DRAFT_EID_WIFA_COT_Northwest_Wellhead_Treatment.pdf
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- Northwest Well Treatment Facility
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- 240220
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- Pima County, Tucson City, Arizona
About this file
The document is an Environmental Information Document for the Northwest Wellhead Treatment Project, prepared by SWCA Environmental Consultants for the Water Infrastructure Finance Authority (WIFA) on behalf of the City of Tucson Water Department in March 2024. The project involves installing water treatment facilities at an existing well (Z-013A) and connecting new facilities to two additional wells (Z-014B and Z-015A) with approximately 11,000 linear feet of new 16-inch diameter buried water lines. The overall project is anticipated to be constructed over 2 to 3 years, with pipeline construction lasting approximately 12 months, and will be located near the intersections of Ina Road, Thornydale Road, and Orange Grove Road in Pima County, Arizona.
The project is being funded through the Drinking Water State Revolving Fund (DWSRF) administered by WIFA, with the primary objective of addressing per- and polyfluoroalkyl substances (PFAS) and 1,4-dioxane contamination in the regional groundwater supply. Nine wells in the northwest portion of Tucson Water's service area were previously taken out of service due to these contaminants, limiting water supply capacity and requiring water to be piped long distances. The proposed project would reactivate three dormant wells to withdraw and treat up to 4,144 acre-feet per year (3.7 million gallons per day), improving the reliability, quality, and quantity of the existing potable water supply for Tucson Water customers while complying with the Tucson Active Management Area's groundwater management plan.
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Water Infrastructure Finance Authority of Arizona
Environmental Information Document
Northwest Wellhead Treatment Project
Prepared by SWCA Environmental Consultants for the Water Infrastructure Finance Authority on behalf of the
City of Tucson Water Department
March 2024
Environmental Information Document for the Northwest Wellhead Treatment Project i
TABLE OF CONTENTS
1.0 Project Description and Need
1.1 Project Description (Proposed Action)
1.2 Need for Project
2.0 Alternatives to the Proposed Project
2.1 Alternatives Considered
2.2 Alternatives Considered but Eliminated from Analysis
2.3 Comparison of Alternatives
2.4 Selection of Alternative
3.0 Environmental Consequences of the Project
3.1 Land Use/Important Farmland/Formally Classified Land
3.2 Floodplains
3.3 Wetlands
3.4 Historic/Cultural and Archaeological Resources
3.5 Sensitive Biological Resources
3.6 Water Resources
3.7 Air Quality
3.8 Wild and Scenic Rivers
3.9 Noise Abatement and Control
3.10 Transportation
3.11 Socioeconomic Issues
3.12 Miscellaneous Environmental Considerations
4.0 Summary of Mitigation
5.0 Correspondence
6.0 Exhibits/Maps
7.0 Certification and Environmental Review Checklist
8.0 Literature Cited
Environmental Information Document for the Northwest Wellhead Treatment Project ii
Appendices
Appendix A. Contact Information for Environmental Regulatory Agencies
Appendix B. Sample Letter to Resource Agencies
Appendix C. U.S. Fish and Wildlife Service Information for Planning and Consultation Species
List
Appendix D. Arizona Game and Fish Department Environmental Online Review Tool Report
Tables
Table 1. Previously Recorded Sites in the Project Area
Table 2. Federally Listed Species Potentially Occurring in Pima County, Arizona
Table 3. Marana, Pima County, and Arizona 5-Year Data Profile
Table 4. Demographics of Marana and Pima County, 2022 American Community Survey
5-Year Data Profile
Figures
Figure 1. General project location
Figure 2. Project area
Environmental Information Document for the Northwest Wellhead Treatment Project 1
1.0 PROJECT DESCRIPTION AND NEED
1.1 Project Description (Proposed Action)
Tucson Water, a department of the City of Tucson (City), provides municipal water service to the residences and businesses in the city and its surrounding areas in Pima County, Arizona. The water system’s infrastructure and resources are a blend of local groundwater supplies and recharged
Colorado River water delivered via the Central Arizona Project (CAP), and reclaimed water used for non-potable purposes. Tucson Water manages around 170 wells for drinking water across
1 main and 8 isolated systems for a total of 9 public water systems. Under the Safe Drinking Water
Act, these public water systems are mandated to conduct regular monitoring of their source wells and entry points to the distribution system to adhere to the drinking water standards set by the U.S.
Environmental Protection Agency (EPA). These entry points undergo testing for over 80 regulated parameters in drinking water, following specific monitoring schedules.
The Sentry Program was established in 2008 under the direction of the City Manager as a voluntary component of the city’s water quality management strategy. The program was designed to proactively identify, track, and address potential contaminants of emerging concern (CECs) in the
City’s drinking water system. Tucson Water has been actively addressing the presence of per- and polyfluoroalkyl substances (PFAS), also known as “forever chemicals,” which are part of a large group of manufactured compounds used in products that resist stains, grease, and water, as well as in firefighting foams.
In response to PFAS found at levels higher than the EPA’s health advisory levels in the regional groundwater aquifer near Davis Monthan Air Force Base and other areas around the city, Tucson
Water has removed affected drinking water production wells from service. The Arizona
Department of Environmental Quality (ADEQ) has dedicated funds to prevent PFAS-contaminated groundwater from impacting additional drinking water production wells and is working with Tucson Water and the Air Force Civil Engineering Center on this issue.
As part of this broader effort, Tucson Water is proposing the Northwest Wellhead Treatment
Facility (project) in an area northwest of Tucson (Figure 1), near the intersections of Ina Road, Thornydale Road, and Orange Grove Road (Figure 2). The project area is characterized by a patchwork of neighborhoods falling under City of Tucson, Pima County, and Town of Marana jurisdictions.
