88063961
Draft
Record of Decision
For the
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MAY 1984
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L35
1984b
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U.S. Department of the Interior
Bureau of Land Management
El Centro Resource Area
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ELM CA TD 84 011 3080
DRAFT
DECISION DOCUMENT
FOR THE
TABLE MOUNTAIN STUDY AREA
WIND ENERGY DEVELOPMENT
Bureau of Land Management
Library
Bldg 50 Denver Federal Center
Denver, CO 80225
Gerald E. Hillier
District Manager
Roger D. Zortman
Area Manager
TABLE MOUNTAIN WIND ENERGY DEVELOPMENT
DRAFT RECORD OF DECISION (ROD)
CA-14633
I. Proposed Action
Preliminary results of a California Energy Commission wind resource study for
San Diego County indicate that the Table Mountain area may have a high poten¬
tial for wind-generated electrical power. An average wind speed of over 15
mph ranks part of the Table Mountain area as one of the top four sites in San
Diego County for wind energy development. Private developers have expressed an
interest in utilizing public lands in this area for wind energy development.
The Bureau of Land Management administers approximately 6,500 acres in the
Table Mountain area. The goal of this action is to determine which of these
lands are suitable for wind energy development.
An Environmental Assessment (EA) has been prepared to determine the area's
suitability for development. The parcels identified for development in this
Draft Record of Decision were based on the findings of the EA
Following approval of this Record of Decision, competitive bidding for develop¬
ment rights on the approved parcels will be conducted. This auction will be
announced in regional papers shortly after publication of the final decision.
Only those approved parcels presently unencumbered by applications would be
available. Conditional rights-of-way grants will be issued to successful
bidders, with the caveat that further site-specific EAs may place additional
constraints or mitigations on development. The successful bidders will be
required to submit a plan of development within twelve months and to prepare a
site-specific EA on their plan of development. The plan of development/EA will
address areas of permanent and temporary disturbance, and location of turbines,
roads, and transmission lines.
BLM will use the site-specific EAs as the primary tool for making determina¬
tions in the followin' three areas:
-The sensitivity of the study area to wind-development-related intrusions;
-The need for further study through an Environmental Impact Statement;
-Additional site-specific mitigation measures.
II. Legal Constraints
San Diego Gas and Electric Company (SDG&E) has the California Public Utilities
Commission (CPUC) license for providing power to San Diego and the region.
Under the Public Utilities Reaulatory Act of 1978, utilities such as SDG&E must
interconnect all power from wind enemy sources into their existing utility
grid. The developer would be required to transmit the power to SDG&E's nearest
substation for interconnection. The nearest substation to Table Mountain is
approximately fifteen miles to the west.
III. Issues
The major issues associated with granting rights-of-way for wind energy deve¬
lopment in the Table Mountain Study area would be the impacts of development on
the area's cultural, visual, wildlife, and wilderness resources. Each poten
tial conflict is described in detail below. Resolutions to the conflicts
are presented in section VI.
Cultural Resources
Approximately 3,960 acres of the study area are included in an Area of Critical
Environmental Concern (ACEC) designated by the 1981 Eastern San Diego County
Management Framework Plan (MFP) in recognition of the area's outstanding
cultural values. The Table Mountain Archaeological District, located in the
northern portion of the study area and within the ACEC,is listed on the
National Register of Historic Places. The Jacumba Discontiguous District, in
the southern portion of the study area, has been evaluated and determined
eligible for inclusion on the Register.
Over 200 archaeological sites have been recorded in the area. The sites
collectively represent an unparralleled concentration of prehistoric habitation
and workshop locations. The area is archaeologically unique. The coincident
occurence of biotic and geologic factors have resulted in a remarkable archaeo¬
logical record. There is no similar area in Southern California. Table
Mountain is also noteworthy because of its special significance for Native
Americans due to shamanistic links to the mountain and the area's status as a
focal point for use. As a result, maintaining the area's environmental setting
and character is very important. How would development affect existing sites
and research potential on Table Mountain? Would development be compatible
with Native American sacred values on the mountain itself? Would the environ¬
mental and visual integrity of the mountain be significantly effected by wind
energy development?
