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7 Attachment A Figures

8 Sheet 1 Sheet 2 Sheet 3 Sheet 4 Sheet 5 K:\San Diego\projects\Iberdrola\00567_15_TuleWind\analyses\ _Variance_20ftIFC_Buffer\Fig01_Tule_VAR006_Rocks_OV.mxd; User: 35528; Date: 3/24/2017 Laydown Yard ac Sheet 9 Sheet 6 Sheet 8 Sheet 7 BLM Land Rocks Mile Figure 1 BLM VAR-006 R-1 Rocks

9 Road G Road B A-3 Road A A-2 1 A-1 McCain Valley Road K:\San Diego\projects\Iberdrola\00567_15_TuleWind\analyses\ _Variance_20ftIFC_Buffer\Fig02_Tule_VAR006_RocksDetail.mxd; User: 35528; Date: 3/24/ BLM Parcels Study Area Rocks Feet Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure C-4 Figure 2 Sheet 1 BLM VAR-006 R-1 Rocks

10 Road G C-4 C McCain Valley Road C-1 Road H C-2 Road F Road E C-3 B-1 3 Road C 2 1 Road D B B-3 Trail Re-Route 4 5 K:\San Diego\projects\Iberdrola\00567_15_TuleWind\analyses\ _Variance_20ftIFC_Buffer\Fig02_Tule_VAR006_RocksDetail.mxd; User: 35528; Date: 3/24/2017 BLM Parcels Study Area Rocks Feet B-4 Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Figure 2 Sheet 2 BLM VAR-006 R-1 Rocks

11 C Road H Road I C-8 C D-1 7 McCain Valley Road 8 Road J Road K E E Road O K:\San Diego\projects\Iberdrola\00567_15_TuleWind\analyses\ _Variance_20ftIFC_Buffer\Fig02_Tule_VAR006_RocksDetail.mxd; User: 35528; Date: 3/24/2017 BLM Parcels Study Area Rocks Feet Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure E-3 Figure 2 Sheet 3 BLM VAR-006 R-1 Rocks

12 Road L D-3 D-4 Road O E E McCain Valley Road Road T E-6 E Road NRoad S Road R E-8 27 E E F-1 Road M K:\San Diego\projects\Iberdrola\00567_15_TuleWind\analyses\ _Variance_20ftIFC_Buffer\Fig02_Tule_VAR006_RocksDetail.mxd; User: 35528; Date: 3/24/2017 F Road Q F-3 F-4 BLM Parcels Study Area Rocks Feet Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Figure 2 Sheet 4 BLM VAR-006 R-1 Rocks

13 30 31 Road W E Road V E McCain Valley Road K:\San Diego\projects\Iberdrola\00567_15_TuleWind\analyses\ _Variance_20ftIFC_Buffer\Fig02_Tule_VAR006_RocksDetail.mxd; User: 35528; Date: 3/24/2017 G-1 G-2 G-3 Road X 10 G G-5 Road Y BLM Parcels Study Area Rocks Feet Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Figure 2 Sheet 5 BLM VAR-006 R-1 Rocks

14 G-6 53 H-1 54 G H-2 Road AA McCain Valley Road 56 G G G-10 Road Y Road Z G G K:\San Diego\projects\Iberdrola\00567_15_TuleWind\analyses\ _Variance_20ftIFC_Buffer\Fig02_Tule_VAR006_RocksDetail.mxd; User: 35528; Date: 3/24/ G-13 G-14 G-15 Road AD Substation O&M Building Construction Office Batch Plant BLM Parcels Study Area Rocks Feet Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Figure 2 Sheet 6 BLM VAR-006 R-1 Rocks

15 13 J-2 Road AC J-3 Road AB Substation Sub Bay O&M Building Construction Office Batch Plant Wash Area 2 Parking McCain Valley Road 5 K:\San Diego\projects\Iberdrola\00567_15_TuleWind\analyses\ _Variance_20ftIFC_Buffer\Fig02_Tule_VAR006_RocksDetail.mxd; User: 35528; Date: 3/24/ BLM Parcels Study Area Rocks Feet Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Figure 2 Sheet 7 BLM VAR-006 R-1 Rocks

16 McCain Valley Road K:\San Diego\projects\Iberdrola\00567_15_TuleWind\analyses\ _Variance_20ftIFC_Buffer\Fig02_Tule_VAR006_RocksDetail.mxd; User: 35528; Date: 3/24/ BLM Parcels Study Area Rocks Feet Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Figure 2 Sheet 8 BLM VAR-006 R-1 Rocks

17 Laydown Yard acres K:\San Diego\projects\Iberdrola\00567_15_TuleWind\analyses\ _Variance_20ftIFC_Buffer\Fig02_Tule_VAR006_RocksDetail.mxd; User: 35528; Date: 3/24/2017 BLM Parcels Study Area Rocks Feet Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Figure 2 Sheet 9 BLM VAR-006 R-1 Rocks

18 K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig03_Tule_VAR006_Rocks_Diagram.mxd; User: 35528; Date: 3/24/ Mile Figure 3 BLM VAR-006 R-1 Rocks

19 Sheet 1 Sheet 2 Sheet 3 Sheet 4 Sheet 5 K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig04_Tule_VAR006_SteepSlopes_OV.mxd; User: 35528; Date: 3/24/2017 Laydown Yard ac Sheet 9 Sheet 6 Sheet 8 Sheet 7 BLM Land Steep Slopes Mile Figure 4 BLM VAR-006 R-1 Steep Slopes

