1. TNMP’s Avian Protection Plan Protecting Birds and Reducing Liability SWEDE Conference April, 2012

2. Why Bother with an APP? Recent enforcement actions prompted TNMP to produce an APP In 2002-2007, PG&E required $3.5 million a year retrofits In 2009, PacifiCorp fined $510,000, paid $900,000 in restitution, and must spend $9.1 million in the next 5 years to retrofit poles in Wyoming (spent $7 mil in 2009 alone) FP&L currently under investigation and grand jury subpoena for violations of the MBTA and BGEPA All of these utilities have active bird programs and Pacificorp’s program is state of the art Investment in bird protection improves reliability and reduces O&M over time

3. What is the Issue with Birds and Power Lines? Birds use utility poles Hunting, resting, roosting, nesting Shading from sun or rain/snow Utility poles can create habitat Bird mortalities result from electrocution or collision Electrocution generally occurs on distribution, not transmission Collisions can occur on either Weather and the age, size, and species of bird are all important variables

4. Electrocution Electrocution typically occurs on distribution –Most commonly on equipment poles –Birds can go phase to phase or phase to ground The good news is that poles can be made avian safe

5. Avian-Safe Separations The Avian Power Line Interaction Committee (APLIC) recommends phase-to-phase and phase-to-ground separations based on skin- to-skin measurements of golden eagles –60 inch horizontal separation and –40 inch vertical separation Achieved through insulation or isolation

6. Collision Occurs on distribution and transmission, especially on static wires Huge issue within the 200 mile wide whooping crane corridor which passes from Aransas north to Canada Last migratory flock on earth with < 300 birds

8. What does the USFWS expect? The USFWS expects utilities to implement serious measures to reduce bird mortality –Identify priorities for limiting mortality –Implement a work plan for achieving priorities –Demonstrate that identified steps are being implemented Communicate with the USFWS Best way to achieve these steps is –APP with a prioritized work plan –Dedicated budget for its implementation

9. What is in an APP? Statement of Commitment Training Permit Compliance Construction Design Standards Injured and Dead Bird and Nest Management Avian Reporting System Risk Assessment Methodology Mortality Reduction Measures Avian Enhancements Quality Control Public Awareness Key Resources

10. TNMP’s New APP Designed to meet USFWS expectations Identified project teams to examine issues Organized according to APLIC/USFWS 12 principles and includes –Preventative –Reactive, and –Proactive measures

11. Producing APP Takes a Team TopicTeamsIssuesStatus Automate reporting ISS, North Texas Engineering, Corporate Systems, ESD Automate import of bird guard and outage interruption data into ArcGIS Ongoing Standards review PNM Standards, North Texas Engineering, South Texas Engineering, ESD Evaluate current standards for avian safety Develop avian safe structures for narrow ROW Review and evaluate cover-up materials Ongoing Problem equipment Standards, ESDGOLB & CapacitorsInterim fixes identified, researching avian safe switches and capacitors TransmissionNorth and South Texas Engineering, ESD, Use raptor safe construction in Hotwings Develop raptor safe distribution under build Complete. Using conductor covers on distribution underbuild SubstationsSubstations, ESDEnsure new stations constructed with adequate clearances and or cover-up Develop retrofit options for old stations Under investigation. Bird guard old stations on case by case basis Promptly addressing bird guard requests Regional subpermittees, North Texas Engineering, ESD Ensure poles, equipment resulting in mortality are promptly bird guarded Complete. Finalizing ways to track.

12. Teams and Issues TopicTeamsIssuesStatus Feeder level bird guard Asset management, North Texas Engineering, ESD Explore bird guard capitalizationComplete Seeking funds for feeder level retrofits ESD, North Texas Engineering, TNMP President, Prepare business case and request funds for capital bird guard project Complete and ongoing. Problem feeder identification North Texas Engineering, ESD Develop methodology and prioritize poor performing feeders by area and bird guard Complete. Poorly performing feeders targeted in 2011. High risk spans within crane and eagle hotwings are identified in APP. Developing risk assessment models for whooping crane and bald eagle ESD, ISSDeveloped a habitat quality model for whooping cranes and bald eagles to define Hotwings. Migrate bald eagle and whooping crane Hotwings into ArcFM. Integrate into work order and project screening process for TNMP. Complete and ongoing. Habitat quality models and risk assessment complete. Hotwings to be migrated in ArcFM and integrated into screening process for TNMP projects. USFWS Reporting ESD, ISS, North Texas Engineering Develop and maintain mortality report in a format compatible with USFWS voluntary reporting system Complete. ESD to begin to track TNMP mortality in USFWS compatible format.

