Biologist Email on R-Project Sent to NPPD

From: Robert Harms

Sent: Friday, February 13, 2015 12:18 PM

To: Kent, Thomas J. Cc: Citta Jr., Joseph L.; Hostetler, Bonnie J.; Linder, Larry D.; Jenniges, James J.; Mike Fritz; michelle.koch@nebraska.gov; Holthe, Craig L.; Harding, Mary A- Board Member; Eliza Hines

Subject: South Alternative for the R-Project

Mr. Kent:

The U.S. Fish and Wildlife Service (Service) requests that the Nebraska Public Power District (NPPD) evaluate a potential R‐project route alternative, herein referred to as the South Alternative, that appears to meet the purpose and need of the R‐project and have less environmental impact. We first became aware of this South Alternate route as an outcome of our public meeting in Burwell, Nebraska and a follow‐up January 21, 2015, meeting in the Burwell area that was requested by several ranchers.

We recognize that NPPD has selected a final route for the R‐project, but the project is still in the early stages of development. Thus, this should not preclude NPPD from conducting an evaluation of (or the Service advocating for) other less environmentally damaging alternatives that may arise; this is especially true given the substantial impact that the final R‐project route will have on federal trust fish and wildlife species, including federally listed threatened and endangered species and migratory birds.

South Alternative

The South Alternative for the R‐Project would start at an existing substation at the intersection of Highways 83 and 92 south of Stapleton, Nebraska and proceed east approximately 40 miles along Highway 92 to the east edge of Merna, Nebraska. The South Alternative would extend east approximately 10 miles to Road 444, northeast of Broken Bow, Nebraska. One half mile south of the intersection of Road 804 and Road 444 is the existing substation for a wind farm at Broken Bow. We have already been contacted by NPPD about the proposed new construction of a 115kV transmission line from the proposed Muddy Creek substation near Broken Bow to an existing substation south of Ord. We are aware that the proposed Muddy Creek substation siting area is near the existing wind farm substation referenced above. As such, the South Alternative could then extend along the proposed route that is already under consideration by NPPD from the Muddy Creek Substation to the Ord Substation. From the Ord substation, the South Alternative would follow Highway 70 to Highway 281, then turn north and parallel Highway 281, then extend east along an existing county road at the Wheeler and Holt County line to intersect the north‐south Western Area Power Administration line.

The South Alternative would have less environmental impact because the majority of it would extend across previously disturbed state and county road right of ways. Impacts to migratory birds would be significantly reduced from the impacts that are expected under the recently finalized route that extends across miles of remote meadows and wetland areas that annually provide a tremendous migration and nesting resource to migratory birds and other wildlife. The South Alternative would also just skirt the range of the federal and state endangered American burying beetle and federal and state threatened western prairie fringed orchid along the eastern edge and completely avoid the range of the federal and state endangered blowout penstemon. The existing final route now extends well within the range of the ABB, the majority of it is located in prime‐rated habitat for the species, and through areas where American burying beetle densities have been shown to be some the highest in the United States. The final route also extends well within the range of the western prairie fringed orchid; previous surveys confirm that the species is abundant in the meadows in the eastern portion of the final R‐project route. The final route also extends across the range of the blowout penstemon, whereas it does not under the South Alternative. While it is true that the South Alternative extends across 2 the whooping crane migration corridor and is located near the table playa wetlands east of Merna, Nebraska, its location paralleling Highway 92 would avoid impacts to the species because the whooping crane avoids areas along highways where noise and activity are prevalent.

In addition, the South Alternative route would avoid the majority of the Nebraska Sandhills and provide improved access for line construction and future maintenance because existing roads are nearby. The final route currently planned by NPPD calls for a significant number of access road upgrades and in many cases, crossing of meadows where compaction by heavy equipment may forever alter existing hydrology. Other benefits may also include a cost savings by using single pole structures installed from existing roads rather than towers that must be flown in by helicopter and installed using specialized equipment mounted on a tracked vehicle. Land restoration may be easier as well given that much of the South Alternative would extend across areas with loess/clay soils instead of sandy soils where erosion and post project restoration will be difficult.

Thank you for your careful consideration of this alternative—we look forward to your response. Please call or email me if I can provide further technical assistance or if you have questions. Thank you.

Robert R. Harms

Fish and Wildlife Biologist

U.S. Fish and Wildlife Service