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Home My WebLink About1.15 CPW LetterTRANSMISSION LINE 6584 REBUILD PROJECT ATTACHMENT P: Colorado Parks and Wildlife Comment Letter Grand Junction (Area 7) Service Center 711 Independent Ave Grand Junction, CO 81505 P 970.255.6100 | F 970.2556111 Heather Dugan, Acting Director, Colorado Parks and Wildlife Parks and Wildlife Commission: Carrie Besnette Hauser, Chair • Dallas May, Vice-Chair • Marie Haskett, Secretary • Taishya Adams Karen Bailey • Betsy Blecha • Gabriel Otero • Duke Phillips, IV • Richard Reading • James Jay Tutchton • Eden Vardy November 2, 2022 Burns & McDonnell 9785 Maroon Circle, STE 400 Centennial, CO 80112 RE: Xcel Transmission Line Rebuild 6584 Dear Ms. Hines, Thank you for the opportunity to provide comments on the proposed Electric Transmission Line Rebuild of the Mitchell Creek to Rifle Transmission Line 6584 Project (Project). Colorado Parks and Wildlife (CPW) has a statutory responsibility to manage all wildlife species in Colorado. This responsibility is embraced through our mission to perpetuate the wildlife resources of Colorado and provide sustainable outdoor recreation opportunities that educate and inspire future generations. CPW fulfills this mission by responding to requests for comments on wildlife impact reports, land use proposals, and consultations through public- private partnerships. CPW understands from the permit application material that Xcel is replacing approximately 30 miles of 115 kV electrical transmission line from the Mitchel Creek substation to the Rifle Substation in Garfield Counties beginning in 2023. Land ownership within this project area includes public, private, and CPW’s Garfield Creek State Wildlife Area. This Project is a part of a large-scale replacement effort in Western Colorado that has reached the end of its serviceable life. Existing wooden poles will be replaced with single, weathered monopoles resulting in fewer structures than what is currently on the landscape. The proposed alignment will follow the existing alignment with minor re-routes proposed near the City of New Castle. The existing 30-50 foot right of way will be expanded to 75 feet to accommodate design upgrades and installation. Expected construction activities could include ground crews, truck support, line-pulling stations, and helicopter operations with material stored on staging areas throughout the project area although not clearly identified in the project materials. The project proponents briefly address necessary vegetation clearing during construction but do not include a reclamation plan. In reviewing the application material, the Project follows the existing alignment through scrub/shrub wildlife habitat. CPW has identified that this project area is located within the following CPW-mapped High Priority Habitats (HPH) with sound, spatial data and scientifically backed Best Management Practices (BMPs). To protect those habitats listed below, CPW recommends the following best management practices to avoid, minimize, and mitigate adverse impacts to sensitive species within the project area while incorporating logically based flexibility to accommodate the project construction because of its community benefit. • Mule deer severe winter range and winter concentration area: part of the overall range where 90% of the individuals are located when the annual snowpack is at its maximum and/or temperatures are at a minimum in the two worst winters out of ten; and the part of the winter range where densities are at least 200% greater than the surrounding winter range. • Project construction managers should pause work if deer are observed within a 400-meter buffer around the construction area, followed by a call to the District Wildlife Manager to discuss alternative plans. • Communication with CPW to evaluate winter pressures, habitat conditions, and weather patterns should occur weekly or as noticed by construction crews or CPW staff. • Elk Winter range and concentration area: part of the overall range where 90% of the individuals are located when the annual snowpack is at its maximum and/or temperatures are at a minimum in the two worst winters out of ten; and the part of the winter range where densities are at least 200% greater than the surrounding winter range. • Project construction managers should pause work if deer are observed within an 800-meter buffer around the construction area, followed by a call to the District Wildlife Manager to discuss alternative plans. • Communication with CPW to evaluate winter pressures, habitat conditions, and weather patterns should occur weekly or as noticed by construction crews or CPW staff. • Native Species Conservation and Sportfish Management Waters: Ephemeral or intermittent streams and rivers serve as aquatic habitats during periods of flowing water and the absence of flowing water. • Should avoid surface occupancy within 500 feet of the ordinary high-water mark. • During construction and operations, the contractor should prioritize erosion control measures identified within the NPDES Permit to minimize off-site and in-channel sediment transport. • Dust suppression should utilize fresh water only. • Implement a Noxious Weed Management Plan to treat topsoil stockpiles and materials at least bi-annually with spot-treatment as needed utilizing a Colorado-cer tified herbicide applicator. • Erosion control measures will be in place before any ground disturbance such as clearing, grubbing, construction, and reclamation; survey work will be exempt. • Traffic crossing the Native Species Conservation or Sportfish Management Waters should be restricted to a single crossing point to minimize damage to the banks and channel bed. • Protect banks and streambeds by incorporating structure or mat reinforcements. • Sediment collection mechanisms will be installed within the