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Appendix 2AApplicant Proposed Measures and BLM Required BestManagement Practices

Table of ContentsAppendix 2AApplicant Proposed Measures and BLM Required Best Management Practices . 2A-i2A.1Air Quality and Climate Change . 2A-12A.2Geology, Minerals, and Soil Resources . 2A-82A.3Paleontological Resources . 2A-112A.4Biological Resources (Vegetation, including Special Status Species, and Wildlife, includingSpecial Status Species and Migratory Birds . 2A-122A.5Vegetation . 2A-402A.6Cultural Resources . 2A-412A.7Recreation . 2A-442A.8Noise . 2A-462A.9Hazards and Hazardous Materials . 2A-482A.10Public Health and Safety . 2A-522A.11Traffic, Transportation, and Public Access . 2A-532A.12Visual Resources . 2A-562A.13Water Resources . 2A-632A.14Miscellaneous . 2A-68Ten West Link 500kV Transmission Line ProjectTechnical Environmental StudyAppendix 2A-i

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2A.1 AIR QUALITY AND CLIMATE CHANGEAPM ORBLMREQUIREDBMPAPM(AlsoaddressesBLM RegionalMitigationStrategy forAZ SEZsMMs)APM/BMPDESCRIPTIONAQ-01:Fugitive DustThe following control measures would beimplemented, as applicable, to reduce PM10and PM2.5 emissions during construction, inconjunction with an Erosion, Dust Control,and Air Quality Plan and Fugitive DustControl Plan for the Project.Basic control measuresThe following measures would beimplemented as applicable at all constructionsites: Water active construction areassufficiently to minimize fugitive dust. Dust control would include the use ofone or more water trucks that wouldwater access roads daily as needed tocontrol dust throughout the constructionperiod Cover trucks hauling soil, sand, andother loose materials and require alltrucks to maintain at least 6 inches offreeboard. Pave, apply water, or apply nontoxicsoil stabilizers as applicable on for allunpaved access roads, parking areas,and staging areas at construction sites tominimize fugitive dust.Enhanced control measuresIn addition to the “basic” control measureslisted above, the following control measuresmay be implemented at all construction sitesgreater than 4 acres:Ten West Link 500kV Transmission Line ProjectTechnical Environmental StudyPRECONST.CONST.XXO&MDECOMXDRECP CMAADDRESSED*LUPA-AIR-01,02, 03, and 05;LUPA-BIO-13CAONLY12KVLINETOSCSXAppendix 2A-1

APM ORBLMREQUIREDBMPAPM/BMPDESCRIPTION Water, hydroseed, or apply nontoxicsoil stabilizers to inactive constructionareas to minimize fugitive dust. Enclose, cover, water, or apply nontoxicsoil binders to exposed stockpiles. Limit traffic speeds on unpaved roads. Install sandbags or other erosion-controlmeasures to prevent silt runoff to publicroadways. Replant vegetation in disturbed areas asquickly as possible, consistent withseasonal survival considerations.Optional control measuresDepending on the extent of dust generation,implementation of the following optionalcontrol measures may occur at largerconstruction sites, near sensitive receptors(residences or other occupied buildings,parks, or trails within 1,000 feet ofearthmoving operations that are substantial;for example, more than excavation for towerfoundations), or in situations which for anyother reason may warrant additionalemissions reductions: Install wheel washers for all existingtrucks, or wash off the tires or tracks ofall trucks and equipment leaving thesite. Suspend excavation and grading activitywhen winds (instantaneous gusts)exceed 25 miles per hour (mph).Limit the area subject to excavation, grading,and other construction activity at any onetime.Ten West Link 500kV Transmission Line ProjectTechnical Environmental StudyPRECONST.CONST.O&MDECOMDRECP CMAADDRESSED*CAONLY12KVLINETOSCSAppendix 2A-2

