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(3) “Appendix G, Arizona Planned HV transmission additions” from the ACC Fourth Biennial Transmission Assessment for 2006-2015, page 152, 30 January 2007.

(4) “Vail Area 138 kV System Project” TEP handout, April 2007

Summary.

These comments concern the environmental impacts associated with the energy requirements for the Rosemont Copper Project. The electrical energy requirements for this project fail to contain cumulative environmental impacts in both Santa Cruz and Pima Counties. None of options presented by Rosemont are in the public interest as the assumptions are erroneous. In particular, the preferred electrical transmission line (Vail to Nogales) does not exist. A Comprehensive Environmental Certification (CEC) Application has not been submitted to the Arizona Power Plant and Transmission Line Siting Committee (Siting Committee) that will have significant issues to decide before a Vail-Nogales transmission line could be approved. The Line Siting Committee has 12-months to recommendation approval, modify or deny a CEC Application to the Arizona Corporation Commission (ACC) that may also approve, modify or deny the CEC Application. Many unresolved issues remain before any electricity can be provided to Rosemont Copper, as total environmental effects are assessed by the Line Siting Committee and in this EIS. It is unknown if the ACC and/or the Line Siting Committee are “cooperating agencies” in this EIS; however, if not, then resultant decision conflicts might result.

Background.

At present, the UNS Electric, Inc. (UNSE) Santa Cruz service area has a single 115 kV transmission line from the Nogales Tap substation in southern Tucson that goes through four substations to be distributed to its customers. Santa Cruz County is serviced by three utility companies. The Sulphur Springs Valley Rural Cooperative service area services to the east of the Santa Rita Mountains and the TRICO Rural Cooperative service area in the western parts of Santa Cruz County. UNSE has the largest service area primarily the Santa Cruz Valley, to the east of the Santa Rita Mountains.

UNSE operates four distribution substations on its 115 kV transmission line, the Kantor substation east of Amado, the Cañez substation in central Rio Rico, the Sonoita substation in southern Rio Rico and the Valencia substation serving the Nogales distribution area.

Reliability Problem Mitigation.

On 2 November 1999, the Arizona Corporation Commission (ACC) approved ACC Decision No. 62011 that mandated a second transmission line to be operational by 31 December 2003. This was to correct reliability problems in the Santa Cruz service area. On 15 January 2001, the ACC modified and then approved a Siting Committee CEC for a two-circuit 345 kV line from Sahuarita via a new “Gateway” substation in Nogales to terminate at Santa Anna, Sonora, Mexico using a “western” corridor. The ACC disapproved “central” and “eastern” corridors. A Department of Energy (DOE) Presidential Permit was required to cross the US-Mexican border. The Final EIS for this project was completed and published in the Federal Register in March 2005 (reference a). The Coronado National Forest (CNF), in this reference, disapproved the “western” corridor. Thus, without ACC-CNF agreement, this “second” transmission line to the Santa Cruz service area, has no approved routes. A NEPA Record of Decision (ROD) has not been issued for this project.

In late 2004, due to the changing circumstances and situation, the ACC re-opened Decision No. 62011 to resolve the remaining reliability issues in the Santa Cruz service area. Hearings were held for five days in August-September 2005. To date, the ACC Administrative Law Judge has not submitted to the Commission a Recommended Opinion and Order (ROO). During these hearings, most of the ten intervenors agreed that upgrading the existing 115 kV to a “double-circuit” configuration meets the ACC-mandated second transmission line mandate and provides adequate electricity to meet the future needs for Santa Cruz service area for several decades.

In February 2008, two local meetings were held by UES to discuss a proposed “Vail to Valencia 115 kV Upgrade Project”. For the handouts see enclosure 1. This proposal is a single-circuit 115 kV to 138 kV upgrade from the Nogales Tap in Tucson to Nogales about 60 miles to the south. A new line is proposed to be constructed from TEP’s Vail substation in eastern Tucson to UNSE’s Nogales Tap substation in southern Tucson. As of this date, neither TEP nor UNSE have not applied to the Siting Committee for a CEC. The CEC permit is required by Arizona Revised Statutes (A.R.S.) 40-360 to 40-360.13 and Arizona Administrative Code R14-3-201 to R14-3-113.

Companies.

There are several companies involved. Until 11 August 2003, Citizens Communications Company owned and managed Santa Cruz service area assets as a public service company in Arizona when UniSource Energy Inc. (UNS) acquired this company. UniSource Energy is a holding company for three public service companies. The largest is Tucson Electric Power Company (TEP) that has service areas in Pima and Cochise Counties, and is an Arizona public service company. UniSource Energy created a holding company, called UniSource Energy Services (UES) to oversee two public service companies; UNSE has service areas in Santa Cruz and Mohave Counties and UNS Gas, Inc. (UNSG) with service areas in five Arizona counties.

