CDTC comments on DEIS for Sun Zia Project proposal

Continental Divide Trail Coalition

P.O. Box 552 Pine, CO 80470**(720)-340-2382


August 21, 2012

Adrian Garcia

Project Manager

Bureau of Land Management

New Mexico State Office

301 Dinosaur Trail

Santa Fe, NM 87508-1560


Re: SunZia Transmission Project Draft Enviromental Impact Statement

Dear Mr. Garcia,

I am writing on behalf of the Continental Divide Trail Coalition (CDTC) to provide comments on the SunZia Southwest Transmission Project Draft Environmental Impact Statement. Our comments are specific to the planning and management of the Continental Divide National Scenic Trail.


The Continental Divide National Scenic Trail (CDNST) was designated by Congress in 1978 as a unit of the National Trails System. The 3,100 mile CDNST traverses the magnificent Continental Divide between Mexico and Canada. It travels through 25 National Forests, 21 Wilderness areas, 3 National Parks, 1 National Monument, 8 BLM resource areas and through the states of Montana, Idaho, Wyoming, Colorado and New Mexico. The vision for the Continental Divide National Scenic Trail is to create a primitive and challenging backcountry trail on or near the Continental Divide to provide people with the opportunity to experience the unique and incredibly scenic qualities of the area. For many of the same reasons National Parks are established, National Scenic Trails are created to conserve the nationally significant scenic, historic, natural and cultural qualities of the area. In addition, National Scenic Trails are designed for recreation and the enjoyment of these very special places.


The Continental Divide Trail Coalition (CDTC) was recently established (June 2012) to provide a national voice and advocate for the CDNST and ensure all areas of Trail protection, promotion, and volunteer stewardship continue to be fully realized.  Prompted by the continued threat of a lack of progress in the Trail’s completion due to shrinking agency budgets and to ensure opportunities for public involvement continued in the absence of a national nonprofit partner, trail enthusiasts formed the Continental Divide Trail Coalition to work with the Federal Agencies tasked with administrative responsibility for the CDNST. The CDTC is comprised of natural resource professionals, CDNST volunteers and supporters, and most importantly Trail users.  CDTC is committed to work on behalf of the Trail and the Trail’s community.  The goal of the CDTC is to become the umbrella group for all CDNST Trail Groups and as a national non-profit partner with the federal agencies in the management of the CDNST, to advise on policy, monitor policy impacts, advocate for congressional appropriations, and establish community based on-going volunteer stewardship of the Trail.

CDTC recognizes the need for additional transmission corridors and lines to accommodate the growing industry of alternative energy sources available in New Mexico. However, CDTC would like to address our concerns for the affect this proposed project will have on the planning and management of the Continental Divide National Scenic Trail.

Trail Location in the Project Area:

The CDNST is located in and around the proposed Lordsburg Substation.  For specific location, we recommend contacting USFS CDNST Program Administrator who may provide you with a location map.  The trail in the are will be impacted by both the construction of the substation facilities as well as the transmission lines coming into and out of the facility.

Nature and Purpose of the CDNST:

As stated in the CDNST Comprehensive Plan, “the nature and purposes of the Continental Divide National Scenic Trail are to provide for high quality, scenic, primitive hiking and horseback-riding, non-motorized recreational experiences and to conserve natural, historic, and cultural resources along the Continental Divide.”  As stated in the CDNST Study Report (page 14)  “One of the primary purposes for establishing the Continental Divide National Scenic Trail would be to provide hiking and horseback access to those lands where man’s impact on the environment has not been adverse to a substantial degree and where the environment remains relatively unaltered. Therefore, the protection of the land resource must remain a paramount consideration in establishing and managing the trail and its corridor. There must be sufficient environmental controls to assure that the values for which the trail is established are not jeopardized ”.

Some general findings from the CDNST Study Report that assist in describing these terms include:

a)     “Designation and establishment of a 3,100 mile Continental Divide Trail…would provide the American people with recreational opportunities of national significance and that trail users would wind their way through some of the most spectacular scenery in the United States and have an opportunity to enjoy a greater diversity of physcial and natural qualities than found on any other extended trail.” (Study Report; page 4)

b)    The Study Report also “advocates that the most minimal development standards consistent with these circumstances be employed..the trail should be regarded as a simple facility for the hiker-horseman.” (Study Report; page 8)

c)     The Study Report describes the trail experience as an “intimate one, where one can walk or ride horseback across vast fields of wildflowers and contemplate a story dating from the dawn of earth’s history…along the way the tranquility of the alpine meadows, verdent forests and semi—desert landscape overwhelms anyone who passes that way. The Trail would provide the traveler his best encounter with the Continental Divide—its serenity and pure air—and would supply for every trail traveler some of the world’s most sublime scenes.” (Study Report; page 18)

