Cut Back on Monitoring

April 2, 2016 - Bird and Bat Mortality Surveys are now being cut back at the Spring Valley Wind Project, Nevada.


While this project has one of the better monitoring programs we have seen, they still only surveyed a third of the project every two weeks. According to the Bureau of Land Management: Currently, there are no mortality surveys occurring at the Spring Valley Wind Project. Bat mortality surveys will resume again this fall and then bird and bat fatality monitoring will occur at year 5, 7, 10 and every fifth year following as outlined in the Avian and Bat Protection Plan.


The project is known to have killed two golden eagles since it was built, and those eagles were found incidentally (not found on surveys). Other birds killed include prairie falcons, eared grebes and saw-whet owls. In 2014, the project killed triple the number of bats than the BLM agreed to allow. They claimed to have solved this problem by enabling a cut-in speed for the turbines, but we have seen no official documentation on their numbers. The project was approved and built three miles from the Rose Guano Cave - a roosting colony of millions of Mexican free-tailed bats. We believe this project is killing more wildlife than we are hearing about and now the monitoring will be cut back even more.

Reports also show this project is producing a lower capacity than promised by the company, Pattern Energy.

Bats need all the help they can get, as white-nose syndrome fungal infection has now been reported from the West Coast: http://www.latimes.com/science/sciencenow/la-sci-sn-white-nose-bats-washington-20160331-story.html

Second Golden Eagle Killed at Spring Valley Wind Project

golden eagle

February 18, 2015 - Spring Valley NV - A second golden eagle was found dead on January 9, 2015, next to a wind turbine generator. The first golden eagle was found two years ago in February 2013. We found the second mortality record while examining the Year two cumulative impacts list October 2014 to Feb 14, 2015.

The following is from WEST, Inc. (Bureau of Land Management personal communication):

The GOEA [golden eagle] was at a scheduled search turbine, but was found incidentall y, not during a scheduled search (reported on incidental tab of report). In response to the GOEA fatality and per the Avian and Bat Protection Plan, we also completed searches of the 44 non-scheduled turbines. Only one fatality was documented during those extra searches (a horned lark). It is reported on third tab as an incidental since it was at one of the non-scheduled turbines (D7).

US Fish and Wildlife Service told us in a personal communication that this is under investigation.

Spring Valley Wind Project with More Bat Deaths than Predicted

August 18, 2014 - The eastern Nevada wind project that was built too close to a major roosting colony of Mexican free-tailed bats has been forced to change operations after its turbines killed triple the number of bats allowed under an agreement with federal regulators. Read more at the Las Vegas Review Journal:


http://www.reviewjournal.com/news/water-environment/bat-deaths-prompt-change-wind-farm

Study Plan for Spring Valley Wind Project

June 12, 2014 - The post-contruction wildlife surveying and monitoring plans are contained in this February 2014 Study Plan report (1.07 MB PDF). The report details how bird and bat mortality studies will be carried out: surveys for dead birds and bats would only be done every other week for the first year, and then only every few years for the lifetime of the project. We feel this will miss much data, many dead bird and bat carcasses that will be scavenged and missed.

A Curtailment Study was done in 2012, a Fall-Only Bat Survey will be done in2016, Bat Acoustic Surveys will be undertaken, Avian Use Surveys, Raptor Nest Survey, and Annual Reports.

Dead Northern Saw-whet Owl Found at Spring Valley Wind Project

February 27, 2014 - The bird mortality monitoring compliance for the Spring Valley Wind Project, located next to Great Basin National Park, Nevada on public lands reports a Northern saw-whet owl (Aegolius acadicus) mortality this winter. The find is “incidental” meaning it was not found during an official search. It makes one wonder what else is being missed and killed by the turbines. The nearby Swamp Cedars Area of Critical Environmental Concern is located right next to the wind farm and could be a breeding habitat for these owls.

The Northern saw-whet owl breeds in conifer forests, including pinyon-juniper woodlands. Some owls move seasonally, and saw-whet owls may have been nesting in the swamp cedars or traveling through the area. They usually nest in old woodpecker holes.

In Nevada they may be uncommon, although probably are more widespread because of the difficulty of detecting the bird. Nesting has been confirmed in the White Pine Range, the Toiyabe Range, and in Great Basin National Park.

They are named for their loud persistent night-time song during the breeding season. Mice and other small mammals make up most of their diet.

Bat and Bird Mortality at Wind Turbines

September 9, 2013 - A yearlong fatality monitoring at the Spring Valley Wind Project has revealed how numerous bats and birds have already died from turbine impacts. Biweekly reports are sent to Bureau of Land management biologists from contractors surveying the ground around the turbines. Environmental groups and concerned citizens had warned the agency that buildinga wind project a mere mile from an important roosting colony of Mexican free-tailed bats would result in mortality. Now Mexican free-tailed bats and other bats are being killed.