20 Road G Road B A-3 Road A A-2 1 A-1 McCain Valley Road K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig05_Tule_VAR006_SteepSlopesDetail.mxd; User: 35528; Date: 3/24/ BLM Parcels Study Area Steep Slopes Feet Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure C-4 Figure 5 Sheet 1 BLM VAR-006 R-1 Steep Slopes

21 Road G C-4 C McCain Valley Road C-1 Road H C-2 Road F Road E C-3 B-1 3 Road C 2 1 Road D B B-3 Trail Re-Route 4 5 K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig05_Tule_VAR006_SteepSlopesDetail.mxd; User: 35528; Date: 3/24/2017 BLM Parcels Study Area Steep Slopes Feet B-4 Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Figure 5 Sheet 2 BLM VAR-006 R-1 Steep Slopes

22 C Road H Road I C-8 C D-1 7 McCain Valley Road 8 Road J Road K E E Road O E-3 K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig05_Tule_VAR006_SteepSlopesDetail.mxd; User: 35528; Date: 3/24/2017 BLM Parcels Study Area Steep Slopes Feet Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Figure 5 Sheet 3 BLM VAR-006 R-1 Steep Slopes

23 Road L D-3 D-4 Road O E E McCain Valley Road Road T E-6 E Road NRoad S Road R E-8 27 E E F-1 Road M K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig05_Tule_VAR006_SteepSlopesDetail.mxd; User: 35528; Date: 3/24/2017 F Road Q F-3 F-4 BLM Parcels Study Area Steep Slopes Feet Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Figure 5 Sheet 4 BLM VAR-006 R-1 Steep Slopes

24 30 31 Road W E Road V E McCain Valley Road K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig05_Tule_VAR006_SteepSlopesDetail.mxd; User: 35528; Date: 3/24/2017 G-1 G-2 G-3 Road X 10 G G-5 Road Y BLM Parcels Study Area Steep Slopes Feet Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Figure 5 Sheet 5 BLM VAR-006 R-1 Steep Slopes

25 G-6 53 H-1 54 G H-2 Road AA McCain Valley Road 56 G G G-10 Road Y Road Z G G K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig05_Tule_VAR006_SteepSlopesDetail.mxd; User: 35528; Date: 3/24/ G-13 G-14 G-15 Road AD Substation O&M Building Construction Office Batch Plant BLM Parcels Study Area Steep Slopes Feet Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Figure 5 Sheet 6 BLM VAR-006 R-1 Steep Slopes

26 13 J-2 Road AC J-3 Road AB Substation Sub Bay O&M Building Construction Office Batch Plant Wash Area 2 Parking McCain Valley Road 5 K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig05_Tule_VAR006_SteepSlopesDetail.mxd; User: 35528; Date: 3/24/ BLM Parcels Study Area Steep Slopes Feet Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Figure 5 Sheet 7 BLM VAR-006 R-1 Steep Slopes

27 McCain Valley Road K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig05_Tule_VAR006_SteepSlopesDetail.mxd; User: 35528; Date: 3/24/ BLM Parcels Study Area Steep Slopes Feet Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Figure 5 Sheet 8 BLM VAR-006 R-1 Steep Slopes

28 Laydown Yard acres K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig05_Tule_VAR006_SteepSlopesDetail.mxd; User: 35528; Date: 3/24/2017 BLM Parcels Study Area Steep Slopes Feet Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Figure 5 Sheet 9 BLM VAR-006 R-1 Steep Slopes

29 Sheet 1 K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig06_Tule_VAR006_Stockpiles_OV.mxd; User: 35528; Date: 3/24/2017 Laydown Yard ac Sheet 2 Sheet 4 Sheet 3 BLM Land Stockpiles Mile Figure 6 BLM VAR-006 R-1 Stockpiles

30 30 31 Road W E Road V E McCain Valley Road K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig07_Tule_VAR006_StockpilesDetail.mxd; User: 35528; Date: 3/24/2017 G-1 G-2 G-3 Road X 10 G G-5 Road Y BLM Parcels Study Area Stockpiles Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Feet Figure 7 Sheet 1 BLM VAR-006 R-1 Stockpiles 4

31 G-6 53 H-1 54 G H-2 Road AA McCain Valley Road 56 G G G-10 Road Y Road Z G G K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig07_Tule_VAR006_StockpilesDetail.mxd; User: 35528; Date: 3/24/ G-13 G-14 G-15 Road AD Substation O&M Building Construction Office Batch Plant BLM Parcels Study Area Stockpiles Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Feet Figure 7 Sheet 2 BLM VAR-006 R-1 Stockpiles 4

32 13 J-2 Road AC J-3 Road AB Substation Sub Bay O&M Building Construction Office Batch Plant Wash Area 2 Parking McCain Valley Road 5 K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig07_Tule_VAR006_StockpilesDetail.mxd; User: 35528; Date: 3/24/ BLM Parcels Study Area Stockpiles Feet Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Figure 7 Sheet 3 BLM VAR-006 R-1 Stockpiles

33 McCain Valley Road K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig07_Tule_VAR006_StockpilesDetail.mxd; User: 35528; Date: 3/24/ BLM Parcels Study Area Stockpiles Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Feet Figure 7 Sheet 4 BLM VAR-006 R-1 Stockpiles 4