APM ORBLMREQUIREDBMPBMPAPMAPM/BMPAQ-01 t palliatives would be applied, in lieu ofwater, to inactive construction areas(disturbed lands or soil stockpiles that areunused for 14 consecutive days). Dustpalliatives would be chosen by the DustControl Site Coordinator and or constructioncontractor. Dust palliatives would beenvironmentally safe; comply with Federal,state, and local regulations; and would notproduce a noxious odor or contaminatesurface water or groundwater and, therefore,would not pose runoff concerns during rainevents. Application rates for dust palliativeswould follow the manufacturer’srecommendations. Material Safety DataSheets (MSDS/SDS) for any palliativeswould be available on site and provided tothe BLM 14 days prior to use.The following measures would beimplemented during construction to furtherminimize greenhouse gas emissions (carbondioxide, methane, and nitrous oxide) perCalifornia AB 32 and criteria air pollutantsfrom vehicle and machinery and inconjunction with the Construction EmissionsMitigation Plan for the Project: Minimize unnecessary constructionvehicle idling time. The ability to limitconstruction vehicle idling time dependson the sequence of constructionactivities and when and where vehiclesare needed or staged. Certain vehicles,Ten West Link 500kV Transmission Line ProjectTechnical Environmental StudyPRECONST.CONST.XXXO&MDECOMXDRECP O-13LUPA-AIR-3XAppendix 2A-3

APM aturallyOccurringAsbestosEmissionsDESCRIPTIONsuch as large diesel-powered vehicles,have extended warm-up times that limittheir availability for use followingstartup. Where such diesel-poweredvehicles are required for repetitiveconstruction tasks, these vehicles mayrequire more idling time. The Projectwould apply a “common sense”approach to vehicle use, such that idlingis reduced as far as possible below themaximum of 5 consecutive minutesrequired under Title 13 of CaliforniaCode of Regulations (CCR) Section2485 (13 CCR 2485). If a vehicle is notrequired for use immediately orcontinuously for construction activitiesor other safety-related reasons, itsengine would be shut off. Encourage use of natural gas- orelectric-powered vehicles for light-dutytrucks where feasible and available.The following measures would beimplemented prior to and during constructionto minimize the potential for naturallyoccurring asbestos emissions, in conjunctionwith an Asbestos Dust Mitigation Plan ifasbestos, serpentinite, or ultramafic rock isdetermined to be present: Prior to construction, representativesamples in the general construction areawould be analyzed for the presence ofasbestos, serpentinite, or ultramaficrock. Analyses could be conducted aspart of the geotechnical investigation.Ten West Link 500kV Transmission Line ProjectTechnical Environmental StudyPRECONST.CONST.XXO&MDECOMDRECP CMAADDRESSED*CAONLY12KVLINETOSCSAppendix 2A-4

APM ORBLMREQUIREDBMPAPM/BMPDESCRIPTION In California, if asbestos, serpentinite,or ultramafic rock is determined to bepresent, all applicable provisions of theAirborne Toxic Control Measure(ATCM) for construction, grading,quarrying, and surface miningoperations (17 CCR 93105) would beimplemented, including the following:For disturbed areas of 1 acre or less:o Construction vehicle speed at thework site would be limited to 15mph or less.o Prior to any ground disturbance,sufficient water would be applied tothe area to be disturbed to preventvisible emissions from crossing theproperty line if asbestos,serpentinite, or ultramafic rock isdetermined to be present.o Areas to be graded or excavatedwould be kept adequately wet toprevent visible emissions fromcrossing the property line.o Storage piles would be keptadequately wetted, treated with achemical dust suppressant, orcovered when material is not beingadded to or removed from the pile.o Equipment would be washed downbefore moving from the propertyonto a paved public road.Ten West Link 500kV Transmission Line ProjectTechnical Environmental StudyPRECONST.CONST.O&MDECOMDRECP CMAADDRESSED*CAONLY12KVLINETOSCSAppendix 2A-5

APM missions sDESCRIPTIONo Visible track-out on the pavedpublic road would be cleaned usingwet sweeping or a high-efficiencyparticulate air-filter-equippedvacuum device within 24 hours.For disturbed areas of greater than 1acre:o Prepare an Asbestos Dust MitigationPlan and obtain approval prior toconstruction.Implement and maintain the provisions of theapproved Asbestos Dust Mitigation Plan fromthe beginning of construction through theduration of the construction activity.In addition to the AQ-1 measures to controlgeneral fugitive dust emissions, the followingmeasures would be implemented prior to andduring construction to create awareness of therisks and inhalation prevention procedureswith respect to Coccidioides immitis fungalspores, which are naturally present in soils inthe desert southwest, and inhalation of whichcan cause Valley Fever: Prior to construction, and for each phaseof construction, implement anEnvironmental Awareness Program forworkers to ensure they are informed ofthe risks of contracting Valley Feverand the protective measures needed tominimize personal exposure to fugitivedust, as well as to minimize possibledust exposure of nearby residents andthe general public.Ten West Link 500kV Transmission Line ProjectTechnical Environmental StudyPRECONST.CONST.XXO&MDECOMDRECP CMAADDRESSED*CAONLY12KVLINETOSCSXAppendix 2A-6