These daily numbers will be used to develop a curtailment plan. Fall daily searches began August 1. 40 turbines are searched.

Here is a tally of individial bat and bird carcasses recovered in plots around the turbines for approximately a year (corrected from a month):

Since October 2012, a Golden eagle and Rough-lgeed hawk were also found dead at the wind project.

Golden Eagle Killed by Wind Project

March 8, 2013 - Already a dead Golden eagle was found on February 25 at a wind turbine generator in the Spring Valley, a place with a dense population of eagles. Those who knew thae area had predicted eagle mortality was likely, but no one thought it would be so soon after the project was completed.

According to the Bureau of Land Management (BLM), Pattern Energy contacted US Fish and Wildlife Service (FWS) as required and preserved the carcass for them. FWS has confirmed it was a strike that killed the eagle.

The golden eagle death triggered a requirement that the company survey all 66 turbines in the next survey period.

Because the death was at the start of the nesting season the company may need to move up their surveys for nests and do some analysis to determine if the eagle killed was resident and part of a nesting pair, or a transient.

BLM says that the project has now “reached but not exceeded” the take threshold for golden eagle of one take. If they get another take this may trigger curtailment and other measures.

Spring Valley Wind Project Up and Running

August 26, 2012 - These photos show the wind project in late July, during a Resource Advisory Committee tour for Bureau of Land Management.

^View of the wind project west of Great Basin National Park, from the trail along Wheeler Ridge in the park. (Photo by Dennis Ghiglieri)

^Turbines and new roads in Spring Valley. (Photo by Wayne Bundorf)

^Salt Cedars Area of Critical Environmental Concern in the distance. (Photo by Wayne Bundorf)

^View of turbines from the intersection at Major's Place on Highjway 6. (Photo by Wayne Bundorf)

^Closer view of the wind project west of Great Basin National Park, from the trail along Wheeler Ridge in the park. (Photo by Dennis Ghiglieri)

^Turbines and the Schell Creek Range. (Photo by Wayne Bundorf)

^Turbines too close to Rose Guano Cave, a roost for Mexican free-tailed bats. (Photo by Wayne Bundorf)

^Tour of the project site newly completed. (Photo by Wayne Bundorf)

^Former winterfat and sagebrush basin habitat of Pygmy rabbits and Sage grouse is now an industrial yard. (Photo by Wayne Bundorf)

^Wheeler Peak in Great Basin National Park. (Photo by Wayne Bundorf)

^Still grading new roads in the Great Basin desert habitats. (Photo by Wayne Bundorf)

^New turbines in Spring Valley (Photo by Wayne Bundorf)

^Turbine almost 400 feet tall. (Photo by Wayne Bundorf)

^Bureau of Land Management tour. (Photo by Wayne Bundorf)

^Base of a turbine. (Photo by Wayne Bundorf)

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Notes on Spring Valley Wind Project Site Visit (Resource Advisory Committee for BLM) on July 20, 2012, provided by Judy Bundorf:

General comments:  The roads are currently about 30 feet wide (estimated); they are in the process of “mitigating” and will replant the outer edges of the roads, and end up with 18-foot wide roads.

As we arrived at the site, the last two of the construction trailers were being hauled out.  The area where all the trailers were is being “reclaimed” and “mitigated”; it presently looks like a plowed field.

1. When we arrived about 9:00 a.m., the turbines were turning very, very slowly or not at all.  We were informed that the power line which takes the power generated onto the grid had been damaged in a fire in early July.  It was anticipated the power lines would be repaired and electricity flowing from the turbines by some time the week of July 23rd.  Thus there was no power going online for about three weeks.  With only one line to deliver the power from the site, seems like this may be a common occurrence due to ice storms, wind storms, and forest fires. 

I asked the Pattern Energy representative if there was another line to export the power on, and the answer was “No.”  I also asked ft NV Energy couldn’t take the power, if it could be sold on the open market.  Again, the answer was “No.” 

Rumor has it that the power purchase agreement between Pattern and NV Energy is between 10 and 12 cents per kwh wholesale.  (My NV Energy bills charge between 12 and 13.5 cents per kwh retail.) 

2. While we were standing outside the maintenance building, the Pattern Energy representative said the 66 2.3 MW Siemens turbines would power for 200,000 homes.  However, when we got inside and saw some poster boards with project specifictions, it indicated the project would power 45,000 homes.

3. The representative pointed out their “bat radar” machine, and talked about how much they were spending to keep the environmentalists happy by tracking bat activity.  He said they had a second radar machine they would be using as well.  Apparently one radar will be set up near the bat cave, and another closer to the turbines.  For two months each year (during the bat migration) Pattern will slow the cut-in speed, and perhaps not operate the turbines for several hours, starting at dusk.  However, there is no way to have the radar shut down the turbines if they detect bats or avian activity.