34 Sheet 1 Sheet 2 Sheet 3 Sheet 4 K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig08_Tule_VAR006_RiprapOutfalls_OV.mxd; User: 35528; Date: 3/24/2017 BLM Land Riprap Outfalls Laydown Yard ac Sheet Mile Figure 8 BLM VAR-006 R-1 Riprap Outfalls

35 Road G C-4 C McCain Valley Road C-1 Road H C-2 Road F Road E C-3 B-1 3 Road C 2 1 Road D B B-3 Trail Re-Route 4 5 K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig09_Tule_VAR006_RiprapOutfallsDetail.mxd; User: 35528; Date: 3/24/ B BLM Parcels Study Area Riprap Outfalls Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Feet Figure 9 BLM VAR-006 R-1 Riprap Outfalls

36 C Road H Road I C-8 C D-1 7 McCain Valley Road 8 Road J Road K E E Road O E-3 K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig09_Tule_VAR006_RiprapOutfallsDetail.mxd; User: 35528; Date: 3/24/ BLM Parcels Study Area Riprap Outfalls Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Feet Figure 9 BLM VAR-006 R-1 Riprap Outfalls

37 Road L D-3 D-4 Road O E E McCain Valley Road Road T E-6 E Road NRoad S Road R E-8 27 E E F-1 Road M K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig09_Tule_VAR006_RiprapOutfallsDetail.mxd; User: 35528; Date: 3/24/2017 F Road Q F-3 F BLM Parcels Study Area Riprap Outfalls Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Feet Figure 9 BLM VAR-006 R-1 Riprap Outfalls

38 30 31 Road W E Road V E K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig09_Tule_VAR006_RiprapOutfallsDetail.mxd; User: 35528; Date: 3/24/2017 G-1 G-2 G-3 Road X 10 G G-5 Road Y McCain Valley Road BLM Parcels Study Area Riprap Outfalls Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Feet Figure 9 Sheet 1 BLM VAR-006 R-1 Riprap Outfalls

39 13 J-2 Road AC J-3 Road AB Substation Sub Bay O&M Building Construction Office Batch Plant Wash Area 2 Parking McCain Valley Road 5 K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig09_Tule_VAR006_RiprapOutfallsDetail.mxd; User: 35528; Date: 3/24/ BLM Parcels Study Area Riprap Outfalls Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Feet Figure 9 Sheet 3 BLM VAR-006 R-1 Riprap Outfalls

40 Sheet 1 Sheet 2 Sheet 3 Sheet 4 K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig10_Tule_VAR006_Gaps_OV.mxd; User: 35528; Date: 3/24/2017 BLM Land Gaps between Roads and Overhead Lines Laydown Yard ac Sheet Mile Figure 10 BLM VAR-006 R-1 Gaps between Roads and Overhead Lines

41 Road G C-4 C McCain Valley Road C-1 Road H C-2 Road F Road E C-3 B-1 3 Road C 2 1 Road D B B-3 Trail Re-Route 4 5 K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig11_Tule_VAR006_GapsDetail.mxd; User: 35528; Date: 3/24/2017 BLM Parcels Study Area Gaps between Roads and Overhead Lines B-4 Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Feet Figure 11 Sheet 1 BLM VAR-006 R-1 Gaps between Roads and Overhead Lines

42 C Road H Road I C-8 C D-1 7 McCain Valley Road 8 Road J Road K E E Road O E-3 K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig11_Tule_VAR006_GapsDetail.mxd; User: 35528; Date: 3/24/2017 BLM Parcels Study Area Gaps between Roads and Overhead Lines Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Feet Figure 11 Sheet 2 BLM VAR-006 R-1 Gaps between Roads and Overhead Lines

43 Road L D-3 D-4 Road O 17 E E McCain Valley Road Road T E-6 E Road NRoad S Road R E-8 27 E E F-1 Road M K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig11_Tule_VAR006_GapsDetail.mxd; User: 35528; Date: 3/24/2017 F F-3 Road Q F-4 BLM Parcels Study Area Gaps between Roads and Overhead Lines Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Feet Figure 11 Sheet 3 BLM VAR-006 R-1 Gaps between Roads and Overhead Lines

44 30 31 Road W E-12 8 Road V 32 E McCain Valley Road K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig11_Tule_VAR006_GapsDetail.mxd; User: 35528; Date: 3/24/2017 G-1 G-2 G-3 Road X 10 G G-5 Road Y BLM Parcels Study Area Gaps between Roads and Overhead Lines Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Feet Figure 11 Sheet 4 BLM VAR-006 R-1 Gaps between Roads and Overhead Lines

45 G H-1 G H-2 Road AA McCain Valley Road 56 G G G-10 Road Y Road Z G G K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig11_Tule_VAR006_GapsDetail.mxd; User: 35528; Date: 3/24/ G-13 G-14 G-15 Road AD Substation O&M Building Construction Office Batch Plant BLM Parcels Study Area Gaps between Roads and Overhead Lines Access Roads!> Turbines Staging Area Project Collector System!( Collection Structure Overhead Transmission Alignment Transmission Structure Feet Figure 11 Sheet 5 BLM VAR-006 R-1 Gaps between Roads and Overhead Lines

