Item Number: 2 · Monopole tubular steel structures are also cost competitive for this Project...

Control Number: 50964

Item Number: 2

Addendum StartPage: 0

PUC DOCKET NO. 50964

APPLICATION OF ELECTRIC § TRANSMISSION TEXAS, LLC TO § AMEND ITS CERTIFICATES OF § CONVENIENCE AND NECESSITY FOR § THE PROPOSED LOBO TO CORAZON § SOLAR 345-KV TRANSMISSION LINE § IN WEBB COUNTY §

BEFORE THE

PUBLIC UTILITY COMMISSION

OF TEXAS

< t ' .v I Jj O ' APPLICATION

3

JULY 24,2020

TABLE OF CONTENTS 6 -\

SECTION NX, PAGE

Application . ? List of Attachments 19 Attachment 1 70 Attachment 2 941 Attachment 3 , ?51 Attachment 4 307 Attachment 5 308 Attachment 6 ....309 Attachment 7 ....310 Attachment Ra 311 Attachment 8b 313 Attachment 8r ....314 Attachment 8d 315 Attachment Rp 170 Attachment 8f 371 Attachment 8g 1?7 Attachment 9a 3?3

Attachment 9b 395

Attachment l Oa 3?6 Attachment 10b ...., 30X

Attachment 11 399

Attachment 1?a 331 Attachment 12b 335

Attachment 13 136 Attachment 14a ....337 Attachment 14b..... 338 Attachment 15 339

APPLICATION OF ELECTRIC TRANSMISSION TEXAS,

LLC TO AMEND ITS

CERTIFICATES OF CONVENIENCE

AND NECESSITY FOR THE

PROPOSED LOBO TO CORAZON SOLAR

345-kV TRANSMISSION LINE

IN VVEl*B COUNTY

DOCKET NO. 50964

Submit seven (7) copies of the application and all attachments supporting the application. If the application is being filed pursuant to P.U.C. Subst. R. 25.JOJ (b)(3 )(D) or P.U.C. Subst. R. 25.174, include in the application all direct testimony. The application and other necessary documents shall be submitted to:

Public Utility Commission of Texas Attn: Filing Clerk 1701 N. Congress Ave. Austin, Texas 78711-3326

Application of Electric Transmission Texas, LLC to Amend its Certificates of Convenience and Necessity for the Proposed Lobo to Corazon Solar 345-kV Transmission Line in Webb County

Applicant Electric Transmission Texas, LLC (ETT) requests that all parties serve copies of all pleadings, discovery, correspondence, and other documents on the following ETT representative:

Service Contact:

Melissa Gage State Bar No. 24063949 AEP Service Corporation 400 W. 15th Street, Suite 1520 Austin, Texas 78701 (512) 481-3320 (Telephone) (512) 481-4591 (Facsimile) maeage(ihaep com

Kerry McGrath State Bar No. 13652200 Duggins, Wren, Mann & Romero, LLP 600 Congress Ave., Suite 1900 Austin, Texas 78701 (512) 744-9300 (Telephone) (512) 744-9399 (Facsimile) [email protected]

Attorneys for Electric Transmission Texas, LLC

Page 2 CCN Form Effective Date: June 8, 2017

W


1. Applicant (Utility) Name : Electric Transmission Texas, LLC

Certificate Number : 30193 and 30194

Street Address 400 W. 15th Street, Suite 800 Austin, TX 78701

Mailinq Address: 400 W. 15th St., Suite 800 Austin, TX 78701

2. Please identify all entities that will hold an ownership interest or an investment interest in the proposed project, but which are not subject to the Commission's jurisdiction.

Not Applicable

3. Person to Contact:

Title/Position-

Phone Number*

Mailine Address:

Randal E. Roper, PE

Regulatory Case Manager - AEP Texas, Inc.

(512) 481-4572 400 W. 15th Street, Suite 1520 Austin, TX 78701

Email Address reroper @ aep . coni

Alternate Contact:

Title/Position

Phone Number

Mailin2 Address

Roy R. Bermea

Regulatory Consultant - AEP Texas, Inc.

(512)481-4575 400 W. 15th Street, Suite 1520 Austin, TX 78701

Email Address · i · rberinea @ aep . coin

Legal Counsel: Kerry McGrath

Phone Number · ( 512 ) 744 - 9300

Mailint Address 600 Congress Ave ., Suite 1900 Austin, TX 78701

Email Address : kmcgrath @ dwmrlaw . com

Page 3 CCN Form Effective Date: June 8,2017


4. Project Description:

Name or Desitnation of Project

Application of Electric Transmission Texas, LLC to amend its certificates of convenience and necessity for the Proposed Lobo to Corazon Single-Circuit 345-kV Transmission Line Project in Webb County (Application).

Provide a general description of the project, including the desifrn voitaffe ratinfz (kV), the operatinR voltate (kV). the CREZ Zone(s) (ifanv) where the project is located Call or in part), anv substations and/or substation reactive compensation constructed as part of the project, and anv series elements such as sectionalizimz switching devices, series line compensation, etc For HVDC transmission lines, the converter stations should be considered to be project components and should be addressed in the project description

Electric Transmission Texas, LLC (ETT), a joint venture between subsidiaries of American Electric Power (AEP) and Berkshire Hathaway Energy Company (BHE), is proposing to develop, construct, and operate a new 345-kilovolt (kV) transmission line in Webb County, Texas, to interconnect a proposed 200 megawatt (MW) solar generation facility with the existing ETT Lobo Station. The proposed Lobo to Corazon Solar 345-kV Transmission Line Project (Project) would be constructed as a single-circuit 345-kV transmission line that will extend from the existing ETT Lobo 345-kV Station to the proposed Corazon Solar point of interconnection (POI). The Project will be constructed using self-supporting, single-circuit tubular steel monopole structures. The total length ofthe proposed Project will be approximately 3.9 miles along a Consensus Route obtained with the consent of the directly impacted landowner and will require a 150-foot right-of-way (ROW) adjacent to an existing 345-kV 150-foot ROW. The proposed Project is designed to directly interconnect a new transmission service customer, BayWa r.e, Solar Projects, LLC (BayWa), into the existing ETT Lobo 345-kV Station. BayWa has requested ETT to interconnect its proposed 200 MW solar farm at 345-kV.

If the project will be owned bv more than one partv, brieflv explain the ownership arrantements between the parties ai'idprovideadescriptionofthe portion(s) that will beownedbveachpartv Providea description of the responsibilities of each partv for implementint the proiect (desizn, Right-Of-Wav acquisition, matenal procurement, construction. etc )

Not applicable. The Project that is the subject ofthis Application will be owned solely by EU.

Jdentifv and explain anv deviation in transmission project components from the oriszinal transmission specifications as previouslv approved bv the Commission or recommended bv a PURA §39 151 organization

Not applicable. There are no transmission specifications that have been previously approved by the Commission. The Electric Reliability Council of Texas (ERCOT) Nodal Protocols Section 3.11 (relating to Transmission Planning) defines a project that interconnects new generation as a "neutral project," which does not require ERCOT Regional Planning Group (RPG) review. Since the Project was not submitted for RPG review, ERCOT did not provide any Project transmission specifications. Thus, in the transmission Project components, there are no deviations from the original transmission specifications previously recommended by ERCOT (a PURA § 39.151 organization).

5. Conductor and Structures:

Conductor Size and Tvpe

The conductor used for the Project will be bundled 795 KCM ACSR (Drake) with two 26/7 Stranded OPGW shield wires.

Number of Conductors Per Phase

The Project will be constructed with two (2) conductor bundles per phase.

Continuous Summer Static Current Rating (A)

The Continuous Summer Static Current Rating for the Project is 2,054 Amps.

Continuous Summer Static Line Cat}acitv at Operatin2 Voltage (MVA)


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The Continuous Summer Static Line Capacity at Operating Voltage for the Project is 1,277 MVA.

Continuous Summer Static Line Capacitv at Desitn Voltage (MVA)

The Continuous Summer Static Line Capacity at Design Voltage for the Project is 1 ,277 MVA.

Tvpe and Composition of Structures

The Project will be constructed primarily using self-supporting single-circuit tubular steel monopole structures on a combination of direct-embedded monopoles for some locations and base-plated monopoles on drilled shaft foundations for other locations. Alternative structure types may be used if engineering constraints are encountered. Constraints may include items such as Federal Aviation Administration (FAA) height limitations, underground and overhead obstructions, or existing line or highway crossings.

Hei2ht of Tvpical Structures

The typical single-circuit structure for the Project will be between 115 -175 feet in height. The height may vary depending on location, clearance requirements due to the terrain, span lengths, and overhead obstructions.

Estimated Maximum HeiH.ht of Tvpical Structures

The estimated maximum height of a typical single-circuit structure for the Project will be 175 feet above ground. Note that all structures will have a 2-foot reveal on the foundation.

Explain whv these structures were selected, include such factors as landowner preference, eneineerimz considerations, and costs comparisons to alternate structures that were considered Provide dimensional drawinfzs of the tvpical structures to be used in the proiect.

The specific area of the Project is currently predominantly brushland/shrubland used for grazing. This is the primary reason that self-supporting tubular steel monopole structures were selected for this Project since they provide a reduced structure footprint. Landowners overwhelmingly prefer single-pole construction in an area where grazing or farming is occurring as well.

The reduced footprint of the monopole structure will ease the ability to access the easement in a manner to reduce the impact to grazing operations for maintenance of the area around the structure, as well as provide the ability of the landowner to utilize more of the property. Monopole tubular steel structures are also cost competitive for this Project application.

Dimensional drawings of the monopole structures are included as Figures 1 - 2 and 1 - 3 of the Environmental Assessment . Proposed Lobo to Corazon Solar 345 - kV Transmission Line in Webb County ( EA ). This document, prepared by ETT's routing consultant TRC Companies (TRC), is also referred to in this application as the EA, and is included as Attachment 1 to this Application.

For joint applications, provide and separateiv identifv the above-required information regardingi structures for the portion(s) of the project owned bv each applicant

Not applicable. This is not a joint application.

6. Right-of-way:

Miles of Right-of-Wav

The total miles ofROW for the Consensus Route filed by E'IT is approximately 3.9 miles in length.

Miles of Circuit

The Project will be a single-circuit transmission line with conductors for one phase installed and the number of circuit miles is approximately 3.9 miles.



Width of Right-of-Wav

The typical ROW for the Project will be 150 feet in width.

Percent of Ritht-of-Wav Acquired

ETT has acquired written consent from the landowner for each of the five parcels crossed by the Consensus Route presented for this Project. Written consent from the landowner for each parcel crossed by the Consensus Route is provided as Attachment 2 to this Application. An aerial road permit for crossing U.S. Highway 59 is anticipated but has not been obtained at this time.

For joint applications, provide and separatelv identifv the above-required information for each route for the portion(s) of the proiect owned bv each applicant.

Not applicable. This is not ajoint application.

Provide a briefdescription of the area traversed bv the transmission line. Include a description of the general land uses in the area and the tvpe of terrain crossed bv the line.

The Study Area (Figure 2-1 in the EA) traversed by the transmission line is in the southeastern portion of Webb County, approximately 11.5 miles northeast of the City of Laredo. No incorporated cities are located within the Study Area. The unincorporated area of Ranchitos Las Lomas, TX is a census-designated place (CDP) beginning approximately 0.75 mile east of the proposed Corazon Substation and north of U.S. Highway 59. There are no schools or other facilities located within the Study Area boundary.

Land-surface elevations range from a high of approximately 750 feet above mean sea level (msl) along the western boundary of the Study Area north of U.S. Highway 59 to a low of approximately 642 feet above msl at the south boundary of the Study Area south of the ETT Lobo Station. The Study Area is predominantly undulating rangeland and has experienced a moderate degree of alteration due to ranching operations and support facilities,

7. Substations or Switching Stations:

List the name of all existin2 HVDC converter stations, substations or switchin£ stations that will be associatedwith the new transmission line. Provide documentation showinz that the owner(s) of the existinsz HVDC converter stations, substations and/or switchint stations have agreed to the installation of the required project facilities

The existing Lobo 345-kV Station is owned by ETT.

List the name ofall new HVDC converter stations, substations or switchimz stations that will be associated with the new transmission line Provide documentation showinf that the owner(s) of the new HVDC converter stations, substations and/or switching stations have afzreed to the installation of the required project facilities

The new Corazon Solar POI will be owned by BayWa.


<1


Estimated Schedule:*

Estimated Dates Of:

Right-of-Way Acquisition

Engineering and Design

Material and Equipment Procurement

Construction of Facilities

Energize Facilities

Start

March 5,2020

January 18, 2020

June 30,2020

October 15, 2020

May 10, 2021

Completion

June 10,2020 January 8, 2021

February 2021

May 10, 2021

May 15, 2021

* With the Consensus Route and necessary easerDents obtained to connect the Lobo Station and Corazon Solar POI, this schedule was provided for a non-contested proceeding.

Counties:

For each route, list all counties in which the route is to be constructed.

The Consensus Route evaluated for this project is located entirely in Webb County, Texas.

10. Municipalities:

For each route. list all municipalities in which the route is to be constructed.

The Consensus Route evaluated for this Project is not located within the incorporated limits of any municipality.

For each applicant, attach a copv ofthe franchise, permit, or other evidence ofthe city's consent held bv the utilitv. if necessarv or applicable. If franchise, permit. or other evidence of the citv's consent has been previouslv filed, provide onlv the docket number of the application in which the consent was filed Each applicant should provide this information onlv for the portion(s) of the project which will be owned bv the applicant.

Not Applicable.

11. Affected Utilities:

Identifv anv other electric utility served bv or connected to facilities in this application

There is no other electric utility served by or directly connected to this Project.

Describe how anv other electric utilities will be afRcted and the extent of the other utilities' involvement in the construction of this project. Include anv other utilities whose existing facilities will be utilized for the project (vacant circuit positions. ROW, substation sites and/or equipment, etc ) and provide documentation showin2 that the owner(s) of the existin2 facilities have atreed to the installation of the required project facilities

Not applicable.

12. Financing:

Describe the method offinancing this project. For each applicant that is to be reimbursed for all or a portion of this project, identifv the source and amount of the reimbursement (actual amount if known, estimated amount otherwise) and the portion(s) of the project for which the reimbursement will be made. Funds for this Project will come from short-term borrowings and owner equity.


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13. Estimated Costs:

Provide cost estimatesfor each route ofthe proposedproiect usingthe followint table Provide a breakdown of"Other" costs bv major cost catesrorv and amount. Provide the information for each route in an attachment to this application

The estimated costs for the Consensus Route for the transmission line facilities and for the termination costs at the existing ETT Lobo Station associated with this Project are provided in the table below.

Transmission Substation Facilities Facilities

Right - of - way and Land Acquisition $ 50 , 000 $ 0

Engineering and Design ( Utility ) $ 75 , 000 $ 10 , 000

Engineering and Design ( Contract ) $ 595 , 450 $ 948 , 360

Procurement of Material and Equipment ( including stores ) $ 3 , 818 , 150 $ 3 , 338 , 520

Construction of Facilities ( Utility ) $ 150 , 000 $ 150 , 000

Construction of Facilities ( Contract ) $ 3 , 340 , 900 $ 4 , 096 , 720

Other $ 0 $ 0 Estimated Total Cost $ 8,029,500 $ 8,543,600

For joint applications, provide and separately identifv the above-required information for the portion(s) of the project owned bv each applicant.

Not applicable. This is not a joint application.

14. Need for the Proposed Project:

For a standard application, describe the need for the construction and state how the proposed project will address the need. Describe the existin2 transmission svstem and conditions addressed bv this application. For projects that are planned to accommodate load growth. provide historical load data and load projections for at least five vears. For projects to accommodate load 2rowth or to address reliabilitv issues, provide a description of the steadv state load flow analvsis that justifies the project. For interconnection projects, provide anv documentation from a transmission service customer, tenerator, transmission service provider, or other entitv to establish that the proposed facilities are needed For projects related to a Competitive Renewable Energv Zone, the fore*oing requirements are not necessarv, the applicant need onlv provide a specific reference to the pertinent portion(s) ofan appropriate commission order specifvinz that the facilities are needed. For all proiects, provide anv documentation of the review and recommendation of a PURA §39.151 organizalion

Pursuant to 16 Texas Administrative Code (TAC) § 25.198(b), a transmission service provider (TSP) is required to provide service for a transmission customer service request when certain conditions are met, including execution of an interconnection agreement. The ERCOT Standard Generation Interconnection Agreement between ETT and BayWa for such an interconnection transmission service request has been executed and included in this Application as Attachment 3. Pursuant to 16 TAC § 25.198(d), a facilities study was also performed to evaluate this transmission service request and determine the cost of transmission facilities required to provide the requested 345-kV transmission service. Additionally, 16 TAC § 25.195(c)( 1 ) provides as follows: "When an eligible transmission service customer requests transmission service for a new generation source that is planned to be interconnected with a TSP's transmission network, the transmission service customer shall be responsible for the cost of installing step-up transformers to transform the output of the generator to a transmission voltage level and protective devices at the point of interconnection capable of electrically isolating the generation source owned by the transmission service customer. The TSP shall be responsible, pursuant to paragraph (2) ofthis subsection, for the cost of installing any other interconnection facilities that are designed to operate at a transmission voltage level and any other



upgrades on its transmission system that may be necessary to accommodate the required transmission service." The Interconnection Agreement between ETT and BayWa is provided as Attachment 3 and specifies and assigns these responsibilities pursuant to 16 TAC § 25.195(c)(1).

The ERCOT RPG Charter and Procedures defines a project that is directly associated with the interconnection of new generation as a "neutral project", which is not required to be submitted for RPG review. Therefore, there is no documentation of a review or a recommendation of a PURA § 39.151 organization.

The location of the Project activity is in close proximity to the existing ETT Lobo Station. The ETT Lobo Station already has 345-kV circuits terminating into the station and the requested 345-kV service request can be provided by termination of direct interconnection into this existing station as well.

15. Alternatives to Project:

For a standard application, desci·ibe alternatives to the construction of this project (not routin£ options) Include an analvsis of distribution alternatives, upgrading voltaze or bundlint of conductors of existinjz facilities. addinH transformers, and for utilities that have not unbundled, distributed Reneration as alternatives to the proiect Explain how the project overcomes the insufficiencies of the other options that were considered.

There are no other practical alternatives to the Project that address the 345-kV transmission service request made by the generator. Any other 345-kV transmission service option not terminating at the Lobo Station would require the construction of a new station as well as some distance of transmission line for the interconnection based on where the station property could be purchased. The use of distribution to attempt to transfer 200 MW from the generation customer's Corazon Solar POI to the ETT Lobo Station is not a practical engineering solution and not responsive to the transmission service request of the generator. The most practical and cost-effective solution to address the interconnection transmission service request is the direct interconnection as proposed.

16. Schematic or Diagram:

For a standard application, provide a schematic or diagram of the applicant's transmission svstem in the proximate area ofthe project. Show the location andvoltasze ofexistinfz transmission lines and substations, and the location of the construction Locate anv taps, ties, meter points, or other facilities involving other utilities on the svstem schematic

A schematic ofthe transmission system in the proximate area ofthe Project is included with this Application as Attachment 4.

I 7. Routing Study:

Provide a briefsummarv ofthe routing studv that includes a description ofthe process ofselectin£ the studv area, identifving routimz constraints, selectin2 potential line sezments, and the selection of the routes Provide a copv ofthe complete routinz studv conducted bv the utilitv or consultant. State which route the applicant believes best addresses the requirements of PURA and PUC Substantive Rules

A copy ofthe complete environmental assessment EA for the Consensus Route, prepared by TRC, is included as Attachment 1 to this Application. The EA presents the analysis that was conducted by TRC and includes the land use and environmental data for the Consensus Route that is being presented in this Application.

The objective of the complete EA was to evaluate the potential environmental and land use impacts for the Project's Consensus Route presented in the Application, and determine if that route complies with the Public Utility Regulatory Authority (PURA) § 37.056(c)(4)(AHD), 16 TAC § 22.52(a)(4), and 16 TAC § 25.101(b)(3)(B), including the Public Utility Commission's (P.U.C.) policy of prudent avoidance. ETT and TRC utilized a comprehensive and well-established evaluation methodology to evaluate the potential environmental and land use impacts ofthe proposed transmission line Consensus Route.



ETT and TRC utilized a multiphase approach for completing such a project route evaluation: define the Study Area; obtain environmental information; map environmental and land use constraints and opportunities; conduct environmental, engineering, and cost analyses; and design and construct the transmission facility. The following sections provide a description ofthe process used in the development and evaluation ofthe proposed Consensus Route.

Description of the Process of Selecting the Studv Area

The Study Area was determined by beginning with the two end points for the transmission line. ETT's existing 345-kV Lobo Station location was used to establish the southern extent and the proposed generator-owned Corazon Solar POI location was used to establish the northern extent. The Corazon Solar POI location, approximately 2.4 miles north of U.S. Highway 59 and approximately 12.8 miles northeast of Laredo, Texas, was established by the solar developer, BayWa, as the optimal location for interconnection near its proposed solar arrays.

The locations of these endpoints established the approximate boundaries of the Study Area. The south boundary of the Study Area is an area around the existing ETT Lobo Station, the north boundary is approximately 0.2 mile north of the proposed Corazon Solar PO[, the west boundary is approximately 0.8 mile west ofthe proposed Corazon Solar POI and approximately 0.2 mile west ofthe existing Lobo Station, and the east boundary is approximately 0.2 mile east of the Lobo Station and the proposed Corazon Solar POI. The Study Area boundary is approximately 0.70 mile in length east to west, and approximately 3.2 miles in length north to south. The Study Area contains approximately 2.28 square miles and is shown on Figure 2-1 in the EA.

Identification of Routing Constraints

Data used by TRC in the evaluation of the Project was drawn from a variety of sources, including published literature (documents, reports, and maps), information from local, state, and federal agencies, recent aerial photography and ground reconnaissance of the Study Area. The routing criteria considered the following aspects ofthe human environment, environmental, and cultural resources:

Human Environment

• Paralleling existing linear facilities, with pipelines considered a constraint • Land use, including habitable structures

Environmental Resources

• Physiography and Geology • Soils • Mineral and Energy Resources • Surface Water • Wetlands • Sensitive Vegetation Habitats • Sensitive Fish and Wildlife Habitats • Recreationally and Commercially Important Species • Threatened and Endangered Species (TES) Critical Habitats

Cultural Resources

• Sensitive Historic Sites • Sensitive Cultural Sites

In addition, the length, number ofangle structures, number of land parcels crossed, and cost were considered. The complete routing criteria is shown in Table 6-1 ofthe EA (Attachment 1 to this Application).

The mapping process was used to identify areas ofconstraint and opportunity. Locations of environmentally sensitive and other restrictive areas within the Study Area were located and considered during the evaluation



process. These constraints were mapped onto an aerial base map (Figure 2-2 of the EA) created using Google Earth Pro 2019. While it is difficult to eliminate the use ofall areas of constraint, alternatives were identified to minimize such areas and impacts to human and environmental resources.