Pattern also will have several college students go to the site each morning to count any dead bats or birds.  I asked why they didn’t consider hiring someone with a dog trained to find the birds and animals that had been killed.  The Pattern Rep. said they would not do that.  (Side note:  I’ve read that a dog is much more efficient than humans in finding anything killed by turbines.  Also, the coyotes will be picking the site clean during the night!)

4. At no time did the representative actually state they would shut down the wind farm because of the bats or avian migration…perhaps I missed it, but my friend did not hear that said either.  Also, the representative indicated the monitoring would go on for five years, but no mention of what would happen after that.

So, for now, just count the fatalities!

5. I asked if there would be strobe lights 24/7, and was told that there would be to comply with FAA requirements.  I don’t know if lights will be on all or just some of the turbines and MET towers.  He mentioned that someone is working on a system that would sense aircraft and turn the lights on only when aircraft were near, but that hadn’t been perfected.  So for now, the “dark night skies” in Spring Valley are no more.

6. Someone asked if the turbines were made in America.  Short answer is “No.”  The blades are manufactured in Utah; the components that go in the nacelle, and the nacelle are manufactured elsewhere, but assembled in the U.S.  The turbine “tower” (i.e., where the nacelle and blades are mounted) is manufactured in China. 

7. Roads into the site all have gates on them now…at some future time, some of the pre-existing roads may be reopened to the public.

8. At the end of the “useful life” of the project, the turbines will be demolished and all resulting materials hauled away.  According to the representative, nothing can be recycled!  The concrete foundations will be removed to 4 feet below present grade.  (I believe he stated the foundations were 56 feet in diameter, by 30 feet deep…hope I’ve got that right!). 

9. Part of the mitigation will include replanting native flora right up to the base of the turbines.  I asked if that wouldn’t present a fire hazard (based on the Searchlight DEIS that talked about how a large area would need to remain plant-free to prevent the spread of fire).  I was told that wasn’t an issue in Spring Valley.

10. Someone inquired as to why the turbines, while mostly in neatly aligned rows, had some randomly placed.  We were told there were areas with heavy sage brush cover that might be home to pygmy rabbits, so those areas were avoided.

11. Someone had told me that the plan was to build many more turbines (up to 1000 total) in Spring Valley.  When I asked about this, I was told this project was built-out at 66 turbines, and there would be no more turbines built by Pattern.  (Some folks commented that other companies may pursue more turbines in the valley.)

Some of the folks from Lincoln County found it interesting that Pattern Energy said they had to build this project in the valley to get the best wind, while Wilson Creek Wind told the people there the project had to be on the mountain tops for the best wind!  Flexible, aren’t they!

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Financing Complete, Full Construction Beginning

September 17, 2011 - Construction has begun on the 150-megawatt, $250-million wind farm with 66 2.3-megawatt turbines. The project is on 8,500 acres of public land managed by the Bureau of Land Management. Now, the developer says, with financing in place, construction will ramp up with completion of the project next summer.

Pattern Energy announced on August 26 that it has secured a construction loan that converts into an 18-year term loan for Spring Valley Wind through Siemens Financial Services, Inc., Credit Agricole Corporate and Investment Bank, and Union Bank, N.A.

"The official completion date is June 30 (2012). We hope to beat that," said Head Developer George Hardie during a groundbreaking ceremony on August 26 at Ely's County Park. He said completion a month ahead of schedule is possible.

"We've got to go through the winter months," he said, and acknowledged that there could be construction difficulties during the wintertime.

The contractor, Mortenson Construction of Minneapolis, Minnesota, will hire about 225 workers for the construction phase of the project and jobs will be available to local residents.

"We've already had job fairs here," Hardie said.

Hardie said the Spring Valley Wind would employ 13 permanent employees after the project is completed.

The BLM land where the turbines will be located is not taxable by the county but the turbine structures would be.

"It (wind generation) is possible because the OnLine is going to connect the northern and southern service areas in Nevada," Hardie said.

Construction of the One Nevada Transmission Line is currently progressing through White Pine and Nye counties. When completed in late 2012, the estimated $510 million, 235-mile long, 500-kilovolt transmission line will run from the Harry Allen Substation north of Las Vegas to the soon to be constructed Robinson Summit Substation, about 20 miles northwest of Ely. The project was formerly known as the Southwest Intertie Project (SWIP).

www.patternenergy.com

http://www.elynews.com/articles/2011/09/02/news/news11.txt

Fall Photo Gallery

November 22, 2010 - Wild and remote, winter flocks of birds frequent this area >>here. Photos courtesy Katie Fite of Western Watersheds Project.

Bureau of Land Management Hastily Approves Project

October 19, 2010 - Despite outcries from environmental groups and Native Tribes, the Ely Bureau of Land Management office decided against doing a more thorough environmental review and went ahead and approved this project with only an Environmental Assessment.

