"I'm Exceedingly Impressed"

Gary Pearson, Tom Nelson, Jean Findley and Cliff Looney at Bob's Steakhouse in Nyssa

"I'm exceedingly impressed in how far you've gotten in such a short time." Tom Nelson, Utility, Energy and Condemnation Law, began his remarks to well over 400 people in FRCC's Snake River Room Monday night by noting that things could be worse: Idaho Power is one of those companies that is still interested in what their customers think.

He expressed the desire to save everyone a lot of grief and expense by having our group convince Idaho Power move the transmission line without going to court. "They didn't stop to think about a whole range of issues," he noted, issues such as not inviting residents of all six counties to have input on the siting of the transmission line.

Bruce Corn & Clinton Kennington overlooking the valley with Tom Nelson

"What you've done so far is excellent," he told the crowd. But when it comes to what happens next, he outlined two paths that will be taken concurrently:

(1) The Federal Environmental Path. National Environmental Policy Act (NEPA) requires that IP file an EIS (Environmental Impact Statement) since they intend to cross Federal land, in this case, 11% of the time. Nelson observed that that IP did not appear to have fully analyzed and evaluated possible alternatives to their chosen corridor.

(2) The State Siting Track. The EFSC (Oregon Energy Facility Siting Council) is a one-stop approval process for determining whether a site certificate (permit to build) should be issued. The hearing is conducted like a court case: "It can be exhausting, time consuming, expensive, and thorough," said Nelson. Anyone with standing can participate. The SIP Board of Directors has already determined that they are willing to go to the expense this process would entail. When all testimony is given in these hearings, Nelson continued, an Administrative Judge will recommend to the EFSC whether a site certificate should be issued for actual construction of the line.

Need for the facility must be proven, something that may now be in question due to the precipitous decline in the economy. If this process actually results in the awarding of a site certificate to IP, they must still go through the condemnation process, which can be litigated by 400 individual landowners in Malheur County and dozens in Owyhee and Baker Counties.

Nelson stressed several points: First, "how immensely proud you should be of your organizing committee. Your relationship with the County Court is excellent.

"The second point is one of unity. You'll be approached individually. Unity and cohesion are critical. . . If Idaho Power calls and says 'I want to meet with you,' say No Thanks, I don't want to meet. My land is NOT FOR SALE. Tell your neighbors! You'll be way ahead.

"Your ultimate goal isn't to kill transmission capacity. You can have it off to the west and off to the north. . .

"Idaho Power's road is not easy. Malheur County has a lot to say. If I were the folks that work in the top floor in Boise, I wouldn't be sleeping well. You can let them know in a persuasive, professional manner, they blew it when they put (the transmission line) down the middle of the valley. . . You will be most effective by convincing Idaho Power that they don't want to dance in Malheur County. IT WILL BE UGLY."

Questions following Nelson's presentation addressed the support of Owyhee County for the Option 2 line as long as it moves farther away from private land; the condemnation process and how this will not benefit anybody; and the desire of other smaller groups in Parma, Owyhee and Baker to retain Tom Nelson to represent them as well.

Thanks to Ken Teramura for the use of his photographs.

2 Important Meetings Coming Up!

(1) Friday, January 9th, 6:30 p.m. at the Boulevard Grange with Oregon State Senator Ted Ferrioli. This will be a Town Hall meeting and the main subject will be the 500 kV transmission line. Senator Ferrioli is interested in meeting local residents, so please stop in.

(2) Monday, January 12th, 7:00 p.m. at the Four Rivers Cultural Center in Ontario. Energy and Utility Law Attorney Tom Nelson will be there to answer your questions. Bring everyone you can to this meeting.

• Roger Findley will bring us up to date on what has happened since our last meeting.
• Bring any petitions you may have had signed.
• You can buy vinyl No Entry signs for $5.00 each. Post these everywhere you can.

If you have an interest in the economic future of Malheur County, you need to come to this meeting. "Get Involved Now or Suffer Later."

Meeting Dates

Meeting dates for the next few weeks:

Monday January 5th 7:00 p.m. Board of Directors meeting at Vo-Tech building TVCC

Friday January 9th 6:30 p.m. (UPDATE earlier time) Senator Feriolli Town Hall meeting at the Boulevard Grange. All invited! Please join us and have a talk with Senator Feriolli.