APM ORBLMREQUIREDBMPBMPAPM/BMPAQ-05: AirQualityRegulationand StandardConformance*See Appendix 2CDESCRIPTION Inform workers of the possiblesymptoms of Valley Fever andencourage them to seek medicaltreatment if these symptoms manifest.All activities would meet the requirements ofthe Clean Air Act (Sections 110, 118, 160,and 176[c]) and the applicable local AirQuality Management jurisdiction(s). Fugitivedust cannot exceed local standards andrequirements.Ten West Link 500kV Transmission Line ProjectTechnical Environmental StudyPRECONST.CONST.O&MDECOMXXXXDRECP ETOSCSAppendix 2A-7

2A.2 GEOLOGY, MINERALS, AND SOIL RESOURCESAPM ORBLMREQUIREDBMPAPM1APM/BMPGEO-01:Erosion andSedimentationDESCRIPTIONPRECONST.DCRT would implement a SWPPP for theProject. A monitoring program would beestablished to ensure that the prescribedBMPs are followed throughout transmissionline construction. Examples of these BMPsinclude the following: Preparation, training, and maintenancefor clear work-site practices, trackingcontrols, and materials management tominimize the direct work impacts onsoil and erosion. Installation of temporary silt fencesand other containment features(including gravel bags and fiber rolls)surrounding work areas to prevent theloss of soil during rain events andother disturbances. Utilization of storm drain inletprotection, including sediment filtersand ponding barriers, to retainsediments on site and prevent excessdischarge into storm drains. Implementation of soil erosioncontrols, including preservation ofexisting vegetation, temporary soilstabilization through hydroseeding,mulching, and other techniques. Stockpiling soils at least 100 feet fromdrainages to the extent possible. If soilstockpiles are within 100 feet from adrainage proper measures would beCONST.O&MXXDECOMDRECP CMAADDRESSED*LUPA-SW-8CAONLY12KVLINETOSCSX1APS would prepare and submit a separate SWPPP for the 12kV distribution line.Ten West Link 500kV Transmission Line ProjectTechnical Environmental StudyAppendix 2A-8

APM -03BMPSOIL-04DESCRIPTIONimplemented such as soil tackifiers,straw wattles around the pile, and/orcovering the stockpile.During reclamation and revegetation efforts,a BLM soil scientist and/or botanist reviewplans and approve, as appropriate, todetermine type and location of anyscarification.During reclamation and revegetation efforts,the BLM would review plans and approve,as appropriate, to determine where soilcompaction would be appropriate, to avoidpotential adverse conditions created bycompaction.Covers for topsoil stockpiles would be ofmaterials resistant to damage and/ordegradation from exposure to ultravioletlight and other elements and would bereplaced (as needed) if they deteriorate,become worn, or damaged.The disruption of desert pavement anddesert varnish shall be minimized to theextent feasible. Grading for new accessroads or work areas in areas covered bydesert pavement and/or desert varnish shallbe avoided if possible.Ten West Link 500kV Transmission Line ProjectTechnical Environmental StudyPRECONST.CONST.O&MDECOMDRECP Appendix 2A-9

APM BMP*See Appendix 2CDESCRIPTIONDesert pavement and desert varnish inactivity areas in California shall be assessedby qualified geological or biologicalmonitors prior to construction. Ifdisturbance from an activity is likely toexceed 10% of the desert pavement and/ordesert varnish identified within the activityboundary, the BLM would determinewhether the erosional and ecologic impactsof exceeding the 10% cap by the proposedamount would be insignificant and/orwhether the activity should be redesigned tominimize desert pavement and/or desertvarnish disturbance.Side-casting of soil during road constructionshall be avoided.To the extent possible, avoid disturbance ofdesert biologically intact soil crusts, andsoils highly susceptible to wind and watererosion.Ten West Link 500kV Transmission Line ProjectTechnical Environmental StudyPRECONST.CONST.XXO&MDECOMDRECP 0XXXXXX12KVLINETOSCSAppendix 2A-10