46 McCain Valley Road K:\San Diego\projects\Iberdrola\00567_15_TuleWind\mapdoc\Variances\A_VAR_001\Fig12_Tule_VAR006_ESA_Avoidance.mxd; User: 35528; Date: 3/24/2017 BLM Parcels Study Area ESA Potential ESA Avoidance Impact Access Roads Overhead Transmission Alignment Transmission Structure Feet Figure 12 BLM VAR-006 R-1 ESA Avoidance

47 Attachment B Foreseen and Unforeseen Impacts Processes

48 Impacts Beyond Existing Disturbance Limits Foreseen Issue Foreman looks for high risk compliance areas. Yes Foreman or Superintendent identifies high risk compliance area (rocks, topsoil salvage, odd shaped limits of disturbance [LOD], etc.). Superintendent verifies the location in the field Considers if it can reasonably and safely done differently to remain within the LOD. Confirms there are no known ESAs in the area. No Construction proceeds within LOD. The proposed activity is unsafe, impacts an ESA, or can reasonably be done within the LOD. Form is not submitted. The proposed activity is safe, outside of known ESAs, and cannot reasonably be done within the LOD End of Variance Process Construction will stay within LOD. Superintendent signs the Foreseen Additional Impacts Signoff Form Dudek reviews the form with the Foreman and/or Superintendent in the field. Activity is approved Day of - Prior to the Start of Work: Area is swept by Environmental Monitors (Native American, cultural, and biological monitors). ESAs, if present, are confirmed and signage updated as needed. Additional Areas Impacts Signoff Form is signed by all 3 monitors and Dudek. If work extends beyond a single day, the areas will be reswept for biological resources prior to starting work. Day of - During Work: Full time cultural and biological monitoring is required, unless otherwise determined in coordination with Dudek/BLM. If the activity involves rock placement, a Restoration Specialist (RS) will be consulted if possible to provide guidance on rock placement. Post Impact: Contractor or Environmental Monitors map the area outside the LOD using a tape measure or GPS unit with submeter accuracy (as appropriate for the size of the additional impact). Impact is logged in the Additional Impacts Spreadsheet. Acreage is calculated and added to the additional impact acres spreadsheet log. The Additional Impacts Spreadsheet will be provided to Dudek/BLM every-other-week, and an update will be provided weekly during our call.

49 Impacts Beyond Existing Disturbance Limits Unforeseen Issue Additional impact occurs outside the LOD. On-site monitors (biological, cultural, and Native American) observe the impact. If biological monitor is not onsite, the Biological Lead is notified by the contractor. Area is surveyed by biological, cultural, and Native American monitors to determine if resources were impacted. Resources were impacted. Dudek is notified. No damage to resources occurred. Biology Cultural Impact is evaluated and the appropriate Agency (CDFW, FWS, etc. is notified within 24 hours). Documentation is completed as required by the appropriate Agency. Impact is documented and ESA fencing is fixed and/or established. County and/or BLM are notified immediately and a report is prepared documented the impact. If further analysis is required a testing plan will be prepared and implemented in consultation with the appropriate Agencies. If impact is to a significant resource additional mitigation may be required. Post Impact: Contractor identifies the issue that caused the exceedance of the LOD. Contractor or Environmental Monitors map the area outside the LOD using a tape measure or GPS unit with submeter accuracy (as appropriate for the size of the additional impact). Dudek and the BLM determine if the incident is a Problem Area, Noncompliance or Serious Violation If the impact is determined to be a Problem Area, it is logged in the additional impacts spreadsheet noting the cause and any corrective actions taken. Acreage is calculated and added to the additional impact acres spreadsheet log. The Additional Impact Acres spreadsheet will be provided to Dudek/BLM every-other-week, and an update will be provided weekly during our call.

50 Attachment C Additional Foreseen Impacts Sign-off Form

51 ADDITIONAL FORESEEN IMPACT AREAS SIGN-OFF FORM Date: Foreman: Location Superintendent: Superintendent Signature: Phone #: Description of Foreseeable Additional Impacts Construction Activity Print Monitor Name Monitor Signature Type Time Monitoring Requirement Dudek Approval [Ex: Rock needs to be relocated from the LOD boundary. Relocation would cause impacts beyond the LOD, including rock placement outside the LOD.] [Ex: Rock relocation using D-8 dozer.] Arch Tribal Sweep Conducted Full Time Monitor Spot Check Monitor No Monitor Required Sweep Conducted Full Time Monitor Spot Check Monitor No Monitor Required Dudek Compliance Monitor Name: Dudek Compliance Monitor Signature: Bio/Env Sweep Conducted Full Time Monitor Spot Check Monitor No Monitor Required Date: Arch Sweep Conducted Full Time Monitor Spot Check Monitor No Monitor Required Dudek Compliance Monitor Name: Tribal Sweep Conducted Full Time Monitor Spot Check Monitor No Monitor Required Dudek Compliance Monitor Signature: Bio/Env Sweep Conducted Full Time Monitor Spot Check Monitor No Monitor Required Date:

52 Attachment D Additional Impacts Spreadsheet

53 Date Spreadsheet sent Total Acres Impacted at to Dudek time of Submittal 3/20/ Total Impacts Remaining Impact Per VAR

54 Unforeseen Impact Tracker Total Square Feet Impacted : Total Acres Impacted: Date Location Monitors Present Description of Incident Contractor Notified by Dudek Personnel Notified 3/13/2017 North of turbine G8 Archaeological and Native American. Area had been swept by a biological monitor. A blade hit a rock below the ground surface during grading activities along the access road north of turbine pad G 8. When the blade hit the rock, it lost balance and travelled outside of the approved limits of disturbance while trying to regain balance. An approximately 40 foot by 10 foot area was disturbed outside of the approved limits of disturbance. Per conversations with the equipment operator, if he had not travelled outside of the approved limits of disturbance to regain balance the blade could have tipped over. Blattner Blattner Foreman, Joseph "Sparky" Rossetti Compliance Monitor PK Sharp Garcia Total area of disturbance (square feet) Resources Impacted Resolved (Y/N) Follow Up Actions 400 No Y Operator was reminded to identify hazard areas prior to commecing work for the day and discuss those areas with the foreman Non Compliance Category Date Report Received from Dudek Problem Area 3/15/2017 3/13/2017 East side of G6 Archaeological and Native American. Area had been swept by a biological monitor. A D8 bulldozer slipped down the east side of the slope at turbine pad G6. The bulldozer did not cross the limits of disturbance, but dirt extending out in two areas (measuring approximately 2 ft x 20 ft and 3 ft x 22 ft) was pushed outside of the limits of disturbance. The dirt that was pushed outside of the limits of disturbance was inspected for sensitive resources and none were identified. The dirt was left in place. Blattner ASM Lead Archeological Monitor, Michelle Dalope Compliance Monitor PK Sharp Garcia 106 No Y Operator was reminded to identify hazard areas prior to commecing work for the day and discuss those areas with the foreman Problem Area 3/15/2017

55 Foreseen Impact Tracker Total Square Feet Impacted : Total Acres Impacted: Date Requested 0 0 Date Approved Location Description of Work Description of Impacts Contractor Person Requesting Additional Area List Surveys Completed Prior to Impact Monitor Signoff Sheet Completed Prior to Work (Y/N) Authorizing Dudek Personnel Total Area of Disturbance (square feet) Resources Impacted Notes

56 U.S. Department of the Interior Bureau of Land Management Determination of NEPA Adequacy (DNA) DOI-BLM- CA- D DNA - Variance Request 006 PREPARING OFFICE U.S. Department of the Interior Bureau of Land Management El Centro Field Office, California

57 Determination of NEPA Adequacy (DNA) DOI-BLM- CA-D xx-DNA - Variance Request 006

58 Table of Contents 1. Determination of NEPA Adequacy (DNA)... 1 Worksheet...1 Description of Proposed Action and any applicable mitigation measures...1 Identify applicable National Environmental Policy Act (NEPA) documents and other related documents that cover the proposed action....4 NEPA Adequacy Criteria...7 Persons/Agencies/BLM Staff Consulted...8 Conclusion...9

59 1 1. Determination of NEPA Adequacy (DNA) Worksheet U.S. Department of the Interior Bureau of Land Management OFFICE: El Centro Field Office, 1661 S. 4 th Street, El Centro, California TRACKING NUMBER: DOI-BLM- CA- D DNA CASE FILE/PROJECT NUMBER: CACA PROPOSED ACTION TITLE/TYPE: Changes to the Variance Request and Approval Process under the Project s Environmental Compliance and Mitigation Plan (ECMP) LOCATION/LEGAL DESCRIPTION: The Tule Wind project is located on 12,360 acres of land administered by the BLM near the town of Boulevard in San Diego County, California. The proposed project-related activities are located within the Tule Wind project right-of-way (ROW) grant boundary, but outside of the limits of disturbance identified in the approved Plan of Development (POD). APPLICANT: Tule Wind LLC Description of Proposed Action and any applicable mitigation measures Tule Wind LLC submitted Variance Request R1 (herein referred to as VR-006) to the BLM on March 24, 2017 in accordance with the protocols set forth in the s Environmental Compliance and Mitigation Plan (ECMP). In summary, VR-006 requests to further refine the Variance Request and Approval process in the ECMP. In accordance with the POD approved for the Tule Wind project, construction activities will be conducted within the approved engineering limits of disturbance and within areas covered by previous focused surveys for biological and cultural resources. As part of the project s final engineering for constructability and overall safety, Tule Wind LLC has identified several known project-related activities that have the potential to exceed limits of disturbance identified in the POD (see VR-006 and itemized list below for further explanation). In foresight of this, Tule Wind LLC has conducted supplemental focused biological, hydrological, and cultural resources surveys, extending 20 feet beyond the project s entire limits of disturbance identified in the POD (see VR-006). Tule Wind LLC is requesting an amendment to the ECMP to allow the Tule Wind LLC and BLM field team leadership (i.e. the Tule Wind LLC construction foreman and on-site compliance leads, Tule Wind LLC lead biologist and archaeologist, and BLM Environmental Compliance Lead) to approve, on a caseby-case basis, specific project-related activities (described below and in VR-006) via a Level 1 Variance Request process within a 20-foot-buffer outside the limits of disturbance in the POD. In the event that