Visual Resources
Based on Table Mountain's good (Class B) scenic quality, moderate-to-high
visual sensitivity, and the high volume of use on Interstate 8. + h» a n^th
of the hiahway was assianed to Visual Resource Management (VRM) Class II by the v
1981 MFP. In this class, changes in form, line, color, and texture of the
landscape caused by development should not be evident. Contrasts resulting
from land uses may be seen but should not attract attention. South of the #
highway, public lands were assigned to VRM Class IV. In this class, visual
contrasts may attract attention and be a dominant feature of the landscape in
terms of scale. These guidelines are recommendations only and are not binding
on management. Would development create landscape and contrast changes in
excess of those recommended in each class area?
Wildlife
The diversity of wildlife species inhabiting the Table Mountain Study Area is
quite high. Peninsular Bighorn Sheep are found just to the west and north of
the area, and isolated sightings have been made within the study area over the
last several years. Would wind energy development negatively effect any
species in this area, particularly Bighorn sheep (for example, inducing greater
levels of stress)?
Wilderness
The former Table Mountain Wilderness Study Area (WSA) is located within the
study area. By Federal Register publication on December 30, 1982, the Secre- *■
tary of the Interior removed certain lands administered by BLM from their
status as Wilderness Study Areas, including WSAs of less that 5,000 acres.
This included the 958-acre Table Mountain unit. Subsequent litigation on the
Secretary's order currently is unresolved. However, as a result of a prelimi¬
nary injunction on September 9, 1983, these areas are being managed to protect
their wilderness values until the litigation is resolved.
2
Therefore, development on lands within the former Table Mountain WSA is subject
to the requirements of the non-impairment criteria of the BLM's Interim Manage¬
ment Policy and Guidelines for Lands Under Wilderness Review . Actions must be
temporary and capable of being reclaimed to a condition of being substantially
unnoticeable in the area. Would wind energy developments meet these criteria?
IV. Other Land Uses
Recreation
Based on aerial visitor count data, the Table Mountain area receives approxi¬
mately 3000 visitor use days annually. Major activities include sightseeing,
rock collecting, off-road vehicle use on approved routes, hunting, horseback
riding, backpacking, and hiking.
Mineral s
As of November 8, 1983, there were nine mining claims within the study area.
There is no current activity, except for annual assessment work.
Utility Corridors and Communications Sites
The southern portion of the area is crossed by a _ ile-wide utility corridor
designated in the 1981 MFP. SDG&E is constructing a 500kV transmission line
within the corridor.
Two communications sites are located on a ridge a short distance north of Table
Mountain.
Livestock Grazing
All public land in T17S, R8E is a part of the McCain Valley Grazing Allotment.
However, there has been no use of the area by livestock for the past five
years.
V. Alternatives Considered
Two alternatives were considered by the Environmental Assessment prepared for
wind energy development in the study area. Public comments on these alter¬
natives are discussed in the Final EA. Comments on the adequacy of the EA and
on the need for an EIS are summarized in Table V-l.
Alternative 1: Full Development
All public lands within the study area would be available for wind eneray
development. Surface access would be provided to all portions of the study
area. Site-specific mitigation measures would be developed in subsequent
site-specific EA" n- ppared on plans of development. Procedures for competitive
bidding, granting rights-of-way, and preparation of site-specific EAs would be
as described under section I above.
Alternative 2: No Action
No wind enerqy development would be allowed. The action would continue current
protection for all resource values.
3
ANALYSIS OF PUBLIC COMMENTS
TABLE MOUNTAIN E.A.
(as of 2-14-84)
COMMENTOR
ADD'TL INFO
NEEDED ON
DRAFT E.A.
DRAFT E.A.