The evaluation of the Project involved studying a variety of environmental factors using desktop analysis of aerial maps and resource maps and an initial field visit conducted on January 29,2020. In addition, biological field surveys were conducted along the ROW for the Consensus Route on February 26-27,2020. The initial field evaluation was conducted by driving the Study Area and reviewing aerial and resource maps. The follow-up biological field evaluation was conducted by walking along the proposed ROW for the Consensus Route. In evaluating the proposed Consensus Route, 39 environmental criteria were considered. These criteria are presented in Table 6-1 ofthe EA (Attachment 1 to this Application). Figure 2-2 ofthe EA shows the environmental and land use constraints within the Study Area.

Consensus Route

The Consensus Route was selected based on evaluation of the potential impacts along with consideration of the direct path between the interconnection points, being parallel to the existing 345-kV line, the length, number of angle structures, number of land parcels crossed, and habitable structures associated with other alternatives. ETT representatives contacted the impacted Iandowner that owns the parcels in the Study Area that was crossed by the Consensus Route and was able to obtain Consensus Agreements that are provided as Attachment 2 to the Application. ETT also determined that the Consensus Route for the Project complies with the requirements of PURA and P.U.C. Substantive Rules.

18. Public Meeting or Public Open House:

Provide the date and location for each public meeting or public open house that was held in accordance with 16 TAC §22 52 Provideasummarv ofeachpublicmeeting orpublic openhouseincludinszthe approximate number of attendants, and a copv of anv survev provided to attendants and a summarv of the responses received. For each public meetinz or public open house provide a description of the method of notice, a copv ofanv notices, and the number of notices that were mailed and/or published.

No public open house meeting was held for this Project. 16 TAC § 22.52 requires an applicant to hold at least one public open house meeting if 25 or more persons would be entitled to receive direct mail notice of the Application. There are fewer than 25 landowners that would be entitled to receive direct mail notice of the Application for the Consensus Route. However, ETT representatives have discussed this transmission project with the representative or owner of all the land directly impacted by this Project and have received signed Consent Agreements from the Iandowner crossed by the Consensus Route (Attachment 2 to this Application). There are no habitable structures within 500 feet located on any adjacent properties to the Consensus Route.

16 TAC § 22.52 (a)(4) related to notice in licensing proceedings, requires a utility to notify the Department of Defense (DoD) Siting Clearinghouse of any public meeting to be held during the route evaluation process. In the event that no public meeting is held due to a small number of affected landowners, the utility is required to provide written notice to the DoD Siting Clearinghouse of the utility's intent to file an application at the P.U.C. ETT provided notice to DoD of its intent to file an application with the P.U.C to amend its Certificates of Convenience and Necessity to construct a single-circuit 345-kV electric transmission line in Webb County, Texas on June 19,2020. This notice is included as Attachment 5 to this Application

19. Routing Maps:

Base maps should be a full scale (one inch = not more than one mile) hiszhwav map of the countv or counties involved, or other maps of comparable scale denotin2 sufficient cultural and natural features to permit location ofall routes in the field. Provide a map (or maps) showint the studv area, routimz constraints, and all routes or line segments that were considered prior to the selection ofthe routes. Identifv the routes and anv existing facilities to be interconnected or coordinated with the project. Identifv anv taps, ties, meter points, or otherfacilitiesinvolving other utilities on the routinfz map. Show all existinz transmission facilities



located in the studv area Include the locations of radio transmitters and other electronic installations, airstrips, irrifzated pasture or cropland, parks and recreational areas, historical and archeoloizical sites (subject to the instructions in Ouestion 27), and anv environmenfallv sensitive areas (subject to the instructions in Ouestion 29).

A Consensus Route map is provided in the EA (Attachment 1 of this Application). Figure 2-2 of the EA is an aerial photograph-based map with a scale of 1 inch = 3,000 feet that shows the Study Area, the proposed Consensus Route and stations, routing constraints, other environmental and land use features, and existing transmission lines.

Provide aerial phototraphs of the studv area displaving the date that the photofrraphs were taken or maps that show (1) the location of each route with each route segment identified, (2) the locations of all maior public roads including, as a minimum, all Rderal andstate roadways. (3) the locations ofall known habitable structures or groups of habitable structures (see Question 19 below) on properties directlv afRcted bv anv route. and (4) the boundaries (approximate or estimated according to best available information if required) of all properties directlv affected bv am; route.

An aerial-photograph-based property ownership map with a scale of 1 inch = 3,000 feet is included in this Application as Attachment 6. It shows the approximate boundaries of all properties that are directly affected by the proposed 345-kV transmission line Consensus Route. Each property has been assigned a unique "Property/Map ID" number. There are no habitable structures located within 500 feet of the Consensus Route. This Property/Map ID number is among the information provided in Attachment 7 that is the cross-reference table discussed below.

For each route, cross-reference each habitable structure (or group of habitable structures) and directlv affected propertv identified on the maps or phototraphs with a list of corresponding landowner names and addresses and indicate which route segment affects each structure/group or property.

There are no habitable structures located within 500 feet ofthe Consensus Route. Landowner names, property identification, links, and map locations are included in a cross-reference table provided as Attachment 7 of this Application.

20. Permits:

List anv and all permits and/or approvals required bv other 2overnmental agencies for the construction of the proposed project Indicate whether each permit has been obtained.

ETT will coordinate with all the appropriate local, state, and federal agencies with jurisdiction regarding the construction ofthe transmission facilities associated with this Project. ETT and TRC have initiated contact with and provided information about the Project to various agencies. Some input from these agencies has been incorporated in this Application; however, requests for permits and or approvals will not be submitted to the appropriate agencies until the Consensus Route is approved and final alignment is determined. None ofthe following potential permits, approvals, requirements, easements, or clearances have been obtained.

• The proposed Project is not expected to affect aviation operations in the Study Area and FAA notification is not anticipated. However, notification to the FAA might be required for the Consensus Route once structure locations and structure designs and heights are complete. Requirements to alter the design of the structures or potential requirements to mark or illuminate the line will be coordinated with the FAA, as necessary.

• Under Section 404 of the Clean Water Act (CWA), activities in Waters of the U.S. (WOTUS) can be regulated by the United States Army Corps of Engineers (USACE). Project consultation with the Fort Worth District of the USACE was initiated in February 2020. The USACE has not responded to date. The proposed Project is not anticipated to affect WOTUS. However, permits or other requirements associated with possible impacts to WOTUS under the jurisdiction of the USACE will be coordinated with the USACE as necessary. The proposed transmission line crosses no USACE-owned property; therefore, no easements on USACE property will be necessary.



• The U.S. Fish and Wildlife Service (USFWS) administers federal wildlife laws under the jurisdiction of the Endangered Species Act (ESA), Migratory Bird Treaty Act (MBTA), and the Bald and Golden Eagle Protection Act (BGEPA). An initial evaluation of federally protected species was conducted using the USFWS Information for Planning and Consultation (IPaC). No critical habitat for federally protected species is located within or near the Study Area. Permits or other requirements associated with possible impacts to endangered/threatened species, although not expected, will be coordinated with the USFWS as necessary.

• The Texas Parks and Wildlife Department (TPWD) is the state agency with the primary responsibility of protecting the fish and wildlife resources in accordance with the TPWD Code Section 12.001 1(b). TRC requested information from TPWD's Texas Natural Diversity Database (TxNDD) and county listed TES lists. TPWD responded by email with recommendations for avoiding impacts to protected species. Although the likelihood of presence exists in the Study Area for some of the state listed TES, no adverse impacts are expected to occur as a result of the construction of the proposed Project. If protected state species are identified during clearing or construction, coordination with TPWD might be necessary to determine the need for any surveys and to avoid or minimize any potential adverse impacts to sensitive habitats, TES, and other fish and wildlife resources along the Consensus Route. ETT will provide a copy of the EA to the TPWD for its review within seven days after filing the Project with the P.U.C. and will coordinate, as necessary, with TPWD to avoid and/or minimize impacts to state protected species.

• Impacts to floodplains located in Webb County, as directed by the Federal Emergency Management Agency (FEMA), are administered by the Webb County Planning and Physical Development Department. Based on feedback from Webb County, the Consensus Route has not been evaluated or determined to be within the designated Webb County floodplain and a floodplain permit is not expected to be required to authorize construction of the transmission line.

• A Storm Water Pollution Prevention Plan (SWPPP) might be required by the Texas Commission on Environmental Quality (TCEQ). E'IT or its contractor will submit a Notice of Intent to the TCEQ at least 48 hours prior to the beginning of construction if necessary. E'IT will have the SWPPP on site at the initiation of clearing and construction activities.

• Permits for crossing state-maintained roads/highways will be obtained from the Texas Department of Transportation (TxDOT), as necessary.

• Cultural resources are protected by federal and state laws if they have some level of significance under the criteria of the National Register of Historic Places (NHRP). The Texas Historical Commission (THC) reviewed the Project plans under the Antiquities Code of Texas and determined that the Consensus Route will not require a cultural resources survey or permit for consideration by the P.U.C. prior to initiating any ground disturbance.

• The Texas General Land Office (GLO) requires a Miscellaneous Easement (ME) for any ROW crossing a State-owned riverbed, navigable stream, or tidally influenced waters. No GLO easement has been identified or is anticipated for this project.



21. Habitable Structures:

For each route, list all sinfrle-familv and multi-familv dwellimzs and related structures. mobile homes, apartment buildints, commercial structures, industrial structures, business structures, churches, hospitals, nursing homes, schools, or other structures normallv inhabited bv humans or intended to be inhabited bv humans on a dailv or retular basis within 300 feet ofthe centerline ifthe proposed project will be constructed for operation at 230kV or less, or within 500 feet of the centerline if the proposed project will be constructed for operation at greater than 230kV Provide a general description of each habitable structure and its distance from the centerline of the route. In cities, towns, or rural subdivisions, houses can be identified in groups. Provide the number ofhabitable structures in each group and list the distance from the cenjerline of the route to the closest and the farthest habitable structure in the group. Locate all listed habitable structures or Hroups of structures on the routin2 map

There are no habitable structures located within 500 feet ofthe centerline of the Consensus Route.

22. Electronic Installations:

For each route, list all commercial AM radio transmitters located within 10,000 Ret of the centerline of the route and all FM radio transmitters, microwave relav stations, or other similar electronic installations located within 2,000 of the centerline of the route. Provide a 2eneral description of each installation and its distance from the center line of the route. Locate all listed installations on a j'outing map.

No commercial AM radio transmitters are located within 10,000 feet ofthe centerline ofthe Consensus Route and no commercial FM radio transmitters microwave towers are located within 2,000 feet of the centerline of the Consensus Route. There is one private communications tower located within the Study Area adjacent to the south side ofthe Lobo Station. This tower is owned by AEP Texas.

The proposed transmission line along the Consensus Route will have no effect upon the electronic installations described above.

23. Airstrips:

For each route, list all known private airstrips within 10,000 feet of the center line of the project. List all airports registeredwith the Federal Aviation Administration (FAA) with at least one rumvav more than 3,200 feet in lentth that are locatedwithin 20,000 feet of the center line ofanv route. For each such airport, indicate whether anv transmission structures will exceed a 50:1 horizontal slope (one foot in height for each 100 feet in distance) from the closest point of the closest rumvav. List all listed airports refristered with the FAA having no rumvav more than 3,200 feet in lentth that are located within 10,000 Ret of the center line ofanv route . For each such airport , indicate whether anv transmission structures will exceed a 50 : 1 horizontal slopefromtheclosestpointoftheclosest rumvav List all heliports locatedwithin 5,000 Ret of the center line ofanv route. For each such heliport, indicate whether anv transmission structures wiH exceed a 25: 1 horizontal slope from the closest point of the closest landin2 and takeoff area of the heliport. Provide a general description of each listed private airstrip, registered airport, and heliport, and state the distance of each from the center line of each route Locate and idenfifv all listed airstrips, airports, and heliports on a routinH map

No known private airstrips are located within 10,000 feet ofthe centerline ofthe Consensus Route.

No known airports registered with the FAA with at least one runway more than 3,200 feet in length are located within 20,000 feet of the centerline ofthe Consensus Route.

There are no known FAA-registered airports having a runway more than 3,200 feet in length are located within 10,000 feet ofthe centerline of the Consensus Route.

No known heliports are located within 5,000 feet of the centerline of the Consensus Route.



24. Irrigation Systems:

For each route, identifv anv pasture or cropland irritated bv travelinfz irrigation svstems frollinH or Divot tvpe) that will be traversed bv the route Provide a description ofthe irritatedland and state how it will be affected bv each route (number and tvpe ofstructures etc ) Locate anv such irritated Dasture or cropland ona routing map.

No pasture or cropland irrigated by traveling irrigation systems (rolling or pivot type) will be traversed by the Consensus Route.

25. Notice:

Notice is to be provided in accordance with P U.C. Proc R. 22.52

A Provide a copv ofthewritten direct notice to owners ofdirectlv affecled land Attach a list of the names and addresses of the owners ofdirectlv affected land receiving notice.

Sample copies of the written direct notice and enclosures that were mailed to the owners of directly affected land are provided in Attachments 8a through 8f. The list of the names and addresses of the owners of directly affected land is provided in Attachment 8g.

B Provide a coin, of the written notice to utilities that are located within five miles of the routes

A sample copy ofthe written notice to utilities that are located within five miles ofthe proposed Project is provided in Attachment 9a. The list of the names and addresses of these utilities is provided in Attachment 9b.

C Provide a copv ofthe written notice to countv and municipal authorities, and the Department of Defense Siting Clearinghouse. Notice to the DoD Sitinfz Clearinfzhouse should be provided at the email address found at hftp hvinv aeq osd mil/dodsc.

Sample copy of the written notice to county and municipal authorities is provided as Attachment 10a. The list of the names and addresses of these authorities is provided in Attachment 1 Ob. A copy of the written notice to the Department of Defense Siting Clearinghouse is provided as Attachment 11.

D Provide a copv of the notice that is to be published in newspapers of;Zeneral circulation in the counties in which the facilities are to be constructed. Attach alist ofthe newspapers thatwillpublish the notice for this application After the notice is published, provide the publisher's affidavits and tear sheets.

A sample copy of the notice to be published in the newspaper of general circulation in the county in which the proposed facilities are to be constructed is provided in Attachment 12a. The notice for this Application will be published in The Laredo Morning Times, in Laredo, Texas, which is the newspaper of general circulation in Webb County and as listed in Attachment 12b.

For a CREZ application, in addition to the requirements of 16 TAC § 22.52 the applicant shall, not less than twentv-one (21) davs before the filing ofthe application, submit to the Commission staff a "generic" com; of each tvpe of alternative published and written notice for review. Staff's comments, if anv, refzarding the alternative notices will be provided to the applicant not later than seven davs after receipt bv Staff of the alternative notices, Applicant mav take into consideration anv comments made bv Commission staff before the notices are published or sent bv mail

Not applicable. This is not a CREZ application.

In addition to the notices described above, 16 TAC §22.52 requires ETT to provide notice ofthis Application to the Office of Public Utility Counsel. A copy ofthat notice is included in this Application as Attachment 13.



26. Parks and Recreation Areas:

For each route, list all parks and recreational areas owned bv a governmental bodv or an organized group, club, or church and located within 1,000 feet ofthe center line ofthe route Provide a general description of each areaandits distance fromthe centerline. Identifr the owner ofthe parkor recreationalarea (public agencv, church, club, etc.) List the sources used to identifv the parks and recreational areas. Locate the listed sites on a routin£ map

No parks or recreation areas are within 1,000 feet of the centerline of the Consensus Route or within the Study Area.

27. Historical and Archeological Sites:

For each route, list all historical and archeological sites known to be within 1,000 feet of the center line of the route. Include a description of each site and its distance from the center line. List the sources (national, state or local commission or societies) used to identifv the sites Locate all historical sites on a routin£ map For the protection of the sites. aj·cheol02icai sites need not be shown on maps.

To identify historical and archaeological sites in the Study Area, TRC researched the records and maps available online through the Texas Archaeological Research Laboratory (TARL) restricted archaeological site database and THC's publicly accessible Texas Historic Sites Atlas database. The two databases provide information and location regarding: listed and eligible National Register of Historic Places (NRHP) properties, sites, and districts; Official Texas Historical Markers; State Archaeological Landmarks; National Historic Landmarks; National Monuments; National Memorials; National Historic Sites; National Historical Parks; museums; cemeteries; historical highways; and courthouses.

This review identified 11 previously recorded cultural resources that are outside of the Study Area. The El Camino Real De Los Tejas National Historic Trail crosses the Study Area approximately 3,330 feet north of U.S. Highway 59. Because the transmission line can span across the trail route it is not anticipated that the trail will be impacted by the Project. The Consensus Route does cross Melone Creek and Becerra Creek and may have the potential for buried unknown/undocumented cultural resources. Given the proposed Project is entirely on private land, the land has undergone previous vegetation clearing and transmission line construction, and a large portion ofthe Study Area has been previously surveyed in 2019, TRC believes it is highly unlikely there are any cultural resource remains that have integrity and an intensive cultural resources survey is highly unlikely to discover any significant cultural resources that are presently unknown.

Because of the limited physical disturbance associated with construction of a substation and transmission line, and the ability to span areas where significant resources could occur, potential impacts to archaeological and historic cultural resources that would result from development of the Project are expected to be limited.

The proposed transmission line along the Consensus Route will have no effect upon the archaeological sites described above.

28. Coastal Management Program:

For each route, indicate whether the route is located, either in whole or in part, within the coastal manaeement Drofzram boundarv as defined in 31 TA.C. 4503 1. Ifanv route is, either in whole or in part, within the coastal manazement program boundarv, indicate whether anv part of the route is seaward of the Coastal Facilities Desiznation Line as defined in 3] TA C. fl 9 2(a)(21). Usinvi the designations in 31 T.A.C 4501 3(b), identifr the tvpe of Coastal Natural Resource Area (s) impacted bv anv part ofthe route and/or facilities.

This proposed Project is not located within the Coastal Management Program (CMP) boundary as defined in 31 TAC § 503.1.



29. Environmental Impact:

Provide copies ofanv and all environmental impact studies and/or assessments of the project. Ifno formal studv was conducted for this project, explain how the routing and construction of this project will impact the environment. List the sources used to identifv the existence or absence of sensitive environmental areas. Locate any environmentallv sensitive areas on a routint map. In some instances, the location of the environmentallv sensitive areas or the location of protected or endanzered species should not be included on maps to ensure preservation of the areas or species Within seven davs after filing the application for the project, provide a copv of each environmental impact studv and/or assessment to the Texas Parks and Wildlife Department (TPWD) forits review at the address below. Includewith this application a copv ofthe letter of transmittal with which f he studies/assessments were or will be sent to the TPWD.

Wildlife Habitat Assessment Program Wildlife Division Texas Parks and Wildlife Department 4200 Smith School Road Austin, Texas 78744

The EA that was prepared by TRC is included with this Application as Attachment 1. Data used by TRC in the evaluation of the Consensus Route were drawn from a variety of sources, including published literature (documents, reports, maps, aerial photography, etc.), information from local, state, and federal agencies, and field investigations conducted on January 29,2020 and February 26-27,2020. An extensive list of reference resources is provided in Section 8.0 of the EA. Ground reconnaissance ofthe Study Area and the proposed Consensus Route ROW, as well as computer-based evaluation of digital aerial imagery, aided in the evaluation. Environmentally sensitive areas (if any) are shown in Figure 2-2 ofthe EA.

A copy of the letter of transmittal of the Application, including the EA for this Project, to the TPWD is included in this Application as Attachment 14a. An affidavit verifying that the Application and EA were sent to TPWD is included in this Application as Attachment 14b.

30. Affidavit:

Attach a sworn affidavit from a qualified individual authorized bv the applicant to verifv and affirm that, to the best of their knowledze, all information provided, statements made, and matters set forih in this application and attachments are true and correct.

The sworn affidavit of the project manager for this Project is included with this Application as Attachment 15.



PUC Docket No. 50964 List of Attachments

Page 1 of 1

CCN Application - List of Attachments

1 Environmental Assessment

2 Consensus Route Agreements

3 Interconnection Agreement

4 Diagram of Transmission System in Project Area

5 ETT Letter of Intent to File CCN Application to DoD

6 Landownership Map

7 Landownership Cross-Reference Table

8a Notice - Landowner Letter 8b Notice - Map of Consensus Route 8c Notice - Consensus Route Description 8d Notice - Landowner Brochure 8e Notice - Comment Form 8f Notice - Intervenor Form 8g Notice - Landowner List

9a Notice - Utilities Letter * 9b Notice - Utilities List

10a Notice - County and Municipal Officials Letter * 10b Notice - County and Municipal Officials List

11 Notice - Department of Defense (DoD) Siting Clearinghouse*

12a Notice - Newspaper Publication 12b Notice - Newspaper Publication List

13 Notice - Office of Public Utility Counsel *

14a Letter of Transmittal of Application to the Texas Parks and Wildlife Department 14b Affidavit Transmittal of Application to TPWD

15 Application Affidavit of Project Manager

* Excluding Maps and Route Descriptions provided in Attachment 8 set of documents

PUC Docket No. 50964 Attachment 1

Environmental Assessment SM

Electric Transmission Texas

PROPOSED LOBO TO CORAZON SOLAR 345-kV TRANSMISSION LINE

IN WEBB COUNTY Docket No. 50964

June 2020

Environmental Assessment

prepared for

Electric Transmission Texas, LLC

Proposed Lobo to Corazon Solar 345-kV Transmission Line in Webb

County

Docket No. 50964

June 2020

prepared by

A ,TRC TRC Companies

Houston, Texas

Proposed Lobo to Corazon Solar 345-kV Transmission Line Table of Contents

TABLE OF CONTENTS Page No.