The Study Report further identifies the significant qualities, characteristics and trail opportunities of the proposed CDNST in five representative segments on pages 20-52.  Excerpts include:

  1. Scenic Qualities: Spectacular Scenery of the quality and magnitude along the proposed CDT route is not available anywhere in the Continental United States. The trail traverses a variety of terrain, including high desert, forests, geologic formations, and mountain meadows.  Flora abounds in the near views, while distant views of major valleys and maintain peaks are exceptional.  (Study Report page 98)
  2. Cultural Qualities: There are significant segments of the trail and adjacent trails that were used by early-day Indians, ancient cliff-dwelling tribes, Spanish explorers and mountain men in their travels within and through the Continental Divide area.  Little visible evidence is left of these activities; however, through interpretative signing, trail users will be alerted to the cultural significance of the area. (Study Report page 101)
  3. Historic Qualities: Many signs of historical activity are within the vicinity of the trail and throughout its entire length. Thus, any person visiting the area may have some advance knowledge of the historical significance of the area to make the visit more meaningful. (Study Report page 103)
  4. Natural Qualities: The “visitor” of the proposed route of the CDNST would encounter a great variety of terrain, geology, climate, and plant and animal life.  This would include the unique and unusual character of Glacier, Yellowstone and the Rocky Mountain National Parks and the back-country solitude of 16 (now 25) National Forest Wilderness and primitive Areas, as well as the living quality of the Red Desert of Wyoming.  Certain plants, trees, and animals that may be observed along the Trail are unique to the area traversed.  (Study Report page104, as modified)

 Incorporating the CDNST Comprehensive Plan into the Mimbres Resource Management Plan:

CDTC is working to develop and encourage consistent management direction for the CDNST across differ­ent administrative unit boundaries. We support the direction as expressed by the CDNST Comprehensive Plan because we feel it offers all administrative units responsible for managing the Trail and its corridor the necessary information and direction to fulfill the intent of the National Trail System Act and ensures consistent administrative treatment of the Trail’s recreational, natural, and cultural resources.

In review of the DEIS, we discovered the new direction for the CDNST as described in the 2009 CDNST Comprehensive Plan has not been used to develop or evaluate the alternatives included in this proposal.  Specifically, the Mimbres Resource Management Plan (RMP) does not reflect the new direction, the evaluation of impacts or treatment of the CDNST in the current DEIS is not consistent or conforming.  Therefore without the resolution of this issue, it is inappropriate to determine what, if any, impacts the Sun Zia transmission line may have on the nature and purposes of the CDNST.  In order to accomplish this, CDTC recommends the Mimbres Resource Management Plan be amended to incorporate this significant new information that will affect land use allocations. Furthermore, we feel that any determination of action may not be made until the primary issues addressing the utilization of the 2009 CDNST Comprehensive Plan in Mimbres RMP occur and bring the plan into compliance.

Adopting CDNST direction in the RMP is within the scope of the SunZia EIS due to potential direct and cumulative impacts of the proposed action and expected connected.  Once the Mimbres RMP is revised or amended, the SunZia (and Southline) transmission line proposal can be further assessed following NEPA processes.  The EIS needs to objectively assess and disclose whether the proposal and connected wind and solar energy developments would substantially interfere with the nature and purposes of the CDNST.  Projects that would result in a substantially interference should not be permitted.

CDNST Comprehensive Plan Direction

Protection includes providing consistent and deliberate management direction for issues such as a desired condition for the Continental Divide National Scenic Trail, scenery management practices, suitable Recreation Opportunity Spectrum (ROS) classification(s), and various other management practices related to timber management, mineral extraction, species of concern, roads, and other special uses within or proximate to the CDNST.  We recommend a consistent approach to treatment and recognition of the CDNST as well as the other National Scenic and Historic Trails affected by this Draft EIS. Therefore, CDTC requests this new direction be utilized in this process.

Special Resource Management Area:

CDTC recommends that upon amendment, the Mimbres RMP should address CDNST integration needs by establishing a revised Special Recreation Management Area (SRMA) direction following the guidance in IM No. 2011-004 or any more recent National Trail planning direction.

Specific recommendations regarding management for the Desired Experience for the CDNST

CDTC promotes the following desired condition for the CDNST Corridor:

The CDNST is a continuous trail in nature from the Mexico-New Mexico Border to Montana–Canada Border for travel primarily by hikers and equestrians through the wild, scenic, forested, desert and culturally significant lands of the Rocky Mountains.  It is usually a simple path, purposeful in direction and concept, favoring the Continental Divide and located for minimum construction to protect the resource. The body of the Trail is the lands it traverses and its soul is in the living stewardship of the volunteers and workers of the Trail community.

