CWF/NWF-TransWest Transmission Line Comments

 CWF and NWF submitted our comments on the TransWest Express Transmission Line draft environmental impact statement on September 30, 2013 to BLM and Western Area Power Administration WAPA).

TransWest is a proposed 725-mile direct current overhead transmission (600kV) line across public and private lands in Wyoming, Colorado, Utah and Nevada that will connect southern Wyoming (the hokecherry and Sierra Madre wind energy project proposal) to the desert southwest area (southern terminal in Las Vegas area). The project would carry up to 3,000 megawatts, which is roughly enough to power approximately one million homes.

CWF’s interest is in the segment that crosses northwest Colorado.  CWF urged BLM and WAPA to select Option 3 at the “chokepoint” at Highway 40 to avoid cutting across the 15,076-acre Tuttle conservation easement purchased by Colorado Parks and Wildlife with supplemental funding by GOCO and US Fish and Wildlife Service. Wildlife values on this conservation easement are noted below in the CWF/NWF comments.










Rocky Mountains and Prairies Regional Center

2995 Baseline Road, Suite 300

Boulder, Colorado 80303



1410 Grant Street, Suite C-313

Denver, Colorado 80203


September 30, 2013

 Delivered via electronic mail ( and U.S. mail (with attachments).

 Sharon Knowlton, BLM Project Manager

TransWest Express Project

Bureau of Land Management

P.O. Box 20678

Cheyenne, WY 82003

Steve Blazek, Western Area Power Administration National Environmental Policy Act (NEPA) Document Manager

Western Area Power Administration

P.O. Box 281213

Lakewood, Colorado 80228–8213

Re: Comments on TransWest Express Transmission Draft Environmental Impact Statement

Dear Ms. Knowlton and Mr. Blazek:

 The National Wildlife Federation (NWF) and the Colorado Wildlife Federation (CWF) appreciate this opportunity to comment on the proposed TransWest Express Transmission Line Project (TransWest Project) and the Draft Environmental Impact Statement (DEIS).

As an organization, the National Wildlife Federation (NWF) represents the power and commitment of four million members and supporters joined by affiliated organizations in 48 states and territories. NWF and its affiliates have a long history of working to conserve the wildlife and wild places of the West. Many members of NWF and its affiliates use the lands and resources that could be impacted by the construction of the TransWest Project.

The Colorado Wildlife Federation (CWF) is Colorado’s oldest statewide wildlife conservation organization, a 501(c)(3) nonprofit whose members consist of hunters, anglers and other wildlife enthusiasts. CWF’s mission is to promote the conservation, sound management, and sustainable use and enjoyment of Colorado’s wildlife and habitat through education and advocacy. CWF understands that wildlife habitat is critical to conserving Colorado’s unique wildlife, hunting and fishing heritage, and wildlife viewing opportunities. These wildlife-related recreation pursuits enrich the well-being of residents and visitors and form a substantial segment of Colorado’s economy. CWF’s members hunt, fish, and recreate on federal public lands in Colorado and elsewhere in the Rocky Mountain region that could be crossed by the proposed transmission corridor.

 NWF and CWF incorporate herein by reference the comments submitted by Audubon Rockies and The Wilderness Society.  We join in their conclusions and supporting reasons regarding the preferred corridor for the TransWest Project as well as other proposed transmission lines, including the Energy Gateway South Transmission Line Project (Gateway South) and the Zephyr Power Transmission Project (Zephyr), which seek to transport power generated in Wyoming to load centers in California, with one notable exception.  NWF and CWF do not support the current alignment of Tuttle Easement Micro-siting Option 1.  Instead, we urge the agencies to avoid lands in Colorado comprising the Tuttle Conservation Easement recently acquired by Colorado Parks and Wildlife (CPW).  As noted in CPW’s letter to the Bureau of Land Management (BLM), by routing the proposed transmission line in the approved corridor that is immediately north of Highway 40, the agencies can avoid permitting a project that could void the easement and damage the future credibility of CPW’s conservation easement program.[1]  We understand that Tuttle Easement Micro-siting Option 3[2] would entail crossing the Deer Lodge Park access road into Dinosaur National Monument.  However, this overhead incursion would occur 12 miles from the body of the Monument and would not impact other National Park Service (NPS) resources.  This is not ideal.  We would not support a route that crossed other NPS lands and resources.  However, we believe that co-locating both roads and transmission to the greatest extent possible will result in lesser impacts to wildlife and their habitats.  Under Option 2, the agencies could avoid both the easement and the NPS access road.  Either Option 2 or 3 would preserve both the Tuttle Conservation Easement and the ability of CPW and others to enter into such agreements in the future.

The 15,076-acre Tuttle Conservation Easement, executed on September 26, 2012, provides an unfragmented expanse of habitat and will improve as the area continues to recover from wildfire, including on surrounding property. CPW views this property as a keystone parcel in its effort to protect wildlife habitat on a landscape scale and as a more important and higher value habitat than that north of Highway 40.  Two of Colorado’s largest elk herds (E-2 and E-6) converge on these lands during average winters, numbering 7,000 to 10,000. The land is mapped as an elk concentration area.  The area also is important as habitat year-round for pronghorn herds. Remaining sagebrush on the easement has become increasingly important to wintering mule deer.  In addition to the presence of a year-round Greater sage-grouse leks site, the conservation easement is situated between two large Greater sage-grouse complexes and serves as an important transitional linkage between the priority habitat from Axial Basin (east) to Blue Mountain (west). CPW notes that habitat south of Highway 40 is greater in value for Greater sage-grouse than north of Highway 40 because it is protected from development in perpetuity. A black ferret release had been planned on this site and is written into the conservation easement.

Although plague has swept through the area, CPW believes that after the white-tailed prairie dog colonies re-establish, the location will serve as a good place for a future black footed ferret release.

NWF and CWF also join the Wyoming Wildlife Federation (WWF) in supporting a determination to eliminate any route near the Flaming Gorge Reservoir and crossing lands in the Little Mountain area of Wyoming.  We also urge the agencies to include WWF’s recommendations regarding mitigation of the TransWest Project in wildlife habitats.[3]


Kathleen C. Zimmerman

Director, Public Lands Program

National Wildlife Federation

Suzanne B. O’Neill

Executive Director

Colorado Wildlife Federation

[1] Letter to Helen Hankins, Colorado State Director, from Rick D. Cables, Colorado Parks and Wildlife Director, April 25, 2013 (attached).


[2] See TransWest Project DEIS at 2-40 and Figure 2-25.

[3] See Comments submitted by Wyoming Wildlife Federation, September 21, 2013 (attached).