA ELECTRIC LLC	777.1	INFO	” Would you be so kind to advise us as to how we can bid on the above mentioned project? Our company has the licenses and experience to be able to perform on such a project. Thank you for all your help in this matter, and looking forward to hearing from you.”	Solicitation of contract work. Request for information is beyond the scope of the BLM.
ROBERT & LINDA LINDGREN	778.1	SUP PA	“My wife and I both support the alternative location for the APS lines along the north side of SR 74. The visual impacts would hurt the beauty of our communities, we have a perfect alternative to keep the beauty of our communities and still put up the APS lines in a very practical place.”	Statement of preference.
David and Sue Hamilton	779.1	SUP PA	“This email is in regards to the new APS line siting in Peoria. We support the PROPOSED ALTERNATIVE which is on the north side of State Route 74. The route that goes just North of Trilogy at Vistancia would be unsightly and would no doubt lower our property values.”	Statement of preference.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Don Borland	781.1	SUR	” I am for the alternative Power line and hope that this gets passed.”	Statement of preference.
Cheryl C Greenwood	783.1	SUP PA	” I TOTALLY SUPPORT the Preferred Alternative Location for the APS Lines along the NORTH Side of SR74.”	Statement of preference.
Dorthea and Dennis Hallberg	784.1	SUP PA	” We strongly support the Preferred Alternative location for the APS lines along the north side of SR 74.”	Statement of preference.
Renee Abbett	818.1	SUP PA	“We are writing in support of the BLM’s selection of the Proposed Action as the Agency Preferred Alternative in the DEIS and BHRMPA for the APS Transmission Line.”	Statement of preference.
Renee Abbett	818.2	LU	“WE must stress the need for consistent land planning for the successful implementation of solar projects. The Proposed action as the Agency Preferred Alternative is the only route consistent with local governmental plans including the City of Peoria.”	Statement of opinion.
Renee Abbett	818.3	RENE	“The Proposed Action establishes critical redundancy and accessibility to renewable resource generation. This Proposed Action will help provide electrical reliability and reduce potential transmission congestion through an interconnected grid incorporating renewable energy and traditional energy throughout the Phoenix Metropolitan Area.”	Statement of opinion. Chapter 1 has also been updated to include additional information on the relationship between this project and renewable energy transmission.
Renee Abbett	818.4	RENE	“This decision will also expand renewable energy use opportunities for the entire solar industry…”	Statement of opinion. Chapter 1 has also been updated to include additional information on the relationship between this project and renewable energy transmission.
Renee Abbett	818.5	RENE	“This Transmission line would be a vital link between the Phoenix Metropolitan Area and Renewable Energy projects in Arizona. It would increase the development timelines for several planned renewable energy projects including: Luke Air Force Base Solar project (a planned 14mW project) Solana Generating Station (a planned 280mW project) Sonoran Generating Station (a planned 300mW project) Star Solar Project”	Statement of opinion. Chapter 1 has also been updated to include additional information on the relationship between this project and renewable energy transmission.
Renee Abbett	818.6	RENE	“There are several areas within the DEIS that we feel need additional analysis to confirm within the DEIS the priorities and recent initiatives set by the BLM. One of these priorities is to “encourage and facilitate renewable energy development – solar, wind, and geothermal – on the Nation’s public lands.” This commitment has already been established from recent initiatives such as the Solar PEIS, the BLM’s participation in the Rapid Response Transmission Taskforce and within the BLM’s own Bradshaw-Harquahala Resource Management Plan, which supports the co-location of utilities including renewable energy infrastructure transmission lines and transportation ROW within designated corridors. The BLM priorities would only need be reaffirmed through further analysis within the DEIS on how promoting alternative energy can reduce greenhouse gas emission and the selecting of the proposed action will pose no unnecessary delays to the transmission line timeline.”	BLM acknowledges in Section 1.5.2 that the project is consistent with its multiple use mandate, executive direction, and agency priorities. Additional information has been added to Section 1.5.2. Also, further analysis on how promoting alternative energy can reduce GHG is beyond the scope of this project.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Renee Abbett	818.7	GHG	“Greenhouse gas emissions as stated in the executive summary have no established method to assess impact but the analysis needs to continue with how beneficial alternative energy sources can be to this. The promotion of renewable energy reduces greenhouse gas emission, thusly benefiting the study area air quality. There is also no mention that the Preferred Alternative 500kV transmission line will impact the timeline for solar projects and also accelerate the solar generation stations or solar leases on BLM land.”	Further analysis regarding development of alternative energy sources, their locations, and construction timeframes are beyond the scope of this project. Increased use of renewable energy and further development of renewable energy projects will reduce overall GHG emissions. GHGs are global pollutants; as a result, localized reductions in GHG emissions will not immediately impact the area.
Mark A. Nelson	819.1	SUP PA	” I would like to express my support for the power line route to be north of state highway 74.”	Statement of preference.
Mark A. Nelson	819.2	LU	” Since the Arizona Department of Transportation has already secured approval for a multilane freeway through BLM land for highway 74 placing the power line along the northern edge of this corridor makes sense. Opponents of this alignment are not aware of these plans and are concerned about wildlife and scenic preservation. Since a mile wide swath will eventually be scraped for highway 74 the present pristine area they worry about will no longer exist. Once again I wish to support the route north of highway 74 above all other options. Lets confine all the environmental impacts to the same corridor.”	Statement of preference.
Harvey and Lydia Friedman	821.1	SUP PA	“…I understand that now the BLM has identified and supports the proposed alternative route, the route we, the Red Shirt Brigade, support. That route of course is the PROPOSED ALTERNATIVE which is on the north side of State Route 74.”	Statement of preference.
Harvey and Lydia Friedman	821.2	LU	“Any route on the south side of State Route 74 would severely impact both existing property as well as future development and is not compatible with the City of Peoria’s General Plan for future developments along the south side of SR 74.”	Statement of opinion.
Harvey and Lydia Friedman	821.3	GEN	“If the visual impact on Trilogy and many parts of Vistancia are not reason enough for your support of the PROPOSED ALTERNATIVE which is on the north side of State Route 74, then certainly the environmental impact that would occur were high-powered transmission lines to be built through native desert if the southern alternative were chosen is reason enough to support the PROPOSED ALTERNATIVE which is on the north side of State Route 74.”	The EIS evaluates the environmental reasonableness of the alternatives considered, as well as those eliminated from detailed analysis, in Chapter 2.
Franklin Schiller Joanna Schiller	822.1	SUP PA	“We strongly support the current proposal for the APS Power Line project, which runs along the north side of State Route 74”	Statement of preference.
Franklin Schiller Joanna Schiller	822.2	LU	“This proposal utilizes State Route 74, which is already designated as a transportation corridor and is slated for eventual expansion to a six-lane highway. Therefore, it will have minimal effect on the environment and private property, especially that of existing individual homeowners and their families.”	Statement of preference.
Franklin Schiller Joanna Schiller	822.3	LU	“In addition, this route is compatible with the City of Peoria’s General Plan and future developments along the south side of SR 74.”	Statement of opinion. Section 4.6 analyzes compliance with land use plans.
Gary Purkat	823.1	SR74	“…I wish to express my support for placing the APS powerlines along the state route 74 transportation corridor.”	Statement of preference.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Gary Purkat	823.2	OPP UR	“We already have more than enough powerlines running between us and the 303 and do not want to contend with additional visual pollution as well as possible health risks of having more powerlines strung near our community.”	Statement of preference.
Wayne & Bev Meddaugh	824.1	SUP PA	“we are supporting the group that is opting for preferred alternative location of the APS lines on the north side of State Route 74.”	Statement of preference.
Arlene & Howard Mandel	826.1	SUP PA	“We as residents of Trilogy at Vistancia wish you to know that we agree with the proposed alternative which puts the transmission lines on the north side of Rt 74.”	Statement of preference.
Connie Nichol	827.1	SUP PA	“Please recommend that the power lines be placed North of SR 74.”	Statement of preference.
Steve Strecker	828.1	SUP PA	“I am writing you to express my support for the DEIS preferred alternative for the APS power lines on the North side of SR74.”	Statement of preference.
Walter “Skip” Zahlmann	829.1	WLF	“There are wild burros on the land just north of present day Vistancia [Blackstone\| and we have wild burros roaming free –north of Vistancia / Blackstone always up to Rte 74 and maybe up wards of the north side of Rte 74. Now did the BLM and the City of Peoria, do any studies or have the developers going back to around 2000 when Sun Belt Holdings and Vistancia were first proposed, along with now Diamond Ventures and Saddleback Heights and lake Pleasant Heights? Did all the above take into consideration the wild burros and their habitat and were any applications made, any studies made, anything regarding these protected animals –burros–and their habitat ????? Was the Department of Interior notified in any way, presented with any studies or EIS studies or of something similar to an EIS study and say the City of Peoria’s Conservation Ordinance that would apply or any other requirements no matter how inconsequential they might have been to others at the time and up until the present time ???? So what about the wild burros that run wild in these areas ????????????? This would include State lands being used for the towers ?????????	Information regarding the existing burro herd management area on BLM-managed public lands within the Study Area was added to Section 3.16.
Walter “Skip” Zahlmann	830	UC	Content unrelated to analysis
Lea Marquez Peterson, President/CEO, Tucson Hispanic Chamber of Commerce	832.1	SUP PA	“We are witing in support of the BLM’s selection of APS’ Proposed Action/Electric Transmission ROW Application as the BLM Agency Preferred Alternative in the DEIS.”	Statement of preference.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Lea Marquez Peterson, President/CEO, Tucson Hispanic Chamber of Commerce	832.2	LU	“The majority of lands in Arizona are held by government agencies, which create dispersed population areas which need water, sewer, electricity, natural gas, communication, rail, and transportation utilities. All public and private utility providers are faced with the challenge of obtaining rights-of-way. Any action which facilitates and expedites right-of-way approval on public land; federal, state or local increases timely and efficient utility service delivery.”	Statement of opinion.
Lea Marquez Peterson, President/CEO, Tucson Hispanic Chamber of Commerce	832.3	LU	“APS’ Proposed action for an electric transmission ROW, is not a new disturbance, but an additional and co-located ROW within an established and Designated BLM Corridor.”	Statement of preference.
Lea Marquez Peterson, President/CEO, Tucson Hispanic Chamber of Commerce	832.4	LU	“Federal guidance found in 43 USC 1763 Right-of-Way; criteria and procedures applicable for designation supports the utilization of rights-of-way in common to minimize adverse environmental impacts and the proliferation of separate rights-of-way. The current and potential future utilization of BLM’s one-mile wide Designated Corridor along State Route 74 permits compatible and adjacent rights of way. Pursuant to 43 USC 1763, BLM’s acceptance of APS’ ROW Application/Proposed Action appropriately considers State land use policy, environmental quality, economic efficiency, national security, safety, and good engineering and technological practices. It further states that any existing transportation and utility corridors may be designated as transportation and utility corridors pursuant to this subsection without further review.”	Statement of opinion.
Rick Brown, Portfolio Manager, Sabal Financial Group, LP	833.1	SUP PA	“We support the approval of the Proposed Action as the Agency Preferred Alternative…”	Statement of preference.
Rick Brown, Portfolio Manager, Sabal Financial Group, LP	833.2	OPP ALTS	“We…oppose Alternative 2, Alternative 3 and the Sub Alternative, which place the transmission line in closer proximity to exisitng and soon-to-be-built and occupied homes.”	Statement of preference.
Rick Brown, Portfolio Manager, Sabal Financial Group, LP	833.3	LU	“The Proposed action as the Agency Preferred Alternative is the only route consistent with local governmental plans including the City of Peoria….”	Statement of opinion. Section 4.6 analyzes compliance with land use plans.

COMMENTOR NAME

COMMENT ID NO.

COMMENT TYPE

COMMENT

RESPONSE TO COMMENT

Rick Brown, Portfolio Manager, Sabal Financial Group, LP

833.4

“In several instances, the DEIS characterizes Alternative 2 and Alternative 3 south of SR74 in Peoria which goes through private mater planned communities as similar to the Preferred Alternative which places the line north of SR74 on BLM land in Peoria and Maricopa County. The DEIS incorrectly characterizing zoned and legally vested land in varying stages of pre-development process as vacant, undeveloped, grazing land. Before a home is constructed within a planned community, there are many phases in the development process, not all viable development activity is visually apparent. There is insufficient or incorrect analysis in Alternative 2 and Alternative 3 in the resources areas of Land, Transportation, Recreation, Visual Resource and Socioeconomics.”

Within applicable sections, revisions have been made to the EIS indicating that “undeveloped land” is not “raw land” and that developments on private lands are in various stages and generally describing a range of effects to developments.

Rick Brown, Portfolio Manager, Sabal Financial Group, LP

833.5

“The National Environmental Policy Act (NEPA) requires the DEIS to analyze the impacts of each alternative on past, present, and reasonably foreseeable future actions or development. While the DEIS notes Lake Pleasant Heights as a Reasonably Foreseeable Development within Appendix 4B, the DEIS does not analyze the impacts of Alternative 2 and Alternative 3 to future residents of Lake Pleasant Heights, that could occupy homes prior to APS initiating construction of the line.

The DEIS should consider future roads as foreseeable developments. Much of this has been excluded from the impact analysis and should be noted. In addition to the height and width associated with the ADOT and MAG future planning for SR74 to 6-10 lanes, regional arterials and streets are also planned south of SR74 within the Study Area identified in the DEIS. These future roads will connect master planned communities, create major intersections for commercial development and employment of centers and will connect with SR74 from the south, at major interchanges. A map showing the location of these planned roads relative to Alternative 2 and Alternative 3 and the change in traffic patterns and dispersal trips for these planned street and regional connection roads have been omitted from the DEIS analysis.”

The impact of the transmission line on the views of future residents is analyzed in Section 4.19.15. Property value effects are analyzed based on the existing condition in Section 4.10. Any residences constructed between analysis and construction of the transmission line would be with the knowledge of the impending transmission line.

COMMENTOR NAME

COMMENT ID NO.

COMMENT TYPE

COMMENT

RESPONSE TO COMMENT

Rick Brown, Portfolio Manager, Sabal Financial Group, LP

833.6

SOC

“The devaluing of land due to transmission lines has been incompletely evaluated. There are two studies provided by the NAHB which were submitted to BLM, but was not included showing Tucson, Arizona; which should be considered a very relevant comparison, with market data resulting in a negative impact of over 25%. This study should be included as additional literature in Appendix 3A. DEIS making home price comparisons of 2005 and 2009 is either current or accurate for the Phoenix metro market. Consistent improving trends in housing is not recognized.

Socioeconomic resource impacts will occur through the limitations to master planned community ability to develop. The decreased home values, prolonged timeline of sales and increased carrying costs to develop will have a much more drastic impact, which in some cases may force some property tax revenue, sales tax revenue, and construction tax revenue, impacts fees, and other city, state and federal income sources to never come to fruition. On page 4-105 the reports states that “the net effect on property tax revenue under Alternative would be beneficial, major and long term. These benefits would accrue to taxing entities and the beneficiaries of those taxes.” The increased tax base from future developments will create a drastic difference between what property tax has been represented as grazing land in Alternative 2 and 3 as compared to the more accurate analysis of primary and secondary property taxes and sales taxes generated from suburban community densities.

Homes similar to this area, would, on average, annually contribute approximately $500 to the County, $200 to the State Equalization tax, $100 to the City of Peoria, $1600 to the Peoria Unified School District, $450 to the Community College District, $200 to public services including fire, health care, flood control, and $1400 in bond tax. These taxation revenues would be threatened from both Alternative 2 and Alternative 3, as both effect hundreds to thousands of dwelling units; both by delaying them coming onto market or having lower assessed valuations. For each home devalued and/or not built, roughly $2000 would be stripped from the educational budget or a total of approximately $4000 per home in general property tax. Using these figures (provided), we believe the analysis of taxation and socioeconomic resources are incorrectly represented.

There is a direct correlation between adding residential rooftops and the development of commercial, retail operations. The DEIS does not portray or analyze the basic economics of residential entitlement, predevelopment, development, marketing and home sales. These activities stimulate a local economy, pay for government, provide public community recreation, provide jobs, and should be accounted for within the socioeconomic impact. An analysis of Peoria’s or any Phoenix metro city’s source of revenue to their general fund, will illustrate the importance of private investment and commercial and residential development to the economy. While the DEIS is significantly detailed about the economic contributions of off highway vehicle recreation and grazing allotments; the economic contributions created by construction of community infrastructure associated with master planned communities and homes, as well as employment and revenues associated with the sale of goods and services during home construction and occupancy have been ignored in the DEIS socioeconomic analysis.”

The referenced NAHB study was reviewed and deemed not applicable to the analysis of impacts to private property values because it deals with compensation for diminished property values caused by fear of EMFs. The other study provided, authored by Kurt Kielish was included in the literature review.

Home values are not used for any impact analysis in Section 4.10. Changes in the real estate market would not change the impact of the transmission line on home values. Regardless of the present value of any property, the addition of the transmission line would affect the value of the property on a percentage basis, as described in the cited source contained in the literature review in Appendix 3A.

The effect of potentially inhibiting development because of the value of the property/homes being reduced by the presence of the transmission line would be an indirect effect and is addressed in Section 4.10, as applicable.

The potential impact on taxes would be a cumulative impacts issue, and Section 4.19.11 is revised, as applicable.

The detail provided in the EIS analysis of socioeconomic impacts of OHV recreation attempts to describe the current contributions of OHV recreation to the local economy, and the impact the transmission line would have on that economic driver. The comment is suggesting that the transmission line would inhibit anticipated future economic drivers, which is a type of analysis, and is now addressed in Section 4.19.11, as appropriate.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Rick Brown, Portfolio Manager, Sabal Financial Group, LP	833.7	VIS	“The DEIS states that the impacts to visual resources in Alternative 2 and Alternative 3 would result in a contrast that would be weak and the long term impact would be negligible. These conclusions are not based on a proper analysis required through Key Observation Points guidelines, such that Key Observation Points (KOPs) should first identify residential viewers, including those in reasonably foreseeable developments.”	Due to private land access issues and the currently undeveloped nature of the areas adjacent to Alternative 3, limited KOPs in this area were deemed adequate for impact analysis.
Steve Saway	834.1	OPP PA	“I do not support the APS Proposed Action and BLM’s Preferred Action.”	Statement of preference.
Steve Saway	834.2	SRMA	“The BLM Resource Management Plan (RMP) for this area was developed after years of very extensive public involvement and collaboration. The results of that collaboration are reflected in the RMP decisions. The area envisioned for the transmission line project north of Hwy 74 was not identified as a utility corridor. Rather, that area is part of the Castle Hot Springs Management Unit. This entire management unit was allocated to the Castle Hot Springs Special Recreation Management Area. This decision was not made lightly. It reflects the outstanding recreation and resource values within the management unit and particularly within the Hieroglyphic Mountains Recreation Management Zone. The desired future conditions for this management unit include an emphasis on preserving open space and scenic/visual qualities and maintaining an array of recreation settings for both motorized and non-motorized activities. This area also has other important resource values, including category 2 desert tortoise habitat and class II visual resources.”	Section 2.10 describes the rationale for why the BLM is selecting the Proposed Action as the Agency Preferred Alternative.
Steve Saway	834.3	OHV	“The area north of Hwy 74 has been developed and managed as a highly popular off-highway vehicle (OHV) destination. Considerable investment has been made to develop the Boulders Staging Area and network of trails in the Hieroglyphic Mountains, including investments from both BLM resources and State of Arizona OHV funds. It provides an important venue for both local and non- local visitors to ride in a designated OHV area that promotes safe and responsible riding. This area has proven to be a successful showcase of how the BLM and State of Arizona partnership can offer a safe, responsible, and popular venue for OHV recreation. The growing number of user visits to this area is a tribute to the success of this partnership. It should be recognized too that this venue has offered a great opportunity for the Arizona OHV Ambassador Program to promote safe and responsible riding.”	Applicable revisions and additional mitigation measures have been added to Section 4.9 addressing impacts to OHV recreation.
Steve Saway	834.4	OPP RMPA	“In my view, the BLM should not select the Proposed Action as its Preferred Action because that would disregard (if not denigrate) the decisions made in the RMP to manage this area for its scenic and recreational values. Placing a utility corridor north of Hwy 74 would change the character and integrity of the BLM lands it would traverse. Plus in my view, it would create unacceptable adverse impacts to the recreational uses and public enjoyment of these lands. It could possibly result in OHV users going to other, less appropriate riding areas with greater potential for user conflicts. Why jeopardize the recreational successes BLM has achieved in this area?”	Section 2.10 describes the rationale for why the BLM is selecting the Proposed Action as the Agency Preferred Alternative. Applicable revisions and additional mitigation measures have been added to Section 4.9 addressing impacts to OHV recreation.
Steve Saway	834.5	SAAA	“I believe the BLM should give serious consideration to selecting Alternative 2 or Alternative 3 as the agency’s Preferred Action. That would sharply reduce the utility corridor’s conflicts with the RMP decisions and the adverse impacts it poses to recreational uses and public enjoyment of BLM lands.”	Statement of preference.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Lynn Hodge	835.1	SUP PA	“I support the position of the City of Peoria for the APS line route.”	Statement of preference.
Norman (Sonny) Sonnenberg Marilyn Sonnenberg	855.1	GEN	“The noise and dreadful looking power lines that would be hanging near this beautiful area is really very upsetting…”	The visual and noise impacts, and mitigation measures addressing those impacts from the proposed transmission line are analyzed in Sections 4.7 and 4.14, respectively, of the EIS.
Norman (Sonny) Sonnenberg Marilyn Sonnenberg	855.2	SOC	“The environment impact on this community if they were too located here would be devastating to both Value and desire to live here.”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values and tax revenue.
Norman (Sonny) Sonnenberg Marilyn Sonnenberg	855.3	NOISE	“The NUMBER #1 complaint was that the hissing noise that they created was extremely loud and it was a continues noise 24 hours a day. It will drive you absolutely nuts to listen to that.”	The impacts from and mitigation of noise generated by the proposed transmission line are analyzed in Section 4.7.2.1 of the EIS.
Norman (Sonny) Sonnenberg Marilyn Sonnenberg	855.4	SUP PA	“I am very pleased to know that BLM has stated great support for the Certificated Route and ask us for our support to that decision, you have our full support for that and it is a decision that is best for the environment impact. The choice that the Arizona Corporation Commission had agreed to by moving the lines out of this community and on public land north of State Route #74 to permanently secure that location is by far a superior choice for this community.”	Statement of preference.
Douglas Pierson	856.1	SUR	“I am requesting that you move forward with the certificated route according to your mapped and outlined areas shown for the transmission lines to be placed. I feel this would be detrimental to the village as for placement, health wise, as well as the economic impact if it were to be placed differently.”	Statement of preference.
Dana Pagliarulo	859.1	SUP PA	“By proposing that APS erect the power lines along the preferred Northern route along Route 74, you save Vistancia from blemishing the quality of life here and the value of our homes and this community.”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values and tax revenue.
Mary Taussi	860.1	SUP PA	“I support the certificated route (Alternative 1) which is also supported by APS, BLM, various political officials, AZ State Land Department and many more.”	Statement of preference.
Mary Taussi	860.2	OPP ALT3	“Power lines do not belong in or near the Vistancia community. I can’t imagine how this would affect our health, property values and wildlife.”	Statement of preference.
Joseph Taussi	861.1	SUP PA	“As a resident of Vistancia, I fully support the certificated route for the APS transmission line (Alternative 1) as the best possible route.”	Statement of preference.
Jill Pierson	862.1	VIS	“Unsightly power lines disrupt the natural beauty of our desert. They stick out like sore thumbs, tower over buildings and natural landscape…”	The impact of the proposed transmission line on visual resources, and specifically the visual resources north of SR 74, is analyzed in Section 4.14.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Jill Pierson	862.2	NOISE	“They…generate a constant annoying “humming” noise, all of which is inconsistent with harmonious living.”	The impacts from and mitigation of noise generated by the proposed transmission line are analyzed in Sections 4.7.2.1 of the EIS.
Jill Pierson	862.3	SOC	“The presence of power lines also decrease the value of land, thereby decreasing the tax base. All taxpayers would certainly be negatively impacted. Land and homes that are built near power lines are extremely or nearly impossible to sell as demonstrated in a neighboring community off Vistancia Blvd, Coldwater Ranch. The majority of the homes are vacant and remain unsaleable due to the close proximity to the power lines. When in the area, a constant audible sound can be heard emanating from the power lines.”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values and tax revenue. The impacts from and mitigation of noise generated by the proposed transmission line are analyzed in Sections 4.7.2.1 of the EIS.
Jill Pierson	862.4	PH&S	“Studies have been conducted whereby the results indicate our health is compromised by residing close to power lines. They are considered to be a health hazard.”	Impacts to Public Health and Safety from all alternatives are analyzed in Section 4.7.
Jill Pierson	862.5	SUP PA	“I support The Bureau of Land Management’s recommendation of Alternative 1 (the certificated route) and am opposed to all other alternatives.”	Statement of preference.
Douglas and Mary Johnson	863.1	SUP PA	“We (Doug and Mary) appreciate the opportunity to express our support for “Alternate 1,” the certified route, which runs along the north side of SR-74.”	Statement of preference.
Carl Johnson	864.1	SUP UR	“We support the present certified route to be installed by APS.”	Statement of preference.
Carl Johnson	864.2	OPP ALT3	“We don’t want any power grids, substations or power line in Vistancia.”	Statement of preference.
David Goldstein, President, Diamond Ventures	865.1	SUP PA	“Diamond Ventures supports the Preferred Alternative Route for the Transmission Line because it would: (1) further the national policy of promoting renewable energy and increasing reliability of the electric grid; (2) create jobs; (3) protect private property; (4) be consistent with state and local planning; and (5) promote the multiuse of a BLM designated corridor.”	Statement of preference.
David Goldstein, President, Diamond Ventures	865.2	OPP MUC	“Diamond Ventures, however, does not support the amendment of the BHRMP as provided for in the Preferred Alternative because the amendment is not consistent with the ROW application, sufficient rationale and analysis is not included in the DEIS, private property surrounds the 1,013 acres and the DEIS states that there would be a change in management of lands by BLM. Co- location and future development projects could occur in the 1,013 acre multi-use corridor with accompanying impacts to resources. Diamond Ventures’ is concerned that certain aspects of the proposed BHRMP amendment are unnecessary and could negatively impact private properties and recreationists, including Saddleback Heights.”	Section 1.3.2 explains BLM’s need to amend the RMP. Section 2.10 describes the rationale for the Agency Preferred Alternative and Section 2.3 describes the reason for the RMPA. Further, Section 4.1.3 indicates that analysis of impacts resulting from future development within a multiuse corridor would be required prior to authorization. The analysis done at that time would address any potential impacts to surrounding private lands.
David Goldstein, President, Diamond Ventures	865.3	LU	“the FEIS must not characterize reasonably foreseeably development such as Saddleback Heights as “vacant” or “undeveloped” land when considering the environmental impact the transmission line alternatives will have on the fifteen identified resources on private property.”	Revisions have been made to the EIS indicating that “undeveloped land” is not “raw land” and that developments on private lands are in various stages of planning and generally describing a range of effects to developments.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
David Goldstein, President, Diamond Ventures	865.4	RENE	“…the Transmission Line would provide a vital link between the Phoenix metropolitan area and renewable energy projects in Arizona… To be consistent with federal renewable energy policy, the FE IS should reflect the fact that the Project would assist the region in meeting the national policy of providing renewable energy.”	BLM acknowledges in Section 1.5.2 that the project is consistent with its multiple use mandate, executive direction, and agency priorities. Additional information has been added to Section 1.5.2.
David Goldstein, President, Diamond Ventures	865.5	GEN	“The FEIS must also evaluate the amount of time and resources each alternative will take to proceed through any State or local permitting processes compared to the Preferred Alternative given the Department of the Interior’s interest in expeditiously increasing the amount of renewable energy generation and transmission.”	Section 4.10.2.4, No Action Alternative was revised to include discussion of the need for APS to return to the ACC process, and address potential indirect socioeconomic effects of that action.
David Goldstein, President, Diamond Ventures	865.6	SOC	“In the recent austere economic times, job creation is essential to the recovery of the national economy, especially areas that were the most hard-hit in the years between 2007 to 2009 such as in the American Southwest. Adopting the Preferred Alternative Route will accelerate the creation of jobs for the region in the construction of the Transmission Line and the potential for development of renewable energy generation sites, facilitating the construction of homes and commercial, retail, office, industrial, civic buildings will create both temporary employment as well as permanent jobs and will generate revenue for the region in fees and taxes. Therefore, the FEIS should consider the positive effect the Transmission Line will have on the local economy and job creation. The FEIS must also consider the reasonably foreseeable timing of those jobs compared to other DEIS alternatives.”	Sections 4.10.2, Alternative 2, Alternative 3, and the No Action Alternative were revised to include discussion of the need for APS to return to the ACC process, and address potential indirect socioeconomic effects of that action.
David Goldstein, President, Diamond Ventures	865.7	SOC	“In addition, if a high voltage transmission line such as the one associated with the Project is located on private lands as proposed in Alternatives 2 and 3, it will forestall certain phases of the development and adversely impact the assessed value of residential and commercial properties on privately-owned land. To be consistent with national policy, public lands should be used for public purposes such as the production of renewable energy. See P. L. 109-58, § 211. Private land owners should not bear the burden of implementing the Administration’s policy when a suitable and designated corridor already exists on public land for the Transmission Line.”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
David Goldstein, President, Diamond Ventures	865.8	PH&S	“Moreover, siting the Transmission Line within the Preferred Alternative Route on public lands would lessen homeowners’ concerns regarding the potential public safety and health risks associated with prolonged exposure to a high voltage transmission line. Accordingly, to preserve property values and to avoid any public safety and health fears, the FEIS should adopt the Preferred Alternative Route.”	Impacts to Public Health and Safety from all alternatives are analyzed in Section 4.7.
David Goldstein, President, Diamond Ventures	865.9	LU	“The Preferred Alternative Route is within an existing one-mile wide designated corridor on BLM lands, and ADOT has indicated that the Transmission Line would be a compatible use within its transportation easement. The shared use of the designated corridor with the Transmission Line would also minimize any environmental disturbance associated with the line. Therefore, to be consistent with federal land policy and to minimize any environmental negative impacts associated with the corridor, the FEIS should adopt the Preferred Alternative Route.”	Statement of preference.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
David Goldstein, President, Diamond Ventures	865.10	LU	“The FEIS should also consider the impact each alternative would have on the capitol improvements, use, and expansion of SR 74.”	The EIS contains text additions to Sections 3.6.3 and 4.6.2.2.
David Goldstein, President, Diamond Ventures	865.11	GEN	“the FEIS should give considerable weight to the ACC proceedings and decision as well as the significant community support for the Preferred Alternative Route that has been consistent from 2010 forward.”	NEPA requires that a Federal Agency give weight to the entire human environment.
David Goldstein, President, Diamond Ventures	865.12	GEN	“The FEIS should also recognize that any other action is likely to significantly delay the implementation of this line by increasing the needed review time at both the state and local level by essentially restarting the approval processes with entities such as the ACC.”	Chapter 2, Alternatives 2, 3, and the Sub-alternative, and Section 2.7 (Alternatives Eliminated from Detailed Analysis), and Section 4.10.2.4 – No Action Alternative were revised to include discussion of the need for APS to return to the ACC process, and address potential indirect effects of that action.
David Goldstein, President, Diamond Ventures	865.13	OPP MUC	“Although Alternative 1 would use the same route as the Preferred Alternative, it would establish a multiuse utility corridor on BLM-managed lands that would begin at the centerline of SR 74 and extend 0.5 mile north, and also include the entire block of BLM lands south of SR 74, potentially allowing for uses incompatible with residential and commercial development.”	Under the Proposed Action/Preferred Alternative, the multiuse corridor would exist only on the key shaped parcel of BLM-managed public land south of SR 74, not north of SR 74. Section 2.10 provides the description of the Agency Preferred Alternative. The decision for proposing to manage this parcel of land was made in order to avoid potentially having to go through the RMPA process again for any proposed and future right-of-way requests.
David Goldstein, President, Diamond Ventures	865.14	OPP RMPA	“An amendment, however, to the BHRMP is unnecessary… the siting of the Transmission Line would not be a “major change” to the use or to BLM’s policy. The BHRMP provides that BLM is encouraged to use joint uses of existing corridors and promote renewable energy. The route selected in the Preferred Alternative fits squarely within these directives. Consequently, it would not be a “major change” for the FEIS to adopt the Preferred Alternative. 43 CFR 1610.5-4 provides that resource management plans and supporting components may be changed by a Maintenance Action to reflect minor changes in data and to further refine or document a previously approved decision incorporated in the plan. Corrections and minor clarifications of resource management plans are also recorded by errata.”	BLM finds that consideration of the Proposed Action, Alternative 1 and Alternative 2 would require the RMP to be amended to comply with the FLPMA as explained in Section 1.3.2.
David Goldstein, President, Diamond Ventures	865.15	OPP RMPA	“As described above, the Transmission Line is clearly consistent with the BHRMP’s broad-based goals and objectives of promoting renewable energy and utilizing existing corridors for joint use. Therefore, no amendment to the plan is necessary. Requiring an amendment to the plan would be applying inflexible standards and prescriptions that should not be applicable to situation such as this where the Transmission Line fits squarely within the plan’s goals and objectives.”	BLM finds that consideration of the Proposed Action, Alternative 1 and Alternative 2 would require the RMP to be amended to comply with the FLPMA as explained in Section 1.3.2.
David Goldstein, President, Diamond Ventures	865.16	OPP MUC	“The dimensions for the proposed multiuse corridor in the Preferred Alternative are significantly different from the Proposed Action and existing designated corridor along SR74 and are not necessary to evaluate the subject ROW application. Moreover, the designation of 1,013 acres south of the SR74 on BLM land as multiuse and VRM IV allows a number of types of disturbances of BLM lands, including, but not limited to, cell towers and gravel pits, which would negatively impact private property values, including reasonably foreseeable developments such as Saddleback Heights.”	BLM can amend the RMP under FLMPA to address needs as they see necessary to address management issues. Further, Section 4.1.3 indicates that analysis of impacts resulting from future development within a multiuse corridor would be required prior to authorization. The analysis done at that time would address any potential impacts to surrounding private lands.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
David Goldstein, President, Diamond Ventures	865.17	OPP MUC	“…the DE IS does not include any analysis or justification for such a broad designation. Nor does it provide any methodology for how BLM determined the amount of acreage. It also fails to discuss how the designation would impact neighboring private properties.”	Section 4.1.3 indicates that analysis of impacts resulting from future development within a multiuse corridor would be required prior to authorization. The analysis done at that time would address any potential impacts to surrounding private lands.
David Goldstein, President, Diamond Ventures	865.18	VIS	“The DEIS states that the Proposed Action would meet VRM Class objectives on approximately half of the VRM Class Ill designated lands north of SR7 4 and approximately 75% of the Class Ill lands south of SR7 4. It further states that in the area where the transmission line would dominate the view on BLM management public lands it would not affect the Scenic Quality rating assigned to the Scenic Quality Rating Unit and there would be no effect to the Visual Resources Inventory. The transmission line would reside within a 200′ ROW and the DEIS states that impacts are limited to within 200′ of the transmission line. For the seven miles of BLM lands north and south of SR74,this would equate to 339 acres of impact. The DEIS does not contain analysis and methodology supporting the decision to change 2,362 acres north of SR7 4 and 1,021 acres south of SR74.”	The methodology is provided in Section 4.14.1 and analysis is provided in Section 4.14.2 of the EIS.
David Goldstein, President, Diamond Ventures	865.19	OPP MUC	“The DEIS refers to the BLM land south of SR7 4 as the “key-shaped public land piece”. The location and configuration of the parcel and it being surrounded on three sides by private land with reasonably foreseeable development do not support designating the entire BLM parcel and acreage beyond what is needed for the Proposed Action as multi-use corridor. Therefore, any multiuse designation in the FEIS should be limited to the existing designated corridor. At a minimum, the FEIS must provide the justification and methodology for the designation and analyze how the amendment would impact nearby private property, including reasonable foreseeable development such as Saddleback Heights.”	BLM can amend the RMP under FLPMA to address needs as they see necessary to address management issues. Further, Section 4.1.3 indicates that analysis of impacts resulting from future development within a multiuse corridor would be required prior to authorization. The analysis done at that time would address any potential impacts to surrounding private lands.
David Goldstein, President, Diamond Ventures	865.20	GEN	“These directives in the BHRMP create a potential inconsistency between the goal of minimizing visual impacts and the Administration’s policy of promoting renewable energy. If amended, therefore, the BHRMP should be amended to reflect the Administration’s “highest” national priority of promoting renewable energy projects, particularly when they can be located within existing designated corridors.”	The RMP amendment is appropriate as discussed in Sections 1.3.2, 1.5, and 2.3.
David Goldstein, President, Diamond Ventures	865.21	LU	“…Designating the subject transportation corridor as a multiuse corridor would minimize any environmental impacts while satisfying the national policy of promoting renewable energy. Therefore, if amended, the BHRMP should be revised to designate the existing SR-74 designated corridor as a multiuse corridor that would accommodate the Transmission Line as well as the planned expansion of SR74.”	Section 2.10 describes the rationale for the Agency Preferred Alternative.
David Goldstein, President, Diamond Ventures	865.22	LU	“Although the DEIS acknowledges that a significant amount of acreage is slated for commercial and residential development by Saddleback Heights, it treats the land as “vacant or undeveloped”. The private land in Peoria impacted by Alternatives 2 and 3 should not be characterized as “vacant and undeveloped”. Rather, the private land is planned, approved, permitted, and the commercial and residential development is reasonably foreseeable. Moreover, there are significant ongoing investments being made in the development of Saddleback Heights. Accordingly, the FEIS should analyze Saddleback Heights as a reasonably foreseeable development as opposed to “vacant or undeveloped” land.	Revisions have been made to applicable sections of the EIS, to indicate that “undeveloped land” is not “raw land” and that developments on private lands are in various stages of planning, and generally describing a range of effects to developments.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
David Goldstein, President, Diamond Ventures	865.23	SOC	“The DEIS acknowledges that “[p]roximity of a property to a transmission line could be a significant factor for impacts on property values”, but states that “properties beyond 200 feet did not experience any negative price effects.” 3.10.7.3,. 3-107. Under NEPA, the DEIS must describe the analytical methodology sufficiently so that the reader can understand how the analysis was conducted and why the particular methodology was used.”	Appendix 3A was revised to incorporate additional sources that provided comments on the EIS. Section 4.10 was revised to change the methodology for determining property value impacts to private property in conjunction with the additions to Appendix 3A.
David Goldstein, President, Diamond Ventures	865.24	SOC	“In Valuation Guidelines for Properties with Electric Transmission Lines, Kurt C. Kielisch, ASA, IFAS, SRIWA, RIW-AC states that: “Electric transmission lines do not directly serve electric utility customers: their power is distributed from distribution point to distribution point. Transmission lines wires are not insulated and are bare. His report researched the impact of electric transmission lines including collecting and indexing research studies, published articles and transcripts in order to determine public perception of high voltage transmission lines. His summary report details twelve specific case studies of the impact of electric transmission lines on real estate values. He recounts information from one national study on the perception of power lines on value and marketing time, that states that 83% of real estate appraisers surveyed said that the presence of power lines negatively affected property values. He also cites a study from the Houston area that found that buyers refused to look at properties that adjoined a power line easement and that such properties took much longer to sell. Numerous studies cited in his report showed that land and homes impacted by electric transmission lines had negative impacts to assessed values of greater than 30%. He also reports on one subdivision where the lots abutting the transmission easements were twice the size of non-easement lots. When factoring in the size of lots, the overall loss of value to the project is even greater. Another study showed that a pending 345kV line was the principal reason the buyer gave for a low offer. A Wisconsin sales analysis recounted a transaction on a property with a home appraisal for $221,000. After installation of a 345kV and 138kV transmission line, as well as the property premises and remodeling of the residence, the home was placed on the market at the revised appraisal of $179,900. The home sold for $128,500. The Kielisch report concludes that the actual loss to property value attributable to an electric transmission line depends on numerous factors, but that significant negative effects can be stated with a high degree of certainty. Here, the DEIS does not describe the methodology used, nor does it discuss what assumptions, including the geographic and temporal scope of the analysis, were made in reaching this conclusion. Accordingly, the FEIS must describe how this conclusion was reached and what assumptions were made in reaching these conclusions.”	Appendix 3A was revised to incorporate additional sources provided with comments on the EIS. Section 4.10 was revised to change the methodology for determining property value impacts to private property in conjunction with the additions to Appendix 3A.
David Goldstein, President, Diamond Ventures	865.25	LU	“…to the extent that any of the alternatives would result in a piece-mealing of Saddleback Heights, or other reasonably foreseeable developments, the FEIS should consider the impact that any of the alternatives would have on the State Trust Land within Saddleback Heights.”	Impacts to State Trust land are analyzed throughout Chapter 4; however, any impacts to the parcel of State Trust land would be resource-specific. Most impacts are aggregated.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
David Goldstein, President, Diamond Ventures	865.26	LU	“The DEIS discusses Alternatives Considered but Eliminated. In several of these alternatives, the conclusion was that the alternative was not environmentally feasible because it interrupted the continuity of portions of a development, be adjacent to a proposed community and be in close proximity to residences. These statements and rationale are also applicable to Alternative 2 and Alternative 3 and provide additional support the Preferred Alternative and the distinctions between the Preferred Alternative and the alternatives that interrupt, bisect, and are adjacent to developing residential neighborhoods.”	Additional information was added to the Land Use Section 4.6 acknowledging that the transmission line under Alts 2 and 3 would bisect Saddleback Heights and any other developments. This would add accurate information to the EIS, but would not change the analysis. Further, please note that bisecting or bifurcating development property was not the sole factor in reaching a decision as to whether or not an alternative was dismissed from detailed analysis.
David Goldstein, President, Diamond Ventures	865.27	SOC	“Moreover, because the same analysis regarding State Land potential master planned communities discussed above applies to reasonably foreseeable development on private lands, the FEIS should also consider the impact the alternatives would have on the nature, make-up and values of neighboring master-planned communities such as Saddleback Heights.”	See Section 4.10 for analysis of impacts to the value and usability of private lands for development.
David Goldstein, President, Diamond Ventures	865.28	GEN	“The DEIS states that the Proposed Project spans 38 miles on “mostly non-public land”. This is not accurate; the majority of this transmission line spans public land.”	The majority of lands crossed by the proposed ROW would be State trust lands. The ASLD does not consider State trust lands to be “public land” in the same sense that BLM-managed public lands are “public land.” Therefore the statement as quoted is correct and no change was made as a result of the comment.
David Goldstein, President, Diamond Ventures	865.29	GEN	“The DEIS suggests that its analysis should assess costs associated with restoration of OHV areas disturbed by construction activities; we would question why the DEIS limits its assessment of this restoration only to OHV areas.”	This was a scoping issue – that OHV trails be rehabilitated after construction, thus was described and summarized in this specific section.
David Goldstein, President, Diamond Ventures	865.30	SOC	“In addressing the socioeconomic impacts of the Proposed Action and Alternatives, the Executive Summary suggests that its baseline for analyzing the impacts to area property values should be “the already weakened housing market.” In fact, the housing market, especially in the Phoenix Metro area, is on the rebound, and this should be reflected in the DEIS? Before Real Estate Consulting analysts state that new housing permit activity was up 60% in the Phoenix Metro last year, and overall pricing increased 10% in 2012. The housing market in North Peoria and the real estate Sub- Market statistics for Peoria exceed the regional averages.”	Impacts to socioeconomic resources are described in Section 4.10. Changes in the real estate market would not change the impact of the transmission line on home values. Regardless of the present value of any property, the addition of the transmission line would affect the value of the property on a percentage basis, as described in the cited source contained in the literature review in Appendix 3A.
David Goldstein, President, Diamond Ventures	865.31	LU	“The DEIS Executive Summary states that the analysis under the DEIS should “consider the quality of the lands north of SR74 for conservation management by the BLM as opposed to expanded development into BLM lands. ” We object to this characterization of the transmission line’s placement north of SR74, and believe instead that it represents co-location of transmission with a transportation corridor.”	This comment is quoting from Section ES.6.1, Public Scoping. The Executive Summary summarizes information that was gathered during internal and external scoping, and is presented in Table 1.8-2. The referenced text is stating the issue as it was raised during scoping, and is not BLM’s characterization of the project.
David Goldstein, President, Diamond Ventures	865.32	CUL	“The DEIS Executive Summary states that “Tribes have expressed concern regarding amending the Bradshaw-Harquahala RMP and impacts to prehistoric sites” but does not make clear which Tribes have submitted.”	It is irrelevant to the impact analysis for the project regarding what specific Tribes have expressed concerns. See Sections 1.6, 3.3.7, 4.3, and 5.5. Section 3.3.7 and 5.5 both indicate which Tribes the BLM is consulting with. Table 5.5-1 in Section 5.5 provides a table that includes the concerns of each Tribe.
David Goldstein, President, Diamond Ventures	865.33	GHG/CC	“The DEIS does not acknowledge that Green House Gas Emissions are reduced by the development of renewable energy resources.”	Section 4.19.3 has been revised to state that development of renewable energy sources will reduce GHG emissions.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
David Goldstein, President, Diamond Ventures	865.34	AIR	“The DEIS states that particulate effects between the Proposed Action and Alternative Two is “essentially the same, just slightly lower.” However, this conflicts with Tables 4.2-2 and 4.2-79, which show that the Proposed Action’s PM-1 0 and PM-2.5 levels would be considerably lower than Alternative Two, at 4.33 and 1.08 respectively for the Proposed Action, and 28.6 and 6.1 for Alternative Two. If the Tables are accurate, we respectfully submit that the narrative of the DEIS should be corrected.”	Totals for PM-10 and PM-2.5 in Table 4.2-7 have been corrected. No changes have been made to the text as it now accurately reflects the information in the tables
David Goldstein, President, Diamond Ventures	865.35	RENE	“The DEIS lacks any assessment of the positive impacts that the facilitation of solar energy via the construction of the Sun Valley to Morgan transmission line would have on air quality in Maricopa County. This was specifically recognized in the BLM’s Restoration Design Energy Project, which acknowledged the estimated 1,700 pounds of C02 which would be annually displaced per megawatt-hour of renewable energy produced.”	Cumulative effects to Air Quality and Climate Change in Section 4.19.3 have been revised to consider the cumulative impact of facilitation of renewable energy.
David Goldstein, President, Diamond Ventures	865.36	CUL	“The impacts of the transmission line placed on the south side of SR74 to Saddleback Heights cultural resources were presented to the ACC during the Line Siting case by Suzanne Griset, PhD Anthropology.”	All applicable and relevant information was used for the analysis presented in the EIS.
David Goldstein, President, Diamond Ventures	865.37	CUL	“In evaluating Cultural Resource impacts, the DEIS omits any analysis of impacts on private lands which were considered as part of the underlying ACC case. Similar to the BLM’s analysis of impacts to State Lands, impacts to private lands should enhance the DEIS analysis and ultimately direct appropriate use of BLM lands.”	In Section 3.3.4 the EIS states, “To fulfill its responsibilities under Section 106 and as a condition of a ROW grant, BLM would require Class III inventories of private lands to identify and assess the effects on any historic properties prior to development.” Further, a supplemental inventory was conducted that included private lands where right-of-entry was granted for cultural resource surveys. The results for private land were added to the EIS.
David Goldstein, President, Diamond Ventures	865.38	LU	“The amount of acreage and land uses within Saddleback Heights impacted by the transmission line placement on the south side of SR7 4 was presented by Ken Abrahams during the ACC Line Siting case and to the BLM by Wendell Pickett, Grey Pickett during the Sun Valley to Morgan Transmission Line Seeping meeting.”	All applicable and relevant information was used for the analysis presented in the EIS.
David Goldstein, President, Diamond Ventures	865.39	LU	“The DEIS quotes the FLPMA regarding protection of resources and public participation, but does not quote the FLPMA regarding minimizing proliferation of separate rights of way and the requirement of utilization of rights-of-way in common to the extent practical.”	Text addition made per comment to Section 3.6.2.1.
David Goldstein, President, Diamond Ventures	865.40	LU	“The DEIS does not reference the BLM Land Use Planning Handbook H-1601-1, the Department of Energy National Electric Transmission Congestion Study, or the BLM 2800 ROW Manual/Handbook as relevant in the section referencing Federal Law, Ordinance, Regulation and Standards.”	A text addition was made to Section 1.3.2 referencing Handbook H1601-1 in conjunction with the Need for BLM Action (related to the need to amend the Bradshaw-Harquahala RMP). Consideration of the handbook in conjunction with laws, ordinances, regulations and standards in Section 3.6.2 is not relevant to the analysis of impacts to Land Use. While the Department of Energy National Electric Transmission Congestion Study (2009) indicates that the Phoenix area is constrained, particularly for transmission of electricity generated through solar or geothermal, this information is not relevant to the analysis of impacts to land use, and has not been referenced. Manual Series 2800 provides BLM policy and administrative guidance for issuing ROWs, and is not relevant to the Land Use discussion in Section 3.6.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
David Goldstein, President, Diamond Ventures	865.41	LU	“The DEIS does not acknowledge that the Land Use and Realty provisions of the Castle Hot Springs Management Unit may need to be amended as would several Record of Decision maps.”	Land Use Decision LR-30 states, “No new utility corridors are designated within the MU.” Under the Proposed Action, a utility corridor would be established within the MU. Text was added to Section 1.3.2, and Table 1.5.1, Decisions to be Made, was revised to indicate that LR-30 would be eliminated.
David Goldstein, President, Diamond Ventures	865.42	LU	“The DEIS does not include the ACC Biennial Transmission Assessments, or the Arizona State Land Department 5-Year Disposition Plan as relevant State Plans.”	The ACC Biennial Transmission Assessment assesses the adequacy of existing and planned transmission facilities to meet the needs of the state. While construction of transmission facilities affects land use in the state, the assessment itself is not relevant to analysis of impacts of the proposed project on land use, and therefore was not referenced in the EIS.
David Goldstein, President, Diamond Ventures	865.43	LU	“The DEIS would be improved by including relevant policy provisions, tables and maps of the City of Peoria’s General Plan.”	The City of Peoria’s General Plan is referenced in the EIS in Section 3.6.3.3.
David Goldstein, President, Diamond Ventures	865.44	GEN	“The DEIS uses specific terminology consistent with many of the disciplines associated with the resources analyzed. However, the DEIS shows a lack of knowledge of real estate industry standards; different sections of the DEIS use inconsistent and undefined terms when discussing real estate. This limits the ability to assess impacts. Examples of undefined terms include: ‘Low to medium density’, ‘conceptual residential subdivisions’ ‘very little’ commercial development occurs in the Study Area, ‘weakened housing market’, etc.”	Definitions of specific terminology have been added to the document glossary in Section 6.3; however, other terminology effectively communicates a general understanding of the subject matter such that the average reader can understand the meaning.
David Goldstein, President, Diamond Ventures	865.45	LU	“Utilities should include water, sewer, road, communications, natural gas and rail in addition to electricity. Existing utilities which are identified in the ADOT ROW Preservation Study as crossing SR74 should be noted.”	Applicable and available information relevant to the impact analysis is either already in Section 3.6 or has been added to relevant portions of Section 4.19, Cumulative Impacts.
David Goldstein, President, Diamond Ventures	865.46	NEPA	“The DEIS does not address Reasonably Foreseeable Actions in Affected Environment or through the majority of Environmental Consequences. Reasonably Foreseeable Actions, specifically the master planned developments in Peoria should be acknowledged early and throughout the DEIS.”	Reasonably Foreseeable Actions are addressed in Section 4.19, Cumulative Impacts.
David Goldstein, President, Diamond Ventures	865.47	LU	“The map which reflects existing land uses shows no private land within the entire map.”	The maps in the EIS reflect color revisions and/or revised legends to clarify presence of private land.
David Goldstein, President, Diamond Ventures	865.48	LU	“The DEIS does not properly contextualize the scope of impacts to BLM property. It states that impacts to private property would be “proportionately small” while not noting the even more de minimis impacts to total BLM acreage.”	Section 4.6.2.1 of the EIS states, “The amount of BLM-managed public lands crossed varies by alternative; however, in all cases the amount would be proportionally small compared to the total amount of BLM-managed public lands in the Study Area.”
David Goldstein, President, Diamond Ventures	865.49	PH&S	“Saddleback Heights and other master-planned communities are not identified as Nearby Residential Communities in the Ambient Noise Sources table.”	The communities do not yet exist thus this is addressed under cumulative impacts Section 4.19.8.1.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
David Goldstein, President, Diamond Ventures	865.50	PH&S	“The DEIS conclusion does not recognize the conflicting studies quoted in the DEIS. It does not reconcile the British Medical Journal Study which concluded that children living within 200 meters or 600 feet were at an increased risk of childhood leukemia and that children living within 600 meters, 1,800 feet were statistically more likely to have leukemia than those living farther away from power lines with the NIEHS expert group with concluded that research assessing the health effects of exposure to EMFs emitted from transmission lines was not sufficient to establish a definitive cause and effect relationship.”	The EIS provides information on a number of studies that have been conducted with regard to the effects of EMF on public health. The EIS states in Section 4.7.1.2 that, “The method for assessing the effects from EMFs is a comparison of projected EMFs for the project with respect to ICNIRP recommendations…”
David Goldstein, President, Diamond Ventures	865.51	OREC	“The DEIS addresses recreational acreage lost, omits the additional recreational amenities and acreage of proposed trails, parks and natural open space gained within the master-planned communities in Peoria.”	Section 4.19.10, cumulative effects to Recreation acknowledges that planned developments would include recreation facilities.
David Goldstein, President, Diamond Ventures	865.52	OREC	“The DEIS omits the golf course amenities within the Saddleback Heights master planned community.”	Section 4.19.10, cumulative effects to Recreation, acknowledges that planned developments would include recreation facilities, however does not specifically mention golf facilities.
David Goldstein, President, Diamond Ventures	865.53	OREC	“The DEIS states that the primary recreational use within the Study Area is OHV recreation. The DEIS does not address hiking, boating, camping, organized youth leagues, team sports associated with K-12 and college education, or golf; all recreational activities within the Study Area supported by residents in masterplanned communities.”	Section 4.19.10, cumulative effects to Recreation, acknowledges that planned developments would include recreation facilities supporting activities discussed in this comment.
David Goldstein, President, Diamond Ventures	865.54	OREC	“The DEIS does not acknowledge recreational development within master plans as reasonably foreseeable development.”	Section 4.19.10, cumulative effects to Recreation, acknowledges that planned developments would include recreation facilities.
David Goldstein, President, Diamond Ventures	865.55	OREC	“The map which indicates recreational land use does not include state or private land recreational uses.”	Figure 3.9-1 shows the Recreation Opportunity Spectrum, which is specific to BLM-managed public lands. Figure 3.9-2 shows special designations and Special Recreation Management Areas, also specific to BLM-managed public lands. No known State or Private recreational uses would be directly affected by the Project. Indirect effects, such as visual resources are addressed in Section 4.14.
David Goldstein, President, Diamond Ventures	865.56	SOC	“The DEIS incorrectly states that “No effect on housing in the Study Area expected” for all alternatives and disregards the ongoing development activity impacted by Alternative 2 and Alternative 3.”	This statement is taken from Table 2.8-1, which summarizes impacts in Chapter 4. This text refers to Section 4.10.2.1, which indicates that construction workers would have no effect on housing. Table 2.8-1 was updated to make this clarification.
David Goldstein, President, Diamond Ventures	865.57	SOC	“The DEIS incorrectly states that “No houses within 200′ of ROW; therefore proximity and price effects do not apply … land within 200′ of the ROW within planned developments could be reduced up to five%”	Section 4.10 has been revised to accurately reflect information on existing houses within 200 feet of the proposed transmission line.
David Goldstein, President, Diamond Ventures	865.58	SOC	“Section 4.10.1.2 appears in conflict with Section 3.10.7.3, as it concludes that identified impacts to property values with structures were inapplicable to vacant, undeveloped and agricultural land, identifying a value impact of zero to 5 percent. The modest value impacts identified are at odds with the negative range of 5 to 36 percent and average negative impact of 20 percent identified in Section 3.10.7.3.”	The discrepancy between Sections 3.10.7.3 and 4.10.1.2 have been reconciled, and the analysis in Section 4.10 was updated accordingly.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
David Goldstein, President, Diamond Ventures	865.59	SOC	“When the DEIS states that new tax revenues for the alternatives would be the same as the proposed action, the DEIS does appropriately acknowledge that the Proposed Alternative has greater potential for private, developed land to contribute application and development fees, connection fees, primary and secondary property taxes and sales taxes that would be associated with the unconstrained development of commercial and residential property on private land within master planned communities. Alternative 2 and Alternative 3 would result in development delays and reductions in assessed valuations. Each year, property taxes paid by land, commercial and residential properties support a variety of essential public health and safety services as well as quality of life components. Some recipients of primary and secondary property taxes include: City of Peoria, Voter-Approved Bonds, Peoria Unified School District, Peoria Unified School District Bonds, Peoria Unified School District Overrides, Community College District, Community College District Bonds, State Equalization Tax, West Mec, General County Fund, Flood Control District of Maricopa County, Central Arizona Water Conservation District, Fire District Assistance, Library District and Maricopa Special Health District”	Section 4.10 provides this analysis.
David Goldstein, President, Diamond Ventures	865.60	SOC	“The DEIS states that Alternative 3 crosses 255.43 acres of private land with an estimated value of $11.0 and that these lands generate $909,151 million in property tax revenue. This number should be corrected.”	The word “million” was deleted following the “$909,151”.
David Goldstein, President, Diamond Ventures	865.61	SOC	“The DEIS is inconsistent in stating the area of direct negative impact of the transmission line. In some places, the effect is stated to be 200′ from the transmission line. In other places, the effect is stated to be 200′ from the ROW. If the transmission line is not located in the middle of the ROW, the DEIS infers that the area of impact could be 600′.”	This inconsistency has been corrected document-wide. In addition, the literature review in Appendix 3A was revised to include new empirical studies, and Section 4.10 was revised to clarify that the value of lots adjoining a ROW would be affected.
David Goldstein, President, Diamond Ventures	865.62	SOC	“The DEIS states the process should consider … the appropriateness of amending the RMP in such a way that would benefit developers … “This language reflects a negative bias against developers and is inappropriate. Therefore, it should be removed.	Table 1.8-2 provides a summary of issues from Scoping, which includes the Economic Strategies Workshop. The issue referenced by this comment is that the process of amending the RMP should consider whether or not it is appropriate to amend the RMP in such a way that would benefit developers. The referenced text is stating the issue as it was raised during scoping, and is not expressing a negative bias against developers on the part of the BLM.
David Goldstein, President, Diamond Ventures	865.63	SOC	“The DEIS does not address the potential impacts of 1,013 Multi-use Corridor designation on the BLM land south of SR74 to market and non-market values.”	Section 4.1.3 indicates that analysis of impacts resulting from future development within a multiuse corridor would be required prior to authorization. Presently, there are no current effects.
David Goldstein, President, Diamond Ventures	865.64	SOC	“The DEIS emphasizes the economic values associated with grazing leases and OHV activity. The high net economic values associated with Off Highway Vehicle Recreation is stated as $68 per OHV trip. The DEIS goes further to state that 20% of the population in Arizona participates in OHV. There is no data provided to substantiate such a large assumption.”	Section 4.10.2.1 cites the source of the referenced $68 per trip as (Silberman and Andereck 2006). Section 3.10.8 was revised to include a citation for the 20% figure.
David Goldstein, President, Diamond Ventures	865.65	SOC	“The DEIS acknowledges that Finance, Insurance and Real Estate accounted for more than 30% of the earnings and employment. The economic contributions, earnings and employment associated with commercial and residential development anticipated within Saddleback Heights and other master-planned communities receives less attention that OHV and grazing.”	The potential economic drivers of Saddleback Heights and other master planned communities that are not yet developed are more speculative, whereas OHV recreation is occurring and would be affected by the proposed project.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
David Goldstein, President, Diamond Ventures	865.66	RENE	“The solar and renewable energy sector of the economy and employment and financial contributions to the Arizona economy are not described in the text of the DEIS. Given the importance of renewable energy and the need for renewable energy transmission the DEIS should address this more completely. While the appendix lists some planned solar projects, it does not mention the entirety of planned solar generation projects in central Arizona.”	The list of projects in Appendix 4B was intended to be as comprehensive as possible for the identified Cumulative Impact Areas, but was based on the best available information at the time the list was compiled.
David Goldstein, President, Diamond Ventures	865.67	SOC	“The Housing Values stated in the DEIS do not reflect the 2010-2012 trends in Phoenix and do not recognize the North Central/ Peoria Sub-Market where values are higher than average for the overall region.”	Home values are not used for any impact analysis in Section 4.10. Changes in the real estate market would not change the impact of the transmission line on home values. Regardless of the present value of any property, the addition of the transmission line would affect the value of the property on a percentage basis, as described in the cited source contained in the literature review in Appendix 3A.
David Goldstein, President, Diamond Ventures	865.68	SOC	“The maximum annual tax income generated from private properties is understated and does not reflect home prices in Peoria or anticipated housing demand within the reasonably foreseeable developments.”	Section 4.19.11 was updated to include analysis of cumulative impacts to tax revenue.
David Goldstein, President, Diamond Ventures	865.69	SOC	“In Alternative 2 and Alternative 3, the DEIS does not include or analyze the impacts of a 40-252 re-evaluation of the ACC Decision and potential new Line Siting case.”	Sections 4.10.2.2 and 4.10.2.4, Alternative 2, Alternative 3, and the No Action Alternative were revised to include discussion of the need for APS to return to the ACC process, and address potential indirect socioeconomic effects of that action.
David Goldstein, President, Diamond Ventures	865.70	SOC	“It should be noted that in 2010, a public record shows a price paid for vacant ROW land at $234,700 per acre.”	Without documentation, this is anecdotal information, and not part of an empirical study, and therefore not listed in Appendix 3A.
David Goldstein, President, Diamond Ventures	865.71	TRANS	“In addition to ADOT’s planned expansion of SR74, MAG, Maricopa County, and Peoria have planned local and regional roadways within the vicinity. The DEIS does not identify these planned roadway locations and the changes in traffic volume and dispersal that will occur.”	The document was reviewed by MAG and additional data provided by MAG regarding transportation upgrades/expansions were added to the EIS.
David Goldstein, President, Diamond Ventures	865.72	TRANS	“The DEIS addresses upgrades, but does not address the new interchanges to be constructed with the widening of SR74 and the impact new intersections and interchanges will have on commercial development.”	Section 4.19.11 includes new commercial development in the analysis of cumulative effects to socioeconomics.
David Goldstein, President, Diamond Ventures	865.73	TRANS	“The description of the BNSF rail line describes with specificity current activity and volume and future projections and potential growth with anticipated volumes as well as the components of the Surprise Logistics Center. The projections and potential growth of Saddleback Heights, Vistancia and Lake Pleasant Heights do not receive similar treatment in the DEIS.”	The identified information was inappropriately located in Section 3.12.2.3, and has been moved to cumulative impacts in Section 4.19.
David Goldstein, President, Diamond Ventures	865.74	VIS	“Saddleback Heights presented an analysis of the visual impacts of the transmission line on the south side of SR74 during the ACC Line Siting by Gary Rich, M.S. Engineering.”	All applicable and relevant information was used for the analysis presented in the EIS. Simulations for alternatives situated on the south side of SR 74 are provided in Section 4.14, along with a viewshed analysis.
David Goldstein, President, Diamond Ventures	865.75	VIS	“The DEIS acknowledges that micro-siting would assist in minimizing impacts, and that micro- siting has not been completed. Any stated conclusions in the DEIS should also state that micro- siting should further reduce Impacts.	Section 4.14.4 states, “Following the implementation of the mitigation measures, although impacts to visual resources would be reduced in some cases, residual effects would still occur with the transmission line still being present in the area where there was not one previously.”