Huge problems remain with large numbers of Golden and Bald eagles, as well as other raptors using Spring Valley, Greater sage grouse leks close, archaeological sites, and groundwater concerns over the nearby unique juniper-dotted wetland. Visual concerns of the giant turbines so close to Great Basin National Park were dismissed.

A Finding of No Significant Impact was issued, and in the Decision Record, BLM states, "Geotechnical investigations will be done for each turbine to ensure not to puncture and dewater the aquifer. Specific measures will be developed as needed to address geotechnical issues. If the perching ground water layer, as identified by the onsite geologist or geotechnical engineer or engineer’s representative is breached, the hole or breach point will be seal grouted to preserve the subsurface hydrology that feeds the local system."

An Avian and Bat Protection Plan describes initial mitigation requirements, post-construction monitoring requirements, and an adaptive mitigation strategy. The plan uses a tiered approach that would result in different levels of mitigation being implemented based on the findings of postconstruction monitoring. But we argue that the plan puts too much emphasis on "adaptive management" -- study later and then decide what to do after birds and bats are killed, after the public review period is over.

"Nest surveys will be conducted prior to the nesting season (approximately March 15 to July 30) and once each month during the nesting season during the first three years and every fifth year after that. Aerial or ground based raptor nest surveys will be conducted within the entire project area and a 1-mile buffer for raptors, except for golden eagles. Golden eagle search distances will be 10 miles from the project area based on current USFWS guidance. The complete 10-mile search area will be limited to once at the beginning of the golden eagle nesting season with monthly follow-up surveys only being completed for identified golden eagle or potential golden eagle nests." Golden eagle nest surveys should have been done already, this is unacceptable. If a nest is found within the area, the project would be shut down, following the strict Bald and Golden Eagle Protection Act of the US Fish and Wildlife Service. No eagle may be killed or harassed, including harassment on foraging grounds.

"As part of the project, the project proponent has volunteered to donate $500,000 to enhance sagebrush habitat that supports species such as the greater sage-grouse. Funds would be deposited into NDOW’s Non-Executive Account and marked specifically for purposes of sagebrush restoration efforts, which could include permitting, equipment and seed purchase, labor, and other necessities for restoration. An effort must first be made to apply the funds to sagebrush restoration within Spring Valley and then outside of the valley if necessary. Donations into this account are eligible for matching federal funding. All decisions of how to utilize the money will require both NDOW and the BLM approval." But this does not mitigate the loss of pristine sagebrush habitat that is currently unfragmented in Spring Valley.

"Any swamp cedar that must be removed would be made available for education, scientific, and research purposes as determined by the BLM." This too is unacceptable, as this species of juniper, Rocky Mountain junipers (Juniperus scopulorum), is unusual growing on this flat valley floor. Will the trees be placed in pots?

"If pesticides are used on the site, an integrated pest management plan shall be developed to ensure that applications would be conducted within the framework of BLM and U.S. Department of the Interior policies and entail only the use of U.S. Environmental Protection Agency (EPA)-registered pesticides. Pesticide use shall be limited to non- persistent, immobile pesticides and shall only be applied in accordance with label and application permit directions and stipulations for terrestrial and aquatic applications." No pesticides should be used in this sensitive habitat, and any plan should be made available for public review.

No Decommissioning Plan was made.

"Per SHPO [State Historic Preservation Offices] requirements, complete detailed recordation and specific photo documentation (prior to construction), of any eligible sites that would be visually impacted by the project, this will be completed to SHPO (2010) standards." In other words, valuable cultural sites would only be photographed before destruction? The Goshute Tribe is concerned about burial sites here.

BLM said, "...a determination was made that the Selected Alternative will not significantly affect the quality of the human environment and that preparation of an Environmental Impact Statement is not required."

This valley is one of the most pristine in the Great Basin, and should not be industrialized.

BLM Ely website page

Our Comments to BLM

August 13th, 2010

Gina Jones, BLM Ely District NEPA coordinator
BLM Ely District Office
HC 33 Box 33500 (702 North Industrial Way)
Ely, NV 89301
(775) 289-1800
gina_m_jones@blm.gov

Dear Ms. Jones,

We would like to submit the following comments on the Spring Valley Wind Project Revised Preliminary Environmental Assessment (EA) and draft Finding of No Significant Impact (FONSI).

Basin and Range Watch is a group of volunteers who live in the deserts of Nevada and California, working to stop the destruction of our desert homeland. Industrial renewable energy companies are seeking to develop millions of acres of unspoiled habitat in our region. Our goal is to identify the problems of energy sprawl and find solutions that will preserve our natural ecosystems and open spaces.