1.0 DESCRIPTION OF THE PROPOSED PROJECT 1-1 1.1 Scope of Project 1-1 1.2 Purpose and Need 1-3 1.3 Description of Proposed Design and Construction .............................................. 1-3

1.3.1 Transmission Line Design 1-3 1.3.2 Right-of-Way Requirements 1-6

1.4 Construction Considerations ................................................................................ 1-6 1.4.1 Clearing and Right-of-Way Preparation. 1-6 1.4.2 Structure Assembly and Erectinn 1-7 1.4.3 Conductor and Shield Wire Installation ................................................ 1-7 1.4.4 Construction Operations 1-7 1.4.5 Cleanup. 1-8

1.5 Maintenance Considerations.............................................................................. 1-9 1.6 Agency Actinnq 1-10

1.6.1 Public Utility Commission of Texaq 1-10 1.6.2 Federal Aviation Administration ............ 1-10 1.6.3 U.S. Army Corps of Engineers 1-11 1.6.4 U.S. Fish and Wildlife Service 1-12 1.6.5 Federal Emergency Management Agency 1-13 1.6.6 Texas Parks and Wildlife Department ................................................ 1-13 1.6.7 Texas Commission on Environmental Quality. ..... 1-13 1.6.8 Texas Department of Transportation 1-14 1.6.9 Texas Historical Commission 1-14 1.6.10 Texas General Land Office 1-14

2.0 ROUTE EVALUATION METHODOLOGY 2-1 2.1 Objective of Study 9-1 2.2 Data Collection .... 2-1 2.3 Evaluation of the Route. 2-1

2.3.1 Study Area Delineation 2-1 2.3.2 Constraints Mapping. 2-2 2.3.3 Evaluation Factors 2-4

3.0 EXISTING ENVIRONMENT 3-1 3.1 Physiography 3-1

3.1.1 Interior Coastal Plains 3-1 3.2 Geology

3-4 3-3

3.3 Soils... 3.3.1 Soil Associationq 3-5 3.3.2 Prime Farmland Soils 3-5

3.4 Mineral and Energy Resources 3-6 3.5 Water Resources .. 3-6

3.5.1 Surface Water 3-6 3.5.2 Floodplainq 3-6

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3.5.3 Groundwater/Aquifers 3-7 3.6 Vegetation.. 3-7

3.6.1 Regional Vegetation.. 3-7 3.6.2 Vegetation Community Types in the Study Area 3-8 3.6.3 Waters ofthe U.S., Including Wetlands . 3-11

3.7 Fish and Wildlife 3-16 3.7.1 Fish and Wildlife Habitats and Species 3-16 3.7.2 Fish 3-19 3.7.3 Reptiles 3-19 3.7.4 Bird q 3-22 3.7.5 Mammals 3-29

3.8 Recreationally and Commercially Important Specieq 3-30 3.9 Threatened and Endangered Species 3-30

3.9.1 Federally-Listed Threatened and Endangered Species....................... 3-31 3.9.2 Federally-Listed Fish, Wildlife, and Plant Species............................. 3-31 3.9.3 Critical Habitat 3-33 3.9.4 State-Listed Fish, Wildlife, and Plant Species.................................... 3-33

3.10 Human Resources 3-39 3.10.1 Community Values and Community Resources................................. 3-39 3.10.2 Land Use ..... 3-39 3.10.3 Recreation ....... 3-40 3.10.4 Agriculture ..... 3-40 3.10.5 Transportation and Aviation 3-41 3.10.6 Communication Towerq 3-41 3.10.7 Existing Utilities 3-42 3.10.8 Aesthetic Values 3-42

3.11 Cultural Resources ..... 3-43 3.11.1 Cultural Overview 3-44 3.11.2 Paleoindian Period (11,500-8,000 B.p.).. 3-46 3.11.3 Archaic (8,500-1,500 B.p) 3-46 3.11.4 Late Prehistoric (1,500-500 B.P.).. 3-48 3.11.5 Protohistoric Period (500-200 B.P.) and Historic Period (200-50

B.P.) ..... 3-48 3.11.6 Previous Investigations....... ..... 3-50 3.11.7 Results ofthe Background Review 3-51

3.12 Paleontological Resources 3-53 3.12.1 Present Climate 3-56

4.0 ENVIRONMENTAL IMPACTS OF THE PROJECT 4-1 4.1 Impact on Natural Resources... 4-1

4.1.1 Impact on Physiography and Geology.... 4-1 4.1.2 Impact on Soils 4-1 4.1.3 Impact on Water Resources 4-2 4.1.4 Impact on the Ecosystem 4-3

4.2 Impact on Human Resources ....... 4-7 4.2.1 Impact on Community Values 4-7 4.2.2 Impact on Land Use 4-7

Electric Transmission Texas, LLC ii TRC Companies


4.2.3 Impact on Recreation 4-9 4.2.4 Impact on Agriculture 4-9 4.2.5 Impact on Transportation and Aviation.. 4-9 4.2.6 Impact on Communication Towers 4-10 4.2.7 Impact on Existing Utilities 4-10 4.2.8 Impact on Aesthetics. _.. 4-10

4.3 Impact on Cultural Resources.. ...... 4-11 4.3.1 Direct Impacts on Cultural Resources ..... 4-11 4.3.2 Indirect Impacts ..... 4-12 4.3.3 Mitigation Measures for Cultural Resources 4-12 4.3.4 Summary of Impacts on Cultural Resources ..... 4-13

4.4 Environmental Mitigation 4-14 5.0 PUBLIC INVOLVEMENT ACTIVITIFR 5-1

5.1 Correspondence with Agencies and Officialq 5-1 5.1.1 Federal 5-1 5.1.2 State 5-1 5.1.3 Local _...5-2

5.2 Agency Actionq 5-5 5.3 Public Open-House Meetings.. 5-7

6.0 PROJECT ASSESSMENT 6-1 7.0 LIST OF PREPARERS 7-1 8.0 REFERENCES 8-1

Appendix A - Agency Correspondence Appendix B - Delineated Features Maps Appendix C - Easement Survey

TRC Companies Electric Transmission Texas, LLC iii


LIST OF TABLES Page No.

Table 3-1: Soil Unitq 3-5 Table 3-2: Waterbody Summary. 3-12 Table 3-3: Representative List of Fish Species That Potentially Occur in the Study Area~ ..............3-19 Table 3-4: Representative List of Reptile and Amphibian Species That Potentially Occur in the

Study Area~ 3-20 Table 3-5: Representative List of Avian Species of Potential Occurrence in the Study Area...........3-22 Table 3-6: IPaC List of Migratory Bird Speciesa 3-27 Table 3-7: Representative List of Mammalian Species that Potentially Occur in the Study Area.......3-29 Table 3-8: Federally-Listed Threatened, Endangered, and Special Status Species that

Potentially Occur in Webb County, Texasa 3-31 Table 3-9: State-listed Threatened, Endangered5 and Special Status Species that Potentially

Occur in Webb County, Texasa 3-33 Table 3-10: Previous Investigations Within one Mile ofthe Study Area 3-51 Table 3-11: Archeological Sites Within one Mile ofthe Study Area. 3-52 Table 6-1: Environmental Data for Consensus Route Assessment Lobo to Corazon 345-kV

Transmission Line Project 6-4 Table 7-1 TRC Professionals Involved in Preparation ofthis Environmental Assessment................7-1

Electric Transmission Texas, LLC iv TRC Companies


LIST OF FIGURES Page No.

Figure 1-1: Project Location 1-2 Figure 1-2: Typical Single-Circuit Tangent Monopole Structure 1-4 Figure 1-3: Typical Dead-end Two-Pole Angle Structure 1-5 Figure 2-1: Study Area Location 7-3 Figure 2-2: Environmental and Land Use Constraints Within the Study Area 2-5 Figure 3-1: Location of Webb County in Relation to the Physiographic Provinces of Texas..............3-2 Figure 3-2: Location of Webb County in Relation to the Vegetation Areas of Texas..........................3-9 Figure 3 - 3 : Topographic Map of Study A rea 3 - 14 Figure 3-4: SSURGO Soils Within the Study Area 3-15 Figure 3-5: Location of Webb County in Relation to the Biotic Provinces of Texas.........................3-18 Figure 3-6: Location of Webb County in Relation to the Central U.S. Whooping Crane Flyway......3-28 Figure 3-7: Location of Webb County in Relation to the Cultural Resources Planning Regions

of Texas 1-45

Electric Transmission Texas, LLC v TRC Companies


LIST OF ACRONYMS AND ABBREVIATIONS Abbreviation Term/Phrase/Name

ACEP Agricultural Conservation Easement Program

AEP American Electric Power

AEPSC American Electric Power Service Corporation

APE Area of Potential Effects

APLIC Avian Power Line Interaction Committee

Atlas Texas Archeological Sites Atlas

BayWa BayWa r.e. Solar Projects, LLC

BEG Bureau of Economic Geology

BHE Berkshire Hathaway Energy Company

BGEPA Bald and Golden Eagle Protection Act

BMP best management practice B.P. Before Present

CCN Certificate of Convenience and Necessity

CDP census-designated place CFR Code of Federal Regulations

CWA Clean Water Act

dba doing business as

DoD Department of Defense

DoI Department of Interior

EA Environmental Assessment

EOR Element Occurrence Record

EMST Ecological Mapping System of Texas

EPA U.S. Environmental Protection Agency

ESA Endangered Species Act

ESSS Ecologically Significant Stream Segments

ETT Electric Transmission Texas, LLC

FAA Federal Aviation Administration

FAR Federal Aviation Regulations

FCC Federal Communications Commission

FCS Flood Control Structures

FEMA Federal Emergency Management Agency

FIRM FEMA Flood Insurance Rate Maps

ft foot/feet

Electric Transmission Texas, LLC vi TRC Companies


Abbreviation Term/Phrase/Name

FVZ foreground visual zone FWCA Fish and Wildlife Coordination Act

GP General Permit

GIS Geographic Information System

GLO General Land Office

GMA Groundwater Management Area

HPA high probability area IP Individual Permit

IPaC Information for Planning and Consultation

kV kilovolt LRGV Lower Rio Grande Valley

MBTA Migratory Bird Treaty Act

ME Miscellaneous Easement

Mortenson Mortenson Construction

MW megawatt

NAIP National Agriculture Imagery Program

NASS National Agricultural Statistics Service

NEPA National Environmental Policy Act

NERC North American Electric Reliability Corporation

NESC National Electrical Safety Code

NFIP National Flood Insurance Program

NHD USGS National Hydrography Dataset

NOI Notice of Intent

NOT Notice ofTermination

NPDES National Pollution Discharge Elimination System

NPS National Park Service

NRA Nueces River Authority

NRCS Natural Resources Conservation Service

NRHP National Register of Historic Places

NWI USFWS National Wetlands Inventory

NWP Nationwide Permit

PCN Pre-Construction Notification

POI point of interconnection

Electric Transmission Texas, LLC vii TRC Companies



PSF Permanent School Fund

PSS palustrine scrub/shrub PUC Public Utility Commission ofTexas

PURA Public Utility Regulatory Act

RGRWA Rio Grande River Water Authority

RHA Rivers and Harbors Act

ROW right-of-way

RRC Railroad Commission of Texas

RTE Rare, Threated, and Endangered Species

SALs State Antiquity Landmarks

SCS Soil Conservation Service

SGCN Species of Greatest Conservation Need

STDC South Texas Development Council

SWPPP Storm Water Pollution Prevention Plan

T&E Threatened and Endangered Species

TAC Texas Administrative Code

TARC Texas Association of Regional Councils

TARL Texas Archeological Research Laboratory

TCAP Texas Conservation Action Plan

TCC AEP Texas Central Company

TCEQ Texas Commission on Environmental Quality

THC Texas Historical Commission

TLTC Texas Land Trust Council

TPDES Texas Pollution Discharge Elimination System

TPWD Texas Parks and Wildlife Department

TRC TRC Companies

TSHA Texas State Historica] Association

TWDB Texas Water Development Board

TxNDD TPWD Texas Natural Diversity Database

TxDOT Texas Department of Transportation

UISD United Independent School District

U.S. United States

USACE U.S. Army Corps of Engineers

Electric Transmission Texas, LLC viii TRC Companies



USDA U.S. Department ofAgriculture

USFWS U.S. Fish and Wildlife Service

USGS U.S. Geological Survey

UT unnamed tributary

WOTUS Waters ofthe U.S.

WRE USDA-NRCS Wetland Reserve Easement

Electric Transmission Texas, LLC ix TRC Companies

Proposed Lobo to Corazon Solar 345-kV Transmission Line Description of Proposed Project

1.0 DESCRIPTION OF THE PROPOSED PROJECT

1.1 Scope of Project

Electric Transmission Texas, LLC (ETT), a joint venture between subsidiaries of American Electric Power (AEP) and Berkshire Hathaway Energy Company (BHE), is proposing to develop, construct, and operate a new 345-kilovolt (kV) transmission line in Webb County, Texas, to interconnect a proposed 200 megawatt (MW) solar generation facility with the existing ETT Lobo Station. The proposed transmission line would be constructed as a single-circuit 345-kV transmission line starting from the existing ETT Lobo Station located approximately 11.5 miles northeast of the City of Laredo, Texas to the south and north of United

States (U.S.) Highway 59. The proposed transmission line heads north from the Lobo Station paralleling an existing 345-kV transmission line for approximately 3.2 miles to an angle structure and then will continue east approximately 0.7 miles to the proposed Corazon Solar point of interconnection (POD where the transmission line will terminate (Project). The proposed transmission line will be certificated as a single-circuit 345-kV transmission line. The total length of proposed Project will be approximately 3.9 miles along a Consensus Route obtained with the directly impacted landowner and will require a 150-foot wide right-of-way (ROW) adjacent to an existing 345-kV 150-foot ROW. Figure 1-1 shows the Project location; the Study Area is described in Section 2.3.1 and shown on Figure 2-1.

ETT retained TRC Companies (TRC) to prepare an Environmental Assessment (EA) to support its

application for a Certificate of Convenience and Necessity (CCN) to be submitted to the Public Utility Commission of Texas (PUC) for the Project. This document has been prepared to provide information and address requirements of Section 37.056 (c)(4) (A-D) ofthe Texas Public Utilities Code, the PUC's CCN application form and PUC Texas Administrative Code (TAC) §25.101, and the PUC's policy of "prudent avoidance." E'IT and Mortenson Construction (Mortenson) provided information in this Section and Sections 1.2,1.3,1.4, and 1.5 concerning the purpose and need for the Project, proposed design, construction methods, easements, clearing, cleanup, and maintenance. This document is intended to provide information and address issues concerning the natural, human, and cultural environment within the Study Area. This document may also be used in support of any additional local, state, or federal permitting activities that may be required for ETT's proposed Project.

Electric Transmission Texas, LLC 1-1 TRC Companies


Figure 1-1: Project Location

~Acni

9

3 -

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Figure 1-1 Project Location

Proposed Lobo to Corazon Single-Circuit 345-kV Transmission Line in Webb County, Texas



1.2 Purpose and Need

This proposed 345-kV transmission Project is designed to directly interconnect a new transmission

service customer, BayWa r.e. Solar Projects, LLC (BayWa), into the existing ETT Lobo 345-kV Station. BayWa has requested ETT to interconnect its proposed 200 MW solar farm. The proposed solar developments will have a single-circuit 345-kV transmission line circuit provided by ETT from the proposed Corazon Solar POI routed into the existing ETT Lobo 345-kV Station.

Additional details are provided in the CCN application regarding the termination into the ETT Lobo Station and the generator Corazon Solar POI. 16 TAC 25.191 (d)(3) requires a Transmission Service Provider to interconnect a generator once the other conditions are completed for transmission service, as defined in 16 TAC 25.191(c).

1.3 Description of Proposed Design and Construction

The following information has been developed by TRC and approved by ETT. This information presents

the proposed development and construction of facilities for the single-circuit 345-kV transmission line.

1.3.1 Transmission Line Design

ETT is proposing to use self-supporting, single-circuit tubular steel monopole structures for the Project,

as shown in Figure 1-2 and Figure 1-3. Design criteria will be per American Electric Power Service Corporation (AEPSC) standard design specifications and will comply with applicable statutes, the appropriate edition of the National Electrical Safety Code (NESC), and acceptable engineering design practice . Geotechnical considerations will include soil borings and in situ soil testing to provide parameters of foundation design and embedment depth ofthe structures. Structures will be supported by foundations that are appropriate and compatible to the structure design. It is expected for this Project that there will be a combination of direct-embedded monopoles for some locations and base-plated monopoles on drilled shaft foundations for other locations. The structure height above ground for the Lobo to

Corazon transmission line will range from 115 to 175 feet in height. These heights will vary depending upon terrain, span requirements, and engineering constraints. Span distance between the structures will vary from approximately 200 feet to 1,330 feet (average span length 800 to 900 feet), with some exceptions due to individual site conditions or engineering requirements.



Figure 1-2: Typical Single-Circuit Tangent Monopole Structure

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1.3.2 Right-of-Way Requirements

The proposed ROW width for this Project will be 150 feet, except for some angle turns that could require additional easement. The proposed transmission line will be located along the centerline of the ROW. Additional temporary workspace may be required at line angles and at dead-ends for conductor pull and construction. Refer to the Easement Survey in Appendix C for more details.

1.4 Construction Considerations

Projects ofthis type require surveying, ROW clearing, foundation installation, structure assembly, erection, conductor and shield wire installation, cleanup, and reclamation or revegetation when the Project

is completed. Construction operations will be conducted with attention to the preservation of natural habitat and existing terrain, as applicable.

1.4.1 Clearing and Right-of-Way Preparation

After regulatory approval and design ofthe transmission line is finalized, ROW will be acquired and then cleared according to ETT's clearing specifications. Clearing will be accomplished to comply with North American Electric Reliability Corporation (NERC) reliability standards. Mortenson, under the direction of ETT, will perform any required clearing ofthe ROW. Available methods of disposal will include mulching, brush piling, and salvaging. The option often selected by landowners requires that cleared brush or trees be stacked and left for use as wildlife habitat adjacent to, but off, the ROW. Trees and brush in the ROW are initially cleared to permit safe construction of the line.

The ROW will be utilized for access during construction operations, with ingress and egress through private property procured as necessary to access the ROW. In these cases, existing private roads will be used where possible. Culverts and angular rock fords will be installed to cross streams where necessary.

Public roads will be used for access to the ROW where feasible as well.

Clearing plans, methods, and practices are extremely important for success in any program designed to minimize the adverse effects of electric transmission lines on the natural environment. The following measures, thoughtfully implemented and applied to this Project, will help meet this goal:

1. Clearing will be performed in a manner that will maximize the preservation of natural habitat and

the conservation of natural resources and minimize impacts to waters in the activity area.

2. The method of clearing ROW will consider soil stability, the protection of natural vegetation,

sensitive habitats, the protection of adjacent resources such as natural habitat for plants and wildlife, and the prevention of silt deposition in watercourses.



3. ETT will use efficient and effective methods to remove vegetation within the ROW. Hydro axes

and flail mowers or similar devices may be used in clearing operations where such use will

preserve the cover crop of grass and similar vegetation.

4. If deemed appropriate, U.S. Environmental Protection Agency (EPA)-approved herbicides will be

applied and handled in accordance with the product manufacturers' published recommendations and specifications and as directed by appropriate qualified staff.

1.4.2 Structure Assembly and Erection

Survey crews will stake or otherwise mark structure locations. Depending on soil type, crews will either direct-embed structures or pour foundations utilizing augured circular holes, rebar cages, and anchor bolts or stubs. Crews will transport and assemble structures and related hardware. The usual procedure is to assemble each structure on its side, then lift the structure and set it on its base. However, taller structures may need to have sections assembled in the air. Sections are either jacked together or connected using bolts, which will be torqued to the manufacturer's recommended value. Once anchor bolt foundations have cured sufficiently, crews will set the structures and install the conductor and shield wire suspension assemblies.

Where direct-embedded structures are used, crews will install them by auguring oversized holes, lifting

and setting the structure, and backfilling with native soils, select fill, or concrete, depending on soil conditions at the site (based on soils testing). Although vehicular traffic is a large part of this operation, construction crews will take care to minimize damage to the ROW by minimizing the number of pathways traveled.

1.4.3 Conductor and Shield Wire Installation

The conductors and shield wires are installed via a tensioning system. A pilot (pulling) line is first

threaded through the stringing blocks or travelers for each conductor and shield wire. Conductor and shield wires are then pulled by the pilot line and held tight by a tensioner to keep the wires from coming into contact with the ground and other objects that could be damaging to the wire. In addition, guard structures (temporary wood-pole structures) will be installed where the transmission line crosses overhead electric power lines, overhead telephone lines, roadways, or other areas requiring an additional margin of safety during wire installation. When the wire is tensioned to the required sag, the wire is taken out of the blocks and placed in the suspension and dead-end clamps for permanent attachment.

1.4.4 Construction Operations

Construction operations will be conducted with attention to the preservation of the natural habitat and the conservation of natural resources. The following criteria will be used to attain these goals. These criteria



are subject to adjustment according to the rules and judgments of any public agencies whose lands may be crossed by the proposed line.

1. Disturbance of construction areas and laydown yards will be minimized. These areas will

be graded in a manner that will minimize erosion and conform to the natural topography.

2. Soil excavated during construction and not used for other purposes will be evenly

backfilled onto a cleared area. Backfilled soil will be sloped gradually to conform to the

terrain and adjacent land.

3. Erosion control devices will be constructed where necessary to reduce soil erosion in the

ROW.

4. If any roads are found to be necessary, they will not be constructed on unstable slopes.

Where feasible, service and access roads are constructed jointly.

5. Clearing and construction activities near streambeds will be performed in a manner that

will minimize damage to the natural condition ofthe area. Stream banks will be restored as

necessary to minimize erosion.

6. Concerted and diligent effort will be made to prevent accidental oil spills and other types of

pollution, particularly while performing work near streams, lakes, and reservoirs.

7. Precautions will be taken to prevent the possibility of accidental range fires.

8. Tension stringing of conductors will be employed, which may reduce the amount of

vegetation clearing necessary.

9. Precautions will be taken to protect natural features and cultural resources (identified by

site-specific studies of the Project) along the ROW, if any are found.

10. If federally protected species or habitat is present, guidance from the U.S. Fish and Wildlife

Service (USFWS) will be obtained prior to clearing or construction activities.

11. Soil disturbance during construction will be kept to a minimum, and restorative measures

will be taken within a reasonable length of time.

1.4.5 Cleanup

The cleanup operation involves the restoration of disturbed areas to grade (as much as possible), the removal of construction debris, and the restoration or compensation of any items damaged by the construction of the Project. The following criteria generally apply to the cleanup of construction debris and the restoration of the area's natural setting.



1. If site factors make it unusually difficult to establish a protective vegetative cover, other restoration procedures will be used, such as the use of gravel or rocks.

2. Sears, cuts, fill, or other aesthetically degraded areas will be allowed to seed naturally or may be

reseeded with native species to reduce erosion, restore a natural appearance, and to provide food and cover for wildlife.

Iftemporary access roads are removed after construction, the original slopes will be restored.

4. Construction equipment and supplies will be dismantled and removed from the ROW when

construction is completed.

5. Construction debris will be removed prior to completion of the Project.

6. Replacement of soil adjacent to water crossings for access roads will be at slopes less than the

normal angle of repose for the soil type involved and will be stabilized/revegetated to avoid erosion.

1.5 Maintenance Considerations

Maintenance of the facilities will include periodic inspection of the line and repair of damaged structures due to equipment failures, accidents, or natural phenomena, such as wind or lightning. In areas where treatment of vegetation within the ROW is required, mowing, pruning, or application of EPA-approved herbicides will be conducted as required (normally once every three to five years) to ensure proper clearance between the conductors and nearby vegetation. While maintenance patrols will vary, aerial, vehicle, and foot patrols will be performed periodically. in cropland areas and properly managed grazing lands and lawn areas, little or no vegetation control will be required, due to existing land-use practices. The major maintenance item will be the trimming of trees that pose a potential danger to the conductors or structures to provide a safe and reliable power line.