2A.3 PALEONTOLOGICAL RESOURCESAPM aleontological ResourcesTreatmentPlanDCRT would prepare a PaleontologicalResources Treatment Plan that woulddescribe procedures to be followed in theevent of the discovery of paleontologicalresources during implementation of theProject. Upon approval of the draft plan,DCRT would follow the procedures set forthin that Plan during implementation of theProject.A qualified paleontologist or geologistqualified in paleontological evaluationswould provide monitoring forpaleontological resources duringconstruction in areas of high or unknownfossil potential.PALEO-02:Paleontological ResourcesMonitor*See Appendix 2CTen West Link 500kV Transmission Line ProjectTechnical Environmental LUPA-PALEO-4XO&MDECOMDRECP CMAADDRESSED*CAONLYAppendix 2A-11

2A.4 BIOLOGICAL RESOURCES (VEGETATION, INCLUDING SPECIAL STATUS SPECIES, ANDWILDLIFE, INCLUDING SPECIAL STATUS SPECIES AND MIGRATORY BIRDSAPM EnvironmentalAwarenessProgramBefore starting any work, includingmowing, staging, installing stormwatercontrol structures, implementing otherBMPs, removing trees, construction, andrestoration, all employees and contractorsperforming activities and new constructionwould receive training on environmentalrequirements that apply to their job dutiesand work. If additional crewmembersarrive later in the job, they would berequired to complete the training beforebeginning work. Training would include adiscussion of the avoidance andminimization measures being implementedand would include information on theFederal and state Endangered Species Actsand the consequences of not complyingwith these Acts. An educational brochurewould be provided to construction crewsworking on the Project. This brochurewould include color photographs ofspecial-status species as well as adiscussion of avoidance and minimizationmeasures.Ten West Link 500kV Transmission Line ProjectTechnical Environmental StudyPRECONST.CONST.O&MDECOMDRECP endix 2A-12

APM ECP CMAADDRESSED*The worker education program wouldprovide interpretation for non-Englishspeaking workers.XXXXLUPA BIO-5A qualified biological monitor would bepresent on the Project site during all workactivities within habitat of special-statusanimal species. The qualified biologistwould conduct a preconstruction survey ofthose areas immediately before workactivities begin and would locate and fenceoff any present individuals of special statusplant species.XXXMultiple biological monitors would beprovided so any work site within habitat ofspecial status species is monitoredconcurrently if sProgramBIO-02:BiologicalMonitoring g andPreconstructionSurveyTen West Link 500kV Transmission Line ProjectTechnical Environmental StudyCAONLY12KVLINETOSCSXAppendix 2A-13XX

APM ORBLMREQUIREDBMPAPMBIO-04:Environmentally SensitiveAreas 6: O-6,LUPA-BIO-14XTo the extent practicable, stockpiling ofmaterial would be allowed only within theestablished work area. Vehicles andequipment would be parked on pavement,existing roads, and previously disturbedareas within identified work areas or accessroads.The BLM would approve areas to be usedfor stockpiling, vehicle parking, or otherconstruction support activity that wouldoccur outside established work areas.Environmentally sensitive areas, such asthe riparian areas, xeroriparian washes, andother habitat of special status species,would be identified in the field. Barrierfences or stakes would be installed at theedge of the easement or around thesensitive area to minimize the possibility ofinadvertently encroaching into sensitivehabitat.Trash dumping, firearms, open fires, andpets would be prohibited at all worklocations and access roads. Smoking wouldbe prohibited along the Project alignment.XXXAll food scraps, wrappers, food containers,cans, bottles, and other trash from the workarea would be disposed of in closed trashcontainers.BIO-03:ApprovedWork AreasAPMXCONST.DESCRIPTIONBIO-03:ApprovedWork AreasDRECP XTen West Link 500kV Transmission Line ProjectTechnical Environmental StudyO&MCAONLYAppendix 2A-14