Comment Deadlines, Environmental Assessment and Fast Tracking Tricks:

It is inappropriate for the BLM to attempt to streamline approval of this project with only an Environmental Assessment. Every other wind energy project proposal on public lands, many with fewer turbines on smaller acreage, is undergoing full review with the required Environmental Impact Statement. Placing an 8,500 acre wind energy facility in this area will undoubtedly create unlimited problems with wildlife resources, adjacent wilderness, National Parks and ACEC’s, cultural resources as well as hydrology resources. In spite of efforts from the public to participate in informing BLM personnel about the direct and cumulative impacts of this project, it is still being frivolously rushed through by the agency with only an inadequate EA.

Although we understand that BLM is under considerable political pressure to develop renewable energy, we believe it is unwise for the BLM to be using “fast tracking” seemingly to expedite approval of this project. We feel that it there are enough outstanding unresolved issues that make approval and construction of facilities by December of 2010 under the American Recovery and Reinvestment Act a very unrealistic goal. This process has lead to an unreasonably rushed schedule that has the potential to have long term impacts on natural resources and overlooks the many concerns that public and adjacent private land owners have raised. The rushed schedule has resulted in a distrust and lack of faith in the ability of our public land agencies and elected officials to actually develop renewable energy in a way that could be sustainable for the future. Furthermore, the fast tracking undermines laws established under the National Environmental Policy Act that have been enacted to insure that resources on public lands are managed soundly for future generations. We would also like to request that the deadline of this comment period be extended so interested parties may comment fully.

This project needs to have a full Environmental Impact Statement prepared with at least two more years of review.

Draft Finding of No Significant Impact:

Please explain the reasoning for issuing a “Draft Finding of No Significant Impact “. We believe it is not appropriate for the BLM to assume that this project deserves this consideration before they can consider all of the comments from interested parties.

Proposed Action and Alternatives:

From the EA:

“2.1.1.1 WIND ENERGY FACILITY COMPONENTS
The principal components of the SVWEF would consist of WTGs, an underground electrical collection system for collecting the power generated by each WTG, electrical substation and switchyard, access roads, O&M building, temporary laydown and storage areas, concrete batch plant, sand and gravel source, fiber-optic communications, one permanent meteorological (MET) tower, two radar units, and a microwave tower. The short-term (the period from beginning of construction until reclamation) and long-term disturbance (the duration of the project) areas for each of these components are described in Tables 2.1-2 and 2.1-3. The project area totals 8,565 acres, all of which are on BLM land covered by the requested ROW for the Proposed Action. This is to allow for the necessary set back distances and spacing between individual WTGs and linear arrays. The total area estimated for use by the wind energy facility (including both short- and long-term disturbance) is 448.0 acres, or 5.2% of the total ROW.”


The EA is suggesting that the overall footprint of the project would be less than significant because of the figure of “448 acres of disturbance”. This statement is misleading from an ecological perspective. New roads, electric lines, substations, underground electrical collection systems, etc. will all be obstructions to wildlife habitat and connectivity in this region. The project will also degrade the remote visual character of Spring Valley. This project will directly impact 8,500 acres as well as cumulatively impact Spring Valley as a whole.


The EA states that further geotechnical investigations will be conducted at the site of the placement of each turbine. Please describe the potential impacts that geotechnical investigations would have on hydrology relating to cone of depression effects on the swamp Cedars Area of Critical Environmental Concern. An EIS should also examine the impacts geo-testing would have on soils and burrowing animals. How many decibels? Would burrowing animals be deafened?


Water Usage, Amounts, Source:


The EA states that up to 30.7 acre feet of water would be used in total for the entire project. Because the basin in question is over-appropriated for water use, we would like to see a final EIS break down the water use in a table. The water use should be broken down into categories of dust control, long term maintenance, concrete mixing and personal use of construction workers. The EA fails on all accounts to adequately describe what is proposed.


Alternatives:


An EIS should list at least three more alternatives. The Alternative Development Alternative still would disturb the hydrological resources of the Swamp Cedars Area of Critical Concern, disrupt connectivity for pronghorn antelope, remove habitat for the sage grouse and pygmy rabbit, still kill many raptors and passerines, and still potentially destroy the population of Mexican free-tail bats in the Rose Guano Cave.


We are surprised that the EA fails to find an alternative away from the site. The project is centrally placed in the worst location possible concerning preservation of wildlife resources. We can only conclude that BLM is pandering to Pattern Energy so they can get the shortest distance to a transmission line.


The DEIS fails to consider enough alternatives and fails to follow the requirements of NEPA listed below. There is no quantitative data that proves that this project will have economic benefits and offset greenhouse gas emissions.