The project includes design and construction of a new water treatment facility (Central Treatment
Facility) on a parcel currently occupied by Tucson Water Well Z-013A, and the installation of approximately 11,000 linear feet of new, 16-inch-diameter piping to bring in and treat water from two additional Tucson Water Wells, Z-014B and Z-015A.
• Well Z-013A is located at 4498 West Ina Road (SW¼ Section 31, Township 12 South, Range 13 East)
• Well Z-014B is located at 4010 West Ina Road (NE¼ Section 31, Township 12 South, Range 13 East)
• Well Z-015A is located at 6410 North Thornydale Road (SE7/4 Section 6, Township 13
South, Range 73 East)
Environmental Information Document for the Northwest Wellhead Treatment Project 2
The total anticipated construction timeframe will be approximately 2 to 3 years for the overall project, with the pipeline construction lasting approximately 12 months. The pipeline will be installed in public rights-of-way, in easements granted to the City, and/or on property owned by the City. Detailed design of the project has not yet been completed. Grant funding would be used to support design and construction of the entire project.
Surface impacts will include the installation of tanks, treatment equipment, aboveground piping, electrical gear, well drilling/rehabilitation, control panels, buildings, fencing, and other civil improvements. Subsurface impacts include the installation of underground utilities including water, communication, sewer, and electrical. Construction will avoid buried utilities and comply with associated utility-related jurisdictional requirements. Where the proposed utility piping crosses Cañada del Oro Wash, the piping will be hung from the existing bridge or bored under the wash.
Tucson Water has requested funds from the Drinking Water State Revolving Fund administered by the Water Infrastructure Finance Authority (WIFA) to construct the project; therefore, the project would be subject to WIFA’s National Environmental Policy Act (NEPA)–like environmental review process. WIFA has recommended that an environmental information document (EID) be completed for the project (WIFA Project DW 057-2022) to document its environmental compliance.
1.2 Need for Project
Tucson Water is responsible for delivering a reliable and adequate supply of water to its service area. The northwest portion of the Tucson Water service area now has limited capacity and redundancy due to concentrations of PFAS and 1,4-dioxane in the groundwater supply. The need for this project is to restore lost capacity and redundancy due the elevated levels of PFAS and
1,4-dioxane in the water supply necessary to maintain a high level of service to Tucson Water customers.
The proposed project would seek to improve the ability of Tucson Water to provide safe and reliable water to its customers, as well as meet customer demands in the service area, by developing a redundant supply source.
Nine wells in the northwest portion of Tucson Water’s service area were taken out of service in
2016 due to groundwater monitoring results indicating the presence of 1,4-dioxane and PFAS, particularly perfluoroocatane sulfonic acid (PFOS) and perflurooctanoic acid (PFOA) above the
Safe Drinking Water Act Health Advisory. Due to the air-gapping of these nine wells, the northwest area is limited in capacity, and potable water is conveyed from long distances through a single pipeline.
2.0 ALTERNATIVES TO THE PROPOSED PROJECT
This section discusses the alternatives that have been considered by Tucson Water to meet the stated project need, including the No Action Alternative; compares the alternatives; and describes the process of selecting the alternative that Tucson Water is proposing (Proposed Action). The
Proposed Action was selected because it provides the most economical means for maintaining
Environmental Information Document for the Northwest Wellhead Treatment Project 3
Tucson Water’s water quality standards and the most effective use of funds available to provide safe drinking water and restore system capacity and redundancy into the Tucson Water system.
2.1 Alternatives Considered
This EID analysis considers the Proposed Action and a No Action Alternative, as described below.
Proposed Action
Under the Proposed Action, Tucson Water’s proposed project would be designed and constructed as described in Section 1.1 using funding secured from the Drinking Water State Revolving Fund and administered by WIFA.
Alternative A
Construction of a second, new treatment facility and additional 15,000 linear feet of 8-inch and
10-inch diameter piping connecting the facility to wells Z-002A, Z-005A, and A-053A. The
Northwest Well Treatment Facility would treat for PFAS and 1,4-dioxane and will be located at well site Z-013 due to its proximity to a 42-inch main, which serves a large portion of Tucson
Water’s northwest service area.
Alternative B
Construction of a third treatment facility and additional 9,000 linear feet of 12-inch diameter piping connecting well site Y-004A to a facility at well site Y-001B.
No Action
Under the No Action Alternative, Tucson Water would continue to operate under limited capacity and have a lack of redundancy in available water supply. Tucson Water would need to continue conveying potable water from long distances through a single pipeline, which incurs increased operating costs.
2.2 Alternatives Considered but Eliminated from Analysis
Alternative A was eliminated from further consideration due to a lack of funding.
Alternative B was eliminated because it would only benefit a small portion of the Tucson Water system; therefore it was not considered to be economically feasible.
2.3 Comparison of Alternatives
The No Action Alternative would not meet the project’s need to deliver a reliable and adequate supply of water to its service area, and would not meet future customer needs in the project area.
Environmental Information Document for the Northwest Wellhead Treatment Project 4
2.4 Selection of Alternative
On the basis of Tucson Water’s evaluation of the available data, and in consideration of project alternatives, Tucson Water decided to pursue the Proposed Action (see Section 1.1). Tucson Water determined that the Proposed Action is a long-term solution that adequately meets the project purpose and need in the shortest amount of time and at the lowest cost; therefore, it was selected as the preferred alternative.
3.0 ENVIRONMENTAL CONSEQUENCES OF THE PROJECT
This section describes the existing conditions for key environmental resources and evaluates the potential impacts expected to result from the Proposed Action and No Action Alternative.
