It is a concern that BPA only defines the action as the construction of the transmission line.  In most actions, such as this, the agency (DOE) defines the action as the construction, operation, and maintenance.

This is important, as the new line will operate at least 60 years. Wanapum will require certain prohibitions at certain times of the year.  If BPA does not define the action as operation and maintenance, BPA will only be able to agree to prohibitions for construction.  

That is just one example. When we add operation and maintenance, which again is generally standard then we begin to think differently about the impacts.  We would like to see the discussion on operation and maintenance included in the action and expanded where it is currently very brief elsewhere in the current EA version. 

Keeping in mind the verbal discussions that the Hanford Tribal Technical Working Group has had with you during monthly meetings for this project, I did not find it necessary to reiterate the discussion points made there.  Instead, I wanted to add some new comments and questions that I had during a recent read of the EA that was distributed in June 2012. 

The CTUIR  CRPP will continue to stay involved with this project on the front end which includes pre-construction, construction, operations, and maintenance.  Concerns will develop during construction and the life of the transmission line and the CRPP wants to continue to consult with BPA on these efforts.  As for the future, the CRPP wants to make sure there is adequate funding for continued cultural resources activities associated with this project and life of the line.  Perhaps there should be a cooperative agreement of sorts for Tribes to help with future activities associated with all future BPA activities (includes meetings, office, and field work) on Hanford.

As discussed in our technical meetings, in years to come, CTUIR would like to consult with BPA on the eventual removal of all lines on Gable Mountain.  Removal of the Midway-Benton No. 1 is a good start. 

P.2-8:  2.2.2. Access Roads:   BPA states that they do not plan on improving existing access roads to remove the structures in Segment 3 (including the Gable Butte and Gable Mountain areas) unless necessary.  Based on past experience with BPA and road access, the CRPP requires technical consultation if any road work is needed.  All road work should be monitored at all times to ensure that the contractor is staying within the confines of the scope of work. 

BPA says they will still maintain the Midway-Benton No. 2 transmission line in this segment, therefore the access roads for Midway-Benton No. 1 would be left in place.  Is there only one access road for both lines?  Do both lines parallel each other?  The CRPP was hoping that after line removal of No. 1 that the access road and all improvements to the road would be removed as well. 

P.2-14:  2.4:  Construction Activities:   BPA’s general construction sequence for this activity would first include removal of structures, conductors, ground wire, and counterpoise.   CRPP requests to be notified prior to activities at each structure and may at that time request further consultation regarding how a particular pole or structure is to be removed. 

P.3-62:   3.8.1:  Cultural Resources:   The third paragraph in this section needs to be re-written.  Historic properties do not include only prehistoric resources and TCPs are not properties that have to be eligible.  In the 4^th paragraph, there is a typo (he should be the).

P.3.66:  Traditional Cultural Properties:   Tribes need to discuss how  to refer to Gable Mountain and Gable Butte. BPA refers to them as separate TCPs.   Is there one TCP landscape that includes both major land forms or does oral history separate the Mountain from the Butte?  This section will expand upon discussions with Tribes. 

P. 3-68:   3.8.4:  Mitigation Measures--  :   Bullets three and four need clarification.  If BPA has two Inadvertent Discovery Plans, one for archaeological material and one for human remains, then they should be labeled as such.  Bullet #3 should read “Implement BPA’s Inadvertent Discovery of Archaeological Materials Procedure for Projects  and bullet #4 should read “The Inadvertent Discovery of Human Remains Procedure.  At Hanford we use the term, unanticipated discovery of cultural resources,  to avoid unnecessary confusion with the discovery of human remains.     I suggest taking a look at the titles of your procedures and add the exact titles here.        

This is all I have for now.  Thank you for all your time that you have given us to discuss this project, our concerns, and questions. 

Julie