NEPA Requirements:


The National Environmental Policy Act has the following requirements for alternatives:
“(a) Rigorously explore and objectively evaluate all reasonable alternatives, and for alternatives which were eliminated from detailed study, briefly discuss the reasons for their having been eliminated.
(b) Devote substantial treatment to each alternative considered in detail including the proposed action so that reviewers may evaluate their comparative merits.
(c) Include reasonable alternatives not within the jurisdiction of the lead agency.
(d) Include the alternative of no action.
(e) Identify the agency's preferred alternative or alternatives, if one or more exists, in the draft statement and identify such alternative in the final statement unless another law prohibits the expression of such a preference.
(f) Include appropriate mitigation measures not already included in the proposed action or alternatives.”

Distributed Generation:

This is the best alternative that can be legally considered not within the jurisdiction of the lead agency. Distributed generation in the built environment should be given much more full analysis, as it is a completely viable alternative. Spring Valley Wind will need just as much dispatchable baseload behind it, and also does not have storage. But environmental costs are negligible with distributed generation, compared with the Spring Valley Wind project. Distributed generation cannot be “done overnight,” but neither can large transmission lines across hundreds of miles from remote central station plants to load centers. Most importantly, distributed generation will not reduce the natural carbon-storing ability of healthy desert ecosystems, will not disturb biological soil crusts, and will not degrade and fragment habitats of protected, sensitive, and rare species.

Alternatives should be looked at that are in load centers, not closest to the project site. There is a need to consider the “macro” picture, the entire state, to look at maximum efficiency.
 
A Master comprehensive plan should exist before large expensive inefficient wind energy projects are sited and built out in the wildlands. This plan should carefully analyze the recreational and biodiversity resources of the desert. A list of assumptions should be included detailing the plan for integrating various fuels mixes and technologies into each utility's plan, an overall state plan, and a national plan. Loads should be carefully analyzed to determine whether additional capacity is needed for peaking, intermediate, or baseload purposes. Unit size, which impacts capital and operating costs and unit capacity factors, has a direct bearing on the relative economics of one technology over another. A plan might recommend that smaller units built in cities and spaced in time offer a less risky solution than one large unit built immediately.
 
Large-scale wind plants have been sited very far from load centers out in remote deserts, with the only criterion being nearness to existing transmission lines and natural gas lines. Very little thought has been given to the richness of biological resources, the cumulative impacts on visual scenery to tourists, the proximity to ratepayers, or the level of disturbance of the site.
 
The California Energy Commission says there will be a need to build many new efficient natural gas peaker or baseload plants to back up the renewables planned, and this will undoubtedly be the case in Nevada as well. Instead, the renewables should be distributed generation in load centers, which will provide much more efficiency, rather than inefficient remote central station plants that reduce biodiversity and require expensive transmission lines. This reduces the risk, as distributed generation is a known technology and has been proven in countries like Germany where incentive programs have been tested. Incentive programs can be designed in an intelligent manner to vastly increase distributed generation.  Incentives for remote projects like Spring Valley Wind are unproven to lower risk and may actually raise debt levels with runaway costs associated with poor siting and higher-than-anticipated operating and maintenance costs.


Off Site Alternative:


The BLM has failed to provide an adequate alternative away from the site. Although we do not feel that a project like this is appropriate on public lands, we do believe that the BLM has provided an incomplete analysis of alternatives based on the DEIS and would like to see one off site. An alternative should be developed using lands at least twenty miles away from the Rose Guano Cave.


Basin and Range Watch Preferred Alternative:


Please provide another No Action Alternative that denies approval of the project and designates the region unsuitable for wind energy development.

Climate Change:

The BLM fails to identify any direct evidence that the proposed project will offset greenhouse gas emissions and even admits the uncertainty. There is no analysis on the volume of greenhouse gas emissions that would occur from the thousands of vehicles required for the construction of this project. There is no analysis on how the removal of carbon storing soil crusts would add to C02 volumes in the atmosphere. From the lack of information in BLM’s analysis, we are actually worried that the proposed project will make an even more problematic situation concerning climate change.

Sulfur hexaflouride is a greenhouse gas which is 24,000 times more potent than C02 and that new transmission lines and upgrades are one of the main sources of these gases.

From the Environmental Protection Agency web site: http://www.epa.gov/electricpower-sf6/basic.html

“The green house gas called SF6 is used primarily in electricity transmission - and is emitted in especially large amounts in construction of new lines – and is 24,000 times as potent as CO2 in it’s global warming impacts. The Environmental Protection Agency has declared “that the electric power industry uses roughly 80% of all SF6 produced worldwide“. Ideally, none of this gas would be emitted into the atmosphere. In reality significant leaks occur from aging equipment, and gas losses occur during equipment maintenance and servicing. With a global warming potential 23,900 times greater than CO2 and an atmospheric life of 3,200, one pound of SF6 has the same global warming impact of 11 tons of CO2. In 2002, U.S. SF6 emissions from the electric power industry were estimated to be 14.9 Tg CO2 Eq. &”

Carbon sink: Scientific studies have revealed that desert ecosystems and minerals have the ability to store C02 gases. Have Desert Researchers Discovered a Hidden Loop in the Carbon Cycle? Richard Stone: Science 13 June 2008: Vol. 320. no. 5882, pp. 1409 - 1410 DOI: 10.1126/science.320.5882.1409

How much C02 storage capability would be replaced by development? If the goal is indeed to reduce greenhouse gases, is it wise to remove this much carbon storing living crust? Please provide a detailed analysis on the amount of GHG that would otherwise be offset by an intact arid ecosystem.