60 2 one of the known project-related activities described below needs to deviate outside the limits of disturbance, a process for approval (identified in VR-006) would be implemented. In summary, the field team leadership would 1) identify the proposed activity needing to occur outside the limits of disturbance, but within the 20-foot survey limit, 2) review the area for biological, cultural, and other natural resources per existing survey data, 3) determine whether or not the activity was within or exceeded disturbance thresholds under VR-006 (see next paragraph below); 4) prepare the Additional Foreseen Impacts Signoff Form (identified in VR-006, Attachment C), and 5) determine based on the aforementioned factors whether or not to approve the disturbance. Prior to work occurring under an approved Variance Request, all necessary pre-construction sweeps for biological and cultural resources would occur in accordance with mitigation measures and all fencing and flagging delineating Environmentally Sensitive Areas (ESA) would be installed to ensure full avoidance of resources. Tule Wind LLC field teams would delineate areas approved for work under, and would monitor activities in accordance with, the ECMP and mitigation measures. Additionally, Tule Wind LLC would track disturbances approved under this specific Variance Request process and submit to the BLM throughout project construction, per documentation methods identified in VR-006 (see Attachment D). Tule Wind LLC anticipates up to 10 acres would be allowed to be permanently disturbed as part of this Variance Request process. In areas where temporary impacts occur, those impacts will be restored consistent with the Habitat Restoration Plan (HRP). The following known project-related activities would be covered (allowed for consideration) under the proposed Variance Request process: 1. Rocks: An inventory has been completed and over 3,000 rocks over five feet in diameter have been identified within the approved disturbance limits. The rocks that were completely within the limits of disturbance and were small enough to haul away have been removed. Many of the remaining rocks rest at the edge of the disturbance limits with part of the rock inside the limits of disturbance and part outside the limits of disturbance. The intent is to use the foreseen impacts process to allow rocks to be placed either permanently or temporarily beyond the limits of disturbance to allow for the grading / construction to occur. Figures showing the Project Alignment and the diagram showing how rocks will be moved during rock placement are included in VR-006, Attachment A, Figures 1-3. This activity is the only activity included in the variance that could result in permanent impacts. Within the 10 acres included in the variance, up to seven acres would be permanent for rock placement. 2. Steep Slopes: The project is located on terrain that generally rises from south to north. While the northern third of the site has a fairly steady gentle slope, the southern and central portions contain many undulating and abrupt hills and drops. When grading through these steeper sections, it can be difficult to tie the proposed slopes to the existing ground. In order to blend the proposed grade to the existing terrain, it may be advantageous to track beyond the limits of disturbance. In addition, tracking beyond the limits may be the only way to safely navigate the boundary between existing and proposed slopes in order to effectively tie them together. The areas of 20% slope and greater have been identified as areas where this construction method may be required (see VR-006, Attachment A, Figures 4 and 5). 3. Stockpiles: Topsoil stockpiles have been created throughout the site in accordance with the project HRP. According to the HRP, stockpile (e.g., backfill and topsoil stockpile) areas will be located within

61 3 disturbance limits. Topsoil stockpiles will be located along or near the perimeter of the disturbance limits. With this in mind, stockpiled topsoil will be situated in a manner where construction equipment can easily access the material and effectively distribute it once the project design feature installation phase is complete. The windrows have been placed at the perimeter of the disturbance limits to protect the topsoil from contamination with the underling DG soils during grading. When mass grading is complete, these piles will be reclaimed and spread over the adjacent soils. In order to maximize the work area, these piles were often placed at the edge of clearance limits, in accordance with the HRP (see VR-006, Attachment A, Figures 6 and 7). The work to reclaim these piles poses a higher risk of encroachment beyond the current limits of disturbance due to the proximity of the pile to the boundary and the equipment needed to pull the soils back. 4. Riprap Outfalls: This refers to the locations where proposed ditches are designed to discharge along McCain Valley Road or the private turbine access roads (see VR-006, Attachment A, Figures 8 and 9). The design outfall is a section of riprap intended to slow the runoff and remove energy and sediment before discharge off site. These areas are a natural risk as sediment or blowouts will naturally migrate downstream directly toward the project limits of disturbance. Many of these areas are in the steep slopes noted above and the foreseen impacts process will allow the contractor space to better construct / fit the outfall with the natural terrain to minimize the risk of blowouts or sediment runoff. 5. Gaps between Roads and Overhead Lines: Portions of the overhead collection or overhead transmission line parallels McCain Valley Road. The designs for the road and the electrical system were completed independently and then merged into the overall project disturbance resulting in a number of locations where a sliver or wedge of undisturbed area is left between two limits of disturbance boundaries (creating a donut hole). This has been a source of confusion; stakes are often close together and visually confusing in the field, thus making it difficult to discern the donut hole sliver which is outside the limits of disturbance (see VR-006, Attachment A, Figures 10 and 11). 6. Limits of Disturbance on the Opposite Side of the Road from an ESA: Where ESAs are immediately adjacent to a temporary road, there is potential for vehicles to accidentally travel outside of the limits of disturbance on the opposite side of the road while trying to avoid impacts to the ESA. The foreseen impacts process will allow the contractor to continue to remain cautious around ESAs and remain in compliance while maintaining site access (see VR-006, Attachment A, Figure 12). VR-006 is predominantly within previously surveyed areas for biological and archaeological resources as part of the EIR/EIS process and as part of developing the final project footprint delineated in the 2016 POD for construction. Approximately one acre of the proposed 20-foot buffer extends beyond the areas previously surveyed for biological and archaeological resources. Supplemental biological and archaeological memoranda have been prepared and submitted as part of this variance to survey portions of the 20-foot buffer outward of the approved limits of disturbance. The activities associated with each proposed action component would be performed at the same time as the construction and conducted in accordance with the same impact avoidance, minimization, monitoring, and mitigation measures that apply to the project impact areas. Such measures

