1.Impact upon a unique and sensitive environmental resource.SunZia will create an entirely new corridor down the San Pedro River Valley with an accompanying road for a minimum of 30 miles. This corridor will become the principal transmission corridor in the Southwest and will likely be expanded in the future, further increasing impact.This route was selected over the strong objections of valley residents, ranchers, conservationists, and political representatives.


2. Misleading statement of purpose and need.The Southwestern Power Group proposed the SunZia Project to provide transmission capacity for its yet-to-be-build 1,000-MW natural gas-fired Bowie power plant.SWPG would not have proposed the project had the Southwest Area Transmission Planning Group (SWAT) not proposed a line through the plantís location to satisfy New Mexico Governor Bill Richard-sonís request to export wind energy.Neither SWPG nor the BLM has acknowledged this purpose.


3.Conflicting government aims. Three federal conservation initiatives are currently focused on the valley that conflict with this choice:(1) an Americaís Great Outdoors conservation initiative, (2) a Fish and Wildlife Service wildlife refuge/collaborative conservation initiative, and (3) a joint Natural Resources Conservation Service/U.S. fish and Wildlife Service Working Lands for Wildlife Habitat initiative.


4.Lack of consideration of better alternatives.The Southline Project currently being permitted accomplishes much the same objectives in southwestern New Mexico and southeastern Arizona with far less impact.This project is in scoping and the BLM is accepting comments (http://www.blm.gov/nm/st/en/prog/more/lands_realty/southline_transmission.html). Building both is redundant and makes each less economically viable because of competition for power generation.

See CWG's Comment to the BLM on the Southline Project.


5.Use by renewable generation is speculative.While this project may facilitate development of some renewable energy sources, wind in particular, the extent of this is highly speculative, and the project is likely to spur expansion of non-renewable energy generation just as much. No companies have yet firmly committed to building renewable energy facilities in response to SunZia.


6. Insufficient project partners.Only the Salt River Project has a significant interest (13%) besides the Southwestern Power Group (MMR Group, 80%) in the project.Energy Capital Partners, which was to provide 40% of the capital to build the project, has withdrawn, and a replacement has not been found.The remaining partners appear to hold an insufficient interest to carry the project.


7.Lack of financial viability and high financial risk.The speculative nature of generation sources and the uncertain schedule of their construction place the project at great financial risk.The project does not appear capable of making a sufficient rate of return to recover costs and make a profit.This also makes it unlikely that SunZia could repay federal loan guarantees tentatively reserved for the project under the American Recovery and Reinvestment Act of 2009.


8. Lack of a market for the power.California has warned against building such lines because the state is projected to meet its Renewable Energy Portfolio requirements with its own resources. Arizona is projected to meet its own Renewable Portfolio Standards with in-state solar resources.The fundamental purpose of this project is to sell New Mexico power to these states to meet their RPSís.


9. Lack of sufficient transmission capacity to deliver power to California.Terminating SunZia at Eloy requires that California utilities and New Mexico power providers take away Arizona transmission capacity that was built by Arizona ratepayers both to deliver power within the state and to develop Arizonaís solar resources.This would sharply reduce Arizonaís ability to access its highest-quality solar energy reserves.


10.Unquestioned endorsement of the project by Obama administration officials.Obamaís high-level energy policy advisers have seized upon this project as a way to fulfill the administrationís renewable energy agenda without carefully weighing the projectís true impact, stated purpose, and likely outcome.In doing so, they have overridden lower-level officials and strong public sentiment against a San Pedro route.

11. Negative Local Economic Impacts. The siting of a utility corridor with the potential for future expansion will negatively impact the San Pedro River Valley and southern Arizona, from both an ecological and economic perspective. The DEIS overestimates the number of jobs that will be created in Cochise County, and underestimates the negative economic impact of the damage to the viewscape in the San Pedro valley. Damage to ecotourism, both locally in the San Pedro Valley (tours, birdwatching, etc.) and more distantly (e.g., hikers on the Arizona Trail) is not analyzed at all.