A final EIS will need to provide a quantitative analysis of the proposed project’s potential to offset greenhouse gases. This project is being advertised as “green energy”, yet there is no proof that it will actually offset greenhouse gas emissions. From the amount of destruction that would occur to the natural ecosystem as well as the impacts to the local community, the BLM has failed to prove that this project can even accomplish what it has set out to do.

Erosion of Soils:

The DEIS inadequately analyzes the project’s potential to remove soil crusts, thus causing an erosional chain reaction that will result in increased dust from blowing winds. How would this be mitigated?

Visual Resources:

From the Spring Valley Wind Visual Assessment:

“The BLM designated the project area as VRM Class III (BLM 2008). The Class III management objective is “to partially retain the existing character of the landscape. The level of change to the characteristic landscape should be moderate. Management activities may attract attention, but should not dominate the view of the casual observer. Changes should repeat the basic elements found in the predominant natural features of the characteristic landscape” (BLM 1980).”

Basin and Range Watch differs with BLM’s designation of the site as only a VRM Class III area. As you may know, this part of Spring Valley was originally intended to be part of Great Basin National Park. Many people have commented on our web site that they feel that Spring Valley is one of the most scenic and remote places left in the west because it is one of the most unspoiled basins left in Nevada. We believe that the BLM is misrepresenting the view of the public, by only designating the VRM for the area as “Class III”.

KOP Simulations:

First, the Google Earth Key Observation Point Simulations are inadequate. These simulations do not capture lighting and actual features. A new Visual Resource Management Assessment should exclude all Google Earth Simulations.

Second, the existing KOP simulations display a “lighting bias”.

KOP’s 1, 2 and 3 should be broken down into 3 photos each, representing morning, afternoon and evening. There should also be KOP’s of the same views representing lighting and contrast from Summer and Winter seasons.

At least 6 additional KOPs are needed.

- At least two KOP’s should be provided from the Mt. Moriah Wilderness Area

- At least one KOP should be provided from a scenic vantage point in the Schell Creek Range

- At least one KOP should be provided representing the flashing red lights at night time.

- Two KOP’s should be provided closer to the project with at least one taken from the Swamp Cedars Area of Critical Environmental Concern.

In 2006, Highway 50 in White Pine County, Nevada and Millard County, Utah was designated by Congress as the Great Basin National Heritage Route. The larger area of these counties and Native American Tribal lands is recognized as the Great Basin National Heritage Area. The Great Basin National Heritage Area is a geographical region encompassing White Pine County, Nevada and Millard County, Utah and adjacent Indian reservations that contains nationally significant archaeological, historical, cultural, natural and scenic features that are emblematic of the entire Great Basin Area.

Socio-Economics and Local Jobs:

We believe that the preservation of this open space for scenic value and wildlife preservation has a more sustainable recreational value to the community and other public land owners than a wind project that will produce a questionable amount of energy and create so few jobs in the long run.

If the project is developed, how much public land would be off limits to the public?

Biological Resources:

NEPA requires agencies to disclose environmental consequences, but the Executive Order 13212 directs Federal Agencies to streamline the approval of environmentally responsible renewable energy. BLM is succeeding all too well in streamlining approval but falls dramatically short on insuring that the Spring Valley Wind Project will be environmentally responsible.

Avian Disaster, Killing Bats and Birds

Bats:

The project is approximately 4 miles from Rose Guano Bat Cave. The Programmatic EIS for wind states that caves used by bats should be avoided. In place of this measure, a project- specific Mitigation Measure has been provided in Section 6.4.2 and in the ABPP. The mitigation measure, to avoid known bat caves and migration corridors, is completely being ignored. There appears to be no mitigation.

The Programmatic Wind EIS states:

“Turbines should not be located near known bat hibernation, breeding, and maternity/nursery colonies, in migration corridors, or in flight paths between colonies and feeding areas.”

The Avian and Bat Mitigation and Adaptive Management Plan is only in Draft Form. Where is the final document? The several unresolved issues in the document indicate that BLM is negligent in completing these studies.

The Draft Avian and Bat Mitigation and Adaptive Management Plan fails to document four species that would occur in the region.