Views from the CDNST are predominantly wide-ranging and grand in nature.  The trail offers a diversity of topography and a variety of vegetation and animal life exposing the user to the entire range of land forms, water features, history, and uses of the land that are found along the Rocky Mountain Region.  The corridor appears natural to the visitor and is characterized by a range of ecological life zones.

This special area retains a natural healthy forested and alpine landscape character shaped by both natural processes and humans. Visitors will experience diversity of native plant and animal species. This corridor traverses a range of Recreation Opportunity Spectrum (ROS) classes. The CDNST setting will either be consistent with or complement the primitive and semi-primitive non-motorized ROS Class. Careful trail design will allow for an appearance of a more primitive setting than the recreation opportunity spectrum would predict.  The linear nature of the corridor is recognized in determining the ROS class.  Roads, utility corridors, or signs of mineral development may be seen, yet they remain visually subordinate.

An atmosphere of self-reliance and respect for CDNST values is fostered and all activities in the Special Area are designed to maintain or enhance the CDNST experience.

CDNST desired conditions should include a “recreation experience not materially different in quality than that extended by a bona fide hiking and equestrian trail and one that is”:

  1. quiet
  2. in a wild and primitive setting
  3. with a natural surface single track (18-36 inches wide)
  4. harmonizes and compliments the surrounding landscapes
  5. travel is at a slow pace

Therefore, CDTC recommends the inclusion of CDNST management direction to achieve the following:

  1. serve to protect the significant experiences and features that exist along the CDNST
  2. establish the best location for a non-motorized CDNST through the most primitive, scenic, diverse and undeveloped landscapes on or near the CDNST that will provide a wide range of experiences and challenges
  3. allow for existing trails to be considered for the final CDNST route so long as they are non-motorized and meet the nature and purpose for a National Scenic Trail
  4. foster communication, participation and partnership along the CDNST
  5. require monitoring and evaluation of the conditions on and around the CDNST
  6. assure proper and sensitive standards pertaining to establishment, operation and maintenance of the trail. Further, it would provide common objectives and means to coordinate the efforts of many agencies and interests having responsibility for implementation.” (Study Report; page 5)

Protection of Visual Resources

CDNST Comprehensive Plan direction that states the USFS Scenery Management System (SMS) is the framework for integrating all scenery management data into all levels of forest planning. The SMS identifies the existing landscape character, visual sensitivity, and scenic integrity, and how actions may affect and alter those resources. We encourage values of Very High or High whenever possible to meet the nature and purpose of the CDNST. In some cases, where the CDNST crosses major highways, or is in proximity to more urban settings, it may result in a value of moderate as an interim, but the goal should always be to attain a level higher than would be suggested by its classification.

CDTC is concerned that the approach of the project proposal risks the loss of protection of resources central to the Trail experience. We recommend the mapping of visual resources and the impacts to these resources should be done in a manner consistent with the Scenery Management System to adequately protect the integrity and quality of the scenic resources in the areas traversed or impacted by the identified project location.

Development and the Continental Divide National Scenic Trail

Development Projects like wind energy farms, natural gas-pipelines, electric transmission lines, telephone trunk lines, communication towers and many smaller utility–distribution lines of all types already cross the Trail in many locations.  These sites are, by nature, intensive, high profile land uses.  The visual impacts and, in some cases, the audible impacts of these facilities detracts from the primitive recreational experience provided by the Trail.  These developments often can be seen for miles from the trail, disrupting an otherwise undisturbed scene (or scenery) found in these unique environments for many miles.  Adverse impacts also include lights, access roads, cleared swaths of land, off-road vehicle access on utility right-of-ways, guy wires, chain link fences, and chemical treatments of the vegetation in the corridor.  These ancillary impacts are often more intrusive than the lines, or sites themselves.  Furthermore, the cumulative impacts of the expansion and development of utility corridors and facilities upon the CDNST environment are substantial.

To this end, CDTC seeks to minimize the impacts of utility developments and their associated facilities on the Trail’s resources.  To do so, CDTC encourages avoiding the following resources whenever possible in sighting utility corridors and facilities near the Trail:

  1. Wilderness areas and their adjacent buffer zones;
  2. Semi-primitive non-motorized areas and other special management or natural areas;
  3. Areas of significant cultural, historic and natural value;
  4. The Foreground zone as determined by Visual Resource Management system for all Trails, and as seen from prominent viewpoints and key scenic features such as rock outcrops with large expansive vistas, or open landscape, sub alpine, alpine areas where the landscape is uninterrupted by man’s influence or development;
  5. Wetlands and other important natural features; and
  6. Any other special area where important Trail values, such as a sense of remoteness, would be compromised.