3.1 Land Use/Important Farmland/Formally Classified Land
Tucson Water Wells Z-013A and Z-014B are located on parcels owned by the City. The Z-013A well site and its adjacent infrastructure occupy two parcels, one inside the Town of Marana and the other in unincorporated Pima County. The third well (Z-015A) is in the southeastern corner of a private parcel owned by the Church of Jesus Christ of Latter-Day Saints, also within the Town of Marana jurisdiction (Pima County 2024a). The planned pipeline would be constructed along
Thornydale and Ina Roads, both of which are existing arterials and bike routes in Marana and would cross a shared-use pedestrian and bicycle path along the Cañada del Oro Wash (Town of
Marana 2019).
The project area traverses parcels with a mix of residential, industrial, commercial, transportation, and vacant land uses, as well as a proposed multifamily mixed-use project. The Marana zoning codes associated with the project area include village commercial (VC), neighborhood commercial
(NC), heavy industrial (HI), and single-family residential (R-36) (Pima County 2024a). The small wellsite parcel that lies within unincorporated Pima County is zoned for single-residence use
(CR-3) (Pima County 2024a). Water infrastructure is a permitted use under the existing zoning throughout the project area.
According to the Make Marana 2040 General Plan, the entire project area lies within Marana’s
South Growth Area which “currently contains the highest concentration of population and commercial activity” and which has a future commercial land use designation of Commercial
(Town of Marana 2019:2-10). According to the 2015 Pima County Comprehensive Plan, the planned land use adjacent to the project area is designated as medium-low/medium intensity urban
(Pima County 2015).
As determined by the U.S. Department of Agriculture Natural Resources Conservation Service
(NRCS) Web Soil Survey, the project area contains soils classified as both “not prime farmland” and “prime farmland if irrigated and either protected from flooding or not frequently flooded during the growing season” (NRCS 2023).
Formally classified lands are defined as properties that are administered by federal, state, or local government agencies or that have special protection through formal legislative designation. This could include national forests, monuments, or landmarks; national historic sites; Bureau of Indian
Affairs land or leases; and Bureau of Land Management–administered lands. No formally
Environmental Information Document for the Northwest Wellhead Treatment Project 5 classified lands are within the project area. The nearest formally classified lands are Richardson
Park, which is approximately 0.3 mile east of the portion of the project area on Thornydale Road, and Ted Walker Park, which is approximately 0.3 mile southwest of the Z-013A well site.
Environmental Consequences of the Proposed Action
There would be no changes to local zoning or land use planning as a result of the project and the
Proposed Action would be in conformance with existing land use designations and zoning. All project activities would be installed in public rights-of-way, in easements granted to the City, and/or on property owned by the City.
While the project area contains soils classified as “prime farmland if irrigated,” the land is already heavily developed for commercial, residential, and transportation uses and there are no plans to use the area for agriculture (Town of Marana 2019). Therefore, no prime farmland would be impacted under the Proposed Action.
Environmental Consequences of the No Action Alternative
No impacts to land use would occur under the No Action Alternative because no changes to existing operations would occur.
3.2 Floodplains
Federal Emergency Management Agency (FEMA) Flood Insurance Rate Map panel
04019C1660L was analyzed for the proposed project area. This review revealed that the project’s northern section, located beyond the Cañada del Oro Wash, falls within Zone X, which is identified as an area of minimal flood hazard. Conversely, the southern portion of the project spans three distinct flood zones:
• An outer Zone X, denoted as a 0.2 percent annual chance flood hazard area, commonly referred to as the 100-year floodplain, envelopes the Cañada del Oro Wash.
• The Cañada del Oro Wash itself is classified under Zone AE, a regulatory floodway, which is subject to specific regulations due to its significant flood risk. This zone includes established base flood elevations.
• The Carmack Wash stormwater channel, positioned further south, is designated as
Zone A. Unlike Zone AE, Zone A lacks mapped base flood elevations but is still recognized as a Special Flood Hazard Area.
Both Zone AE and Zone A areas are classified as Special Flood Hazard Areas (FEMA 2023).
Environmental Consequences of the Proposed Action
Impacts to floodplains typically occur if the topography of a project area is altered by the placement of fill or structures that impede stormwater flows. The project includes the installation of underground pipelines, and the original surface elevations of the ground surface will be restored to their pre-construction conditions following the installation; therefore, impacts to floodplains would not occur under the Proposed Action.
Environmental Information Document for the Northwest Wellhead Treatment Project 6
Environmental Consequences of the No Action Alternative
No impacts to 100-year floodplains would occur under the No Action Alternative because no construction activities would occur.
3.3 Wetlands
According to the U.S. Fish and Wildlife Service (USFWS) National Wetlands Inventory (NWI), no identified or designated wetlands are within or adjacent to the proposed project area
(USFWS 2023a). No hydric soils are mapped within or adjacent to the project area (NRCS 2023).
Furthermore, no wetlands were identified in the project area during the SWCA Environmental
Consultants (SWCA) biological evaluation survey (see Section 3.5).
Environmental Consequences of the Proposed Action
No wetlands are present within the project area; therefore, no impacts to wetlands would occur under the Proposed Action.
Environmental Consequences of the No Action Alternative
No impacts to wetlands would occur under the No Action Alternative since these resources are not present.
3.4 Historic/Cultural and Archaeological Resources
WIFA consulted with the Arizona State Historic Preservation Office (SHPO) on September 21, 2022, and SHPO determined that a Class I archival cultural resources review of the project area would be required to obtain additional information regarding cultural resources. An SWCA archaeologist conducted the Class I review and prepared a Class 1 cultural resources inventory report (SWCA 2023). The record review resulted in the identification of five previously recorded archaeological sites within or close to the project area (Table 1).