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
David Goldstein, President, Diamond Ventures	865.76	VIS	“The DEIS quotes the Kroll and Priestly 1991 study which minimizes the effects of visual and health concerns of transmission lines, without providing the same level of detail in the DEIS text or from more recent studies which reach emphasize significant effects.”	The commenter did not provide additional sources for consideration and it was determined that sufficient information and analysis is currently provided.
David Goldstein, President, Diamond Ventures	865.77	SOC	“The DEIS appears to summarize numerous studies and makes a conclusive statement that properties 50 to 200 feet from the transmission line experienced small negative price effects and the properties beyond 200 feet did not experience any negative price effects. It further states this effect may not be as relevant to rural locations, such as the Project Area. The DE IS should not reach a conclusion regarding the geographic range of impacts or the effect of visibility of a transmission line has on land, commercial and residential properties of varying types. The DEIS should acknowledge the site specific nature and the many factors that influence the range and degree of impacts of electric transmission lines on property values.”	Section 4.10.1.2 was revised to include a statement indicating that impacts to property values were estimated based on empirical studies available at the time of analysis and actual impacts would be influenced by local conditions.
David Goldstein, President, Diamond Ventures	865.78	VIS	“The DEIS analysis omits future residents of planned developments as sensitive viewers in the KOP analysis. Visual impacts from several of the Key Observation Points should include future residents of developments such as Saddleback Heights, Vistancia and Saddleback Heights as sensitive viewers.”	The EIS analyzes impacts to existing conditions under direct and indirect effects. Impacts to visual resources as perceived by future residents are addressed in Section 4.19.15.
David Goldstein, President, Diamond Ventures	865.79	VIS	“The DEIS description of the BLM land south of SR74 which states “the vegetation is similar to the vegetation on BLM land north of SR74, but the terrain is less hilly and more rolling for about 1.5 miles” does not acknowledge the topography and elevation of BLM land adjacent to SR74, or the prominent butte that is mentioned as the most prominent landform along SR74 in the Study Area.	The description of the BLM land south of SR 74 has been revised per the comment.
David Goldstein, President, Diamond Ventures	865.80	SOC	“The DEIS does not propose any mitigation for impacts to socio-economic resources. Mitigation proposed under Alternative 2 and Alternative 3 should be greater than the mitigation associated with the Proposed Action. Mitigation on private developed land should be consistent with the ROW being adjacent to permanently occupied homes and businesses rather than vacant BLM land with intermittent recreationists.”	The impacts for socio-economic resources are identified in Section 4.10; however, no mitigation measures for these impacts were identified and none were suggested by the commenter.
David Goldstein, President, Diamond Ventures	865.81	VIS	“The most detailed description of the Saddleback Heights Specific Area Plan occurs in the Visual Resources Focus Area. The DEIS is inconsistent and states that the areas where the structures would be visible would be very similar under the Proposed Action and Alternative 2. It goes on to state that under Alternative 2, when the structures would be on the south side of SR 74, they would appear larger in the landscape than under the Proposed Action. Within and estimated 800′ of the transmission line the structures would dominate the views.”	Section 4.14.2.4 states that, “…the overall viewshed impacts of Alternative 2 in terms of areas where the transmission line would be visible and number of structures visible in different areas would be very similar to the impacts of the Proposed Action route.” This statement does not speak to the relative perception of the stature of the structures under the alternatives or their dominance of the view.
David Goldstein, President, Diamond Ventures	865.82	WLF	“Saddleback Heights presented a biological evaluation of the impacts of the transmission line on the south side of SR 74 during the ACC Line Siting by Eleanor Gladding, M.S. Biology.”	All applicable and relevant information was used for the analysis presented in the EIS.
David Goldstein, President, Diamond Ventures	865.83	WLF	“The DEIS states loss of habitat associated with the transmission line, without acknowledging that the BHRMP has conceded a 1-mile designated corridor which may be disturbed for SR74 expansion.”	Site specific impacts from development within the transportation corridor would require future analysis prior to authorization. No loss of habitat has occurred through corridor designation in the RMP.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
David Goldstein, President, Diamond Ventures	865.84	GEN	“Failure to Reflect Comments Made During Scoping: Many of the comments and specific reports provided during the scoping process, are not discussed or included in the DEIS, including comments submitted by: (a) Chuck Gray of ORANGE regarding private property rights; (b) Rob Wanless of SOLON Corps regarding the importance of electric transmission lines to the Arizona solar industry (c) Steve Burg of the City of Peoria concerning the Project’s impacts to the Peoria General Plan (d) Charlie Bowles of Southern AZ Home Builders concerning impacts of electric transmission lines on residential real estate communities and (e) Wendell Pickett of Saddleback Heights concerning impacts south of SR74; and (f) Congressman Franks’ comments relating to homeland security and Electromagnetic Pulse threats to national security. These comments should be addressed and considered in the FEIS.”	All comments provided during the public scoping process were reviewed and all relevant information and comments were addressed as applicable to the analysis for this project. Detailed information regarding scoping is available in the Scoping Report.
David Goldstein, President, Diamond Ventures	865.85	GEN	“Scoplng: The FEIS should clarify what the distinction between what was derived for inclusion in the document from “internal” and “external” scoping.”	Section 1.8 was revised to indicate that Internal scoping issues were derived from the BLM and external scoping consisted of public input.
David Goldstein, President, Diamond Ventures	865.86	GEN	“Terminology and Definitions: Text covering the same topic in different sections uses different terminology. Specifically the terms corridor, right-of-way, route, transmission line are used differently. Impacts to properties adjacent are difficult to determine when there is a lack of location specificity and vague terminology.”	Definitions of specific terminology have been added to the document glossary in Section 6.3; however, other terminology effectively communicates a general understanding of the subject matter such that the average reader can understand the meaning. Terminology has been revised document-wide to improve consistency and use.
David Goldstein, President, Diamond Ventures	865.87	GEN	“Natural and Built Environment: The grade changes, topography, and different elevations are not incorporated into analysis of impacts or integrated with the existing and reasonably foreseeable development actions.”	All information necessary to conduct a thorough and complete analysis was used and included in the EIS.
David Goldstein, President, Diamond Ventures	865.88	GEN	“Incomplete Project History: The DEIS project history is incomplete. As such, the FEIS should discuss BLM’s administrative proceedings relating to APS’s ROW application and the ACC proceedings relating to the same.”	Section 1.1.2 has been revised to expand the summary of the project history.
David Goldstein, President, Diamond Ventures	865.89	GEN	“Coordination not discussed: The DEIS fails to discuss the impact that clearing and grading In section 2.4.2.4 could have on private land, nor does it discuss the need for coordination with private land owners. As such, the FEIS should address these issues.”	The impacts of clearing and grading are discussed by resource throughout Chapter 4; however those impacts are not broken out by land ownership. Beyond the environmental impacts of clearing and grading, coordination between APS and private land owners regarding clearing and grading is beyond the scope of analysis in the EIS.
David Goldstein, President, Diamond Ventures	865.90	GEN	“Study Areas: The study areas for each resource are different and no explanation Is given for this. This makes determination of aggregate impacts difficult to reconcile.”	Section 3.1.3 explains the rationale for study areas.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
David Goldstein, President, Diamond Ventures	865.91	OPP MUC	“Given the consistency of the Transmission Line with the overall goals of the Agency and the BHRMP, the plan does not need to be amended. If, however, the plan is amended, it should be clarified to reflect the Administration’s “highest priority” of promoting renewable energy and designate the SR-74 as a multi-use corridor. That said, it should not be amended as proposed, but should only designate as multi-use and VRM IV those lands necessary to accommodate the Project I Proposed Action and not the entire 1,013 acres of public land managed by the BLM south of SR 74 because of the unknown and potentially negative impacts it would have on neighboring private property, including reasonably foreseeable development.”	BLM has determined that the Bradshaw-Harquahala RMP requires amendment to comply with the FLPMA as described in Section 1.3.2.
Jo Ann Crane	866.1	SUP PA	“It is my understanding the Bureau of Land Management is supporting and recommending Alternative 1 , the certificated route, which runs along the north side of SR-74…I support the certificated route.”	Statement of preference.
Robert Barclay	867.1	SUP PA	“I support the certificated route”	Statement of preference.
Brent Cain, PE, Deputy State Engineer, Urban Operations, ADOT	868.1	SUP PA	“I would express our support for the BLM Agency Preferred Alternative alignment for the proposed Arizona Public Service (APS) Sun Valley to Morgan 500/230kV Transmission Line.”	Statement of preference.
Bob Stump, Chairman; Gary Pierce, Commissioner; Brenda Burns, Commissioner; Bob Burns, Commissioner; Susan Bitter Smith, Commissioner	869.1	SOC	“This transmission line is extremely important as the connection between the Sun Valley and Morgan Substations would be the final segment in completing a continuous 500kV supply from the Palo Verde hub area to the northeast Phoenix metropolitan area, providing much needed reliability.”	Statement of opinion. Chapter 1 describes the need for the project.
Bob Stump, Chairman; Gary Pierce, Commissioner; Brenda Burns, Commissioner; Bob Burns, Commissioner; Susan Bitter Smith, Commissioner	869.2	SUP PA	“…we support the Proposed Action route as the Agency Preferred Alternative route of the proposed transmission line.”	Statement of preference.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Richard Stallings	870.1	RNA	“Alternative in addition to those analyzed in EIS: The route would be the same as the Proposed Action to the Lone Mountain Road alignment. From the Lone Mountain alignment proceed northerly, staying on ASLD property to approximately 1/2 mile north of the Joy Ranch alignment, then easterly thru 1/2 mile of private land to the 243rd Ave alignment, then northerly to SR74, then along the south side of SR74 9 miles to the 179th Ave alignment, then follow the route of Alternative 3 to the Morgan Substation. This route would have several positive effects: 1. Minimize the diversion of ASLD lands by the ROW; 2. Route would not pass near the Thunder Ridge Airpark; 3. Route would not pass near residences; 4. Route would put the town of Wittmann outside the 2 mile cumulative zone; 5. There would be a substantial reduction of turning structures required for the project; 6. Route would not require amendment to the EIS/RMP.”	This suggested alternative was evaluated and incorporated into Section 2.7 and added to Figure 2.7-10.
Howard Rosenthal	873.1	SUP PA	“We are in support of the PROPOSED ALTERNATIVE which is on the north side of State Route 74”	Statement of preference.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.1	LU	“The BLM originally rejected APS’s ROW application because a utility corridor had not been established in the ACC-certificated route. When the Interior Board of Land Appeals (IBLA) then remanded the decision back to BLM, it indicated that the decision rationale “required more detail” (pg. 1-3, Section 1.1.2, emphasis added). It is important to note that the IBLA did not say that the decision had to be changed; it only requested more detail as to why it was refused. Based on the information in the DEIS, the BLM’s original rejection of the proposed utility corridor should remain.”	Statement of preference.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.2	UC	“To clarify the real “purpose and need” for this project, it is important to look again at the Saguaro National Park Land Exchange that occurred in 1997. In that exchange, Tucson Mountain Investors (led by Don Diamond and Chris Monson) acquired 4,322 acres of BLM land south of SR74. The federal government received only 632 acres near Saguaro National Park in return. Appraised at the ridiculously low price of $800 per acre, the BLM land was quickly sold to other developers for windfall profits. This same land south of SR74, including the Carefree Highway alignment, is what is in question today regarding APS’s original proposed power line route. To maximize profits even more and to get more of the public’s land, developers now want the APS power line moved north of SR74.”	This project is for a proposed transmission line and the Purpose and Need, as described in Chapter 1, was deemed appropriate and applicable for this project.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.3	RENE	“As with many projects, it appears that the developers and proponents of moving the line are attempting to “greenwash” and have now included language about it serving to help Arizona Public Service Company (APS) meet the Renewable Energy Standard Requirements. (page 1-9) That is an assertion with no basis in fact and that is not substantiated in the DEIS. Please explain and/or remove this in the final document.”	Additional information was added to Section 1.5.2, as applicable.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.4	M&M	” The DEIS includes a number of qualifiers in discussion of mitigation measures. These qualifiers make it difficult to understand what mitigation will actually take place and also seem to provide a significant amount of wiggle room in terms of what and when mitigation is required.”	The mitigation measures were reviewed. Where possible they were revised to be more affirmative in Sections 2.9.1 and 4.2.4.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.5	M&M	” “Riparian areas would be avoided and would not be disturbed by construction activities unless absolutely necessary” (pg. 4-186, Section 4.16.2.1, emphasis added). No further information is provided about when it may be absolutely necessary to disturb riparian habitats. Such information is important to include in the DEIS.”	Additional information has been added to the EIS in terms of potential impacts to Waters of the US/wetland and riparian areas from the project.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.6	M&M	” “Access roads could be gated to prevent access by unauthorized personnel” (pg. 2-9, Section 2.4.1.3, emphasis added). When would roads not be gated? Would the BLM require gates on access roads on its lands? This information is pertinent in order to understand potential implications of increased public access, use of this area, and creation of new routes.”	Section 4.9.3 has been revised to specify locations for gates on BLM-managed public lands.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.7	M&M	” “Where warranted, a qualified biologist would be retained to monitor, and advise the construction contractor during preconstruction activities to minimize or prevent impacts to sensitive species or habitat” (pg. 2-15, Section 2.4.2.4, emphasis added). When would retention of a qualified biologist not be warranted? How and when would this be decided?”	Sections 2.4.2.4 and 4.16.3 have been revised in response to the comment.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.8	NEPA	” The BLM must seek to ensure that the need for new transmission and related facilities on its lands is not eclipsed by irreparable harm to unique and important ecosystems. Related to this, it is also important to confirm that new transmission will fulfill its primary purpose. To this end, BLM has not adequately justified the purpose and need for the proposed APS Transmission Line Project. The DEIS states that BLM is responding to the APS application under Title V of the Federal Land Policy Management Act (FLPMA) for a right-of-way (ROW) grant and that it is “[t]o meet public needs for use authorizations such as ROWs, permits, leases, and easements, while avoiding or minimizing adverse impacts to other resource values and locating the uses in conformance with land-use plans” (Sec. ES.2.1, pg. ES-2).”	The BLM purpose and need presented in Section 1.3 legally supports the development of this EIS.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.9	NEPA	” This project would not meet public needs as it is being pushed by private developers, primarily Diamond Ventures. It also does not avoid or minimize adverse impacts to other resource values or locate the uses in conformance with land use plans.”	Section 1.3.2 has been revised to expand information on BLM’s mission and multiuse mandate. The EIS addresses the issue of the proposed project’s non-conformance with the RMP by proposing an RMP amendment to establish a utility corridor, as described in Section 1.3.2. Further, BMPs and mitigation measures are proposed to be implemented that would avoid and/or minimize adverse impacts.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.10	NEPA	” The DEIS goes on to say that “[t]he Preferred Alternative will reasonably accomplish the purpose and need for the federal action, while fulfilling the BLM’s statutory mission and responsibilities, giving consideration to environmental, economic, and technical factors. This action is responsive to public input for avoiding environmental and economic impacts to lands in the project vicinity” (pg. ES-20). This statement is inaccurate as this action is not in the best interests of the public, nor does it respond to input for avoiding environmental impacts. As noted above, this proposal would essentially give away public lands for the benefit of a private developer to the detriment of natural resources and public values. The BLM must reassess this proposal with regards to the agency’s mission and its FLPMA mandate.”	Section 2.10 provides the rationale for the Agency Preferred Alternative. Section 1.3.2 has also been revised to expand information on BLM’s mission and multiuse mandate.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.11	NEPA	” The RMP was barely issued before the BLM began looking into amending it in order to permit this project. The agency is instructed to revise land-use plans only when appropriate. In other situations, it is instructed to maintain the RMP. Utility corridors were determined not to be suitable for this area in the RMP. The RMP emphasizes “preserving open space and retaining scenic and visual qualities” (pg. 80 of RMP). The BLM was correct about its original assessment and there is no need for this corridor or the proposed RMP amendment.”	Statement of preference.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.12	NEPA	” The BLM has a multiple use mandate pursuant to the FLPMA. This law, however, calls for a qualified requirement to “use and observe the principles of multiple use and sustained yield set forth in this and other applicable law” (section 202(c)). Moreover, Section 202(c) enumerates nine specific requirements, not only the so-called multiple use mandate. The BLM ignores entirely these other requirements of section 202(c), notably subsection 3, which requires that agencies give priority to the designation and protection of areas of critical environmental concern. By singling out one subsection of FLPMA, section 202(c), and characterizing it as a “mandate,” the BLM fails to fully and fairly inform the public about FLPMA’s role relative to the proposed transmission line.”	The area of BLM-managed public lands that would be crossed under the Proposed Action/Preferred Alternative is not designated an Area of Critical Environmental Concern (ACEC). Need for designation of ACECs was analyzed in the process of development of the RMP.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.13	NEPA	” The BLM has failed to adequately explain why the agency selected the Proposed Action as the agency’s preferred alternative.”	Section 2.10 provides the BLM’s rationale for the Agency Preferred Alternative.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.14	LU	” The City of Peoria states that the Carefree alignment does not comply with its comprehensive land use plan and, therefore, the transmission line should be moved to BLM land on the north side of SR74 (pg. 2-40). However, the transmission line does not comply with BLM’s RMP, either, so Peoria’s argument seems to be largely a wash. The DEIS admits that a main concern of the City is the planned upscale development at Saddleback Heights, Lake Pleasant Heights, and Vistancia.”	The Land Use sections of the EIS fully explain and describe the applicable land use plans and compliance with these plans and Section 2.10 provides the BLM’s rationale for the Agency Preferred Alternative.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.15	PH&S	” A close look at the Phoenix Metropolitan Street Atlas however shows no development or roads currently exist within two to three miles of the proposed Carefree alignment. Indeed a recent edition of the Atlas does not even go north as far as SR74, calling into question claims of health effects from power lines to residents in the area.”	Impacts to Public Health and Safety from all alternatives are analyzed in Section 4.7. Health effects are not anticipated.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.16	LU	” It is appalling to believe that development could be proposed over such a large geographical area and yet somehow be held exempt from having to make space for infrastructure such as power lines. It is even more stunning when public lands are proposed to be a dumping ground for these projects so that developers can further profit from building on desert land.”	Statement of opinion.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.17	LU	” Peoria also contends that golf courses, parks, and trails planned near the Carefree alignment could be negatively affected by a transmission line. This is certainly true, but the land is already private, and more infrastructure and development is not going to affect the potential land status and overall management of private lands as it will on public lands.”	Impacts to future recreation development on private lands are addressed in Section 4.19.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.18	AIR	” A portion of the project is in the designated PM10 nonattainment area and by blading undisturbed desert and opening up the area to more off-road vehicle activity by creating a defacto road, there will be a negative impact on air quality related to PM10. There is also a great likelihood that this is just the first way these lands will be fragmented and disturbed, so the cumulative impacts to the air quality could be substantial.”	Impacts to air quality, including PM 10 are analyzed in Section 4.2. Cumulative impacts to air quality are analyzed in Section 4.19.3. Mitigation measures added to Section 4.9.3 specify that the centerline access would be designated an administrative road and closed to recreational use, in part to reduce air quality impacts.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.19	GHG/CC	” No real assessment of the impacts to lands in light of climate disruption and at a minimum it should have been considered in the cumulative impacts analysis.”	Future climate disruption and its impacts on affected lands are beyond the scope of this project. Impacts have been evaluated based on best available current data.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.20	CUL	” There are nine historic properties known in the area of the proposed transmission line and while the project would attempt to avoid or span these, it would clearly have a negative impact on them as it negatively affects the context.	Impacts to cultural resources are analyzed in Section 4.3.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.21	CUL	” Has the BLM addressed the tribal concerns with prehistoric sites?	Background information on Native American tribes is presented in Section 3.3.7. Native American consultation and coordination was presented in Section 5.5 of the EIS. Consultation is on-going and any mitigation measures to reduce impacts to tribal and cultural resources would be adopted in the ROD.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.22	PH&S	” Moving this line to north of SR74 will have little, if any, positive impact relative to public health and safety. Regardless of which alternative is selected, the DEIS indicates that, “the expected range of Electromagnetic fields is at least two orders of magnitude less than the recommended exposure limit of 2,000 milliGauss.” (pg. ES-12)”	Impacts to Public Health and Safety from all alternatives are analyzed in Section 4.7.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.23	OREC	” The DEIS does not adequately address the impacts of this proposed transmission line to non- motorized recreation or to those who are potentially seeking quieter recreation. What will the cumulative impact be?”	Section 4.9.2.2 was revised to specifically address impacts to non-motorized recreation. No cumulative impacts to non-motorized recreation were identified.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.24	OHV	” What will prevent access by off-road vehicles? History has shown that projects such as this with its 38 miles of new permanent roads in the ROW will be abused by ORVs and an increase in erosion, dust, noise, and damage to vegetation both within and outside the ROW will result.”	The analysis and mitigation in Section 4.9 have been expanded to clarify recreational use of the ROW and specify mitigation required to prohibit unauthorized recreation use.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.25	OHV	” BLM is acknowledging that it can’t keep bikes, etc. off the new center line roads and there will be significant additional impacts.”	Additional recreation mitigation measures have been added. Mitigation measures added to Section 4.9 are intended to prohibit unauthorized recreational use of the ROW, and provide BLM authority to enforce the recreational use decisions.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.26	OREC	” The DEIS also indicates “While the centerline access would be closed to recreational use, it would be an attractive area for target shooting and may lead to unauthorized access into the area if techniques used to prevent access are not thorough.” (4-84) This has potential to significantly affect other forms of recreation and should be analyzed”	The mitigation measures in Section 4.9 have been expanded to specify requirements for prohibition of unauthorized uses. Mitigation listed in the revised section provides BLM authority to enforce the recreational use decisions.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.27	VEG	” The Draft indicates “The Proposed Action and all Action Alternatives contain a very similar amount of (estimated) temporary and permanent disturbance.” ( P 4-129) How is this possible? The proposed action north of 74 would be going through an undisturbed area and therefore would be creating more disturbance and more destruction of vegetation and potential for spreading invasive plant species. Please address this in the final document.”	Tables 2.4-4 and 2.4-7 and their associated footnotes detail the calculation assumptions for disturbance under the proposed action.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.28	SSS	” Preconstruction surveys will be conducted to locate any special status plant individuals that lie within the construction zone. (p 4-129-130) The DEIS admits poor success with this. It is unclear, however, how poor the success will be and just how many native special status plants will be killed and how many will survive. They admit poor success rate for this.”	The comment accurately reflects the analysis provided in Section 4.13.2.1.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.29	VEG	” The DEIS should make it clear that the area beneath these transmission lines will be denuded, saguaros will be removed or chopped off, and any tree species are likely to be removed. The area under these transmission lines becomes a defacto road with little in the way of native vegetation. That should be acknowledged and evaluated. How would it be mitigated?	APS would follow and implement a Vegetation Management Program, approved by BLM, and minimize impacts to vegetation underneath the transmission line as described in Chapter 2, Chapter 4, and Appendix 2B. Additional information to describe the impacts of clearing and to clarify what vegetation management will be needed for construction and maintenance has been added to these sections of the EIS.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.30	VEG	” The DEIS also indicates “While the centerline access would be closed to recreational use, it would be an attractive area for target shooting and may lead to unauthorized access into the area if techniques used to prevent access are not thorough.” (4-84) This has potential to significantly and negatively vegetation as saguaros are frequently a target of recreational shooters.”	The mitigation measures in Section 4.9 have been expanded to specify requirements for prohibition of unauthorized uses, including target shooting. Mitigation listed in the revised section provides BLM authority to enforce the recreational use decisions that would also benefit vegetation resources as well.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.31	VIS	” The proposed transmission corridor and power line are within a Class II VRM area. As noted above, the goal is keep any change low, and activities should not attract attention. No matter how this large transmission line is constructed, it will attract attention and detract from the scenic quality of this area. As proposed, the line would cross SR74 twice, making it especially intrusive relative to the scenic character of the area.”	The comment generally reflects the analysis in Section 4.14. However, the BLM also proposes to change the VRM class of the area containing the proposed ROW, as described in Section 1.3.2.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.32	VIS	” In addition to the fact that the area north of SR74 is a Class II VRM, it is also designated as a scenic corridor by Maricopa County.”	The Maricopa County Zoning Ordinance establishing scenic corridors is referenced in Section 3.14.1. As described in this section, the City of Peoria does not recognize the Scenic Corridor in the referenced area.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.33	LU	” The DEIS gives a brief paragraph on the Maricopa County Zoning Ordinance that established the Highway 74 Scenic Corridor (pg. 3-134). As part of the debate regarding the suitability of building transmission lines north of SR74 centers on the Scenic Corridor, we feel more attention should be given to this matter in the DEIS.”	The level of analysis of impacts to the Maricopa County scenic corridor in Section 4.14 is appropriate given the fact that the corridor is not recognized by the City of Peoria, the majority of the area with the higher intensity impacts to visual resources would occur within the City of Peoria boundaries, and the transmission line would not be within the scenic corridor outside the City of Peoria boundaries under any of the Action Alternatives.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.34	WLF	” Overall, the DEIS greatly underestimates potential impacts to biological resources, including wildlife species. In drafting it, the BLM seems to have made numerous assumptions and did not provide adequate information on species presence and affected population sizes, potential impacts, and suitable mitigation efforts. The DEIS is also full of qualifiers that do not allow the public and other reviewers to adequately understand BLM’s plans and mitigation intentions. “	Additional information and applicable revisions to the biological resources sections have been made addressing avian collisions with power lines in Section 4.16.2.1, and avoidance of desert tortoise impacts in Section 4.16.2.2. Mitigation revisions are contained in Section 4.16.3.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.35	WLF	” The BLM does admit that “[i]rreversible and irretrievable commitments of wildlife resources would occur through incidental mortality of individuals, or incidental take in the case of special status species” (pg. 4-200, Section 4.17.15) and that “[h]abitat removal would adversely affect the long-term productivity of wildlife habitat for many species, including special status species and migratory birds” (pg. 4-205, Section 4.18.15). However, it then assumes that impacts to these species will be negligible. This assumption is in direct contradiction to the statements above.”	An irreversible or irretrievable impact would not necessarily inherently be of higher intensity or significant. The fact that an impact is irreversible or irretrievable does not mean that it cannot also be an overall negligible effect.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.36	WLF	” At least 248 vertebrate species could be affected by this project (pg. 3-178, Section 3.16.3), including at least 19 special status species (pg. 3-181, Section 3.16.4). However, these numbers are mere estimates as they are based only on known occurrence, suitable habitat, and inadequate surveys. The DEIS ignores that other species may also be present and disregards that some species may occasionally utilize habitats that are not qualified as “suitable.”2 We understand that it is virtually impossible to have a thorough understanding of what species are present in an area and their associated population sizes. However, the BLM cannot assume that only species known to inhabit an area will be affected. Without acknowledging this fact, potential impacts may be drastically underestimated.”	NEPA analysis is not meant to provide encyclopedic data. It is not necessary to address all species of wildlife, species by species. For general wildlife, the analysis is sufficient to provide the context and intensity of the loss of Sonoran Desert habitat; species level analysis is provided for the special status species. The data used was the best available data from reliable sources – as required by NEPA. The EIS provides an extensive list of species that may be impacted. The EIS also provides the context (number of acres impacted) and intensity (permanent vs. temporary). All of the special status species that could occur in the area are listed in the EIS and the impacts are analyzed as if they were present – where suitable habitat occurs for those species.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.37	WLF	” The DEIS does not acknowledge that the sources used to determine presence of a species in the project corridor do not provide a complete representation. For example, we assume that one of the tools used was the Arizona Game and Fish Department’s Heritage Data Management System (HDMS). However, the HDMS relies on incidental observations and data from surveys that have been conducted in an area and does not provide a complete representation of species located in that area. Additionally, many observations and survey results are not reported and, therefore, are not included in the HDMS.”	Sources of data used to determine presence of species in the Project Area are specified in Section 3.16.2, 3.16.3, and citations throughout Section 3.16. The Arizona Game and Fish Department information was reviewed and used for the baseline data presented in the EIS.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.38	WLF	” The DEIS notes that field reconnaissance occurred during November 2007, May 2008, and October 2011. No further information is provided about methods, who conducted the surveys, timing within these months, specific locations, etc. This information should have been provided in the DEIS.”	Section 3.16.2 was revised to include more details regarding field reconnaissance.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.39	WLF	” Because some species may only be present or active during certain times of the day or year or may not be observed in a given year, it is important to conduct surveys at different times of the day, in various seasons, and repeatedly through multiple years. For example, bats, most species of owls, and many small mammals are primarily nocturnal; many bird species are most active during early morning hours; and some species are crepuscular and are most active during dawn and dusk. Similarly, many migrating bird species are only present during certain times of the year, whereas others may not utilize this habitat every year. By only conducting surveys during three months (for an unknown duration within those months and at unknown timings), likely only a small portion of wildlife species present in the Study Area were observed.”	Section 3.16.2 was revised to include more details regarding field reconnaissance conducted. Field surveys of species as suggested by the comment are not warranted. All of the special status species in the area were addressed, where appropriate habitat exists, as if they were present. The EIS considers the area occupied by the candidate (tortoise) species which would receive clearance surveys prior to construction and mitigation post construction. The EIS also states that clearance surveys for migratory birds/nests and mitigation would take place as appropriate.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.40	WLF	” Similarly, different methods need to be used to identify various species. For example, bats are best identified through mist-net and acoustic surveys, whereas small mammal surveys typically include trap surveys. The only indication of methods provided in the DEIS is that “plant and wildlife species observed were noted throughout the course of the field reconnaissance” (pg. 3-177, Section 3.16.2). What survey methods were used? Were various species and classes targeted, or did the surveys only involve incidental observations? Again, without conducting targeted surveys, the vast majority of species present in the Study Area likely were not identified.”	Section 3.16.2 was revised to include more details regarding field reconnaissance survey work. Surveys involved only incidental observations of wildlife and associated sign.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.41	M&M	” The DEIS states that “all ground clearing/disturbance activities that could affect sensitive species or habitat would be monitored” (pg. 2-15, Section 2.4.2.4). Who would conduct the monitoring and what training/qualifications would this person or people have? Would the monitor(s) be on-site during all construction activities at all times?”	Section 2.4.2.4 was revised to specify that monitoring for desert tortoise presence and migratory bird active nests would be conducted. Any potential tortoise shelter sites in harm’s way would be cleared for tortoises and then rendered unusable (filled in, blocked off with rocks, etc…). A ‘qualified biologist’ would meet the qualifications for the 0486 series wildlife biologist as posted on usajobs.gov and be approved by the BLM biologist. This project would also included a BLM 3^rd Party contracted and approved biological and construction compliance monitor for BLM lands.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.42	M&M	” A qualified biologist may be retained to monitor and advise the construction contractor during preconstruction activities, where warranted. Again, we question when a biologist would not be warranted. We also question why the biologist would not be on-site during construction, as well as during pre-construction activities. The potential for direct mortality of species is significantly higher when work is being performed in an area; it would make sense to have a qualified biologist on-site during these activities, as well.”	Applicable clarification has been added to the biological resources mitigation measures.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.43	M&M	” Who will conduct the mandatory Environmental Awareness Program for personnel working on site? What training/qualifications will that person or people have? Will the person(s) have appropriate knowledge of all the resources that may be encountered? What mitigation efforts will be included as part of this program, and will any enforcement of these efforts occur?”	APS’s environmental contractor and/or BLM’s 3^rd party compliance inspection contractor, approved by the BLM, would provide this training. All training would be conducted by experienced and qualified biologists approved by the BLM. The training, at a minimum, would cover identification of tortoises, how to move them according to AGFD guidelines, the protocols for waiting for clearances prior to construction (communication), and when/if a monitor needs to be present. Migratory birds and active nests would be covered with a briefing on the criminal penalties of take under the Act. This information has been added to the EIS in Section 4.16.3.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.44	M&M	” The DEIS notes that gates will be installed on permanent ROW access roads as required by the landowner. Again, we ask whether BLM will require gates on all roads associated with this project that are not already open to the public. In order to limit resource damage, we strongly encourage the BLM to make these roads inaccessible to the public. Also, the DEIS says that gates “would prevent unnecessary traffic along access roads that would disrupt wildlife behavior or cause direct impacts (collisions) to wildlife” (pg. 2-88, Section 2.9.15). It is important to note that gates do not necessarily prevent access (see Impacts of Roads section of our comments).”	Section 4.9.3 has been revised to specify locations for gates on BLM-managed public lands. Mitigation measures have been added to Section 4.9 designating the centerline access as an Administrative route that is intended to prohibit unauthorized use of the ROW, and provide BLM authority to enforce the recreational use decisions. Additionally, Section 4.9.3 specifies that the centerline access would be signed and speed limits enforced during construction, which would reduce adverse impacts to wildlife.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.45	M&M	” Would any mitigation measures be enforced if emergency maintenance activities are required? The DEIS states that it may not be feasible to schedule these with sensitivity to wildlife resources (pg. 4- 190, Section 4.16.2.1) and that all adverse impacts would be unavoidable (pg. 4-196, Section 4.16.4). However, it does not discuss whether any mitigation efforts, such as enforced speed limits, would still be in place. What “reasonable measures to protect wildlife” will be taken?”	The referenced text occurs under the heading of Noise and Vibration and speaks to the inability to schedule unforeseen maintenance activities. All mitigation measures would be enforced unless there was something specific due to the nature of the emergency that prevents it.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.46	M&M	” Several important mitigation measures are also absent from the DEIS. For example, in order to minimize trapping or burying of wildlife, will any holes or pits be covered when not in use and checked for animals prior to use? The DEIS must discuss additional mitigation.”	Sections 2.4.2.4 and 4.16.3 have been revised to include the recommended additional mitigation.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.47	WLF	” The DEIS says that pre-construction surveys will be done for biological resources to identify areas to avoid during construction. However, little further information is provided. Who will conduct these surveys? It is important for a biologist who is familiar with various species to conduct the surveys to ensure that all species/individuals that occupy the area are identified; it may, in fact, require multiple biologists as many species are very specialized and can be difficult to locate without proper training.”	Sections 2.4.2.4 and 4.16.3 have been revised to specify that surveys would be conducted by a qualified biologist, approved by the BLM.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.48	GEN	” When will the surveys be conducted with regards to the start of construction? Ideally, surveys should be done when the specific route is being determined and again immediately prior to work being conducted in that area. Surveys conducted in advance of specific route designation will help minimize risk to special status species and other sensitive resources as those resources can be avoided. However, considering the mobility of wildlife, surveys must also be done immediately prior to work in an area (i.e., on the same day) to help ensure that animals are not in the path of construction. If a species is found within the work path, it should either be moved or avoided, as appropriate, or work should cease until the animal has moved on or other appropriate action has been taken.”	Sections 2.4.2.4 and 4.16.3 have been revised to specify that preconstruction surveys would be done along the construction footprint in the layout/project planning phase and then again immediately prior (within a few days) to construction.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.49	GEN	” We request that the BLM provide more detailed information about proposed pre-construction surveys.”	Sections 2.4.2.4 and 4.16.3 have been revised to specify that preconstruction surveys would be done along the construction footprint in the layout/project planning phase and then again immediately prior (within a few days) to construction. Preconstruction surveys would be done for desert tortoise and potential shelter sites, active migratory bird nests, and Hohokam agave (Agave murpheyi), as well as other incidental observations of wildlife and an inventory of the dominant vegetation present.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.50	WLF	” The DEIS greatly downplays the significance of habitat fragmentation and the effect this project could have on the connectivity of the landscape. A large amount of habitat would be destroyed or degraded as a result of the Proposed Action and action alternatives. These effects would be longterm and significant. However, the DEIS glosses over this fact and does not adequately discuss impacts to the various species in the project area.	Habitat fragmentation is appropriately addressed in Section 4.16.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.51	WLF	” With regards to habitat loss, the BLM frequently notes that wildlife will be able to utilize adjacent habitat, so this project would not have serious impacts. However, the BLM also notes that “adjacent habitat may be less suitable because it may already be occupied or defended, and resources may already be at a carrying capacity to maintain a particular species’ population” (pg. 4-186, Section 4.16.2.1). We appreciate recognition of this fact but are confused as why the BLM then assumes minor or no impacts to a species from this project as animals can move to adjacent habitat. The BLM should reassess potential impacts based on the potential for less suitable or unavailable surrounding habitat.”	The EIS quantifies the impacts to habitat in acres by land ownership and intensity (permanent or temporary) (Tables 2.4-4 and 2.4-7). The expected impacts to special status species that may occur in the area are listed in Table 4.16-2. For most of these species where habitat losses will occur the impacts are expected to be minor, defined as: “There would be a small, but detectable effect to habitat amount/quality or to individuals of a species that would be noticeable primarily on the scale of individuals in a localized area. There would be no effect on the viability of the local population or habitat capability”. Given the narrow footprint of the project relative to the surrounding habitat, this would be a reasonable expectation of the magnitude of the impact.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.52	WLF	” This proposal will disrupt a considerable amount of land. As the BLM notes, removal of habitat under any action alternative would result in a permanent removal of habitat due to the slow-growing nature of Sonoran desert vegetation (pg. 4-186, Section 4.16.2.1). Not only will the habitat along the centerline of the transmission line be destroyed, but construction will affect a larger area and impacts will spread into the surrounding landscape. The BLM does not adequately address how this fragmentation and habitat removal will affect biological resources and instead assumes that any impacts would be minor.”	Habitat fragmentation is appropriately addressed in Section 4.16 and the level of impacts are described.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.53	WLF	” The BLM does not acknowledge the importance of maintaining large tracts of unfragmented habitat. These large, connected landscapes are becoming increasingly rare and also increasingly important as development and other pressures destroy or degrade desert areas. Many species rely on large expanses of natural habitat for survival. In fact, according to prominent conservation biologists, habitat fragmentation is the most serious threat to biological diversity and is the primary cause of the present extinction crisis.” Preserving small or disconnected plots of land will do little to ensure survival of some species and ecosystems. The BLM must consider this implication and analyze potential impacts to species that currently or may in the future utilize this area.	Habitat fragmentation is addressed in the EIS in Section 4.16.2.1 under the heading of Habitat Fragmentation.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.54	GHG/ CC	” These large, connected landscapes are also becoming increasingly important in the face of climate change. As habitats are modified due to changes in temperature and weather patterns, species need the ability to move and the ability to access resources within a broader area. Researchers have found that climate change alters ecosystem quality, potentially making it more difficult for species to access necessary resources solely within previously occupied areas. Similarly, increasing temperatures are causing habitat ranges of many North American species to shift northward in latitude and upward in elevation. Habitat fragmentation and the inability of animals to shift their range in response to climate change is a chief concern. In the DEIS, the BLM notes that “[c]urrent conditions in the Sonoran Desert represent the extreme range for many plant species, and the combination of increasing temperatures and decreasing water availability is likely to shift the range of many plants and animals northward or even cause them to become extinct” (pg. 3-16, Section 3.2.5.6). However, even though recognizing these threats, the BLM does not discuss climate change or the implications for wildlife species based on lost and fragmented habitat. In fact, Section 3.2.5 is the only section of the DEIS in which climate change is actually mentioned and, even then, only general information is provided rather than information specific to this project. This is a serious oversight.”	Section 4.2.3.2 provides quantifications of the Greenhouse Gas (GHG) emissions for the project. GHG emissions from the project are significantly below reporting or permitting thresholds that apply to stationary sources. Since there is no established method to assess the impacts of GHG emissions, a meaningful assessment of the climate change impacts of the project cannot be determined. Section 4.19.17 describes potential cumulative effects to wildlife resources that address some of these comments.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.55	WLF	” The BLM also does not address the fact that some species prefer not to cross open areas without suitable habitat cover. The DEIS does note that “[p]opulations of small mammals or reptiles could be fragmented by the transmission line if a portion of the population becomes isolated by or avoids the disturbance area” (pg. 4-191, Section 4.16.2.1). However, it then states that these impacts would be short-term and minor. How was this conclusion reached? Fragmentation of a population is neither a short-term nor minor effect. As noted above, habitat fragmentation is one of the primary threats facing many species; the inability or unwillingness of a species to cross an open area must factor in to BLM’s analysis.	Habitat fragmentation is appropriately addressed in Section 4.16 and the level of impacts are described.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.56	WLF	“The DEIS also recognizes that transmission lines pose a barrier for migratory bird flights, despite raptor protection features, and creates smaller areas of suitable habitat, resulting in long-term and moderate impacts. Considering the number of migratory bird species that utilize this area, including several special status species, such an impact can be quite significant. Similarly, disturbance of desert wash habitats can fragment important habitat for a variety of species as well as critical wildlife linkages. Unfortunately, no mitigation can resolve these concerns. The BLM should reassess potential impacts based on these threats.”	BMPs (Appendix 2A) and mitigation measures (Section 2.9 and throughout Chapter 4) would be implemented for the project that would help to avoid and/or minimize potential impacts. Section 4.16 describes habitat fragmentation impacts.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.57	WLF	“With regards to habitat loss and fragmentation, we request that the BLM provide a more detailed analysis of potential impacts from this project. The DEIS does not adequately represent or discuss some important implications of lost, degraded, and fragmented habitat, such as those relative to climate change and lost movement abilities, which does not allow the true impacts of this project to be evaluated.”	Habitat fragmentation and its impacts to wildlife species are discussed in Section 4.16.2.1. The EIS acknowledges impacts from fragmentation and impediments to movement for some species. Since there is no established method to assess the impacts of GHG emissions, a meaningful assessment of the climate change impacts of the project cannot be determined. Section 4.19.17 describes potential cumulative effects to wildlife resources that address some of these comments.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.58	SSS	“The Preferred Alternative and several of the action alternatives have the potential to greatly affect desert tortoises. The Proposed Action would destroy or degrade 135 acres of Category II habitat and 192 acres of Category III. Considering that the Sonoran desert tortoise is a candidate for listing under the Endangered Species Act and that studies have shown that habitat fragmentation and development are chief threats, this is unacceptable. As the DEIS indicates, Category II habitat may be crucial for survival of the species as it is essential to maintenance of viable populations. Destruction and degradation of this habitat thus endangers the viability of that population of tortoises, further threatening the species. The BLM must be cognizant of this fact and work to preserve habitat areas such as this. Unfortunately, the mitigation measures discussed in the DEIS will do little to help protect this species.”	As explained in Section 4.16.3.1, loss of Sonoran desert tortoise habitat would be compensated according to the BLM desert tortoise mitigation policy. The intent of the mitigation policy is to maintain habitat in order to ensure the existence of viable populations.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.59	SSS	“In addition to habitat fragmentation, this project also has the potential to further exacerbate other threats to this species, including disease, exotic plant species and the associated fires, illegal collection, predation, and the effects of increased recreation access and off-road vehicles, among other issues. These impacts have the potential to cause direct mortality and a reduction in the effective population size, as well as further alter habitat.14 However, the DEIS does not discuss associated impacts with regards to this species.”	Section 4.16 analyzes the potential impacts to the desert tortoise from the project and Section 4.19.17 provides a description of potential cumulative effects to wildlife resources.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.60	SSS	“In the DEIS, the BLM seems to rely primarily on compensation for loss of desert tortoise habitat. This is not an appropriate mitigation measure. First and foremost, purchasing suitable desert tortoise habitat for the purposes of conservation does not create habitat, as the DEIS implies, as that habitat already exists. Because purchasing land does not create habitat, the statement that this project will result in “no net loss” of tortoise habitat is completely inaccurate. This project will eliminate and degrade existing habitat, which will result in a net loss.”	The following text was added to Section 4.16.3.1: The first focus of the desert tortoise mitigation policy is on avoiding and minimizing impacts to tortoises and their habitat. If an action with on-site mitigation measures would result in residual impacts, then compensation would be required. Category II habitats would be compensated for at a rate ranging from 2:1 to 5:1. Category III habitats would be compensated for at a rate of 1:1. Acquiring habitat is the primary means of compensation for impacts to tortoise habitat; however, compensation funds can also be used for other tortoise conservation efforts. Purchasing private lands with tortoise habitat would bring these lands into federal protection, making the habitat more secure. Further, reclamation of temporarily disturbed areas would also be conducted and would assist with restoring impacted habitat.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.61	SSS	” Second, purchasing small tracts of land across the state will not necessarily help protect survival of this species. Small, disconnected fragments of land do not compare to large blocks of intact habitat. In order to ensure self-sustaining populations of tortoises, large, connected landscapes must be kept intact. As noted above, large blocks of intact landscapes are becoming increasingly rare and increasingly important. Similarly, there is no guarantee that purchased habitat will be of the same quality as the lands that are destroyed, especially considering size and fragmentation effects. Third, purchasing land for the purposes of conservation does not ensure that those lands will not be developed, fragmented, or otherwise degraded in the future. As is evident by this proposed project and the proposed RMPA, lands set aside for conservation are not immune to development.”	The BLM’s tortoise compensation policy directs that the BLM purchase habitat of equal or higher value for tortoises. Connectivity to adjacent tortoise habitat is an important decision when determining the value of the habitat. The purchased land would be in federal protection and any proposed ground- disturbing impacts would have to be analyzed through NEPA, and would be open to public input.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.62	SSS	” Finally, compensation for removal of tortoise habitat instead of purchasing lands for conservation also does not create habitat. If compensation is required, habitat will be lost, even according to BLM’s standards. The statement that “[t]here would be no net loss of desert tortoise habitat” (pg. 4- 193, Section 4.16.2.2) is false and should not be used to justify this project.”	Through compensation there would be no net loss of desert tortoise habitat on public lands. The compensation rate for category II habitat would be from 2:1 to 5:1.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.63	M&M	” Another mitigation measure offered specific to desert tortoises is for a desert tortoise monitor to survey the ROW prior to ground-clearing construction activities (pg. 2-88, Section 2.19.15). What training or experience would this monitor have? Tortoises can be very difficult to locate, depending on terrain and vegetation, so it is important for a person with suitable experience to conduct the surveys. Also, when would the surveys be conducted relative to the start of construction? It is important to survey the area just prior to and during construction as tortoises are highly mobile.”	Sections 2.4.2.4 and 4.16.3 have been revised to specify that surveys would be conducted by a qualified and BLM approved biologist. A ‘qualified biologist’ would meet the qualifications for the 0486 series wildlife biologist as posted on usajobs.gov and have the necessary experience and expertise required by the BLM. These sections have also been revised to specify that preconstruction surveys would be done along the construction footprint in the layout/project planning phase and then again immediately prior (within a few days) to construction.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.64	M&M	” The DEIS also says that desert tortoise training would be included in the Environmental Awareness Program. Who would develop this portion of the program? Would there be any enforcement of recommended procedures to reduce tortoise mortality?”	APS’s environmental contractor and/or BLM’s 3^rd party compliance inspection contractor, approved by the BLM, would provide this training. All training would be conducted by experienced and qualified biologists approved by the BLM. The training, at a minimum, would cover identification of tortoises, how to move them according to AGFD guidelines, the protocols for waiting for clearances prior to construction (communication), and when/if a monitor needs to be present. BLM would have in place any applicable and relevant enforcement procedures, typical for similar construction projects on BLM land.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.65	SSS	” Speed limits and signs will be posted on all access roads in desert tortoise habitat. However, as noted in the Impacts to Roads section of our comments, these may do little to reduce tortoise mortality from collisions with vehicles. Personnel and any members of the public who access these roads may not follow the posted speed limit. Additionally, tortoises are very cryptic and blend in well with their surroundings; they may be difficult to see on the roadway, especially at higher speeds.”	The EIS was revised to indicate that the centerline access would be designated an administrative route, and as such, speed limits would be enforced by the BLM. Environmental training for construction workers would also increase awareness and reduce the risk of mortality.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.66	SSS	” The BLM does not adequately address potential impacts to the Sonoran desert tortoise, yet assumes that impacts will be negligible. Based on the information provided in the DEIS as well as the information discussed above and in the Cumulative Impacts portion of this section of our comments, impacts to this species could be significant, especially in the long term. The BLM should reassess potential impacts to tortoises.”	The EIS states that impacts to desert tortoise would be long-term and minor. Minor is defined as: “There would be a small, but detectable effect to habitat amount/quality or to individuals of a species that would be noticeable primarily on the scale of individuals in a localized area. There would be no effect on the viability of the local population or habitat capability.”

