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ODFW Report Feb 2011-1

ODFW Report Feb 2011-1

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Published by: earthfixteam on Nov 15, 2011
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 1March 01, 2011Ms. Sue Oliver Oregon Department of Energy245 Main Street, Suite CHermiston, OR 97838Dear Ms. Oliver;The Oregon Department of Fish and Wildlife (ODFW) previously providedcomments on Horizon Energy’s (Horizon or Applicant) Notice of Intent to Applyfor an Energy Facility Site Certificate (June 01, 2009); Preliminary Applicationfor Site Certificate (December 02, 2009); and Response to Oregon Department of Energy’s (ODOE) First Request for Additional Information (May 09, 2010) for the Antelope Ridge Wind Farm (ARWF or Project). Within those comments,ODFW identified several Project siting concerns and recommended modificationsto Project siting to minimize impacts to fish and wildlife and their habitats. Themajority of ODFW’s concerns and recommendations, however, were notaddressed or incorporated into the Final Application for Site Certificate (ASC).The ODFW received Horizon’s Final ASC January 06, 2011. Based on ODFW’sreview of the Final ASC, serious concerns with the proposed siting of the Projectremain:1.
The Project as proposed does not avoid impacts to wildlife habitatclassified as Category 1 under the Habitat Mitigation Rules;2.
Horizon’s proposed mitigation measures are insufficient to avoid or mitigate anticipated impacts of the Project to fish and wildlife in habitatclassified as Category 2.3.
The preponderance of the evidence in the record does not support thelegal findings necessary for issuance of a site certificate (concerningcompliance with the Habitat Mitigation Rules and protection of listedspecies).As result, ODFW must recommend against issuance of a site certificate for the project as currently described in the Final ASC. ODFW believes issuance canoccur if the ASC is modified to reflect the mitigation recommendations inAttachment 1.ODFW is responsible for reviewing the ASC and assuring it complies withstatutes, rules, policies and management plans related to Oregon’s fish, wildlife,and their habitats. Therefore, ODFW met with Horizon staff on multipleoccasions in 2009 and 2010 to discuss Project siting, study needs and protocols,impacts, and mitigation. ODFW and Horizon discussed the avoidance, protection,
 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.
A potential sage-grouse lek discovered within the ZMBV on Ramo Flat.5.
An estimated 650 bat fatalities per year from direct and indirect impacts and mitigation for these fatalities.6.
An estimated 377-930 non-raptor bird fatalities per year and mitigation for these fatalities.7.
A directed survey for goshawk nests.8.
A 0.25 - 0.5 mile setback from raptor nests and the edge of rims and ridges.9.
Mitigation for displacement of elk and mule deer. After construction of the Elkhorn ValleyWind Project, deer and elk were displaced up to 1000 – 3000 meters from the tower strings.Displacement effectively removes between 25,000 – 59,000 acres of big game habitat.The avoidance, protection, and enhancement measures identified by ODFW and included in theattachment are necessary to minimize impacts to fish, wildlife, and their habitats and to providemitigation and monitoring measures that are consistent with statues, rules, policies, andmitigation plans related to Oregon’s fish, wildlife, and their habitats. Unless included in any sitecertificate issued for the Project, the certificate will not meet the legal standards for issuance.Please contact me if you have any questions on the comments provided or need additionalinformation from ODFW.Sincerely,Jon GermondHabitat Resources Program Manager Wildlife Divisioncc: Ron Anglin, Wildlife DivisionCraig Ely, Northeast RegionGary Miller, FWSValerie Franklin, Horizon EnergyAttachments: ODFW Comments on Horizon’s final Application for Site Certificate

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