Table 1. Previously Recorded Sites in the Project Area
Site Number Site Description/Affiliation
AZ AA:12:3(ASM) Artifact scatter (ceramics, lithics)/Hohokam
AZ AA:12:6(ASM) Artifact scatter (ceramics, lithics)/Hohokam
AZ AA:12:20(ASM) Habitation site/Early Agricultural, Early Ceramic, and Hohokam
AZ AA:12:74(ASM) Artifact scatter (ceramics, lithics)/Hohokam
AZ AA:12:836(ASM) Field house or farmstead/Hohokam
Note: ASM = Arizona State Museum
The inventory was intended to identify previously recorded archaeological sites in the project area, and to consider whether these constitute historic properties (listed in or eligible for listing in the
National Register of Historic Places [NRHP]). Arizona State Museum (ASM) site numbers
AZ AA:12:20(ASM) and AZ AA:12:836(ASM) have previously been determined eligible for listing in the NRHP and therefore constitute historic properties. None of the significant discoveries
Environmental Information Document for the Northwest Wellhead Treatment Project 7 in AZ AA:12:20(ASM) were made in the project area. It has been suggested that
AZ AA:12:836(ASM) has been destroyed within the Ina Road corridor (the project area).
AZ AA:12:3(ASM) and AZ AA:12:74(ASM) have not received agency eligibility determinations.
It is likely the sites have been destroyed by development, and that they do not constitute historic properties. AZ AA:12:6(ASM) may have been determined eligible in the past, but SWCA previously recommended it as not eligible for the NRHP. The site has likely been destroyed within the project area.
Environmental Consequences of the Proposed Action
Based upon the Class I results, the SHPO recommended monitoring of all ground disturbance within the boundary of AZ AA:12:20(ASM), “as it has previously yielded a lot of buried deposits, including human remains and it is unclear whether this portion of the site is extant within the project area.” As such, monitoring of any work in the vicinity of AZ AA:12:20(ASM), will be required (email from Erin Davis, Archaeological Compliance Specialist, SHPO to Samantha
Lemke, Environmental Program Supervisor dated January 12, 2024).
Should previously unidentified cultural resources be discovered during construction, all construction activity will cease in the immediate vicinity of the find. Appropriately qualified experts in coordination with the SHPO would determine the NRHP eligibility of the find, assess whether the Proposed Action has had or may have an adverse effect on the find, and develop and implement mitigation measures, as appropriate.
Environmental Consequences of the No Action Alternative
Impacts under the No Action Alternative no construction activities would occur, and no historic/cultural or archaeological resources would be affected.
3.5 Sensitive Biological Resources
An SWCA biologist conducted a biological evaluation survey of the project area on August 22, 2023. A summary of the biological evaluation findings is presented below.
Vegetation and Wildlife
The project area is located within the Arizona Upland subdivision of the Sonoran Desertscrub biotic community at elevations ranging from approximately 2,210 to 2,250 feet above mean sea level (amsl). Pusch Ridge of the Catalina Mountains is located approximately 7 miles northeast of the project area, and Wasson Peak in the Tucson Mountains is located approximately 7 miles to the southwest. The Cañada del Oro Wash crosses the project area on Thornydale Road and flows into the Santa Cruz River located approximately 1 mile to the west. The project area is in an urban area and is mostly landscaped; however, scattered pockets of native desertscrub vegetation are present. No perennial waterways are in the project area, and the only waterways present are the ephemeral Cañada del Oro Wash and the Carmack Wash stormwater channel located approximately 0.5 mile south of the wash.
Native trees observed during the site visit included velvet mesquite (Prosopis velutina), yellow paloverde (Parkinsonia microphylla), blue paloverde (P. florida), desert ironwood (Olneya
Environmental Information Document for the Northwest Wellhead Treatment Project 8 tesota). Other native species observed included whitethorn acacia (Vachellia constricta), brittlebush (Encelia farinosa), desert broom (Baccharis sarothroides), canyon ragweed (Ambrosia ambrosioides), climbing milkweed (Funastrum cynanchoides), fairy duster (Calliandra eriophylla), ocotillo (Fouquieria splendens), saguaro (Carnegiea gigantea), Santa Rita prickly pear (Opuntia santa-rita), sotol (Dasylirion wheeleri), and Palmer’s agave (Agave palmeri).
No broadleaf deciduous riparian vegetation communities (i.e., communities containing cottonwood [Populus spp.], willow [Salix spp.], or ash [Fraxinus spp.]) or suitable bat roost sites
(e.g., natural caves or mine features) occur in the project area. The underside of the Canyon del
Oro Wash bridge was inspected during the site visit, and it was found unsuitable for bats because the spaces between the bridge girders were too far apart to be used for roosting.
Nonnative grass species in the project area include Bermuda grass (Cynodon dactylon) and
Johnson grass (Sorghum halepense). Johnson grass is listed as a Class C noxious weed species by the Arizona Department of Agriculture (ADA) under Arizona Administrative Code R3-4-245.
These two nonnative species were only observed in the Carmack Wash stormwater channel.
Native plants in the project area are protected under the Arizona Native Plant Law (NPL) (Arizona
Revised Statutes 3-904) as administered by the ADA. The NPL states that a Notice of Intent to
Clear Land form be filed with the ADA prior to land clearing activities, even if no plants will be salvaged and moved from the site.
Seven avian species were observed on-site: American kestrel (Falco sparverius), house finch
(Haemorhous mexicanus), verdin (Auriparus flaviceps), mourning dove (Zenaida macroura), great-tailed grackle (Quiscalus mexicanus), Eurasian collared dove (Streptopelia decaocto), and rock dove (Columba livia). Other wildlife observations included round-tailed ground squirrel
(Xerospermophilus tereticaudus), common side-blotched lizard (Uta stansburiana), and desert spiny lizard (Sceloporus magister).
No nests were observed in the project area at the time of the site visit; however, all birds observed except for Eurasian collared dove and rock dove are protected under the Migratory Bird Treaty
Act (MBTA) (16 United States Code 703–712), which provides federal protection to all migratory birds, including nests and eggs.