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.67	WLF	” The BLM assumes that amphibians will either not be impacted or will experience only minor impacts from this project due to the lack of surface water in the Study Area. However, amphibians can exist in areas without semi-permanent surface water for prolonged periods. Many estivate during dry periods and become active only when surface water is available. Additionally, these species typically estivate underground, making them especially vulnerable to ground disturbance.15 Because amphibians rely on both terrestrial and aquatic areas, they are especially vulnerable to habitat fragmentation and disturbances within their range. However, the DEIS does not mention any impacts of this project on amphibians due to the above assumption. The DEIS greatly underestimates potential impacts to amphibians. These impacts should be reassessed.”	Additional potential impacts to amphibians have been added to the Mortality and Fragmentation sections of 4.16. Impacts to amphibians from desert wash habitat disturbance are described as potentially moderate.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.68	WLF	” The DEIS says that a wildlife biologist observed bird fauna along the Agua Fria River from an outlying access road in May 2008 (pg. 3-180, Section 3.16.3). However, this survey does not provide an adequate or reliable account of species that utilize this area. First, a single survey or surveys conducted only in one month of one year do not accurately represent species presence in an area, as discussed above. Second, the survey was conducted from an outlying road, from where several species may not have been seen or heard. Third, numerous other species were likely occupying this area but were not seen or heard at that specific time. The BLM must recognize that surveys such as this do not provide an adequate representation of species in an area and should not base decisions on them.”	More details regarding reconnaissance field surveys have been added to Section 3.16. Further, impacts to special status bird species that possibly occur in and near the project site were assessed in the EIS (Table 4.16-2). Mitigation to reduce impacts to these and other bird species include surveys for active nests so that the nests could be avoided during construction activities or by scheduling construction outside of the nesting period.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.69	WLF	” The BLM admits that “[o]ccurrence, use, and movement of golden eagles in the Study Area are not well understood” (pg. 3-189, Section 3.16.4.4). Without this knowledge, how can potential impacts to this species be ascertained? The BLM cannot ignore potential impacts just because the baseline data is not available. We would also like to remind the BLM that use of the HDMS does not provide definitive data (see comments above), so it cannot be assumed that golden eagles do not use this area.”	The EIS acknowledges that there may be long-term minor impacts to golden eagle foraging habitat. Potential suitable nesting habitat was modeled and there was no suitable nesting substrate for golden eagles within one mile of the project right of way.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.70	WLF	” Potential impacts to these species from loss of habitat are also not provided adequate attention. For example, disturbance of desert washes and loss of riparian habitat would have significant negative effects on species such as the crissal thrasher and Lucy’s warbler; the DEIS acknowledges this. However, it assumes that no such impacts would occur because desert washes containing seasonal flows or riparian vegetation would be avoided if possible (pg. 4-186, Section 4.16.2.1). No indication is given when it would not be possible to avoid such areas.”	The project right of way crosses many washes. In some areas it may not be possible to access the construction site and construct the power line and facilities without impacting wash habitat. If destruction of desert wash habitat occurs, the EIS states that it would be a long-term moderate impact to crissal thrasher and Lucy’s warbler habitat. Further, additional information on potential impacts to ephemeral washes were added to the EIS in the Water Resources section.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.71	M&M	” If nests are found during pre-construction surveys, the DEIS states that “a timing or special buffer may be implemented. The relatively short duration of construction activities would be considered before implementing the recommended buffer” (pg. 4-195, Section 4.16.3, emphasis added.) When would a buffer not be implemented? Who would make this decision? Mitigation measures such as this should be mandatory in order to be effective.”	A buffer would not need to be implemented if the nest was not active. This decision to buffer or put timing restrictions on an area would be made on a case by case basis. The decision maker would be the Field Manager with advice from the BLM Wildlife Biologist.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.72	WLF	” The DEIS also makes assumptions as to possible effects. For example, it states that “[s]ome nests may be within a larger radius where noise and vibration impacts may still be present, but would not cause adverse reproductive effects” (pg. 4-187, Section 4.16.2.1). Why is it assumed that no adverse reproductive effects would occur? No reference is provided. Is this merely an assumption or is it based on scientific knowledge?”	The EIS is acknowledging that there exists an area where there are noise and vibration impact to birds, but the disturbance isn’t great enough to harm reproductive success due to the attenuation of noise over distance. The EIS also acknowledges that there is an area closer to the disturbance where there would be an adverse effect on nesting success. Those nests within the construction zone are considered close enough to the disturbance that reproductive success may be compromised, so they would be buffered by avoiding the area where nesting is taking place or postponing construction until the nesting season is over.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.73	WLF	” The DEIS admits that “[m]ortality would occur when individuals are buried or run over by equipment; many small mammals and reptiles utilize small burrows underground, so these impacts are particularly likely if individuals stay underground within the direct disturbance area instead of moving to adjacent habitat” (pg. 4-185, Section 4.16.2.1). Most burrowing animals utilize their burrows for protection when threatened, so they likely would not have the opportunity to move out of the way of construction activities. What mitigation measures are proposed to reduce impacts to these species?”	The EIS acknowledges the likelihood of the mortality of these burrowing species where road building and other excavation takes place. There is mitigation for the burrowing special status species, Sonoran desert tortoise, but there are no mitigation measures for other burrowing reptiles or mammals.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.74	WLF	” The DEIS states that “the number of bat species in the Study Area predictably would be highest along the Agua Fria River within riparian habitat” (pg. 3-180). However, it then notes that 12–17 species of bats could utilize the riparian habitat along the Agua Fria, whereas 17–21 species could use other areas (Section 3.16.3). How were these numbers derived? Why is a lower number of bat species listed for riparian habitat compared to other areas? Although bats may forage or roost in certain areas, most species still seek riparian areas and free-standing water.”	The EIS mentions that between 17 and 21 species of bats could forage in the creosote-white bursage and the Sonoran palo verde mixed-cactus desert scrub habitats. This information was derived from Hoffmeister (1986) which is included in the references section of the EIS. The EIS also states that 12 to17 species of bats could frequent riparian habitat along the Agua Fria River, although it is likely that all of the bat species utilizing the upland habitats could also frequent the riparian habitat as well; this information came from the Biological baseline report.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.75	WLF	” The DEIS also assumes that no impacts will occur to Western red bats and Western yellow bats because the project will not result in loss of aquatic or riparian habitat (Table 4.16-2). However, both species of bats are not riparian obligates and may utilize other areas of the project site for both roosting and foraging.19,20 The Western red bat may use other areas, including mesquite bosques and desert washes;21 the DEIS indicates that the action alternatives and the Primary Segment Common to All Action Alternatives would cross such areas. The DEIS also notes that riparian habitats and desert washes will be avoided only when possible, which implies that important habitat for these species may be destroyed or degraded. The BLM must address potential impacts to these species.”	Riparian habitats would be avoided; language regarding disturbance in these habitats was revised accordingly. Desert wash habitats (Waters of the US) may be disturbed, however, and Table 4.16-2 and associated text were revised to address potential impacts to special status bat species.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.76	WLF	” The cumulative impacts analysis with regards to biological resources is deficient and does not provide an adequate representation of possible effects. Rather than provide analysis for each species and area affected, it generalizes all effects. Some species may be more heavily affected by projects and actions occurring in the region of the project, but this analysis does not give any indication of that. We realize how difficult it would be to assess cumulative impacts for each of these species and the affected habitat, but the BLM must acknowledge that the information provided in its cumulative impacts analysis is of little use to fully understanding the effects to these resources.”	Section 4.19.17 was revised to include discussion of disturbance associated with the Project and indicates that the Project would make a relatively minor contribution to the cumulative impacts. Analyzing cumulative impacts to wildlife by species would require greater site-specific analysis keyed to individual species habitat, which would result in an overly cumbersome analysis for such a large cumulative effects area, when the Project’s contribution is relatively minor.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.77	CE	” We also question why only a two-mile buffer was used to analyze cumulative impacts to wildlife. Many of the species inhabiting this area have a range much wider than just two miles. Combined with actions occurring in other areas of their range outside of that two-mile buffer, this project could have significant impacts. We question why the BLM assumes that “a two-mile buffer should encompass potential indirect impacts” (Table 4.19-1, emphasis added) and encourage the agency to broaden its analysis to include activities occurring in other parts of the species’ ranges.”	Table 4.19-1 states, “For some of these resources, the CIA boundary was chosen for simplicity purposes…” Expansion of the CIA for wildlife would likely dilute effects. Indirect impacts for the majority of wildlife species using the area directly impacted by the project wouldn’t extend beyond the two-mile buffer. Expanding the CIA for wildlife such as bird species that could travel much greater distances would dilute the potential cumulative effects resulting from the proposed project. Further, additional analysis in Section 4.19.17 has been included in the FEIS.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.78	CE	” This project, when combined with all other projects and actions occurring or potentially occurring in the area, results in significant habitat loss, degradation, and fragmentation. Cumulatively, these actions may result in impacts to species at the population or species level. However, the DEIS does not address these impacts.”	The cumulative impact analysis in Section 4.19.17 recognizes the potential cumulative population level impacts. It states, “Overall cumulative effects to wildlife resources…would be minor to moderate” and, “The effects described above are often amplified for special status wildlife.” Therefore, impacts to special status species, if amplified, could rise to the level of significance.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.79	CE	” In light of past, present, and reasonably foreseeable actions, it is critical to preserve habitat, including the area this project would affect. See the Habitat Loss and Fragmentation/Wildlife Linkages section of our comments for further information on this. The habitat currently available in the project area will become increasingly important as development occurs, including the planned community development south of SR74, which would decimate 82,403 acres. The BLM has a responsibility to maintain intact landscapes and habitat. By allowing this project to occur on its lands, that mandate will not be met.”	Section 1.3.2 was revised to expand the discussion of BLM’s mission and multiple use mandates. The revised section now states, “BLM’s multiple-use mission, set forth in the FLPMA, mandates that the BLM manage public land resources for a variety of uses…” While the commenter is correct that BLM has a responsibility to maintain intact landscapes and habitat, the BLM’s mandate clearly indicates that the BLM has a responsibility to balance a variety of uses.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.80	CE	” The DEIS does not adequately address impacts of increased recreation, potential spread of nonnative plant species, and other landscape-altering activities that will most assuredly continue to increase in this area. Such impacts are only briefly mentioned in the DEIS. These activities already have a negative impact on biological resources, and this project as well as foreseeable future actions will certainly exacerbate those impacts.”	Section 4.19.17 states, “Increased population in the CIA would likely increase recreational pressure on surrounding public lands. Increased human activity, hunting, and potential increased poaching would all lead to impacts to wildlife.”
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.81	CE	” When determining cumulative and potential long-term effects, the BLM must also account for changing habitat and range of species. Many species naturally alter their range or disperse to new areas. In addition, as climate change, drought, human development, and other factors alter habitat availability, quality, and range, species occurrence, range, and movement will shift. Most of the impact assessments in the DEIS only account for the current range or known locations of the affected species. This is an inadequate assessment.”	The EIS analyzes impacts to suitable habitat for a number of species. Impacts to suitable habitat are detailed in Table 4.16-2.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.82	GHG/CC	” Related to this, the BLM does not provide any consideration to other stressors, such as climate change and drought. As the U.S. Forest Service discusses in detail, “the issues of global climate change and cumulative impacts are closely related.” Such stressors are reasonably foreseeable and may have very significant impacts on the resources discussed in the DEIS. Although changes to the ecosystem and the implications for the resources these areas support are not well understood, it is imperative for land management agencies to incorporate climate change in planning decisions. By excluding factors such as climate change from the cumulative impacts analysis, the BLM has significantly underestimated the potential impacts of this project.”	Section 4.2.3.2 provides quantifications of the Greenhouse Gas (GHG) emissions for the project. There is no established method to assess the impacts of GHG emissions from the project, which are significantly below reporting or permitting thresholds that apply to stationary sources. As a result, no meaningful assessment of the climate change impacts of the project can be determined. Section 4.19.17 describes potential cumulative effects to wildlife resources that address some of these comments.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.83	CE	” The BLM’s assertion that cumulative effects to wildlife resources would be “minor or moderate” is unfounded and likely inaccurate. Even within its narrow scope of a two-mile buffer, the cumulative impacts should be considered major. Within this two-mile buffer, past, present, and reasonably foreseeable actions included in the DEIS would affect 93.6 percent of the cumulative impacts area. That degree of disturbance is significant. If the BLM were to appropriately analyze all cumulative impacts to wildlife resources, as discussed above, these impacts become even more significant.”	Section 4.19.17 states, “Overall cumulative effects to wildlife resources… would be minor to moderate” and, “The effects described above are often amplified for special status wildlife.” Therefore, impacts to special status species, if amplified, could rise to the level of significance.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.84	AR	” The DEIS greatly downplays the impacts that access roads can have on resources. Roads pose significant threats to the land and resources, including impacts on wildlife through direct and indirect mortality and habitat fragmentation. Although existing roads would be used for construction to the extent practicable, several new roads will need to be created. Roads, whether paved or primitive, inflict a horrific toll on wildlife. They facilitate inadvertent or deliberate disruption of wildlife and fragment habitat by carving otherwise large patches into smaller ones, resulting in negative impacts to interior habitat. Roads also directly eliminate wildlife habitat by occupying space within the ecosystem and by altering adjacent habitat. Roadside habitats experience increased temperature extremes and solar input and pollution from exhaust, herbicides, garbage, dust, and noise. These conditions can increase habitat disturbance by a minimum of 500– 600 meters on either side.”	Temporary construction routes would be reclaimed. Section 4.9.3 has been revised to specify locations for gates on BLM-managed public lands to prohibit four-wheel access to the centerline route. Mitigation measures added to Section 4.9 designating the centerline access as an administrative route is intended to prohibit unauthorized recreational use of the ROW, and provide BLM authority to enforce the restrictions on vehicular use of the centerline.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.85	AR	” In the Southwest, roads and associated activities are the primary cause of extensive arroyo cutting during this century. Severe gully formation negatively affects soils, vegetation, and archaeological resources. Vehicular traffic directly destroys biological resources by crushing vegetation and microbiotic crusts. The resulting soil compaction retards the recovery of vegetation. In addition, off road vehicle (ORV) use can cause unsustainable erosion rates, exacerbate the spread of non-native invasive plants, cause user conflicts, and damage cultural sites.”	Temporary construction routes would be reclaimed. Section 4.9.3 has been revised to specify locations for gates on BLM-managed public lands to prohibit four-wheel access to the centerline route. Mitigation measures added to Section 4.9 designating the centerline access as an administrative route is intended to prohibit unauthorized recreational use of the ROW, and provide BLM authority to enforce the restrictions on vehicular use of the centerline. Chapter 4 provides analysis of impacts from construction activities, including the creation and use of access roads.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.86	WLF	” The DEIS states that “[t]he effect of habitat fragmentation from roads…is particularly important for smaller sensitive species, such as the Sonoran desert tortoise, Arizona chuckwalla, and reticulate gila monster, as the ‘breaks’ in the habitat either separate populations from each other resulting in genetic isolation, separate habitat components that are crucial at different life stages, or offer greater opportunities for predators” (pg. 4-236, Section 4.19.17). However, such impacts are not thoroughly discussed in the DEIS, and the BLM consistently assumes that impacts will be minor. Effects such as those described in this statement are not minor; in fact, they can be considered major in the long- term.”	Sections 4.17 and 4.19.17 analyze the direct, indirect, and cumulative impacts to wildlife, including sensitive species.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.87	M&M	” Few measures to mitigate the effects of temporary and permanent roads are presented in the DEIS; these measures are not adequately discussed, nor are they likely to sufficiently reduce the threats to the resources. Adequate information is not provided in the DEIS to determine if the mitigation efforts that are identified will be suitable. For example, the DEIS states that “[i]f required by the underlying land owner or if APS finds it to be warranted, access roads could be gated to prevent access by unauthorized personnel” (pg. 2-9, Section 2.4.1.3). Would the BLM require gates on roads crossing its lands? If so, would these gates be locked? What monitoring or enforcement would occur to ensure that the public is not using these roads?”	Section 2.4.2.8 states, “Temporary construction roads, not required for future maintenance access, would be restored after construction of the Project is complete.” The centerline access would be a permanent road that would remain after construction. Section 4.9.3 has been revised to: Specify that the BLM would work with APS to develop a Construction Access Plan that would strictly limit construction access and operation of construction equipment to specific routes. Specify that the BLM would designate the centerline access route as an administrative access route only; prohibition of recreational use of the centerline access route (except for single-track trail crossing of the centerline access) and speed limits would be enforced by BLM. Specify locations for gates on BLM-managed public lands. Mitigation measures added to Section 4.9 designating the centerline access as an Administrative route is intended to prohibit unauthorized recreational use of the ROW, and provide BLM authority to enforce the recreational use decisions.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.88	OHV	” Increased recreation as a result of the new or improved access roads is a potential threat; however, it is not discussed in the DEIS. BLM has, itself, recognized that off-road vehicle use can significantly degrade public lands and that users may not stay on established trails; it has also acknowledged that creation of spur roads from designated routes frequently occurs and can cause even greater impacts. Numerous studies have also shown that high percentages of off-road vehicle users do not stay on established trails, even when those trails are well marked.38 In fact, the BLM has had to close a number of areas to off-road vehicle travel due to considerable damage to environmental resources. Additional information about the potential impacts from increased use of existing roads and creation of new ones should have been included in the DEIS.”	There would be no new or improved public access roads on BLM-managed public land as a result of the project. The centerline access would be a permanent road that would remain after construction. Section 4.9.3 has been revised to specify locations for gates on BLM-managed public lands. Mitigation measures added to Section 4.9 designating the centerline access as an administrative route is intended to prohibit unauthorized recreational use of the ROW, and provide BLM authority to enforce the recreational use decisions.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.89	AR	” The Study Area is located near popular off-road vehicle routes and special areas, including the Castle Rock Springs Special Recreation Management Area; the DEIS states that access to portions of this area may be prohibited and that approximately seven percent of BLM-designated routes and three percent of two-track trails in the Study Area may be closed during construction but that they would be reopened following construction. Would these reopened routes provide access to any roads created as part of this project? Will access to project-specific roads be blocked?”	Section 4.9.3 states that the centerline access would be gated and fenced to a natural barrier where it intersects roads. The mitigation measures have been expanded to indicate that APS and BLM staff would monitor conditions. APS would be responsible for making further modifications if the measures are not effective. Routes would be reopened once construction and reclamation activities are completed in the specific areas of the routes. Single-track trails would intersect the centerline access, but this newly created access would not be authorized for recreational use, nor would it be expected to be used illegally on a routine basis, as the centerline would not provide the recreational experience single-track users are looking for.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.90	M&M	” Land management agencies have also found that gates do not provide an impermeable barrier as the public frequently tampers with them or creates other access points. These issues and their implications for this project should have been addressed in the DEIS. Suitable mitigation measures should also have been discussed in detail. For example, if gates are used to prevent unauthorized access to project roads, what enforcement and monitoring will occur to ensure that the public is not accessing these areas?”	Section 4.9.3 states that the centerline access would be gated and fenced to a natural barrier where it intersects roads. The mitigation measures have been expanded to indicate that APS and BLM staff would monitor conditions. APS would be responsible for making further modifications if the measures are not effective.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.91	M&M	” The DEIS also states that temporary roads will be closed once construction is completed and if the roads are no longer needed. However, how will these roads be monitored during the construction phase to ensure that the public is not negatively affecting resources? How long after construction will the roads be closed? The longer these roads remain open, the more potential there is for abuse by recreationists.”	In response to other comments and concerns, BLM will work with APS to develop a Construction Access Plan to definitively identify access routes on BLM-managed public lands, particularly north of SR 74. Construction access north of SR 74 is envisioned to be limited such that no single-track OHV routes would be used, and a large portion of this area is closed to four-wheel OHV recreation. In addition, the EIS was revised to indicate that the centerline access would be designated an administrative route, and as such, restrictions on recreational use would be enforced by the BLM.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.92	AR	” Finally, the DEIS says that speed limits on project roads will be set at 20 mph and that they would be “strictly enforced” (pg. 2-13, Section 2.4.2.2). How will these speed limits be enforced? Without strict enforcement, it is highly unlikely that those traveling on the project area would adhere to the speed limit, including project staff and members of the public who access the area. Is there any funding available to ensure adequate enforcement activities on BLM lands?”	The EIS was revised to indicate that the centerline access would be designated an administrative route, and as such, speed limits would be enforced by the BLM. In addition, APS would monitor the route, and construction monitors would be employed, as described in Section 2.9. Environmental training for construction workers would also increase awareness and reduce the risk of mortality.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.93	AR	” We also object to the statement that “[p]ermanent roads associated with the transmission line (14- feet wide) would not measurably disrupt wildlife behavior as these roads would be used very infrequently, and would not be improved (i.e., paved). Direct fragmentation impacts to wildlife from permanent roads would be negligible” (pg. 4-191, Section 4.16.2.1). The DEIS does not provide information about how each species in the project area would respond to the presence of the roads, to disturbances on those roads, or to fragmentation caused by those roads. Without an understanding of these responses, the BLM cannot assume that impacts – especially fragmentation impacts – would be negligible.”	While the analysis under the heading of Habitat Fragmentation in Section 4.16.2.1 does not provide analysis by species, it does make some general distinctions between different types of wildlife sufficient to determine meaningful impacts.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.94	EJ	“As illustrated in Figure 3.10-1, the proposed action route at its northwest section passes through Circle City which is considered to be a low income area. Further east, the proposed route runs into the Highway 74 corridor at the Peoria boundary and then crosses the highway in order to avoid planned upscale developments at Saddleback Heights, Vistancia, and Lake Pleasant Heights. To be fair, if low income people are adversely affected, upscale development along the Carefree Highway should be expected to bear a burden as well.”	Section 4.10 has been revised and expanded in response to other comments, and now includes specific conclusions with regard to Environmental Justice impacts. The Environmental Justice portion of Section 4.10 now contains analysis of disproportionate effects to the identified low income block group.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.95	EJ	“To its credit, the DEIS devotes considerable space to Socioeconomics and environmental justice (3.10). It studied 17 block groups with a total population of over 39,000 people, and designated Block Group one, Circle City, as an environmental justice community because of a low income population of over 20 percent above that of the county. But the DEIS draws no conclusion from its findings, and does not discuss the inequitable treatment of Block Group one with respect to proposed development in Peoria. The Final EIS should complete this section and write out its conclusion to its Environmental Justice study.”	Section 4.10 has been revised and expanded in response to other comments, and now includes specific conclusions with regard to Environmental Justice impacts.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.96	WLF	” Impacts to wildlife from the spread of non-native invasive plant species is not addressed in wildlife section.”	Section 4.13.2.1 includes a discussion of this issue under Invasive and Noxious Plant Species. In addition, Section 4.19.17 also addresses this issue from a cumulative effects standpoint on wildlife habitat.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.97	VEG	” Even with noxious and invasive weed management plans, non-native species may still be introduced and spread.”	Section 4.13.2.1 includes a discussion of this issue under Invasive and Noxious Plant Species.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.98	M&M	“Will vehicles entering site be washed throughout the lifetime of the project?”	Yes, this is addressed in Appendix 2A – Best Management Practices.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.99	LU	” If the RMP is amended and the line is allowed to be built north of SR74, we are extremely concerned that it will result in significant degradation of the land and in a diminished viewshed, especially in light of the fact that the proposal would not only run along SR 74 but would actually cross SR74 twice. This would nudge development further into the BLM lands and could result in a subsequent loss of interest by BLM to manage these lands for conservation. These public lands might then be sold or traded away in another poorly conceived exchange that shortchanges the public as occurred with the 1997 Saguaro National Park Land Exchange.”	Table 1.5-1 explains the decisions to be made, and these decisions are specific to the future use of the public lands managed by the BLM.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.100	LU	“… While perhaps seeming improbable today, siting large scale infrastructure such as electric transmission lines north of SR74 raises the specter of massive development of private and state lands in the Lake Pleasant area sometime in the future, destroying any opportunity for proper consolidation and management in the public interest for wildlife habitat and recreation”	Development and land management beyond that described in Section 4.19 is not reasonably foreseeable and is beyond the scope of analysis of the EIS.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.101	SRMA	” According to the 2010 RMP40, these lands north of the SR74 are part of the Castle Hot Springs Management Unit and are worthy of protection for several reasons. According to the plan, no public lands in this area are available for disposal and no new utility corridors are designated (page 79). These lands include the following: Category II desert tortoise habitat A Class 2 Visual Resource Area Castle Hot Springs Special Recreation Management Area, which includes Hieroglyphic Mountains Recreation Management Zone (RMZ), Sheep Mountain RMZ, and Baldy Mountain RMZ Hells Canyon Wilderness The Recreation Management for this area emphasizes “preserving open space and retaining scenic and visual qualities” (page 80).”	Section 2.10 provides the rationale for the Agency Preferred Alternative.
Sandy Bahr, Chapter Director, Sierra Club – Grand Canyon Chapter	874.102	GEN	” This proposed right-of-way and RMP amendment should be rejected as they will result in degradation of habitat and public lands and will significantly impair the scenic nature of this area. This could also be the first step in pushing development further into the public lands and a means of promoting additional development on those lands, especially via future land exchanges.”	Statement of preference.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Paula Rockcastle	878.1	OPP UR	“We recently purchased a house in the area where this project is proposed and is within a 1/2 mile to a mile of our house. We purchased this house in this location because of the beautiful area with gorgeous mountains views. This will be destroyed. The proposed corridor is unacceptable. There must be a better solution as to not effect so many people. Part of the East/West portion runs right behind our house, (North of 257th). Why can’t this be further North towards Circle City. There is lots of land this can be put on further North. Many houses that are for sale in the area (and there are many), may remain vacant due to this project.”	Statement of preference. Alternatives to the Proposed Action route that would place the transmission line along an alignment other than the east-west segment along Lone Mountain Road are described in Section 2.7, along with explanations as to why those routes were eliminated from detailed analysis in the EIS.
Kathleen Martyn Goforth, Manager, Environmental Review Office (CED-2), EPA Region IX	879.1	WTR	“We have rated the DEIS as Environmental Concerns- Insufficient Information (EC-2), due to the lack of sufficient information to determine the extent of direct, indirect and cumulative impacts to waters of the U.S.”	The EIS has been revised to respond to each of the EPA’s concerns and comments and address the Insufficient Information.
Kathleen Martyn Goforth, Manager, Environmental Review Office (CED-2), EPA Region IX	879.2	WTR	“…it is difficult to determine the extent of direct, indirect and cumulative impacts to waters if the delineation is not conducted until completion of the DEIS. Also, it is difficult to determine the Least Environmentally Damaging Practicable Alternative and compliance with CW A 404 without this baseline information.”	Additional field work and modeling of impacts has occurred after publication of the DEIS, as part of a Preliminary Jurisdictional Delineation and that new information is incorporated into the FEIS in Section 4.15.
Kathleen Martyn Goforth, Manager, Environmental Review Office (CED-2), EPA Region IX	879.3	WTR	“The statement of a broad estimate of potential impact to waters at 25.7 acres seems in conflict with other statements in the DEIS that APS plans to avoid discharges related to the power line construction.”	Additional field work and modeling of impacts has occurred after publication of the DEIS, as part of a Preliminary Jurisdictional Delineation and that new information is incorporated into the FEIS in Section 4.15 in an effort to better clarify potential impacts.
Kathleen Martyn Goforth, Manager, Environmental Review Office (CED-2), EPA Region IX	879.4	WTR	“For the FEIS, expand and clarify the discussion of impacts to jurisdictional waters to include an estimate of type(s) and acreage, and include a discussion of impact avoidance measures, mitigation availability, and compliance with the Guidelines and Mitigation Rule.”	Additional field work and modeling of impacts has occurred after publication of the DEIS, as part of a Preliminary Jurisdictional Delineation and that new information is incorporated into the FEIS in Section 4.15 in an effort to better clarify potential impacts.
Kathleen Martyn Goforth, Manager, Environmental Review Office (CED-2), EPA Region IX	879.5	WTR	“Based on the results of the Preliminary Jurisdiction Delineation, the FEIS should include a table and clear narrative on the direct, indirect/secondary and temporary impacts to waters, including wetlands.”	Additional field work and modeling of impacts has occurred after publication of the DEIS, as part of a Preliminary Jurisdictional Delineation and that new information is incorporated into the FEIS in Section 4.15 in an effort to better clarify potential impacts.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Kathleen Martyn Goforth, Manager, Environmental Review Office (CED-2), EPA Region IX	879.6	WTR	“The FEIS should include additional detailed information on the functions and locations of ephemeral washes that may be impacted. Natural ephemeral washes perform a diversity of hydrologic and biogeochemical functions that directly affect the integrity and functional condition of higher-order waters downstream. Healthy ephemeral waters with characteristic plant communities control rates of sediment deposition and dissipate the energy associated with flood flows. Ephemeral washes also provide habitat for breeding, shelter, foraging, and movement of wildlife. Many plant populations are dependent on these aquatic ecosystems and adapted to their unique conditions. Potential damage that could result from disturbance of flat-bottomed washes includes alterations to the hydrological functions that natural channels provide in arid ecosystems: adequate capacity for flood control, energy dissipation, and sediment movement, as well as impacts to valuable habitat for desert species.”	The EIS has been updated in Section 3.15.1.3 to include a discussion on the functions that area ephemeral washes typically provide. Regarding location of the washes, the Project Record includes maps prepared for the Preliminary Jurisdictional Delineation.
Kathleen Martyn Goforth, Manager, Environmental Review Office (CED-2), EPA Region IX	879.7	WTR	“The FEIS should quantify the likely impacts to ephemeral streams from the proposed project, and project alternatives, and discuss potential mitigation.”	Additional field work and modeling of impacts has occurred after publication of the DEIS, as part of a Preliminary Jurisdictional Delineation and that new information is incorporated into the FEIS in Section 4.15 in an effort to better clarify potential impacts. This new information also includes applicable information on ephemeral washes.
Kathleen Martyn Goforth, Manager, Environmental Review Office (CED-2), EPA Region IX	879.8	WTR	“The FEIS should commit to avoiding, if possible, or minimizing direct and indirect impacts to ephemeral streams (such as erosion, migration of channels, and local scour).”	BMPs, outlined in Appendix 2A, are already part of the Proposed Action and address minimizing direct and indirect impacts to ephemeral streams.
Kathleen Martyn Goforth, Manager, Environmental Review Office (CED-2), EPA Region IX	879.9	WTR	“Provide, in the FEIS, additional information on the functions and locations of ephemeral washes in the project area that may be impacted and their hydrologic and biogeochemical roles in relationship to higher-order waters downstream.”	The EIS has been updated in Section 3.15.1.3 to include a discussion on the functions that area ephemeral washes typically provide. Regarding location of the washes, the Project Record includes maps prepared for the Preliminary Jurisdictional Delineation.
Kathleen Martyn Goforth, Manager, Environmental Review Office (CED-2), EPA Region IX	879.10	WTR	“The new 500/230 kV transmission line would result in the placement of between two and five towers within the 100 year flood hazard area (p. 4-179). These structures could impede flood flows or redirect flood flows to areas not currently within a flood hazard area by raising the base flood elevation. While the DEIS includes Best Management Practices to provide diversion structures that would be designed to minimize potential destabilization and erosion of adjacent and down gradient drainages, no additional details are provided.”	Additional information and details have been added to the FEIS in Section 4.15.2.1 in regards to having structures located within flood hazard areas.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Kathleen Martyn Goforth, Manager, Environmental Review Office (CED-2), EPA Region IX	879.11	WTR	“The FEIS should identify any areas subject to flash floods where structures are likely to be placed, discuss the impacts of the project on flood flows and demonstrate how flows will not be impeded and flood debris will not obstruct flows or result in scouring.”	Additional information and details have been added to the FEIS in Section 4.15.2.1 in regards to having structures located within flood hazard areas.
Kathleen Martyn Goforth, Manager, Environmental Review Office (CED-2), EPA Region IX	879.12	AIR	“The FEIS should also discuss the emissions of carbon monoxide with respect to de minimis levels and SIP Conformity.”	Applicable information and discussion was added as requested to Section 4.2.2.
Kathleen Martyn Goforth, Manager, Environmental Review Office (CED-2), EPA Region IX	879.13	VEG	“The EPA recommends that priority be given to alternative management practices that limit herbicide use, focusing, instead, on other methods to limit invasive species vegetation and decrease fire risk.”	Additional details on APS’ Invasive Plant Management Plan and proposed herbicide treatment activities has been either added to or referenced in the EIS. Measures in Appendix 2A (Noxious and Invasive Weed Management) are predominantly alternatives to herbicide use. Herbicides would only be used for treating noxious weeds where it is reasonable and prudent to do so and provided the herbicide being applied would be an effective treatment. Appendix 2B, APS’ Transmission Management Program, has been updated in the EIS. However, Appendix 2A will remain unchanged.
Kathleen Martyn Goforth, Manager, Environmental Review Office (CED-2), EPA Region IX	879.14	VEG	“In order to consolidate the numerous BMPs and mitigations and to strengthen the effort, the EPA recommends the development of an invasive plant management plan. If pesticides will be used to manage vegetation, the DEIS should disclose the projected quantities and types of chemicals to be used. The plan should also describe post-construction activities that will be required, such as surveying for invasive species following restoration of the construction site and measures that will be taken if infestations are found.”	Additional details on APS’ Invasive Plant Management Plan and proposed herbicide treatment activities has been either added to or referenced in the EIS. Measures in Appendix 2A (Noxious and Invasive Weed Management) are predominantly alternatives to herbicide use. Herbicides would only be used for treating noxious weeds where it is reasonable and prudent to do so and provided the herbicide being applied would be an effective treatment. Appendix 2B, APS’ Transmission Management Program, has been updated in the EIS. However, Appendix 2A will remain unchanged.
Kathleen Martyn Goforth, Manager, Environmental Review Office (CED-2), EPA Region IX	879.15	CUL	“The FEIS should discuss how any concerns raised by the Tribes were addressed and resolved. Provide an update on the status of the coordination with the Tribes and whether it is still ongoing. We recommend that any measures to reduce impacts to tribal and cultural resources that are developed be adopted in the ROD.”	Background information on Native American Tribes is presented in Section 3.3.7. Native American Tribal consultation and coordination was presented in Section 5.5 of the EIS. Consultation is on-going and any mitigation measures to reduce impacts to tribal and cultural resources would be adopted in the ROD.
Kathleen Martyn Goforth, Manager, Environmental Review Office (CED-2), EPA Region IX	879.16	AIR	“On page 3-11, the DEIS states, “There is also a carbon dioxide attainment area with a maintenance plan.” Recommendation: The FEIS should replace the word dioxide with the word monoxide.”	The text was revised as recommended in the comment.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Kathleen Martyn Goforth, Manager, Environmental Review Office (CED-2), EPA Region IX	879.17	AIR	“On page 4-17 in Table 4.2-7, the total for PM1 0 is 28.6 Tons/Month and for PM2.5 6.1 Tons/Month; these appear to be incorrect. Recommendation: The FEIS should replace PM1 0 total with 4.25 Tons/Month and the PM2.5 with 1.06 Tons/Month.”	The text was revised based on the comment. However, the PM2.5 total was rounded up to 1.07 tons/month.
Jewel Ray Chaudhuri	880.1	SUP PA	“The purpose of this email is to let you know of our support for the PROPOSED ALTERNATIVE which is on the north side of State Route 74.”	Statement of preference.
Jewel Ray Chaudhuri	880.2	OPP ALT3	“If lines are placed on the Carefree Highway Alignment, they will be visible from Trilogy and many parts of Vistancia and will mar the beauty of a community like Trilogy. We are concerned about the value of our property and how limiting our clear mountain views will affect future home sales.”	Statement of preference.
Jewel Ray Chaudhuri	880.3	LU	“In addition, State route 74 is already an existing transportation corridor and it makes sense to place the power lines there.”	Statement of preference.
Andrew J. Anderson, Corporate Counsel, Infinity Capital Golf Resources, LLC	882.1	OPP PA	“…we strongly object the proposed action as stated in the Draft EIS published in November, 2012…”	Statement of preference.
Andrew J. Anderson, Corporate Counsel, Infinity Capital Golf Resources, LLC	882.2	SAAA	“…it is in the public’s best interest that the preferred route be situated along the south side of SR-74. (This route is contemplated under Alternative 2.) The routing of the Proposed ROW corridor clearly is not logical and in fact, flies in the face of common sense. The Proposed ROW originates at the Morgan Substation on the south side of SR-74. The Proposed ROW then crosses SR-74 just east of the Saddleback Heights project and proceeds on the north side of SR-74 for approximately 5 miles. The Proposed ROW remains on the north side of SR-74 and crosses SR-74 immediately west of the Saddleback Heights project. The Proposed ROW route results in a gerrymandered route which unnecessarily crosses SR-74 two times in a very short distance.”	Statement of preference.
Andrew J. Anderson, Corporate Counsel, Infinity Capital Golf Resources, LLC	882.3	LU	“The location of Quintero Community, including Quintero Golf Club was selected for the uniqueness of its real estate and the serenity of its surroundings. With access off the SR-74 scenic corridor and surrounded by thousands of acres of BLM acreage, Quintero was able to represent to its residents that Quintero and the surrounding area would remain preserved and untouched for decades to come. In reliance on the uniqueness of the Quintero land, more than 100 million dollars was invested in the Quintero Community.”	Statement of opinion. Comment registered and noted.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Andrew J. Anderson, Corporate Counsel, Infinity Capital Golf Resources, LLC	882.4	SOC	“The proposed ROW will have a direct effect on the Quintero Community and Quintero Golf and Country Club as the ROW. The presence of the transmission lines, monopole tower structures and supporting infrastructure nearby and within view of the Quintero project will negatively impact the value of real estate in the Quintero Community. The visibility of the transmission lines and monopole towers will devalue those lots and will diminish the pure golf experience that Quintero Golf Club currently provides to its guests. The vistas toward the Quintero community from SR-74 will be disturbed by the transmission lines and monopole towers.”	The ROW would be 200 feet wide, 100 feet either side of centerline of the transmission line. The ACC- certificated corridor (referred to as the ACC-certificated route in the EIS) does extend beyond the Proposed Action/Preferred Alternative ROW; however, as depicted in the EIS, there are no plans for BLM to authorize APS to utilize this area in support of construction.