stream bed, including dry channels, and along the banks. • Active Bald Eagle Nest or Roost site: defined as groups of individual trees that provide nesting habitat or diurnal or nocturnal perches and are usually the tallest available trees in the wintering area located primarily in riparian habitats. o No permitted or authorized human activities within .5-miles of winter night roost or communal roost site from November 15th to March 15th if there is a direct line of sight to the activity, .25-mile if there is no direct line of sight. o A Nest survey be performed in each project area (half-mile radius) no later than two weeks before initiating construction for each project location to identify potential raptor nests, perching, foraging areas, and winter roosting areas. o Project construction managers should pause work if nesting or roosting behavior is observed within a .25-mile buffer around the location, followed by communicating with the District Wildlife Manager to discuss alternative plans. o Helicopter activity near identified roosting sites should be avoided from November 15th through March 15th to avoid conflicts with roosting raptor activity. • CPW State Wildlife Area - Garfield Creek SWA: privately owned lands offering wildlife-related recreation to the public, paid for by sportspeople and managed under state law by Colorado Parks and Wildlife for the benefit of wildlife and hosts opportunities for the public to participate in hiking, wildlife viewing, wildlife refugia, and hunting. • Garfield Creek SWA serves as a critical wildlife sanctuary following the big game hunting seasons and when snow levels are high. No work will be authorized on or adjacent to Garfield Creek SWA from December 1st to April 30th. • Garfield Creek SWA is used by hunters throughout big and small game hunting seasons, construction crews should be prepared for early morning and late evening traffic for hunters accessing the area in addition to usual daytime traffic. Protecting large landscapes that support such a wide variety of wildlife species and habitats that they utilize can only be accomplished by partnering with other land users, conservation organizations, and agencies. CPW recommends the following general BMPs that protect wildlife resources. • Submit and follow a robust restoration plan with a wildlife-friendly mix of grasses and shrubs to revegetate disturbed areas. • Any clearing, grubbing, or stockpile materials will be managed to prevent sediment transport and may include seeding with cover crops, tackifier application, or mechanical controls. • Noxious weed control will be required through chemical or mechanical treatment in any disturbed area using a Colorado-certified herbicide applicator. • Any cleared vegetation or topsoil will be treated for noxious weeds and stored outside of the Native Species and Sportfish Management Water Buffer zone and include stormwater control measures. • Notifications to pause or alter work will be at the sole discretion of the CPW District Wildlife Manager or Land Use Specialist and may be short or long-term in nature and will be the result of weather conditions or wildlife movement and other observations. • District Wildlife Managers or Land Use Specialists will assess the situation, the impact, and the duration of the disturbance to develop alternative work plans. • Project construction Managers will discuss upcoming weather events that may impact big game movements, accessibility concerns, or damage to the resources with CPW staff. • Elk, deer, and other wildlife may not be hazed or moved off-site. • Work can resume if the presence of big game is not detected for 24 hours. • Dogs will not be allowed at the Project location. • Trash and debris should be removed daily. • Lighting should be capped from above to help reduce night-sky l ight pollution to avoid interference with nocturnal wildlife behavior. • Conduct work during daylight hours to minimize disturbance to wintering elk, deer, and other wildlife that utilize this area. • The flight path for any helicopter work should be kept within the construction easement corridor to reduce additional disturbance as much as possible. Helicopter work should avoid any wildlife spotted in the area and limit sightseeing diversions. • Remove any mud or debris and disinfect equipment, hand tools, pumps and hoses, boots, and other equipment previously used in a river, stream, lake, pond, or wetland before moving the equipment to another water body following the attached aquatic disinfectant protocols: https://cpw.state.co.us/Documents/Research/Aquatic/pdf/Publications/Quaternary- Ammonia-Compound-Disinfection-Protocols.pdf#search=disinfect Colorado Parks and Wildlife commends the project proponent for minimizing new disturbance, acknowledging wildlife in the area, and incorporating timing stipulations for sensitive wildlife species. CPW appreciates the opportunity to review this project application material and provide recommendations to avoid, minimize, and mitigate adverse impacts on wildlife. If there are any questions or needs for additional information, don’t hesitate to contact CPW wildlife managers: Travis Bybee, District Wildlife Manager 970-985-5882, travis.bybee@state.co.us Kirk Oldham, Area Wildlife Manager, 970-255-6178, kirk.oldham@state.co.us Matt Yamashita, Area Wildlife Manager 970-989-8617, matt.yamashita@state.co.us Darren Chacon, Assistant AWM, 970-948-3405 darren.chacon@state.co.us Buddy McNeel, Garfield Creek SWA, 970-984-9872, buddy.mcneel@state.co.us Molly West, Land Use Specialist 970-255-6105 molly.west@state.co.us Sincerely, Kirk Oldham Area Wildlife Manager CC List Darren Chacon, Assistant AWM Buddy McNeel, Garfield Creek SWA Property Technician Julie Mao, Terrestrial Biologist Kendall Bakich, Aquatic Biologist Dani Neumann, Land Use Specialist Glenn Hartmann, Garfield County Senior Planner