The project area is also within the range of Western burrowing owl (Athene cunicularia ssp.
hypugaea). The western burrowing owl is a migratory bird species protected by international treaty under the Migratory Bird Treaty Act of 1918 (16 United States Code 703-711) (MBTA) and by
Arizona state law (Arizona Revised Statues 17). To avoid violating these laws, all burrowing owls and active burrows should be identified prior to any ground-disturbing activity.
Species Evaluation
SWCA accessed the USFWS Information for Planning and Consultation online database to obtain a project area–specific Official Species List. The list includes species that are currently listed or are proposed for listing as endangered or threatened under the Endangered Species Act (ESA) or are considered experimental populations, non-essential (EXPN). The list also includes candidates proposed for listing as threatened or endangered species. The ESA specifically prohibits the “take” of a listed wildlife species. Take is defined as “to harass, harm, pursue, hunt, shoot, wound, kill, Environmental Information Document for the Northwest Wellhead Treatment Project 9 trap, capture, or collect, or to engage in any such conduct.” However, the ESA does not provide the same take protections for plant species, except on federal land. Some bird species also receive legal protection under the federal MBTA (16 United States Code 703–712).
The Arizona Game and Fish Department (AZGFD) maintains a statewide database, known as the
Heritage Data Management System (HDMS). This database can be accessed through the AZGFD online environmental review tool (i.e., Arizona Heritage Geographic Information System). The
HDMS tracks occurrence records for federally listed species and other species of special concern.
SWCA accessed the HDMS database to obtain a project-specific Online Environmental Review
Tool Report for the project.
According to the project’s USFWS Information for Planning and Consultation Official Species
List, there is no proposed or designated critical habitat in or in the vicinity of the project area. The
AZGFD Online Environmental Review Tool Report indicates that the project area is located within
3 miles of known occurrences of the threatened yellow-billed cuckoo (Coccyzus americanus) and cactus ferruginous pygmy owl (Glaucidium brasilianum cactorum), the endangered Gila topminnow (Poeciliopsis occidentalis occidentalis), the candidate for listing monarch butterfly
(Danaus plexippus), and two state-listed species, the Arizona ridge-nosed rattlesnake (Crotalus willardi willardi) and Sonoran desert tortoise (Gopherus morafkai) (AZGFD 2023a).
Environmental Consequences of the Proposed Action
None of the 26 species listed by the USFWS in Pima County as threatened, endangered, proposed, EXPN, or candidates for listing are known to occur in the project area; however, habitat research and the results of the site visit indicate that one species, the monarch butterfly, has the potential to occur because the project area was found to contain vegetation or landscape features known to support this species. Monarch butterfly is discussed in Table 2.
The other 25 species are not likely to occur in the project area because the project area is clearly beyond the known geographic or elevational range of these species, does not contain vegetation or landscape features known to support these species, or both. Habitat requirements, potential for occurrence, and possible effects of the project on listed species are summarized in Table 2.
The recommended determination of effect for these remaining 25 listed species is no effect.
Table 2. Federally Listed Species Potentially Occurring in Pima County, Arizona
Common Name (species name)
Status* Range or Habitat Requirements Potential for Occurrence in Project Area
Determination of Effect
Acuña cactus (Echinomastus erectocentrus var.
acunensis)
E This cactus occurs in disjunct populations across southern Arizona on well-drained gravel ridges and knolls on granite-derived soils. It grows in the Arizona Upland subdivision of the Sonoran desertscrub plant association at elevations between 1,198 and 2,789 feet amsl. This species occurs in Maricopa, Pima, and Pinal Counties.
Unlikely to occur. The project area is outside the range of this species.
No effect.
Environmental Information Document for the Northwest Wellhead Treatment Project 10
Common Name (species name)
Status* Range or Habitat Requirements Potential for Occurrence in Project Area
Determination of Effect
Arizona eryngo (Eryngium sparganophyllum)
PE This perennial forb occurs in spring-fed cienega wetlands in moist to saturated organic alkali soils (USFWS 2020). Plants thrive in full sun in areas without nonnative plant species or excessive woody vegetation. In Arizona, occurs in three disjunct populations in Pima and Cochise Counties at elevations from 2,707 to 4,000 feet amsl: Agua Caliente Ranch, where it is extirpated but has been reintroduced; La Cebadilla Cienega, near Tanque Verde Wash east of Tucson; and in Lewis Springs Cienega within the San Pedro Riparian National Conservation Area.
Unlikely to occur. The project area is not within the current range of this species and does not contain cienega wetland habitat.
No effect.
Bartram’s stonecrop (Graptopetalum bartramii)
T Occurs in rocky outcrops in shrub live oak (Quercus turbinella) grasslands along meandering arroyos on sides of rugged canyons at elevations of 3,650 to 6,700 feet amsl. Typically occurs in areas with heavy litter cover and shade, where moisture drips from rocks, and often within Madrean evergreen woodland. In Arizona, occurs in the Atascosa-Pajarito, Baboquivari, Chiricahua, Dragoon, Mule, Patagonia, Rincon, Santa Rita, and Whetstone Mountains.
Unlikely to occur. The project area is not within the current range of this species.
No effect.
Beardless chinchweed (Pectis imberbis)
E Typically occurs in grasslands at lower elevations and oak woodlands and tropical deciduous forests at higher elevations.
Found at elevations ranging from 3,773 to 5,660 feet amsl. However, has also been observed on disturbed road cuts, arroyo cuts, and unstable rocky slopes in areas where it has little competition for sunlight.
In the United States, it occurs in the Atascosa-Pajarito, Huachuca, Patagonia, and Santa Rita Mountains and the Canelo Hills.
Unlikely to occur. The project area is not within the current range of this species.
No effect.
Cactus ferruginous pygmy owl (Glaucidium brasilianum cactorum)
T Historically, this species was common in mesquite (Prosopis spp.) bosques and along rivers throughout southern Arizona.