Andrew J. Anderson, Corporate Counsel, Infinity Capital Golf Resources, LLC	882.5	VIS	“Although the transmission lines will cross SR-74 to the east of the Quintero entrance, the ROW extends further past the entrance of the Quintero community and will allow APS and its contractors to construct structures and the store materials in close proximity to the Quintero entrance. This will certainly create an immediate negative visual impact and will detract and devalue the entrance to the project.”	The ROW would be 200 feet wide, 100 feet either side of centerline of the transmission line. The ACC- certificated corridor (referred to as the ACC-certificated route in the EIS) does extend beyond the Proposed Action/Preferred Alternative ROW; however, as depicted in the EIS, there are no plans for BLM to authorize APS to utilize this area in support of construction.
Andrew J. Anderson, Corporate Counsel, Infinity Capital Golf Resources, LLC	882.6	SOC	“The actual impact on the Quintero Community and Quintero Golf Club will not be known for years and will be extremely difficult to quantify. However, it is clear in past instances in which electrical transmission infrastructure was constructed in close proximity to existing residential real estate that the value of that property was negatively impacted. The economic cascade will trickle down to local municipalities and taxing districts that will receive diminished tax receipts as a result in the permanent diminution of nearby real estate in value.”	An analysis of socioeconomic impacts of all alternatives is in Section 4.10, including potential impacts to property values.
Andrew J. Anderson, Corporate Counsel, Infinity Capital Golf Resources, LLC	882.7	VIS	“The BLM obligated Quintero to take extraordinary measures to insure that the scenic corridor and the views of the area were not disturbed. In fact, millions of dollars were spent by Quintero’s developer to bury the Community’s incoming power supply, water delivery and blend the entrance and sightlines to the community into the natural topography and landscape. Quintero has gone since inception without signage to the entrance to the community in order to comply with the Visual Resource Management (VRM) Class III standards and requirements due to the strict requirements of the VRM. The Proposed ROW is inconsistent with the BLM’s previous commitments to keep the north side of SR-74 in its natural state and requirements that were mandated on Quintero’s developer. If the Proposed ROW is finalized, the actions of Quintero’s developer of burying the power lines to the Quintero Community were unnecessary and millions of dollars will have been wasted.”	Section 2.10 provides the rationale for the BLM’s Agency Preferred Alternative. In addition, Chapter 1 has been revised to describe the BLM’s multiple use mandate and how the ACC process played a role in the overall decision.
Andrew J. Anderson, Corporate Counsel, Infinity Capital Golf Resources, LLC	882.8	LU	“The location of the proposed ROW is a critical decision that will provide the path to further development and eventual destruction of the pristine desert environment.”	Table 1.5-1 explains the decisions to be made and these decisions are specific to the future use of the public lands managed by the BLM.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Andrew J. Anderson, Corporate Counsel, Infinity Capital Golf Resources, LLC	882.9	SAAA	“…we respectfully request that the BLM … consider Alternative 3 which will create less environmental impact or take no action at this time.	Statement of preference.
Walter “Skip” Zahlmann	883	UC	Content unrelated to analysis
Walter “Skip” Zahlmann	884	UC	Content unrelated to analysis
Walter “Skip” Zahlmann	885	UC	Content unrelated to analysis
Laura Canaca, Acting Chief, Habitat Branch, State of Arizona Game and Fish Dept.	886.1	RIP	“The Department recommends riparian areas and desert washes be avoided unless absolutely necessary.”	Section 4.15.2.1 indicates that all washes would be spanned. Additional information on potential impacts to washes that potentially contain riparian habitat were incorporated into the FEIS, based upon additional field work that has been completed after publication of the DEIS.
Laura Canaca, Acting Chief, Habitat Branch, State of Arizona Game and Fish Dept.	886.2	SSS	“…we support the avoidance to the maximum amount possible for Category II and III desert tortoise habitat.”	BLM is aware and concerned about impacts to desert tortoise and this is considered in the analysis and mitigation requirements. Section 4.16 analyzes impacts to desert tortoise habitat by the Proposed Action and the Action Alternatives. The EIS analyzes disturbances and degradation of Category II and III tortoise habitat. Mitigation specific to desert tortoise is provided in Sections 2.9.15 and 4.16.3.1.
Laura Canaca, Acting Chief, Habitat Branch, State of Arizona Game and Fish Dept.	886.3	OREC	“We recommend consideration be given to wildlife related recreation, specifically hunting within the analysis of the alternatives.”	Analysis of potential impacts to hunting were added to the Chapter 4 Recreation sections.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Laura Canaca, Acting Chief, Habitat Branch, State of Arizona Game and Fish Dept.	886.4	SAAA	“We have determined Alternative 3-Carefree Highway Route, the most southern alignment of the project from I 79th Avenue to the Raceway Substation, as having the least potential for impacts on both wildlife resources and recreational uses. The area along this southern route has been planned for large residential developments (Saddleback Heights, Vistancia, Lake Pleasant Heights, etc.) and would consequently result in highly degraded quality and connectivity of habitat for wildlife. Additionally, this southern area is not known as a popular recreation area for OHV users, due to a mix of land ownership and access restrictions and would not likely require mitigation for loss of recreational uses.”	Statement of preference noted.
Laura Canaca, Acting Chief, Habitat Branch, State of Arizona Game and Fish Dept.	886.5	GEN	“Alternative 2, just to the south along State Route 74 and the PA Alternative, north of State Route 74 transect is a popular OHV area and is composed of higher quality wildlife habitat. These routes would require mitigation to offset for the loss of OHV use as stated in the document and would in turn cause additional wildlife habitat modification that is not currently discussed within the analysis, also potentially requiring minimizing and/ or mitigation consideration. Even if mitigation was not implemented as stated, OHV users would still be displaced by the construction and changes in access, causing them to degrade previously undisturbed wildlife habitat as a potential cumulative impact consideration.”	Required mitigation is specified by resource in Chapter 4 and is summarized in Section 2.9.
Laura Canaca, Acting Chief, Habitat Branch, State of Arizona Game and Fish Dept.	886.6	SAAA	“Therefore, the Department believes Alternative 3, followed by Alternative 2, pose the least potential impacts to wildlife resources and recreational uses.”	Statement of preference.
Laura Canaca, Acting Chief, Habitat Branch, State of Arizona Game and Fish Dept.	886.7	OPP PA	“The Proposed Action Alternative would have the most overall potential for impacts to wildlife resources and recreational uses due to the location, current and anticipated uses, and wildlife habitat quality.”	Statement of preference.
Walter “Skip” Zahlmann	887.1	UC	Content unrelated to analysis
Richard Stuhan, Siting Consultant Senior, APS	888.1	SUP PA	“APS supports the Bureau of Land Management’s (“BLM”) identification of the Proposed Action route as the Agency Preferred Alternative as it is consistent the decision of the Arizona Corporation Commission (Decision No. 70850, March 17, 2009).”	Statement of preference.
Richard Stuhan, Siting Consultant Senior, APS	888.2	GEN	“Section ES.4.4, page ES-7 does not clearly differentiate where the federal ROW is needed. APS requests that this section be revised to clearly explain that a federal ROW is needed for Alternative 3.”	Section ES.4.4 was revised per the comment.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Richard Stuhan, Siting Consultant Senior, APS	888.3	GEN	“In Section ES.6.1, page ES-9 the phrase “routine watering” is not defined. This could be clarified by adding a reference to Appendix 2A for details.”	Section ES.6.1 was revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.4	CUL	“Section ES.6.2, page ES-9, does not reflect current BLM and SHPO consultation information. APS requests the text be revised to read: “Ten National Register-eligible cultural resource sites (i.e., historic properties) are known to be within the Proposed Action route. These include three historic sites, five prehistoric sites, and two multi-component sites.”	The corridor width inventoried for cultural resources was 400 feet, while the corridor width analyzed in the EIS is 200 feet. The number of sites presented in the EIS are those within the 200 foot wide corridor.
Richard Stuhan, Siting Consultant Senior, APS	888.5	CUL	“With respect to Section ES.6.2, APS requests revising the second and third paragraphs on page ES- 10 (Cultural Resources section) to read: “Operation, maintenance, and abandonment of the transmission line are not anticipated to cause direct impacts in addition to those resulting from construction, but if BLM and ASLD conclude that National Register-eligible properties might be threatened, BLM and ASLD will work with APS to implement measures to avoid adverse impacts. BLM and/or ASLD staff, perhaps assisted by Arizona Site Stewards program volunteers, would conduct long-term monitoring as warranted.”	Section ES.6.2 was revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.6	GEN	“Section ES.6.6, page ES-12, the second sentence of the last paragraph suggests that EHV lines attract lightning, therefore increasing lightning strike risk in the surrounding area. This is not true. APS recommends removing the following sentence in that paragraph: “Physical presence of the transmission line may increase the likelihood of lightning strikes in the vicinity of the transmission line and structures, which would lead to a small increased risk of lightning caused fires along the entire route of the Project.””	Section ES.6.6 was revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.7	GEN	“In Section ES.6.11, page ES-15, APS recommends that the following text be inserted at the end of the first sentence in the second paragraph: “to the extent practicable.” APS also requests that the second sentence of that same paragraph be revised to note that in some instances construction access roads outside of the transmission line ROW would be used on an ongoing basis for operations and maintenance.”	Section ES.6.11 was revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.8	GEN	“In Section ES.6.14, page ES-18, APS recommends that the second sentence of the fourth paragraph be revised to say: “To the extent practical, all washes would be spanned.”	Section ES.6.14 was revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.9	GEN	“In Section 1.1.1, page 1-1, APS requests that its name be revised to say “Arizona Public Service Company.”	Section 1.1.1 was revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.10	GEN	“Section 1.1.2 implies that APS did not participate in the development of the Bradshaw- Harquahala Resource Management Plan. APS requests that this section be revised to clarify that APS did participate and provide comments during the development of the RMP, including submittal of a letter identifying the area along SR 74 as a potential future utility corridor.	Additional information was added to Section 1.1.2 for clarification, per the comment.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Richard Stuhan, Siting Consultant Senior, APS	888.11	GEN	“In Section 1.5.4, page 1-14, APS requests that the ”State Historic Preservation Act (A.R.S. 41- 861 to 41-864)” be inserted as a regulatory requirement column revision to the first line of Table 1.5-3 by adding to the third column of table because that statute also stipulates consultation with the SHPO for projects on state land.	Section 1.5.4 was revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.12	GEN	“Also in Section 1.5.4, page 1-14, APS requests a revision to Table 1.5-3 by inserting a line after the first entry to indicate an Arizona Antiquities Act permit would be required from the Arizona State Museum pursuant to the Arizona Antiquities Act (A.R.S. 41-841 to 41-847) for investigation of archaeological, historical, and paleontological sites and objects on state land.	Table 1.5.3 was revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.13	GEN	” In Section 2.3.2, page 2-5, there are examples of short-term ROWs that may be necessary as part of the Project. This comment is intended to clarify that the list of examples is not complete, i.e., geotechnical testing and other temporary or short-term uses of public land are not listed.”	Section 2.3.2 was revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.14	GEN	” In Section 2.4, page 2-6, the second paragraph states the transmission line “would be constructed on single-pole steel structures…” implying that no other structure types would be used. However, elsewhere in the document the potential for different structures is mentioned. Therefore, APS requests this sentence be revised to read “…would typically be constructed…””	Section 2.4 was revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.15	GEN	” In Section 2.4, page 2-6, in the second sentence of the second paragraph replace the word “would” with “may.””	Section 2.4 was revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.16	GEN	” In Section 2.4, page 2-7, the text in Table 2.4.1 identifies the 230kV circuit as using a single circuit per phase. However, APS is considering using either a single or a two bundle conductor option as described in Section 2.4.1.2. APS requests the text in the table be revised to be consistent with the text in Section 2.4.1.2.”	Table 2.4.1 was revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.17	GEN	” In Section 2.4.1.1, page 2-7, the text states “self-weather finish available for tubular steel structures only this finish is not available for lattice structures.” APS requests a sentence be added to clarify that the pole structures would be dulled galvanized or self-weathering steel, as the self- weathering finish is not available for lattice structures, which will have a galvanized finish.”	Section 2.4.1.1 was revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.18	GEN	” In Section 2.4.1.1, page 2-7, the text states structure type selection will include “…coordination with underlying land owner.” APS does not intend to coordinate various structure types with private landowners along the route, though does commit to coordination with the appropriate land- managing agency. Similar language occurs throughout the document and APS requests a change be made to this section and conforming change in the document as a whole.”	Text revision made document-wide.
Richard Stuhan, Siting Consultant Senior, APS	888.19	GEN	” In Section 2.4.1.2, page 2-8, APS requests a revision to clarify that the Project could include two 96-pair fiber optic/static neutral cables or a single 96-pair fiber optic/static neutral cable with a single steel static shield wire. That is, APS may need only one fiber optic cable for both the 500kV and 230kV circuits, but a static shield wire would then be installed above the 230kV circuit.”	Section 2.4.1.2 was revised per the comment.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Richard Stuhan, Siting Consultant Senior, APS	888.20	GEN	” In Section 2.4.1.3, page 2-9, APS requests a revision to clarify that APS does not intend to use gravel at drainage crossings. APS requests the following change: “Graveling dirt access roads is not anticipated or proposed, although it may be necessary where access roads intersect paved roads to prevent track out.””	Section 2.4.1.3 was revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.21	GEN	” The following statement in Section 2.4.1.3, page 2-9, reads as though BLM is authorizing a separate ROW for the permanent construction access road: “A 14-foot wide permanent access route parallel to the transmission line within the ROW would provide construction access, and would require authorization on associated BLM lands.” APS requests that this sentence be restated to clarify that the 14–foot-wide permanent access road would be within the granted ROW and when temporary construction access or access for operations and maintenance outside of the ROW is necessary, authorization would be required on associated BLM lands.”	Section 2.4.1.3 was revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.22	GEN	” In Section 2.4.1.3, page 2-9, in the second sentence of the second paragraph, APS requests that the phrase “avoid impacts” be replaced with “minimize impacts.” In Section 2.4.1.3, page 2-9, and throughout the document, the text refers to the “underlying land owner” (or “land owner”), when it would be more appropriate to reference an agency with jurisdiction. Specifically, the statement that “APS would coordinate with ADOT…” should be modified to explain that paved acceleration and deceleration lanes would be removed if required by the entity with jurisdiction over the roadway. APS recommends that the use of the term “land owner” be reviewed throughout the document.”	Section 2.4.1.3 was revised per the comment. Text revisions made document-wide to address change from land owner to appropriate land management agency.
Richard Stuhan, Siting Consultant Senior, APS	888.23	GEN	” In Section 2.4.2.1, page 2-10, APS requests the statement regarding the transportation of structure components and associated hardware be clarified to include transportation by truck or other means of transportation, including helicopter use.”	Section 2.4.2.1 was revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.24	GEN	” In Section 2.4.2.1, page 2-10, the sequence of activities described in the first paragraph is a typical sequence; therefore, APS requests that the word “would” be changed to “could.””	Text in Section 2.4.2.1 revised per comment to “…would typically…”
Richard Stuhan, Siting Consultant Senior, APS	888.25	GEN	” In Section 2.4.2.2, page 2-12, the document states that “water would be applied on a continuous basis in areas of construction and at least three to four times daily in non-active construction zones for dust control purposes.” However, the objectives of dust control may be met through a variety of measures, as contemplated by the mitigation measures included in Section 2.9.1. APS requests that Section 2.4.2.2 be revised to be consistent with Section 2.9.1.”	This statement was removed from the subsection “Construction Utilities” as the next subsection “Dust Control” fully addresses how dust control would be accomplished for the project.
Richard Stuhan, Siting Consultant Senior, APS	888.26	GEN	” In Section 2.4.2.4, page 2-13, the Stormwater/Wastewater Management and Erosion Control text describes wastewater would be generated during construction from concrete loads emptied from trucks and from washing construction equipment, which if required, would be performed offsite. The subsequent sentence indicates that wastewater would be managed such that there would be no discharge offsite, which appears contradictory. This comment is intended to clarify that APS would manage wastewater from concrete truck washdown and cleaning of construction equipment such that there would be no discharge to surface waters.”	Section 2.4.2.4 was revised per the comment.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Richard Stuhan, Siting Consultant Senior, APS	888.27	GEN	” In Section 2.4.2.4, page 2-15, the description of native plant protection appears to be broader than what is explained elsewhere in the document. This comment intends to clarify that APS would comply with the Arizona Native Plant Law and, to the extent feasible, minimize the destruction of protected native plants during Project construction.”	No revisions were necessary in this section.
Richard Stuhan, Siting Consultant Senior, APS	888.28	GEN	” In Section 2.4.2.4, page 2-15, the text states that nursery locations would be identified for salvaged plants. This comment intends to clarify that APS may relocate salvaged plants to the edge of the ROW as an option to establishing nursery locations.”	Section 2.4.2.4 was revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.29	GEN	” In Section 2.4.2.5, page 2-16, the description of lattice structure assembly does not include the potential for assembling the structures at each site. This comment is intended to clarify that APS may either assemble the structures in sections in the laydown area then transport the sections for assembly at the structures sites or APS may do the full structure assembly at each structure site.”	Section 2.4.2.5 was revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.30	VEG	” In Section 2.4.3.4, pages 2-21 and 2-22, APS suggests noting that the vegetation clearance distances may change from those listed in the Draft EIS in tables 2.4-5 and 2.4-6. Over the life of the Project, APS will follow current industry standards and regulatory requirements. APS is required to control vegetation in proximity to high-voltage transmission lines in conformance with NESC and NERC (FAC 003) Standards. Additionally, the information regarding the desired outcome of Integrated Vegetation Management is provided in Section 4.13.2.1, and need not be repeated within the description of the proposed action.”	Section 2.4.3.4 was revised per the comment to indicate APS would follow industry standards. The desired outcome of Integrated Vegetation Management was the subject of other comments and was revised accordingly, and left in place.
Richard Stuhan, Siting Consultant Senior, APS	888.31	OHV	” In Section 2.8, Table 2.8-1, and the supporting information from Section 4.9.2.2, page 4-79, indicates that The Boulders Staging Area access road would be crossed by the ROW; this crossing is not depicted on Figures 3.9-2 and 3.9-3, which indicates the access road likely would not be crossed by the ROW. Therefore, APS requests that this section be revised to indicate that no impacts would occur during construction to the Boulders Staging Area access road during construction. Similarly, the impacts noted in Table 2.8-1 should be revised accordingly.”	Table 2.8-1 and Section 4.9.2.2 were revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.32	CUL	” In Section 2.8, page 2-68, APS suggests correcting the site counts in Table 2.8-1. The second line (Prehistoric) under Proposed Action column should be 5 (not 4) and the entry in the Alternative 2 column should be 4 (not 3).”	The corridor width inventoried for cultural resources was 400 feet, while the corridor width analyzed in the EIS is 200 feet. The number of sites presented in the EIS are those within the 200 foot wide corridor.
Richard Stuhan, Siting Consultant Senior, APS	888.33	GEN	” In Section 2.8, page 2-76, Table 2.8-1 presents indicators to compare the impacts of the alternatives. It seems unclear why, under the Land Use and Range resources, the indicator “Compliance with Land Management Plans and Zoning” does not include information related to the local land use plans of Buckeye, Surprise, and/or Peoria, yet such plans are included as an indicator under visual resources. APS requests that these analyses be revisited and that the document articulate consistency or conflict with the respective jurisdictional plans for land use and visual resources for each alternative.	Table 2.8-1 and Section 4.6 were revised per the comment.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Richard Stuhan, Siting Consultant Senior, APS	888.34	CUL	” In Section 2.9.2, page 2.81, to be consistent with discussion of best management practices in Appendix 2A, APS requests the second sentence of third paragraph on page 2-81 be revised to read: “Procedures for scientific investigations, reporting, and long-term preservation of data and collections would be specified in a Historic Properties Treatment Plan implemented in accordance with the terms of a Section 106 Memorandum of Agreement (MOA) executed to address any identified adverse effect.” (MOA should be added to the list of acronyms.)”	Section 2.9.2 and Acronyms in Section 6.2 revised per comment.
Richard Stuhan, Siting Consultant Senior, APS	888.35	CUL	” In Section 2.9.2, page 2-81, APS requests that the second paragraph be revised as follows: “Under the Proposed Action, Alternative 1, or Alternative 2, spanning the historic properties near the Agua Fria River may not be possible. If not, supplemental Class III cultural resource survey would be conducted so that options for avoiding impacts by shifting the alignment to the east could be considered.””	Additional cultural resource inventories and a more detailed siting analysis was conducted between the DEIS and FEIS. Applicable information from these additional inventories and clarification on avoidance of historic properties near the Aqua Fria River has been added to the EIS in Section 4.3.2.1.
Richard Stuhan, Siting Consultant Senior, APS	888.36	M&M	” In Sections 2.9.6 and 4.7.3.1, pages 2-82 and 4-72, under the General heading, second paragraph, the mitigation lacks measurable definition; APS suggests mitigation be consistent with the State approval of the Project. As required by the Arizona Corporation Commission (ACC), through the conditions of a Certificate of Environmental Compatibility (CEC), APS shall make every reasonable effort to identify and correct, on a case-specific basis, all complaints of interference with radio or television signals from operation of the transmission line and related facilities addressed in the CEC. APS shall maintain written records for a period of five years of all complaints of radio or television interference attributable to operation, together with the corrective action taken in response to each complaint. All complaints shall be recorded to include notations on the corrective action taken. Complaints not leading to a specific action or for which there was no resolution shall be noted and explained.”	Sections 2.9.6 and 4.7.3.1 were revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.37	GEN	” In Section 2.9.6, pages 2-82 (and also in the Executive Summary) and subsequent impact analyses in Section 4.7, the text reads that construction activities would be confined to the hours of 7:00 am to 7:00 pm as typical or normal working hours. While this generally may be the case, it may not apply to all construction activities, which could begin earlier, particularly when sunrise occurs prior to 7:00 am. Typical summer hours could be 5:00 am to 4:00 pm while typical winter hours could be 6:00 a.m. to 5:00 pm. This comment is intended to clarify that APS would restrict noise-generating construction activities, such as the use of heavy equipment or helicopters, within 0.5-mile of residential areas to the hours of 7:00 am and 7:00 pm.	Sections 2.9.6, the Executive Summary, and Section 4.7 were revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.38	GEN	” With reference to Section 2.9.6, page 2-82, APS suggests clarifying that the contractor safety requirements in the appendix of the POD would typically be employed during construction and APS employees receive annual health and safety training, which includes fire prevention and response. These requirements, together with information described in the Health and Safety Plan (and Emergency Response Plan) will cover fire protection efforts associated with this Project. That is, project-specific fire prevention and response training is not proposed. APS expects to provide updated information in the H&S Plan as part of the POD.”	Section 2.9.6 was revised per the comment.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Richard Stuhan, Siting Consultant Senior, APS	888.39	AR	” In Sections 2.9.8 and 4.9.3, pages 2-83 and 4-88, the DEIS suggests that no use of any singletrack routes would occur for construction. While generally, this is APS‟ intent, there may be a need to cross one or more single-track routes for construction access, depending on final design and mitigation requirements associated with other resources. In the event a single-track route is crossed, APS would provide barriers, such as fencing, to restrict access to the ROW from the single-track route (similar to what would be implemented at four-wheel OHV access route crossings), to the extent practicable.	Other comments were received regarding impacts to single-track OHV routes. BLM will work with APS to prepare a Construction Access Plan, which will definitively identify construction access routes to assure that there would be no loss of single-track trail, as indicated in the EIS.
Richard Stuhan, Siting Consultant Senior, APS	888.40	GEN	” In Section 2.9.12 and 4.13.3.1 the text states: “The area around transmission line structures and abandoned access roads would be reclaimed according to BLM stipulations in the ROW grant.” The statements would be clarified with a reference to the reclamation plan. APS suggests the following clarification: “Areas of temporary disturbance, identified in Table 2.4-4, would be reclaimed according to BLM stipulations in the ROW grant and the final reclamation plan.””	Section 2.9.12 was revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.41	M&M	” In Sections 2.9.12 and 4.13.3.1, the text identifies restoration mitigation for areas of significant ground disturbance or recontouring. APS does not anticipate significant ground disturbance as a result of the proposed action and requests deleting the term “significant for ground disturbance”, and if appropriate, reference the reclamation plan.”	Sections 2.9.12 and 4.13.3.1 were revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.42	M&M	” In Sections 2.9.12 and 4.13.3.1, the text states: “…all existing roads would be left in a condition equal to or better than their condition prior to the construction of the transmission line.” APS requests revising this sentence to clarify „equal or better condition‟ and the criteria by which existing roads could be subject to this mitigation.”	Sections 2.9.12 and 4.13.3.1 were revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.43	M&M	” In Sections 2.9.12 and 4.13.3.1, the text state: “Species protected by the Arizona Native Plant Law would be relocated and transplanted.” APS understands that there are several levels of protection under the Arizona Native Plant Law, not all levels provide the same types of protection. The Arizona Native Plant Law does not prohibit the destruction or require relocation and transplantation of protected plant species. As written, this mitigation could require more relocation and transplantation of protected plant species than required by law. APS requests clarification that the intent is for APS to abide by the Arizona Native Plant law.”	Sections 2.9.12 and 4.13.3.1 were revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.44	M&M	” In Sections 2.9.15 and 4.16.3, the text requires monitoring of ground clearing/disturbing activities that could affect special status species. It is unclear what criteria would be used to identify where monitoring would occur, what the monitoring program would include, and where along the proposed ROW such monitoring is warranted. This should be clarified.”	Sections 2.9.15 and 4.16.3 were revised per this comment and others regarding the ambiguity of monitoring requirements.
Richard Stuhan, Siting Consultant Senior, APS	888.45	M&M	” In Sections 2.9.15 and 4.16.3.1, the text requires compensation for desert tortoise habitat loss. APS requests that it be clarified that this would apply only to tortoise habitat loss on BLM administered land. In addition, other mitigation measures referencing the Final Report on Compensation for the Desert Tortoise or Desert Tortoise Habitat Management on Public Lands in Arizona apply only to BLM-administered land.”	Sections 2.9.15 and 4.16.3.1 were revised per the comment.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Richard Stuhan, Siting Consultant Senior, APS	888.46	M&M	” Sections 2.9.15 and 4.16.3.1 specify the speed limit of 20 mph as mitigation to reduce potential impacts on desert tortoise. Rather than installing signs, APS suggests this mitigation be achieved through a Best Management Practice that prescribes speed limits for all unpaved construction and maintenances access roads.”	BLM would designate the centerline access as an administrative route and would enforce the 20 mph speed limit; as such the route would need to be signed during construction.
Richard Stuhan, Siting Consultant Senior, APS	888.47	GEN	” In Section 2.9.13, page 2-87, last paragraph, implies that individual landowners will be consulted to arrive at an amicable decision regarding design and infrastructure type. Rather, APS will consult land-managing agencies in the decision making process.”	Section 2.9.13 was revised per the comment. Text revisions made document-wide to address change from land owner to appropriate land management agency.
Richard Stuhan, Siting Consultant Senior, APS	888.48	CUL	” In Section 3.3.5.1, page 3-27, to reflect accurate site count, APS requests revising the second paragraph to read: “A total of 27 archaeological and historical sites have been identified along the Proposed Action route (Table 3.3-1). The sites included seven prehistoric sites, 18 historic sites, and two sites with both prehistoric and historic components. Six of the sites are on public land managed by BLM, 18 are on state land, one is on privately owned land and two overlap state and privately owned land.””	The corridor width inventoried for cultural resources was 400 feet, while the corridor width analyzed in the EIS is 200 feet. The number of sites presented in the EIS are those within the 200 foot wide corridor.
Richard Stuhan, Siting Consultant Senior, APS	888.49	CUL	” In Section 3.3.5.1, page 3-27, to reflect BLM and SHPO consultation, APS requests revising the second paragraph to read: “BLM, in consultation with the SHPO, determined that 10 of these sites are eligible for the National Register. Five of the six prehistoric sites and the two prehistoric components of the multicomponent sites AZ T:3:350(ASM) and AZ T:3:351(ASM) were determined eligible under Criterion D for their potential to yield important information about the prehistoric occupation of the region…….. Four other Hohokam sites along the Agua Fria River, including sites AZ T:3:11 and 353(ASM) and multi-component sites AZ T:3:350 and 351(ASM) also might have buried features or could be temporary, limited activity sites.”	The text was revised to include, “BLM, in consultation with the SHPO, determined…” but the site counts reflects the 200 foot wide corridor not the 400 foot wide inventory corridor, so the number of sites stayed the same.
Richard Stuhan, Siting Consultant Senior, APS	888.50	CUL	” In Section 3.3.5.1, page 3-28, APS requests revising: third line of third paragraph to indicate correct date as follows: “ . . .developed between 1912 (not 1921) and 1955 . . .” paragraph 4 to read: “The other 15 historical sites are evaluated as ineligible for the National Register. Five of those sites are dumps or scatters of domestic trash with no features other than artifact concentrations: AZ T:2:145, 146, and 147(ASM), AZ T:3:347(ASM), and AZ T:6:137(ASM)…” paragraph 5 to read: “Seven of the remaining historic resources are roads. No artifacts have been recorded along three of those: AZ T:3:200, 201, and 256(ASM)…” paragraph 6 to read: “. . . to postdate 1940. Site AZ T:6:138(ASM) has a shallow pit that might reflect prospecting activity. Further study of these sites ”	Text change was made to third line of third paragraph to correct 1921 to 1912 date. The corridor width inventoried for cultural resources was 400 feet, while the corridor width analyzed in the EIS is 200 feet. The number of sites presented in the EIS are those within the 200 foot wide corridor. Therefore the next three changes will not be made.
Richard Stuhan, Siting Consultant Senior, APS	888.51	CUL	” In Section 3.3.5.2, page 3.29, APS suggests correcting site count in paragraph 3 from “17 sites” to “21 sites.”	The corridor width inventoried for cultural resources was 400 feet, while the corridor width analyzed in the EIS is 200 feet. The number of sites presented in the EIS are those within the 200 foot wide corridor.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Richard Stuhan, Siting Consultant Senior, APS	888.52	CUL	” In Section 3.3.5.3, page 3-29, APS suggests correcting the site count in the first sentence of paragraph 5 from “Nineteen” to “Twenty-three.”	The corridor width inventoried for cultural resources was 400 feet, while the corridor width analyzed in the EIS is 200 feet. The number of sites presented in the EIS are those within the 200 foot wide corridor.
Richard Stuhan, Siting Consultant Senior, APS	888.53	CUL	” In Section 3.3.5.4, page 3-29, APS suggests correcting the site counts in second sentence of paragraph 7 from “Sixteen archaeological” to “Eighteen archaeological.”	The corridor width inventoried for cultural resources was 400 feet, while the corridor width analyzed in the EIS is 200 feet. The number of sites presented in the EIS are those within the 200 foot wide corridor.
Richard Stuhan, Siting Consultant Senior, APS	888.54	CUL	” In Section 3.3.5.4, page 3-30, APS suggests correcting the site counts in paragraph 2 to read: “All 14 historical resources . . . The other 11 historical resources are evaluated as ineligible . . . Those ineligible historic resources included six dumps or scatters of circa 1920s to 1960s domestic trash: AZ T:2:144, 145, 146, 147, and 148(ASM), and AZ T:6:137(ASM). Four of the other ineligible historic resources are minor local roads, AZ T:3:200, 201, 344, and 353(ASM)………………………………………………………………………………………………………………………………….. and cross the Alternative 3 route. Site AZ T:6:138(ASM) has a shallow pit that may be related to prospecting.”	The corridor width inventoried for cultural resources was 400 feet, while the corridor width analyzed in the EIS is 200 feet. The number of sites presented in the EIS are those within the 200 foot wide corridor.
Richard Stuhan, Siting Consultant Senior, APS	888.55	CUL	” In Table 3.3-1, page 3-31 and 3-32, the table is missing entries for four sites: Lake Pleasant Road/AZ T:3:256(ASM), Historic Road, Not eligible, along Proposed Action, Alt. 1, and Alt. 2 routes AZ T:3:353(ASM)/AZ T:3:30(ASU), Prehistoric habitation site, Eligible, along Proposed Action, Alt. 1, and Alt. 2 routes AZ T:6:137(ASM), Historic Trash, Not eligible, along Proposed Action, Alt.1, Alt. 2, and Alt 3 routes AZ T:6:138(ASM), Historic, possible prospecting site, Not Eligible, along Proposed Action, Alt. 1, Alt. 2, and Alt. 3 routes The totals for the columns should be Proposed Action – 27 (not 23), Alt. 1 – 28, Alt 2 – 20, and Alt 3 –18. Suggest revising note: These 21 sites are along the Alternative 1 route outside the 0.5-mile.”	The corridor width inventoried for cultural resources was 400 feet, while the corridor width analyzed in the EIS is 200 feet. The number of sites presented in the EIS are those within the 200 foot wide corridor.
Richard Stuhan, Siting Consultant Senior, APS	888.56	LU	” In Section 3.6.3.2, page 2-98, additional information should be included regarding the ACC Biennial Transmission Assessment (BTA) within the paragraph related to the ACC. The BTA process requires transmission providers to file a 10-Year Plan every January 31 with the ACC. Biennially, the ACC assesses the 10-Year Plans to determine the adequacy of the existing and planned facilities in the state to reliably meet the present and future energy needs of the state. The analysis is guided by Arizona best engineering practices coupled with the use of regional and national reliability council criteria and standards. The Sun Valley to Morgan Project has been included in the Company‟s 10-Year Plan filings and has been found to be beneficial to the reliability needs of the Project area.	Sections 3.6.3.2 and 4.6.2.1 were revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.57	LU	” In Section 3.6.3.4, page 3-56, the description of future utilities includes only a 230kV line from the future Sun Valley Substation to the future Trilby Wash Substation. This comment is intended to clarify that APS has planned and completed the permitting for a new 500kV transmission line from the Palo Verde Generating Station area to the future Sun Valley Substation (through the future Delaney Substation), which provides one potential source of power that would be carried through the connection between the Sun Valley and Morgan substations.”	Section 3.6.3.4 and Appendix 4B (if necessary) were revised per the comment.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Richard Stuhan, Siting Consultant Senior, APS	888.58	LU	” In Section 3.6.2.7, Table 3.7-7 does not include the units from the distance from structure, which should be noted as feet based on the information included in APS’ CEC Application (URS 2008). In addition, APS requests that the values for the distance from the structure be corrected to be consistent with the referenced document, and read as follows (which would represent the worst-case scenario at the edge of right-of-way for the transmission lines): (see table in letter)	Section 3.6.2.7, Table 3.7-7 revised per the comment and information provided.
Richard Stuhan, Siting Consultant Senior, APS	888.59	M&M	“In Chapter 4, as well as other areas of the document where mitigation measures are described, APS requests that the document clearly state which mitigation measures apply to BLM administered land, State Trust land, and private land, as requirements may vary based on jurisdiction.”	Section 2.9 and mitigation sections in Chapter 4 revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.60	CUL	” In Section 4.3.2.1, page 4-25, the text requires that construction work within a 50-meter area cease if unanticipated cultural resource discoveries occur. The term “area” is unclear. This comment is intended to clarify that APS would cease construction activities within 50 feet from the boundary of the discovery.”	Section 4.3.2.1 revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.61	CUL	” In Section 4.3.2.1, page 4-25, the cultural resource Monitoring and Discovery Plan discussed in the second paragraph of the Construction section is not tied to a MOA intended to address a Section 106 adverse effect. The last sentence of the section indicates that BLM might not make a determination of an adverse effect (and therefore an MOA would not be needed) if all National Register eligible properties can be avoided by construction activities. APS requests that the paragraph be revised to read: “All sites would be avoided where practicable by Project design, such as locating transmission towers, access routes, and other facilities outside site boundaries; or by using helicopters for construction in sensitive areas. If avoidance is not feasible due to technical issues or resource conflicts, BLM would develop a MOA to address the adverse effect. Regardless of whether an MOA is required, BLM and ASLD would work with APS to develop a Discovery Plan, and if warranted a Monitoring Plan, which would define procedures for evaluating and treating discoveries of unrecorded cultural resources or recognition of unanticipated adverse effects.” Start new paragraph with “[Ten] National Register-eligible cultural resource sites. ”	Section 4.3.2.1, revised per the comment. The corridor width inventoried for cultural resources was 400 feet, while the corridor width analyzed in the EIS is 200 feet. The number of sites presented in the EIS are those within the 200 foot wide corridor, thus no changes will be made.
Richard Stuhan, Siting Consultant Senior, APS	888.62	CUL	” In Section 4.3.2.1, page 4-25, APS requests the site count be changed from “Nine” to “Ten” in the last complete sentence.”	The corridor width inventoried for cultural resources was 400 feet, while the corridor width analyzed in the EIS is 200 feet. The number of sites presented in the EIS are those within the 200 foot wide corridor.
Richard Stuhan, Siting Consultant Senior, APS	888.63	CUL	” In Section 4.3.2.1, page 4-26, APS requests the site count be changed from “four” to “five” in the first sentence as follows: “ . . . and the Beardsley Canal), five prehistoric sites (AZ T:3:10(ASM), AZ T:3:11(ASM), AZ T:3:325(ASM), AZ T:3:348(ASM), and AZ T:3:353(ASM), and . . .”	The corridor width inventoried for cultural resources was 400 feet, while the corridor width analyzed in the EIS is 200 feet. The number of sites presented in the EIS are those within the 200 foot wide corridor.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Richard Stuhan, Siting Consultant Senior, APS	888.64	CUL	” In Section 4.3.2.1, page 4-26, a cultural resource Monitoring and Discovery Plan discussed in the second paragraph of the Operations, Maintenance, and Decommissioning section is not tied to a MOA intended to address a Section 106 adverse effect. The last paragraph of the previous section indicates that BLM might not make a determination of adverse effect (and therefore an MOA would not be needed) if all National Register eligible properties can be avoided by construction activities. APS requests revising the paragraph to be consistent with Section 2.9.2 to read: . . . Procedures would be implemented, as warranted, to ensure that if any National Register-eligible properties in the ROW are designated for avoidance by construction activities, and that they would not be inadvertently damaged during operation, maintenance, and decommissioning of the project. If BLM and ASLD conclude that National Register-eligible properties might be threatened, BLM and ASLD would work with APS to implement measures to avoid adverse impacts. BLM and/or ASLD staff, perhaps assisted by Arizona Site Stewards program volunteers, would conduct long-term monitoring as warranted. Long-term monitoring on privately owned land would be at the discretion of the land owner.”	Section 4.3.2.1, revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.65	CUL	” In Section 4.3.2.3, page 4-29, APS requests the site count be changed from “Eight” to “Nine” in the first sentence to read: “Nine National Register-eligible cultural resources . . .””	The corridor width inventoried for cultural resources was 400 feet, while the corridor width analyzed in the EIS is 200 feet. The number of sites presented in the EIS are those within the 200 foot wide corridor.
Richard Stuhan, Siting Consultant Senior, APS	888.66	CUL	” In Section 4.3.3, page 4-31, to clarify responsibility for implementing long-term Monitoring and Discovery Plan, APS requests that the last sentence in first paragraph be revised to read: “BLM and/or ASLD staff, possibly assisted by Arizona Site Steward Program volunteers, would monitor and document the condition of National Register-eligible properties within the ROW as warranted.” APS also requests that second paragraph be revised to read: “If not, supplemental Class III cultural resource survey would be conducted so that options for avoiding impacts by shifting the alignment to the east could be considered.””	Section 4.3.3, revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.67	CUL	” In Section 4.3.3, page 4-32, second sentence of second paragraph, APS requests that the terms “Data Recovery Plan” be replaced with “Historic Properties Treatment Plan” so that it is consistent with discussion of best management practices in Appendix 2A.”	Section 4.3.3, revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.68	AR	” In Section 4.6.1, page 4-52, the analysis states that the permanent access road would be constructed within the ROW along the centerline of the ROW. This comment is intended to clarify that APS will locate the permanent access road within the transmission line ROW to the extent practicable, the road may not be along the centerline; however, the road will be located where appropriate with consideration of engineering and environmental constraints, and associated mitigation.”	Section 2.4.1.3 was revised to indicate that the permanent access road within the ROW would be referred to in the document as the centerline access. Section 4.6.1 revised to refer to centerline access, but not indicate that the road would be built along the centerline. Centerline Access was added to the document glossary, with a definition indicating that the route may not exactly follow the centerline of the transmission line, but provide access within the ROW.
Richard Stuhan, Siting Consultant Senior, APS	888.69	OHV	” In Section 4.9.2.2, page 4-79, the analysis indicates that The Boulders Staging Area access road would be crossed by the ROW; this crossing is not depicted on Figures 3.9-2 and 3.9-3, which indicates the access road likely would not be crossed by the ROW. APS requests that this sentence be clarified to indicate no impacts would occur during construction to the Boulders Staging Area access road during construction. Similarly, the impacts noted in Table 2.8-1 should be revised accordingly.”	Table 2.8-1 and Section 4.9.2.2 were revised per the comment.