Due to IRS bond tax restrictions, TEP is allowed to serve customers only in Pima and Cochise County and UNSE in Santa Cruz and Mohave Counties. Both UNSE and TEP have this two-county service area restriction.

The existing 115 kV transmission line is owned and operated by UNSE and is the only source of imported power to this service area. This line is not owned by TEP; however, in January 2000, Citizens (now UNSE) and TEP signed a Project Development Agreement (PDA) whereby TEP would manage and build the Sahuarita-Nogales-Mexico dual-circuit 345 kV transmission line and a Gateway substation system.[1] UNSE has contracted with TEP to perform most transmission line functions for UNSE; however, as a UNSE ratepayer, separation of these two public service companies is critical when it comes to determine “rates” for each company. When the separation of these two public service companies is not clear, costs might become mingled, to the detriment of both companies. The ACC makes decisions for rate cases and demands each company account for all expensed.

The Rosemont Copper Electric Plan.

0n 11 July 2007, Rosemont Copper submitted the “Rosemont Project Mine Plan of Operations” (reference c). Section 2.7 of this report is titled “Electrical Power Supply” with Appendix C containing an Electrical Load Summary (enclosure 2). It should be noted that the connected load for Rosemont Copper is 133 kV (enclosure 2, Appendix C) while at 138 kV transmission line can carry 100-120 MW, thus at least two 138 kV or one larger capacity transmission line is required for Rosemont Copper.

This “electrical plan” shows a “Preferred Electrical Supply Transmission Supply Route” in Figure 1 below, which is from the Mine Plan of Operations. Four options were proposed. Each will be discussed below, as one reads Section 2.7. Option Four is the “preferred” route.

[NB: most of the answers below will be determined during Siting Committee proceedings]

Option 1 – Interconnection with TEP Line Serving Santa Cruz County (section 2.7.1).

Q-11. Why isn’t UNSE indicated at the owner of the 115 kV line?

Q-12. There is NO existing Vail-Kantor line (as there are no transmission lines between Vail and the Nogales Tap substations), so how can a 115 kV Vail-Kantor line be upgraded?

Q-13. There are significant customer/ratepayer costs for changing from the DOE Western Power Administration (WAPA) 115 kV line to a 138 kV TEP line originating at Vail. Has the impact of this customer cost been assessed which impact UNSE Santa Cruz service area customers?

Q-14. What is the cost of this new substation and will UNSE Santa Cruz service area customers pay for a new 138 kV switching station on this UNSE-owned 115/138 kV line?

Figure 1. - Transmission Line Options for Rosemont Copper Electrical Supply.

Q-15. What does “partially borne by TEP” mean in terms of specific rate increases for UNSE Santa Cruz service area customers?

Q-16. Why even consider this option for 75 MW of power if it does not provide the 132 MW of power required by Rosemont Copper?

Option 2 – Interconnection with SWTC Sahuarita 230 kV Substation. (2.7.2)

Q-21. What are the cost differences between Options 1, 2, 3, and 4?

Q-22. If the project will overload the existing 345/230 kV Bicknell transformer, can a new transformer be acquired, and at what additional cost?

Q-23. Has this option been “noticed” to TRICO customers by Public Notices in the appropriate newspapers?

Q-24. TEP is not involved for this option. Will TEP manage this SWTC project as TEP will have no role if this option is selected?

Q-25. What will be the costs borne by TRICO ratepayers for Option 2?

Option 3. Interconnection with TEP South 345/138 kV substation. (2.7.3)

Q-31. Higher voltage transmission lines have less line loss, thus transmit electricity at lower cost per mile than a transmission system at a lower voltage. What are the life-cycle cost differences between a 138 kV, 230 kV, and 345 kV transmission systems to support Rosemont Copper?

Q-32. Why is TEP the service provider, when TRICO (SWTC) might be able to provide lower cost services to Rosemont Copper?

Q-33. What is the cost per mile for 138 kV and the cost the appropriate 138 kV transformers?

Q-34. Is the only problem with this option is the 12 miles length of the line?

Q-35. The TEP South substation is inside the 100-year flood plain. Due to its criticality for Tucson’s power, it should be required to meet the 500-year flood criteria. How will TEP meet the potential floods that routinely occur on the Santa Cruz River that is adjacent to the South substation (reference a, Appendix C, Figure 2, p. C-4) which shows it is inside the 100-year floodplain?

Option 4. Interconnection with TEP South Line to the TEP Vail-Kantor Line. (2.7.4)

Q-41. What happens if the Line Siting Committee CEC specifies a different alternative than the Vail Kantor 138 kV line?