Based on current information, habitat is loosely described as streamside cottonwoods [Populus spp.] and willows [Salix spp.] and adjacent mesquite bosques, usually with saguaros [Carnegiea gigantea] on nearby slopes.
Less often, this species is found along dry washes where large mesquite, paloverde (Parkinsonia spp.), ironwood (Olneya tesota), and saguaro thrive.
Unlikely to occur. While the project area contains saguaros in landscape plantings, it is also located in an area that has been fragmented by commercial and residential development and roads and the current noise levels produced by traffic, residences, and businesses have diminished the habitat qualities required by this species. Furthermore, pygmy owl surveys conducted at 17 geographic locations in southern Arizona in the spring of 2020, including one in northwest Tucson with 67 call points, only detected this species in Ironwood National Monument, over 20 miles west of the project area (USFWS 2022: Figure 4.5).
Environmental Information Document for the Northwest Wellhead Treatment Project 11
(species name)
Status* Range or Habitat Requirements Potential for Occurrence in Project Area
Determination of Effect
California least tern (Sterna antillarum browni)
E Forms nesting colonies on barren to sparsely vegetated areas. Nests in shallow depressions on open sandy beaches, sandbars, gravel pits, or exposed flats along shorelines of inland rivers, lakes, reservoirs, and drainage systems at elevations below 2,000 feet amsl. Found in Maricopa, Mohave, and Pima Counties.
Unlikely to occur. The project area is above the elevation range of this species and it does not contain beaches, sandbars, gravel pits, or exposed flats suitable for this species.
No effect.
Canelo Hills ladies’-tresses (Spiranthes delitescens)
E Found at elevations between 4,585 and 4,970 feet amsl in cienega wetlands, usually intermixed with tall grasses and sedges, on fine-grained, highly organic, saturated soils. Only known in four cienegas in southern Arizona.
Unlikely to occur. The project area is below the elevation range of this species, and it does not contain wetlands.
No effect.
Chiricahua leopard frog (Rana chiricahuensis)
T Restricted to springs, livestock tanks, and streams in the upper portions of watersheds at elevations between 3,281 and 8,890 feet amsl in central, east-central, and southeastern Arizona.
Populations in central and east-central Arizona are disjunct from those in southeastern Arizona and may be distinct species.
Unlikely to occur. The project area does not contain aquatic habitat.
No effect.
Desert pupfish (Cyprinodon macularius)
E Found in shallow waters of desert springs, small streams, and marshes at elevations below 5,000 feet amsl. One natural population still occurs in Quitobaquito Spring and Quitobaquito Pond in Pima County, and reintroductions have been made in Pima, Pinal, Maricopa, Graham, Cochise, La Paz, and Yavapai Counties.
Unlikely to occur. There are no perennial water sources in the project area.
No effect.
Gila chub (Gila intermedia)
E Normally found in smaller headwater streams, cienegas, and springs or marshes of the Gila River Basin at elevations between 2,720 and 5,420 feet amsl.
Unlikely to occur. There are no perennial water sources in the project area.
No effect.
Gila topminnow (incl. Yaqui) (Poeciliopsis occidentalis)
E Occurs in small streams, springs, and cienegas at elevations below 4,500 feet amsl, primarily in shallow areas with aquatic vegetation and debris for cover.
In Arizona, most of the remaining native populations are in the Santa Cruz River system.
Unlikely to occur. There are no perennial water sources in the project area.
No effect.
Huachuca water umbel (Lilaeopsis schaffneriana var.
recurva)
E Semi-aquatic to aquatic perennial found in shallow water or saturated soil of cienegas or marshy wetlands at elevations between 4,000 and 6,500 feet amsl. Known from the Huachuca Mountains, Canelo Hills, headwaters of the Santa Cruz River to Black Draw, and the San Pedro River.
Unlikely to occur. There are no wetlands in the project area, and the project area is outside the range of this species.
Environmental Information Document for the Northwest Wellhead Treatment Project 12
(species name)
Status* Range or Habitat Requirements Potential for Occurrence in Project Area
Determination of Effect
Jaguar (Panthera onca)
E Although jaguars were once more common in southern Arizona, currently they are most associated with expansive rugged areas within the Madrean evergreen woodland and semidesert grasslands biotic communities and distant from human presence and roads while near water, prey, and cover in the mountain ranges of southeastern Arizona.
Additionally, valley bottoms and drainage features may provide travel corridors for jaguars between these areas. In the past 27 years (1996–2023), there have been reliable and spatially accurate sighting records of seven, possibly nine, male jaguars (including five individuals sighted multiple times) in the mountain ranges and canyons in southeastern Arizona (USFWS 2024).
Unlikely to occur. The nearest recent occurrence record is from 2014 in the Santa Rita Mountains east of Tubac, approximately 50 miles south of the project area (Wildlife Conservation Society 2023).
No effect.
Kearney’s blue-star (Amsonia kearneyana)
E Found on dry, open slopes (20 to 30 degrees) at elevations between 4,000 and 6,000 feet amsl in the transition zone between Madrean evergreen woodland and interior chaparral. Also occurs at elevations between 3,600 and 3,800 feet amsl on stable, partially shaded, coarse alluvium along dry washes under deciduous riparian trees and shrubs in Sonoran desertscrub or desertscrub-grassland ecotone. Known only from a west-facing drainage in the Baboquivari Mountains.
Unlikely to occur. This species is only known from a few small populations in the Baboquivari Mountains, more than 40 miles southwest of the project area.
No effect.
Masked bobwhite (Colinus virginianus ridgwayi)
E Found at elevations between 1,000 and 4,000 feet amsl in desert grasslands with diverse, moderately dense native grasses and forbs and adequate brush cover. This subspecies has been found to be closely associated with prairie acacia (Acacia angustissima). Known only from reintroduced populations on Buenos Aires National Wildlife Refuge.
