Save Our Scenic Area (SOSA)
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Save Our Scenic Area (SOSA)
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Thank you all for attending and commenting during the recent EFSEC held public hearings. It was great seeing everyone and hearing all of the valuable comments.A recent article in the Columbian might be of interest, which declares wildlife concerns when you put the Whistling Ridge Wind project in forest land. We thought you might also be interested in reading the recent letter from the Department of Fish and Wildlife, submitted as their comments to EFSEC. The text is as follows: MWR-07-09 May 18, 2009 Allen J. Fiksdal, EFSEC Manager Energy Facility Site Evaluation Council P.O. Box 43172 905 Plum Street SE Olympia, WA 98504-3172 SUBJECT: Whistling Ridge Windpower Project, EFSEC Application No. 2009-01 Dear Mr. Fiksdal: The Washington Department of Fish and Wildlife (WDFW) has reviewed the above-referenced documents and offers the following comments at this time. Other comments may be offered as the project progresses. General Comments Based solely on the data contained in the application, and subsequent data that will likely be presented in the EIS, the proposed Whistling Ridge Wind Energy Project could have adverse impacts to birds and bats. Therefore, WDFW is in full support of additional studies, as identified in section 2.17.2, specifically, northern goshawk and bat surveys. However, it is unlikely that the additional data on northern goshawks, northern spotted owls, and bats coupled with the existing avian and bat data will alleviate the concerns we have with potential impacts to birds and bats with this wind energy project. The habitat is predominately managed coniferous forests, a characteristic that has likely resulted in the high raptor, bat, and bird use/occurrence recorded at this site, and a habitat type that has little to none avian and bat data, impacts, and conclusions associated with wind energy development. There is a lack of comparable wind power projects in coniferous forests any where in the U.S. from which we can assess preconstruction avian and bat data with operational fatality. However, based on the data and statements such as, “thus, based solely on the presumed relationship between pre-construction bat activity and post-construction fatalities, bat mortality rates at SWRA may be higher than many other wind resource areas in the U.S” and “based on data collected during this study, raptor use of the Saddleback project area is…moderate to moderately high compared to most other WRAs evaluated throughout the western and Midwestern U.S” our approach to this project at this point in time is to proceed cautiously, carefully consider, protect, and conserve the natural resources of the site and adjacent lands, and slow down the incentivized green energy freight train that is barreling through the State of Washington. Specific Comments We recommend that the information presented on the Northern Goshawk, a State Candidate Species for listing and a Federal Species of Concern, be consistent throughout the application. For example, on Page 1-8 it states that “although no goshawks were detected during protocol surveys, individuals were spotted during general avian migration and breeding surveys.” This is in contrast to the information in Section 2.17.2 that states “no goshawks were found on the project site, nor were any observed on any surrounding properties. It is highly unlikely that goshawks will be found on the project site…” However, the data in Appendices B-5 and B-6 indicate that northern goshawks were recorded during both the Fall 2004 and Summer 2006 surveys. Additionally, Section 2.17.2 states that goshawk, and other avian species surveys were conducted ion 2004, 2005, and 2008. The appendices indicate that these surveys were also conducted in 2006. We recommend that any statements addressing raptor mortality of operational wind power projects in shrub-steppe and agricultural habitats with the anticipated raptor mortality of this site be removed from any future reports as they are misleading. They are misleading because “other new wind plants in the Pacific Northwest” are in shrub-steppe and agricultural habitats; not coniferous forest…” We appreciate that an attempt was made to suggest that raptor mortality “is expected to be low.” However, based on information in the application, raptor use of the site is high. In fact, …”raptor use of the Saddleback area in Fall is approximately 1.5 times higher than mean fall use at the other WRAs.” (in east Oregon and Washington) and that…”raptor use of the Saddleback project area…is moderate to moderately high compared to most other WRAs evaluated throughout the western and Midwestern U.S.” Comprehensive auditory surveys were conducted for northern spotted owls and goshawks in 2004 and 2008. While the 2004 goshawk surveys appears to include the proposed turbine string to the east of the “Cedar Swamp” the 2008 survey does not. Interestingly, one bird species, the Barred Owl, was recorded frequently during the northern spotted owl surveys, but was not included in any of the avian reports. Additionally, while no spotted owls were recorded, we question the suitability of a wind farm within one of the few spotted owl special management areas in the State of Washington. The bat data is extremely interesting and alarming in that “no data on bat mortality levels associated with wind energy developments in western coniferous forests are available to help predict risk to bats at the Saddleback Wind Resource Area.” The data in Table 4 in Appendix B-8 should serve as warning that the Whistling Ridge Project could result in bat mortality 3-4 times higher than any other wind power project in the U.S. From Table 4, bat activity is a fairly good predictor of bat fatality. Fatality is presented in the number of bats/turbine. Using the Saddleback bat activity data from the table (138.4 bats) with the proposed 50 turbines, almost 7,000 bats would be killed on an annual basis. However, “bat fatality patterns may differ from those in open habitats as well as in eastern deciduous forests.” The Turbine Timber Buffer (Figure 2.3-4), may reduce the typical open turbine string corridor, thereby reducing its appearance as an avenue for bird and bat travel, but may also attract birds and bats as a roosting, foraging, and nesting habitat. At this point, we recommend that additional discussions occur to develop the most suitable management actions along the turbine strings. We also recommend that sensitive features such as such as snags, water, Oregon white oak, and talus be identified as an aid to impact assestment. We look forward to working with all interested parties through the development of this project. Sincerely,
Michael Ritter Wind Mitigation Biologist
Whistling Ridge Wind Project (a.k.a Saddleback Wind Turbine Project)
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