APM ofilamentPlasticNo monofilament plastic would be used forerosion control (for example, matting, fiberroll, wattles, silt fencing backing).Appropriate materials include burlap,coconut fiber, or other materials asidentified in the general and site-specificSWPPP.Vehicular and equipment refueling shouldnot occur within 100 feet of a wetland ordrainage unless secondary containment isconstructed, for example, a berm and linedrefueling area. Proper spill prevention andcleanup equipment would be maintained inall refueling areas in accordance with theSpill Prevention, Control, andCountermeasures Plan (SPCC) for theProject.BIO-08:RefuelingTen West Link 500kV Transmission Line ProjectTechnical Environmental 9XCONST.O&MDECOMDRECP CMAADDRESSED*CAONLYAppendix 2A-15

APM ORBLMREQUIREDBMPAPMAPMAPM/BMPDESCRIPTIONBIO-09: EscapeRampsAll excavated steep-walled holes ortrenches more than 1-foot-deep would becovered at the end of each working daywith plywood or similar material or wouldbe provided with one or more escape rampsconstructed of earth fill or wooden planks.Each trench or hole would be inspected forwildlife at the beginning of each work dayand before such holes or trenches are filled.Wildlife found trapped in trenches or holeswould be relocated to suitable habitatoutside the work area. If possible, pipesand culverts greater than 3 inches indiameter would be stored on dunnage toprevent wildlife from taking refuge inthem, to the extent feasible.The BMPs included in the SWPPP wouldbe implemented during construction tominimize impacts associated with erosion.Watering for dust control duringconstruction would also be used asdescribed previously (AQ-01). Wateringshall not result in prolonged ponding ofsurface water that could attract wildlife tothe work area. Minimal or no vegetationclearing and/or soil disturbance would beconducted for site access and constructionin areas with suitable topography (i.e.,overland driving/overland access).BIO-10:Erosion andDust DECOMDRECP CMAADDRESSED*CAONLY12KVLINETOSCSX2APS would prepare, submit, and adhere to the BMPs in a separate SWPPP for the 12kV distribution line.Ten West Link 500kV Transmission Line ProjectTechnical Environmental StudyAppendix 2A-16

APM ationManagementPlanThe Vegetation Management Plan(Appendix 2B) would be approved by theBLM and implemented. That Plandescribes the surveys, permitting, feepayments, and plant protection to beconducted in areas where Project designwould not eliminate the need for vegetationcontrol for the Project to be in compliancewith NERC requirements. Vegetationwould be trimmed or otherwise controlledfor safe operation of the transmission lineand would be designed to minimizeimpacts on special status species to theextent practicable. At a minimum,vegetation treatments shall incorporate themeasures identified in the June 2016Memorandum of Understanding regardingvegetation management along ROW forelectrical transmission and distributionfacilities (USDA 2016). The Plan alsowould describe how vegetation would besalvaged, as needed, in order to complywith the applicable Arizona Native PlantLaw and California regulations.PRECONST.CONST.O&MXXDECOMDRECP FIRE-1CAONLY12KVLINETOSCSX3APS is currently compiling vegetation maintenance activities into a Vegetation Management Plan specific to the 12kV distribution line per BLM IM-2018-070.Ten West Link 500kV Transmission Line ProjectTechnical Environmental StudyAppendix 2A-17

APM tionManagementPlanIn addition to the description of theVegetation Management Plan in thecorresponding APM BIO-11, the planwould also: Meet BLM guidelines formapping and surveying of cacti,yuccas, and succulents. Include a wire zone/borderzone/effective border zoneapproach to vegetationmaintenance as described inBallard, et al. 2007. Identify tall vegetation species bygeographic reach and growthrates, from relevant scientificliterature (such as Drezner 2003),to be used to determine maximumallowable vegetation heights inthe context of wire zone/borderzone/effective border zoneconcepts, to accommodateidentified growth periods (e.g.,ten years) based on the specificvegetation community. Speciesexamples include, but are notlimited to, saguaro cactus,ironwood, palo verde,cottonwood, Gooding willow.Ten West Link 500kV Transmission Line ProjectTechnical Environmental StudyPRECONST.CONST.O&MXXXDECOMDRECP RE-1CAONLY12KVLINETOSCSXAppendix 2A-18