14. TNMP Statement of Commitment Management commitment is key to the successful implementation of an APP

15. Training, Training, Training… Training in the importance of bird issues is nothing short of culture change Training with live birds is effective TNMP training includes Handling dead and injured birds Bird guarding SOP Line Marking SOP Vegetation Management

16. Distribution Standards Review Systematic review of existing standards for avian safety –Use of cover-up materials to make existing standards avian safe –Adoption of PNM Chapter 19 for avian safe standards for use by TNMP

17. Assessing Risk Each utility has to assess its highest risk TNMP service territory falls within the Aransas Wood Buffalo whooping crane corridor and crane collision is the largest liability TNMP has an expanding bald eagle population within its service territory Developed whooping crane and bald eagle habitat models to evaluate risk

18. Whooping Crane Habitat Model Developed model after discussions with USFWS crane coordinator and literature review Line collision during crane stopover has been identified as a leading source of mortality (38%) Cranes prefer Shallow unconsolidated bottom wetlands close to appropriate forage (such as agricultural fields) Flat open terrain with unobstructed visibility GIS layers used to identify these habitats Assigned value to layer cells to identify very high, high, moderate, low, and very low quality habitat

20. Bald Eagle Habitat Model Developed model after discussions with Texas Parks and Wildlife eagle biologist and literature review Eagles prefer Water bodies >35 acres in size or > 10 m in width Areas at least 500 m away from human development High tree height to support nesting and roosting High ratio of water to land Assigned value to layer cells to identify very high, high, moderate, low, and very low quality habitat

22. Risk Assessment TNMP electric infrastructure overlain on GIS habitat models Cranes at risk of collision whereas eagles at risk of electrocution TNMP poles and spans assigned the same risk as the underlying habitat Line spans within whooping crane Hotwings ranked in terms of very high to low risk Poles, equipment within eagle Hotwings ranked in the same manner Very high risk poles and spans identified for bird guard and marking

23. Risk Assessment TNMP electric infrastructure overlain on GIS habitat models Cranes at risk of collision whereas eagles at risk of electrocution TNMP poles and spans assigned the same risk as the underlying habitat Line spans within whooping crane Hotwings ranked in terms of very high to low risk Poles, equipment within eagle Hotwings ranked in the same manner Very high risk poles and spans identified for bird guard and marking

24. Preventative Measures Encourages designers to avoid eagle and whooping crane Hotwings Requires that new construction in whooping crane Hotwings is built to avian safe standards and lines appropriately marked Requires that new construction in bald eagle habitat is built to avian-safe standards Bird guard all new equipment as part of routine maintenance

25. Reactive Measures Ensure timely response to bird mortality Poles/equipment resulting in bird mortality bird guarded within 90 days –Facilitated by new GIS-based reporting system –Tracks mortality and bird guarded poles/equipment in GIS by automated upload Ability to track bird guard request through completion Reports generated in USFWS compatible format on an on-going basis

26. Sample SOP

27. Proactive Measures Provide resources and training to improve employee’s knowledge and awareness Partner with bird conservation/rehabilitation organizations –TNMP partners with Bay Area and Rogers Wildlife Rehabilitation –Through ESD, TNMP sits on the Whooping Crane Habitat Conservation Plan steering committee with USFWS –Corporate sponsor Rains County Eagle Fest –Community crew projects throughout TNMP service territory Through PNM, TNMP participates in APLIC

28. Proactive Measures cont. New Environmental Management System screening form urges designers to check whether project occurs in “Hotwings” Establishes SOPs for –Handling dead and injured birds and problem nests –What, when and how to bird guard –Marking lines for collision New system for tracking bird mortality and bird and collision retrofits Bird guard program identifies priorities and addresses them through a bird guard budget

29. Proactive Measures cont. Cornerstone of proactive measures is bird guard program Evaluate “at risk” poles and spans within whooping crane and bald eagle Hotwings Evaluate poorly performing feeders Dedicated budget to bird guard and mark lines as appropriate

30. Proactive Measures cont. APP crane and bald eagle models used to evaluate spans for bird guard and marking

31. Whooping Crane Committee Migration corridor of the last self sustaining whooping crane population passes through the country’s best wind resource USFWS worried about the rapid expansion of wind farms and interconnections on this fragile population Has convened wind developers and utilities within the crane corridor to develop a Habitat Conservation Plan (HCP) to support issuance of Incidental Take Permits USFWS issued a notice of intent to produce an EIS on wind development HCP in July, 2011

32. Whooping Crane Committee USFWS convened utilities through APLIC in January 2010 to initiate a similar process TNMP is participating in the steering committee

33. Summary New APP is a robust program aimed at reducing avian mortality and increasing system reliability New APP meets USFWS expectations with clearly articulated work plan –Bird guard lethal structures –Bird guard as part of routine maintenance –Hotwings in ArcFM and T&D EMS screening results in systematic use of avian-safe construction/marking in Hotwings –Bird guard program addresses areas of highest species risk –Mortality and bird guard tracked in GIS format –Automated GIS process allows emerging issues to be identified and addressed –Bird guarded 1,728 poles during 2011 Collectively these steps reduce liability, increase reliability and have the potential to decrease O&M cost over time

34. Going Forward Adopt avian friendly design standards as default Evaluate of the effectiveness of increased bird guard in decreasing mortality and increasing reliability Continue to involve vegetation management in avian protection Bird guard and mark spans in eagle and crane Hotwings Whether capital or O&M, a dedicated bird guard budget is critical to limit liability now and in the future

35. Questions?