Monday January 12th 7:00 p.m. Monthly meeting at the Four Rivers Cultural Center. Everyone is invited to this one. We'll be talking with Attorney Tom Nelson, Utility and Energy Law. Bring everyone you know. We will be posting the agenda in the near future.

No Path of Least Resistance Here

Grotesque contortions of proposed transmission lines into Malheur County so Ada and Canyon County residents can avoid having to look at 12-story towers.

Possible larger loop with relocated substation (click for larger picture)

We had a good turnout at our Monday night Grange meeting in spite of the weather. Roger Findley gave a presentation on what has happened since our last meeting:

1. Durkee Meeting
2. Owyhee County Commissioner Jerry Hoaglund
3. Retaining legal counsel, Attorney Tom Nelson, Utility and Energy law
4. Letter written by Jean and Roger Findley to Oregon agencies and affected counties (Owyhee, Gem, Malheur and Payette) requesting 2 corridors
5. Proposed wider circle avoiding all private land

including quotes from the 38-member Ada and Canyon County all-Idaho siting committee, some of which are printed below for your amusement:

• "Can the 500 kV line extend into Oregon? "
• "Can we go beyond the Treasure Valley and hide the 500kV line in the mountains?"
• "Can transmission lines be placed in hills or steep country?"
• "Stay away from ridgelines"
• "Don’t go too close to Emmett bench on north side"
• Don’t want a source substation in the view shed in Canyon County, especially in the Lake Lowell area"
• "Want to push the source and hub substations more to the west"
• "Can it go into Oregon, it’s not as developed?"
• "Run transmission lines through the draws so the whole valley does not see"

Bruce Corn reported on

1. Meetings with the BLM and the Malheur County Court, giving high praise to County Judge Dan Joyce for his efforts to inform Oregon officials and agencies on what is happening here.
2. County Planner Jon Beal asks for help in assembling soil classifications. If you have this information, please send it to him!
3. Contacts with Ron Wyden's aide, Wayne Kinney, and Scott Fairley, Gov. Kulongoski's office

Lisa Davis reports that Federal loans will not be made on property under transmission lines, rendering it much less valuable and in some cases, unsellable.

Jean and Roger Findley submitted a letter to state officials requesting that IP's Notice of Intent be rejected until it proposes alternate corridors as required by Oregon law, and include a cost benefit analysis of crossing agricultural land rather than uninhabited public land:

1. Option 1: Buchanan between John Day and Boardman. This is the longest of the 3 options but encourages moving the Sand Hollow substation to north of Payette, and crosses no private land. Cost cannot be the sole consideration for utility placement.


2. Option 2: PP&L line, Grassy Mt. south of Vale behind Bully Creek and Huntington Junction, then along the freeway


3. Option 3: Through Canyon County. Note: one of the attendees at our meeting, a resident of Canyon County under the less than two miles of corridor through Parma, is very upset and supports our citizens' group request that Option 1 route be followed.

The entire group voted unanimously to adopt the non-profit organization Bylaws written up by Vale Attorney Cliff Looney, and voted unanimously for the 20 Board of Directors

1. Roger and Jean Findley
2. Tom and Pat Phillips
3. Clint and Patty Kennington
4. Bruce Corn
5. Cliff Looney (our SOLE contact with Attorney Tom Nelson)
6. Farrell Larson
7. Evelyn Sayers
8. Gary Pearson
9. Ken Teramura
10. Grant Kitamura
11. Larry and Rod Price
12. Dick Davis
13. Stacey Trenkel
14. John Faw
15. Alice Ure
16. Eric White

Many thanks to all those who agreed (some with a little arm twisting) to serve. The Board of Directors will elect officers and open a bank account for our fund raising efforts, which went very well last night. If the more than 400 households under 30 miles of lines each contribute $100, we will have more than sufficient for legal and engineering counsel.

Bob Kemble, CPA for Pete Nichols is doing 501-C and non-profit status free of charge. Any monies not used will be prorated and returned.

Sue Kurth had prototype vinyl "No Entry for Purposes of Obtaining Easements/Rights-of-way" signs made up. We voted for the ones shaped like stopsigns (if ODOT allows us to use that shape). If not, large rectangular signs will be available for approx. $5.00 at our next meeting.

New petitions requesting Idaho Power to reroute these lines in alternate corridors are available for download and printing and signing. Please return these petitions at our next meeting.