AEPSC's maintenance of ETT's transmission ROW occurs through the implementation of a comprehensive, systematic, integrated vegetation management program designed to ensure that the vegetation along each transmission line is managed at the proper time and in the most cost effective and environmentally sound manner. Vegetation is managed on a prescriptive basis. Ongoing evaluation of the system through ground and aerial inspections provides the basic information used by AEPSC to develop an annual plan. Circuit criticality, historical data, line voltage, location, vegetative inventory information, and land use are among the factors considered in developing the annual vegetation management plan. As conditions change, vegetation patrols may modify the plans.



1.6 Agency Actions

Numerous federal, state, and local regulatory agencies and organizations have promulgated rules and regulations regarding the routing and potential impacts associated with the proposed transmission line Project. This section lists the major regulatory agencies that are involved in project planning and permitting of transmission lines in Texas, and it describes the permits or approvals required. TRC solicited comments from various regulatory agencies and officials during the development of this document. A summary of agency responses is provided in Section 5.0 (Correspondence with Agencies and Officials) and copies of the responses received are included in Appendix A (Agency Correspondence). Construction documents and specifications will indicate any special construction measures needed to comply with the regulatory requirements listed below.

1.6.1 Public Utility Commission of Texas

The proposed transmission line Project will require ETT to file an application to amend its CCNs with the PUC. This EA report has been prepared by TRC in support of ETT's application to amend its CCNs for this Project. This document is intended to provide information on certain environmental and land use factors contained in Public Utility Regulatory Act (PURA) § 37.056(c)(4), and PUC's Substantive Rule 16 TAC § 25.10 1 (b)(3)(8), as well as to address relevant questions in the PUC's CCN application document to be used by an electric utility to amend a CCN. This report may also be used in support of any local, state, or federal permitting requirements, if necessary. ETT will obtain PUC approval of its CCN application prior to beginning construction of the Project.

1.6.2 Federal Aviation Administration

According to Federal Aviation Administration's (FAA) Federal Aviation Regulations (FAR), Part 77, the construction ofa transmission line requires FAA notification if structure heights exceed 200 feet or the height of an imaginary surface extending outward and upward at one of the following slopes (FAA, 2010):

• A 100:1 slope for a horizontal distance of 20,000 feet from the nearest point of the nearest

runway of a public or military airport having at least one runway longer than 3,200 feet.

• A 50:1 slope for a horizontal distance of 10,000 feet from the nearest runway of a public or

military airport where no runway is longer than 3,200 feet in length.

• A 25:1 slope for a horizontal distance of 5,000 feet for heliports.

Based on these guidelines, AEPSC, as agent for ETT, will make a final determination of the need for FAA notification based on the alignment of the approved Consensus Route, structure locations, and structure designs. If necessary, AEPSC will file a Notice of Proposed Construction or Alteration (Form 7460-1) with the FAA at least 30 days prior to construction. The result ofthis notification, and the



subsequent coordination with the FAA, could include changes in the design or potential requirements to mark or illuminate portions ofthe line.

1.6.3 U.S. Army Corps of Engineers

Under Section 404 of the Clean Water Act (CWA), activities in waters of the U.S. (WOTUS), including wetlands, can be regulated by the U.S. Army Corps of Engineers (USACE) in conjunction with the EPA. Certain construction activities that potentially impact WOTUS may be authorized by one of the USACE's Nationwide Permits (NWPs), or by a General Permit (GP) or Individual Permit (IP). All NWPs are subject to a series of general conditions which prohibits the use of NWPs to authorize any activity that is likely to directly or indirectly jeopardize the continued existence of a listed species protected by the Endangered Species Act (ESA) or destroy or adversely modi fy the critical habitat of a listed species.

Prior to April 15,2020, NWP 12 (Utility Line Activities) was typically utilized to authorize most utility line projects that resulted in potential impacts to WOTUS. However, a federal court in the District of Montana determined that the USACE's 2017 reissuance ofthe NWP 12 violated the ESA and therefore the court vacated NWP 12. As a result, NWP 12 cannot, at this time, be utilized to authorize any activities. Current USACE permits that may apply to placement of support structures and associated activities are NWP 25 (Structural Discharges) and NWP 3 (Maintenance). NWP 25 generally authorizes the discharge of concrete, sand, rock, etc., into tightly sealed forms or cells where the material is used as a structural member for standard pile-supported structures (linear projects, not buildings or other structures). NWP 3 generally authorizes the repair, rehabilitation, or replacement of any previously authorized, currently serviceable structure or fill, or of any currently serviceable structure or fill authorized by 33 CFR 330.3. The USACE may utilize NWP3 in some instances where minor deviations in the structure's configuration or filled area, including those due to changes in materials, construction techniques, requirements of other regulatory agencies, or current construction codes or safety standards that are necessary to make the repair, rehabilitation, or replacement are authorized. This NWP also authorizes the removal of previously authorized structures or fills that may be required for some new construction projects.

As a result of vacating NWP 12, the USAGE has indicated that if a current NWP cannot be utilized then a GP or IP may be warranted. GPs are issued nationwide or regionally for a category or categories of activities that are either similar in nature and cause only minimal individual and cumulative adverse impacts or would result in avoiding unnecessary regulatory control exercised by another federal, state, or local agency. Typically, GPs are utilized when the environmental consequences and/or impacts ofthe activity are expected to be individually and cumulatively minimal. GPs include terms and conditions for compliance and may require a preconstruction notification ofthe USACE prior to Project commencement.

An IP is the basic form of a permit. Processing such permits involves evaluation of individual, project specific applications in what can be considered three steps: pre-application consultation (for larger



projects), formal permit application review, and decision-making. Pre-application consultation usually involves one or several meetings between an applicant, USACE staff, interested resource agencies (federal, state, or local), and sometimes the interested public. The basic purpose of such meetings is to provide for informal discussions about the pros and cons of a proposal relative to its effects on the aquatic environment while the applicant is still in the planning process. The process allows for a consideration of potentially less environmentally damaging alternatives available to accomplish the project purpose, to discuss measures for reducing the impacts of the project, and to inform the applicant of the factors the USACE must consider in its decision-making process. Once a complete application is received. the formal review process begins. Issuance ofa public notice is often required. Additional steps to evaluate the impacts of the project and address all public comments received typically add significant time to the permitting process.

Although the proposed Project is not anticipated to impact WOTUS, ephemeral streams located within the Study Area may be considered WOTUS under certain conditions, and cultural sites located adjacent to these streams may be impacted by the proposed Project. Ifthe impacts of the proposed Project exceed the

criteria established under General Condition 21 (Discovery of Previously Unknown Remains and Artifacts) then the USACE-Fort Worth District will need to be consulted to determine if permitting will be required. If USACE permitting ensues, a review of cultural resources will need to be conducted to ensure compliance under Section 106 of the National Historic Preservation Act of 1996, as amended. If necessary, AEPSC, as agent for ETT, will coordinate with the USACE prior to clearing and construction to ensure compliance with the appropriate regulations associated with construction-related impacts to cultural resources.

Under Section 10 of the Rivers and Harbors Act of 1899 (RHA), 33 U.S.C. § 403, the USACE is directed by Congress to regulate all work and structures in, or affecting the course, condition, or capacity of navigable WOTUS, including tidal waters. No navigable waters occur within the Study Area that would require permitting under this Act.

1.6.4 U.S. Fish and Wildlife Service

The USFWS administers federal wildlife laws and provides technical and biological information for proposed projects under the jurisdiction of the ESA, Migratory Bird Treaty Act (MBTA), and Bald and Golden Eagle Protection Act (BGEPA). Additionally, USFWS oversight includes review of projects with a federal nexus under the Fish and Wildlife Coordination Act (FWCA) and National Environmental Policy Act (NEPA).

An initial review of federally protected species was conducted using the USFWS 's Information for Planning and Consultation (IPaC). IPaC is a tool to assist project proponents in increasing the compatibility of their activities with the conservation of USFWS trust resources. lt is meant to assist in the implementation of all activities regardless of whether they will be implemented through Sections 7 or



10 ofthe ESA. An "Official' species-list obtained through IPaC is considered to be the USFWS's official response.

1.6.5 Federal Emergency Management Agency

As directed by Federal Emergency Management Agency (FEMA), ETT will consult as necessary with the county floodplain administrator once the Consensus Route is approved by the PUC. Impacts to floodplains located in Webb County are administered by the Webb County Planning and Physical Development Department. Portions of the Study Area are located within a 100-year floodplain (FEMA 2008).

1.6.6 Texas Parks and Wildlife Department

The Texas Parks and Wildlife Department (TPWD) is the state agency with the primary responsibility of protecting the fish and wildlife resources in accordance with the Texas Parks and Wildlife Code Section 12.001 1 (b). TRC did initial research on the TPWD's Texas Natural Diversity Database (TxNDD), and county listed threatened and endangered (T&E) species during the Project scoping phase. The TxNDD, which is maintained by TPWD, has been reviewed in order to assess the potential for federal and state-listed threatened and endangered (T&E) species to occur within the vicinity of the Study Area. Data from the TxNDD do not provide a definitive statement as to the presence, absence, or condition of special status species, natural communities, or other significant features within a specified area. A copy of this EA will be submitted to TPWD when the CCN application is filed with the PUC. Once the PUC approves the Consensus Route, additional coordination with TPWD may be necessary to determine the need for additional species surveys, and to avoid or minimize potential adverse impacts to sensitive habitats, T&E species, and other protected fish and wildlife resources (Appendix A, Agency Correspondence Responses).

1.6.7 Texas Commission on Environmental Quality

The Project may require a Texas Pollution Discharge Elimination System (TPDES) General Construction Permit (TX 150000) as implemented by the Texas Commission on Environmental Quality (TCEQ) under the provisions of Section 402 of the CWA and Chapter 26 of the Texas Water Code. The TCEQ has developed a three-tiered approach for implementing this permit that is dependent on the acreage of disturbance. No permitting is required for land disturbances of less than one acre (Tier I). Disturbance of more than one acre, but less than five acres, would require implementation ofa Storm Water Pollution Prevention Plan (SWIPPP) (Tier II). If more than five acres of land are disturbed, the requirements mentioned above for Tier II are necessary and the submittal of a Notice of Intent (NOI) and Notice of Termination (NOT) to the TCEQ is also required (Tier III). Once the route is approved by the PUC, ETT will determine the amount ofground disturbance and the appropriate tier and conditions of the TX general permit no. TXR150000.



1.6.8 Texas Department of Transportation

Permits and approvals will be obtained from the Texas Department of Transportation (TxDOT) for any crossing of, or access from, a TxDOT-maintained roadway. Best management practices (BMPs) will be used, as required, to minimize erosion and sedimentation resulting from the construction. Revegetation will occur within TxDOT controlled ROW as required under the "Revegetation Special Provisions" and contained in TxDOT Form 1082 (Rev. 12/09).

1.6.9 Texas Historical Commission

Cultural resources are protected by federal and state laws ifthey have some level of significance under the criteria of the National Register of Historic Places (NRHP) (36 Code of Federal Regulations [CFR] Part 60) or under State guidance TAC, Title 13, Part 2, Chapter 26.7-8). TRC contacted the Texas Historical Commission (THC) and reviewed the Study Area under Section 106 of the National Historic Preservation Act of 1966, as amended and the Antiquities Code of Texas. Please see Appendix A, Agency Correspondence, for copies ofthe communication with the THC. If state lands or subdivisions ofthe state are involved, including school districts, cities, counties, or municipalities, the Antiquities Code of Texas is triggered. The THC reviewed the Project plans under the Antiquities Code of Texas and on February 24,2020 determined that the final route and substation sites will not require a cultural resources survey for consideration by the PUC prior to initiating any ground disturbance.

1.6.10 Texas General Land Office

The Texas General Land Office (GLO) requires a Miscellaneous Easement (ME) for any ROW crossing a

State-owned riverbed, navigable stream, or tidally influenced waters. The agency asked to be contacted once the final Consensus Route for the Project has been determined to see if it will cross any streambeds or Permanent School Fund (PSF) land that would require an easement from the GLO. However, no GLO easement has been identified or is anticipated for this Project.


Proposed Lobo to Corazon Solar 345-kV Transmission Line Route Evaluation Methodology

2.0 ROUTE EVALUATION METHODOLOGY

2.1 Objective of Study

The objective of this study was to evaluate the potential environmental and land use impacts for ETT's proposed 345-kV transmission line Project that complies with PURA § 37.056(c)(4)(A)-(D), 16 TAC § 22.52(a)(4), and 16 TAC § 25.101(b)(3)(B), including the PUC's policy of prudent avoidance. ETT and TRC utilized a comprehensive and well-established evaluation methodology to evaluate potential impacts of the proposed Consensus Route. ETT utilizes a multiphase approach for completing such a Project: define the Study Area; obtain environmental information; map environmental and land use constraints; conduct environmental, engineering, and cost analyses; and design and construct the transmission facility. The following sections provide a description of the process used in the development and evaluation of the proposed Consensus Route.

2.2 Data Collection

To evaluate the Project, TRC collected data from a variety of sources, including published literature (documents, reports, maps, aerial photography, etc.), information from local, state and federal agencies, and site-specific studies or investigations performed by others. The following types of data were used throughout the evaluation of the Project: recent aerial imagery (ESRI Digita1Globe 2018), U.S. Geological Survey (USGS) topographic maps (1:24,000), USGS National Hydrography Dataset (NHD), USFWS National Wetlands Inventory (NWI) maps, TPWD's TXNDD, U.S. Department of Agriculture (USDA) - National Agricultural Statistics Service (NASS) Cropland Data Layer, Railroad Commission of Texas (RRC) Pipeline Data, REXTAG dba Hart Energy Mapping & Data (REXTAG 2020), and ground reconnaissance surveys. The data collection effort, although concentrated in the early stages of the Project, was an ongoing process. A preliminary field reconnaissance ofthe Study Area was made by TRC personnel on January 29,2020, which was performed in advance ofthe formal biological survey effort, to evaluate and document the major terrain features, vegetation, and accessibility of the Study Area. This was followed by the biological survey of the Consensus Route by TRC biologists on February 26-27, 2020.

2.3 Evaluation of the Route

2.3.1 Study Area Delineation

The Study Area was determined by beginning with the two end points for the transmission line. ETT's existing 345-kV Lobo Station location was used to establish the southern extent and the proposed generator-owned Corazon Solar POI location was used to establish the northern extent. The Corazon Solar POI location, approximately 2.4 miles north of U.S. Highway 59 and approximately 12.8 miles northeast of Laredo, Texas, was established by the solar developer, BaWa, as the optimal location for gathering the generation output from the proposed solar arrays.



The locations ofthese endpoints established the approximate boundaries ofthe Study Area. The south boundary of the Study Area is an area around the existing ETT Lobo Station, the north boundary is approximately 0.2 mile north of the proposed Corazon Solar POI, the west boundary is approximately 0.8 mile west of the proposed Corazon Solar POI and approximately 0.2 mile west of the existing Lobo Station5 and the east boundary is approximately 0.2 mile east of the Lobo Station and the proposed Corazon Solar POI. The Study Area boundary is approximately 0.7 miles in length east to west, and approximately 3.2 miles in length north to south. The Study Area contains approximately 2.28 square miles. The Study Area is shown on Figure 2-1.

2.3.2 Constraints Mapping

To quantify potential impacts to sensitive environmental and land use features, a constraints mapping process was used in evaluating the Project. The geographic locations of environmentally sensitive and other restrictive areas within the Study Area were located and considered during the evaluation process. These constraints were mapped onto an aerial base map (Figure 2-2) created using Google Earth Pro 2019.

Data used by TRC in the evaluation ofthe Project were drawn from a variety of sources, including published literature, information from local, state, and federal agencies, recent aerial photography, and ground reconnaissance of the Study Area. The routing criteria considered the following aspects of the human environment, environmental, and cultural resources:

Human Environment

• Paralleling existing linear facilities, with pipelines as a constraint

• Land use, including habitable structures

Cultural Resources

• Sensitive Historic Sites

• Sensitive Cultural Sites

Environmental Resources

• Physiography and Geology

• Soils

• Mineral and Energy Resources

• Surface Water

• Wetlands

• Sensitive Vegetation Habitats

• Sensitive Fish and Wildlife Habitats

• Recreationally and Commercially Important Species

• T&E Species Critical Habitats



Figure 2-1: Study Area Location

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NUMBER IN DOCKET NO. 50964



In addition, the length, number of angle structures, number of land parcels crossed, and cost were considered. The complete routing criteria are shown in Section 6, Table 6-1 of this EA. Figure 2-2 shows the environmental and land use constraints within the Study Area.

2.3.3 Evaluation Factors

The evaluation of the Project involved studying a variety of environmental factors using desktop analysis of aerial maps and resource maps and conducting an initial field reconnaissance on January 29,2020. The biological field surveys were conducted along the ROW for the Consensus Route on February 26-27, 2020. The initial field reconnaissance was conducted by driving the Study Area and reviewing aerial and resource maps. The follow-up biological field evaluation was conducted by walking along the proposed ' ROW for the Consensus Route. In evaluating the proposed Consensus Route, 39 environmental criteria were considered. These criteria are presented in Table 6-1.

The analysis ofthe Project involved the inventory and tabulation of the number or quantity of each environmental criterion located along the Consensus Route (e.g., number of habitable structures within 500 feet, amount of brushland/shrubland crossed, etc.) (see Section 6, Table 6-1 for details). The number or amount of each criterion was determined by reviewing and field verifying various maps and recent color aerial imagery (Google Earth Pro 2019). Potential environmental impacts of the transmission line route are addressed in Section 4.0 ofthis document.

Consensus Route

The Consensus Route was selected based on evaluation ofthe potential impacts along with consideration of the direct path between the interconnection points, being parallel to the existing 345-kV transmission line, the length, number of angle structures, number of land parcels crossed, and habitable structures associated with other alternatives. In addition, TRC contacted the landowner that owns the parcels in the in the Study Area that will be crossed by the Consensus Route. ETT believes the Consensus Route best addresses the requirements of PURA and PUC Substantive Rules. The landowner crossed by the Consensus Route has signed Consensus Route Agreements that will be provided as part of the CCN Application.


Proposed Lobo to Corazon Solar 345-kV Transmission Line Existing Environment

Figure 2-2: Environmental and Land Use Constraints Within the Study Area

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3.0 EXISTING ENVIRONMENT

3.1 Physiography

Webb County, located in the southwestern portion of the South Texas Plains, is located within the interior

Coastal Plains physiographic province (Figure 3-1). The land surface of Webb County is characterized by nearly level to rolling slopes and ranges in elevation from 300 to 800 feet above mean sea level (Bureau

of Economic Geology [BEG] 1996).

3.1.1 Interior Coastal Plains

The Interior Coastal Plains is one ofthree sub-provinces of the Gulf Coastal Plains that occupy the southern and southeastern portions of Texas. The Interior Coastal Plains province features long, sandy ridges derived from uncemented sands among weaker shale outcroppings. Topographic elevations in the Interior Coastal Plains range from 300 to 800 feet (BEG 1996). The southwestern portion ofthe province is part of the Tamaulipan Shrublands biome that stretches from the Balcones Escarpment toward Mexico (Blair 1950; Griffith et al. 2007). The climate of the region is influenced by the humid, subtropical coast to the east, and the overall semi-arid conductions of South Texas producing extreme variability in precipitation, high temperatures, and infrequent frosts.



Figure 3-1 : Location of Webb County in Relation to the Physiographic Provinces of Texas

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i i A. Coastal Prairies B. Interior Coastal Plains

~ C Blackland Prairies

C,3 D. Grand Prairie E. Edwards Plateau

k 0' Central Texas Uplift North-Central Plains

H. High Plains 1. Trans-Pecos Basin and Range

ETTT~- Location of Webb County In Relation Figure 3-1

5 E £,ectdo r*Tem to the Physiographic Provinces of Texas 0 575 230 Proposed Lobo to Corazon

9 5 Single-Circuit 345-kV TRC Transmission Une in Webb County, Texas Mbs

1 Inch =115 Mles

115



3.2 Geology

The geology of Webb County is variable, ranging from Holocene alluvium to Eocene and Paleocene-age formations (USGS 2014). According to the USGS Geologic Database of Texas (2014), geologic formations present in Webb County include:

• Jackson Group, undivided: Jackson Group, undivided is of Oligocene and Eocene-age and occur within 22 percent of the county. These deposits consist of clay, sandstone, siltstone, and tuff and have a thickness up to 875 feet. They are generally mapped south ofthe Frio River.

• Yegua Formation: These Middle Eocene deposits occur within 17 percent of the county. It is predominantly clay with minor beds of sandstone and some concretionary limestone beds and lenses of oyster shell. The sandstone is mostly quartz and some fine-grained chen. It has a thickness up to 1,000 feet.

• Laredo Formation: Laredo Formation occurs within 17 percent of the county and is of Middle Eocene age. It consists of sandstone and clay, with thick, very fine grained to fine grained sandstone in the upper and lower parts and red and brown clay in the middle. It typically weathers orange and yellow. It ranges in thickness between 600 to 700 feet.

• El Pico Clay: El Pico Clay is of Eocene age and occurs within 16 percent ofthe county. It is predominantly gray to brown clay with sandstone and some coal deposits. The sandstone primarily occurs in thin to massive beds and is typically fine grained and gray to brown in color. It ranges in thickness between 700 to 900 feet.

• Goliad Formation: This Miocene age formation occurs within six percent ofthe county. It consists ofclay, sandstone, marl, caliche, limestone, and conglomerate. The thickness ofthe formation varies from approximately 100 to 500 feet.

• Alluvium: Alluvial deposits of Holocene age occur within five percent of the county. Alluvium consists of clayey fine to very fine quartz sand, silt, clay, and gravel with various thicknesses as stream laid deposits.

• Terrace Deposits: These deposits of Pleistocene and Holocene age are alluvial sands and silts along drainages throughout the county. Gravels occur more frequently in older and higher terrace deposits. Locations include point bars, natural levees, and stream channels along valley walls.

• Bigford Formation: This Eocene age formation covers three percent of the county. It is characterized by a combination of siltstone, sandstone, and clay with the thickness ranging from 50 to 200 feet.

• Quaternary Deposit, undivided: These deposits occur within three percent of the county and consist of sand, silt, clay, and gravels. They are locally indurated with calcium carbonate (caliche)



deposits. They occur on point bars, natural levees, stream channels, sand dunes, terraces, alluvial fans, and playas.

• Uvalde Gravel: Uvalde Gravel is of Pleistocene age and consists of caliche-cemented gravel; well-rounded pebbles and cobbles of chert; and some pebbles and cobbles of quartz and igneous rocks with a thickness up to about 30 feet. It occurs within three percent of the county.

• Sand Sheet Deposits: Sand Sheet deposits of Holocene age occur within two percent of the county. The sand sheets consist of eolian sand with some larger dunes. The sand has moderate to high permeability and low to moderate water-holding capacity.

• Frio Clay: Frio Clay is of Oligocene age and occurs within one percent ofthe county. The clay is typically dark greenish gray with some gypsum and calcareous concretions. The thickness is approximately 200 feet and feathers out northward.

