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 4th 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