Jean Findley and Evelyn Sayers have divided Malheur County into 8 areas for the purpose of informing ALL county residents of the proposed lines, since there are still those who don't know about it. Each group leader will have maps, letters to neighbors and the new petition asking IP to reroute its line. These eight areas are:

1. Oregon Slope
2. South of 20-26 near Lincoln. Pat Trenkel has volunteered for this group.
3. Vale west of the Butte
4. South of 20-26, north of Imperial. Donna Kemble has volunteered for this group.
5. North of Nyssa--Bruce Corn will take this.
6. South of Nyssa, south of Alberta and Owyhee Corners - Melda Schiemer will do part of this
7. North of Adrian-Jackass Flats - Pat Bashaw is helping here
8. South of Adrian. The Prices will take this one.

Please let Jean or Evelyn know if you can help with #1 or #3.

Action Plan:

• Next meeting: Monday, January 12, 7:00 p.m. at the Four Rivers Cultural Center in Ontario.
• Write more letters! More letters! More letters!
• Pass around and sign New Petitions requesting IP to reroute the transmission lines, return by next meeting
• Vinyl No Entry signs for sale at next meeting
• Keep writing those checks!! And THANK YOU!! Grant Kitamura is collecting checks, make out to Stop Idaho Power and send to Finance Committee, P.O. Box 9, Ontario, OR 97914

Monday Dec.15th Meeting Agenda

Our meeting scheduled for Monday December 15th, 7:00 pm at the Grange Boulevard on Hwy 20-26 will address the following:

1. Updates on the County Court meeting with Tom Stoops, energy facility siting manager for Oregon; meeting with Wayne Kinney, aide to Oregon Senator Ron Wyden; meetings in Durkee and Keating (also under the proposed corridor)with Idaho Power


2. Non-profit bylaws, election of board of directors and officers (bring nominations if you have any)


3. Attorney Tom Nelson, Energy and Utility Law, retained


4. Additional reports, i.e. Jon Beal, Malheur County Planning, working on soil classifications and the designation of historic and/or scenic sites; our nonprofit "Group in Standing" requests the BLM to evaluate ALL corridors; County Court's request for Jim Johnson of the Oregon Department of Agriculture visit our corridor route


5. New petition asking Idaho Power to reroute its B2H transmission line (also downloadable under "Document links") Let's flood them with signatures!


6. UPDATED Addresses and bullet point handouts for PERSONAL letters to state representatives and agencies. Let them know how you, your family, your business, income, health, and your community will be affected if these lines are not rerouted. Be specific.
   
7. Vinyl NO TRESPASSING signs will be available to order (and to raise money)


8. Keep making donations! Pay now or lose it later.

Our next meetings will hopefully be held in the FRCC or in the Nyssa auditorium.

Monday, Dec. 15th Meeting

UPDATE - Because of scheduling conflicts, our next general meeting will be Monday, December 15th, 7:00 p.m. at the Boulevard Grange on Hwy 20-26. Please bring your neighbors, since the outcome of what happens will affect northeastern Malheur County for years to come.

At the meeting we will be brought up to date on what has been happening to further our cause, and what steps must be taken next.

Write Personal Letters to the Energy Siting Council
According to one well-placed source, writing personal letters about how 120-190 ft. transmission towers on 40-ft concrete pads through some of Oregon's best farm country will affect your family, your living and your future, will be among the most effective things you can do. You can use information on this blog, including letters, printed maps, points of concern, and quotes from blog posts to add to your letters.

The address is:

Energy Siting Council
Oregon Department of Energy
625 Marion St. NE
Salem, OR 97301-3737

Monday Nov. 17th Meeting

I talked to Bryan Wolfe of the Energy Siting Council. This is the council that actually has the power to condemn land. He said he would accept mail from me as a contact but didn't want to be inundated with letters, so please don't send any letters to the Hermiston address! You can send them to:

Energy Siting Council
Oregon Department of Energy
625 Marion St. NE
Salem, OR 97301-3737

They will also get the letters from the BLM and the ODOE and PUC. Bryan said they will most certainly have at least one meeting here. Larry Price of the Wheat League knows Lori Brogoitti, another of the council members, and has been in contact with her.

What is most important concerning the Siting Council is how can we educate our group and be informed on how the process works, so there will be more info coming. I think Bryan was surprised to hear from me so early, because there will be more public hearings on this process.