• Catahoula Formation: Catahoula Formation is of Oligocene age and occurs within 0.7 percent ofthe county. The upper member consists oftuffaceous mudstone, sand, and sandstone approximately 180 feet thick. The second Soledad Volcanic Conglomerate member has large amounts of pebbles, cobbles, and boulders upwards of 75 feet thick. The lowest Fant Tuff member consists oftuff, claystone, and sandstone approximately 600 feet in thickness. The formation generally ranges in thickness between 300 to 600 feet.

• Carrizo Sand: Carrizo Sand is of Eocene age and occurs within 0.4 percent ofthe county. It consists of beds of light yellow and brown, iron-oxide banded, medium to very coarse-grained sandstone beds. The thickness varies from approximately 140 to 200 feet.

• Indio Formation: This Paleocene to Eocene age formation occurs within 0.3 percent ofthe county. It consists of a combination of sandstone, shale, siltstone, and lignite. The approximate thickness is 140 feet.

• Catahoula Formation and Frio Clay, undivided: This formation is of Oligocene age and occurs within <0.1% of the county. It shares characteristics of both dark greenish gray Frio clay and the Catahoula Formation.

3.3 Soils

The Study Area occurs within southwestern Webb County. The general soil map of Webb County, published by the USDA Natural Resources Conservation Service (NRCS), formerly the Soil Conservation Service (SCS), was referenced for the following descriptions of the general soil map units within the Study Area.



3.3.1 Soil Associations

The soil resources within the Study Area are derived from residuum of limestone, sandstone, caliche, mari or shale, in ancient or recent alluvium. Much of the parent material in Webb County, Texas contains gypsum or other forms of salt, resulting in saline soils to a certain degree. The Study Area contains five soil series: Catarina, Copita, Maverick, Moglia, and Tela. The Catarina and Maverick soils are characterized by deep to moderately deep, well drained, clayey soils which form on upland plains and valleys. The Moglia, Copita and Tela soils are characterized by deep to moderately deep, well drained loamy soils. These soils form on upland prairies and valleys (USDA-NRCS 1985). Table 3-1 presents each soil map unit that occurs within the Study Area.

Table 3-1: Soil Units

Soil Map Unit

Acres in Soil Type Proposed Symbol Project

Footprint

Percentage of Proposed

Study Area Corrosive to Steel Rating Hydric

Catarina clay, 0 to 2 percent CaB 1,358.4 24.7% High No slopes

Catarina clay, 0 to 2 percent CfA 210.0 3.8% High No slopes

Copita fine sandy loam, 0 to CpB 1,286.4 23.4% High No 3 percent slopes

Maverick- Catarina complex, MCE 911.6 16.5% High No gently rolling

Moglia clay loam, 1 to 5 MgC 1,715.5 31.1% High No percent slopes

Tela sandy clay loam, 0 to 1 Te 14.9 0.3% Moderate No percent slopes, frequently

flooded

3.3.2 Prime Farmland Soils

The USDA-NRCS defines prime farmland as land that has the best combination of physical and chemical characteristics for producing food, feed, forage, fiber, and oilseed crops and is available for these uses. Prime farmland could be cultivated land, pastureland, forestland, or other land, but it is not urban or built-up land or water areas. The soil quality, growing season, and moisture supply are those needed for the soil to produce economically sustained high yields of crops when proper management, including water management, and acceptable farming methods are applied. In general, prime farmland has an adequate and dependable supply of moisture from precipitation or irrigation, a favorable temperature and growing season, acceptable acidity or alkalinity, an acceptable salt and sodium content, and few or no rocks. The water supply is dependable and of adequate quality. Prime farmland is permeable to water and air. It is



not excessively erodible or saturated with water for long periods, and it either is not frequently flooded during the growing season or is protected from flooding. Slope ranges mainly from 0 to 6 percent. More detailed information about the criteria for prime farinland is available at the local office ofthe USDA-NRCS (USDA-NRCS 1997). According to the USDA-NRCS Web Soil Survey (USDA-NRCS 2020), none of the soil units within the Study Area are considered prime farmland.

3.4 Mineral and Energy Resources

The Bureau of Economic Geology (BEG) Texas Mineral Resource Map indicates that no major mineral resources are mapped near the Study Area (BEG 2019). Additionally, USGS topographic maps do not indicate the presence of mines or quarries near the Study Area.

Current aerial photographs, the REXTAG database (REXTAG 2020), and the RRC indicate the presence of one active gas well in the Study Area located approximately 3,317 feet (0.63 mile) north of U.S. Highway 59 and approximately 1,026 feet east of the Consensus Route. Other oil and gas activity in the Study Area includes plugged oil and gas wells, permitted locations, shut-in gas wells, and dry holes. Similar categories appear to the east and west of the Study Area. There also is a natural gas gathering pipeline owned by DCP Interstate Network, LLC that crosses the Study Area just north of U.S. Highway 59 (Figure 2-2).

3.5 Water Resources

3.5.1 Surface Water

Webb County is bordered on the southwest by the Rio Grande River. The northern and eastern sections of the county are drained by a number of creeks that flow north and eventually enter the Nueces River; the

southern and western parts of the county are drained by the Rio Grande. In addition, throughout the county are 59 named creeks and 42 named lakes/tanks, with Lake Casa Blanca being the largest lake.

The TPWD designates Ecologically Significant Stream Segments (ESSS) for waters that display unique ecological value based on biological function, hydrologic function, riparian conservation areas 5 water quality, aquatic life, aesthetics, or habitat for T&E species. Of the waterbodies present in Webb County, 43 are designated ESSS. There are no ESSS located within the Study Area.

3.5.2 Floodplains

Webb County experiences flooding at several locations within its boundaries, mostly along the Rio Grande River, which constitutes the major source of flooding. A review of the FEMA Flood Insurance Rate Maps (FIRM) (FEMA 2008) for Webb County shows that the majority ofthe Study Area is located within the 500-year floodplain (Zone X, areas of minimal flood hazard). However5 small portions in the northern and southern sections of the Study Area are located within Zone AE (also known as the "100-year floodplain"). Areas designated as Zone AE have al% probability of flooding every year and where



predicted flood water elevations above mean sea level have been established. Properties in Zone AE are considered to be at higher risk of flooding under the National Flood Insurance Program (NFIP).

As directed by FEMA, ETT will consult as necessary with the local floodplain administrator once the Consensus Route is approved by the PUC. Per the Senior Planner with the Webb County Planning Department, a floodplain designation must first be made before the applicant can apply for a permit. A formal coordination letter was sent to the Webb County Planning and Physical Development Department on February 7,2020.

3.5.3 Groundwater/Aquifers A major aquifer is defined as an aquifer that supplies large quantities of water over a large area of the

state. A minor aquifer supplies a large quantity of water over a small area, or small quantities over a large

area (Ashworth and Hopkins 1995). The major aquifers and sources of groundwater in Webb County are

the Gulf Coast aquifer in southeastern Webb County, the Carrizo-Wilcox aquifer in central and northwest

Webb County. One minor aquifer (Jackson Yegua) is located throughout central and eastern Webb

County (TWDB 2020a, 2020b). Extending from the Rio Grande in South Texas northeastward into

Arkansas and Louisiana, the Carrizo-Wilcox aquifer provides water to all or parts of 66 counties. The

Wilcox Group and the overlying Carrizo Formation of the Claiborne Group form a hydrologically

connected system known as the Carrizo-Wilcox aquifer. The Carrizo-Wilcox aquifer is predominantly

composed of sand locally interbedded with gravel, silt, clay, and lignite deposited during the Tertiary

Period. South of the Trinity River and north of the Colorado River, the Wilcox Group is divided into three

distinct formations: the Hooper, Simsboro, and Calvert Bluff. Ofthe three, the Simsboro typically

contains the most massive water-bearing sands. This division cannot be made south of the Colorado River

or north ofthe Trinity River due to the absence of the Simsboro as a distinct unit. Aquifer thickness in the

downdip artesian portion ranges from less than 200 feet to more than 3,000 feet (Ashworth and Hopkins

1995).

3.6 Vegetation

3.6.1 Regional Vegetation As shown on Figure 2-1, the Study Area is located in Webb County within the Southern Texas Plains

ecoregion, defined by the EPA as Ecoregion 31, a Level III ecoregion. The Study Area is located in a sub-

ecoregion ofthe Southern Texas Plains, the Texas-Tamaulipan Thomscrub (3 lc). The Tamaulipan

Thornscrub, or "brush country" as it is called locally, is a rolling to moderately dissected plain that was

once covered in many areas with grassland and savanna vegetation that varied during wet and dry cycles. Following long continued grazing and fire suppression , thorny brush , such as honey mesquite ( Prosopis



glandulosa ), \ s now the predominant vegetation type . Cenizo ( Leucophyllumfrutescens ) and blackbrush

Otcacia rigidula ) occur on caliche soils , which are common ( Griffith et al . 2004 ). The Study Area is

somewhat disturbed due to clearing for electrical transmission lines and ranch roads for hunting and

ranching.

The vegetation is dominated by drought-tolerant, mostly small-Ieaved, and often thorn-laden small trees

and shrubs, especially legumes. The dominant woody species is honey mesquite. Where conditions are suitable, there is a dense understory of smaller trees and shrubs such as brasil or Brazilian bluewood

( Condalia hookerf ), colima or lime pricklyash ( Zanthoxylunfagara ), sugar hackberry ( Celtis laevigata ), Texas persimmon ( Diospyros texana ), lotebush ( Ziziphus obtusifolia ), granjeno or spiny hackberry ( Celtis pallida ), kidneywood (* ysenhardtia texana ), coyotillo ( Karwinskia humboldtiana ), Texas paloverde ( Parkinsonia texana ), anacahuita ( Cordia boissierf ), and various species ofcacti . Xerophytic brush species , such as blackbrush , guajillo ( Acacia berlandieri ), and ceniza , are typical on the rocky , gravelly ridges and uplands. The brush communities also tend to grade into desert scrub near the Rio Grande. Mid

and short grasses are common , including cane bluestem ( Bothriochloa barbinodis ), silver bluestem ( Bothriochloa laguroides ), multiflowered false rhodesgrass ( Trichloris pluriflora ), sideoats grama ( Bouteloua curtipendula ), pink pappusgrass ( Pappophorum bicolort , bristlegrasses Getaria spp .), lovegrasses ( Eragrostis spp .), and tobosa ( Hilaria mutica ). On overgrazed sites or drier sites to the west , red grama (Bouteloua trifidd),Texas grama (Bouteloua rigidiseta),buffa\ograss (Buchloe dactyloides),

and curleymesquite ( Hilaria belangerf ) occur ( Griffith et al . 2007 ).

3.6.2 Vegetation Community Types in the Study Area

TPWD, in cooperation with private, state5 and federal partners, has produced a 398-class land

classification for the State of Texas. The land classification for the Study Area is (31 c) Texas-Tamaulipan

Thornscrub (Figure 3-2). This was accomplished by attributing land cover and abiotic variables to 10-

meter resolution image objects generated from National Agriculture Imagery Program (NAIP)

photographs. In some regions, enhanced satellite land cover classification, landform modeling efforts, or other ancillary data were included to map important current vegetation types. These results are used by a

wide variety ofpartners in Texas for conservation planning and management.



Figure 3-2: Location of Webb County in Relation to the Vegetation Areas of Texas







3.6.2.1 Other Vegetation Types

According to the TPWD's Ecological Mapping System of Texas (EMST), there are 11 EMST habitat types mapped within the Study Area (TPWD 2020a). Descriptions of each EMST habitat type is described below:

South Texas: Clayey Mesquite Mixed Shrubland. A discontinuous canopy of shrubs and small trees characterize this type, and soils range from clayey to loamy. Species such as mesquite, blackbrush, granjeno , sugar hackberry , brasil , guajillo , lotebush , prickly pear ( Opuntia spp .), and whitebrush ( Aloysia gratissima ) are common components . Buffelgrass ( Pennisetum ciliaris ) is a common herbaceous dominant.

South Texas: Clayey Blackbrush Mixed Shrubland. Relatively dense, tall, and diverse shrublands with species such as blackbrush , honey mesquite , granjeno , guajillo , guayacan ( Guaiacum coulteri ), whitebrush , lotebush , amargosa or Texas goatbrush ( Castela erecta ssp . texana ), brasil , and / or colima .

South Texas: Disturbance Grassland. A variety of mainly heavily grazed grasslands, including managed exotic pastures, are circumscribed within this type. Grasses and shrubs both are important components . Common dominant species include buffelgrass , Bermudagrass ( Cynodon dactylon ), King Ranch bluestem ( Bothriochloa ischaemum var . songarica ), Kleberg bluestem ( Dichanthium amulatum ), guineagrass ( Urochloa maxima ), pink pappusgrass , threeawn species Olristida spp .), and red graina . Shrubs and small trees may include honey mesquite , blackbrush , lotebush , huisachillo ( Vachellia schalfneri ), and granjeno .

South Texas: Ramadero Shrubland. This type is mapped in narrow bands along upland drainages, and common shrubs or small trees include honey mesquite, sugar hackberry. blackbrush, granjeno, Texas persimmon, colima, brasil, Texas paloverde, whitebrush, pricklypear, and lotebush.

Row Crops. This type includes all cropland where fields are fallow for some portion ofthe year. Some fields may rotate into and out of cultivation frequently, and year-round cover crops and tame hay fields are generally mapped as grassland. No row crop vegetation communities (active or fallow) were observed within the Study Area during desktop analysis or during the February 2020 on-site field investigation.

South Texas: Ramadero Dense Shrubland. This type is mapped as narrow bands along upland drainages. Common small trees or shrubs include honey mesquite, granjeno, sugar hackberry, retama or Jerusalem thorn ( Parkinsonia aculeata ), Texas paloverde , whitebrush , colima , brasil , elbowbush (Forestiera angustifolia), and lotebush.

Barren. This type includes areas where little or no vegetation cover existed at the time of image data collection. Many areas mapped as this type are human-associated land clearings.



South Texas: Ramadero Evergreen Woodland. This type is mapped as narrow bands along upland drainages. Common small trees include sugar hackberry, honey mesquite, retama, la coma or saffron plum ( Sideroxylon celastrium ), live oak ( Quercus virginiana ), and Texas ebony U ? ithecellobium flexicaule ), Common shrubs include whitebrush , granjeno , brasil , Texas persimmon , elbowbush , and lotebush.

South Texas: Ramadero Woodland. This type is mapped as narrow bands long upland drainages. Common small trees include honey mesquite, granjeno, sugar hackberry, and retama. Common shrubs include granjeno, whitebrush, Texas persimmon, colima, brasil, elbowbush, and lotebush.

Urban Low Intensity. This type includes areas that are built-up but not entirely covered by impervious cover and includes most ofthe non-industrial areas within cities and towns. No urban low intensity habitat was observed within the Study Area during desktop analysis or during the February 2020 on-site field investigation.

Open Water. Areas that were water year-round at the time of data collection (circa 2010) are included. This includes reservoirs, rivers, canals and ponds, and marine waters along the Gulf of Mexico.

3.6.3 Waters of the U.S., Including Wetlands

Section 401 of the CWA (33 U.S.C. 1251 et seq.), as amended, requires that a Water Quality Certification Permit be obtained for anticipated discharges associated with construction activities or other disturbance within waterways. No discharges associated with construction activities or other disturbance within WOTUS are anticipated. Therefore, Section 401 ofthe CWA would not apply to the proposed Project action or no-action alternative.

Section 402 ofthe CWA (33 U.S.C. 1251 et seq.) as amended, regulates construction discharges of pollutants into WOTUS or a municipal separate storm sewer system (MS4) and specifies that stormwater discharges associated with construction activities shall be conducted under the National Pollution Discharge Elimination System (NPDES) guidance. The proposed Project is not located within a MS4 area. Construction activities associated with the proposed Project would cause ground disturbance of approximately 4.73 acres. Therefore, a Tier II SWPPP is required by the contractor for small construction sites (those that disturb from one to less than five acres) under Construction General Permit TXR150000. The SWPPP would include erosion control BMPs that would be utilized during construction and post-construction activities until natural vegetation communities are restored. Based on the utilization of erosion control measures outlined in the SWPPP, the proposed Project action impacts from stormwater runoff are expected to be negligible.

Section 404 ofthe CWA (33 U.S.C. 1251 et seq.), as amended, provides for the protection of WOTUS through regulation of the discharge of dredged or fill material. A desktop analysis of potential wetlands



and WOTUS was performed for the Study Area by reviewing aerial imagery, topographic maps (Figure 3-3; USGS 2019), online web soil survey data (Figure 3-4; USDA - NRCS 2020a), and NWI wetlands data (USFWS 2020). Based on a review of the USFWS's NWI map, there are a total of eight potentially jurisdictional streams (ephemeral), five freshwater ponds, and three palustrine scrub/shrub (PSS) features located within the Study Area. Aerial photography indicates that the features appear to be ephemeral in nature and show characteristics of a drainage basin.

Pursuant to Section 404 of the CWA and Section 10 ofthe RHA, a qualified wetland biologist conducted

a survey of wetlands, waterbodies, and other special aquatic sites along the Consensus Route within the

Project Study Area on February 26-27,2020. Seven potentially jurisdictional streams (ephemeral) and

one man-made freshwater pond were identified (Appendix B, Maps 1-5). Each ofthe streams were dry at

the time of the survey, with drainage only anticipated during heavy participation events. The areas

adjacent to each stream and pond were dominated by upland vegetation species. Table 3-2 contains

descriptions and location information for each delineated waterbody along the surveyed Consensus Route

within Study Area.

Table 3-2: Surveyed Waterbody Summary

Feature ID Feature Name Flow Feature Delineated Feature Location Type (Figure Number)

S-TCP-01 UT Ephemeral Stream Appendix B, Map 1 S-TCP-02 Melone Creek Ephemeral Stream Appendix B, Map 1 S-TCP-03 UT Ephemeral Stream Appendix B, Map 2 S-TCP-04 Melone Creek Ephemeral Stream Appendix B, Map 3 S-TCP-06 UT Ephemeral Stream Appendix B, Map 5 S-TCP-07 UT N/A Pond Appendix B, Map 5 S-TCP-08 Becerra Creek Ephemeral Stream Appendix B, Map 4 S-TCP-09 UT Ephemera] Stream Appendix B5 Map 4

T = Unnamed Tributary /A = Not Applicable

No distinct wetlands or wetland plant communities were observed within proposed Study Area. One

freshwater pond (S-TCP-07) was observed within the proposed Study Area (Appendix B, Map 5). This

man-made feature is located north of the ETT Lobo Station and appears to be used primarily for watering

of domestic livestock. Based on the current design plans, these identified features would be avoided

during construction and would not be impacted by the proposed Project design plans. Therefore,

authorization under Section 404 ofthe CWA from the USACE - Fort Worth District would not be



required for authorization ofthe proposed Project. Additionally, the THC did not recommend cultural

surveys be conducted for the proposed Project. Therefore, USACE permitting is not indicated for the

proposed Project.



Figure 3-3: Topographic Map of Study Area







Figure 3-4: SSURGO Soils Within the Study Area







3.7 Fish and Wildlife

3.7.1 Fish and Wildlife Habitats and Species

As shown on Figure 3-5, the Study Area is located in the Tamaulipan Biotic Province. The Tamaulipan Biotic Province in Texas extends east and north from a line along the Rio Grande River south of Del Rio, Texas to the mouth ofthe Rio Grande, eventually transitioning to the more elevated Balconian and Texan Biotic Provinces. To the west ofthe Rio Grande River lies the Chihuahuan Desert. The Tamaulipan includes two distinct biotic districts, with the Study Area being wholly within the Nuecian District (Blair, 1950). This area is also considered to be part ofthe Southern Texas Plains, Texas-Tamaulipan Thornscrub (Griffith et al, 2004). Within the Texas-Tamaulipan Thornscrub (3 l c), the vegetation is dominated by small woody species such as honey mesquite along with other thorny brush species. Mid and short grasses are common (but not dominant) as understory plants, along with cacti. Characteristic faunal species of the area are discussed below. Most of the area is rangeland with large ranches raising beef cattle. Wildlife species that occur include species that have historically occurred in the area , such as white - tailed deer ( Odocoileus virginianus), collared peccary/javelina (Pecari tq/acu),and northern bobwhite (Colinus virginianus).

The rolling to moderately dissected plain was once covered in many areas with grassland and savanna vegetation that varied during wet and dry cycles. Following long continued grazing and fire suppression, thorny brush, such as mesquite, is now the predominant vegetation type. Most of the region (called "brush

country" locally) has its greatest extent in Mexico. The subhumid to dry region contains a diverse mosaic of soils, mostly clay, clay loam, and sandy clay loam surface textures, ranging from alkaline to slightly acidic. The ecoregion contains a high and distinct diversity of plant and animal li fe. Large cattle ranches, along with northern bobwhite and white-tailed deer hunting are the dominant land uses. Oil and natural gas production activities are widespread. The Nueces, Guadalupe, San Antonio, Lavaca and the Rio Grande Rivers are the dominant rivers in the region.

Dominant woody vegetation species include honey mesquite, with a dense understory of smaller trees and shrubs including brasil, lime prickly-ash, Texas persimmon, lotebush, granjeno, kidneywood, coyotillo, Texas paloverde, and various species of cacti. Xerophytic brush species, such as blackbrush, guajillo, and ceniza, are typical on the rocky, gravelly ridges and uplands. Mid and short grasses are common, including cane bluestem, silver bluestem, multiflowered false rhodesgrass, sideoats grama, pink pappusgrass, bristlegrasses, lovegrasses, and tobosa.

Wildlife species that could frequent this area may include white-tailed deer, black-tailed jackrabbit (Lepus cal®rnicus), javelinakollared peccary, Mexican free-tailed bat (Tadarida brasilliensis), feral hog (Sus scrofc ), coyote ( Canis latrans ), bobcat ( Lynx rufim ), green jay ( Cyanocorax luxuosus ), and northern bobwhite. In addition, various mammals and reptiles such as mice, rabbits, skunks, and snakes may also transit through the proposed Study Area.



The proposed construction would occur in areas that are managed for cattle ranching. A biological survey ofthe proposed Study Area was conducted on February 26-27,2020. Wildlife species observed within the Study Area consisted mainly ofavian species ; Audubon ' s oriole Ucterus graduacauda ), northern mockingbird ( Mimus polyglottos ), northern bobwhite , mourning dove , greater roadrunner ( Geococcyx californianus ), turkey vulture ( Cathartes aura ), and sparrow species Passerellidae spp .). Eastern cottontails, white-tailed deer, and javelina were also observed.



Figure 3-5: Location of Webb County in Relation to the Biotic Provinces of Texas

Austroriparian n

Navahonian -

Kansah .-i -

t J

exan

chihuat,an n-2\ Balconian_ £,f - :i~c A

r

Taniaulipan

y 0

m/U

XO

8738

00_3

·5_b

»tic

m*d

apher Mlorn

Figure 3-5 ETT 4 - Location of Webb County in Relation E/ectr#c Transmission Texas to the Biotic Provinces of Texas

Legend 0 57 5 230 Proposed Lobo to Corazon Single-Circuit 345-kV * TRC Transmission Line in Webb County, Texas 1 Inch =115 Mles

115



3.7.2 Fish

Due to the ephemeral nature of the streams and ditches within the Study Area, fish species are only expected to be present within ponds and stock tanks located along the Study Area. Table 3-3 contains a representative list of the fish species of potential occurrence in the Study Area.