62 4 include those specified in the Project s ECMP, BLM s ROD, the Project s ROW grant, and approved plans and permits for specific activities related to the construction of the Project. Consequently, the potential impacts associated with the modified disturbance footprint have been addressed and analyzed in the Final EIS/EIR and have been mitigated through measures identified in the Final EIS/EIR and adopted by the ROD. Land Use Plan (LUP) Conformance LUP Name Date Approved: Record of Decision, Implementation of a Wind Energy Development December 15, 2005 Program and Associated Land Use Plan Amendments Eastern San Diego County Resource Management Plan April 13, 2008 and Record of Decision The proposed action is in conformance with the LUP because it is clearly consistent with the following LUP decisions (objectives, terms, and conditions) and, if applicable, implementation plan decisions: The 2008 Eastern San Diego County Regional Management Plan (RMP) designated select lands within the planning area as available for geothermal leasing and wind energy development. Public lands within the 1 McCain Valley area were made available for both geothermal leasing and wind energy development. The was determined to be consistent with land use plans in the 2011 ROD (Section 3.3, Land Use Plan Conformance) for the project. Development of the Proposed Action is consistent with BLM s land use designation for wind energy development, because the Proposed Action (changes to Variance Request processes in the ECMP) includes components that part of the overall wind project, and the wind project ROW remains within the area designated as available for wind energy development (McCain Valley East) 2. Also, consistent with management actions identified in Section , Renewable Energy, of the 2008 RMP, the Proposed Action would provide for the production and distribution of renewable energy (Renewable Energy (RNE)-08), would not be sited within a special designation (wilderness area, wilderness study area) 3 (RNE-03 and RNE-11), and has been sited to avoid sensitive resources (RNE-09), consistent with mitigation measures for the project. 1 As shown in the Final EIR/EIS, Figure D.4-3B, BLM Lands Available for Renewable Energy Development, lands on which the has been sited have made available for wind energy development through BLM planning; Map 2-28: Lands Available For Wind Energy Development and Geothermal Leasing Alternative D (BLM 2007) as approved in the Eastern San Diego County Resource Management Plan and Record of Decision (BLM 2008) 2 Ibid 3 As shown in in the Final EIR/EIS, Figures D4-8A through D4-8cB, Existing Land Uses

63 5 Applicable National Environmental Policy Act (NEPA) documents and other related documents that cover the proposed action ASM Affiliates Re: Confidential Cultural Resources Analysis for the : Variance Request #6. Letter Report from Brian Williams, M.M.A, RPA Senior Archaeologist, Carlsbad Office and Jennifer Roland, M.A., RPA Associate Archaeologist, to Donna Beddow, County of Sand Diego, and Sheila Brierley, Archaeologist, El Centro Field Office, March 3, BLM (Bureau of Land Management) Record of Decision: Implementation of a Wind Energy Development Program and Associated Land Use Plan Amendments. December 15, BLM Resource Management Plan and Record of Decision. El Centro, California: BLM, El Centro Field Office. October /fesdrmp.Par File.dat/ESDC_RMP26ROD.pdf. BLM Record of Decision for the. DOI Control No. FES11-20, Case File Number: CACA El Centro, California: BLM, El Centro Field Office. December 19, BLM Right-of-Way Grant. Serial No. CACA El Centro, California: BLM, El Centro Field Office. Issued April 12, BLM Documentation of National Environmental Policy Act (NEPA) Adequacy. Tule Wind Modified 138 kv Transmission Gen-Tie. DOI-BLM-CA-D DNA. March 7, BLM Amended Record of Decision. DOI Control No. FES 11-06, Case File Number: CACA El Centro, California. BLM, El Centro Field Office. March 7, BLM Decision. Proposed Amendments to Right-of-Way Grant CACA and Response to Request for Extension of Notice to Proceed. El Centro, California. BLM, El Centro Field Office. Issued November 5, BLM Right-of-Way Grant. Serial No. CACA El Centro, California. El Centro Field Office. Issued June 30, Bureau of Land Management-California, Department of Energy, Bureau of Indian Affairs, U.S. Army Corps of Engineers, Ewiiaapaayp Band of Kumeyaay Indians, Tule Wind LLC, the California State Historic Preservation Officer, and the Advisory Council on Historic Preservation Memorandum of Agreement Among the Bureau of Land Management-California, Department of Energy, Bureau of Indian Affairs, U.S. Army Corps of Engineers, Ewiiaapaayp Band of Kumeyaay Indians, Tule Wind LLC, the California State Historic Preservation Officer, and the Advisory Council on Historic Preservation Regarding the Tule Wind Energy Project, San Diego County, California. November 16, CPUC and BLM (California Public Utilities Commission and Bureau of Land Management) Joint Final Environmental Impact Report/ Environmental Impact Statement (EIR/EIS) East County Substation/Tule Wind/Energia Sierra Juarez Gen-Tie Projects. DOI Control No. DOI-BLM-CA- D EIS. October ICF Biological Resources Variance 006. Memorandum from James Hickman, Designated Biologist, to Tom Zale [BLM]. March 3, 2017

64 6 Tule Wind LLC Plan of Development. February 2013, Revised May Submitted by Tule Wind LLC to Bureau of Land Management California Desert District. May 6, U.S. Fish and Wildlife Service Formal Section 7 Opinion for the Proposed, San Diego County, California (FWS-SD-1 OBO F0229). Memorandum from the Field Supervisor, Carlsbad Fish and Wildlife Office, transmitting the Biological Opinion to the District Manager, Bureau of Land Management, California Desert District Office. September 2011.

