We sent a letter based on the text below to Nevada Division of Forestry, the state agency in charge of managing sensitive and rare plants.

Basin & Range Watch and Western Watersheds Project are requesting that the Nevada Division of Forestry deny issuing a special permit to NV Energy and their contractors to develop the Greenlink West Transmission Project on the habitat for the Sodaville milkvetch (Astragalus lentiginosus var. sesquimetralis) in Sarcobatus Flat, Nevada. Sodaville milkvetch is listed as state Critically Endangered in both Nevada and California, is ranked T1 by Natureserve,and is a Bureau of Land Management (BLM) Special Status Species. It is known from only five geographically isolated populations in alkaline wetland habitats in Nevada, and one population near the state line in Inyo County, California. All of the known populations are threatened by groundwater depletion, mining, energy development, recreation, grazing, and climate change. It appears that the planned construction of Greenlink West on Sarcobatus Flat would directly destroy a significant portion of one of these six populations and indirectly impact the remaining portion, and will likely cause the extirpation of this population. 

Astragalus lentiginosus var. sesquimetralis is a groundwater dependent perennial herb that occurs only in small portions of moist alkaline flats in basins between 3000 and 5000 feet. It is distinct from other Astragalusspecies due to its extremely restricted habitat, prostrate growth form, long stems, fruit shape, compact racemes, and flower morphology. 

The Final Environmental Impact Statement for Greenlink West failed to identify Astragalus lentiginosus var. sesquimetralis among likely impacted special status taxa in Sarcobatus Flat under the selected Scotty’s Junction Transmission Alternative ‘A’ despite botanical surveys along the route undertaken for years prior to the Record of Decision. [1] [2] On May 20, 2025, extensive survey stakes and ATV tracks were observed throughout the Sodaville milkvetch population and its habitat on Sarcobatus Flat. 

The Greenlink West Transmission Project has been approved by the Bureau of Land management and the first phase of construction has already begun between Kyle Canyon near Las Vegas to Amargosa Valley, Nevada. The BLM has recently issued a Notice to Proceed to allow construction from Amargosa Valley to the Esmeralda Substation. About 3 to 4 miles south of Scotty’s Junction on Sarcobatus Flat, Nevada, the Greenlink Project will be built on ¾ of a square mile of habitat for the Sodaville milkvetch one of only 6 populations in the world. The construction footprint of one pole and pad for the project would remove the bulk of the habitat in Sarcobatus Flat.  It would be possible to avoid this population if the Greenlink West line were moved just a quarter mile to the east. This would add minimal cost and time to the project, and the powerline poles would not have to be moved a great distance. 

Astragalus lentiginosus var. sesquimetralis is listed as a Nevada Critically Endangered Species. Nevada Revised Statute (NRS) 527 requires Nevada Division of Forestry to maintain and hold meetings about the protection and preservation of timbered lands, trees and flora.

The Nevada Natural Heritage Program (NNHP) is currently tracking over 600 species on either the tracking list or the watch list. Species placed on the tracking list are those species that NNHP actively maintain inventories for. Species placed on the watch list are those species that are considered to be of long-term concern.

Under Nevada Revised Statute (NRS) TITLE 47 - FORESTRY; FOREST PRODUCTS AND FLORA,CHAPTER 527 - PROTECTION AND PRESERVATION OF TIMBERED LANDS, TREES AND FLORA: 

NRS 527.270  List of fully protected species declared to be threatened with extinction; special permit required for removal or destruction. A species or subspecies of native flora shall be regarded as threatened with extinction when the State Forester Firewarden, after consultation with competent authorities, determines that its existence is endangered and its survival requires assistance because of overexploitation, disease or other factors or because its habitat is threatened with destruction, drastic modification or severe curtailment. Any species declared to be threatened with extinction shall be placed on the list of fully protected species, and no member of its kind may be removed or destroyed at any time by any means except under special permit issued by the State Forester Firewarden.

The BLM issued the Record of Decision for the Greenlink West Transmission Project in September 2024. This population of plants was first found by surveyors for the project proponent NV Energy two years ago. 

Despite knowing where this population is located and knowing how rare the species is, BLM is making no attempts to move the line just one quarter mile off this habitat.

The BLM is required to use special management to avoid and protect Special Status Species.

The species was not even discussed in the U. S. Fish and Wildlife Service Biological Opinion (BO) for the Greenlink West Transmission Project (GLWP), but the BO advises the following Environmental Management Measures:

            BIO 40, Page 283: “Permanent and temporary disturbances will avoid suitable      special status plant habitat, where feasible. Where disturbance must occur within      special status plant habitat, flagging and other appropriate means of demarcation            will be used to delineate areas of authorized activity. All activities will be confined to these areas.”   

The BO also advises micro- siting of poles and pads on special status species habitat. 

AMPS-15, Page 60: 

            Federally listed and Special status plant surveys will be conducted by qualified     botanists prior to construction for the plant species listed in Section 3.1 and 3.3 of   the EIS as having high or moderate potential of occurring within either the temporary or permanent disturbance areas for the GLWP. Surveys will be conducted during a season when target species are readily identifiable. Areas to be surveyed include those with known populations or records, suitable habitat, and/or modeled habitat. The exact timing, methodology, and survey locations for each plant species will be determined on a case-by-case basis in coordination with applicable land and resource management agencies. Surveys will be conducted prior to final GLWP siting and design so that GLWP facilities can be micro-sited to avoid special status plants where feasible. Survey        reports documenting the survey methodology, areas surveyed, and survey  results including the locations and number of special status plants found, and recommendations will be provided to the BLM and, if not on BLM land, the appropriate land management agency for approval prior to construction. Special status plant surveys will also be conducted within suitable habitat prior to new ground disturbance or vegetation maintenance activities during O&M and reclamation. (Emphasis added.)

It is technologically feasible to move this line about a quarter to one half mile away to avoid this population. The flat basin makes micro-siting feasible. 

For Greenlink West, the Right of Way is 600 feet wide in flat areas and 1,200 feet wide over passes. Those are the temporary construction Rights of Way and the permanent Right of Way would be 200 feet wide. There are survey stakes marking pads and new vegetation clearing throughout this entire population spanning about one half to three quarters of a square mile. Surveyors have already crushed some of these plants with all-terrain vehicles.

We are not asking for the construction to be stopped, but that the tower pad be moved off the habitat of this Nevada Critically Endangered Species and Bureau of Land Management Special Status Species. This can feasibly be accomplished to save this plant population. We would also like to see any invasive weeds on adjacent and disturbed areas controlled and removed preferably by hand and not using herbicides.