Table 3-3: Representative List of Fish Species That Potentially Occur in the Study Areaa

Common Name Scientific Name

Alligator Gar Bluegill Black Bullhead Bullhead Minnow Channel Catfish Common Carp Flathead Catfish Gizzard Shad Green Sunfish Largemouth Bass Longear Sunfish Redbreast Sunfish Rio Grande Cichlid Sheepshead Minnow Tadpole Madtom Threadfin Shad Yellow Bullhead Warmouth Western Mosquitofish White Crappie

a Fishes of Texas -

3.7.3 Reptiles

Atractosteus spatula Lepomis macrochirus Ameiurus melas Pimephales vigilax Ictalurus punctatus Cyprinus carpio

Pylodictis olivaris

Dorosoma cepedianum Lepomis cyanellus

Micropterus salmoides Lepomis megalotis Lepomis auritus

Herichthys cyanoguttatus Cyprinodon variegatus Noturus gyrinus

Dorosoma petenense Ameiurus natalis

Lepomis gulosus Ganibusia affinis Pomoxis annularis

Texas Freshwater Fishes in the Rio Grande Drainage (FOT 2020).

A representative list of amphibian and reptile species that potentially occur in the Study Area is included as Table 3-4.



Table 3-4: Representative List of Reptile and Amphibian Species That Potentially Occur in the Study Areaa

Common Name

Amphibians Tiger Salamander Black-spotted Newt Lesser Siren Frogs and Toads Green Toad Cane Toad Gulf Coast Toad Red-spotted Toad Texas Toad Rio Grande Chirping Frog Northern Cricket Frog Green Treefrog Spotted Chrous Frog Great Plains Narrow-mouthed Toad Rio Grande Leopard Frog American Bullfrog Couch's Spadefoot Hurter's Spadefoot Plains Spadefoot Crocodilians American Alligator Lizards Reticulate Collared Lizard Texas Banded Gecko Mediterranean House Gecko Greater Earless Lizard Spot-tailed Earless Lizard Keeled Earless Lizard Texas Horned Lizard Round-tailed Horned Lizard Blue Spiny Lizard Graphic Spiny Lizard Texas Spiny Lizard Prairie Lizard Rose-bellied Lizard Ornate Tree Lizard Green Anole

Scientific Name

Ambystomatidae tigrinum Notophthalamus merdionalis Siren intermedia

Bufo debilis

BHfo marinus

Bufo nebulifer Bufo punctatus Bufo speciosus Eleutherodactylus cystignathoides Acris crepitans

Hyla cinerea

Pseudacris clarkii Gastrophryne olivacea Rana berlandieri Rana catesbeiana

Scaphiopus couchii Scaphiopus hurterii Spea bombiftons

Alligator mississippiensis

Crotaphytus reticulatus Coleonyx brevis Hemidactylus turcicus Cophosaurus texanus Holbrookia lacerata Holbrookia propinqua

Phrynosoma cornutum Phi·ynosoma modestum

Sceloporus cyanogenys

Sceloporus grammicus Sceloporus olivaceus Sceloporus undulatus Sceloporus variabilis Urosaurus ornatus

Anolis carolinensis




Common Name

Amphibians Great Plains Skink Four-lined Skink Little Brown Skink Eastern Spotted Whiptail Laredo Stripped Whiptail Marbled Whiptail Six-line Racerunner Snakes Glossy Snake Central American Indigo Snake Tamaulipan Hook-nosed Snake Mexican Hog-nosed Snake Chihuahuan Nightsnake Common Kingsnake Milksnake Coachwhip Schott's Whipsnake Diamond-backed Watersnake Rough Greensnake Great Plains Ratsnake Eastern Ratsnake Gophersnake Long-nosed Snake Eastern Patch-nosed Snake Groundsnake DeKay's Brownsnake Flat-headed Snake Smith's Black-headed Snake Plains Black-headed Snake Checkered Gartersnake Western Ribbonsnake Western Diamondback Rattlesnake Massasauga Texas Coralsnake Plains Threadsnake Turtles Rio Grande Cooter

Scientific Name

Plestiodon obsoletus

Plestiodon tetragrammus

Scincella lateralis Aspidoscelis gularis Aspidoscelis laredoensis

Aspidoscelis marmorata Aspidoscelis sexlineata

Arizona elegans Drymarchon melanurus Ficimia streckeri Heterodon kennerlyi

Hypsiglena.jani Lampropeltis getula Lampropeltis triangulum Masticophis.flagellum

Maticophis schotti Nerodia rhombifer

Opheodrys aestivus Pantherophis emoryi Pantherophis obsoletus

Pituophis catenifer Rhinocheilus lecontei Salvadora grahamiae Sonora semiannulata Storeria dekayi Tantilla gracilis Tantilla hobartsmithi Tantilla nigriceps Thamnophis marcianus Thamnophis proximus

Crotalus atrox Sistrurus catenatus Micrurus tener

Leptotyphlops dulcis

Pseudemys gorzugi




Common Name Scientific Name

Amphibians Ornate Box Turtle Pond Slider Yellow Mud Turtle Texas Tortoise Spiny Softshell

a Herps of Texas Website 2020

3.7.4 Birds

Terrapene ornata

Trachemys scripta

Kiiiosternon.flavescens

Gopherus berlandieri Apalone spinifera

Avian species that potentially occur in the Study Area include many year-round residents, migrants,

summer residents, and winter residents. A representative list of bird species that potentially occur in the

Study Area is included as Table 3-5.

Table 3-5: Representative List of Avian Species of Potential Occurrence in the Study Area

Common Name Acadian Flycatcher American Avocet American Coot American Goldfinch American Kestrel American Pipit American Redstart American Robin American White Pelican American Wigeon Anhinga Ash-throated Flycatcher Audubon's Oriole Baltimore Oriole Bank Swallow Barn Owl Barn Swallow Bell's Vireo Belted Kingfisher Bewick's Wren Black Phoebe Black Vulture Black-and-white Warbler Black-bellied Whistling -Duck Black-chinned Hummingbird


b Scientific Name

Empidonax virescens Recurvirostra americana Fulica americana Spinus tristis Falco sparverius Anthus rubescens Setophaga ruticilla Tui·dus migratorius Pelecanus erythrorhynchos Mai·eca americana Anhinga Myiarchus cinerascens jcterus graduacauda Icterus galbula Riparia Tyto alba Hirundo rustica Vii·eo bellii Megaceryle alcyon Thryomanes bewickii Sayornis nigricans Coragyps atratus Mniotilta varia Dendrocygna autumnalis Archilochus alexandri

3-22

ac Likely Seasonal Occurrence ' Migrant Migrant Resident Winter Resident Resident Winter Resident Migrant Winter Resident Winter Resident Winter Resident Summer Resident Resident Resident Migrant Migrant, Summer Resident Resident Summer Resident Migrant, Summer Resident Winter Resident Resident Resident Resident Migrant Resident Summer Resident

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Common Name Black-crested Titmouse Black-crowned Night-Heron Black-necked Stilt Black-tailed Gnatcatcher Black-throated Green Warbler Black-throated Sparrow Blue Grosbeak Blue-gray Gnatcatcher Blue-headed Vireo Blue-winged Teal Bonaparte's Gull Brewer's Blackbird Broad-winged Hawk Bronzed Cowbird Brown-crested Flycatcher Brown-headed Cowbird Bufflehead Bullock's Oriole Cactus Wren Cassin's Sparrow Cattle Egret Cave Swallow Cedar Waxwing Chihuahuan Raven Chimney Swift Chipping Sparrow Clay-colored Sparrow Cliff Swallow Common Grackle Common Ground Dove Common Nighthawk Common Paurague Common Poorwill Common Yellowthroat Cooper's Hawk Couch's Kingbird Crested Caracara Curve-billed Thrasher Dickcissel Double-crested Cormorant Eared Grebe Eastern Bluebird Eastern Kingbird Eastern Meadowlark Eastern Phoebe Eastern Screech Owl


b Scientific Name

Baeolophus atricristatus Nycticorax Himantopus mexicanus Polioptila melanura Setophaga virens Amphispiza bilineata Passerina caerulea Polioptila caerulea Vireo solitarius Spatula discors Chroicocephalus philadelphia Euphagus cyanocephalus Buteo platypterus Molothrus aeneus Myiarchus tyrannulus Molothrus ater Bucephala albeola Icterus bullockii Campylorhynchus brunneicapillus Peucaea cassinii Bubulcus ibis Petrochelidonfulva Bombycilla cedrorum Corvus cryptoleucus Chaetura pelagica Spizella passerina Spizella pallida Petrochelidon pyrrhonota Quiscalus quiscula Columbina passerina Chordeiles minor Nyctidromus albicollis Phalaenopttlus nuttallii Geothlypis trichas Accipiter cooperii Tyrannus couchii Caracara cheriway Toxostoma curvirostre Spiza americana Burhinus bistriatus Podiceps nigricollis Sialia sialis Tyrannus Sturnella magna Sayornis phoebe Megascops asio

3-23

ac Likely Seasonal Occurrence ' Resident Resident Migrant, Summer Resident Summer Resident Migrant Resident Summer Resident Winter Resident Winter Resident Migrant, Winter Resident Resident Winter Resident Migrant Resident Summer Resident Resident Winter Resident Summer Resident Resident Resident Summer Resident Resident Winter Resident Resident Summer Resident Winter Resident Migrant Summer Resident Winter Resident Resident Summer Resident Resident Resident Resident, Winter Resident Resident, Winter Resident Summer Resident Resident Resident Summer Resident Winter Resident Winter Resident Migrant, Winter Resident Migrant Winter Resident Summer Resident Resident

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Common Name Eastern Wood-Pewee European Starling Franklin's Gull Gadwall Golden-fronted Woodpecker Grasshopper Sparrow Gray Catbird Gray Hawk Great Blue Heron Great Crested Flycatcher Great Egret Great Horned Owl Great Kiskadee Greater Roadrunner Greater White-fronted Goose Greater Yellowlegs Great-tailed Grackle Green Heron Green Jay Green Kingfisher Green-winged Teal Groove-billed Ani Harris's Hawk Hermit Thrush Herring Gull Hooded Oriole Horned Lark House Finch House Sparrow House Wren lnca Dove Indigo Bunting Killdeer Ladder-backed Woodpecker Lark Bunting Lark Sparrow Laughing Gull Least Bittern Least Flycatcher Least Grebe Least Sandpiper Lesser Goldfinch Lesser Nighthawk Lesser Scaup Lesser Yellowlegs Lincoln's Sparrow


b Scientific Name

Contopus virens Sturnus vulgaris Leucophaeus pipixcan Mareca strepera Melanerpes aurifrons Ammodramus savannarum Dumetella carolinensis Buteo plagiatus Ardea herodias Myiarchus crinitus Ardea alba Bubo virginianus Pitangus suiphuratus Geococcyx californianus Anser albifrons Tringa melanoleuca Quiscalus mexicanus Butorides virescens Cyanocorax yncas Chloroceryle americana Anas crecca Crotophaga sulcirostris Parabuteo unicinctus Catharus guttatus Larus argentatus Icterus cucullatus Eremophila alpestris Haemorhous mexicanus Passer domesticus Troglodytes aedon Columbina inca Passerina cyanea Charadrius vociferus Dryobates scalaris Calamospiza melanocorys Chondestes grammacus Leucophaeus atricilla Ixobrychus exilis Empidonax minimus Tachybaptus dominicus Calidris minutilla Spinus psaltria Chordeiles acutipennis Aythya aff ln1S Tringa flavipes Melospiza lincolnii

3-24

ac Likely Seasonal Occurrence ' Migrant Resident Migrant Winter Resident Resident Resident, Winter Resident Migrant Resident Resident Migrant Resident Resident Resident Resident Winter Resident Summer Resident Resident Summer Resident Resident Resident Migrant Summer Resident Resident Migrant, Winter Resident Migrant Summer Resident Resident, Winter Resident Resident Summer Resident Winter Resident Resident Migrant Resident Resident Winter Resident Resident Migrant Migrant Migrant Resident Winter Resident Resident Resident Migrant, Winter Resident Migrant Winter Resident

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Common Name Little Blue Heron Loggerhead Shrike Long-billed Curlew Long-billed Dowitcher Long-billed Thrasher Magnolia Warbler Marsh Wren Merlin Mississippi Kite Mourning Dove Mourning Warbler Nashville Warbler Northern Bobwhite Northern Cardinal Northern Flicker Northern Harrier Northern Mockingbird Northern Parula Northern Pintail Northern Shoveler Northern Waterthrush Olive Sparrow Olive-sided Flycatcher Orange-crowned Warbler Orchard Oriole Osprey Painted Bunting Pectoral Sandpiper Peregrine Falcon Pied-billed Grebe Plain Chachalaca Purple Martin Pyrrhuloxia Red Shouldered Hawk Red-billed Pigeon Red-eyed Vireo Red-tailed Hawk Red-winged Blackbird Ring-billed Gull Ringed Kingfisher Ring-necked Duck Rock Pigeon Rock Wren Ruby-throated Hummingbird Ruddy Duck Rufous Hummingbird


b Scientific Name

Egretta caerulea Lanius ludovicianus Numenius americanus Limnodromus scolopaceus Toxostoma longirostre Setophaga magnolia Cislothorus palustris Falco colimibarius lctinia mississippiensis Zenaida macroura Geothlypis philadelphia Leiothlypis rujicapilla Colinus virginianus Cardinalis Colaples auratus Circus hudsonius Mimus polyglottos Setophaga americana Anas acuta Spatula clypeata Pat·kesia noveboracensis Arremonops rujivirgatus Contopus cooperi Leiothlypis celata Icterus spurius Palldion haliaetus Passerina ciris Calidris melanotos Falco peregrinus Podilymbus podiceps Ortalis vernia Progne subis Cardinalis sinuatus Buteo lineatus Patagioenas jlavirostris Vireo olivaceus Buteo jamaicensis Agelaius phoeniceus Larus delawarensis Megaceryle torquata Aythya collaris Columba livia Salpincles obsoletus Archilochus colubris Oxyurajamaicensis Selasphorus rufus

3-25

ac Likely Seasonal Occurrence ' Migrant Winter Resident Migrant Migrant Resident Migrant Winter Resident Winter Resident Migrant Resident Migrant Migrant Resident Resident Winter Resident Winter Resident Resident Migrant Migrant, Winter Resident Winter Resident Migrant Resident Migrant Winter Resident Migrant Winter Resident Winter Resident Migrant Migrant Winter Resident Resident Summer Resident Resident Summer Resident Summer Resident Migrant Resident Resident Winter Resident Resident Migrant, Winter Resident Resident Winter Resident Migrant Winter Resident Migrant

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b a, c Common Name Scientific Name Likely Seasonal Occurrence Sandhill Crane Antigone canadensis Migrant , Winter Resident Savannah Sparrow Passerculus sandwichensis Winter Resident Say ' s Phoebe Sayornis saya Winter Resident Scaled Quail Callipepla squamata Resident Scissor - tailed Flycatcher Tyrannusforjicatus Summer Resident Semipalmated Sandpiper Calidris pusilla Migrant Sharp - shinned Hawk Accipiter striatus Winter Resident Snowy Egret Egretta thula Migrant Solitary Sandpiper Tringa solitaria Migrant Sora Pot · zana carolina Winter Resident Spotted Sandpiper Actitis macularius Winter Resident Stilt - tailed Sandpiper Calidris himantopus Migrant Summer Tanager Piranga rubi · a Migrant , Summer Resident Swainson ' s Hawk Buteo swainsoni Summer Resident Swainson ' s Thrush Catharus ustulatus Migrant Swamp Sparrow Melospiza georgiana Migrant , Winter Resident Tree Swaliow Tachycineta bicolor Winter Resident Tricolored Heron Egretta tricolor Migrant Turkey Vulture Cathartes aura Resident Verdin Auriparus jlaviceps Resident Vermilion Flycatcher Pyrocephalus rubinus Resident Vesper Sparrow Pooecetes gramineus Winter Resident Warbling Vireo Vireo gilvus Migrant Western Kingbird Tyrannus vertical is Summer Resident Western Meadowlark Sturnella neglecta Winter Resident Western Sandpiper Calidris mauri Migrant White - eyed Vireo Vii · eo griseus Resident White - faced Ibis Plegadis chihi Migrant White - tailed Kite Elanus leucurus Summer Resident White - tipped Dove Leplolila verreauxi Resident White - winged Dove Zenaida asiatica Resident Wild Turkey Meleagris gallopavo Resident Willow Flycatcher Empidonax traillii Migrant Wilson ' s Phalarope Phalaropus tricolor Migrant Wilson ' s Snipe Gallinago delicata Winter Resident Wilson ' s Warbler Cardellina pusi ] Ia Migrant Yellow Warbler Setophaga petechia Migrant Yellow - bellied Sapsucker Sphyrapicus varius Winter Resident Yellow - billed Cuckoo Coccyzus americanus Summer Resident Yellow - breasted Chat Icteria virens Migrant , Summer Resident Yellow - headed Blackbird Xanthocephalus Migrant Yellow - rumped Warbler Teretistrisfernandinae Winter Resident Yellow - throated Vireo Vireo jlavifrons Migrant ' According to Lockwood and Freeman (2014) and Arvin (2007). bNomenclature follows Chesser et al. (2018) ° Resident: Occurring regularly in the same general area throughout the year - implies breeding.



Summer Resident: Implies breeding but may include nonbreeders. Winter Resident: Occurring during winter season. Migrant: Occurs as a transient passing through the area either in spring or fall or both.

The MBTA, originally passed in 1918, implements the U.S. commitmentto fourbilateral treaties, or conventions, for the protection ofa shared migratory bird resource, protecting more than 800 species of birds. The protection of migratory birds is regulated by the MBTA and BGEPA. Based on recent interpretation (issued December 2017; revised April 2018) ofthe MBTA by the U.S. Department of the Interior (DOI), the take provision for migratory birds is restricted to intentional actions. The USFWS field offices in Texas are now applying this interpretation with respect to project-related activities such as clearing ofvegetation within the breeding season. Since these activities are not designed to specifically take migratory birds5 the USFWS has not imposed seasonal timing restrictions or required compensatory mitigation. TPWD recommends excluding vegetation clearing during the general bird nesting season,

March through August, to avoid adverse impacts to nesting migratory birds. Ifthis is not feasible, TPWD

recommends a nest survey be conducted and any vegetation where occupied nests are located should not be disturbed until the eggs have hatched and the young have fledged. TPWD also referred to Avian Power Line Interaction Committee (APLIC) guidance documents for reducing bird collision with power lines (APLIC 1994).

According to the IPaC, it lists a total of four migratory birds of conservation concern which have the potential to occur in the Study Area (Table 3-6). Figure 3-6 shows the migration path for the federally protected whooping crane ( Grus americana ), which is outside of the Study Area . The breeding season for migratory birds is generally between April 1 through August 31.

Table 3-6: IPaC List of Migratory Bird Speciesa.

Probability of Common Name Scientific Name Presence in Study Breeding Seasona

Area Audubon ' s Oriole Jcterus graduacauda

Curve - billed Thrasher Toxosloma eun > i

Harris ' s Hawk Parabuteo unicintus

Lark Bunting Calamospiza melanocorys a According to USFWS (2020).

Possibly Breeding

Possibly Breeding

Possibly Breeding

Migrating

April-September

February- August

March-August

Breeds elsewhere



Figure 3-6: Location of Webb County in Relation to the Central U.S. Whooping Crane Flyway







3.7.5 Mammals

A representative list of mammals that may occur in the Study Area is included as Table 3-7.

Table 3-7: Representative List of Mammalian Species that Potentially Occur in the Study Area

Classification and Common Namea Scientific Nameb Didelphimorphia Virginia Opossum Chiroptera Brazilian free-tailed bat Ghost-faced bat Pallid bat Southern yellow bat Eastern red bat Cave myotis American Parastrelle Carnivores Coyote Common gray fox Bobcat Ocelot Hog-nosed skunk Striped skunk American Badger Ringtail Northern Racoon Artiodactyls White-tailed deer Collared Peccary Rodentia American Beaver Northern pygmy mouse Southern plains woodrat Northern grasshopper mouse Cactus deermouse Lacey's white-ankled deermouse White-footed deermouse Fulvous harvest mouse Hispid cotton rat Texas pocket gopher Gulf Coast kangaroo rat Ord's kangaroo rat Merriam's pocket mouse Rio Grande ground squirrel Eastern fox squirrel Spotted ground squirrel Lagomorphs Eastern Cottontail Desert cottontail Black-tailed jackrabbit Soricomorpha Least shrew

'' According to Schmidly and Bradley (2016) b Nomenclature follows Manning et al (2008)

\ Didelphis virginiana

Tadarida brasiliensis Mormoops megalophylla Antrozous pallidus Lasiurus ega Lasiurus borealis Myotis velifer Parastrellus herperus

Canis latrans Urocyon cinereoargenteus Lynx rufus Leopardus paradalis Conepatus Ieuco}lotus Mephitis Taxidea taxus Bassariscus astutus Procyon Iotor

Odocoileus virginianus Pecari tajacu

Castor canadensis Baiomys taylori Neotoma micropus Onychomys leucogastor Peromyscus eremicus Peromyscus laceianus Peromyscus leucopus Reithrodontoniys,fulvescens Sigmodon hispidus Geomys personatus Dipodomys compactus Dipodomys ordii Dipodomys merriami Ictidomys parvidens Sciurus niger Spermophilus spilosoma

Sylvilagus floridanus Sylvilagus audubonii Lepus californicus

\ Cryptotis parva



3.8 Recreationally and Commercially Important Species

A species is considered important if one or more of the following criteria apply:

• The species is recreationally or commercially valuable

• The species is endangered or threatened

• The species affects the well-being of some important species within criterion (a) or (b)

• The species is critical to the structure and function ofthe ecological system

• The species is a biological indicator.

Wildlife resources can generally be categorized as consumptive (fishing, hunting, trapping, etc.) and non-consumptive (photography, bird watching, etc.). Several species ofmammals, fish, and birds in the Study Area have consumptive value, while all may be considered to hold non-consumptive value. Primary consumptive value species in the general vicinity include white-tailed deer, javelina, mourning dove, white-winged dove, northern bobwhite, wild turkey, and several migratory duck species (Anas sp.). The white-tailed deer is generally considered the most economically important mammal in Texas (Schmidly 2016), due to the popularity of big game hunting. Additionally, several species are considered recreationally or commercially valuable for wildlife viewing opportunities, including many ofthe species listed in Tables 3.6-3.8.

Commercial fishing does not occur in the region; however, recreational fishing opportunities are present in the area. Due to the lack ofperennial waterways, fishing opportunities are limited to stock ponds and lakes within the Study Area. Common recreational fish species in the region include largemouth bass, white crappie, channel catfish, flathead catfish, and sunfish species.

