San Diego County U.S. Fish and Wildlife Service San Diego Gas & Electric

The generation and delivery of electricity involves extensive uses of land and water. In order to deliver electric power to all of California's residents, electric utilities maintain more than 670,000 miles of transmission line rights-of-way (ROW). Hydroelectric projects often preserve significant project lands that can benefit various plants and animals. The service territory of San Diego Gas & Electric (now owned by Sempra Energy) currently has more listed species - and species waiting to be listed - under the Federal Endangered Species Act (ESA) than any other area in the continental U.S.

In an effort to meet the energy needs of California while protecting threatened species, San Diego Gas & Electric adopted a system-wide multiple species Habitat Conservation Plan (HCP) covering 110 species. The development of this HCP included not only $1.2 million for the creation of a mitigation bank but also the development of an extensive and ongoing training program for construction maintenance personnel.

U.S. Fish and Wildlife Service (FWS) initially told Sempra that they did not need to mitigate for the Quino Checkerspot Butterfly when preparing their HCP. However, upon the species re-emergence in the service area, FWS has asked Sempra to amend their HCP to address the needs of the butterfly or apply for a separate "take" permit under Section 10 of the ESA. Either of these requests would seriously affect Sempra's maintenance schedule of it's existing transmission lines and create delays to any effort to expand the system in butterfly habitat areas.

Like many other complex systems, electric and gas systems require periodic maintenance to avoid shutdowns. Because utilities provide an essential service necessary for public health, safety and welfare, outages can cause serious economic and human health problems. In addition, lack of maintenance can be counter-productive to the goals of the ESA.

For example, electric systems, deferred maintenance has potentially serious consequences. Three of the most common are outages, equipment damage, and fire. If unperformed maintenance results in a fire, extensive damage to the habitat areas of concern, including the potential loss of many species can be expected. Ironically, the same activities that were prevented for the purpose of protecting habitat can facilitate that habitat's destruction by fire.