Unlikely to occur. The project area does not contain grassland habitat, and it is over 40 miles northeast of the Buenos Aires National Wildlife Refuge.
No effect.
Mexican spotted owl (Strix occidentalis lucida)
T Found in mature montane forests and woodlands and steep, shady, wooded canyons. Can also be found in mixed-conifer and pine-oak vegetation types.
Generally nests in older forests of mixed conifers or ponderosa pine (Pinus ponderosa)–Gambel oak (Quercus gambelii). Nests in live trees on natural platforms (e.g., dwarf mistletoe [Arceuthobium spp.] brooms), snags, and canyon walls at elevations between 4,100 and 9,000 feet amsl.
Unlikely to occur. The project area does not contain woodland or forest habitat, and it is below the elevation range of this species.
Environmental Information Document for the Northwest Wellhead Treatment Project 13
(species name)
Status* Range or Habitat Requirements Potential for Occurrence in Project Area
Determination of Effect
Monarch butterfly (Danaus plexippus)
C A migratory species found in a variety of habitats, monarch butterfly requires milkweed (Family Asclepiadaceae) for breeding (USFWS 2021). During fall migration in Arizona, monarchs favor nectar from native plants including sunflowers (Helianthus spp.), rabbitbrush (Ericameria spp.), desertbroom (Baccharis sarothroides), sweetbush (Bebbia juncea), thistles (Family Asteraceae), mule-fat (Baccharis salicifolia), milkweeds, and a variety of other native and garden plants (Morris et al. 2015). Populations in Arizona can migrate either to California or Mexico for winter (USFWS 2021) or may overwinter in the low deserts in California or Arizona (Morris et al. 2015). In the southwestern United States, migrating monarchs often occur near water sources (e.g., rivers, creeks, riparian corridors, roadside ditches, irrigated gardens) (USFWS 2021). In the low deserts of Arizona, monarchs breed in late August to early September (Morris et al. 2015).
May occur. Milkweed plants that could be used for reproduction were identified within the project area, and flowering plants are available within the project area and vicinity that this species could use while foraging. Project construction would result in up to approximately 5 acres of ground disturbance, which may include the removal of landscaping and pockets of native vegetation.
May impact individuals, but is not likely to result in a trend toward federal listing or loss of viability.
Nichol’s Turk’s head cactus (Echinocactus horizonthalonius var.
nicholii)
E Found in Sonoran desertscrub with limestone-derived alluvium at elevations between 2,000 and 3,600 feet amsl.
In Arizona, its known range is limited to the Waterman and Vekol Mountains.
Unlikely to occur. The project area is outside the limited range of this species.
No effect.
Northern Mexican gartersnake (Thamnophis eques megalops)
T This species is most abundant at elevations between 3,000 and 5,000 feet amsl in densely vegetated habitat surrounding cienegas, streams, and stock tanks, in or near water along streams in valley floors and generally open areas, but not in steep mountain canyon stream habitat (Rosen and Schwalbe 1988).
Considered extant in fragmented populations within the middle to upper Verde River drainage, middle to lower Tonto Creek, Cienega Creek, and a small number of isolated wetland habitats elsewhere in southeastern Arizona.
Unlikely to occur. There are no aquatic or semi-aquatic habitats in the project area.
No effect.
Ocelot (Leopardus (=Felis) pardalis)
E In Arizona, this species has typically been observed in subtropical thorn forest, thornscrub, and dense, brushy thickets at elevations below 8,000 feet amsl and is often found in riparian bottomlands.
The critical habitat component is dense cover near the ground and complete avoidance of open country. In Arizona, there are five recent confirmed sightings of ocelot in Cochise County between 2009 and 2012, one near Globe (2010), and unconfirmed sightings in the Chiricahua and Peloncillo Mountains.
Unlikely to occur. The species is very rare, and there are no dense, brushy thickets or riparian bottomlands in the project area.
Environmental Information Document for the Northwest Wellhead Treatment Project 14
(species name)
Status* Range or Habitat Requirements Potential for Occurrence in Project Area
Determination of Effect
Pima pineapple cactus (Coryphantha scheeri var. robustispina)
E Found on alluvial bajadas in sand or rocky loam soils that are on slopes with less than 10% grade within desert grassland and Sonoran desertscrub at elevations between 2,800 and 3,500 feet amsl.
In Arizona, found in the Santa Cruz and Altar Valleys and the Patagonia Mountains.
Unlikely to occur. While the project area contains Sonoran desertscrub, it is outside the geographical range and below the elevational range of this species.
No effect.
Sonora chub (Gila ditaenia)
T Found at an elevation of approximately 3,900 feet amsl in perennial and intermittent small to medium-sized streams, where it prefers pools near cliffs, boulders, or other cover in stream channels. In Arizona, its range includes Sycamore Creek and Peñasco Canyon in the Atascosa Mountains and California Gulch in Santa Cruz County.
Unlikely to occur. There are no perennial water sources in the project area.
No effect.
Sonoran pronghorn (Antilocapra americana sonoriensis)
E/EXPN Found in Sonoran desertscrub within broad, intermountain alluvial valleys with creosote (Larrea tridentata)–bursage (Ambrosia spp.) and paloverde–mixed cacti associations at elevations between 2,000 and 4,000 feet amsl. The only extant U.S. population is in southwestern Arizona in extreme eastern Pima County, southwestern Maricopa County, eastern Yuma County, and southern La Paz County.
Unlikely to occur. The project area is outside the range of this species.
No effect.
Sonoyta mud turtle (Kinosternon sonoriense longifemorale)
E In Arizona, found only in pond and stream habitat at Quitobaquito Springs in Organ Pipe Cactus National Monument. This subspecies of the more common Sonora mud turtle (Kinosternon sonoriense sonoriense) also occurs in Rio Sonoyta, Mexico.