3.9 Threatened and Endangered Species

This section assesses the potential for the proposed Project to adversely affect any of the T&E species

considered by USFWS and TPWD as having the potential to occur in Webb County or within the proposed Study Area. The analysis for this section includes a review of TPWD's TxNDD, including a review ofmaps and Element Occurrence Records (EOR). EORs are used as supporting data in conjunction with the desktop and field surveys. TRC consults with TPWD biologists on T&E species, and TPWD biologists respond to the data requests and provide the most up to date species data for the Study Area. The potential for the presence of special status species is described in the following sections. Available information from the USFWS (2020), TPWD (2019), and TPWD's TxNDD (TxNDD 2020) was reviewed to identify likelihood of federally and/or state-listed T&E species as well as Species of Greatest Concern (SGCN) to occur within the Study Area.



3.9.1 Federally - Listed Threatened and Endangered Species

Currently, there are seven T&E species listed by the USFWS as threatened or endangered that have the potential to occur within the Study Area (USFWS 2020; Appendix A Agency Correspondence Responses) and are listed below in Table 3-8.

Table 3-8: Federally - Listed Threatened, Endangered, and Special Status Species that Potentially Occur in Webb County, Texasa

Status Common Name Scientific Name USFWS Potential for

Occurrence in the Study Area

Birds Interior Least Tem Sternula antillarum athalassos Endangered Not likelyb Piping Plover Charadrius melodus Threatened Not likelyb Red Knot Calidris canutus mfa Threatened Not likelyb Clams Texas Hornshell Popenaias popeii Endangered Not likely Plants Ashy Dogweed Thymophylla tephroleuca Endangered Not likely Mammals

Herpailurus (=Felis) Gulf Coast Jaguarundi Endangered yagouaroundi cacomitli Ocelot Leopardus pardalis Endangered a According to USFWS IPaC (2020) b Only expected to occur as a migrant, transient, or rare vagrant within the Study Area

Not likelyb

Not likelyb

3.9.2 Federally - Listed Fish, Wildlife, and Plant Species

There are five federally endangered and two federally threatened species that have the potential to occur within the Webb County including the interior least tern, piping plover, red knot, Texas homshell, ashy dogweed, Gulf Coast jaguarundi, and the ocelot. The TxNDD review did not identify EORs for any ofthe federally - listed T&E species within 10 miles of the Study Area. Based on the existing conditions, no suitable habitat for the interior least tern, piping plover, red knot or Texas hornshell, was observed within the Study Area. Therefore, the proposed Project will have "no effect" on the interior least tem, piping plover, red knot, and the Texas hornshell. Based on the desktop analysis and the field observations, marginally suitable habitat for the ashy dogweed, ocelot and Gulf Coast jaguarundi was annotated and/or observed within the Study Area and are discussed below.

Ashy Dogweed

Ashy dogweed ( Thymophylla tephroleuca ) \ s a federally and state - listed endangered plant species in Webb County (USFWS 2020; TPWD 2020b). This species is an herbaceous perennial that occupies sandy pockets of Maverick-Catarina, Copita-Zapata and Nueces-Comita soils in Webb and Zapata Counties (TPWD 2019). Maverick-Catarina and Copita-Zapata map units (USDA-NCRC 2020) are located within



the Study Area. Ashy dogweed blooms March through May, depending on rainfall, but is present in its' habitat year-round. A species-specific field survey for the ashy dogweed was conducted within the Study Area by Acme Botanical Services and ESE Partners, LLC on September 23-24,2019 (ESE 2019). This report concluded that this site was found to lack any populations or habitat for the species. Additionally,

no ashy dogweed plants or specific suitable habitat were observed within the proposed Consensus Route during TRC's field surveys in February 2020. Therefore, the proposed Project will have "no effect" on the ashy dogweed.

Gulf Coast Jaguarundi

The Gulf Coastjaguarundi Uferpailurus yaguarondi ) \ s a federally - listed endangered species ( USFWS 2020). The habitat of the jaguarundj includes dense thornscrub with greater than 95% canopy cover. The

jaguarundi also uses brushlands, grasslands and riparian areas for travel and forage. Potential habitat

includes four areas of the Lower Rio Grande Valley (LRGV): Mesquite-Granjeno Parks, Mesquite-Blackbrush Brush, Live Oak Woodlands/Parks, and Rio Grande Riparian (TPWD 2020c; Appendix A Agency Correspondence Responses). Habitat loss and fragmentation from agriculture and development, especially along the Rio Grande, are the primary causes of population decline. No jaguarundis were observed nor was sufficient continuous habitat identified during the February 2020 field survey.

Therefore, the proposed Project will have "no effect" on the Gulf Coast jaguarundi.

Ocelot

The ocelot ( leopardus pardalis ) is a federally - listed endangered species ( USFWS 2020d ). This species is found from the southern tip of Texas and Arizona and northern Mexico into northern Argentina, Paraguay, and Uruguay. The habitat of the ocelot is similar to that of the jaguarundi and includes dense thornscrub with greater than 95% canopy cover. Ocelots also use brushlands, grasslands and riparian areas for travel and forage. Potential habitat includes four areas of the LRGV: Mesquite-Granjeno Parks, Mesquite-Blackbrush Brush, Live Oak Woodlands/Parks, and Rio Grande Riparian (TPWD 2020d). Large tracts of isolated dense brush and even smaller tracts (75 acres or less) connected with other habitat

tracts by brush corridors, are considered very important. Tracts as small as five acres (adjacent to larger areas) may also be used by Ocelots. Roads, narrow water bodies, and rights-of-way are not considered barriers to movement. Brushy fence lines, water courses, and other dense brush connecting areas of habitat are very important (TPWD 2020d). Habitat loss and fragmentation from agriculture and development, especially along the Rio Grande, are the primary causes of population decline. No ocelots were observed during the February 2020 field survey.

The Study Area is located along previously disturbed areas and regular maintenance activities (e.g., tree and shrub vegetation clearing) are conducted along the existing adjacent ROW (Figure 2-1). In South Texas, male ocelots require continuous habitat/territory, typically greater than 25 square miles, to support



breeding populations (TPWD 2020d). The maintained ROW areas within the Study Area fragment the habitat and disrupt continuity of vegetation. Additionally, the Study Area is located in the northern-most section of their known historical habitat (TPWD 2020d). Construction noise may negatively impact Gulf Coast jaguarundi or ocelots that are within 300 feet of the construction area. No ocelots were observed, nor was sufficient continuous habitat identified during TRC's February 2020 field survey. Therefore, it was determined that the proposed Project will have "no effect" on ocelots.

3.9.3 Critical Habitat

The USFWS, in Section 3(5)(A) of the ESA, defines critical habitat as:

"(i) the specific areas within the geographical area occupied by the species, at the time that it is listed in accordance with the ESA, on which are found those physical or biological features (I) essential to the conservation of the species and (II) which may require special management considerations or protection; and (ii) specific areas outside the geographical area occupied by a species at the time it is listed in accordance with the ESA, upon a determination by the Secretary of the Interior that such areas are essential for the conservation of the species."

The IPaC provided by USFWS constitutes the official coordination documentation with the USFWS. The IPaC revealed that no critical habitat is located within or near the Study Area for any federally - listed species under the ESA.

3.9.4 State-Listed Fish, Wildlife, and Plant Species

There are 70 species listed by TPWD as threatened, endangered, or Species of Greatest Conservation Need (SGCN) in Webb County (TPWD 2019; Appendix A Agency Correspondence Responses). Ofthe listed species, there are three state endangered, 17 state threatened, and 50 state SGCN (TPWD 2019). These species are listed in Table 3-9 below.

Table 3-9: State-listed Threatened, Endangered, and Special Status Species that Potentially Occur in Webb County, Texasa

Common Name

Amphibians South Texas Siren (Large Form) Birds Franklin's Gull Gray Hawk Interior Least Tern Mountain Plover Reddish Egret


Potential for Status Scientific Namea TPWDb Occurrence in the Study Area

Siren sp . 1 Threatened Likely

Leucophaeus pipixcan SGCN Not likely Buteo plagiatus Threatened Not likelyc Sternula antillarum athalassos Endangered Not likelyc Charadrius montanus SGCN Not likelyc Egretta rufescens Threatened Not likelyc

3-33 TRC Companies



Common Name

Western Burrowing Owl White-faced Ibis Wood Stork Fish Rio Grande Darter Rio Grande Shiner Speckled Chub Tamaulipas Shiner Insects American Bumblebee Neojuvenile Tiger Beetle Unnamed Mayfly Mammals American Badger Black Bear Cave Myotis Bat Davis Pocket Gopher Eastern Red Bat Eastern Spotted Skunk Hoary Bat Long-tailed Weasel Mexican Free-tailed Bat Mountain Lion Ocelot Southern Yellow Bat Strecker's Pocket Gopher Tricolored Bat Western Hog-nosed Skunk Western Spotted Skunk White-nosed Coati Mollusks Glossy Wolfsnail Mexican Fawnsfoot Mussel Salina Mucket Texas Hornshell Reptiles Keeled Earless Lizard

Potential for Status Scientific Namea Occurrence in TPWDb the Study Area

Athene cunicularia hypugaea SGCN Not likely Plegadis chihi Threatened Not likelyc Mycteria americana Threatened Not likelyc

Etheostoma graham Threatened Not likely Notropis . jemezanus SGCN Not likely Macrhybopsis aestivalis SGCN Not likely Notropis braytoni SGCN Not likely

Bombus pensylvanicus SGCN Likely Cicindela obsoleta neojuvenilis SGCN Likely Latineosus cibola SGCN Likely

Taxidea taxus SGCN Not likely Ursus americanus Threatened Not IiI ( elyc Myotis velifer SGCN Not likely Geomys personatus davisi SGCN Not Likely Lasiurus borealis SGCN Not likely Spilogale putorius SGCN Not likelyc Lasiurus cinereus SGCN Not likely Mustelafrenata SGCN Not likely Tadarida braslliensis SGCN Not likely Puma concolor SGCN Likely Leopardus pardalis Endangered Not Likely Lasiurus ega Threatened Not likely Geomys streckeri SGCN Not likely Perimyotis subflavus SGCN Not likely Coenpatus leuconotus SGCN Not likelyc Spilogale gracilis SGCN Not likelyc Nasua narica Threatened Not likelyc

Euglandil ' la texasiana SGCN Not likely Truncilla cognata Threatened Not likely Potamilus metnecktayi Threatened Not likely Popenaias popeii Threatened Not likely

Holbrookia propinqua SGCN Not likely




Common Name

Massasauga Northern Cat-eyed Snake Reticulate Collared Lizard Rio Grande River Cooter Southern Spot-tailed Earless Lizard Spot-tailed Earless Lizard Texas Horned Lizard

Potential for Status Scientific Namea Occurrence in TPWDb the Study Area

Sisfrurus lei * geminus SGCN Not likely Leptodeira septentrionalis Threatened Likely Crotophytus reticulafus Threatened Likely Pseudemys gorzugi SGCN Not likely Holbrookia lacerata subcaudalis SGCN Not likely Holbrookia lacerata SGCN Likely Phrynosoma cornutum Threatened Not likelyc

Texas Indigo Snake

Texas Tortoise Timber (Canebrake) Rattlesnake Western Box Turtle Western Hognose Snake Plants Arrowleaf Milkvine Ashy Dogweed Buckley's Spiderwort Croft's Bluet

Fitch's Hedgehog Cactus

Johnston's Frankenia Kleberg Saltbrush McCart's Whitlow-won Nickel's Cory Cactus

Sand Sheet Leaf-flower

Shortcrown Milkvine Siler's Huaco South Texas Gilia

Drymarchon melanurus Threatened Likely erebennus Gopherus berlandien Threatened Likely Crotalus hot ' ridus Threatened Not likely Tel · rapene ornate SGCN Likely Heierodon nasicus SGCN Likely

Matelea sagittifolia SGCN Likely Thymophylla tephroleuca Endangered Not likelyc Tradescantia buckleyi SGCN Not likely Houstonia croftiae SGCN Not likely Echinorcereus reichenbachii var SGCN Not likelyc fitchii Frankenia . johnstonii SGCN Not likely Atriplex klebegorum SGCN Not likely Paronychia maccartii SGCN Not likely Corypantha nickelsiae SGCN Not likely Phyllanthus abnormis var SGCN Not likely riograndensis Matelea brevicoronata SGCN Not likely Manfreda sileri SGCN Not likely Gilia iudens SGCN Not likely

South Texas Yellow Clammyweed Polanisia erosa ssp. SGCN Not likely Breviglandulosa Texas Almond Texas Shrimp-plant Texas Stonecrop Yellow-flowered Alicoche ~ According to TPWD (2019).

Prunus minutiflora SGCN Not likely Yeatesia piatystegia SGCN Not likely Lenophyllum texanum SGCN Not likely Echinocereus papillosus SGCN Not likely

b SGCN = Species of Greatest Conservation Need (TPWD, 2019) c Only expected to occur as a migrant, transient, or rare vagrant within the Study Area.



Potentially suitable habitat for 13 species listed in Table 3-9 was observed within the Consensus Route Study Area during field surveys in February 2020 including five state-listed T&E species, the south Texas siren, northern cat-eyed snake, reticulate collared lizard, Texas indigo snake, and Texas tortoise. Additionally, eight SGCN species including American bumblebee, mayfly, arrowleaf milkvine, neojuvenile tiger beetle, western box turtle, western hognose snake, spot-tailed earless lizard, and the mountain lion have the potential to occur within the Consensus Route Study Area.

The TxNDD did not identify any EOR within the Study Area, however EORs for the Texas Stonecrop ( Lenophyllum texanum ), Johnston ' s Frankenia ( Frankeniajohnstonii ), and Uie western hog - nosed skunk ( Coenpatus leuconotus ) were identified within five miles of the Study Area . The EOR records for the western hog-nosed skunk date from the 1890s, and with no recorded sightings since that time, the species is likely extirpated from the area. No sign of western hog-nosed skunks was observed during the February 2020 field investigation, nor were any direct observations made of the species. As noted above, the habitat observed within the proposed Consensus Route within the Study Area does not appear to coincide with the needs ofthe western hog-nosed skunk. Therefore, the Consensus Route is not anticipated to provide suitable habitat for the American hog-nosed skunk at this time. Texas Stonecrop and Johnston's Frankenia are identifiable year-round in the habitats in which they occur. However, no species, or

preferred habitat, of Texas Stonecrop or Johnston's Frankenia were observed during the February 2020 on-site field investigation ofthe proposed Consensus Route.

South Texas Siren

The south Texas siren is an aquatic salamander known for burrowing into debris and mud within slow-moving bodies of water. There is considerable debate regarding the whether the south Texas siren is its own species, or if it is a subspecies of the much more widespread lesser siren. Suitable habitat for the South Texas siren was observed within the Study Area stock ponds located north ofthe Lobo Station (Figure 2-2), but outside ofthe proposed Consensus Route. Based on the current design plans, the proposed Project will avoid impacts with any aquatic features including stock ponds. No EORs or preferred aquatic habitat for the South Texas siren is located within the Consensus Route. Therefore, the proposed Project will have "no impact" on the South Texas siren.

Northern Cat-eyed Snake

The northern cat-eyed snake can be found in thorn brush woodlands, dense thickets bordering ponds, and streams. Suitable habitat was observed near stock ponds within the Study Area located north of the Lobo Station (Figure 2-2), but outside of the proposed Consensus Route. No EORs for the northern cat-eyed snake were recorded within 10 miles of the Study Area (TXNDD 2020). Based on the current design plans, the proposed Project will avoid impacts with any aquatic features including stock ponds. Therefore, the proposed Project is expected to have "no impact" on the northern cat-eyed snake.



Reticulate Collared Lizard

The reticulate collared lizard occupies a variety of habitats, which include brush-grasslands and thorn-scrub vegetation, usually on well-drained rolling terrain of shallow gravel, caliche, or sandy soils. The reticulate collared lizard can also be found on scattered flat rocks below escarpments or isolated rock outcrops among scattered clumps of prickly pear and mesquite rock piles. The reticulate collared lizard

burrows in brushy environments (TPWD 20]9). Suitable habitat (loose sandy soils, brush-grasslands, thorn-scrub vegetation) was observed throughout the Study Area. No EORs were recorded within 10 miles of the Study Area. No reticulate collared lizard species were observed during the February 2020 on-site field investigation within the proposed Consensus Route. Based on field observations and the presence of potentially suitable habitat for the reticulate collared lizard, i f TPWD recommendations are followed, the proposed Project "may impact, but not likely to adversely impact" the reticulate collared lizard.

Texas Indigo Snake

The Texas indigo snake is the largest nonvenomous snake in North America and is typically associated with aquatic habitats including creeks, streams, ponds, and drainages. The riparian corridors that develop along drainage ditches provide suitable habitat for this species. Due to its high metabolism, it has a large home range in which it searches for prey and may be encountered away from aquatic habitats (TPWD 2019). Because all snakes are generally perceived as a threat and killed when encountered during vegetation clearing, TPWD recommends that Project plans include comments to inform contractors ofthe potential for state listed snakes to occur in the Project area. The TPWD agency response received on March 26,2020 Appendix A, Agency Correspondence Responses) directs that contractors should be advised to avoid impacts to this species and other snakes as long as the safety of the workers is not compromised. For the safety workers and preservation of protected snakes, attempting to catch, relocate

and/or kill non-venomous or venomous snakes is discouraged by TPWD. If encountered, snakes should be permitted to safely leave the Project areas on their own. TPWD encourages construction sites to have a "no kill" policy in regard to wildlife encounters. Based on field observations and the presence of potentially suitable habitat for the Texas indigo snake, if TPWD recommendations are followed the proposed Project "may impact, but not likely to adversely impact" the Texas indigo snake.

Texas Tortoise

The Texas tortoise has a home range of approximately five to 10 acres. Potentially suitable habitat for the Texas tortoise occurs throughout portions of the proposed Project's study area and adjacent areas (TPWD 2019). The TPWD agency response received on March 26,2020 (Appendix A, Agency Correspondence Responses) recommends that contractors working in the proposed Project area be made aware of the

potential for the state listed Texas tortoise to occur in the area. Contractors and other staff should be made



aware that in south Texas, the Texas tortoise is inactive from December through January and is, therefore, likely to be undetectable in a Project area during this time. TPWD recommends that a biological monitor be on site during any vegetation clearing to inspect sites subject to disturbance that may provide cover for tortoises, particularly bases of prickly pear cactus. Additionally, tortoises have been known to seek cover (shade) underneath parked vehicles; therefore, TPWD recommends that before driving vehicles that have been parked with the Project construction corridor, contractors should check underneath the vehicles to ensure no tortoises are present. Based on field observations and the presence of potentially suitable habitat for the Texas tortoise, i f TPWD recommendations are followed the proposed Project "may impact, but not likely to adversely impact" the Texas tortoise.

Species of Greatest Conservation Need

TPWD is the steward ofthe Texas Conservation Action Plan (TCAP). This revised Texas plan (approved

by the USFWS in 2013) is a series of 11 regionally - specific Ecoregion handbooks, a Statewide/Multi-region handbook, and an Overview document. While the TCAP is a conservation plan for species most at risk, its primary purpose is to bring people together to realize conservation benefits, prevent species listings, and preserve our natural heritage for future generations. Handbooks contain information on SGCN, regionally important habitats, local conservation goals and projects, regional and statewide activities, contact information for conservation partners, and maps. The activities in each handbook are starting points to engage landowners, land-use planners, natural resources professionals, and the public in regional and local community-based conservation.

Suitable habitat for eight SGCN including the American bumblebee, mayfly, arrowleaf milkvine, neojuvenile tiger beetle, western box turtle, western hognose snake, spot-tailed earless lizard, and the mountain lion were observed within the Study Area. No species of arrowleaf milkvine were observed during the February 2020 on-site field investigation. During construction, conservation measures will

include, but are not limited to, contractors being made aware that these species may be present during construction, and if present, to avoid harming or killing these species.

Sensitive Plant Communities

The TxNDD data lists plant communities which are considered valuable or at risk due to habitat alteration. The TxNDD data identifies one EOR for the Texas stonecrop and two for the Johnston's frankenia between three and four miles to the wesUnorthwest of the Study Area. The EOR for the Texas

stonecrop are for rock outcrops and other terrain features not observed within the Study Area during the February 2020 on-site field investigation. Johnston's frankenia is considered a SGCN by TPWD (TPWD, 2019) and has been de-listed by USFWS and TPWD. Suitable soils (strongly saline, highly alkaline, calcareous or gypseous soil map units are located within the Study Area. No specimens of either Texas stonecrop or Johnston's frankenia were observed during the February 2020 on-site field investigation.



3.10 Human Resources

3.10.1 Community Values and Community Resources

The term "community values" is included as a factor for consideration of transmission line certification

under PURA § 37.056(c)(4). Although the term is not formally defined in the statute or PUC rules, the PUC and the PUC Staff have recognized a working definition as "a shared appreciation of an area or other mutual resource by a national, regional, or local community" in several CCN proceedings.

TRC evaluated the proposed Project for community resources that may be important to a community as a whole, such as parks or recreational areas, historical and archeological sites, or scenic vistas within the Study Area. Additionally, TRC mailed consultation letters to federal, state, and local officials (Appendix A) to, among other things, identify and collect information regarding community values and community

resources. Input received was used in the evaluation ofthe proposed Project. Community values and

community resources are discussed in the following sections.

3.10.2 Land Use

The Study Area is located in the east-central portion of Webb County, Texas approximately 11.2 miles northeast of the City of Laredo. Webb County is the 6th largest county of 254 counties in Texas in terms of land area, at approximately 3,376 square miles (Texascounties.net 2020). The estimated total population of Webb County was estimated to be 275,910 in 2018 (Data USA 2020). Laredo, which serves as the county seat, is located approximately 11.2 miles southwest of the Study Area. No incorporated cities are located within the Study Area. The unincorporated area of Ranchitos Las Lomas, TX is a census-designated place (CDP) beginning approximately 0.75 mile east ofthe proposed Corazon Solar POI and north of U.S. Highway 59. The population at the 2010 census was 266 within approximately 21.9 square miles (U.S. Census Bureau 2020). The area is served by the United Independent School District (240903) (USDI 2020). There are no schools or other facilities located within the Study Area boundary.

The Study Area is located in State Planning Region No. 19, represented by the South Texas Development Council (STDC) 7 (Nortexrpc 2020). The STDC serves four counties and eight cities in the region. The region covers approximately 6,799 square miles and a population of approximately 359,659 (Texas Regional Council 2020).

The STDC, organized in 1956, serves local governments in its four-county region (Webb, Jim Hogg, Starr, and Zapata), also known as State Planning Region 19. STDC is the regional planning commission organized under Chapter 3915 Local Government Code, and is one of 24 regional planning commissions within the State of Texas (STDC 2020a).