The Monday meeting went well, due to Professor Roger Findley's ability to keep meetings to about an hour. There were even more people at this meeting than the first one. Larry Meyer has done a great job covering the ongoing action for the Argus. A lot of property owners under the 3/4 mile transmission line zones were identified, and Jim Johnson of the Oregon Dept of Agriculture is interested in taking a tour along the route.

Bruce Corn reported on the meeting with the County Court, and Roger showed the circle maps and how IP has violated Page 48 of its own Treasure Valley Electrical Plan's Committee Consensus recommendations when it comes to Malheur County, explained about the condemnation process, committees to sign up for, writing checks, and make sure you don't let anyone on your land or sign right of ways!!! We must all hang together or we will all hang separately!

Someone suggested that we post signs warning anyone affiliated with Idaho Power or Sunstone that they must not assume they have the right to be on our property without permission. Roger Findley heard a rumor that Sunstone may be pulling back because of the economic downturn, but it has not been confirmed or denied.

Cliff Bentz explained about ethics rules in the Oregon legislature and how it makes it difficult for him to take action, since his law firm has represented Idaho Power in the past. He has done as much as he can under the ethics rules.

UPDATE Committee signups:

• HEAD BOSS CHAIR: Roger and Jean Findley, co-chairs
• COMMUNICATIONS: Patty Kennington and Pat Phillips, co-chairs, Pat Trenkel, Launa Frahm, Michaelann Seiders, Susan and Mike Kurth
• FINANCE: Grant Kitamura, chair, Katrina Trenkel, Staci Trenkel, Sandy Bowen, Pat Looney
• POLITICAL ACTION: Farrell Larson and Tom Phillips, co-chairs, Dan Andersen, Larry Price
• LEGAL: Cliff Looney, chair, Ken Teramura, Gary Pearson, Carrie Petterson, Debbie Hopkins, Clinton Kennington

The handouts that were available at the meeting are in our Document Links section, including suggested points for letters to political leaders. Greg Walden's office recommends that we flood our senators and representatives. I still don't have an address for Jeff Merkley, if someone has one I"ll post it. It hasn't appeared yet on the http://www.leg.state.or.us/ website, Gordon Smith is still there. Remember, you don't have to follow the Siting Standards for letters to your representatives.

You can keep writing letters to the BLM and ODOE using the Siting Standards. I'm sure they love getting them. If anyone isn't on our email list, get their email address to Pat Phillips at pat@tomphillipsagency.com

And while I'm at it, hello to you guys at Idaho Power! I hear you're a fan of the blog. :)

Monday night's meeting agenda

For our November 17th 7:00 p.m. meeting at the Boulevard Grange:

1) Bruce Corn reports on the County Commissioners meeting on Wednesday morning
2) Roger Findley reports on Idaho Power meeting Wednesday afternoon
3) Sign up for committee work, including the following:

• Finance. Are there any accountants who could answer some questions? Make out checks to Stop Idaho Power.
• Communications, including letter writing to political leaders, identifying landowners in the corridor (we will have maps on the wall to identify your property), and more email address signups
• Political contact committee to meet with elected and regulatory officials
• Legal committee to begin the process of vetting an attorney and identifying pertinent legal questions, case law and statutes concerning utilities and condemnation

Bring in any extra petitions, letters, address labels, etc.

We need everyone's help! Idaho Power is digitizing a GPS survey of alternate corridors, a good sign. The PUC website says on its B2H page: "Due to high volume the OPUC will not respond to comments individually." This means we're getting through! Keep it up! Thanks for all you've done, but we still have a long way to go.

I've categorized the links to make things easier to find. Several new documents are now posted under Document Links, including the ODOE Fact Sheet, Oregon Energy Siting Standards for comments to the BLM and ODOE, Points of Concern for Rerouting, and Bullet Points for Political Letters, including addresses. Copies will be available at the Monday Grange meeting.

We can't be reminded enough, don't respond to requests from utility companies to survey or even cross your land.

Monday mtg, property access, letter to the Gov

I'm drafting a letter to Governor Kulongoski, our state representatives, LCDC, Union and Umatilla Counties, etc. etc. They all need to know what's going on here. If anyone wants input, make a comment to this blog post or send it via email. I'll bring my letter to the meeting Monday night.

