2and enhancement measures that we believed were necessary for the Project to be issued a sitecertificate. Unfortunately, after a number of meetings, Horizon withdrew from the discussions.The siting of a wind energy project is the most important element in avoiding or minimizingimpacts to fish and wildlife species and their habitats.
Despite previous recommendations byODFW, a substantial part of the proposed facility siting is on either big game winter range or biggame critical wildlife habitat. It is also located on sage-grouse breeding and wintering habitatand within
mile from multiple sensitive raptor species nests. During wildlife surveysconducted throughout the Site Boundary, 20 state sensitive species (one state threatened bird,four state-critical birds, 12 state vulnerable birds, two state vulnerable mammals, and one stateendangered mammal) and nine federal species-of-concern were recorded. In addition, sixty-fiveactive and thirty-one inactive raptor nests were located within the analysis area, and seventy-fivespecies were identified during the forest breeding bird surveys.The Project is one of the first wind power projects in Oregon proposed to be sited in critical biggame winter range and very productive wildlife habitat, resulting in the potential construction of a large industrial facility that negatively impacts Oregon’s wildlife. Horizon proposes to erectturbines in an area referred to by ODFW as the Zone of Multiple Biological Values (ZMBV),comprised of habitat classified as either Category 1 or 2 under the Habitat Mitigation Policyrules (OAR chapter 635, division 415). Category 2 habitat in this area has been identified sincethe 1980’s when Union County adopted the county comprehensive land use plan.The number and diversity of sensitive species and critical habitats present, coupled with theimportance of the ZMBV to terrestrial species result in significant concerns with proposedProject siting. These concerns warrant implementing elevated post-construction surveying andmonitoring requirements and a higher standard for mitigating impacts to fish and wildliferesources compared to what would occur with development of wind power projects on a previously disturbed site (e.g. wheat fields). This is consistent with recommendations in theOregon wind energy siting guidelines.As such, attached are ODFW’s comments on Horizon’s ASC, including mitigation measuresODFW believes are necessary for the proposed Project to be in compliance with statutes, rules, policies and management plans related to Oregon’s fish, wildlife, and their habitats. Alsoenclosed are ODFW’s recommendations for monitoring that will be necessary to estimate actualProject impacts and evaluate adequacy of mitigation.These impacts, mitigation measures, and monitoring proposals include:1.
No construction in the ZMBV due to significant impacts to wildlife in a large block of nativehabitat without substantially increasing mitigation for impacts beyond Horizon’s current proposal.2.
An estimated 12–93 raptor fatalities per year including golden eagles.3.
Disturbance to six active golden eagle nest sites.