Cascabel Working Group
A grassroots organization concerned with the cultural and ecological integrity of the lower/middle San Pedro Valley

Update 2017: NRCD Change of Position on SunZia

Since this petition was filed back in 2011-2, the Winkleman and Redington NRCDs have changed their position on the SunZia project.
...SunZia offered to pay them a total of $600,000 in post-construction payments, plus NRCD legal fees, plus allow NRCD input on the SunZia Plan of Development, all in exchange for the NRCDs dropping all opposition to the transmission project.
See the update on the current lawsuit against the ACC, questioning the validity of its CEC decision.

NRCD's Petition
  • The gist: SunZia's claim to be "primarily renewable" has misled the public
  • The long awaited response finally received mid-April, 2012 (scroll down to the blue Response section for details)

Information Quality Act Petition

The Redington and Winkelman Natural Resource Conservation Districts have submitted a petition to the BLM entitled
The gist of the petition is that the description of purpose made by SunZia has misled the public and those who attended BLM scoping meetings of the true nature of the project. Their stated purpose is
" to transport electricity generated from power generation resources, including primarily renewable resources, to western markets and load centers".
The 'primarily renewable' description which has so heavily influenced supporters of the SunZia project is argued to be purely speculative.

Click here to view the petition.

Information Quality Act Appeal

Unfortunately, the response to the original petition was that the New Mexico BLM would simply make unspecified revisions to the five challenged statements of purpose in the draft EIS. So an appeal was filed that explains how this action would defeat the purpose of the scoping period by denying the public and stakeholders the right to comment on an accurate description of the project prior to the final development of the draft EIS. The Appeal also continues to insist that four specific disclosures are made regarding the relationship between the proposed project and non-renewable sources of energy, as well as the regulatory and economic factors that would affect the nature of generation sources ultimately gaining access to the proposed lines. The Washington D.C. based Information Resources officer had until November 5th, 2011 to respond to this Appeal.

Here is a copy of the Appeal.


To view the response letter from BLM director Robert Abbey to Redington NRCD director Andy Smallhouse, click here.

What follows is an April article written by Peter Else of the Friends of the Aravaipa Region (FAR), summarizing the events and results of the petitioning process.

Sent: Saturday, April 21, 2012 11:44 AM
Subject: SunZia News! BLM Issues Disclaimers

Over a year and a half after first being requested to do so, the
Bureau of Land Management (BLM) issued disclaimers related to their
claim that the proposed SunZia transmission project would primarily
enable the development of renewable energy resources, such as wind and
solar energy. In a response received this week by the Winkelman and
Redington Natural Resource Conservation Districts, BLM Director Robert
V. Abbey instructed his New Mexico office to modify their SunZia
website in order to comply with provisions of the Information Quality
Act (IQA). This response, titled "BLM Director's Response to
Winkelman [and Redington] Natural Resource Conservation District re:
SunZia Southwest Transmission Project (4/6/2012)" can be found on the
agency's IQA web site:

The first request for correction was made in September of 2010 by the
author of this Friends of the Aravaipa Region newsletter. When no
response was given to this request, and following subsequent contacts
with the New Mexico BLM office over a six month period, the Winkelman
and Redington Conservation Districts developed and approved a joint
petition, entitled "Request for Correction of Information in Scoping
Documents for the SunZia Southwest Transmission Project". Letters of
support for this petition were provided by several local conservation

After two subsequent appeals by the petitioners and two unusual delays
by the agency, the Director of the BLM finally instructed his New
Mexico office to make a correction on their SunZia website and issue
disclaimers related to scoping documents that have been linked to this
site for the past three years. These changes appeared on the website
last Thursday. The word "primarily" was dropped from the term
"primarily renewable energy resources" in the main page of this
website, and two disclaimers were issued, regarding the Notice of
Intent and the three scoping period newsletters.

In one of the disclaimers, the term "non-renewable energy" was used
for the first time in any of the scoping documentation written by the
agency. Scoping documents contained twenty references to renewable
energy and displayed graphical representations of wind generators.
The current environmental impact process for this project only applies
to the construction of transmission lines, and does not cover
construction of renewable energy generation plants on public lands.

These disclaimers can be read on the BLM's SunZia web site at:

The disclaimers call into question the validity of a recent economic
study commissioned by SunZia, in which there is an assumption that 80%
to 94% of the energy resources on the proposed line would come from
renewable energy generation plants. The BLM has now acknowledged that
it is speculative to even claim that most of the new energy generation
enabled by this project will come from renewable resources. At this
time, it is not known whether the BLM will allow this economic study
to be incorporated in the Environmental Impact Statement. The
economic study has also been challenged by local scientist Norman
Meader on the basis of inflated job numbers.

The petitioners have repeatedly argued that disseminating a misleading
statement of purpose for the proposed project over an extended period
of time has violated the intent of the Information Quality Act. They
have also noted in an appeal that prolonging the dissemination of
misleading information does not meet the acceptible legal standard for
informed public participation in a National Environmental Policy Act
process, and has, in effect, given a government stamp of approval to
unsubstantiated claims in SunZia's marketing plan. Claims that the
project will primarily enable the development of renewable energy
resources are part of the basis for SunZia' endeavor to obtain
federally guaranteed loans.

At this point, the BLM has only posted these disclaimers on its SunZia
website, and has not distributed them through the mailing list it
compiled during the scoping process, as requested by the petitioners.
Mr. Abbey indicated that information related to these disclaimers will
be disseminated in the draft Environmental Impact Statement (EIS),
which is due to be released to the public in June. One of the
current disclaimers references "the project proponent's historical
focus on facilitating renewable energy projects", a statement of
historical focus that has been challenged by the petitioners in their

Also, at this point, it is not known if the draft EIS will contain
disclosures requested by the petitioners, such as the financial
interest held by the majority owner in a large permitted fossil-fueled
plant located on the proposed route in Bowie, as well as the
disclosure of other large permitted non-renewable energy plants that
would be expected to apply for access to the proposed transmission
lines. The petitioners have also requested disclosure that SunZia
would be under no obligation to construct all portions of the proposed
line, which could also affect the amounts and relative proportions of
renewable and non-renewable energy resources developed as a result of
the project.

All three of the remaining proposed Arizona routes pass through the
San Pedro River valley.

Friends of the Aravaipa Region (FAR) distributes information and
opinion to conservation activists in the Southwest and to several media
representatives in southern Arizona. If you wish to be removed or
added to this distribution list or make a comment, please respond to
the author, Peter Else, at the enclosed email address.