Don't forget: If anyone from Idaho Power contacts you about coming on your property, politely but firmly decline.

I've been looking at these "Circle Maps" from the Treasure Valley Electrical Plan, and the more I think about it, the less the idea of using any corridor across Malheur County farmland seems needful at all. Most of the line will be in Oregon already, so after it starts in Boardman, it should cross the Snake River into Idaho above Vale and Ontario, then stay there all the way to Hemingway instead of going 30 miles out of its way to recross the Oregon border to pick up farms in Nyssa and Adrian.

See you Monday night 7:00 p.m. at the Boulevard Grange.

Idaho Power Meeting Wednesday Afternoon

Jean Findley reports that a dozen or so Malheur County residents sat down with the Idaho Power people in Boise, who she says were cordial but insisted that the centerpiece to their transmission line was the proposed Sand Hollow substation. Roger Findley did the main presentation, Bruce Corn talked about the effect on farming, and Jean outlined alternate routes, including

• Grassy Mountain to Huntington Junction
• The Pacific Power and Light line to Buchanan, the designated BLM utility corridor
• Follow I-84

but Idaho Power claimed these alternates did not meet their needs.

The most astonishing piece of information was that when asked, IP admitted that NOT ONE OREGON RESIDENT was included in their corridor siting committee. This is insular thinking of the highest order, either that or unabashed cluelessness. They evidently have not dealt with Oregon land use laws before, or aggravated Oregonians, for that matter. This underscores the need to involve Oregon government officials and regulatory bodies as soon as possible. As one of my neighbors points out, they are finding Oregon's strict land use laws useful since there are fewer homes in their path, and "of course the public BLM land must have too many homes since they are using our private land."

IP was fairly surprised that our citizens' group is so well organized so early, and they further admitted that they have never before had to condemn property because everyone was willing to simply give it to them. No wonder the proposed transmission line corridor is a marvel of how to avoid crossing Idaho for the sake of Idahoans. They even said they couldn't run it through Idaho because it would CROSS FARM GROUND.

Jean made it clear that revising the siting inside Malheur County is NOT an option; we are not going to shove the transmission line a mile this way or a mile that way onto our neighbor's place.

Which reminds me, DO NOT LET ANYONE ON YOUR PROPERTY. Sunstone (Natural Gas Pipeline) has been doing environmental impact studies, you may see big helicopter X's painted on road intersections, and surveyors are out. Call the sheriff, if you must.

Jean said she believes IP was impressed with the seriousness of our group, especially when they were told we would be in the process of hiring an attorney. Since we have abided by Oregon land use laws for these last 30 years, IP must abide by them, too.

UPDATE Ken Teramura adds his observations of the meeting:

Their attention was drawn when:

• The petition with 1302 names on it.
• Exclusive Farm Use Laws in Oregon were violated
• Oregon Public Utilities must OK the project
• Farrell Larson said we will take it to the supreme court if necessary
• Mrs. Sayers comment that they will not be welcome on her property

We need at the Monday meeting:

• Get more names of people affected
• Contact Governor Kulongoski and PUC
• Check if Baker and other cities might have the same laws violated
• What to tell the person from Sunstone or Idaho Power on your property
• If the north route through Idaho is being contested
• Cost of legal counsel
• Keep people writing letters because Nov 14 might not be the final date

Monday Nov. 17th Grange Meeting!

If you think the last Grange meeting was full, make sure you're early for this one. We'll be meeting at the Boulevard Grange at 7:00 p.m. on November 17th to discuss the latest findings and what we intend to do next, including hiring a good attorney.

Meeting with Idaho Power

The meeting with our citizens' group and Idaho Power will take place Wednesday, November 12th at 3:00 p.m. The location is

Boise Plaza (formerly Boise Cascade)
1111 Jefferson St
Boise, ID 83728

Renae Corn talked to Eric Hackett and got his FAX number. She reports that he said that the cutoff date of Nov. 14th for public comment will "not negate comments if they come in after that." (Believe this at your own peril.)

ehackett@idahopower.com
Eric Hackett, Project Manager
P.O. Box 70
Boise, ID 83707208-388-5712

UPDATE Evidently I posted the wrong FAX number, which was actually the number of a co-worker. I'll have to wait until I get the real one.

