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88063961 


Draft 

Record of Decision 


For the 



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I 

MAY 1984 



195 
. E49 
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 


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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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11 





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TABLE MOUNTAIN WIND 
STUDY AREA 


Areas not available 
energy development 


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Areas Suitable for Further 
Consideration for Wind Energy 
Development 


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