Big Chino Valley Pumped Storage Project (FERC No ) Desert Tortoise Study Plan

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November 16, 2018 1.0 Introduction Big Chino Valley Pumped Storage LLC, a subsidiary of ITC Holdings Corp. (ITC), submitted a Pre- Application Document (PAD) and Notice of Intent to file an Application for an Original License to the Federal Energy Regulatory Commission (FERC or Commission) on March 30, 2018 for the proposed (Project). FERC issued ITC a preliminary permit for a term of 36 months on December 28, 2017, which grants ITC priority of application for a license for the Project under Part I of the Federal Power Act (ITC 2018). A supplemental PAD and NOI was filed on October 4, 2018 to include ITC s three proposed transmission corridors. The proposed Project will be located in Coconino, Yavapai and Mohave Counties, Arizona and Clark County, Nevada. The 2,000 megawatt, closed-loop, pumped storage facility will require the construction of new water storage, water conveyance, generation, and transmission facilities in currently undeveloped areas. The Project will be located entirely off-stream, meaning neither the upper nor lower reservoir will intercept a perennial surface watercourse. Water to initially fill the reservoir system and required make-up water for evaporation losses will be pumped from groundwater resources. Project reservoirs would occupy approximately 450 acres of lands currently used for grazing. In addition to the reservoirs and associated facilities, the Project will include three transmission lines with tie-ins to existing substations. The three transmission line corridors will be the Yavapai corridor (54 miles), Peacock corridor (58 miles), and the Eldorado corridor (158 miles). ITC plans to pursue the permits, licenses, and agreements needed to build and operate the Project, and implemented a suite of resource studies in the reservoir vicinity during 2018. During 2019, ITC will conduct additional studies to assess resource impacts associated with the Project s proposed transmission routes. Results and analyses for both 2018 and 2019 studies will be included in ITC s license application to FERC. 2.0 Project Nexus and Study Goals Construction, operation, and maintenance of the Project may have the potential to affect the Mojave population of the desert tortoise (Gopherus agassizii). The Mojave population of desert tortoise occurs only to the north and west of the Colorado River. This portion of the Project is approximately 28 miles of the Eldorado transmission corridor and occurs entirely within the State of Nevada. The Mojave population of the desert tortoise is listed as Threatened under the Endangered Species Act (ESA). The desert tortoise is a species of reptile that inhabits arid desert regions. They have a large, dome-shaped shell and short, stubby legs. Because they are slow-moving and camouflage well with the ground, and because their burrows are often difficult to see, the desert tortoise could potentially be affected by Project construction activities. The goal of this study is to provide information concerning desert tortoise presence and distribution within the Project area and to assess the potential impacts from the Project. Page 1

3.0 Summary of Existing Information Desert tortoise surveys have not been conducted within the study area. Datasets maintained by the US Fish and Wildlife Service (USFWS) indicate that desert tortoise may occur in the portions of the Project s Eldorado transmission line corridor located in Nevada, which generally supports suitable habitat for the species. The USFWS has designated lands near Interstate 95 as critical habitat for desert tortoise, including portions of the study area (USFWS 2018). 4.0 Methods 4.1 Study Area Based on ITC s ongoing assessment of the preferred and alternative transmission routes, the preferred routes which generally follow existing infrastructure have less impacts to natural resources and local communities. Given the preliminary conclusions of ITC s transmission route alternatives analysis, which will be shared with stakeholders once the analysis is completed, ITC s study area for the 2019 studies encompasses only the preferred transmission routes. Within these routes, the Transmission Study Area for the Desert Tortoise Study consists of all Project-affected lands within the proposed Eldorado transmission line corridor in Nevada and access roads that are proposed for construction or improvement, as well as a 100 foot buffer surrounding each of these locations (Appendix A). 4.2 Study Methods 4.2.1 Survey Preparation and Agency Coordination During preparations for fieldwork, ITC will coordinate with the southern Nevada office of the USFWS, and with other stakeholders by request, to convey survey dates, ensure the use of current survey protocols, and check for new datasets potentially of relevance to the Project. 4.2.2 Desert Tortoise Surveys ITC will conduct protocol-level presence/absence survey for desert tortoise within the study area, in accordance with guidelines included in the USFWS Preparing for Any Action That May Occur Within the Range of the Mojave Desert Tortoise (Gopherus agassizii) (USFWS 2010), or the current USFWS protocol. Surveys will consist of pedestrian transects spaced at a maximum of 30 feet apart throughout all suitable habitats in the study area. If topography or vegetation are such that surveyors do not have a clear view of the ground, transect width will be reduced to a minimum of 10 feet. All tortoises and tortoise sign will be documented, photographed, and the location recorded using a GPS device. Tortoise sign to be recorded will include shell, bones, scutes, limbs, scat, burrows, pallets, tracks, egg shell fragments, courtship rings, drinking sites, and mineral licks. Any tortoises encountered will be photographed and a size estimate will be recorded. No tortoises will be harassed, handled or touched during the survey. Potential burrows will be recorded and investigated only to the point that a mirror or flashlight will be used to observe the visible extent of the burrow. No burrow scopes will be utilized during survey efforts, to avoid damage to burrows. Presence/absence surveys will be conducted during the most active periods for desert tortoise. These include the spring survey months of April and May and the fall survey months of September and October. Surveys will be conducted when the ambient temperature is below 104 degrees Fahrenheit measured 2 inches from the soil in the shade of the surveyor. Page 2

If desert tortoise or tortoise sign are observed within the study area, the USFWS Desert Tortoise Survey Protocol will be used to estimate the potential population of tortoises. 4.2.3 Study Reporting Following the completion of field work, a report documenting the methods, results and findings of the survey will be prepared and included with ITC s FERC license application for the Project. The survey report will include all data used regarding desert tortoise presence or absence as well as maps, photographs, data sheets and transect information. 5.0 References USFWS 2010. United States Fish and Wildlife Service. Preparing for any Action that May Occur within the Range of the Mojave Desert Tortoise (Gopherus agassizii). 2010 Field Season. Page 3

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Appendix A. Desert Tortoise Study Area Map Page 5

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± 15 NEVADA Las Vegas Henderson Eldorado Station ARIZONA 40 17 10 Scottsdale LEGEND '! Proposed Interconnection Point Eldorado Interconnection Route Corridor Desert Tortoise Critical Habitat 0 1 2 4 6 8 10 Miles PROPOSED BIG CHINO VALLEY PUMPED STORAGE PROJECT DESERT TORTOISE STUDY AREA