COMMENTOR NAME

COMMENT ID NO.

COMMENT TYPE

COMMENT

RESPONSE TO COMMENT

Richard Stuhan, Siting Consultant Senior, APS

888.70

SOC

“In Section 4.10.2.2, page 4-99, the analysis states, “Offsetting the loss of future development would be the lease revenue that APS pays annually on State Trust lands to the ASLD.” This comment is to clarify that APS anticipates making a one-time rental payment to ASLD for the entire lease term, assumed to be perpetual. The total costs presented in Table 4.10-1, which were provided by APS, include this lease payment.”

Section 4.10.2.2 was revised to indicate that the payment to ASLD by APS would be lump sum and is included in the ROW acquisition costs in Table 4.10-1.

Richard Stuhan, Siting Consultant Senior, APS

888.71

TRANS

” In Sections 4.12.2.1 and 4.12.3, the analysis suggests a long-term adverse effect on the Thunder Ridge Airpark, and that mitigation would include installing spherical markers and lighting as directed under FAA Advisory Circular AC 70/7460-1K. APS believes that the use of spherical line marker balls would not be required and requests that the analysis reflect that the use of marker balls would be strictly voluntary. APS has completed an independent review of this analysis with the following assumptions and conclusions.

Assumptions:

The closest portion of the proposed 165-foot Above Ground Level (AGL) transmission line, its associated support pole structures, guys and right-of way that are proposed to be in proximity to the Thunder Ridge Airpark would be situated approximately 0.33 miles to the east and would run generally parallel to the Airpark‟s single 2,600-foot paved north/south runway and its extended runway centerline. Beginning at a point northeast of the Airpark, the proposed transmission line would transition from a south-to-north direction to a west-to-east direction.
The Airpark is listed as “Private Use” facility that is currently limited to Visual approach and departure operations on Runway 17/35. It is assumed that aeronautical activity at the Airpark is limited to Visual operations that are typically generated by single-and/or light multi-engine propeller-driven general aviation aircraft along the extended Runway 17/35 centerline. Visual operations to and from Runway 17 currently utilize a published standard left-hand Airport Traffic Pattern. Visual operations to and from Runway 35 currently utilize a published nonstandard right- hand Airport Traffic Pattern. The maximum AGL height of the Downwind leg of each Airport Traffic Pattern (left or right) may possibly range from 800 to 1,000 feet.

Conclusions:

Visual arrival operations to Runway 17 (from the north to the south) would be executed using a standard left-hand Base-to-Final turn that would be begin well north and east of the portion of the transmission line in proximity to the Airpark. It is assumed that pilots transition from the Base to Final descending approach segments of the Visual approach north of the Airpark at AGL heights ranging from 500 feet to 250 feet. Utilizing a standard 3- degree 1- to 0.75-mile Final approach glide path, Visual approach operations would not be adversely affected by the proximity or height of the transmission line located to the east. When executing Visual departure operations from Runway 17 (from the north to the south), it is assumed that pilots will utilize a standard left-hand climbing Crosswind turn to the east that would most likely be initiated at AGL heights ranging from 500 to 800 feet that would be greater than the proposed 165-foot AGL height of the transmission line and support towers.