ADEQUATE
EIS
NEEDED
PROPOSAL
Yes No
Yes No
Yes No
Pro Con
Ken Bosley
N/
A
N/
A
N/A
X
County of San Diego
Dept of Planning &
Land Use
X
X
X
X
Harriet Allen
X
X
N/A
X
Mrs. R. Landis
Ny
A
N/
A
N/A
X
Jan Townsend
X
X
N/A
X
Sierra Club - SD Chapter
N/
A
N/
A
N/A
X
SDG&E
X
X
N/A
X
Mountain Defense League
X
X
X
X
Desert Protective
Council
X
X
X
X
Arch Survey Assoc - SC
N/
A
N/
A
N/A
X
Ronald V. May
X
X
X
X
Gilmer Boggs
Ny
A
Ny
A
N/A
X
Jerry L. Hull
X
X
N/A
X
IVC Museum Society
Ny
A
N/
A
N/A
X
SD Cty Arch Society
X
X
N/A
X
Florence C. Shiper
X
X
N/A
X
Advisory Councel on
His Pres
X
Ny
A
N/A
X
Assoc, for Trans¬
personal Anthropology
Int
X
X
N/A
X
IVC Barker Museum
Ny
A
Ny
A
*
N/A
X
State Clearing House
(Fish & Game)
(Parks & Rec)
Ny
Ny
A
A
Ny
Ny
A
A
N/A
N/A
TOTAL 7 5 6 5 4 — 3
N/A - Not specifically addressed
4
VI. Decision and Rationale
Wind energy development in Southern California is still in an early research
and development phase. Development has centered in two areas, the San Gorgonio
and the Tehachapi passes. Several hundred turbines have been erected in each
pass. Due to the high quality of the wind energy resource in each pass, both
areas provide developers with extensive opportunities to advance the state of
the art of wind energy generation technology, windpark design, and measures to
mitigate impacts on sensitive resources. Although the Energy Commission Study
identified Table Mountain as an area with high wind energy values and little
chance of impact to sensitive resources, the study was flawed in two respects.
First, only one anemometer was used to obtain the wind resource values.
Second, cultural resources were not considered when the no impact conclusion
was reached. Each pass is already much more heavily impacted by past uses than
Table Mountain, which is a nearly pristine, undisturbed area.
San Diego County has expressed general support for wind energy development.
However, the County Department of Planning and Land Use was concerned over
specific plans to develop Table Mountain. They commented that "Table Mountain
has well documented values as a natural resource area. The development of wind
towers...would represent an extreme change in the atmosphere and setting of the
site. ...It would be unfair to the people of the United States to develop a
proposal that would benefit individual entrepeneurs over the public when
public lands are concerned." The Planning Department also noted the County
Board of Supervisor's support of all the features of the 1981 MFP, and then
stated that wind energy development on Table Mountain "appears to be a direct
conflict with the Management Framework Plan and ACEC."
Given the relatively small amount of power which could be developed on Table
Mountain, the availability of other areas in Southern California for wind
energy research and development, the concerns raised by the County and the
general public, and the limited economic return the government is likely to
realize, the public would be better served by not allowing development of a
windpark. Rather, we feel the cultural and visual resource values are of such
magnitude that they should be protected.
Therefore, no development will be allowed north of interstate 8. South
of the interstate, all public lands will be available for further consideration
for development, although only those areas not encumbered by the existing wind
energy application will be available for competitive bidding for development
rights. Map 1 identifies those areas suitable for further consideration; Map 2
indicates the boundary of the ACEC, the former WSA, and the area encumbered by
the existing application. The rationale for the decision follows.
Table Mountain ACEC
No development would be allowed within the Table Mountain Area of Critical
Environmental Concern (T17S, R8E, Sections 26, 27, 28, 33, 34, 35, and those
portions of T18S, R8E, Sections 3 and 4 north of Interstate 8). Development
within the ACEC would create an "adverse impact" on the cultural resources of
the Table Mountain Archaeological District, as defined by 36 CFR 800.36 (Final
EA, p. 58). Any action that is inconsistent with the terms of an ACEC desig¬
nation or would adversely impact an ACEC-protected resource is not permitted
unless the Bureau determines that the public benefits of such an action out¬
weigh the benefits of continuing the ACEC. Such would be the case for Table
Mountain only if the criteria used in 1981 to designate this area were no
longer valid. These criteria and their present validity follow:
5
Criteria 1: The designation must still be relevant to the resource values.
The area has been added to the National Register since designation as an
ACEC. S^enir and wildlife resources are still undisturbed.
Criteria 2 : The designation must still be important locally, regionally
and nationally. The values are more important than they were in 1981. The
resources are considered irreplaceable. This is supported by both the
local and regional Native American Community and the San Dieao County
Plannina Department.
C riteria 3 : The designation must still be critical ; that is, the desig¬
nation must be necessary to prevent adverse impacts. At Table Mountain,
this concerns the high potential for human impacts on the resource. The
cultural resources on Table Mountain are fragile, sensitive, rare and
irreplaceable. They are extremely vulnerable to impact because they are
accessible and easily damaged. Special management remains necessary for
protect ion.
Criteria 4 : The designation must be protectable and enforceable . This
requirement is of paramount consideration. If no development occured,
the ACEC could be protected due to its size, shape, location, physiography,
configuration, limited adjacent uses, and lack of access. Only by main¬
taining these factors can the integrity of the ACEC be maintained.
