Terry, the entire facility has not been disturbed.  Only most of it.  Id say 
approx 70%.  The other 30% has been impacted but not tot the point of 
disturbing all the vegetation, just foot and vehicle traffic.  I dont have 
problem with saying the above, but keep in mind, the facility has been there 
and just because the trees havent been disturbed, doesnt mean that the 
understory beneath the trees has been pristine.   It has always been 
Transwetern's policy to maintain an environmetnal presence at all of its 
locations, especially at sites where there is some aesthetic value (scenery 
wildlife etc).  I dont have a problem with including resource reports 3 and 7 
for vegetation and soils.  I have received a verbal from the US Fish and 
Wildlife and they agreed with the intent in my letter to them that pipline 
activites at each location tend to preclude any impacts to sensitive or 
critical habitats.  In addition, the adjacent lands are of the same habitat 
types as that which are contained within the facility and therefore, would 
not be an issue of habitat loss.   There are not any old TW hands around to 
positively verify that the site was cleanred and there has been natural 
encroachment of the trees into the area, I seriously doubt it.  Again, TW 
tried to mantain a postive presence at each site, but did utilize the sites 
for their intended purpose.

In Arizona, we do not have a blanket approval for discharges of hydrostatic 
testwater.  We do however plan to use new pipe and water supplied either from 
the closest City (ie Flagstaff for station 2 construction) or from a drinking 
well source.  In any event, we will test the water prior to discharge and 
ensure that the discharge will stay on the facility property to soak into the 
ground.  I cant imagine that there will be large volumes of hydro water as we 
dont plan on installing a large amount of new pipe.

If we need to discuss the above, give me a call     




"Hackett, Terry" <THackett@ENSR.com> on 03/09/2001 02:18:52 PM
To: "'Larry.Campbell@enron.com'" <Larry.Campbell@enron.com>
cc: "'Donna.Martens@enron.com'" <Donna.Martens@enron.com> 

Subject: Station 2 Concerns


Larry,

I gave the tree issue at Station 2 some thought and I have a couple of
concerns regarding the environmental report.  The report is being written,
based on the fact that all construction will occur within the station yard
and on previously disturbed ground.  If we impact areas (even within
existing facilities) that were not previously disturbed we are required to
include environmental data about those areas.

So the first question is whether the entire station yard has been
"previously disturbed".  To help determine this, I downloaded a USGS aerial
(1996) of the station from the internet and the trees occurring within the
station yard look to be the same age/size as those surrounding the station.
This would indicate that the areas within the station covered with trees
have not been "previously disturbed".  A copy of the aerial is attached.

However, it is conceivable that the site was cleared prior to initial
construction and the trees simply grew back.  Unfortunately, I don't have
that information and don't know if you do either.  And let me point out that
my concern is not whether Transwestern will receive approval to construct,
but the amount of information supplied in the report.  I want to feel
comfortable that we are supplying the required information to FERC.

For this project, that would primarily include a description of the existing
vegetation and soils (resource report 3 and 7).  All we would really need is
a brief description of the existing vegetation and soils, and how much will
be permanently impacted, etc. However, we did not budget any time to obtain
this information, nor did we anticipate the need for site visits.

My hope is that we can find an answer to whether the site was previously
disturbed or not.  If not, I hope to come up with some verbiage that
everyone is comfortable with to satisfy the FERC requirements.  Otherwise,
we will have to obtain the necessary information, and that's beyond our
initial scope.

If you have had any biological reports done for the area on other projects,
that may provide enough information.  Again, it only needs to be brief.
Also, we need to verify for the other 3 stations that we are constructing in
previously disturbed areas.

Lastly, Arnold has indicated that the hydro-test water will come from
existing water source at each station and that it will be discharged under
Transwestern's blanket permit.  Please verify...and I think we should
provide a copy of the blanket permit with the filing.

After you have had a chance to think about this, please call and we can
discuss.

Terry.

 <<Station 2 aerial.jpg>>


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 - Station 2 aerial.jpg