Section 4.12.3 was revised per the comment to indicate that APS would use spherical markers and lighting on a strictly voluntary basis.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Richard Stuhan, Siting Consultant Senior, APS	888.71 (Continued)	TRANS	Visual arrival operations to Runway 35 (from the south to the north) would be executed using a nonstandard right-hand Base-to-Final turn that would begin well east of south-to north portion of the transmission line. It is assumed that when aircraft pilots transition from the Base to Final approach segments directly over the north/south segment of the transmission line, the descending aircraft will be at AGL heights ranging from 500 feet to 250 feet. Utilizing a standard 3-degree 1- to 0.75-mile Final approach glide path, Visual approach operations would not be adversely affected by the proximity or height of the transmission line located to the east. When executing Visual departure operations from Runway 35 (from the south to the north), it is assumed that pilots will utilize a nonstandard right hand climbing Crosswind turn to the east the will begin well north of the west-to- east portion of the transmission line at AGL heights ranging from 500 to 800 feet. The runway, because it is designated as a “Private Use” facility, does not have FAA prescribed trapezoidal CFR Part 77 Civil Airport Imaginary 20:1 Approach Surfaces that would, if applicable, extend outward and upward from each end of the associated Primary Surface 200 feet beyond of each end of the runway. The use of spherical line marker balls would not be required, and should be considered strictly voluntary.
Richard Stuhan, Siting Consultant Senior, APS	888.72	VEG	” With regard to Section 4.13.2.1, pages 4-131 and 4-132, APS will be submitting to the BLM a revised Vegetation Management Program (VMP), which is intended to replace Appendix 2B and will be incorporated in APS‟ Plan of Development for the Project.”	Appendix 2B was replaced with the new Vegetation Management Program, and Section 4.13.2.1 was revised accordingly.
Richard Stuhan, Siting Consultant Senior, APS	888.73	CUL	” In Section 4.18.2, page 4-202, APS requests revising Section 4.18.2 to acknowledge that long term productivity of cultural resources is a possibility. The revised statement could read: “The Project could result in physical destruction of National Register-eligible archaeological sites, which would be short-term use. Although impacts would be mitigated by recovery and preservation of artifacts and information, the long-term productivity of the archaeological record would be reduced because the sites would not be available for future investigations, when research methods and procedures might be improved.””	Section 4.18.2 was revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.74	CUL	” In Section 4.19.4, page 4-214, APS requests the site count in second paragraph be changed from “up to six to nine sites” to” up to 10 sites…””	The corridor width inventoried for cultural resources was 400 feet, while the corridor width analyzed in the EIS is 200 feet. The number of sites presented in the EIS are those within the 200 foot wide corridor.
Richard Stuhan, Siting Consultant Senior, APS	888.75	GEN	” In Section 5.5, page 5-8, and in Chapter 6, page 608, APS notes that the title of BLM Manual 8120 is more correctly referred to as Tribal Consultation under Cultural Resource Authorities.”	Section 5.5 and Chapter 6 (which is Chapter 7 in the Final EIS) revised per the comment.
Richard Stuhan, Siting Consultant Senior, APS	888.76	CUL	” APS requests the second sentence under Cultural Resources section of Appendix 2A be revised to read: If needed, the Memorandum of Agreement would be on file….. Similarly, the use of “Programmatic Agreement” in the parenthetical sentence at the end of the section on page 2A-5 is contradictory. APS request that entire sentence be deleted.”	Appendix 2A revised per the comment.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Richard Stuhan, Siting Consultant Senior, APS	888.77	CUL	” The third, fourth, and fifth bullets under Cultural Resources section of Appendix 2A refer to a Monitoring Plan and a Discovery Plan as separate documents, but sixth bullet refers to a Monitoring and Discovery Plan. APS requests that the bullets be revised to read “Monitoring and Discovery Plan” for consistency.”	Appendix 2A revised per the comment.
Bob Barrett, Mayor, City of Peoria	889.1	SUP PA	“As we have stated consistently throughout this process, Peoria strongly believes that the transmission line route adopted by the State of Arizona and sought by APS now (as reflected in the APS Application) is the appropriate location for the power lines through and adjacent to Peoria.”	Statement of preference.
Bob Barrett, Mayor, City of Peoria	889.2	GEN	“The data compiled and analyzed in the DEIS supports the Proposed Action, which is incorporated, embodied, and reflected in the BLM Preferred Alternative.”	The comment does not raise questions about the analysis or provide additional information for consideration.
Bob Barrett, Mayor, City of Peoria	889.3	NEPA	“The DEIS makes clear that Alternative 2, Alternative 3, and the No Action Alternative fail to meet NEPA’s statutory standards. All three alternatives merit rejection in the EIS.”	The NEPA requires analysis of a reasonable range of alternatives. Section 2.2 explains that “reasonable,” is usually defined as alternatives that are realistic (not speculative), technologically and economically feasible, and that respond to the purpose of and need for the Project. Alternatives 2 and 3 were found to meet these criteria. The NEPA requires analysis of a No Action alternative as a basis to compare the Action Alternatives against.
Bob Barrett, Mayor, City of Peoria	889.4	NEPA	“No other reasonable alternatives exist to be analyzed in the EIS. BLM can proceed expeditiously to complete the EIS based on the alternatives already studied.”	Statement of preference.
Bob Barrett, Mayor, City of Peoria	889.5	GEN	“Finally, Peoria would like to summarize the crucial factors that support the conclusion in the DEIS that the Proposed Action is the BLM Preferred Alternative: The State of Arizona approved the power line route. Broad community consensus exists for expedited approval of the APS Application. The power line route complies with all existing plans at the local, county, and state levels.	Statement of opinion.
Bob Barrett, Mayor, City of Peoria	889.6	SOC	“The power lines will provide economic benefits to the region through construction, increased renewable energy transmission, and residential, commercial, and industrial growth (leading to jobs and revenue from fees and taxes).”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential job creation.
Bob Barrett, Mayor, City of Peoria	889.7	LU	“The power line route is entirely within BLM’s existing designated Transportation Corridor for the future freeway development of State Route 74, and BLM policies (as well as the City’s) support co- location of rights-of-way within designated corridors.”	The combined environmental impact of the Proposed Project with development of the transportation corridor is analyzed in Section 4.19 of the EIS.
Bob Barrett, Mayor, City of Peoria	889.8	LU	“In its RMP amendment which culminated in 2008-2009, BLM did not consider designating a utility corridor along State Route 7 4, so this is the first time that BLM has conducted a substantive analysis of such a corridor in this location.”	Statement of opinion.
Bob Barrett, Mayor, City of Peoria	889.9	VIS	“The visual impacts of the power line route can be mitigated fully.”	Section 4.14.5 indicates that the visual impacts of the transmission line cannot be fully mitigated and that there would be unavoidable adverse impacts to visual resources.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Bob Barrett, Mayor, City of Peoria	889.10	LU	“Nearly two-thirds of the entire power line route is on State lands. Placing a portion of the route on BLM lands is consistent and compatible with the national federal energy priority established by the President, Congress, and various federal Departments, including Energy, Homeland Security, and Interior (including specifically BLM) to promote renewable energy development and protection of the nation’s energy grid.”	Table 1.5-2 lists the federal laws, statutes, regulations, and executive orders with which the Proposed Action and all Action Alternatives must conform.
Bob Barrett, Mayor, City of Peoria	889.11	NEPA	“As explained in the DEIS, Alternatives 2 and 3, as well as the No Action Alternative, each fail to satisfy these above factors.”	Table 1.5-2 lists the federal laws, statutes, regulations, and executive orders with which the Proposed Action and all Action Alternatives must conform.
Bob Barrett, Mayor, City of Peoria	889.12	LU	“Page ES-1. The City previously provided comments (4/3/12 and 7/3/12) on the Preliminary Draft EIS (“PDEIS”), in which we explained that we thought the draft failed to acknowledge and address the significance of the Proposed Action route falling entirely within an existing SR74 Transportation Corridor in the RMP. We suggest that the SR74 Transportation Corridor be explained in the opening paragraph of the Executive Summary. At a minimum, it should be explained on page ES-3 in Section ES.3.2, as part of the second paragraph that discusses co-locating transportation and utility corridors.”	Comment noted. While the transportation corridor is germane to the EIS analysis, it is not of a level of significance to merit explanation in the opening sentences of the document. Text was added to Section 3.6.3.4 and it was presented in Section 3.12.2.1.
Bob Barrett, Mayor, City of Peoria	889.13	GEN	“Page ES-3. As we noted in our comments on the PDEIS, the draft includes this phrase: “the appropriateness of amending the RMP in such a way that would benefit developers.” The City does not understand this phrase in the context of the section and is requesting its removal.”	Table 1.8-2 provides a summary of issues from Scoping, which includes the Economic Strategies Workshop. The issue referenced by this comment is that the process of amending the RMP should consider whether or not it is appropriate to amend the RMP in such a way that would benefit developers. This was an issue identified from scoping, thus is included in this specific section. The referenced text is stating the issue as it was raised during scoping.
Bob Barrett, Mayor, City of Peoria	889.14	LU	Page ES-11. As we noted in our comments on the PDEIS, the City is confused by the attempted conclusion in the second paragraph in this Section. The first paragraph discusses BLM lands and concludes: “Because the portion of BLM lands where the land use would be affected by the Proposed Action or any of the Action Alternative routes would be relatively small, overall impacts to BLM-administered land use would be minor, regardless of alternative.” The second paragraph discusses all other lands – which includes State Lands and lands owned by many different private parties. Then BLM attempts to conclude: “Because the portion of private and State Trust lands where the land use would be affected by the Proposed Action or any of the Action Alternative routes would be relatively small, overall impacts to land use would be minor, regardless of alternative.” This seems to be comparing apples to oranges – BLM as a single landowner as compared all other landowners combined. To be accurate, shouldn’t the comparison be to individual landowners, rather than grouping them all together into a single “land use impact”? A single landowner affected by an alternative could well have a major impact on its property. It is far too simplistic and just not accurate to claim that such impacts would be minor. A quick review of the proceedings before the Arizona Power Plant & Line Sitting Committee in 2008, as well as the voluminous information submitted to BLM during Public Scoping and now on the DEIS, will make clear how large the negative impacts would be of Alternatives 2 and 3 on certain individual landowners.	The land use analysis analyzes the impacts to land use rather than impacts to land owners or economic impacts in particular. Impacts to land owners and economics are addressed under socioeconomics in Section 4.10. The NEPA standard of “reasonably foreseeable” applies to cumulative impacts.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Bob Barrett, Mayor, City of Peoria	889.14 (Continued)	LU	The NEPA standard is “reasonably forseeable development.” The DEIS does not appear to apply this standard. Also, under NEPA “current” is defined as a 0-10-year period. The DEIS does not appear to apply this standard.”
Bob Barrett, Mayor, City of Peoria	889.15	LU	“Page ES-20. The data and analysis in the DEIS supports BLM’s conclusion that the Proposed Action should be the Agency Preferred Alternative. However, BLM’s proposal to amend the RMP in three respects is not clearly supported. (1) Single-use utility corridor (2) Multi-use utility corridor south of State Route 74. Note that “multi-use utility corridor” is not defined in the Glossary, Section 6.3 (see pages 6-47 and 6- 48). The types of acceptable uses do not appear to be described in the DEIS. Does BLM have any pending applications for use of this land? If not, what uses does BLM envision for this “multi-use utility corridor”? (3) VRM classification change from III to IV	BLM finds that the RMP requires amendment to comply with the FLPMA as explained in Section 1.3.2. The definition of multiuse corridor has been added to the Glossary in the EIS.
Bob Barrett, Mayor, City of Peoria	889.16	GEN	“Page 1-1. Statement in the middle of the second full paragraph that the transmission lines would be on “mostly non-public lands” is incorrect. Please correct to read “mostly public lands.””	Table 4.6-2 indicates that out of the approximate 38 miles in length of the Proposed Action, approximately 4.4 miles would cross private property and 24.7 miles would cross State Trust lands. The State does not consider trust lands to be public lands in the sense the BLM-managed federal lands are public lands.
Bob Barrett, Mayor, City of Peoria	889.17	GEN	“Page 1-2. As we noted in our comments on the PDEIS, we are not sure whether the intent is to relate this sentence (“In addition, the . . .) to the prior sentence (“The Director . . .). Is the intent to state that the Director’s dismissal of the protest letter to Peoria in February of 2009 included reference to the 2009 Record of Decision (ROD)? We do not recall such a reference. Also, we are not sure why this sentence about the 2009 ROD is included, but it appears that the draft omits any reference to the March 2003 letter from APS to BLM in which APS identified SR 74 as a “Preliminary Utility Corridor.””	There is no relationship between the last sentence of the referenced paragraph under Section 1.1.2 (“In addition…) and the City of Peoria’s protest, or the director’s dismissal of the protest. The sentence provides additional information about the ROD.
Bob Barrett, Mayor, City of Peoria	889.18	LU	“Page 2-36 and 2-37. The description of the Vistancia and Lake Pleasant Heights master-planned developments as being “proposed” does not adequately describe the zoning entitlement for the properties. Both developments have full zoning entitlements and executed Development Agreements with the City of Peoria.”	In terms of route overview and screening in Section 2.7.4.3, the technical status of the master planned developments is incidental and does not affect the outcome of the screening. Section 2.7.4.3 was revised to eliminate the term proposed and now reads, “including the Vistancia (final plat) and Lake Pleasant Heights (preliminary platting stage) developments.“ Sections 3.10 and 4.10 (as appropriate) have been revised to clarify the status of the developments, to indicate that they are in various stages of planning for development.
Bob Barrett, Mayor, City of Peoria	889.19	SOC	“Page 2-71. Under “Socioeconomics and Environmental Justice, Effects Common to All Action Alternatives – Social Values, Population and Housing,” the statement is: “No effect on housing in the Study Area expected.” This appears to be inconsistent with other descriptions in the DEIS of planned residential development that is “reasonably foreseeable” in this area (for example, Pages 4,208, 4-226 and 4-230 and 4- 231). Clearly, Alternatives 2 and 3 will have significant impacts on current and reasonably foreseeable housing. Please correct this inconsistency in the DEIS.	This statement is taken from Table 2.8-1, which summarizes impacts in Chapter 4. This text refers to Section 4.10.2.1, which indicates that construction workers would have no effect on housing. Table 2.8-1 was updated to make this clarification.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Bob Barrett, Mayor, City of Peoria	889.20	SOC	“Page 2-72. Under “Socioeconomics and Environmental Justice, Socioeconomics – Market Value Effects, Developed Property Values and Undeveloped Land Values,” long statements are made under Alternatives 2 and 3. The City is not clear how BLM is defining the terms “Developed Property” and “Undeveloped Land.” In other portions the DEIS describes planned residential development that is “reasonably foreseeable” in this area (for example, Pages 4-208, 4-226 and 4- 230 and 4-231). Why then is this reasonably foreseeable development not included as “Developed Property” for purposes of the analysis summarized in this Table? None of these terms appear to be defined in the Glossary (Sec. 6.3). Also, the statements in this portion seem limited to impacts only within the 200-feet of the actual power line right-of-way, although other portions of the DEIS acknowledge both direct and indirect effects/impacts (those terms are defined in the Glossary). This inconsistency is confusing and should be resolved.”	Section 4.10.1.1 contains the first reference to the terms “Developed Property” and “Undeveloped Land” and that section has been revised to contain definitions for these terms as they are used in the analysis. The terms have also been added to the glossary in Section 6.3. The NEPA standard of “reasonably foreseeable” applies to cumulative impacts. The master planned communities are not present in the existing condition. Any impacts of the transmission line on the communities would be cumulative as additional development (other impacts) would be required before the communities would be affected. Section 4.10 has been revised in response to this and other comments to clarify impacts to properties that would adjoin the proposed ROW rather than within 200 feet.
Bob Barrett, Mayor, City of Peoria	889.21	SOC	“Page 2-72. Under “Socioeconomics and Environmental Justice, Socioeconomics – Market Value Effects, Property Taxes,” the statement under Alternatives 2 and 3 is: “New tax revenues would be the same as P.A.” This is incorrect. If the power lines were constructed within Alt. 2, the City of Peoria’s Saddleback Heights Planned Community District would need to be amended to reflect the direct and indirect impacts caused by the lines, resulting in fewer homes, which would cause the amount of property tax collected to decrease. Likewise, if the lines were constructed within Alt. 3, both the City’s Saddleback Heights PCD, Lake Pleasant Heights PCD and Vistancia PCD would need to be amended, resulting in a significantly larger decrease in property taxes collected.	The effects described in this comment are cumulative effects, as another action (construction of the community) would have to occur in order for the outcome to occur. Cumulative impacts to Socioeconomics are addressed in Section 4.19.11; however, this section has been revised to include impact to tax revenue.
Bob Barrett, Mayor, City of Peoria	889.22	LU	“Page 2-76. In Linear KOP for Alternative 2, it incorrectly indicates conformance to the Peoria General Plan. The General Plan Land Use Map illustrates the proposed action. A corridor south of SR-74 is not compliant with the General Plan.”	Text in Table 2.8-1 under the heading of the Linear KOP does not reference the General Plan.
Bob Barrett, Mayor, City of Peoria	889.23	LU	“Page 2-76. Under “Visual Resources, Complies with Town of Buckeye and City of Peoria General Plan,” Alt. 2 is answered “Yes.” This is incorrect. The correct answer is “No – City of Peoria.” Alt. 2 does not comply with the Peoria General Plan. The Proposed Action complies with the Peoria General Plan.”	Table 2.8-1 and Section 4.14 revised per the comment.
Bob Barrett, Mayor, City of Peoria	889.24	GEN	“Page 3-55. The heading to this Section is “Future Planned Land Use” but then the first words under the heading read “Future and planned land uses.” (emphasis added). “Future” is not defined in the Glossary (Sec. 6.3). Isn’t “current” defined under NEPA as within 0-10 years? Why is “future” used in the DEIS to describe any activity occurring after the day the sentence is written? We recommend removing the word “future” in this Section.”	The first sentence after the heading 3.6.3.4 was edited to remove the word “and.” NEPA does not define the term “current.” Generally speaking, direct impacts are analyzed considering the existing conditions present at the time of analysis. Impacts to future land use (land use in a general, not specific sense) are considered an indirect effect as they occur at a different time. Impacts to specific future land uses, such as master planned communities, are cumulative impacts, as the communities themselves have to be developed before there is an impact.
Bob Barrett, Mayor, City of Peoria	889.25	GEN	“Page 3-55. The listed and existing ‘Estates at Lakeside’ entitlement and planned community was amended in January/2013 and is now known as ‘Cholla Hills’ and should be reflected accordingly on all exhibits.”	Changes were made document-wide to address the comment.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Bob Barrett, Mayor, City of Peoria	889.26	OREC	“Page 3-90. In the introductory paragraphs of this Section, the EIS should make clear that any recreation activities that would occur within the Proposed Action area also would be occurring within the existing SR-74 Transportation Corridor. By designating the Transportation Corridor in its RMP Amendments acknowledged that the State of Arizona plans to develop SR-74 into a ten-lane freeway. This fact is addressed repeatedly in the DEIS (for example, Pages 4-223, 4-224, 4-227, 4- 229 (referred to as “reasonably forseeable”), and 4-232). It will help a reader understand the impacts described later in the DEIS if the Transportation Corridor is noted in this Section.”	While the RMP designates a transportation corridor on BLM-managed public lands in the referenced area along SR 74, the corridor designation itself does not change the existing land use. Additional environmental analysis (in compliance with NEPA) would be required prior to any future transportation development; therefore, changes to recreation are not necessarily a foregone conclusion just because the RMP designated a transportation corridor. Designation of a transportation corridor simply means the RMP envisions the possibility of that use in that area, and future proposals for development of transportation in that area would not require an RMP amendment.
Bob Barrett, Mayor, City of Peoria	889.27	OHV	“Page 3-94 thru 3-97. In the introductory paragraphs of this Section, the EIS should make clear that any OHV recreation activities that would occur within the Proposed Action area also would be occurring within the existing SR-74 Transportation Corridor. By designating the Transportation Corridor in its RMP Amendments acknowledged that the State of Arizona plans to develop SR-74 into a ten-lane freeway. This fact is addressed repeatedly in the DEIS (for example, Pages 4-223, 4- 224, 4-227, 4-229 (referred to as “reasonably forseeable”), and 4-232). It will help a reader understand the impacts described later in the DEIS if the Transportation Corridor is noted in this Section.”	While the RMP designates a transportation corridor on BLM-managed public lands in the referenced area along SR 74, the corridor designation itself does not change the existing land use. Additional environmental analysis (in compliance with NEPA) would be required prior to any future transportation development; therefore, changes to recreation are not necessarily a foregone conclusion just because the RMP designated a transportation corridor. Designation of a transportation corridor simply means the RMP envisions the possibility of that use in that area, and future proposals for development of transportation in that area would not require an RMP amendment.
Bob Barrett, Mayor, City of Peoria	889.28	LU	“Page 3-124. In the “SR74” section of this Table, the DEIS describes the dramatic increase in traffic that will occur as SR-74 is developed as a ten-lane freeway. An increase in average daily traffic trips from just over 5,000 to well over 25,000 (500%) projected for 2031 is certainly significant. Many other Sections of the DEIS seem to be written without this important fact in mind. Repeated use of terms such as “rural” to describe the area fail to acknowledge and consider that this area is about to become urbanized. A gentleman who provided oral public comments at the Phoenix public meeting on December 13, 2012 understood this perfectly, as he described how electric lines that were constructed in one-time “rural” Peoria now blend into what is now a fully “urban” environment. At most, the BLM lands north of SR-74 may remain “rural,” but the area immediately surrounding SR- 74 and most everything south of that area is in the process of becoming urban. Or, as stated in Section 4.19.2 on page 4-208 of the DEIS, “urban development is encroaching.” This, as some portions of the DEIS make clear, is a “reasonably foreseeable” fact. It would help the analysis provided in the DEIS if this fact was used consistently through all portions of the document.”	The last column on the right in Table 3.12-1, 2031 projected average daily trips, and text referencing future transportation projects in the paragraph following the table were removed. The same information is provided, and cumulative effects are appropriately analyzed in Section 4.19.13.
Bob Barrett, Mayor, City of Peoria	889.29	TRANS	“Page 3-125. The language is inconsistent with other portions of the DEIS when it refers to the “potential” development of the SR-74 freeway. For example, on Page 4-229 the freeway is identified as “reasonably foreseeable.” The text and Figure 3.12-1 refer to the future regional highways in the study area. However, the future Phase 4 extension of Loop 303 to the north is not shown. This project includes extending SR74 due east along the Joy Ranch Road alignment – immediately east of the study area.”	Text referencing future transportation projects in the paragraph following Table 3.12-1 was removed. The same information is provided, and cumulative effects are appropriately analyzed in Section 4.19.13. Figure 3.12-1 was not intended to show future transportation projects.
Bob Barrett, Mayor, City of Peoria	889.30	VIS	“Page 3-148. Linear KOP description at top of page, 2nd line: Peoria does not believe that it is correct to identify the portion of SR74 in the study area as has having “recognized scenic values”. This implies the area may have some formal scenic designation, which is incorrect. Peoria recommends removing “recognized” from the sentence.”	The referenced text was revised per the comment.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Bob Barrett, Mayor, City of Peoria	889.31	VIS	“Page 3-185. Peoria is concerned about the use of KOP 15 as it is located of the lower end of an approach to a bridge over the CAP. The view point to the north is partially obscured by the fill material for the approach. A better view point would have been at the CAP canal or towards the northern boundary of the Vistancia development.”	At the time of the analysis, the location of KOP 15 represented the views of the northernmost residences of Vistancia.
Bob Barrett, Mayor, City of Peoria	889.32	GEN	“Page 3-161. We are not sure why the statement “Since the 1960’s, treated effluent from metropolitan Phoenix has been delivered through some canals” needs to be included. Peoria is not aware of any irrigation canals in the study area that are delivering treated effluent and would recommend removing this sentence.”	The referenced text was deleted per the comment.
Bob Barrett, Mayor, City of Peoria	889.33	LU	“Page 4-3 and 4-4. Peoria is not clear as to the purpose of this Section concerning the “Draft RMPA.” What is the “Draft” that is being referred to? The language then describes that the RMP “may be amended” and follows with three options. None of the options acknowledges the existing SR-74 Transportation Corridor. None of the options identifies the potential conversion of the Transportation Corridor into a Multi-Use Corridor. Why do the “options” fail to include the use of a Multi-Use Corridor? As Peoria has pointed out to BLM in the past, Map 9, the “Utility & Transportation Corridors and Communications Sites” map in the RMP only identifies “Multi-use Corridors” and “Transportation Corridors.” “Single-use utility corridors” and “multiuse utility corridors” are not identified. The Multi-use Corridor identified on RMP Map 9 for the electric transmission lines on BLM lands that parallel portions of I-17 north of Phoenix seems to be a pretty close model for the Proposed Action along SR-74. Peoria does not understand why it is not identified as a potential option. As Peoria previously noted in its May 25, 2011 public scoping comments: “In one of the confusing aspects of the RMP, BLM stated in its presentation during the public scoping meetings that the RMP does not include any utility only corridor designations (as opposed to” transportation only” corridors). However, BLM also stated that there is a “utility corridor” along the CAP canal. When BLM pointed out this “utility corridor” on a map, the key to the map only identified “multi-use corridors” and “transportation corridors.” The term “utility corridor” does not appear anywhere on the BLM map.”	Section 4.1.3 is reiterating the decisions that the BLM needs to make, as outlined in Table 1.5-1. The process the BLM goes through to amend an RMP involves issuing a “draft” amendment, which is in conjunction with a draft EIS. At the final EIS stage, the RMP amendment would be “proposed”, and the Record of Decision contains the final RMP amendment decision. The designation of the transportation corridor along SR 74 in the RMP is irrelevant to the analysis of a utility or multiuse corridor. While the RMP designates a transportation corridor on BLM-managed public lands in the referenced area along SR 74, the corridor designation itself does not change the existing land use. Additional environmental analysis (in compliance with NEPA) would be required prior to any future transportation development. Designation of a transportation corridor simply means the RMP envisions the possibility of that use in that area, and future proposals for development of transportation in that area would not require an RMP amendment. Alternative 1 analyzed in the EIS contains provision for designation of a multiuse corridor that would take in the existing transportation corridor, and as described in Section 2.5.1, would allow for co-location of future utilities. The fact that the RMP does not reference utility corridors does not prohibit the BLM from consideration of or establishing a single-use utility corridor in conjunction with appropriate NEPA analysis.
Bob Barrett, Mayor, City of Peoria	889.34	OREC	“Page 4-78 and 4-79. This section should also point out the long-term recreation access north of SR74 will be limited in the future when the roadway is turned into a 10-lane freeway.”	While the RMP designates a transportation corridor on BLM-managed public lands in the referenced area along SR 74, the corridor designation itself does not change the existing land use. Additional environmental analysis (in compliance with NEPA) would be required prior to any future transportation development; therefore, changes to recreation are not necessarily a foregone conclusion just because the RMP designated a transportation corridor. Designation of a transportation corridor simply means the RMP envisions the possibility of that use in that area, and future proposals for development of transportation in that area would not require an RMP amendment.
Bob Barrett, Mayor, City of Peoria	889.35	OREC	“Page 4-78 and 4-79. Following the completion of powerlines, the recreation areas could also be impacted by future development of private or State Trust Lands located north of SR74.”	Section 4.19.10 analyzes the cumulative impacts to recreation from the transmission line in conjunction with reasonably foreseeable projects, including development of surrounding lands.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Bob Barrett, Mayor, City of Peoria	889.36	OREC	” BLM must consider the evaluation of Recreational Impacts relative to the City of Peoria approved General Plan. As represented in the City of Peoria’s voter approved General Plan, the recreational uses south of SR 74 would be severely impacted by the placement of the power line south of SR 74 due to the highly integrated natural land uses on the south side of SR 74 involving schools, parks, commercial, residential and open space. By comparison, the relative recreational impact of locating the power line north of SR 74 would be much less than the location of the power lines south of SR 74.”	Section 4.19.10 analyzes the cumulative impacts to recreation from the transmission line in conjunction with reasonably foreseeable projects, including development of recreational resources south of SR 74.
Bob Barrett, Mayor, City of Peoria	889.37	LU	“Page 4-96. The City is not clear how BLM is defining the term “Affected Acreage” for purposes of this Table. The amounts listed for Saddleback Heights seem limited to impacts only within the 200-feet of the actual power line right-of-way, although other portions of the DEIS acknowledge both direct and indirect effects/impacts (for example, Pages 4- 230 and 4-231). This inconsistency is confusing and should be resolved.”	Table 4.10-3 is now Table 4.10-4, and has been revised to distinguish between the acreages within and outside the ROW, and within 200 feet of the transmission line. As a result of additions to the literature review, Sections 3.10 and 4.10 now clarify that impacts to property values can occur for private property adjoining the ROW; however, the EIS continues to quantify a range of impacts to private property within 200 feet of the transmission line, per findings of the literature review.
Bob Barrett, Mayor, City of Peoria	889.38	SOC	“Page 4-97. The statement that the annual property tax revenue generated by private properties crossed by the Proposed Action is $289,151 appears to Peoria to be far too low. Does this number include the “reasonably foreseeable” development discussed elsewhere in the DEIS?”	The impact analysis in Section 4.10.2.2 is analyzing the impact to the affected environment described in Chapter 3. The effects described in this comment are cumulative effects, as another action (construction of the community) would have to occur in order for the outcome (higher tax revenue) to occur. Cumulative impacts to Socioeconomics are addressed in Section 4.19.11; however, this section has been revised to include impacts to tax revenue.
Bob Barrett, Mayor, City of Peoria	889.39	OREC	“Page 4-99 and 100. As Peoria noted in an earlier comment, this Section on “Effects on Recreation” should make clear that any recreation activities that would occur within the Proposed Action area also would be occurring within the existing SR- 74 Transportation Corridor. By designating the Transportation Corridor in its RMP Amendments acknowledged that the State of Arizona plans to develop SR-74 into a ten-lane freeway. This fact is addressed repeatedly in the DEIS (for example, Pages 4-223, 4-224, 4- 227, 4-229 (referred to as “reasonably forseeable”), and 4- 232).”	While the RMP designates a transportation corridor on BLM-managed public lands in the referenced area along SR 74, the corridor designation itself does not change the existing land use. Additional environmental analysis (in compliance with NEPA) would be required prior to any future transportation development; therefore, changes to recreation are not necessarily a foregone conclusion just because the RMP designated a transportation corridor. Designation of a transportation corridor simply means the RMP envisions the possibility of that use in that area, and future proposals for development of transportation in that area would not require an RMP amendment.
Bob Barrett, Mayor, City of Peoria	889.40	VIS	“Page 4-101. The note that area residents, commuters and recreationists have “rural scenic expectation” of SR74, does not take into account that ADOT is planned to turn this into a 10-lane freeway.”	The impact analysis contained in Section 4.10 analyzes the impacts to the affected environment described in Chapter 3. Expansion of SR 74 is a reasonably foreseeable project, which is analyzed in conjunction with other projects in Section 4.19, Cumulative Impacts.
Bob Barrett, Mayor, City of Peoria	889.41	LU	“Page 4-103. If the power lines were constructed within Alt. 2, the City of Peoria’s Saddleback Heights Planned Community District would need to be amended to reflect the direct and indirect impacts caused by the lines, resulting in fewer homes, which would reduce property values and cause the amount of property tax collected to decrease.”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values and tax revenue. The impact analysis in Section 4.10.2.2 is analyzing the impact to the affected environment described in Chapter 3. The effects described in this comment are cumulative effects, as another action (construction of the community) would have to occur in order for the outcome (higher tax revenue) to occur. Cumulative impacts to Socioeconomics are addressed in Section 4.19.11; however, this section has been revised to include impacts to tax revenue.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Bob Barrett, Mayor, City of Peoria	889.42	LU	“Page 4-106 thru 4-108. Likewise, if the lines were constructed within Alt. 3, both the City’s Saddleback Heights PCD, Vistancia PCD and Lake Pleasant Heights PCD would need to be amended, resulting in a significantly larger decrease in property values and property taxes collected. The ”Affected Acreage” in the Table is way too low, when considering both indirect and direct impacts/effects (as considered in other portions of the DEIS – for example, Pages 4-226 and 4- 230 and 4-231).”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values and tax revenue. The impact analysis in Section 4.10.2.2 is analyzing the impact to the affected environment described in Chapter 3. The effects described in this comment are cumulative effects, as another action (construction of the community) would have to occur in order for the outcome (higher tax revenue) to occur. Cumulative impacts to Socioeconomics are addressed in Section 4.19.11; however, this section has been revised to include impacts to tax revenue.
Bob Barrett, Mayor, City of Peoria	889.43	LU	“Page 4-125. It should be described here that in a December 7, 2010 letter Arizona Department of Transportation Deputy State Engineer Robert Samour stated to BLM that “the Department does not see any conflicts with the placement of this line adjacent to our future right-of-way easement needs as identified in the ADOT SR 74 Feasibility Report, Right-of- Way Preservation.”	Inclusion of the ADOT comments is appropriate. Impacts of the transmission line on the future widening of SR 74 would be indirect impacts. The text of Section 4.12 was revised per the comment.
Bob Barrett, Mayor, City of Peoria	889.44	LU	“Page 4-137. The first full paragraph, discussing Maricopa County’s “scenic corridors.” Please add the following two sentences to provide more complete information: “Maricopa County has stated in writing that it is not opposed to the State-certificated route contained in the APS Application. In addition, evidence introduced at the State line siting hearings, including the “Maricopa County State Route 74 Scenic Corridor Guidelines” and the “Maricopa County Zoning Ordinance, Chapter 10, Section 1009, Hwy 74 Scenic Corridor,” made clear that even within the County scenic corridor, high-voltage transmission lines are contemplated and authorized.” Peoria previously provided to BLM both documents cited in the above sentence.”	The referenced text is describing the methodology used for visual analysis; the recommended text is not appropriate in this section. Section 3.14.1 contains the suggested information. Upon further review it was determined that neither the Proposed Action nor any of the Action Alternatives would place the transmission line within the SR 74 scenic corridor outside the jurisdiction of the City of Peoria. This was also clarified in Section 4.14.2.1.
Bob Barrett, Mayor, City of Peoria	889.45	VIS	“Page 4-162. Peoria is concerned about the use of KOP 15 as it is located of the lower end of a approach to a bridge over the CAP. The view point to the north is partially obscured by the fill material for the approach. A better view point would have been at the CAP canal or towards the northern boundary of the Vistancia development.”	At the time of the analysis, the location of KOP 15 represented the views of the northernmost residences of Vistancia.
Bob Barrett, Mayor, City of Peoria	889.46	OHV	“Page 4-203. While new access road for the power lines could lead to an increase in user-defined OHV trails, this section seems overly negative. It would seem that BLM and the OHV users could work together to revise the managed trail system north of SR74 to account for the disturbance. The DEIS and related public process has the appearance of an undue emphasis on recreational uses over other factors required by law to be considered. One example of this is the legal-size, two-sided project flyer handout provided by BLM at the public comment meetings — why is “The Boulders Staging Area” the only non-project item identified on the first-page map? It makes no sense to identify it by name but omit the existing Transportation Corridor, the future freeway corridor along State Route 74, the reasonably forseeable master-planned Peoria developments in the vicinity, etc. (Peoria contrasts this with Figure 3.9-1, a map of “Recreation Opportunity Spectrum” which seems to appropriately identify the location of the “Boulders OHV Staging Area”).”	The existing conditions of the BLM-managed lands north of SR 74 is that the area is maintained focusing on OHV recreation. The majority of the area is managed under the ROS class Semi-Primitive Motorized (Figure 3.9-1). The addition of the transmission line to this environment has the potential to significantly impact the existing recreational use and experience, and the BLM’s management of the area. With regard to the flyer handout, the Boulders Staging Area is an existing improvement on BLM- managed public lands north of SR 74 that facilitates OHV use of the area that would potentially be affected. The suggested addition of the reasonably foreseeable master-planned communities would not be appropriate as they are not part of the existing condition.
Bob Barrett, Mayor, City of Peoria	889.47	GEN	“Page 4-208. In this Section, the DEIS succinctly summarizes what is discussed in some other portions of the document – that the residential, commercial, transportation and other development in the Project Area is “reasonably foreseeable.” This conclusion, as noted in other Comments from Peoria herein, should be consistently applied throughout the DEIS.”	The title of Section 4.19 is Cumulative Impacts. The referenced text on page 4-208 is under the heading of 4.19.2, Past, Present, and Reasonably Foreseeable Actions. These actions, in conjunction with the proposed transmission line would lead to cumulative impacts. Discussion of cumulative impacts under Direct and Indirect impacts in other areas of the EIS would be inappropriate.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Bob Barrett, Mayor, City of Peoria	889.48	TRANS	“Page 4–210. As Peoria noted in our comments on the PDEIS, prior to the discussion of the Maricopa County “scenic guidelines,” BLM should explain that because SR 74 is a State highway, the State of Arizona could have designated it as a State Scenic Road under State law. State highways all across Arizona have been designated as “State Scenic Roads.” In its comments to BLM during the public scoping period in May of 2011, the City attached the then-current “Arizona Scenic Roads & Federal Lands” map produced by the Arizona Department of Transportation. The Scenic Roads map also is available on the ADOT website. SR 74 is not (and never has been) designated as a “State Scenic Road.” In fact, a witness testified at the Arizona Line Siting hearing that she inquired with ADOT about SR 74, and ADOT informed her that a member of the public in the past had submitted a request to designate SR 74 as a State Scenic Road and after review the State determined that the road was not worthy of such a designation. These facts should be included and emphasized in this section, prior to any mention of the Maricopa County documents.”	The fact that the State could have designated SR 74 a State Scenic Road is not relevant to the analysis in the EIS. SR 74 was designated as a Maricopa County Scenic Highway, but as stated in the EIS, according to the City of Peoria, the SR 74 Scenic Corridor within their jurisdiction does not apply.
Bob Barrett, Mayor, City of Peoria	889.49	LU	“Page 4-216. In the final paragraph on page 4-216, a correct reference is made to the City of Peoria 2010 General Plan. The DEIS will be more accurate and comprehensive if it also includes the specific land use plans adopted by the Peoria City Council as Planned Community Districts for Vistancia, Saddleback Heights, and Lake Pleasant Heights. Peoria previously provided the three PCD’s to BLM in Peoria’s May 25, 2011 public scoping comments.	Community development for the communities of Vistancia, Saddleback Heights, and Lake Pleasant Heights are referenced in Appendix 4B, which provides brief descriptions of the past, present, and reasonably foreseeable projects in the cumulative impact areas.
Bob Barrett, Mayor, City of Peoria	889.50	GEN	“Page 4-217. The listed and existing ‘Estates at Lakeside’ entitlement and planned community was amended in January/2013 and is now known as ‘Cholla Hills’ and should be reflected accordingly throughout the document.”	The revision recommended by the comment was implemented document-wide.
Bob Barrett, Mayor, City of Peoria	889.51	GEN	“Page 4-217 and 4-218. Throughout this Section the DEIS discusses the reasonably forseeable developments by writing each sentence to read that the development “would” do certain things (“change,” “transform,” “include,” etc.). To accurately reflect the conclusion that each development is reasonably foreseeable, the sentences will be more accurate if “would” is changed” to “will” in each case.”	The EIS consistently refers to any future actions’ impact as “would” document-wide as this is the proper analysis for a NEPA document as the future actions are not guaranteed to occur.
Bob Barrett, Mayor, City of Peoria	889.52	LU	“App 4B. Under City of Peoria “Community Development”, various projects are identified – some within and outside the Study Area. West Wing Mountain is specifically emphasized (outside Study Area) as a project that includes the dedication of hillside areas for open space. It would be more relevant to emphasize Saddleback Hts, Lake Pleasant Hts and Vistancia as fully-entitled projects that include specific requirements for public open space dedication. Also, as noted herein, just a reminder that ‘Estates at Lakeside’ is now ‘Cholla Hills.’”	The developments listed in Appendix 4B are all within the various Cumulative Impact Areas, but not all are necessarily within the 2-mile Buffer Cumulative impact Area. Therefore, no developments were removed from Appendix 4B. References to the “Estates at Lakeside” have been revised to “Cholla Hills.”
Bob Barrett, Mayor, City of Peoria	889.53	GEN	“App 4B. Saddleback Heights location descriptor should be just “City of Peoria” as it is wholly within the city boundaries. Additionally, project type should be planned community or some other descriptor that recognizes it is not just housing but other land uses including commercial, mixed-use and employment. Also, acreage is 5,296.”	Appendix 4B was revised per the comment.
Bob Barrett, Mayor, City of Peoria	889.54	GEN	“App 4B. Under Vistancia, remove “(aka Entrada) There is no other recognized name for Vistancia. Entrada is simply one of many subdivisions within Vistancia.”	Appendix 4B was revised per the comment.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Bob Barrett, Mayor, City of Peoria	889.55	GEN	“App 4B. Need to include row(s) and descriptors for the Lake Pleasant Heights and Cholla Hills (formerly Estates at Lakeside) master-planned communities. Peoria Staff will provide copies of these plans.”	Appendix 4B was revised per the comment.
Bob Barrett, Mayor, City of Peoria	889.56	GEN	“App 4B. As we noted in our comments on the PDEIS, under “Brief Description,” in the second paragraph, second and third sentences, statements are made concerning Maricopa County’s “scenic overlay.” As explained in the comment for Page 4-210 above, facts concerning the State’s decision to not designate SR 74 as a “State Scenic Road” should be included and emphasized in this section, prior to any mention of the Maricopa County overlay.”	The fact that the State could have designated SR 74 a State Scenic Road is not relevant to the analysis in the EIS.
Bob Barrett, Mayor, City of Peoria	889.57	LU	“Figure 1. Peoria does not believe that it is relevant to the analysis in the DEIS to include the Maricopa County “Scenic Corridor” designation which lies outside of the land sought by APS in the Proposed Action. It also is irrelevant because highvoltage electric transmission lines, such as those in this project, are authorized within the Maricopa County Scenic Corridor. We recommend deleting the “Scenic Corridor” on the Project Location Map. If BLM insists on including it, then at a minimum the key on the map should clarify that it is a “Maricopa County Scenic Corridor.” It is important to be consistent with other terms used in the map key, which identify the “ACC Certificated Corridor” and the “BLM Transportation Corridor.” As currently written, the map key is inconsistent.”	The comment correctly points out that no portion of the proposed project would be within the Maricopa County SR 74 scenic corridor. The scenic corridor was removed from all EIS maps and added to Figure 3.14-4, as the scenic corridors are discussed in conjunction with visual resources.
Bob Barrett, Mayor, City of Peoria	889.58	TRANS	” It would be useful to show the planned regional Arterial roadway network within the limits of the study area on Figure 3.12-1.”	Figure 3.12-1 shows the existing roadway system as discussed in Chapter 3, Affected Environment, which discusses the existing conditions in the Study Area.
Bob Barrett, Mayor, City of Peoria	889.59	GEN	“App 4B. Brief Description, add “ Peoria has a Municipal Planning area of approximately 233 square miles and a population of 154,065 (2010 Census)””	Appendix 4B was revised per the comment, except the citation was revised to City of Peoria 2013.
Bob Barrett, Mayor, City of Peoria	889.60	GEN	“App 4B. Please revise the description for the Quintero development to include that it is entitled for 283 dwelling units and covers 828 acres.”	Appendix 4B was revised per the comment.
Bob Barrett, Mayor, City of Peoria	889.61	GEN	“App 4B. Pleas add “Westland Park” to the list of park sites. The site contains 2 shaded playgrounds, basketball court, 2 ramadas and multi-purpose turf area. The site is 5 acres.”	Appendix 4B was revised per the comment.
Bob Barrett, Mayor, City of Peoria	889.62	GEN	“Figure 3.6-2. Future Planned Land Use map The map does not correctly reflect Peoria’s currently adopted Land Use plan, The land plan for Saddleback Heights was changed in December 2011. The land plan for Lake Pleasant Heights was changed in December 2012, The Estate at Lakeside development was changed to ‘Cholla Hills” in January 2013 to and expanded to include an additional 244 acre parcel to the northwest of the original development.”	Figure 3.6-2 was revised per the comment.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Bob Barrett, Mayor, City of Peoria	889.63	GEN	“Figure 3.6-3. The information for “Existing Mines Sites” is confusing. It appears to include both currently active mines, existing mining claims with no activity and historic mining sites/claims. Peoria recently updated our land use map (Per SB1598) to include all of the currently recognized permitted (per Office of State Mining Inspector) mines. It is recommended that this data be displayed and identified with more clarity.”	The information in question that was used for this Figure is from a reliable source. After some additional research and investigation on the data used, it was determined that updating the suggested data specifically for the City of Peoria was unnecessary to appropriately analyze the impacts to mining sites in the project area.
Bob Barrett, Mayor, City of Peoria	889.64	WTR	“Figure 3.15-2. Groundwater Resources map This map des not currently identify the “Municipal Water service Area for Peoria. It also appears to incorrectly identify the Phoenix Municipal Water service Area as extending south of SR74 to the Morgan Substation, which is inside Peoria’s city limits. Peoria will provide a current map of water service areas.”	Figure 3.15-2 was revised per the comment.
Dr. Jack S. Tuber	915		Not a comment letter (his comment letter is 267)
Dale & Sheryll Chicoine	929.1	SUP PA	“We wish to register our support for the proposed APS power lines north of SR74.”	Statement of preference.
Ron & Barb Guagenti	951.1	OPP ALT3	” From an aesthetic / visual perspective … UNsightly transmission powerlines on Carefree Highway will actually be visible from our development, and from many parts of the Vistancia community, and we find this totally unacceptable;”	Statement of preference. Section 4.14 provides relevant Figures, simulations, and an analysis of impacts to visual resources from various locations in the project area.
Ron & Barb Guagenti	951.2	LU	“Location / Site … because SR74 is already a designated ‘transportation corridor’, it would be much more logical to construct this powerline system on the land adjacent to an existing roadway system. Furthermore, because ADOT has scheduled SR74 to be expanded into a 6-lane highway in the near future, APS has the required 1,000 ft. ‘right-of-way’ property available to install the powerlines adjacent to this aforementioned ‘right-of-way’”	Statement of preference. APS has proposed to site the transmission line largely within the transportation corridor on BLM land along SR 74.
Ron & Barb Guagenti	951.3	GEN	“Environmentally … building a high-powered transmission line through an undisturbed, ‘native’, & pristine desert ecosystem is illogical, & would be environmentally unreasonable & irresponsible. The alternative proposal will guarantee protection of the native desert for generations to come.”	The EIS evaluates the environmental reasonableness of the alternatives considered, as well as those eliminated from detailed analysis, in Chapter 2.
Walter “Skip” Zahlmann	952	UC	Content unrelated to analysis
Gary Torhjelm, Manager, Group Three Properties and Noranda Properties Inc.	953.1	SUP PA	“We support the approval of the Proposed Action as the Agency Preferred Alternative…”	Statement of preference.
Gary Torhjelm, Manager, Group Three Properties and Noranda Properties Inc.	953.2	OPP ALTS	“We…oppose Alternative 2, Alternative 3 and the Sub Alternative, which place the transmission line in closer proximity to existing and soon-to-be-built and occupied homes.”	Statement of preference.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Gary Torhjelm, Manager, Group Three Properties and Noranda Properties Inc.	953.3	LU	“The Proposed action as the Agency Preferred Alternative is the only route consistent with local governmental plans including the City of Peoria, and is the expectation of the Federal Land Policy and Management Act…”	The comment correctly states that the Proposed Action is the only route consistent with local governmental plans. FLPMA says “…the Secretary shall, to the extent he finds practical, …assure that consideration is given to those State, local, and tribal plans that are germane in the development of land use plans for public lands; assist in resolving, to the extent practical, inconsistencies between Federal and non-Federal Governmental plans….” “Land use plans of the Secretary under this section shall be consistent with State and local plans to the maximum extent he finds consistent with Federal law and the purposes of this Act.”
Gary Torhjelm, Manager, Group Three Properties and Noranda Properties Inc.	953.4	LU	“In several instances, the DEIS characterizes Alternative 2 and Alternative 3 south of SR74 in Peoria which goes through private master planned communities as similar to the Preferred Alternative which places the line north of SR74 on BLM land in Peoria and Maricopa County. The DEIS incorrectly characterizing zoned and legally vested land in varying stages of pre-development process as vacant, undeveloped, grazing land. Before a home is constructed within a planned community, there are many phases in the development process, not all viable development activity is visually apparent. There is insufficient or incorrect analysis in Alternative 2 and Alternative 3 in the resource areas of Land, Transportation, Recreation, Visual Resource and Socioeconomics.”	Revisions have been made to the EIS indicating that “undeveloped land” is not “raw land” and that developments on private lands are in various stages and generally describing a range of effects to developments.
Gary Torhjelm, Manager, Group Three Properties and Noranda Properties Inc.	953.5	CE	“The National Environmental Policy Act (NEPA) requires the DEIS to analyze the impacts of each alternative on past, present and reasonably foreseeable future actions or development. While the DEIS notes Lake Pleasant Heights as a Reasonably Foreseeable Development within Appendix 4B2 , the DEIS does not analyze the impacts of Alternative 2 and Alternative 3 to future residents of Lake Pleasant Heights, that could occupy homes prior to APS initiating construction of the line. The DEIS should consider future roads as foreseeable developments. Much of this has been excluded from the impact analysis and should be noted. In addition to the height and width associated with the ADOT and MAG future planning for SR743to 6-10 lanes, regional arterials and streets are also planned south of SR74 within the Study Area identified in the DE IS. These future roads will connect master planned communities, create major intersections for commercial development and employment centers and will connect with SR74 from the south, at major interchanges. A map showing the location of these planned roads relative to Alternative 2 and Alternative 3 and the change in traffic patterns and dispersal of trips for these planned street and regional connection roads have been omitted in the DE IS analysis.”	The impact of the transmission line on the views of future residents is analyzed in Section 4.19.15. Property value effects are analyzed based on the existing condition in Section 4.10. Any residences constructed between analysis and construction of the transmission line would be with the knowledge of the impending transmission line. Descriptions of future roads as foreseeable projects are contained in Appendix 4B, and analyzed in Section 4.19, Cumulative Impacts.

COMMENTOR NAME

COMMENT ID NO.

COMMENT TYPE

COMMENT

RESPONSE TO COMMENT

Gary Torhjelm, Manager, Group Three Properties and Noranda Properties Inc.

953.6

SOC

“The devaluing of land due to transmission lines has been incompletely evaluated. There are two studies provided by the NAHB which were submitted to BLM, but was not included showing Tucson, Arizona; which should be considered a very relevant comparison, with market data resulting in a negative impact of over 25%. This study should be included as additional literature in Appendix 3A. DEIS making home price comparisons of 2005 and 2009 is neither current nor accurate for the Phoenix metro market. The consistent, improving trend, in the housing market is not recognized.

Socioeconomic resource impacts will occur through the limitations to master planned community ability to develop. The decreased home values, prolonged timeline of sales and increased carrying costs to develop will have a much more drastic impact, which in some cases may force some property tax revenue, sales tax revenue, construction tax revenue, impacts fees, and other city, state and federal income sources to never come to fruition. On page 4-105, the report states that “the net effect on property tax revenue under Alternative 2 would be beneficial, major and long term. These benefits would accrue to taxing entities and the beneficiaries of those taxes.” The increased tax base from the future developments will create a drastic difference between what property tax has been represented as grazing land in Alternative 2 and 3 as compared to the more accurate analysis of primary and secondary property taxes and sales taxes generated from suburban community densities.

Homes similar to this area, would, on average, annually contribute approximately $500 to the County, $200 to the State Equalization tax, $100 to the City of Peoria, $1600 to the Peoria Unified School District, $450 to the Community College District, $200 to public services including fire, health care, flood control, and $1400 in bond tax. These taxation revenues would be threatened from both Alternative 2 and Alternative 3, as both effect hundreds to thousands of dwelling units; both by delaying them coming onto the market or having lower assessed valuations. For each home devalued and/or not built, roughly $2000 would be stripped from the educational budget or a total of approximately $4000 per home in general property tax. Using these figures (provided), we believe the analysis of taxation and socioeconomic resources are incorrectly represented.

There is a direct correlation between adding residential rooftops and the development of commercial, retail operations. The DEIS does not portray or analyze the basic economics of residential entitlement, predevelopment, development, marketing and home sales. These activities stimulate a local economy, pay for government, provide public community recreation, provide jobs, and should be accounted for within the socioeconomic impact. An analysis of Peoria’s or any Phoenix metro city’s source of revenue to their general fund, will illustrate the importance of private investment and commercial and residential development to the economy. While the DE IS is significantly detailed about the economic contributions of off highway vehicle recreation and grazing allotments; the economic contributions created by construction of community infrastructure associated with master planned communities and homes, as well as employment and revenues associated with the sale of goods and services during home construction and occupancy have been ignored in the DEIS socioeconomic analysis.

The referenced studies were reviewed and deemed not applicable to the analysis of impacts to private property values.