Q-42. What are the specific relationships (agreements) between UNSE (who owns the existing 115 kv line) and TEP?

Q-43. Will UNSE ratepayers pay any costs for the Rosemont Copper installations?

Q-44. Are two lines, one from South substation and one from Vail being proposed by this option (the two sources)?

Q-45. Since UNSE requires two circuits, based on the reopened ACC Decision 62011 hearings in 2005, how will a third circuit for Rosemont fit on these UNSE utility poles?

Q-46. What are the mean time between failure (MTBF) and mean time to repair (MTTR) (both are common reliability engineering measures) for each option being proposed?

A Fifth Option, Line Siting Case No. 137 for the Vail 138 kV System Project.

This TEP proposal provides another option to provide power to Rosemont Copper. This project provides for double-circuit 138 kV transmission lines to go southwest from the Vail substation to a new Cienega substation in Phase 1 and a new Mountain View substation in Phase 2 to the south of Interstate 10, next to State Route 83 that goes directly to the Rosemont Copper mine (see enclosure 4).

Q-51. Will the proposed Mountain View substation be considered as a power source for Rosemont Copper?

Q-52. How much power will be available at the Mountain View substation, if Phase 2 is ever build, after servicing its distribution demands?

Q-53. When is the Mountain View substation to be operational?

Preliminary Power Flow Analysis. (2.7.5)

Q-61. Why was 2010 assumed for the power flow analysis since the proposed upgrade shows a Vail-Nogales line is not expected to be complete in 2012? (See enclosure 3)

Studies “show that the Vail substation could serve up to 75 MW of mine load if 20 MW of generation is on-line at the Valencia generation facility, or up to 100 MW, if the Gateway Project were in service.” The power requirements for a mine are continuous, varying little during the 24-hour day.

Q-62. How can 75 MW + 20 MW meet the 133 MW Rosemont Copper 133 MW load requirements in Appendix C?

Q-63. The peak power requirements for the UNSE Santa Cruz service area is 75.4 MW reached on 28 June 2007. How will power be furnished to the Santa Cruz service area when over 75 MW or 100 MW of power is required?

Q-64. How can 100 MW from the Gateway meet the 133 MW load requirements?

Q-65. What authority does TEP have that require turbines to run in Nogales to furnish power for Rosemont Copper?

Q-66. At present, there is inadequate amount of natural gas to continually run the 65 MW of generation capabilities that exist in the City of Nogales so diesel fuel is used when natural gas runs out. What are the future natural gas and electrical demands for the Santa Cruz service area in 2015 and 2025 and how much local generation can be made available to continuously meet the additional power requirements for Rosemont Copper?

Q-67. The City of Nogales is an EPA non-attainment of compliance requirements for clean air. What are the projected air pollution impacts for 2015 and 2025 that running 20 MW to 65 MW of natural gas or diesel turbines in Nogales have on air quality in that city?

Q-68. Is there any basis to assume the Gateway Project will be on line in 2010 as TEP assured the Commission it would be online by 31 December 2003?

Q-69. Since when did the Gateway substation move from NW of Nogales (in reference a) to “near Sahuarita”?

Q-70. Why is there any impacts between the UNSE Sonoita substation and a Rosemont substation that require “pre-project” voltage levels to be corrected by shunt capacitors?

Q-71. Why are upgrades required to “certain SWTC facilities” to mitigate any impacts due to outages” if Option 4 is selected?

TEP has a significant portion of its power sold to mines, such as those in Green Valley. In 1996, for example, 925,000,000 MW-hrs were purchased by these mining activities, about 10% of the total retail sales of 9,201,000,000 MW-hrs. The Rosemont Copper mine will consume 1,165,000,000 MW-hrs (=133 MW x 8,760 hrs/year) when operating at full capacity demand of 133 MW/hr. TEP uses over 95% coal-fueled electrical generation plants, thus, for 133 MW of power, then about 250,000 tons of Carbon Dioxide (CO2), 830 tones of Nitrite oxides (NOx), and 250 tons of Sulfur Dioxide (SP2) will be required by TEP to furnish the electrical power necessary for Rosemont Copper.

Q-72. How will Rosemont Copper compensate for these 250,000 tons of CO2, 830 tons of NOx and 250 tones of SO2 that will be necessary to generate the electricity required for this mine?

Q-73. Will another source, with less coal-fueled electrical generation be assessed during the EIS process?

Q-74. How much water will be required for the coal-fired electrical generators required for the Rosemont Copper mine?

Q-75. Will Rosemont Copper also “recharge” the Tucson Aquifer to account for the water necessary to generate Rosemont Copper’s electricity?