In addition, we encourage the following guidelines to identify areas, where when necessary to cross, parallel or otherwise include the CDNST, utility lines and facilities may be located as to reduce their impacts to the CDNST:

  1. Locating at a site where the CDNST crosses an existing state or federal highway or highway intersection.  In these instances, through applying sound sighting procedures, many of these crossings may only be visible at the point of intersection.
  2. Locating at a site where the CDNST crosses areas that are already developed, and classified as Rural or Urban by the USFS Recreation Opportunity Spectrum (ROS);
  3. Upgrading or co-aligning a new corridor with existing lines, or relocating existing lines into new single corridors, and the subsequent decommissioning of replaced or relocated utility lines;
  4. Utilization of  an underground route through open areas for natural gas pipelines; and
  5. Passage through an area where Trail values, such as a sense of remoteness, would not be compromised.

Most importantly, we ask and encourage the review teams to engage with CDTC and our agency partners to identify these key areas and potential mitigation when the CDNST and its unique resources can not be avoided.

Protection of Recreational Experiences

As a unit of the National Trails System, and otherwise considered designated area, the project proposal should include a fully evaluated section on impacts to recreational experiences within, intersected by, or otherwise impacted by the proposed project.  We realize that each section of the CDNST is unique with specific localized conditions, however, we also feel that there should be consistent treatment of the Trail and its resources and the experience it offers all users in the discussion of impacts to recreational resources in this document.

CDTC supports the use of the Recreation Opportunity Spectrum (ROS) system to delineate, define, and integrate CDNST recreational opportunities in land management planning (FSM 2311.1). The CDNST should be located in Primitive and Semi-Primitive Non-Motorized ROS settings  where available in the land management planning area, while recognizing that the CDNST will intermittently traverse through more developed areas, and across designated motor vehicle use routes (Subpart B— Designation of Roads, Trails, and Areas for Motor Vehicle Use, Part 212 Travel Management, of Title 36 Code of the Code of Federal Regulations (36 CFR 212 subpart B)), in order to provide for a continuous travel route between Canada and Mexico along the Continental Divide. Where the CDNST must be located in a ROS setting of lesser scenic integrity, management guidelines for that segment should reflect long term goals to improve the setting to reflect a primitive and semi-primitive setting.

Cumulative Impacts to the Continental Divide National Scenic Trail

Perhaps our greatest concern has to do with cumulative effects. If full environmental-impact analysis occurs only at the project or activity level, then how does the agency propose to assess the cumulative impacts of multiple projects or activities over time and their impacts to the entire CDNST? While we applaud the agency’s intentions to undertake such a collaborative process, we are concerned that without rigorous attention to the cumulative impacts of incremental decisions, the cumulative impacts of multiple projects and activities could be obscured and lead to unintended consequences that may or may not be consistent with a particular management direction for the CDNST. CDTC believes that for linear resources, such as the CDNST or any National Scenic or Historic Trail, that are affected by more than one project area like this over its entire 3,100 mile span, that special attention be given to a full exploration and understanding of the cumulative effects to these very special and unique resources. 

Mitigation of impacts to the CDNST

We recommend that the EIS address mitigation to help alleviate direct, ancillary and cumulative impacts to the CDNST in identification of this potential wind energy development project.  The section should address the need for both on-site and off-site enhancements to benefit the unavoidable scenery and Recreation Opportunity Spectrum setting effects on the CDNST and other National Scenic and Historic Trails.  Potential mitigation to minimize impacts could be both on site and off site strategies and might include the following:

  1. Funding for CDNST trail development and maintenance, corridor management, rights-of-way acquisition, and trailhead developments;
  2. Removal of facilities that are no longer needed to improve the quality of the Trail corridor;
  3. Relocation of existing smaller capacity transmission lines to the corridors identified by the EIS, and reclamation of those sites back to a natural state;
  4. Careful review of the height and type of power line towers;
  5. Careful location of power line towers so as to minimize their impacts, like using perpendicular crossings versus parallel routings to the Trail;
  6. Color and reflectivity of facilities to minimize their lay on the landscape; and
  7. Landscape treatment within the right-of-way and at other places that screen structures.

Thank you for the opportunity to express our concerns regarding the proposed SunZia Southwest Transmission Project. We request to remain on the mailing list and to be engaged in future public involvement processes regarding this process.  I can be reached at (540) 449-4506 and if needed to clarify our comments.


Teresa Ana Martinez /s/

Teresa Ana Martinez,

CO –founder and Director

Continental Divide Trail Coalition