The potential impact on taxes would be a cumulative impacts issue, and Section 4.19.11 is revised, as applicable.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Gary Torhjelm, Manager, Group Three Properties and Noranda Properties Inc.	953.7	VIS	“The DEIS states that the impacts to visual resources in Alternative 2 and Alternative 3 would result in a contrast that would be weak and the long term impact would be negligible. These conclusions are not based on a proper analysis required through Key Observation Points guidelines, such that Key Observation Points (KOPs) should first identify residential viewers, including those in reasonably foreseeable developments.”	Impacts on the views of reasonably foreseeable developments are contained in Section 4.19.15.
Herman and Kathleen Burgess	954.1	OPP SAR	“One of the proposed routes from this transmission line is to go down Cloud Road. The information I was made aware of puts one of the main towers basically in my backyard. Obviously this is not what a property owner wants to see out his backdoor. We are not people who are against the progress and growth of our community, but there are acres and acres of land that can be used for this project that will not infringe on current homeowners rights.”	Statement of preference.
Herman and Kathleen Burgess	954.2	PH	“we as a group need to do a better job in communicating to the property owners in the area of the projected routes. I found out about the Cloud Road Proposal from a neighbor who went to a meeting at a school based on a small sign that was posted on a road. We did not get any prior notification, nor had any of my neighbors.”	Chapter 1 contains a detailed description of the public outreach and hearing process conducted for this project.
Dan Gainor	955.1	SUP PA	“I am writing to express my support of the proposed alternative to high power transmission lines running through native desert of Trilogy at Vistancia and having the lines placed on the north side of State Route 74.”	Statement of preference.
Dan Gainor	955.2	GEN	“Building high power transmission lines through native desert is not environmentally responsible.”	The EIS evaluates the environmental reasonableness of the alternatives considered, as well as those eliminated from detailed analysis, in Chapter 2.
Lydia Alzo	957.1	SUP UR	” I am in support of the APS lines.”	Statement of preference.
Walter “Skip” Zahlmann	958	UC	Content unrelated to analysis
Paulette Miller	959.1	SUP PA	“Preferred Alternative location for the APS lines along the north side of SR 74.”	Statement of preference.
Krisitina Jauch	960.1	OPP FL	“I’m distressed that the BLM is considering violating the trust of the public by desecrating public land with APS transmission towers. As a concerned citizen, I support the ongoing campaign for keeping these ugly towers off of pristine desert lands. A few of my concerns are: 1. Improper notification of Wittmann, Circle City, Morristown and surrounding residents. 2. Continued refusal to provide Freedom of Information requests. 3. Decrease of property values throughout the areas (up to 50%). 4. Unnecessary disruption of Endangered Species. 5. Conservation of pristine BLM land.”	Statement of preference. The EIS provides a complete analysis of most of the concerns: Notification of Wittmann, Circle City, Morristown and surrounding residents is addressed in Section 5.2. Addressing Freedom of Information Act requests is beyond the scope of the EIS. Impacts to property values are addressed in Section 4.10 Impacts to endangered species are addressed in Section 4.16. The BLM’s mission is explained in Section 1.5.2, and impacts to land use on BLM-managed public land are addressed in Section 4.6.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Ramon A. Gaanderse, Executive Director, Tucson Utility Contractors Association	961.1	SUP PA	“…we are writing in support of the BLM’s selection of APS’ Proposed Action/ Electric Transmission ROW Application as the BLM Agency Preferred Alternative in the DEIS. Amendments to BLM’s Bradshaw Harquahala Resource Management Plan which support co-location of utility rights-of-way in designated corridors are appropriate.”	Statement of preference.
Ramon A. Gaanderse, Executive Director, Tucson Utility Contractors Association	961.2	LU	“TUCA’s opinion is that both the public and private utility providers are faced with the challenge of obtaining rights-of-way. The majority of lands in Arizona are held by government agencies which need water, sewer, electricity, natural gas, communication, rail, and transportation utilities. Any action which facilitates and expedites right-of- way approval on public land; federal, state or local increases timely and efficient utility service delivery.”	Statement of opinion and agreement that rights-of-way need to be obtained.
Ramon A. Gaanderse, Executive Director, Tucson Utility Contractors Association	961.3	LU	“A shared corridor with adjacent transportation and utility ROW is an industry standard…”	Statement of preference.
James E Jaenicke	964.1	SAAA	” … I now support Alternative 2 where the transmission lines stay on the south side of SR 74 instead of Alternative 1. The additional cost it takes to cross over SR 74 twice and use BLM lands is not prudent or efficient construction and seems just plain silly. It seems there may be ulterior motives for Alternative 1 such as a developer (Sunland) protesting the southern Alternative 2 route.”	Statement of preference.
James E Jaenicke	964.2	VIS	” In either Alternative 1 or Alternative 2 the developers residential buildings will see the transmission lines. I recommend and support Alternative 2 as the best overall solution!”	Statement of preference.
Walter “Skip” Zahlmann	996	UC	Content unrelated to analysis
Karen Savage, Transportation Planning Manager City of Surprise	997.1	GEN	“At this time the city does not have any objections to the Preferred Alternative described in the document. The document appears to address issues raised earlier in this process by the City of Surprise.”	Statement of preference.
Joe Carmin	999.1	NEPA	“I am very concerned about the process of selecting a route for this proposed line and how it seems to be dictated by land development corporations. It seems to me that the people in charge of selecting this route are listening to these corporations promoting future development instead of the people with homes in already established residential areas”	Section 2.10 provides the rationale for the Agency Preferred Alternative and Chapter 1 provides the background and processes that have been followed for this project.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Joe Carmin	999.2	OPP SAR	“Also, I am adamantly opposed to the sub-alternative route that is proposed down Cloud Road. Why does this line have to go so close to an established residential area when there is almost three miles of undeveloped state trust land that is between Highway 74 and Cloud Road? I also don’t see how APS and the state of Arizona can ruin our lives and property to save a few dollars in the possibility of developing their land sometime in the future.”	Statement of preference.
Emily & Andrew Walkerwicz	1000.1	SUP PA	“My husband and I want to convey our sincere hope that the power lines will be placed on the North side of SR74.”	Statement of preference.
David Thompson	1002.1	SUP PA	“I support the Preferred Alternative location on the north side of SR 74. I support it because of the visual impact, because SR 74 is already a designated transportation corridor, for environmental reasons and because several entities (ADOT, Maricopa County, City of Peoria, etc.) support it as well.”	Statement of preference.
Merl Schafer Daisy Anderson	1008		Not a comment letter, but rather the info letter for the Petition.
Ray Prendergast	1024.1	NEPA	“Does your proposal include as an option to NOT PROCEDE until more conservation measures have been studied?”	Recommended mitigation measures are contained in Section 2.9 with added mitigation now included in the EIS, and under specific resources in Chapter 4 and a list of BMPs for the project are provided in Appendix 2A.
Ray Prendergast	1024.2	VIS	“One such option would be to make the usual glossy, ungainly white towers (we see everywhere across Arizona) somehow be made more harmonious with the landscape, This might be to study how best the towers should be placed to preserve the views, and to make sure their color preserves one of Arizona’s prime views.”	Mitigation for impacts to visual resources is contained in Section 2.9.13 and 4.14.4.
Sierra Club on behalf of David Ravenscraft	1032		See Letter 116 – Added: “Siting this line on our public lands north of SR74 is not in the best interests of the public and does not support the mission of the Bureau of Land Management (BLM). Instead, it primarily benefits one developer, while sacrificing important public resources.”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
Leisa Brug, Director, Governor’s Office of Energy Policy	1049.1	SUP PA	“We are grateful that you elected to participate in this line siting process, and, in the end, endorsed the preferred route selected by the committee after much consideration and compromise.”	Statement of preference.
Bonnie Carmin	1051.1	OPP FL	” I am writing to you because I am upset about the BLM thinking about giving the APS right of way for a transmission line across our federal desert lands.”	Statement of preference.
Bonnie Carmin	1051.2	OPP SAR	“I didn’t realize how this would affect us until after the public meetings were held when we found out that a large development corporation had input as to where it should go and that APS had created a new alternative route that would be only less than 200 feet from our back yard along Cloud Road.”	Statement of preference.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Bonnie Carmin	1051.3	NEPA	“I am hoping that the BLM can halt this proposed line until more input from citizens can be heard and more thought can be put into this process. So many people are upset because it will affect their property values on land that is already an established residential area. Please have the BLM reconsider this proposal or at least delay it until you have heard other ideas.”	Section 4.10 provides the Socioeconomic impacts analysis. Chapter 1 provides a description of the processes that BLM has followed for this project. The FEIS addresses and/or responds to the comments received on the DEIS.
Bradley Reithmann	1070.1	PH&S	“When we moved to Vistancia, I made a new friend named Jagger. When Jagger was born his family lived in Phoenix and were living under power lines. When Jagger was two years old he got leukemia. The doctor told his parents the power lines are why he got sick. So his family moved here so they could get away from the power lines. When they found out that APS might put power lines here, they moved again. I miss Jagger very much and wish he never got sick. I don’t want this to happen to any other kids especially my friends. Please put these power lines as far away from children as you can.”	Impacts to Public Health and Safety from all alternatives are analyzed in Section 4.7.
Christopher and Connie Ecker	1190.1	SUP PA	“…I…commend the Bureau of Land Management’s choice for alternative #1…all…have deemed placement along the north side of SR74 as the most logical choice and the one that will least impact all concerned considerations.”	Statement of preference.
Doug Reithmann	1191.1	SUP PA	“I respectfully request that you revise your Resource Management Plan to allow placement of the APS 500/250kV power distribution lines on the north side of SR 74.”	Statement of preference.
Doug Reithmann	1191.2	WLF	“Should BLM officials reject alignment along the north side of SR 74, APS will have no choice but to place the power distribution lines along the “Carefree Highway alignment” which literally draws an imaginary line from the southern most section of the Carefree Highway extending across pristine desert land. This land is home to coyote, bobcats, javalina, roadrunners, wild donkey, quail, rabbits, squirrels, desert tortoise. These populations will be dramatically affected by the power lines and placement of a roadway in order for APS to perform maintenance and repairs. We must protect all wildlife.”	Impacts to wildlife and associated habitat (including sensitive species and their habitat), along with mitigation measures to minimize impacts, are both analyzed and described in Section 4.16.
Lynda Reithmann	1192.1	SUP PA	“we are actively supporting the proposed alternative to place the APS 500/250kV power distribution lines along the north side of SR 74…”	Statement of preference.
Lynda Reithmann	1192.2	OPP ALTS	“we…strongly reject placement along any other route closer to current and future residential communities.”	Statement of preference.
Lynda Reithmann	1192.3	PH&S	“A report by the United States National Council on Radiation Protection stated, “There is a powerful body of impressive evidence showing that even low exposure to electromagnetic radiation has a long-term effect on health.” Some effects listed in the report include sudden infant death syndrome, childhood leukemia, changes in brain chemistry which can lead to Alzheimer’s Disease, impairment of the immune system and inhibition of melatonin production which suppresses certain cancers, including prostate and breast cancers. Considering the 500kV power distribution lines are the most powerful in existence, these statements are quite alarming. Further, they reported that the “only protection from electromagnetic fields is distance from the source.”	Impacts to Public Health and Safety from all alternatives are analyzed in Section 4.7.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Lynda Reithmann	1192.4	SOC	“I can site many areas in Arizona where property values are less for homes under power lines than homes that are not. One example is Sun City Grand, where homes east of the 303 sell for approximately $20,000 more than homes on the west side of the 303 that are in sight of the power lines. Plummeting property values due to poor economic conditions have devastated thousands of families in the Valley of the Sun through short sales, foreclosures and bankruptcy. Placement of the APS 500/230kV power lines anywhere but on the north side ofSR 74 will further the devastating effect oflower property values for Vistancia, Trilogy and Blackstone residents. The viability of cities is greatly based on tax revenue coffers that provide essential services to local residents. Just as residential homes are affected, the city coffers will be dramatically lowered through lesser tax revenues. There is no doubt that homes located near power lines have a lower property value. Through the domino effect, schools will be negatively impacted as budget cuts, due to lower tax revenues, are inevitable. Our schools have already suffered severe budget cuts and can’t afford to lose more funding.”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values and tax revenue (which fund local school systems).
Lynda Reithmann	1192.5	VIS	“Power lines along a transportation corridor affects scenic views on a part-time basis; power lines along family communities affects scenic views 100% of the time. APS representative, Mike De Witt, stated during a Q&A session at the Kiva Club in Trilogy that the power lines could be placed in front of, behind or on TOP of the beautiful mountain scenery that frames our community. The fact is, SR 74 is not designated a scenic corridor in Arizona.”	The impact of the proposed transmission line on visual resources, and specifically the visual resources of SR 74, is analyzed in Section 4.14.
Tom Reithmann	1193.1	SOC	“Should the APS power lines encroach on our Vistancia community, home values will be adversely affected on a permanent basis. Lower home values = lower tax revenues = even less funding for schools. Why is it that the actions of adults are so often detrimental to our children?”	Socioeconomic impacts of all alternatives are analyzed in Section 4.10, including potential impacts to property values and tax revenue.
Tom Reithmann	1193.2	SUP PA	“Please revise your Resource Management Plan to enable placement of the APS 500/250kV power lines along the north side of SR 74.”	Statement of preference.
Brent & Rose Dubberstein	1204.1	SUP PA	“My wife and I are in support of the PROPOSED ALTERNATIVE which is on the north side of State Route 74.”	Statement of preference.
CHANGE.ORG	1229		Not a comment letter, but a letter from CHANGE.ORG stating that a petition had been started by Merl Schafer.
Sierra Club on behalf of Ann Wagner	1235		See Letter 116 – Replaced first paragraph with: “Please do not cave to pressure from one individual: your mission is to serve the public interest, not to help someone increase their private wealth.”	Chapter 1 in Section 1.3.2 has been revised to clarify the BLM’s multiple use mandate under the FLPMA and provide information on the BLM’s mission, which provides context for the BLM’s purpose and need.
Jeff Gursh, AZOHVC and ATR	1276.1	SAAA	“…this overview of our support of Alternate 3 the Carefree alignment.”	Statement of preference.
Jeff Gursh, AZOHVC and ATR	1276.2	OPP PA	“We cannot support your Proposed Action/ Preferred Alternative. A power line corridor in this area on BLM lands North of Hwy. 74 is a direct and major long term impact to recreation…”	Statement of preference.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Jeff Gursh, AZOHVC and ATR	1276.3	LU	“APS and the city of Peoria appeals were turned down three separate times filed AFTER end of comment period and after the Signed 2010 EIS. Finally, APS and ACC put enough pressure on the BLM that we are now looking at revising a less than 2 year old EIS to accommodate Agencies that did not plan ahead.”	Chapter 1 provides a detailed description of the background information for this project and Section 2.10 provides the rationale for the Agency Preferred Alternative.
Jeff Gursh, AZOHVC and ATR	1276.4	OPP ALT1	“AZOHVC and ATR do not support alternate 1, expansion of APS corridor on BLM lands north of Hwy74.”	Statement of preference.
Jeff Gursh, AZOHVC and ATR	1276.5	SAAA	“Alternate 2 move corridor /ROW to south side of HWY 74 This option would be our 2 choice but believe that Alternate 3 the Carefree alignment would be the least impact overall. We would support this alternate over PROPOSED ACTION.”	Statement of preference.
Jeff Gursh, AZOHVC and ATR	1276.6	SAAA	“…we support alternative 3, the Carefree Hwy alignment. This alternate, from the data given, is the least impact to BLM lands and majority of concerns listed.”	Statement of preference.
Jeff Gursh, AZOHVC and ATR	1276.7	GEN	“Page 32-34 ES.3.2 Issues – Issue 1: AII the issues noted here can be addressed with the corridor located south of HWY 7 4. The existing APS corridors and substations south were the original intended locations and are a much better fit considering the future plans for the areas North of Hwy 74 by both the City of Peoria and the Maricopa county Parks. Both agencies plan on creating open space preserves and trails systems to join BLM routes and Maricopa County Parks is looking at resorts and other amenities just east of Castle Hot Springs road near Lake Pleasant because of the beauty of the area north of 74 and the undisturbed view shed.”	Section 2.10 provides the rationale for the Agency Preferred Alternative.
Jeff Gursh, AZOHVC and ATR	1276.8	GEN	“Issue 2: COST, APS, if preferred alt is chosen, should have to pay for any and all expenses that the BLM would incur to amend the existing EIS RMP for the North side of Hwy 74. This would include but not be limited to: EIS/RMP amendment, NEPA for APS project mitigation, NEPA and clearances to rehab area, NEPA and clearances to rebuild/relocate trail systems, Mitigation of T and E species such as Tortoise, relocation of all high value plants including Saguaros and trees to other BLM areas that would benefit from replanting , this would mean that Topping Saguaros and clear- cutting would NOT be an acceptable method to protect corridor under lines, see AZOHVC costs at end of this document for more specific costs including a breakdown of costs to control dust , trespass and law enforcement needs to enforce no cross country travel in corridor.”	APS is responsible for the cost of the EIS process. The EIS specifies mitigation that APS would be responsible for; some mitigation sections in the DEIS have been revised and/or expanded in the FEIS. No trails would be required to be rebuilt/relocated; see additional subsequent comment responses. Additional clarification has been added to the EIS in Appendix 2A to specify how saguaros would be handled.
Jeff Gursh, AZOHVC and ATR	1276.9	LU	“Issue 3: Transmission lines placed in existing corridors and near existing sub stations that are currently in or near subdivisions should be considered. These areas were developed around the APS corridors and residents purchased their homes knowing that these corridors were there as well as that future lines and corridors were in the planning. Your EIS data shows that public expect to see this type of utility structures in this Carefree Hwy urban area corridor setting. Please look at corridors south of Hwy 74. This would greatly reduce the cost and impacts to both environment and recreation planning that already has been signed off on and paid for.”	The EIS evaluates route alternatives to the Proposed Action/Preferred Alternative, including the Carefree Highway alignment under Alternative 3.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Jeff Gursh, AZOHVC and ATR	1276.10	AIR	“Issue 4: Air quality will be an issue with the corridor long after construction is completed. Similar corridors in other public lands (FS see accompanying AZOHVC document)) show issues with wind blow dust events , trespass, cross country travel and erosion damage due to the continuing clear cutting under the towers long after construction. This must be considered especially on the north side for 74 due to the greater density of vegetation and designated Multiuse /OHV recreation that will be in this area. Your data shows problems with trying to keep OHV and trespassers out of ROW and off centerline road. This could easily result in closure to all OHV due to dust and resource damage if unchecked. The other issue will be allowing other non-motorized recreation access to the closed to OHV groups. Whatever reasons ROW is closed to OHV should also apply to any other recreation.”	Mitigation was added to Section 4.9 designating the centerline access as an administrative route, which is intended to prohibit unauthorized recreational use of the ROW, and provide BLM authority to enforce the recreational use decisions.
Jeff Gursh, AZOHVC and ATR	1276.11	OREC	“Issue 5: The current approved, BLM 201 0 RMP/EIS, address managed, responsible recreation and resource management, to imply that because the area already has grazing and Multiuse/ OHV use, that APS impact would be similar, is unacceptable. Impacts according to your data show it to be a moderate to major impact (page 462) previously impacted OHV and multiuse recreational areas show major long term impacts from the Corridors and centerline roads left after construction. ANY impact from recreation or grazing was seriously considered and needed mitigations were put in place by BLM for the acceptance of the 2010 EIS /RMP. There was no consideration of an APS corridor in the planning for good reason . The clear cutting and removal of trees, vegetation and topping of Saguaros will cause future problems with Water shed that would deal with the following: Silt moving into wash areas creating windblown dust issues, and the same silt affecting wildlife and water supplies. Both these issues will be greater on the North side due to the proximity to the “head water” drainage from mountain areas. The initial removal of the plant life during construction and clear cutting under wires is not a short term issue. This process will continue thru the life of the tower system. This long term clear cutting will continue to be an issue that must be funded by APS.”	The EIS contains a revised and updated Appendix 2B, APS’ Transmission Vegetation Management Program. Sections 3.9 and 4.9 of the FEIS reflect changes to the affected environment description and impacts analysis. Additional clarification has been added to the FEIS in Appendix 2A to specify how saguaros would be handled.
Jeff Gursh, AZOHVC and ATR	1276.12	VEG	“Issue 6: Dense vegetation on North side and remote areas that will be difficult to access to fight fires is another issue North of HWY 74 that is not as big an issue the farther south you move.”	The issue of Fire is discussed and addressed in Sections 3.7.3 and 4.7.1.3.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Jeff Gursh, AZOHVC and ATR	1276.13	OHV	“Issue 7: Recreation: The Boulders SRMA area is one of the most popular OHV areas in the State. The public spent years working with the BLM to find a way to protect the area while allowing responsible OHV and other types of recreation to use the area. Terrain and vegetation are used to keep recreation on designated trails. Corridors such as this one have caused tremendous long term damage to recreation systems in other locations such as the Prescott Forest and the Tonto Forest. These impacts include soil erosion due to clear cutting under towers and lines, new access to areas that would have otherwise been inaccessible, loss of trails due to opening canyons and washes to equip to build, loss of vegetation that restricted users to specific trails and access to the now created new roads to build system of towers and lines. With the closure to OHV thru out the entire Row, including the 4.5 mile section North of Hwy 74, Single track users will be directly affected. The access roads and centerline The cost to rebuild .. relocate or otherwise mitigate these issues is very high, but the long term cost or the continued clear cutting and the cost to the BLM to pay for long term rehab and law enforcement to reduce the impacts form the new corridor cannot be ignored. A single officer is more than $100,000 a year plus his equipment to use to patrol areas that his Truck or car cannot access. This is a major expense that the BLM should not have to incur and should be included in any mitigation that would be put in place to address the RECREATION issue.”	The EIS contains a revised Appendix 2B, APS’ Transmission Vegetation Management Program. Mitigation was added to Section 4.9 designating the centerline access as an administrative route, which is intended to prohibit unauthorized recreational use of the ROW, and provide BLM authority to enforce the recreational use decisions. Recreation mitigation in Section 4.9 was expanded to specify locations for gates on the centerline to prevent unauthorized access along the centerline. Section 4.9 has been revised to emphasize that while the centerline access is closed to recreation, single- track users will be allowed to cross the centerline, ensuring continuity and no loss of single-track trails. Recreation mitigation in Section 4.9 was expanded to include monitoring of the centerline by APS and patrolling of the ROW by BLM, enforcing the designation of the centerline as an Administrative route.
Jeff Gursh, AZOHVC and ATR	1276.14	SOC	“Issue 8: As we presented in the 2011 comment period, Re creation is a huge part of the Arizona economic fabric. The Boulders OHV area is one of the most popular OHV areas in the State. There are a large number of OHV related businesses that have developed in the near by Cities and communities that bring in much needed revenue to the county as well as the State. These also have thousands of employees. Horse back riding out fitters , mountain bikers and related businesses, hikers, rock hounds and many more recreations also enjoy the area. Both the City of Peoria and Maricopa county parks are looking to increase the use of this area north of hwy 74 in the form of preserves and parks with these areas tie back to the BLM trail systems. Corridors such as this have forced agencies to close large areas to recreation due to the damage from cross country travel and the incursions into sensitive areas that the corridor access roads and construction created. This would greatly impact the use and the socioeconomic value of the area. Though many may argue this point, a large percentage of residents in the Area of concern for this project are OHVer that bought their homes in the area to be near the OHV recreation the Boulders SRMA provides. The impact to this area by accepting preferred alternative will be significant.”	As demonstrated by the expanded mitigation measures in Section 4.9 and BLM’s preference for a single- use utility corridor north of SR 74, BLM strongly supports continued responsible recreation use of the areas accessed from the Boulders Staging Area. Implementation of expanded mitigation measures contained in Section 4.9 would minimize adverse impacts to recreation on BLM-managed public lands north of SR 74.
Jeff Gursh, AZOHVC and ATR	1276.15	SOC	“Issue 9: The proposed section on BLM Lands that is north of Hwy 7 4 will be greatly impacted by P .A. as noted previously. There are no homes affected in alternate 2 for the south side of HWY 74 section to avoid the BLM SRMA and other recreation/ preserve areas. Please look at existing homes that would be impacted rather than what future resident that would have moved into the corridor area knowingly. The residential areas South in Alternate 2 and 3, already have multiple corridors as well as existing substations and smaller utility line corridors … the visual effects are already an existing impact to these area were adjusted for in existing corridor home values. The south side of the hwy is still the least impact to both enviroment and public recreation resources and fits ,according to your data, in an urban area setting.”	Chapter 4 analyzes impacts of the proposed project on the Affected Environment, as described in Chapter 3. The comment correctly notes that homes do not currently exist in the planned development areas south of SR 74 where Alternatives 2 and 3 would cross. However, the NEPA does require the analysis of cumulative impacts. The EIS analyzes the cumulative impacts of the proposed project in conjunction with other past, present, and reasonably foreseeable projects (including planned community development) in Section 4.19.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Jeff Gursh, AZOHVC and ATR	1276.16	OREC	“Page 42 ES.6.8 Recreation – Long term issues have not been shown, these include new access roads and clear cutting that will allow other types of recreation not currently allowed, to access remote single track trails or completely eliminate single track by removing the limiting terrain or vegetation. This will become a long term issue with the loss of single track in area. Another issue is that these are the long distance connector trails that allow Single trackers to loop back to trails in north and west of SRMA. Though you show as only a small percentage of the total, they are major corridors that allow access to other BLM areas. In addition, there is no mention of the loss of all access to trails or routes that currently have to access area thru ROW. The ROW and centerline road are closed to all OHV use. This cuts all travel from LP5 end east to mile marker 18. APS should cover the cost of NEPA and the cost to do an additional Amendment to add /replace these important routes outside the corridor area if PREFERED ALTERNATIVE is chosen.”	The EIS contains a revised Appendix 2B, APS’ Transmission Vegetation Management Program. Mitigation was added to Section 4.9 designating the centerline access as an administrative route, which is intended to prohibit unauthorized recreational use of the ROW, and provide BLM authority to enforce the recreational use decisions. Recreation mitigation in Section 4.9 was expanded to specify locations for gates on the centerline to prevent unauthorized access along the centerline. Section 4.9 has been revised to emphasize that while the centerline access is closed to recreation, single- track users will be allowed to cross the centerline, ensuring continuity of loop trails and no loss of single- track trails. Recreation mitigation in Section 4.9 was expanded to include monitoring of the centerline by APS and patrolling of the ROW by BLM, enforcing the designation of the centerline as an administrative route.
Jeff Gursh, AZOHVC and ATR	1276.17	SOC	“Page 42 ES.6.9 Socioeconomic – Property values are always a big concern, private property owners should be compensated for the perceived loss of value or known loss due to project. Currently, there are no homes just south of HWY 74 alternate 2 that would be affected but the private land would be. This land has steep terrain on it that is not suitable for building. This terrain runs from MM18 to the Quintero golf course area (south side lands) Much of the land south in Alternate 2 would not drop in value based on the inability to build on. AS for the misconception that this would be a short term effect on the OHV and other multiuse recreation we would beg to differ. Other recreation areas have been greatly impacted to the point of routes and areas being closed due to similar corridors (please seen AZOHVC comments for details and photos) Everything from the purchase of new OHV and recreation equipment (bikes, horse tack ect) and indirect multipliers such as gas, groceries, campers as well as hotel and restaurant revenue would drop if areas closed or were adversely affected. AZOHVC has supplied and will supply again, economic impact studies for OHV and other local business letters that show direct cause and effect of loss or impact to these recreations. Please consider these in your decision.”	Impacts to private property south of SR 74 that would be affected by Alternatives 2 and 3 were determined based on existing conditions for direct and indirect impacts; and based on plans for future development for cumulative impacts. As demonstrated by the expanded mitigation measures in Section 4.9 and BLM’s preference for a single- use utility corridor north of SR 74, BLM strongly supports continued responsible recreation use of the areas accessed from the Boulders Staging Area. Implementation of expanded mitigation measures contained in Section 4.9 would minimize adverse impacts to, and prevent use that could lead to closure of the area to recreation on BLM-managed public lands north of SR 74.
Jeff Gursh, AZOHVC and ATR	1276.18	AR	“Page 44 ES.6.11 Transportation – Yes, some roads do exist to access work areas. Few if any exist to access tower locations. These were pointed out to both BLM and contractors for APS that access would be in narrow side drainage and wash areas that would not be able to be put back to their natural state after widening……. ie single track. The habitat and wildlife will have major Impacts and areas that had not had access to in the past will directly affect resources and wildlife. Also of great concern is the fact that ROW and centerline road will be closed to OHV users. This will close all access from the LP5 area trails and the Boulders OHV area east. This closes long distance looped trails that make the Boulders OHV area so popular with Single trackers. This is a much larger percentage of trails lost than you show. Long term mitigation funds should be put aside for BLM to protect areas affected by these “temporary roads”.”	BLM will work with APS to prepare a Construction Access Plan, which will definitively identify construction access routes to assure that there would be no loss of single-track trail, as indicated in the EIS. This Plan would be part of the Plan of Development document.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Jeff Gursh, AZOHVC and ATR	1276.19	AR	“”Construction Access roads outside the ROW.” This is an important point. This would mean that a permanent road along the ROW would remain. The ROW and centerline road would be closed to OHV use which will close access to this area from Boulders OHV area LP5. Also, it is noted that existing trails or roads would be utilized to access ROW road and tower work. This is in contradiction to the page166 2.9.8 No single track would be used as access to work or ROW or lost for that matter{see pg. 462).”	BLM will work with APS to prepare a Construction Access Plan, which will definitively identify construction access routes to assure that there would be no loss of single-track trail, as indicated in the EIS. Mitigation was added to Section 4.9 designating the centerline access as an administrative route, which is intended to prohibit unauthorized recreational use of the ROW, and provide BLM authority to enforce the recreational use decisions. Recreation mitigation in Section 4.9 was expanded to specify locations for gates on the centerline to prevent unauthorized access along the centerline. Section 4.9 has been revised to emphasize that while the centerline access is closed to recreation, single- track users will be allowed to cross the centerline, ensuring continuity of loop trails and no loss of single- track trails.
Jeff Gursh, AZOHVC and ATR	1276.20	VEG	“ES.6.12 Vegetation – Short term and temporary seem to be the norm for all comments……. long term maintenance is not mentioned. Long term maintenance includes the practice of clear cutting and topping of trees and Saguaros. This ongoing long term maintenance will continue to directly affect populations of Saguaros, trees and wildlife due to this maintenance practice. As mentioned before, both the Tonto National Forest Cave Creek district and Prescott National Forest areas where the clear cutting and topping are practiced, are greatly affecting recreation, plant life, water shed and erosion issues. This must be addressed in EIS. Another issue is the destruction of valuable plants. Rather than topping Saguaros or removing trees thru excessive trimming or crushing……… we ask that APS relocate boxed trees and Saguaros to areas identified by BLM in other areas that need plants to rehab damage from users, construction and commercial use. This would save valuable plants that would otherwise be lost. The long term practice of topping should be discouraged. A trust fund from APS should be started to address the damage and help BLM mitigate the issues that will be associated with this P.A.”	The EIS contains a revised Appendix 2B, APS’ Transmission Vegetation Management Program. Additional clarification has been added to the EIS in Appendix 2A to specify how saguaros would be handled.
Jeff Gursh, AZOHVC and ATR	1276.21	VIS	“ES.6.13 Visual – From any ridge line trail, hillside or staging area North of hwy 74, the predominate feature would be the power lines. From any view looking west from Lake Pleasant proposed resorts and recreation areas the towers will impact a large % and be the predominate feature. Anyone accessing the Quintero golf course would find the Line the predominate feature. Our last meeting with the City of Peoria showed proposals to incorporate the north area into a preserve plan that would be greatly affected by the preferred alternative. We ask again that alternative 3 be chosen to reduce impacts to what will become an irreplaceable recreation area. In addition the practice of clear cutting and topping greatly impact the visual resource by creating unnatural look to any plant in ROW area. See attached ROW corridor impacts.”	The impact of the proposed transmission line on visual resources is analyzed in Section 4.14.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Jeff Gursh, AZOHVC and ATR	1276.22	WTR	“ES.6.14 Water – Though again you show a temporary use of an amazing amount of water to control dust and settle construction, the long term maintenance is not mentioned. Each time the area is clear cut and topped, top soils will be disturbed and windblown dust issues will arise. What will the additional use of water cost and where will it come from? {Which you do not currently address in other areas during these operations). This is a long term affect that must be address as the valley grows and the need for power is a concern … so is the need for water!”	According to APS, long-term maintenance activities are very minor and infrequent. Undisturbed desert surfaces maintain a crust that does not require repeated application of water. Post-construction use of access roads is described as minimal. Disturbed unpaved roads and vacant areas would be maintained as required by Maricopa County Rule 310.01.
Jeff Gursh, AZOHVC and ATR	1276.23	WTR	“If water for project is sourced from area well owner, this amount of water would greatly affect all other well owners and drop the water table for rancher and other livestock concerns. Please refrain from tapping ground water.”	Any water obtained from a private source by APS would already have the approvals and permitted allocations associated with the water right and the amount of water that is allowed to be used.
Jeff Gursh, AZOHVC and ATR	1276.24	SSS	“ES.6.15 Wildlife – A running issue with recreation is the mitigation of the loss or possible loss of habitat for sensitive species. Tortoise habitat is on the top of the list. BLM rule of thumb has been for each mile of route to open, 3 miles of route has to be closed. SINCE APS cannot take and close existing routes to allow this 3 to one formula, a dollar value should be placed on the amount of habitat lost and the possible damage to the population in the area. the costs for relocating or replacing habitat is extremely high and should be factored into the cost effectiveness of having the corridor on this section of BLM north of hwy 74. In addition to the construction damage and loss of that habitat thru disturbance, the roads and access routes as well as the clear cutting area under the entire corridor will be a permanent scar. This loss of habitat is of high value and will not recover due to future maintenance under lines. Long term costs to mitigate this damage will need to be put in place funded by APS. Further, these routes for access during construction and the elimination of terrain and vegetation to restrict access from public will further damage area. The long term costs to enforce rules to protect these areas will be needed and funded by APS for BLM LEO and ranger work, possibly a trust?”	Section 4.16.3.1 specifies mitigation for impacts to Sonoran Desert Tortoise, which includes potential compensation for habitat loss.
Jeff Gursh, AZOHVC and ATR	1276.25	GEN	“ES.8 – WE would prefer alternate 3 as the preferred alternative due to zero impact to existing SRMA and BLM EIS. Should the preferred alternative be chosen, please include in a APS funded trust, but not limit to, the long term costs for rehab, dust control, law enforcement, and the following: Cost of EIS or EA to rebuild trails system, cost to redo and amend original EIS and do new EIS for corridor, cost to do long term Law Enforcement, Cost of all NEPA, and required surveys to mitigate trail construction and monitor and enforce closures into the clear cut areas under the lines. Also it should be included that APS would compensate BLM for the loss of Tortoise Habitat and as mention at a rate of 3 to one (1 mile opened or disturbed, 3 miles replaced) APS corridor would be approx. 5 miles x .5 miles which equals an area value to replace habitat at 15 miles x 1 1/2 miles. It is hard to put a dollar figure on replacing a living eco system, that would need to be worked out with BLM staff.”	Statement of preference. APS is responsible for the cost of the EIS process. The EIS specifies mitigation that APS would be responsible for; some mitigation sections in the DEIS have been revised and/or expanded in the FEIS. No trails would be required to be rebuilt/relocated; see additional subsequent comment responses. Recreation mitigation in Section 4.9 was expanded to include monitoring of the centerline by APS and patrolling of the ROW by BLM, enforcing the designation of the centerline as an administrative route.
Jeff Gursh, AZOHVC and ATR	1276.26	NEPA	“ES10 – To comment on the 980 pages of data and make meaningful comments during the Xmas holidays is an impossible task for the public. Even at a non-holiday time frame 90 days to read and comment on this much is something the average person just won’t do. This make the public side of the NEPA process sadly lacking form the public comment side. It is unfortunate that this important project time line fell in the holiday period for comments.”	Statement of opinion. Comment noted.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Jeff Gursh, AZOHVC and ATR	1276.27	GEN	“1.1.1 PAGE 55 – the EIS or RMP amendment cost , though most likely done in house , will still cost the the Federal government and that cost should be passed onto APS as a condition to any one of the alternative accepted.”	APS is responsible for the cost of the EIS process, including time spent by federal employees and contractors.
Jeff Gursh, AZOHVC and ATR	1276.28	INFO	“1.1.2 PROJECT HISTORY – Where is a copy of this document? It would be valuable for the public to see where APS had plans for this corridor in this report.”	Section 1.1.2 has been revised to expand information about the RMP development process, and includes APS’ role in the process.
Jeff Gursh, AZOHVC and ATR	1276.29	GEN	“As noted the BLM dismissed Peoria’s claim of a corridor missing from original EIS and as one of the many other groups that did bother to work with the BLM to develop this existing EIS and subsequent SRMA………….. it is unfair and a disservice to the public and the NEPA process to “back door” this size and type of change to the existing area EIS. APS and others, if this was that important a corridor, should have known and taken the time to comment on the future needs at least so that it could have been incorporated and the public known up front of this type of change to the BLM landscape. The public has a hard enough time trusting the Federal agencies; this type of change discourages public participation in this NEPA process.	Section 1.1.2 has been revised expand information about the RMP development process, and includes APS’ role in the process.
Jeff Gursh, AZOHVC and ATR	1276.30	LU	“PAGE 57……. ROD and RMP approval: This again makes it very hard for the public to bother commenting when large corporations can force changes to approved plans. There is no recourse for public who spent their time working on the original EIS for area that did not include a corridor. Again, if this was such an important issue, why was it not brought up at the public meetings for the BLM plans or at the ADOT hwy 74 meetings that will in the future widen 74 to 41ands? Other agencies plan ahead and one would think that APS did the same…….. or did they? The original plans called for future corridors as shown in alternative 3 Along the Carefree hwy alignments.”	Section 1.1.2 has been revised to expand the information about the RMP development process, and includes APS’ role in the process.
Jeff Gursh, AZOHVC and ATR	1276.31	NEPA	“1.2 Applicant objective – Applicant makes it sound like there are no alternatives to having the corridor on BLM land for the short 5 miles north. A 5 mile long section that forces the amendment of an existing EIS, has the corridor jump twice over a busy hwy and future ten lane project and Affects preservation and recreation areas already completed or in the works. No one argues the need … just the alignment. Based on data in this DEIS, the P.A. is not the appropriate choice.”	Section 1.1.2 has been revised to detail the Arizona Corporation Commission (ACC) process that led to the development of the Proposed Action route. The ACC requires that APS utilize the route they specified.
Jeff Gursh, AZOHVC and ATR	1276.32	GEN	“1.5.1 EIS frame work – Sadly, after 12 years of working on the SRMA area to develop the existing EIS signed plan, it took less than 2 years to decide that the public, who in good faith worked with the BLM, now has to go back to years of meetings and comments so you can allow an agency that did not bother to comment on the original EIS plan. the public can and will feel that no matter what they do or how much time they spend to comment and work with agencies like the BLM………………………………………………………………………………………………………………………………………… in the end it is a waste of time……… thus defeating the purpose of the public comment side of the NEPA process……… “	Section 1.1.2 has been revised to expand information about the RMP development process, and includes APS’ role in the process.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Jeff Gursh, AZOHVC and ATR	1276.33	LU	“1.5.2 Local jurisdictions: Note that the first 3 plans did not specifically limit or restrict but did not support or include corridors. As with APS, the City of Peoria did not bother to comment on or show BLM during the Existing EIS, any interest in a corridor on BLM in this area. City of Surprise, though did not specifically limit or restrict the transmission line corridors, was pragmatic about the location of lines and did comment to BLM on future plans in the surprise area. MAG and ADOT plans are after the signed 2010 EIS and RMP for this BLM area and should have at the least, commented to BLM on possible future corridor needs based on preliminary work on these reports. Alternative 2 or three would seem to be a better fit with the lack of concern from these agencies during original planning process for existing BLM EIS I RMP.	Section 1.1.2 has been revised to expand information about the RMP development process.
Jeff Gursh, AZOHVC and ATR	1276.34	NEPA	“1.8 Scoping Page 72-73 – AZOHVC , with membership of over 5000 and 11 different OHV organizations , OHV business groups , Arizona trail rider Organization and members as well as ASA4WD (2500 members) and somehow only 11 comments were received for recreation? Not all substantive or same comments?”	The text in the second paragraph following the Section 1.8 heading explains the information contained in Table 1.8-1. The heading for the column on the right in Table 1.8-1 has been revised to “Issues Identified” to address this comment.
Jeff Gursh, AZOHVC and ATR	1276.35	LU	“Page 74 Table Issues – In areas where there are currently no power lines or corridors avoid placement near homes This should not apply to sites that currently have corridors or substations or both near or in sight of residents, these home owners purchased homes with these utilities in place, the addition of new lines to existing systems or impacted areas should not affect the choice of alternatives for this project.”	Comment noted.
Jeff Gursh, AZOHVC and ATR	1276.36	SOC	“This is not addressed. AZOHVC and MC Dealers Assoc. submitted economic impact data and specific OHV store financials to show what area does currently generate. Page 156 chart shows unknown impact. You missed the point and the data. Please look at this data as an important factor in P.A. location.”	Section 4.10.2.2, Effects on Recreation, addresses potential adverse effects to socioeconomics associated with recreation in Arizona.
Jeff Gursh, AZOHVC and ATR	1276.37	AR	“2.4.1.3 Access roads page 92 – A permanent 14 foot road along transmission lines will cause extensive resource damage and allow access, no matter how well gated or closed off into areas that have previously been undisturbed. Habitat and resource loss will be extreme. The area in the proposed action on BLM lands is extremely rugged and will require extensive disturbance of ground to build thru canyons and drainage areas. Spur roads will cause additional damage and resource damage. This is another example of issues with land directly under lines and the long term maintenance. Rehabbing and reseed on areas outside the corridor will allow erosion and reduction in habitat permanently. These areas in other APS locations have shown to be prone to cross country travel, dust problem areas and resource damage from easy access to dump. The costs to relocate and rehab to a level to reduce these impacts and the cost to enforce the rules that would be need to protect this area should be passed on to the APS and a fund set up as future mitigation is needed.”	Mitigation was added to Section 4.9 designating the centerline access as an administrative route, which is intended to prohibit unauthorized recreational use of the ROW, and provide BLM authority to enforce the recreational use decisions. Recreation mitigation in Section 4.9 was expanded to specify locations for gates on the centerline to prevent unauthorized access along the centerline. Section 4.9 has been revised to emphasize that while the centerline access is closed to recreation, single- track users will be allowed to cross the centerline, ensuring continuity of loop trails and no loss of single- track trails. Recreation mitigation in Section 4.9 was expanded to include monitoring of the centerline by APS and patrolling of the ROW by BLM, enforcing the designation of the centerline as an administrative route.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Jeff Gursh, AZOHVC and ATR	1276.38	M&M	“Long term dust abatement would require an enormous amount of water. APS is willing to commit to long term dust management of these roads? The Cost should be included in any funding for EIS with BLM, funded by APS ( in a trust) to cover this expense.”	According to APS, long-term maintenance activities are very minor and infrequent. Undisturbed desert surfaces maintain a crust that does not require repeated application of water. Post-construction use of access roads is described as minimal. Disturbed unpaved roads and vacant areas will be maintained as required by Maricopa County Rule 310.01.
Jeff Gursh, AZOHVC and ATR	1276.39	GEN	“2.4.1.4 Temporary Use areas This is a huge loss of habitat and Vegetation. Damage from this type of work at each tower in the five mile north Corridor would require the closure of all OHV trails based on the 3 to one habitat formula applied to new OHV routes. How can BLM even consider the loss of this much habitat when combined with the centerline access road to be constructed? Example, the Mile Marker 14 area was rehabbed in 2012 to eliminate social parking and related damage. LP 2 wash had Boulder barriers installed to restrict access to Single track only. Will APS repay BLM for work destroyed with new power line center access road and pull sites?”	Section 4.16.3.1 specifies mitigation for impacts to Sonoran Desert Tortoise, which includes potential compensation for habitat loss.
Jeff Gursh, AZOHVC and ATR	1276.40	VEG	“This plan is for short term, where is the long term plan for centerline road and clear cut under towers? This will be a long term issue since each season clear cut will disturb the ROW area.”	The EIS contains a revised Appendix 2B, APS’ Transmission Vegetation Management Program. Additional clarification has been added to the EIS in Appendix 2A to specify how saguaros would be handled.
Jeff Gursh, AZOHVC and ATR	1276.41	VEG	“Hay bales, currently, noxious weeds are a big problem, weed free hay for horses has been a requirement on some FS lands for years, will the hay be sterile or weed free to help reduce this issue? OHv are required in some Areas on BLM lands to wash vehicles before use on those lands ……… its that important.”	Appendix 2A provides a description of the measures to be implemented for noxious weeds and includes certifying that all straw and/or hay would be weed free.
Jeff Gursh, AZOHVC and ATR	1276.42	VEG	“2.4.2.4 Clearing and grading Page 98 – Construction short term issues are big impacts, “clearing” of any kind including trampling, will leave area bare for years. The big issue from our stand point is the damage from continued long term TOPPING of trees and Saguaros and clearing vegetation under lines. This leaves a very unnatural look and are prone to erosion and dust issues. A trust should be setup to mitigate long term effects for BLM to address.”	The EIS contains a revised Appendix 2B, APS’ Transmission Vegetation Management Program. Additional clarification has been added to the EIS in Appendix 2A to specify how saguaros would be handled.
Jeff Gursh, AZOHVC and ATR	1276.43	M&M	“Funding from APS to pay for BLM LEO or park rangers should be included in any mitigation funds for long term monitoring and mitigation of damage from construction of this corridor.”	Recreation mitigation in Section 4.9 was expanded to include monitoring of the centerline by APS and patrolling of the ROW by BLM, enforcing the designation of the centerline as an administrative route.
Jeff Gursh, AZOHVC and ATR	1276.44	VEG	“Revegetation, we would as that more of the plant materials were salvaged rather than crushed or cut down. High value cacti (such as barrel, hedgehog, ocotillo, Saguaros), trees and scrub, should be boxed or removed in a manner to be used on BLM restoration projects nearby. Mature trees are needed to give wildlife safe havens and all this vegetation can bring back other areas thru rehab. APS should, at their cost, make available 25% or more of the usual destroyed plant material for restoration of other areas. We realize that this is not required now, but the damage to plants thru the current topping and crushing just is not acceptable. As a leader in the valley for conservation …….. this would seem to be a win win situation.”	The EIS contains a revised Appendix 2B, APS’ Transmission Vegetation Management Program. Additional clarification has been added to the EIS in Appendix 2A to specify how saguaros would be handled.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Jeff Gursh, AZOHVC and ATR	1276.45	AR	“2.4.2.9, Chart 2.4-4 from the chart, under Federal lands, your data shows a total of 44 acres or approx. 26 miles of 14 foot wide road … BLM requires: for each 1 mile of route opened, 3 miles of routes have to close or the equal to in acreage. That would equal over 79 miles of 14 foot wide road …. to mitigate habitat loss, just to build the centerline road and spurs, this does not include the clear- cut corridor.{BLM Fed lands column) Since you tell us in the EIS that no OHV routes will be closed where does the 79 miles come from? If not roads, then there should be a very high monetary cost to replace and mitigate the loss of this much habitat.”	Section 4.16.3.1 specifies mitigation for impacts to Sonoran Desert Tortoise, which includes potential compensation for habitat loss.
Jeff Gursh, AZOHVC and ATR	1276.46	M&M	“2.4.3 Operations and Maint. As noted in first section of this EIS, access roads and pads, ground clearing and topping maintenance and road repairs to access roads will make for long term issues with dust, habitat lose and access to areas previously undisturbed by public access. These a major concerns for the protection of resources on BLM lands. The cost to mitigate these issues for long term should be funded by a trust setup to cover these BLM expenses. Please see attached Corridor impacts document .”	Expanded mitigation is provided under specific resource sections in Chapter 4 and summarized in Section 2.9. According to APS, long-term maintenance activities are very minor and infrequent. Undisturbed desert surfaces maintain a crust that does not require repeated application of dust suppressants. Post- construction use of access roads is described as minimal. Disturbed unpaved roads and vacant areas would be maintained as required by Maricopa County Rule 310.01.
Jeff Gursh, AZOHVC and ATR	1276.47	OHV	This section gives APS the right to dictate use on public land in or near corridor. Compatible uses determined by APS would be allowed…… compatible is the key word. This has the potential to close OHV routes if APS feels it could harm or damage their property or safety of lines. That leaves OHV community at APS rules rather than the Federal rules that would apply to the existing area under the RMP or SRMA. Again the public has a hard time working and understanding theBLM rules, add in rules that apply to APS and then County PM 1 0 rules such as P27 and P28 or310.01 and no one will understand what is open or closed.””	The EIS analyzes impacts to the Affected Environment for existing recreational (and other uses) on BLM- managed public lands in Section 4.9. Any planned changes to existing uses are detailed and analyzed in the EIS. This section is referring to the potential for future land uses within the ROW, which would require BLM and APS approval.
Jeff Gursh, AZOHVC and ATR	1276.48	AR	“2.4.3.3 Permanent access road – Permanent is the key word. Nothing bladed and compacted as much as you will do to create and use the access centerline road will grow vegetation. Talk to any BLM representative on OHV damage and that the roads are permanent scars. This will be used by all users in area, from hunters to OHVers to equestrians. The surface will be disturbed and dust will be an issue as will safety to the public since you will only maintain to access your equipment. Funds set aside for BLM to deal with this issue have been mentioned above and should be seriously considered.”	Mitigation was added to Section 4.9 designating the centerline access as an administrative route, which is intended to prohibit unauthorized recreational use of the ROW, and provide BLM authority to enforce the recreational use decisions. Recreation mitigation in Section 4.9 was expanded to specify locations for gates on the centerline to prevent unauthorized access along the centerline. According to APS, long-term maintenance activities are very minor and infrequent. No routine maintenance activities for access roads is planned or anticipated.
Jeff Gursh, AZOHVC and ATR	1276.49	VEG	“Again, we would ask that rather than top or crush or clearcut, any high value plants such as Saguaros, Ocotillos and trees, be saved and transplanted to other BLM sites for rehab purposes. Rarely does the vegetation come back as described in text and the slash that is left from initial clear cutting in other locations is still visible years after the construction is done.”	The EIS contains a revised Appendix 2B, APS’ Transmission Vegetation Management Program. Additional clarification has been added to the EIS in Appendix 2A to specify transplanting procedures and requirements for saguaros.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Jeff Gursh, AZOHVC and ATR	1276.50	GEN	“2.4.3.5 Permanent disturbance – So along with the permanent road (centerline and spurs} all Shrubs, trees, large cactus, woody veg. and ground cover would be removed around towers … approx. 0.2 acres per pole. Permanent loss of habitat, permanent source of dust. These areas would be similar to social parking areas and camp sites………… something that if the public were to create would be closed and rehabbed by BLM as illegal damage from public that required fixing …….. again, we understand your rules and need, but public only sees damage that seems not to matter I n the area and will continue to do same.”	Rehabilitation of temporarily disturbed areas (such as around pole locations) would be required and is described in Section 2.4.4.4. The centerline access would be considered permanent disturbance and the route designated as an administrative route, which is intended to prohibit unauthorized recreational use of the ROW, and provide BLM authority to enforce the recreational use decisions.
Jeff Gursh, AZOHVC and ATR	1276.51	AR	“2.4.3.7 Permanent Disturbances – Chart 2.4.7 from the chart, under Federal lands, your data shows a total of 27 acres or approx. 13 miles of 14 foot wide road … BLM requires: for each 1 mile of route opened, 3 miles of routes have to close or the equal to in acreage. That would equal over 39 miles of 14 foot wide road….. to mitigate habitat loss, just to build the centerline road and spurs, this does not include the clear-cut corridor.(BLM Fed lands column) Since you tell us in the EIS that no OHV routes will be closed where does the 39 miles come from? If not roads, then there should be a very high monetary cost to replace and mitigate the loss of this much habitat. 2.4-4 chart shows 44 acres temporary which is much more likely based on other APS areas with access centerline roads and spurs. In either case, this is a large amount of lost habitat that must be mitigated or compensated for.”	Section 4.16.3.1 specifies mitigation for impacts to Sonoran Desert Tortoise, which includes potential compensation for habitat loss.
Jeff Gursh, AZOHVC and ATR	1276.52	SOC	“Though future homes would be impacted by the Carefree route, these homes and business would be moving into home built with the knowledge that the corridor was already there or on its way. Values of the home built after the installation of the corridor would not be affected only the value of the land before they were built.”	Impacts to private property that would be affected by Alternatives 2 and 3 were determined based on existing conditions for direct and indirect impacts; and based on plans for future development for cumulative impacts.
Jeff Gursh, AZOHVC and ATR	1276.53	VIS	“DEIS assumes OHV multiuse recreatlonists don’t care about what the area looks /Ike and those who do will have to live with it. This area’s natural beauty Is part of the attraction for the public to visit this location. We also see It as a big part of the States economy. The tourist Industry Is the only portion of the State Economy that has been fairly stable during the economic down tum. Thousands visit the Boulders from Out of State each year. A natural environment is a must for site seers and OHV alike.”	Statement of opinion. Section 4.9.2.2 addresses the impact of the project on the recreational experience. Impacts to the tourist industry are addressed in Section 4.10.
Jeff Gursh, AZOHVC and ATR	1276.54	SAAA	“2.5.4 Sub alternative ASLD lands – State Trust land sales benefit many groups , one of which is the public schools system. Allowing ASLD to select an alternate that does not affect the cost or the other land agencies concerned while allow for highest and best use of trust land seem a win win situation. We support ASLD alternative that allows for better use of ASLD property while having no affect on other agnecy proposals.”	Statement of preference.
Jeff Gursh, AZOHVC and ATR	1276.55	OHV	“Page 1561mpact indicator chart – Boulders OHV area is one of the most popular in State and certainly most popular in Maricopa County. Many OHV businesses are located in nearby Peoria and Wickenburg and Surprise area. In addition, gas stations, grocery stores and restaurants all rely heavily on OHV and recreation purchases from this area. The Boulders is one of just a hand full of OHV areas with single track. Impacts and closure of single track will greatly reduce the number of OHv visitors. An at least moderate magnitude of impact”	Section 4.10.2.2, Effects on Recreation, addresses potential adverse effects to socioeconomics associated with recreation in Arizona.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Jeff Gursh, AZOHVC and ATR	1276.56	OHV	“Potential Benefit show is new recreational access .•..•…. •• from what? New corridor roads that would be open only to non-motorized? You show access to the corridor ROW as illegal for OHV but will encourage other users to access? The negative aspect is change in quality of the recreational experience … .for whom? The Negatives for the OHV community is closure for nonmotorized it would be a tower/ visual. You missed the impact here. See page 462, 463 on closed to OHV.	The subject text was removed from the EIS.
Jeff Gursh, AZOHVC and ATR	1276.57	OHV	“2.9.8 Recreation and Special designation You state that BLM would not allow new single track to be created to offset loss of single track. You state that BLM will not allow APS to use single track routes for construction access. YET, on page 462, you explain “only” 0.8 miles of single track will be used for access as well as no OHV use in ROW. All single track in this area is connected to by routes that follow and are in the ROW from LP5 and the Boulders OHV area in the West. Your claim of no impact to single track is incorrect .. .in your own document. If OHV use is banned from ROW and close adjacent routes are closed to OHV as is the line access route under the wires, no OHV routes could be in or thru the ROW. This will close access and routes east of Quintero and create dead end trails that will not be dead ends for long.”	Section 4.9 has been revised to emphasize that while the centerline access is closed to recreation, single- track users will be allowed to cross the centerline, ensuring continuity of loop trails and no loss of single- track trails.
Jeff Gursh, AZOHVC and ATR	1276.58	OREC	“3.9.2 Recreation overview – You mention undeveloped recreation as being unaffected and include hiking, mountain biking, horseback riding target shooting and dispersed OHV recreation. Then you say that OHV recreation is the only one to talk about because it is the one that will be impacted? All recreation share OHV trails, if you close routes you close to all or you take from one user, in this case Single Track MC I OHV, and give to non-motorized horse, hike and bike. All users get to their recreation in a vehicle, this makes all users and OHVer at one time or another. How do the horsemen access the area if roads are closed? Since all ROW and centerline road is closed to OHV use and non-motorized such as horse , hike and bike are allowed , you have trade away OHV trails for this preferred alternative………. contradicting EIS in that no OHV trails would be lost.”	Section 4.9 has been revised to emphasize that while the centerline access is closed to recreation, single- track users will be allowed to cross the centerline, ensuring continuity of loop trails and no loss of single- track trails.
Jeff Gursh, AZOHVC and ATR	1276.59	OHV	“3.9.4.1 OHV recreation – One of the most popular single track rides for MC OHV has been the routes LP1 ,2 and 3 and the surrounding areas 2 track that allows the single track to be connected into a looped , long distance ride. This area has historically been part of a permitted OHV MC enduro event which would no longer have these historic route available. The Preferred Alternate cuts the access to these trails and all connectivity to the south end of these routes for the ability to make loops. All access from Boulders OHV area from LP5 will be lost. In addition, all hunting access by motorized access from MM14 will be lost. This is a far cry from “no Motorized use will be affected” ( ROW and centerline road closed to OHV use) as stated in long term impacts. Please see attached map# .”	Section 4.9 has been revised to emphasize that while the centerline access is closed to recreation, single- track users will be allowed to cross the centerline, ensuring continuity of loop trails and no loss of single- track trails.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Jeff Gursh, AZOHVC and ATR	1276.60	OHV	“3.9.4.1 OHV recreation – Page 276……. Single track is a misnomer, M.G. use Jeep Roads, ATV roads and single track to create connections and looped trails systems. The issue here is, that should you widen a two track or a Tertiary road to allow equipment, you allow all users to access that route from an area that may not have had access to that route from full size OHV (larger than MC) Single track trails are a rare occurrence on public lands, they are hard to maintain (hand crews) and with this rarity, connecting existing single track together is based on access to wider trails and routes to make the connections. Your document shows that APS will close the ROW and parallel access route to OHV . This will greatly reduce the connectivity of existing area trails to loop trails system or eliminate it all together. This is a far cry from no long term changes as show on page 166.”	Section 4.9 has been revised to emphasize that while the centerline access is closed to recreation, single- track users will be allowed to cross the centerline, ensuring continuity of loop trails and no loss of single- track trails. Recreation mitigation in Section 4.9 was expanded to specify locations for gates on the centerline to prevent unauthorized access along the centerline. BLM will work with APS to develop a Construction Access Plan to definitively identify access routes on BLM-managed public lands, particularly north of SR 74. Construction access north of SR 74 is envisioned to be limited such that no single-track OHV routes would be used, and a large portion of this area is closed to four-wheel OHV recreation.
Jeff Gursh, AZOHVC and ATR	1276.61	OREC	“3.9.4.2 Target shooting – Though popular, when located in high use areas or unmanaged, impacts are severe. Centerline road and ROW will open up areas that had no access before. The close proximity to existing urban interface and future growth of area in population will create long term issues that will require tremendous amount of resources and funds from BLM to manage. APS should, put in trust, funds to cover these mitigations, See Table Mesa area issues and resources cost from BLM Hasyampa field office.”	Recreation mitigation in Section 4.9 was expanded to specify locations for gates on the centerline to prevent unauthorized access along the centerline. Mitigation was added to Section 4.9 designating the centerline access as an administrative route, which is intended to prohibit unauthorized recreational use of the ROW, and provide BLM authority to enforce the recreational use decisions.
Jeff Gursh, AZOHVC and ATR	1276.62	SOC	“3.10.6 Recreation Expenditures – Many businesses moved to the Peoria, Surprise, Wickenburg and other nearby Cities and towns … ….. because of the access for public recreation … especially OHV recreation. This benefits city tax base (as shown). Other business types benefit too. Gas stations, restaurants, hotels, grocery stores, repair shops.ect .. All benefit from OHV use in the area. Though you seem to think that nothing will change( depending on where you read in the report) or that only the visual aspect will change, tht is not the case. The ROW and centerline droad is closed to all OHV use ( all motorized use of any kind). This causes the cut off of routes East of LP 5 and the dead ending of LP1 2 and 3. All are part of long distance single track and part of past Permitted events. This will be a big impact to business that caters to Dirt bike sales, repairs and accessories.”	Section 4.9 has been revised to emphasize that while the centerline access is closed to recreation, single- track users will be allowed to cross the centerline, ensuring continuity of loop trails and no loss of single- track trails. Section 4.10.2.2, Effects on Recreation, addresses potential adverse effects to socioeconomics associated with recreation in Arizona.
Jeff Gursh, AZOHVC and ATR	1276.63	GEN	“The original EIS considered the area important enough to rate very highly the need to keep the visual impacts low. The new EIS, to place Corridor on north side of HWY 74, changes that in a big way. For the public, it shows that there is no “big business” or City that cannot change important decisions such as EIS or EA’s to get what they want. Whereas the public is stuck following the rules set up in the EA’s and EIS to follow. We have no recourse, as APS, to force you to change a Signed EIS it just would not happen. As I mentioned earlier, this will greatly reduce the number of comments on future EA, ElS, RMPs and planning for both BLM and FS. This is not the way to run the Public side of NEPA for comments.”	Section 1.1.2 has been revised to expand information about the RMP development process.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Jeff Gursh, AZOHVC and ATR	1276.64	VIS	“The BLM is considering projects for alternative power and public works all over the State. Solar Fields and wind farms will take away hundreds of miles of OHV multiuse trails and have a major impact on Visual resources. How do all these “new “pieces of the landscape fit into Visual Resource management practices? Will they be thrown out to allow more and bigger impacts too? Visual Impacts are part of every NEPA project and was part of the original EA for this area. Please reconsider this impact and the Original EA’s needs when deciding on the Power line placement Alternative.”	Any project for alternative power or other public works on BLM-managed public lands would require environmental analysis prior to project implementation. The EIS considers the cumulative impact of the proposed project in conjunction with past, present, and reasonably foreseeable projects in Section 4.19.
Jeff Gursh, AZOHVC and ATR	1276.65	SOC	“3.10.8.2 Recreation use – See attached ASU /ASP Economic Impact study and the multiplier effect. The point should be made that though the amount spent per trip may only decrease by 2.2 %, WHERE the money is spent WILL change. Reducing the single track or closing the areas east will move OHV users to another area. This may not seem an issue for those who are not fans of OHV use, but it will greatly affect local business. Look at the closure of the granite Mountain OHV area in north Scottsdale. The city closed a multiagency OHV recreation area, with in a year of closure, two OHV dealers moved out of North Scottsdale area to be near an open OHV recreation site (Peoria} … the Boulders.”	Section 4.9 has been revised to emphasize that while the centerline access is closed to recreation, single- track users will be allowed to cross the centerline, ensuring continuity of loop trails and no loss of single- track trails.
Jeff Gursh, AZOHVC and ATR	1276.66	SOC	“3.12.2 HWY 74 ROW – According to some land owners, the impact to the saleablility of their land would be affected by the placement of Corridor south of HWY 7 4. Please consider the impact of a 10 lane freeway in your decision. As an example, look at the Anthem outlet malls and subdivisions where 2 corridors now existing along hwy 17. There is no shortage of home buyers or business in this area and is a very popular area to live. Homes were built around and under lines. The land just south of Hwy 74 is currently vacant, with the future hwy and if lines place south, anyone buying would know up front of the lines. It is a different story in areas with existing homes and this should be considered in the other portions of the plan.”	The cumulative effect of the transmission line along with community development is considered in Section 4.19, cumulative impacts.
Jeff Gursh, AZOHVC and ATR	1276.67	LU	“3.14.1 Laws, Ordinances – The City of Peoria Policy 3.B.4 would apply to Visual resources, Quote” Promote the use of EXISTING utility and major transportation corridors for new overhead utility siting to minimize visual and environmental impacts”. That’s a big statement and would do more than imply that, like the BLM original EIS for the area north, this is an important visual resource for Peoria’s future Preserve and open space. Please consider this in your Decision.”	The Proposed Action/Preferred Alternative is the only alternative in the EIS that would comply with the City of Peoria’s general plan.
Jeff Gursh, AZOHVC and ATR	1276.68	SSS	“3.16.4 Threatened, Endangered – Please refer to our statements on BLM Tortoise habitat, 3 to 1 match for new roads or open areas. This is the rule of thumb to mitigate damage to habitat.”	Section 4.16.3.1 specifies mitigation for impacts to Sonoran Desert Tortoise, which includes potential compensation for habitat loss.
Jeff Gursh, AZOHVC and ATR	1276.69	OHV	“Page464 – Correct on the notion that All users will create new routes and cause a long term issue for BLM management of area affected by Corridor. APS should be required as part of the long term mitigation to set up a trust for long term mitigation and construction of new routes to replace trails and connectivity. Wrong assumption here. You created a road and ROW that Included access roads and trails to looped single track routes. You state that it will be hard to keep MC off but single track MC won’t like to run the road. WRONG. Single track will use It evety trip they take to access the single track trails that you isolated with the corridor.”	Section 4.9 has been revised to emphasize that while the centerline access is closed to recreation, single- track users will be allowed to cross the centerline, ensuring continuity of loop trails and no loss of single- track trails.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Jeff Gursh, AZOHVC and ATR	1276.70	AR	“Target shooting is one of the biggest issues for the BLM and FS. This area has had little target shooting due to its past in accessibility. The Corridor ROW and center line road will open area up to unmanaged shooting. This will cause the loss of vegetation and trash dumping as well as create an environmental issue with lead, so near to water sources. Funds need to be put in trust for BLM to mitigate these issues as well as cover LEO costs to enforce rules to keep users out of ROW and Centerline road.”	Recreation mitigation in Section 4.9 was expanded to specify locations for gates on the centerline to prevent unauthorized access along the centerline. Mitigation was added to Section 4.9 designating the centerline access as an administrative route, which is intended to prohibit unauthorized recreational use of the ROW, and provide BLM authority to enforce the recreational use decisions. Recreation mitigation in Section 4.9 was expanded to include monitoring of the centerline by APS and patrolling of the ROW by BLM, enforcing the designation of the centerline as an administrative route.
Jeff Gursh, AZOHVC and ATR	1276.71	OHV	“Page 481…You state in the comments there would be a moderate to heavy impact to long term single track OHV use and then say in other areas that it would only be short term. “	Section 4.9 has been revised to emphasize that while the centerline access is closed to recreation, single- track users will be allowed to cross the centerline, ensuring continuity of loop trails and no loss of single- track trails. In Section 2.9, listed mitigation measures are derived from the direct and indirect impact analysis based on the Proposed Action, which includes the use of single-track trails for construction access, which would result in long-term impacts. However, Section 4.9.3, recreation mitigation, specifies that single track trails would not be allowed for construction access, thus impacts to single-track OHV trails would be short-term during construction.
Jeff Gursh, AZOHVC and ATR	1276.72	OHV	“4.19.10 – Again we see a contradiction from the language in the PA. This state that BLM could abandon some single track. The true problem is that the corridor will bring a new 14 foot wide road that will be impossible to close to OHV use. It will cut existing OHV corridors and eliminate the connectivity to other areas that are a part of the looped trails system on this SRMA area. Single track is rare as we have mentioned in the last 600 pages numerous times. the fact that your P.A. jumps the hwy 74 corridor and runs the whole length of the SRMA shows just how little the OHV and recreation public counts as a consideration for following what we thought was a well designed and had ample time for all concerned to comment.”	Section 4.19.10 was revised to eliminate reference to loss of single-track trail.
Jeff Gursh, AZOHVC and ATR	1276.73	OHV	“Since no OHV are allowed in ROW (page 154,462,604 no OHV use or closure), this will close any route in the ROW and cut all access from LP5 and main access to single track from Boulders OHV area. This will not just eliminate the single track East of Quintero Golf Course but create a new centerline road (power line rd.) and clear cut corridor under lines. In addition, access roads for construction have historically been left to access these previously inaccessible areas. On page 166, you note that there will be no long term closure of OHV routes and that it will only be a short term impact with no loss of single track , yet on page 462 you state that at least 0.8 miles (7%) of single track will be used for access road and lost and a moderate to major impact to OHV /Single track users.”	Section 4.9 has been revised to emphasize that while the centerline access is closed to recreation, single- track users will be allowed to cross the centerline, ensuring continuity of loop trails and no loss of single- track trails. The referenced area is already closed to most four-wheel OHV access.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Jeff Gursh, AZOHVC and ATR	1276.74	OHV	“Page 464 notes that though the center line under line road and ROW is closed to OHV access and use, it may be difficult to keep users out (note: , only non-motorized are restricted) you are correct on the notion that All users will create new routes and cause a long term issue for BLM management of area affected by Corridor. APS should be required as part of the long term mitigation to set up a trust for long term mitigation and construction of new routes to replace trails and connectivity.”	Section 4.9.3, recreation mitigation was expanded; however, the EIS stated that should mitigation prove ineffective, APS would be required to institute new/additional mitigation to prevent unauthorized access.
Jeff Gursh, AZOHVC and ATR	1276.75	OHV	“Continuing on this page, you are wrong in your assumption about single track users. You created a road and ROW, closed to motorized, that included access roads and trails to looped single track routes. You state that it will be hard to keep MC off but single track MC won’t like to run the road. WRONG. Single track will use it every trip they take to access the single track trails that you isolated with the corridor.”	Section 4.9 has been revised to emphasize that while the centerline access is closed to recreation, single- track users will be allowed to cross the centerline, ensuring continuity of loop trails and no loss of single- track trails.
Jeff Gursh, AZOHVC and ATR	1276.76	OHV	“Though you state no closure on page 166, you consistently contradict this in charts and text thru out the remaining document.”	In Section 2.9, listed mitigation measures are derived from the direct and indirect impact analysis based on the Proposed Action, which includes the use of single-track trails for construction access, which would result in long-term impacts. However, Section 4.9.3, recreation mitigation, specifies that single track trails would not be allowed for construction access, thus impacts to single-track OHV trails would be short-term during construction.
Jeff Gursh, AZOHVC and ATR	1276.77	OHV	“Page 604 – project could cause BLM to abandon…………. this is a far cry from no long term Affect…”	Section 4.19.10 was revised to eliminate reference to loss of single-track trail.
Jeff Gursh, AZOHVC and ATR	1276.78	SOC	“OHV recreation is a 4.3 BILLION dollar a year industry for AZ economy, we consider this as a direct Impact to that recreation and tourism Industry.”	Section 4.10.2.2, Effects on Recreation, addresses potential adverse effects to socioeconomics associated with recreation in Arizona.
Jeff Gursh, AZOHVC and ATR	1276.79	OREC	“Both Peoria and Maricopa County Parks are developing recreation areas north of Hwy 7 4 in this area. Interconnecting trails and routes in and thru affected area will be greatly impacted or completely block In the case of OHV use. Please reconsider and select alternate 3.”	Section 4.9 has been revised to emphasize that while the centerline access is closed to recreation, single- track users will be allowed to cross the centerline, ensuring continuity of loop trails and no loss of single- track trails.
Jeff Gursh, AZOHVC and ATR	1276.80	OHV	“Who would foot the bill to do all the needed planning , repairs and law enforcement to recover area? OHV users currently contribute $25 per OHV to State Parks Fund to keep areas open…………………………………………………………………………………………………………………………………………………. we should not have to pay to repair damages from APS placement of ROW corridor.”	Mitigation was added to Section 4.9 designating the centerline access as an administrative route, which is intended to prohibit unauthorized recreational use of the ROW, and provide BLM authority to enforce the recreational use decisions. Recreation mitigation in Section 4.9 was expanded to specify locations for gates on the centerline to prevent unauthorized access along the centerline. Section 4.9 has been revised to emphasize that while the centerline access is closed to recreation, single- track users will be allowed to cross the centerline, ensuring continuity of loop trails and no loss of single- track trails. Recreation mitigation in Section 4.9 was expanded to include monitoring of the centerline by APS and patrolling of the ROW by BLM, enforcing the designation of the centerline as an administrative route.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Jeff Gursh, AZOHVC and ATR	1276.81	SOC	“We ask that a trust fund be setup , funded by APS, to mitigate the long term cost of the corridor impacts on PUBLIC BLM lands. This could cover the cost of Law enforcement, and area park ranger, relocation of OHV and multiuse routes, mitigation of loss of trail continuity( loop opportunities) resource mitigation form long term clear cutting and topping as well as BLM in house costs for engineering , supervisory and specialist time. We also ask that NO COST TO BLM be incurred for the amendment to the existing EIS nor any future EIS, EA or surveys required to mitigate damage or issues from the placement of the corridor………. if located on BLM lands.”	Mitigation was added to Section 4.9 designating the centerline access as an administrative route, which is intended to prohibit unauthorized recreational use of the ROW, and provide BLM authority to enforce the recreational use decisions. Recreation mitigation in Section 4.9 was expanded to specify locations for gates on the centerline to prevent unauthorized access along the centerline. Section 4.9 has been revised to emphasize that while the centerline access is closed to recreation, single- track users will be allowed to cross the centerline, ensuring continuity of loop trails and no loss of single- track trails. Recreation mitigation in Section 4.9 was expanded to include monitoring of the centerline by APS and patrolling of the ROW by BLM, enforcing the designation of the centerline as an administrative route. Additional clarification has been added to the EIS in Appendix 2A to specify how saguaros would be handled.
Jeff Gursh, AZOHVC and ATR	1276.82	AR	“AZOHVC Utility Corridors and recreation areas As was seen when the Gas Pipe Line was built along 117 on BLM lands(Table Mesa Area OHV/Multiuse area) and on the Tonto and Prescott FS APS corridors , the trail systems for all users were directly and adversely affected by the new road as well as power line corridor and accompanying clear cut and topping of vegetation in the corridor .. This creates a huge problem with new trails being created from the access roads to build the power lines. These roads would provide access to areas unreachable before construction, causing further resource damage. Similar APS projects on Tonto National Forest and Prescott National Forest show long term issue with the permanent access roads and long term clear cutting and topping maintenance these ultility corridors require.”	Recreation mitigation in Section 4.9 was expanded to specify locations for gates on the centerline to prevent unauthorized access along the centerline. Mitigation was added to Section 4.9 designating the centerline access as an administrative route, which is intended to prohibit unauthorized recreational use of the ROW, and provide BLM authority to enforce the recreational use decisions. Recreation mitigation in Section 4.9 was expanded to include monitoring of the centerline by APS and patrolling of the ROW by BLM, enforcing the designation of the centerline as an administrative route. The EIS contains a revised Appendix 2B, APS’ Transmission Vegetation Management Program. Additional clarification has been added to the EIS in Appendix 2A to specify how saguaros would be handled.
Jeff Gursh, AZOHVC and ATR	1276.83	Out of Scope	“The BLM is considering projects for alternative power and public works all over the State. Solar Fields and wind farms will take away hundreds of miles of OHV multiuse trails and have a major impact on Visual resources. How do all these “new” pieces of the landscape fit into Visual Resource management practices? Visual Impacts are part of every NEPA project and was part of the original EA for this area. Please consider this impact and the Original EA’s needs when deciding on the Power line placement.”	The EIS considers the cumulative impact of the proposed project in conjunction with past, present, and reasonably foreseeable projects in Section 4.19.