The Environmental Assessment disclosed no new information which would justify
altering or deleting any of the ACEC decisions °f the 1981 MFP. The EA did
determine that development on Table Mountain would irrecoverably affect the
visual integrity of Table Mountain archaeoloqy. The environmental setting and
character of the mountain would be permanently altered by developments, such as
turbines, transmission lines, roads, and support facilities (Final EA, p. 58).
There would be "irreparable" damage t" Kumeyaay sacred values (ibid, p. 59).
In addition, development would result in contrasts exceeding VRM Class II
limits (ibid, p. 52). Construction of roads, turbines, and other facilities
would result in removal of vegetation, causing the loss of topsoil due to the
moderate to high erosion potential of the granitic soils in the area (ibid, p.
53). In addition to the impacts from erosion, the original vegetation would
not be able to reestablish itself.
Former Table Mountain WSA
No development would be allowed within the former Table Mountain Wilderness
Study Area (T17S, R8E, parts of sections 15 and 22). Construction of turbines
and support facilities would constitute impairment of the area's suitability
for wilderness (Final EA, p. 52). Resultant impacts would not be temporary.
Facilities could not practically be removed and the area reclaimed to a condi¬
tion of beina substantially unnoticeable within the timefrome specified by the
nonimpairment criteria (Final EA, p. 52). Wind energy development would not
meet the criteria of BLM's Interim Management Policy and so is precluded.
Other Public Lands North of Interstate 8
No development would be allowed in those parts of T17S, R8E, sections 15, 21,
and 22 outside the former Table Mountain WSA. This area topographically is a
shallow valley between Table Mountain and the Jacumba Mountains. The southern
half of the valley is within both the Table Mountain ACEC and the Archaeo¬
logical District. Few sites have been recorded in the northern half of the
valley; however, this area has never been surveyed. Therefore, it is possible
6
that the area is nearly as rich in cultural values as Table Mountain itself.
The area is bordered on the south by the ACEC, on the northeast by the former
Table Mountain WSA, and on its other borders by Anza-Borreqo Desert State
Park. Transmission lines and improved access roads would have to cross one or
more of these areas. There is no evidence that this valley possesses a uniquely
outstanding wind resource relative to the rest of the study area. A no develop¬
ment decision also prevents conflicts with bighorn sheep, which have occasion¬
ally been sighted in the western portion of the valley.
Public Lands South of Interstate 8
All public lands south of Interstate 8 are suitable for further consideration
for wind energy development. The area is outside the Table Mountain ACEC.
There are many existing impacts in the area, including Interstate 8, old
highway 80, and the new SDG&E 500kV transmission line. Developments would not
exceed the guidelines of VRM Class IV. No significant conflicts with wildlife
would occur. Only those public lands not encumbered by the existing wind
energy application would be available for competitive bidding for development
rights, approximately 260 acres. Procedures for granting riahts-of way and
for permitting development would be as described under section I above.
However, part of this area is within the Jacumba Discontiguous Archaeological
District. No development will be allowed until BLM meets full compliance with
both section 106 of the National Historic Preservation Act (36 CFR 800) and the
Programatic Memorandum of Agreement between the BLM, the California State
Historic Preservation Officer, and the Advisory Council on Historic Preservation
regarding cultural resources.
4
7
VII Mitigating Measures or Proposed Stipulations
Since the decision is based strictly on existing data, the following mitigat¬
ing measures are reproduced _in toto from the Environmental Assessment (pps.
66-76). The reader is cautioned, that on cursory examination, certain mitiga¬
tions appear to conflict. However, without site-specific information, which
will be provided by site specific inventories performed by the applicants, it
is impossible to resolve these conflicts. Inventories will be performed
according to all applicable ELM Manual standards, at the applicant's expense.
It should be noted that these inventories could be expensive and time con¬
suming (e.g., initiation of section 106 requirements for cultural resources).
Mitigations which are standard operating requirements are not listed here.
Recreation
1. Use existing access routes whenever possible to minimize impacts to
botanical resources and upland game habitat.
2. In areas where public use of new access roads would not create safety
hazards or adversely affect botanical resources or game habitat, leave
access roads open for public use.
3. Implement visual resource mitigations even in the seldom-seen zones in
order to protect scenic values for recreationists using the area. (Sec¬
tion IV.B).