Description of Proposed Electrical Power Supply. (2.7.6)

Q-81. The existing 115 kV line or upgraded to 138 kV in Option 4 already transverses the Santa Rita Experimental Range (see Figure 1 above). Is this line to modified to avoid this range, contrary to Figure 1?

Q-82. TEP has a very poor track record in forecasting completion dates for its projects (as discussed above for its 345 kV project to Mexico). How can TEP confirm the date that a proposed Vail-Kantor transmission line and upgrades be completed since no application for such a line has been submitted to the Line Siting Committee?

Q-83. Can a “Vail-Kantor” 138 kV transmission line meet all the power requirements for Rosemont Copper?

Q-84. What is the long-term impact of the 138 kV line radiated electro-magnetic and electric fields on pipeline corrosion in the parallel fresh water pipeline route?

Q-85. Does the mean time between failure for the Option 4 11.6 mile transmission system exceed 300 years as required by the National Electrical Reliability Council (NERC), or its successor’s reliability criteria?

Q-86. What is the impact of fire and smoke on the capabilities of the proposed UNSE 138 kV line to furnish power to Rosemont Copper?

Q-87. Is the 7.2 MW of power required for the well fields included in the loads in enclosure 2 (Appendix C) or is the total demand for Rosemont Copper over 140 MW (= 133 + 7.2)?

Some General Questions:

Q-100. Where is a detailed trade-off study comparing the four electrical supply options?

Q-101. Will any transformers for the transmission and distribution lines contain any PCBs or other toxic substances?

Q-102. What is the impact on Rosemont Copper if the electrical supply required can not be provided until 2012, 2015, or 2018?

Q-103. What was the basis to select TEP to be the power provider to Rosemont Copper compared to self-generated power using natural gas from the El Paso Natural Gasline that runs parallel to Interstate 10?

Q-104. How can UNSE have a double-circuit 138 kV line to Nogales if one circuit of that line is used for Rosemont Copper?

Q-105. In section 2.8.2 (Legal and Regulatory Considerations), the role of obtaining environmental capability certification from the Line Siting Committee and its approval by the ACC are omitted. Will this omission be corrected and considered?

Q-106. When will the CEC Application for the proposed TEP and/or UNSE and/or SWTC transmission lines be submitted to the Line Siting Committee?

Cumulative Effects involving Water and Air.

In the West, water is a dominate natural resource and must be considered comprehensively for all decisions. When performing the NEPA Cumulative Effects analyses, it is critical that the impact on the whole water cycle be considered for the project. A natural gas pipeline or transmission line has very little direct impact on water resources; however, each may have significant indicted impacts. A 100 MW transmission line that will support another 50,000 families needs to consider the water resource impacts that the line will for these new families using this energy. At 200 gallons per day per captia, over 250,000,000 gallons are required.

Q-201. If the end users do not have that water available, where will it come from?

Q-202. How much water is required to generate that 100 MW, based on the logical generation anticipated for this community?

Q-203. If the community is already in an EPA non-attainment area, how will the additional “exurban” commuters change the quality of air?

Q-204. Both ends and intermediate points along the “system” must be assessed and extrapolated for the life-cycle of the project, usually 50 or more years into the future.

Anything less than a complete analysis of the above issues and related factors is an irresponsible, incomplete, and misleading environmental assessment. A complete, high quality, and informative environmental analysis is absolutely necessary for the many jurisdictional decision makers involved with the Rosemont Copper project.

Sincerely,

Marshall Magruder

marshall@magruder.org

520.398.8587

Enclosures:

(1) “Vail to Valencia 115 kV Upgrade Project” UES handouts, February 2008

(2) “Rosemont Project Mine Plan of Operations”, section 2.7 and Appendix C, 11 July 2007.

(3) “Appendix G, Arizona Planned HV transmission additions” from the ACC Fourth Biennial Transmission Assessment for 2006-2015, page 152, 30 January 2007.

(4) “Vail Area 138 kV System Project” TEP handout, April 2007

Enclosure 1

“Vail to Valencia 115 kV Upgrade Project”

UES handouts

February 2008

Enclosure 2

“Rosemont Project Mine Plan of Operations”

Section 2.7 and Appendix C,

11 July 2007.

Enclosure 3

“Appendix G, Arizona Planned HV transmission additions”

from the ACC Fourth Biennial Transmission Assessment for 2006-2015,

page 152,

30 January 2007.

Enclosure 4

“Vail Area 138 kV System Project”

TEP handout,

April 2007

[1] A proposed new Gateway substation west of Nogales with have double-circuit 345 kV transmission lines to/from Mexico and TEP’s South substation in Sahuarita and a single-circuit 115 kV line to/from the Valencia substation in central Nogales.

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