What's in the Imperial-Mexicali 230-kV Transmission Lines EIS

The Imperial-Mexicali 230-kV Transmission Lines EIS addressed Baja California Power's (BCP's) and Sempra Energy Resources' (SER's) transmission line projects, focusing on whether to grant or deny presidential permits and rights-of-way to BCP and SER, as if the transmission lines did not exist.

Base for EIS Analysis

An agency's analysis of the proposed action and alternatives to that proposal is said to be the heart of an EIS. The analysis is intended to present the environmental impacts of the proposal in the United States and the alternatives in comparative form, thereby sharpening and defining the issues and providing a clear basis for choice by the decision maker and the public. The agency's alternatives should reflect the range of reasonable decisions consistent with the purpose and need for action. DOE and BLM also desire to comply with the court's orders. In its July 8, 2003, order remanding this matter back to the respective agencies for additional NEPA review, the court stated:

"Finally, the court PROHIBITS the federal defendants from considering the interim operation of the transmission lines, the completion of the construction, or this Court's equitable analysis of the environmental impacts of the proposed actions as part of the NEPA analysis and determination process on remand". Cf. Northern Cheyenne Tribe v. Hodel, 851 F.2d 1152, 1157 (9th Cir. 1988). (Emphasis in original.)

DOE and BLM have interpreted this language to require that they should conduct their NEPA review from a fresh slate, i.e., as if the transmission lines did not exist. Accordingly, DOE and BLM based their EIS analysis on the same purpose and need as they did originally: whether to grant or deny presidential permits and rights-of-way to BCP and SER.

Proposed Preliminary Alternatives

In order to consider the complete range of reasonable alternatives, DOE and BLM proposed the following preliminary alternatives:

1. No action. Deny both permit and corresponding right-of-way applications. This will present the environmental impacts in the United States as if the lines had never been constructed and will provide a baseline against which the impacts in the United States of the action alternatives can be measured in the absence of presidential permits and corresponding rights-of-way.


2. Grant one or both permits and corresponding right(s)-of-way. This set forth the impacts in the United States of constructing and operating the line(s) from Mexican power plants, as those plants are presently designed. This is DOE's and BLM's preferred alternative.


3. Alternative technologies. Grant one or both permits and corresponding right(s)-of-way to authorize transmission lines that connect to power plants that employ more efficient emissions controls and alternative cooling technologies, such as "dry cooling" or a combination of wet and dry cooling that will minimize environmental and health impacts in the United States.


4. Mitigation measures. Grant one or both permits and corresponding right(s)-of-way to authorize transmission lines whose developers employ off-site mitigation measures to minimize environmental impacts in the United States. (For example, off-site mitigation could include off-sets, such as paving roads and retiring older automobiles.)

DOE and BLM also propose to consider alternative routes for the transmission lines within the United States under the action alternatives described above.

Because DOE and BLM have proceeded here from the assumption that no lines now exist, this EIS did not address the environmental impacts in the United States of removing the existing transmission lines and poles from BLM lands. Should permits and rights-of-way not be granted, the issue of whether to remove the existing lines from BLM lands will arise and the impacts in the United States from that action would have to be considered in an appropriate future NEPA review.

Identification of Environmental Issues

In addition to the issues identified by the court ((1) the potential for public controversy; (2) water impacts; (3) impacts from ammonia and carbon dioxide; (4) the range of alternatives; and (5) cumulative impacts), DOE and BLM analyzed the following potential environmental issues:

1. Impacts on protected, threatened, endangered, or sensitive species of animals or plants, or their critical habitats in the United States (e.g., the Flat-tailed Horned Lizard);


2. Impacts on floodplains and wetlands in the United States;


3. Impacts on cultural or historic resources in the United States;


4. Impacts on human health and safety in the United States;


5. Impacts on air, soil, and water resources in the United States (e.g., the Salton Sea and the New River);


6. Visual impacts in the United States; and


7. Disproportionately high and adverse impacts on minority and low-income populations in the United States.

This list is not intended to be all inclusive or to imply any predetermination of impacts, and DOE and BLM invite interested parties to suggest other issues to be considered.

See Getting Involved to learn more about participating in the EIS process.