COMMENTOR NAME

COMMENT ID NO.

COMMENT TYPE

COMMENT

RESPONSE TO COMMENT

Jeff Gursh, AZOHVC and ATR

1276.84

SOC

“Estimated costs based on current projects on BLM lands to mitigate type of impacts common in this EIS ROW proposed Preferred Alternative on BLM lands inside the SRMA and original EIS.

Costs

*Dust treatment per mile (Durasoil dust control fluid) Road 20 foot wide $30,000.00/ mile

*Dust treatment access roads. This is an engineered road that would allow BLM to meet PM10 ordinances for 20 % opacity test. Typical for access road to parking areas. $70,000.00 I mile for 20 foot road.

*Rehab per acre, includes re-contour of land, native seed, replanting , soil stabilizer and crusting agent.

$4000.00/acre (less design and NEPA and survey costs)

*Close areas to public access, this varies with terrain. Anything from gates and fences to boulders and steel bollards can be needed. $1000.00 to $15,000.00

*Cost of law enforcement and or Park ranger…… this will vary based on proximity to urban

interface.

LEO , multiple days per month $60,000.00/ year, Park Ranger $35,000.00/year.

*Signage, this would include PSAs , maps and or literature to educate the public on staying on trails and out of the ROW and centerline roads and spurs. $12,000.00( In the Table Mesa Recreation area, we average $380.00 in replacement signs per month).

*Relocate routes that have been closed due to power lines ROW and Centerline road. Though not typical, APS is showing this ROW closed to OHV and Motorized traffic. $12,000.00 to $15,000.00 per mile ( USFS Trails Unlimited trail construction Enterprise team average costs)

*We will assume that both the Quintero and MM14 rehabbed sites will be damaged during construction based on access road maps in EIS. These areas were done under grants from AZ. State Parks and required BLM to maintain areas for term of grants. APS should be required to follow these special rehab areas as they were part of new procedures to test long term plant growth and rehab procedures.

We have no cost figures on the replacement of Tortoise habitat or the loss of habitat and highvalue Cacti and plants but do know BLM requires a 3 to 1 match for the loss of tortoise habitat. That requires that for every mile of road opened , 3 miles of road in similar or higher tortoise habitat has to be closed to allow construction. In some cases, BLM will allow a monetary amount to be used in lieu of the 3 to 1 requirement.

The EIS contains a revised Appendix 2B, APS’ Transmission Vegetation Management Program.

Section 4.16.3.1 specifies mitigation for impacts to Sonoran Desert Tortoise, which includes potential compensation for habitat loss.

Additional clarification has been added to the EIS in Appendix 2A to specify how saguaros would be handled.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Jeff Gursh, AZOHVC and ATR	1276.84 (Continued)	SOC	*We would ask that rather than trampling , clear cutting or topping , that APS box and move trees, Relocate high value Cacti and other small high value plants, to BLM locations that need this type of vegetation for rehab of other BLM sites. This can be used to close old access roads or ROW Spur roads, as well as replant disturbed areas. AZOHVC has worked with MCDOT and contractors to acquire these types of plant to successfully rehab damaged areas and reduce PM 10 dust problems… Please consider this rather than the current practice of topping. This is just a short list of long term mitigation costs that BLM will incur with placement of ROW on north side of Hwy 74.”
Jeff Gursh, AZOHVC and ATR	1276.85	OHV	“Blue route is proposed new single track to reconnect from LP5 Boulders OHV area trail loops. This uses a combination of old existing route and new construction. Would close MM14 jeep road from HWY 74 to Admin only to reduce the issues with full size OHV trying to access single track. Mine access thru locked gate would be only full size access and only on jeep route to mine.”	Section 4.9 has been revised to emphasize that while the centerline access is closed to recreation, single- track users will be allowed to cross the centerline, ensuring continuity of loop trails and no loss of single- track trails. Replacement single-track trail would not be required.
Jeff Gursh, AZOHVC and ATR	1276.86	VEG	“…Topping is the greatest visual impact to the Saguaros. This is something the public has a hard time justifying…note that the chain sawed arms have lost the ‘flesh’…”	The EIS contains a revised Appendix 2B, APS’ Transmission Vegetation Management Program. Additional clarification has been added to the EIS in Appendix 2A to specify how saguaros would be handled.
Jeff Gursh, AZOHVC and ATR	1276.87	VEG	“This is the Tonto again…Note that 2 of the four Saguaros are dead or dying…Of the 89 Saguaros that were ‘topped’, 35 are dead and an additional 9 are not close behind.”	The EIS contains a revised Appendix 2B, APS’ Transmission Vegetation Management Program. Additional clarification has been added to the EIS in Chapter 2A to specify how saguaros would be handled.
Jeff Gursh, AZOHVC and ATR	1276.88	VEG	“Clear cutting and topping in 2009 allowed users of all kinds (horse, hike, OHV) to create new trails, jumps, race tracks and generally make managing the ROW very expensive. It is difficult to keep users on a road or trail when there is no vegetation or natural terrain to limit them to the route. Signing to keep users on routes is also a big expense.”	Recreation mitigation in Section 4.9 was expanded to specify locations for gates on the centerline to prevent unauthorized access along the centerline. Mitigation was added to Section 4.9 designating the centerline access as an administrative route, which is intended to prohibit unauthorized recreational use of the ROW, and provide BLM authority to enforce the recreational use decisions. Recreation mitigation in Section 4.9 was expanded to include monitoring of the centerline by APS and patrolling of the ROW by BLM, enforcing the designation of the centerline as an administrative route. The EIS contains a revised Appendix 2B, APS’ Transmission Vegetation Management Program. Additional clarification has been added to the EIS in Appendix 2A to specify how saguaros would be handled.
Jeff Gursh, AZOHVC and ATR	1276.89	AR	“New roads show up as erosion from little to no vegetation allows water to cut thru open space and damage roads.”	Appendix 2A contains BMPs to minimize potential erosion impacts and additional mitigation measures have been added to Section 4.9.
Jeff Gursh, AZOHVC and ATR	1276.90	VIS	“Visual impacts are severe. This type of topping and clear cutting drastically alter the natural look o f the area and create a negative experience when viewing the damaged Saguaros. The chain saw cut plants and Cactus show the destruction and this is especially an issue with Saguaros with there limited habitat and slow growth.”	The EIS contains a revised Appendix 2B, APS’ Transmission Vegetation Management Program. Vegetation management specified in the EIS would minimize visual impacts. Additional clarification has been added to the EIS in Appendix 2A to specify how saguaros would be handled.

COMMENTOR NAME	COMMENT ID NO.	COMMENT TYPE	COMMENT	RESPONSE TO COMMENT
Jeff Gursh, AZOHVC and ATR	1276.91	AR	“Just west of the Tonto National Forest is the former Granite Mountain Multiuse Recreation area. This area is now a preserve for the City of Scottsdale. In 2009, this was a single 10 foot wide road. In December of that year, APS clear cut under the towers and more than 90 feet on each side of the wire. This created an open ROW that invited motorhomes, campers and new trails that could not be restricted. Though the area is non-motorized, as you can see the traffic is still present. Campers and nature tours use the area daily.”	Recreation mitigation in Section 4.9 was expanded to specify locations for gates on the centerline to prevent unauthorized access along the centerline. Mitigation was added to Section 4.9 designating the centerline access as an administrative route, which is intended to prohibit unauthorized recreational use of the ROW, and provide BLM authority to enforce the recreational use decisions. Recreation mitigation in Section 4.9 was expanded to include monitoring of the centerline by APS and patrolling of the ROW by BLM, enforcing the designation of the centerline as an administrative route. The EIS contains a revised Appendix 2B, APS’ Transmission Vegetation Management Program. Additional clarification has been added to the EIS in Appendix 2A to specify how saguaros would be handled.
Jeff Gursh, AZOHVC and ATR	1276.92	SOIL	“..the BLM Table Mesa Multiuse / OHV recreation area… is also home to a APS corridor and a gas pipe line corridor. In 2010, APS clear cut all vegetation from the ROW. BLM had just finished layouts for new OHV and Multiuse trails that crossed under the lines and thru the ROW. Once the clear cutting and topping were completed by APS, the new routes had little to no vegetation to keep users on the route. There was nothing to restrict them from going cross country. This cross country travel breaks the crust of the soil, damages plants that hold the soil together and creates a PM10 dust issue. It is also a big impact for managing agency.”	See rationale for ID No.1276.91.
Jeff Gursh, AZOHVC and ATR	1276.93	OREC	“This is the BLM Table Mesa area Spur road from access road. Shooters have taken the spur and turned the whole hillside into a shooter site, note all vegetation scoured from hillside by bullets. This area had to be fenced and signed and has regular BLM LEO and ranger patrols to keep closed. This is a huge expense to BLM and should be covered by APS as a long term mitigation affect from ROW.”	See rationale for ID No.1276.91.
Tom Mindak	1277.1	OPP ALT3	“I’m a home owner in Trilogy of Vistancia, Peoria, Arizona. Please vote no for installing power lines in our area.”	Statement of preference.
Walter “Skip” Zahlmann	1278	UC	Content unrelated to analysis
Walter “Skip” Zahlmann	1279	INFO	Request for wildlife studies, no comment	Request for information is beyond the scope of the BLM.

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