Unlikely to occur. The project area is outside the limited range of this species.
No effect.
Southwestern willow flycatcher (Empidonax traillii extimus)
E Found in dense riparian habitats along streams, rivers, and other wetlands where cottonwood, willow, boxelder (Acer negundo), saltcedar (Tamarix sp.), Russian olive (Elaeagnus angustifolia), buttonbush (Cephalanthus spp.), and arrowweed (Pluchea sericea) are present.
Nests are found in thickets of trees and shrubs, primarily those that are 13 to 23 feet high, among dense, homogeneous foliage. Habitat is found at elevations below 8,500 feet amsl.
Unlikely to occur. There is no riparian habitat present in the project area.
Environmental Information Document for the Northwest Wellhead Treatment Project 15
(species name)
Status* Range or Habitat Requirements Potential for Occurrence in Project Area
Determination of Effect
Yellow-billed cuckoo (Coccyzus americanus)
T Typically found in riparian woodland vegetation (cottonwood, willow, or saltcedar) at elevations below 6,600 feet amsl. Dense understory foliage appears to be an important factor in nest site selection. The highest concentrations in Arizona are along the Agua Fria, San Pedro, upper Santa Cruz, and Verde River drainages and Cienega and Sonoita Creeks. Migration and wintering habitat needs are not well known, although they appear to include a relatively wide variety of conditions. Migrating yellow-billed cuckoos have been found in coastal scrub, second-growth forests and woodlands, hedgerows, forest edges, and smaller riparian patches than those used for breeding.
Unlikely to occur. There is no riparian habitat present in the project area.
No effect.
Range or habitat information is from AZGFD (2023b); Arizona Rare Plant Committee (ca. 2001); USFWS (2023b); and Corman and Wise-Gervais (2005).
* USFWS Status Definitions
C = Candidate. Candidate species are those for which the USFWS has sufficient information on biological vulnerability and threats to support proposals to list as endangered or threatened under the ESA. However, proposed rules have not yet been issued because such actions are precluded at present by other listing activity.
E = Endangered. An animal or plant species in danger of extinction throughout all or a significant portion of its range.
EXPN = Experimental Population, Non-Essential. Experimental populations of a species designated under Section 10(j) of the ESA for which the USFWS, through the best available information, believes is not essential for the continued existence of the species. Regulatory restrictions are considerably reduced under an EXPN designation.
PE = Proposed Endangered. Proposed endangered species are those that are not currently federally protected under the ESA but are eligible to be listed as endangered under the ESA.
T = Threatened. An animal or plant species likely to become endangered within the foreseeable future throughout all or a significant portion of its range.
Environmental consequences of the project on sensitive biological resources would include potential impacts from ground-disturbing activities, vegetation removal, and the presence of workers and equipment.
Ground disturbance and vegetation removal would occur during construction on up to approximately 5 acres over the 2- to 3-year anticipated construction timeline. A portion of this area includes landscaping or other vegetation that may provide limited wildlife habitat. The project is located in an urban environment and effects to vegetation would be limited to the removal of some areas of landscaping. Removal of native plants protected under the NPL would require an ADA
Notice of Intent to Clear Land form.
Ground-disturbing and vegetation removal activities could impact migratory birds protected under the MBTA if the activities occur during the migratory bird nesting season (generally mid-
February–October). Ground-disturbing and vegetation removal activities outside the nesting season are not anticipated to result in impacts to migratory birds. Clearing vegetation outside the migratory bird nesting season and/or conducting preconstruction surveys would reduce potential impacts to nesting migratory birds.
Environmental Information Document for the Northwest Wellhead Treatment Project 16
Environmental Consequences of the No Action Alternative
No impacts to sensitive biological resources would occur under the No Action Alternative because no construction activities would occur.
3.6 Water Resources
Surface Waters
The following sources were reviewed for potential surface and groundwater resources: recent aerial imagery available online (Google Earth 2023); the USFWS’s NWI data viewer (USFWS
2023); the EPA’s Watershed Assessment, Tracking, and Environmental Results System, Surface
Water Information System, which includes National Hydrography Dataset features (EPA 2023);
Arizona Department of Environmental Quality (ADEQ) eMaps (ADEQ 2023a); and the
U.S. Geological Survey (USGS) topographic map (USGS Jaynes, Arizona 1:24,000-scale quadrangle) (USGS 2023).
The proposed project area is located within the Lower Cañada del Oro (12-digit hydrologic unit code 150503010908) and Ruelas Canyon-Santa Cruz River watersheds (hydrologic unit code
150503010807) which are approximately 24,171 and 46,208 acres in size, respectively (EPA
2023). The Santa Cruz River is the primary receiving water for streams in these watersheds; it is located approximately 1.1 river miles downstream of the project area via the Cañada del Oro Wash
(USGS 2023).
No permanent surface water bodies are in or near the project area, and the only waterways present are the ephemeral Cañada del Oro Wash and the Carmack Wash stormwater channel. The
USFWS’s NWI maps both modeled features as R5UBH (USFWS 2023a), which translates to riverine, unknown perennial, unconsolidated bottom, and permanently flooded (Cowardin et al.
1979), while the National Hydrography Dataset simply classifies them as stream/rivers (EPA
2022). These ephemeral washes can be assumed to be waters of the United States (WOTUS) under the jurisdiction of the U.S. Army Corps of Engineers (USACE) because they are tributaries to the
Santa Cruz River, a designated traditional navigable water.
Water Quality
One impaired waterbody is located within 1 mile of the project area: the Santa Cruz River (ADEQ
Assessment Unit 15050301-001), approximately 0.84 mile to the west, is designated as impaired for Escherichia Coli (E.
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