APM us andInvasiveSpecies ControlA Noxious Weed Control Plan (Appendix2B) would be developed, approved by theBLM, and implemented prior to initiationof ground disturbing activities. That Planwould identify noxious and invasivespecies to be addressed in the Project Area,describe measures to conductpreconstruction weed surveys, reduce thepotential introduction or spread of noxiousweeds and invasive species duringconstruction, and monitor and controlweeds during operation of the transmissionline. It would be designed to minimizeimpacts on special status species to theextent practicable. Coordination withresource agencies regarding invasive plantspecies would be conducted beforeconstruction. BMPs would include use ofweed-free straw, fill, and other materials;requirements for washing vehicles andequipment arriving on site; propermaintenance of vehicle inspection andwash stations; requirements for managinginfested soils and materials; requirementsand practices for the application ofherbicides; and other requirements inapplicable BLM Weed Management Plans.PRECONST.CONST.O&MDECOMXXXXDRECP NLY12KVLINETOSCSX4APS would comply with their existing noxious weed protocol in its existing vegetation management plan on file with the BLM.Ten West Link 500kV Transmission Line ProjectTechnical Environmental StudyAppendix 2A-19

APM arianHabitatAvoidanceRiparian areas and xeroriparian drainagesthat occur within the ROW would bedenoted as environmentally sensitive areasand would be avoided during constructionto the extent practicable. Existingtopography would be restored to preProject conditions to the extent possible.In areas with suitable topography, minimalor no vegetation clearing and soildisturbance would be conducted for siteaccess and construction (i.e. overlanddriving/overland access). Overlanddriving/overland access would be used inareas that support the necessaryconstruction equipment. Upgrading ofexisting access roads and construction ofnew access roads would be implemented asnecessary for the safe ClearingTen West Link 500kV Transmission Line ProjectTechnical Environmental BIO-14O&MDECOMDRECP CMAADDRESSED*CAONLY12KVLINETOSCSXAppendix 2A-20

APM lamationand RestorationA Habitat Restoration and Monitoring Planwould be developed, approved by BLM,and implemented for construction andoperation of the Project. Revegetate allsites disturbed during construction thatwould not be required for operation of thetransmission line, and restore disturbedareas to the extent practicable, given thearid desert environment. The Plan woulddescribe in detail methods for surveyingand characterizing vegetation in disturbedareas before construction; topsoil salvageand management, erosion control, postconstruction recontouring and sitepreparation, seeding and planting, andpost-construction watering, monitoring,and remediation. It would be designed toreduce impacts on special status species tothe extent practicable.As a part of the Habitat Restoration andMonitoring Plan, the soil horizons wouldbe stored separately for the areas where thesuccess of restoration could be crucial forrare plant species.BIO-15:Reclamationand RestorationTen West Link 500kV Transmission Line ProjectTechnical Environmental StudyPRECONST.CONST.O&MDECOMDRECP dix 2A-21

APM ORBLMREQUIREDBMPAPMAPMAPM/BMPDESCRIPTIONBIO 16:Treatment ofSaguaro CactusMeasures would be implemented tominimize the number of saguaro cacti thatmust be relocated for the safe constructionand operation of the transmission line andassociated SCS distribution line. Inaccordance with the VegetationManagement Plan (Appendix 2B), a surveyof saguaros within the ROWs would beconducted before construction and wherepossible, the transmission line anddistribution line would be designed tominimize the number of saguaros affectedby adjusting tower or pole locations andconductor height. The Plan would addressplant salvaging, storing, and replantingrequirements and methods, only thosesaguaros that are within 50-feet of theoutermost conductors and could be tallenough to pose a hazard would be removedif they cannot be avoided through Projectdesign. When possible, saguaro that mustbe removed would be relocated as directedby the BLM and state agency protocols.Monitoring and management of saguarosduring operations would occur as describedin the Vegetation Management Plan.Vehicular travel would be limited toestablished roads to the maximum extentpracticable.BIO-17: LimitOff-roadVehicle Travel5PRECONST.XCONST.O&MXXXXDECOMDRECP PA-BIO-13XManagement of saguaro cactus for the alternative 12kV distribution line would be completed per APS’ Arizona BLM lands Vegetation Management Plan.Ten West Link 500kV Transmission Line ProjectTechnical Environmental StudyAppendix 2A-22 pa

APM OR BLM REQUIRED BMP APM/BMP DESCRIPTION PRE-CONST. CONST. O&M DECOM DRECP CMA ADDRESSED* CA ONLY 12KV LINE TO SCS APM NO-01: Noise Minimization with Portable Barriers Compressors and other small stationary equipment used during construction would be shielded

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