The primary focus of STDC is to serve as advocate, planner, and coordinate initiatives that can be more effective and efficient. These initiatives include homeland security, elderly assistance, law enforcement



training, criminal justice planning, solid waste management, health services outreach and assistance, infrastructure development, economic analysis, transportation and regional planning, community and economic development, census data, and HIV services (STDC 2020b).

USDA NASS geospatial data and interactive maps were referenced to estimate land use within the Study Area and Consensus Route ROW. The total land area of the Study Area is approximately 2,478 acres and the Consensus Route ROW is approximately 69.6 acres (0.1 square miles). The Study Area includes approximately 2367 acres ofshrubland and approximately 30 acres of Grassland/Pasture (grazing land), of which approximately 68.4 acres of Shrubland and 0.5 acres of Grassland/Pasture are within the Consensus Route ROW. Webb County includes approximately 90 percent pastureland, seven percent woodland, and three percent other uses (USDA NASS, 2019).

As identified above in Section 3.4, no major mineral resources are mapped near the Study Area (BEG 2019). Additionally, USGS topographic maps do not indicate the presence of mines or quarries near the Study Area. RRC records indicate there are no oil gathering or natural gas lines that overlap the Study Area (RRC 2019). Current aerial photographs, the REXTAG database (REXTAG 2020), and the RRC indicate the presence of one active gas well in the Study Area located approximately 2,325 feet (0.44 mile) north of U.S. Highway 59 and approximately 450 feet east of the Consensus Route. Other oil and gas activity in the Study Area includes plugged oil and gas wells, permitted locations, shut-in gas wells, and dry holes. Similar categories appear to the east and west of the Study Area. There also is a natural gas gathering facility and pipelines owned by DCP Interstate Network, LLC that cross the Study Area just north of U.S. Highway 59.

3.10.3 Recreation

Webb County Texas is included in the Southern Texas Plains Conservation Action Plan Ecoregion and Texas Outdoor Recreation Plan region 2. A review of the Texas Outdoor Recreation Plan (TPWD 2018), federal, state, and local maps, an Internet search, and field reconnaissance did not reveal any national, state, county, or municipal parks, forests/grasslands, wildlife refuges, wildlife management areas, or preserves within the Study Area (TPWD 2018). Recreational activities such as hunting may occur on private properties within the Study Area, but these properties are not open to the public.

3.10.4 Agriculture

Webb County is in the Western Rio Grande Plain major land resource area (USDA-NRCS 2006). The land surface is nearly level to rolling and elevations in the county range from 300 feet to about 800 feet above sea level (BEG 1996). The average annual rainfall is 20.4 inches. The mean annual temperature is 71.8°F (USA.com 2020). The USDA-NRCS Web Soil Survey (USDA-NRCS 2019) identifies several major soil types present in the Study Area. Of these, the Moglia clay loam, Catarina clay, Maverick-



Catarina complex, and Copita fine sandy loam soils have moderate potential to contain significant cultural sites.

Webb County is primarily ranch country, and cattle ranching is the major agricultural enterprise. Webb County is consistently one ofthe leading cow-calfproducing counties in Texas. Leasing ofranches for hunting is another important enterprise in the county. White-tailed deer, javelina, dove, and quail are the major game species. Vegetables, grain sorghum, cotton, and pasture grasses are grown using irrigation

water from the Rio Grande. In 1980, about 5,000 acres in the county were irrigated cropland or pasture, about 25,000 acres were urban or built-up land, and the remaining 2,124,163 acres were rangeland, wildlife habitat, roads, and water areas (USDA-NRCS 2005).

3.10.5 Transportation and Aviation

The major transportation feature located within the Study Area is U.S. Highway 59. U.S. Highway 59 bisects the Study Area approximately one mile north of the southern boundary of the Study Area. The length of U.S. Highway 59 through the Study is approximately 1.0 mile (refer to Figure 2-1).

A review of the Brownsville Sectional Aeronautical Chart (FAA 2020), the TxDOT Airport Directory (TxDOT 1998), aerial photography, USGS maps, field reconnaissance, and Internet sources revealed no FAA-registered airports within 20,000 feet or heliports located within 5,000 feet of the proposed Consensus Route. Additionally, no private airstrips or heliports were identified within the Study Area.

There are no known FAA-registered airports having a runway more than 3,200 feet in length that are

within 10,000 feet of the centerline of the Consensus Route. No known airports registered with the FAA with at least one runway more than 3,200 feet in length are within 20,000 feet ofthe centerline ofthe Consensus Route. The only public airport is the Laredo International Airport located approximately 11.2 miles southwest of the Study Area. There is a private airport, Santa Maria Ranch Airport (Location ID: 0TE5) approximately 6.9 miles southeast of the southern boundary of the Study Area ( Data 2020a).

No heliports are within 5,000 feet ofthe centerline ofthe Consensus Route. The only known heliports are at Doctors Hospital Heliport (Location ID: 28XA) and the Laredo Medical Center Heliport (Location ID: XA22), located approximately 12.0 miles west and approximately 12.7 miles southwest, respectively, of

the Study Area.

3.10.6 Communication Towers

A search ofthe Federal Communications Commission (FCC) website, online cell tower search engines, and field reconnaissance revealed no commercial AM or FM radio towers within the Study Area (FCC, 2019; Antenna Search, 2019; Cell Reception, 2019). There is one private communications tower located within the Study Area adjacent to the south side of the ETT Lobo Station. This tower is owned by AEP Texas. Other communications towers in the vicinity include one located east of the Study Area on the



north side of U.S. Highway 59 and west of Camino Los Lomas road and south of Ranch Road 7150G, another located east ofthe Study Area to the north of U.S. Highway 59 and east of Las Lomas road, and another located west of the Study Area and south of U.S. Highway 59 approximately 1.46 miles west of the ETT Lobo Station access road (see Figure 2-2) (City Data 2020b).

3.10.7 Existing Utilities

Existing utilities within the Study Area include electric facilities owned and operated by ETT and AEP Texas. Electric distribution lines owned by AEP Texas are located along major roads and, in the census-designated place Ranchitos Las Lomas community serving electricity to local homes and ranch

operations, and commercial properties. There also is a natural gas gathering facility and pipelines owned by DCP Interstate Network, LLC that cross the Study Area just north of U.S. Highway 59 (refer to Figure

2-2).

3.10.8 Aesthetic Values

Aesthetics is included as a factor for consideration in the evaluation of transmission facilities in PURA §37.056(c)(4). The term aesthetics refers to the subjective perception of natural beauty in the landscape, and this section of the document attempts to define and measure the Study Area's scenic qualities.

Consideration of the visual environment includes a determination of aesthetic values where the major potential effect ofthe Project on the resource is considered aesthetic or where the location of a transmission line could affect the scenic enjoyment of a recreation area.

The aesthetic analysis considers potential visual impacts to the public. Areas visible from major roads and highways, or publicly owned or accessible lands (e.g., parks or privately-owned recreation areas open to the public) were analyzed. Several factors are taken into consideration when attempting to define the potential impact to a scenic resource that would result from the construction of the proposed transmission line. Among these are:

• topographical variation (hills, valleys, etc.)

• prominence of water in the landscape

• vegetation variety (forests, pasture, etc.)

• diversity of scenic elements

• degree of human development or alteration, and

• overall uniqueness of the scenic environment compared to the larger region.

The THC operates the Texas Heritage Trails Program, a statewide heritage tourism program based on 10 scenic driving trails originally created by TxDOT. This program operates throughout 10 regions of Texas



and enables people to learn about, and be surrounded by, local customs, traditions, history, and culture of the different regions. The Study Area is located within the Tropical Trail Region, which contains 20 counties and covers approximately 23,000 square miles. Situated between the mountain plateaus and the Gulf, the Tropical Trail Region has a subtropical climate with plants and animals found nowhere else in the United States. The region is made up of four distinct byways: the Border Byway skirts the nation of Mexico; the Gul f Coast Byway runs along the Gulf Coast; the rich landscapes between are called the Brush Country Byway and the Wild Horse Desert Byway (Tropical Trail 2020). There are more than 60 historic markers in Webb County (Webb County Historical Commission 2020). Seven of the markers are within Laredo, Texas. None of the markers are located within the Study Area (THC, 2019).

U.S. Highway 59 passes through the Study Area from Laredo in a northwesterly direction where it crosses rural ranching areas with scattered residences, power lines, communications towers, and oil and gas development. There are no rest areas, historic markers, or scenic overlooks along the highway (Go-Texas 2020). No other outstanding aesthetic resources, designated scenic views, or unique visual elements were identified from web searches or from ground reconnaissance ofthe Study Area.

The Study Area exhibits a low to moderate degree of aesthetic quality for the region. The majority of the Study Area is ranchland, categorized by undulating topography, and no significant water bodies. The closest habitable structure to the Consensus Route is approximately 0.45 miles northeast ofthe ETT Lobo Station. One other habitable structure is located in the Study Area approximately 0.5 mile east of the Consensus Route and approximately 0.5 mile north of U.S. Highway 59. There are no other habitable structures in the Study Area. The Census Designated Community ofRanchitos Las Lomas begins approximately 0.75 mile east of the eastern Study Area Boundary and east of the proposed Corazon Solar POI. There is no commercial development in the Study Area and the landscape has experienced a moderate degree of alteration due to the existing Lobo Station and transmission lines, and the U.S. Highway 59 transportation corridor that bisects the Study Area north of the existing ETT Lobo Station.

3.11 Cultural Resources

As shown on Figure 3-7, Webb County occurs in the Rio Grande Plains Archeological Region as delineated by the THC. Archaeologically, the Study Area is in the Interior Coastal Plains region ofthe South Texas Plains that is physiographically classified as South Texas Brush County and the vegetation is part of the Tamaulipan Shrublands biome that stretches from the Balcones Escarpment toward Mexico (Blair 1950; Griffith et al. 2007). There have been 183 previous cultural resource investigations, 848 previously recorded archaeological sites, and 59 previously recorded historic resources documented in Webb County.



3.11.1 Cultural Overview

Archeologists in Texas have assigned cultural regions to Texas that generally correspond to various physiographic characteristics of the areas. As such a construct, the South Texas Archeological Region is bounded by the Rio Grande River to the west and south, the Guadalupe River to the east, and the Balcones Escarpment/Edwards Plateau to the north. Few in-depth excavations have been conducted in this region since the 1960s (Hester 2004:128). As Hester (2004) has observed, the evidence of human occupation is abundant, but has proved challenging to establishing a chronological sequence of events and interpreting past human lifeways. While deeply stratified sites that provide a continual assessment of chronology and associated techno-cultural adaptations have been excavated with some temporal consistency in the Lower Pecos (see Bush et al. 2015; Castenada and Koenig 2016; Turpin 2004; and Texas Beyond History 2018), similar research has occurred with less regularity for the reaches of South Texas outside of Bexar County. Within a one-county-adjacent proximity to the current Study Area some notable archeological projects include work at 41MV120 (Vierra 1998); 41MV372 (Boyd et al. 2014); 41 WB441, 41WB572, 41 WB578, and 41 WB621 (Carpenter et al. 2010); 41 WB437 (Quigg et al. 2000); 41 WB557 (Quigg et al. 2002; Carpenter et al. 2010); 41ZV155 (Inman et al. 1998); 41ZV202 (Mauldin et

al. 2010); 41Z41ZV527 and 41 ZV528 (Haefner et al. 2013). Open surface occupation sites are the most frequent archeological site found across this region. These are usually found to be heavily eroded with large expanses of archeological material on the disturbed surface. Other site types identified include lithic caches, cooking hearths, pit features, bone clusters, human burials, worked shells, and activity areas (Hester 1969,1976, 1978a; 1978b, 1980; 1983,1994,1995,2004; Collins et al. 1969; Prewitt 1974). The typical streamside open campsite in extreme South Texas occurs commonly in long and narrow occupation zones. These strips frequently represent single, thin occupational deposits that rarely overlap.

The archeological mani festations of South Texas are divided into four broad time periods: the Paleoindian (11,500-8,000 Before Present [B.P])3 Archaic (8,500-1,500 B.P.), Late Prehistoric (1,500-500 B.P.), and Protohistoric (500-200 B.P.) and Historic periods (200-50 B.P.) (Black 1989; Hester 1995, 2004). A

brief synthesis ofthe key characteristics of these four periods is presented below.



Figure 3-7: Location of Webb County in Relation to the Cultural Resources Planning Regions of Texas

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to the Cultural Resources Planning Eractdc Tiaismlssjon Texas Regions of Texas

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1 Inch=115 Mles Transmission Line in Webb County, Texas



3.11.2 Paleoindian Period (11,500-8,000 B.p.)

The general accepted temporal range ofthe Paleoindian Period for South Texas is from approximately 11,500 to around 8,000 B.P. The defining artifactual characteristic ofthe Paleoindian period is considered the large lanceolate projectile points that include commonly recorded types such as Clovis, Folsom, Midland, Plainview, and Agate Basin. These points were used to tip the shafts of spears. Generally, the economic reliance was thought to have focused primarily on big game hunting, although recently a more diverse subsistence base has come to light (Hester 1983; Johnson 1987). The earliest groups in the Clovis period are thought to have had subsisted upon diverse and extinct big game, but the groups after about 11,000 years ago focused on extinct bison as the principal animal resource. Given a mobile food resource such as bison, it is believed that most Paleoindian populations were constantly on the move following the game animals and, therefore5 very nomadic hunters. Although many Paleoindian projectile points have been recovered in the region, very few well-excavated and reported Paleoindian site investigations have been completed in South Texas.

Areas in South Texas where Clovis points have been documented include sites in Wilson and Dimmit counties (Kelly I 988), Atascosa County (Hester et al. 1993), and just south of Falcon Reservoir in Mexico. In the same token, several Folsom-aged points have also been recorded throughout south Texas (Bettis 1997). Currently noted site types dated to the early Paleoindian period in South Texas are mainly limited to tool manufacturing localities. Later Paleoindian cultural manifestations, including those that

exhibit Plainview, Scottsbluff, and Angostura artifacts, do not fare much better. St Mary's Hall site, a discrete camp site and reduction locality in Bexar County, Texas, is one exception (Hester 1990). Faunal kill and butchering sites are not known in South Texas. Any large fauna found from this period is usually in secondary deposits along stream beds (Hester 2004:133). Typically, archeological sites dating to this Paleoindian period lack the large concentrations of burned rocks and burned rock features that are

common in the subsequent Archaic period.

3.11.3 Archaic (8,500-1,500 B.P.)

Following the Paleoindian period, the Archaic extended from approximately 8,500 to about 1,500 B.P. This period is generally divided into shorter time units that are labeled as Early, Middle, and Late Archaic. In the South Texas region, few sites of the Archaic Period have been extensively excavated and reported on. What evidence exists suggests that Archaic populations appear to have diversified their subsistence base, utilizing an array of plant and animal resources. With this diverse economy came intensive use of many and diverse burned rock cooking features. During the Archaic, projectile point forms also changed to smaller, stemmed and notched forms that were used to tip dart shafts used with the atlatl (spear thrower). Large herds of bison were apparently not as frequent as during Paleoindian times and the plant foods more localized, therefore the groups were thought to have been more regional.



Together with more regional economics came an apparent increase in population size and density as well as an overall decrease in mobility.

The Early Archaic is considered to have occurred from about 8,500 to 5,000 B.P. This is a period generally associated with the mid-Holocene Altithermal or Atlantic interval, a dry and warm period (Hofman 1989:45). The Early Archaic is characterized by several new tool forms including grinding tools and gouges, but the latter possibly appeared even earlier. Hester (1989) recognizes two primary cultural horizons in the Early Archaic, early corner-notched projectile users and early basal-notched users. Both horizons have comparable projectile point affinities (Martindale-Uvalde-Baker-Bandy) in adjacent cultural regions of Texas. In South Texas, the early corner-notched using peoples are poorly understood. Hester suggests that these peoples may have operated as small bands that were highly mobile and wide ranging due to the arid climatic conditions modeled for this timeframe (Hester 2004:137; Story 1985). Early basal notched point users include Bell, Andice, and Calf Creek peoples (Wyckoff 1995). This horizon seems to extend from the Texas Coast up through the United States Central Plains (i.e., Kansas). Whether these points were used primarily for hunting or cutting has been pondered for some time. Bement et al . ( 2005 ) documented a Bison occidentalis skull that , through magnetic resonance imaging , was shown to have a basally notched point embedded in it. This corroborated the use of the form, at least partly, as a hunting implement.

The Middle Archaic Period is considered to be from about 5,000 to 2,500 B.P. Triangular dart points, such as the Tortugas and Abasolo are most common throughout this period. Studies of impact trauma to triangular point tips confirm that at least in some part these were used as projectiles (Bettis 1997). Other tools found in association with triangular points ofthis period include beveled varieties that may have been used for wood-working tasks (Hester 1973). The production of formally modified flakes (dorsally

flaked/beveled), like the Nueces tool (Hester et al. 1969), show evidence of extensive re-sharpening (i.e., curated) oftool forms. Middle Archaic open camp sites have been found along stream channels but are also known to have existed on floodplains and natural levees (Hester 2004:139).

The Late Archaic Period has been defined in south Texas to range from 2,500 to 1,500 B.P. The precise

timing of this division is not well established since so few threshold sites have been excavated and radiocarbon dates from good context are infrequent. Excavated components in the Late Archaic, however, are much more numerous than their earlier predecessors. Point types are generally of the stemmed variety (e.g., Marcos, Shumla, Ensor, and Montell points). The Choke Canyon investigations yielded 44 sites that exhibited artifacts ofLate Archie association. Many of these sites had fire cracked rock features (earth ovens and hearths). Interestingly, grinding implements were recovered in this area, which give some insight into intensification of plant resources such as mesquite beans and various types of grain (Brown et al. 1982). Preservation offaunal remains also indicate an intensification of small and large mammals. It is not uncommon for Late Archaic period camp sites to be situated along stream channels.



At the end of the Late Archaic, stemmed point varieties also are observed at sites that represent a different artifact sequence, termed Late Prehistoric. In many cases, this late portion ofthe Late Archaic is termed the Terminal Archaic. This timeframe reflects a change or innovation in technological prowess from spear-based dart use (which is hand or atlatl propelled) to bow and arrow powered projectiles.

3.11.4 Late Prehistoric (1,500-500 B.P.)

This covers a period from about 1,500 B.P. to about 500 B.P. when the European exploration and

settlement began to occur in the region. The Late Prehistoric period is marked by the introduction ofthe bow and arrow as the principal weaponry system and the beginning of pottery making. Agriculture is also considered a major innovation during this period. It is not clear as to when these varied innovations came to the Harlingen-Brownsville area, and they probably did not all happen simultaneously. it is assumed that these technological innovations had profound effects on the regional populations.

Most researchers divide the Late Prehistoric period into early (1,500 to 1,000 B.P.) and late (1,000 to 500 B.P.). For the early Late Prehistoric sub-period in the southern region of Texas, there seems to be an overlap of dart-using (e.g., Ensor, Catan, Zavala point using peoples). The exact circumstances under which they are present at later sites are unknown, but possibilities include, recycling and/or co-mingling of technologies (Creel et al. 1979). Some ofthe earliest evidence of bow and arrow technology may be the occurrence of Edwards and Scallorn points across multiple regions of Texas. Perdiz points also occur in this period. Exactly how these groups manifested or interacted is uncertain. Several broad cultural complexes have been identified including the Kawakawa (coastal bands) and Coahuiltecan (inland groups) (Ricklis 1996). These cultural groups were lumped together in what was referred to as the

Western Gul f culture area (Newcomb 1961). A third group, the Toyah culture (typically thought to be primarily bison hunters), also seems ever-present across central Coastal and South Texas (Ricklis 2004).

One of the primary indicators of Late Prehistoric period peoples is the introduction and use of pottery. Bone (Leon Plain) and shell tempered specimens are prevalent in occupations throughout South Texas in this period. The increased use of pottery suggests a more sedentary existence that involves less frequent

travel and focus on more intensive subsistence activities, such as horticulture. Prominent archeological sites ofthis period include Loma Sandia, Tortuga Flat (41ZV155), and Falcon Reservoir Project (Hester 2004).

3.11.5 Protohistoric Period (500-200 B.p.) and Historic Period (200-50 B.P.)

Excavated archeological data is also scarce for these two periods, beginning with the arrival of the first Europeans exploring the broad unknown territories. This generally reflects a period from about 450 B.P. to the present. Identified cultural resource sites in the region have not been assigned to any specific native groups and the cultural material left behind may not be characteristic enough to actually assign a cultural assemblage to a named group. Again, the lack of major excavations has limited the data necessary to



address which groups were using this region at the time of European settlement. Various authors have researched and discussed the various groups that might have occupied the land across South Texas (Ruecking 1955; Campbell and Campbell 1981; Campbell 1983,1991; Salinas 1990).

The discussion below is taken and/or paraphrased from the county history discussions regarding Webb County posted on Handbook of Texas Online (TSHA 2019, Leffler and Long 2019). When possible, additional information has been added to highlight various important historical aspects relevant to these projects.

European exploration of Webb County occurred in the late 17th century when Alonso De Leon crossed the northwestern corner ofthe county. Subsequent exploration was undertaken along the Rio Grande in 1747 by Miguel de la Garza to determine the best location for the Presidio de Santa Rosa Maria del Sacramento. During this same time a substantial trail was established to facilitate travel and trade by Spanish settlers to the area. By 1755, Tomas del la Barrerra y Garza built a settlement near the Paso de Jacinto ford which came to be known as Laredo. Subsequent to the creation of a local government and the issuance of land grants to Spanish settlers, Laredo grew rapidly between the 1790s and the early 19til century.

Spanish settlers primarily engaged in ranching, which was a major part of the economy. Livestock raised in the area could be traded for food and other goods coming in from the south. The exportation of wool brought in a substantial amount of wealth to the area. The rapid expansion ofthe ranching economy and the prospect of operating a lucrative ranching operation encouraged population growth to the area in the early 19th century. The rapid growth also had negative consequences as Spanish settlers began to encroach on Comanche and Lipan Apache controlled lands to the north. The early decades of Spanish settlement saw a number of Indian attacks on outlying ranches and became an increasing problem after the Mexican War for Independence and during the Texas Revolution in the 1 830s as military resources were diverted

by the Mexican government to engage in these conflicts.

In the 1 830s and 1 840s Laredo and the surrounding area was part of the conflict over the Nueces Strip located between the Rio Grande and Nueces River. Over these years, forces from the Republic of Mexico and incoming Texan settlers engaged in raids and small-scale battles. By 1842, Alexander Somervell captured and plundered Laredo, and by 1846 United States military forces captured the town during the Mexican War. Webb County was officially established by the Texas legislature in 1848 and incorporated into the United States in May of that year.

During the Civil War, a substantial number of men from Webb County joined the Confederacy. A regiment of Confederate cavalry was instrumental in protecting shipments of goods traveling to and from Mexico. The necessity for livestock during the Civil War bolstered the ranching economy ofthe area. Trade in livestock was improved further by the arrival ofthe Corpus Christi and Rio Grande and the International-Great Northern railroads that passed through Laredo. Not only did the lines allow ranchers


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