Idaho Power Transmission Line Project Meeting Notes

This blog is a response to Idaho Power's Boardman to Hemingway Transmission Line Project Notice of Intent to place 500kV transmission towers through a 2-mile-wide corridor across prime farmland in Malheur County, Oregon.

The Notice of Intent was introduced to Malheur County at an informational meeting held Wednesday, October 22, at the Four Rivers Cultural Center in Ontario.

Approximately 250-300 citizens whose property will be affected by these transmission lines met Monday, November 3 at the Boulevard Grange.

Roger Findley, Natural Resources Instructor at Treasure Valley Community College, conducted the meeting, introducing the following agenda:

1. The goal of the citizen's group is to relocate the Idaho Power 5000 kV transmission line out of Exclusive Farm Use (EFU) land.

2. The mission is to discuss and develop options to achieve the goal, and to maintain communication with local citizens.

3. Overview: "Notice of Intent" is a 299 mile long, 2-mile-wide corridor that would contain a 250 right of way, including access roads, from Boardman, Oregon, to a substation in Sand Hollow, Idaho, crossing again into Oregon and then to a substation in Hemingway, Idaho.

These 12-story lattice transmission towers are 120 feet tall and 30 feet across at the base. Once a corridor is established, more power lines can be installed. Plans are in motion to also route a 42" gas line in an accompanying corridor. An example of a power line photo at Succor Creek was supplied by Jean Findley.

4. The NOI must provide alternative routes to EFU land, according to ORS 215.275. Criteria to determine public service were listed on a fact sheet:
a) tehnical and engineering feasibility
b) locationally dependent
c) lack of available urban and nonresource lands
d) availability of existing right of ways
e) public health and safety
f) other requirements of federal and state agencies

5) The siting committee (EFSC) process in public information meetings

6) Construction completed by 2012 "Fast Track"

7) Siting decision making council must include two from Eastern Oregon

8) Comments must be submitted by November 14 to the BLM and DOE. There is no recourse if comments are not submitted by this date.

Idaho Power has retained a private assessment firm, Tetra Tech, to do the Environmental Impact Statement.
89% of the 299 miles is now routed through private lands, including prime farmland.
Comments to the DOE and BLM are technically not supposed to address:

1. loss of property value (estimated to be 5% to 15% for those whose lands are affected) and


2. health issues such as the affect transmission lines may have on human beings.

9. Cited EFSC Standards (from Fact Sheet) to base DOE and BLM comments on:

• Safety and health; possibly, productivity of livestock


• General standards of review


• Organizational and expertise to build; this is the biggest project Idaho Power has ever undertaken


• Structural standards


• Soil protection


• (The most valuable point for comment purposes) Land use, espeically Exclusive Farm Use. A local commission OR Energy Siting Council MUST abide by Malheur County standards.


• Protected areas


• Retirement and financial (letter of credit in order to complete project)


• Threatened and endangered species; hawks, peregrine falcons, owls, etc.


• (another valuable point for comments) Scenic and aesthetic values, together with


• Historic, Cultural and Archeological Resources, including Malheur Butte, a landmark on the Oregon Trail; Mitchell Butte, and the overview at Trenkel Hill. John Beal, Malheur County Planning Commission, reports that Malheur County has no "scenic views" listed in its county plan.


• Recreation; Country View Golf Course


• Waste minimization


• Carbon Dioxide Emissions


• Need Standard for Nongenerating facilities

Other comments, although not listed on the siting standards, may include the following:

• Health issues


• Decrease in property value (lowered tax revenue to county and state)


• Aerial application of pesticides, sprinkler and center pivot irrigation systems


• TDML (Total Maximum Daily Load) for DEQ Clean Water Act standards for the Malheur River Allocation Watershed Council, which are in the process of eliminating surface flow irrigation


• Proximity of the Ontario Municipal Airport


• The use of "Utility Corridors" already identified by the BLM and established in Land Use Plans


• Send comments to BLM, ODE and Malheur County Planning in Vale

A subcommittee including Roger Findley, Bruce Corn, Ty Frasier, Mike Lovaas, Farrell Larsen, Evelyn Sayers, Ron Jones, John Beal and a member of the Malheur County Court will be meeting with Idaho Power to introduce an alternate plan and offer resistance to the current plan. If this is not successful, the entire group will meet again to plan strategies including retaining legal counsel and beginning subcommittee work with government agencies and alternative routes.