Realty
1. Equipment shall not be placed closer to the edge of the right-of-way for
the Southwest Powerlink than the equipment's maximum height.
2. Move the receiver out of the path of wind turbine and transmitting sta¬
tion.
3. Instead of metal blades, use non-metallic material; wood, fiber glass,
and composite materials for fewer electromagnetic effects.
Range
1. Schedule construction activity from March through October to minimize
disruption of livestock grazing.
2. Install locked gates across roads where practical, to control access.
Visual Resources
1. Construct roads to follow natural landforms (curvilinear lines) rather
than arbitrary straight lines.
9
2. Conceal roads by constructing them on the sides of ridges located away
from the KOPs when possible.
8
3. Limiting access roads to areas having slopes of 25% or less
in the foreground distance zone of VRM Class II areas.
(Windfarm development would not meet class limitations in
these areas).
4. Avoid "skylining" of turbine towers.
5. Paint all structures to match the characteristic landscape
color. Since the landscape generally has a mottled appearance
consisting of various shades of tan, desert camouflage would
be the preferred paint scheme. A medium desert tan would be
the preferred color if a solid color were used. Structures
unavoidably skylined should be painted a light powder blue.
All paint should be approved by BLM prior to actual application.
6 . For power distribution lines (69 kV or smaller), use nonspecular
conductors and insulators. If metal distribution line towers
are to be used, ungalvanized metal weathering to a natural
brown is preferred.
7. Avoid skylining of power distribution lines if possible.
Vegetation
1. Keep all disturbed areas and new roads to a minimum. Waterbar
and block roads that are unneeded after construction.
2. Conduct a botanical inventory of all proposed road and
construction sites before work begins. No surface occupancy
in those areas identified as containing plants named on
Table 10, of the Environmental Assessment.
3. Limit road construction to the minimum acceptable amount.
4. Prohibit all off-road vehicular travel.
5. Waterbar roads on grades over 75' long and 5% slope.
6 . At the end of construction, barricade all roads not needed
for maintenance.
7. Avoid construction of any facilities in areas shown on map 5
of the Environmental Assessment.
Wildlife
1. Minimize surface disturbance.
2. Close new roads to public use.
3. Do not allow surface disturbance within 1/2 mile of gallinaceous
guzzlers or other permanent water sources, if they occur.
4. If a guzzler or other water source is impacted, grantee must
compensate with one in a new location.
9
5. Survey for mule deer, bighorn sheep, spotted bat (roosts),
magic gecko, and San Diego horned lizard to provide site
specific information for EAs on applications. Ungulate
surveys should emphasize seasonal use and type of use
(fawning/lambing, travel corridor, etc.).
6 . Do not allow construction in fawning/lambing areas if these
are found.
7. Do not allow construction from February - June within 1/2
mile of fawning/lambing area if found.
8 . Do not allow development within 1/2 - 3/4 mile of cliff
nesting areas and in foraging areas.
9. Transmission lines should not cross canyon mouths or ridge tops.
10. No construction is to be allowed near golden eagle nesting and
foraging territories from January - July. This mitigation can
be suspended if nesting activity is not observed by March 31 of
a given year.
11. Powerlines are to be constructed according to raptor protection
guidelines (Olendorff et. al., 1981), where applicable.
12. Avian mortality should be monitored.
13. General wildlife surveys should be done on a site specific basis
to determine presence of wildlife species of special concern.
Cultural Resources
1. Tower sites, access roads and transmission lines may be
positioned to avoid sites. (Archaeology)
2. Data recovery is a possibility for archaeology.
3. Sites must be inventoried for archaeological values.
4. Site specific EAs must be written.
5. Denial of Project development north of Interstate 8 .
6 . Perform supplemental Native American interviews and contacts
and contact appropriate Kumeyaay Reservations.
10
VIII Environmental Compliance & Signatures
We have reviewed the EA prepared to analyze the environmental effects of
the action and have determined that the action and approved mitigating
measures would not have a significant effect on the human environment.
Therefore, an EIS is not required to further analyze the environmental
effects of the action.
Prepared by: _
Roger Zortman, Area Manager
Reviewed by: _
William Collins, CDD Environmental Coordinator
I Approve: _
Gerald E. Hillier, District Manager
«
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TABLE MOUNTAIN WIND
STUDY AREA
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energy development
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Areas Suitable for Further
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