65 7 NEPA Adequacy Criteria 1. Is the new proposed action a feature of, or essentially similar to, an alternative analyzed in the existing NEPA document(s)? Is the project within the same analysis area, or if the project location is different, are the geographic and resource conditions sufficiently similar to those analyzed in the existing NEPA document(s)? If there are differences, can you explain why they are not substantial? Yes. The proposed action consists of a revised variance request and approval process that would allow for field-level approval of known project-related activities anticipated to exceed the delineated limits of disturbance identified in the approved POD. All project-related activities would be features of the approved project. The project-related activities would be within the same analysis area as the proposed action alternative ( Proposed Project ) in the Joint Final Environmental Impact Report/ Environmental Impact Statement (EIR/EIS) East County Substation/Tule Wind/Energia Sierra Juarez Gen-Tie Projects (BLM 2011) and wholly within the approved ROW area for the project. Moreover, the proposed action would review variances for project-related activities within the extent of existing biological, hydrological, and cultural resources surveys and within the supplemental survey areas conducted for the 20-foot buffer extending beyond the approved limits of disturbance. 2. Is the range of alternatives analyzed in the existing NEPA document(s) appropriate with respect to the new proposed action, given current environmental concerns, interests, and resource value? Yes. The proposed action would only entail a modified variance request and approval process, and would not approve project-related activities that were not previously contemplated as part of the project. 3. Is the existing analysis valid in light of any new information or circumstances (such as, rangeland health standard assessments, recent endangered species listings, and updated lists of BLM sensitive species)? Can you reasonably conclude that new information and new circumstances would not substantially change the analysis of the new proposed action? Yes. The variance areas are within the Project s ROW grant boundary and predominately within areas previously surveyed for biological and archaeological resources. Approximately one acre of the proposed 20-foot buffer extends beyond the areas previously surveyed for biological and archaeological resources. Supplemental biological, hydrological, and archaeological memoranda have been prepared for projectrelated activities with the possibility of going outside the limits of disturbance. The subsequent biological and cultural evaluations conclude that with recommended avoidance measures, activities that may (or may not) be approved under this specific variance request and approval process would not result in new significant impacts. Thus the analyses and conclusions in the Final EIS/EIR are valid as of October 2011 and apply to all project related activities, including the proposed action. There is no new information and no new guidance associated with the proposed action that would trigger the need of additional analyses beyond the analysis presented in the Final EIS/EIR. 4. Are the direct, indirect, and cumulative effects that would result from implementation of the new proposed action similar (both quantitatively and qualitatively) to those analyzed in the existing NEPA document?

66 8 Yes. The direct, indirect, and cumulative effects of the project-related activities that could be approved by the proposed action (modified variance request and approval process) are substantially the same to those analyzed in the Final EIS/EIR for the approved project. Should the project need to perform the abovementioned project-related activities outside the limits of disturbance identified in the POD, and those activities approved as part of the variance request and approval process, the project-related activities could increase the overall permanent disturbance acreage identified in the POD up to 10 acres. Any project activities approved as part of this variance request and approval process above would be conducted in accordance with the same impact avoidance, minimization, monitoring, and mitigation measures that apply to all other Project impact areas. Such measures include those specified in the Project s ECMP, BLM s ROD, and approved plans and permits. Consequently, the direct, indirect, and cumulative effects of installation of riprap beyond the previously approved limits of disturbance would be within the scope of those analyzed and mitigated for in the Final EIS/EIR for the approved Tule Wind project. 5. Are there public involvement and interagency reviews associated with existing NEPA document(s) adequate for the current proposed action? Yes. Public involvement and comment on the Proposed Project was extensive. The California Public Utilities Commission and BLM distributed the Joint Draft Environmental Impact Report/Environmental Impact Statement (EIR/EIS) East County (ECO) Substation, Tule Wind, and ESJ Gen-Tie Projects for public review on December 24, Recognizing that the public review period began during the holidays, the public review period was extended past the typical 45-day review period to 54 days. In response to public comments received on the Draft EIR/EIS, the close of the public review and comment period was further extended past the original February 16, 2011, deadline to March 4, 2011; in total, the duration of public review period was 70 days. The Final EIR/EIS was published October 14, The ROD was signed by the Secretary of the Interior on December 19, Additionally, the 2013 Amended ROD for the, which allowed the overhead alignment of the 138 kv Transmission Line, was signed by BLM on March 7, 2013, and underwent a 30-day public appeal period as described in Section 7 of the ROD. Because the Proposed Action is within the study area of the original Proposed Project in the Final EIR/EIS, the BLM believes the review of the Final EIR/EIS and affiliated decisions is adequate for the current Proposed Action. Persons/Agencies/BLM Staff Consulted List of Preparers Name Role Discipline Carrie Sahagun Assistant Field Manager, BLM General Miriam Liberatore Planning and Environmental General Coordinator, BLM Camden Bruner Wildlife Biologist, BLM Biology Sheila Brierley Archaeologist, BLM Archaeology Derek Eysenbach NEPA Coordinator, BLM General Micah Hale Archeologist, Dudek Archaeology Keith Carwana Environmental Compliance General Manager, Dudek David Hochart Environmental Compliance Manager, Dudek General