These species are:

California myotis (Myotis californicus)

Fringed myotis (Myotis thysanodes)

Western Pipistrell (Pipistrellus hesperus)

Hoary Bat (Lasiurus cinereus)


The hoary bat is mentioned in the in the EA, but the EA neglects to mention that the Hoary bat is a BLM Species of Special Concern.

An EIS will need to provide a complete list of bat species that would occur in the area.

In April, 2010, BLM employees informed us that this new mitigation and adaptive management plan “would resolve issues associated with bats.” We believe that this was a premature statement.

From the US Geological Survey web site:

http://www.fort.usgs.gov/BatsWindmills/

“In the push to develop new forms of sustainable energy, the wind power industry is at the forefront....However, recent evidence shows that certain species of bats are particularly susceptible to mortality from wind turbines. Bats are beneficial consumers of harmful insect pests, and migratory species of bats cross international and interstate boundaries. Dead bats are turning up beneath wind turbines all over the world. Bat fatalities have now been documented at nearly every wind facility in North America where adequate surveys for bats have been conducted, and several of these sites are estimated to cause the deaths of thousands of bats per year. This unanticipated and unprecedented problem for bats has moved to the forefront of conservation and management efforts directed toward this poorly understood group of mammals. The mystery of why bats die at turbine sites remains unsolved. Is it a simple case of flying in the wrong place at the wrong time? Are bats attracted to the spinning turbine blades? Why are so many bats colliding with turbines compared to their infrequent crashes with other tall, human-made structures?”

Adaptive Management Plan:

The Draft Avian and Bat Mitigation and Adaptive Management Plan in no way convinces us that bat mortality can be avoided. We are concerned that the BLM is considering approving a Right of Way for a project that is so close to the Rose Guano Cave and in a region that has such a robust population of different species of raptors.

The Draft Avian and Bat Mitigation and Adaptive Management Plan states:

“A curtailment study will be completed during the first year to determine the most effective cut-in speed following methods based on those developed by Arnett et al. (2009) in which they evaluated the effectiveness of increasing cut-in speeds from an initial 4.0 m per second (m/s) to experimental speeds of 5.0 and 6.5 m/s. These increased cut-in speeds were effective in reducing bat mortality by 53%–87%, with minimal loss of revenue for the WEF (Arnett et al. 2009). No Brazilian free-tailed bats were evaluated in this study; therefore, testing is needed to determine the effectiveness of increased cut-in speed.”

Because “No Brazilian free-tailed bats were evaluated in the study”, you have very little information as to what the future outcome will be.

The report states:

“During this study, turbine cut-in speeds will be altered from sunset to 4 hours after sunset for a 62-day period (248 hours) during the highest use period of August 1 through September 31.”

There are 12 other species of bats that could potentially be impacted by this project from May to the beginning of August. An adaptive management plan should be created for the additional species at risk as well.

Mortality Surveys:

We have interviewed two biologists who have participated in mortality surveys for wind energy projects. It is extremely difficult to train people to find carcasses of dead bats due to the size of the animals and the camouflage color of the animals. Most biologists tend to feel that this kind of monitoring is not effective.

Creating a Wind/Wildlife Research Fund:

The EA States:

“The project proponent will provide $10,000 per year for three years to fund wind/wildlife interaction studies. Research will be recommended by the TAC, approved by the BLM Authorized Officer, and funded by the proponent. Additionally, the BLM or other participating agency may elect to contribute funding. In that event, the proponent would provide funding to the BLM, and the BLM would issue a Request for Proposals for the study.”

A $30,000 research fund will not bring back the Rose Guano Cave population of Mexican free-tailed bats if the wind farm causes a giant population crash. This is not an acceptable mitigation plan.

Carcass Removal Trials:

The EA States:

“Carcass removal trials will be completed seasonally as described above in Section 6.2. Different seasonal rates for carcass removal are necessary to address changes in the scavenging throughout the season, as well as over time, as scavengers adapt to a novel food source. Carcasses will be placed as described for searcher efficiency trials. Carcasses will be checked at 1, 2, 3, 4, 5, 6, 7, 14, 21, and 28 days following placement, or until they are all removed. Separate carcass removal rates will be determined for bats, small birds (passerines), and large birds (raptors). Carcasses used for removal trials will be handled with disposable nitrile gloves or an inverted plastic bag to avoid leaving a scent on the carcasses and interfering with the scavenger removal trial (Arnett et al. 2009).”

This still is in the trial phase. More studies should be conducted before the project is constructed, not after. This data should be included in an EIS.

Mortality Threshold:

The Mortality Threshold fails to explain the reasons that the numbers listed are acceptable thresholds for mortality of species. A final EIS will need to justify these numbers from an ecological perspective.

Mitigation Phases:

All of the mitigation phases are “after the fact”. You have not convinced us that any of these mitigation phases will be adequate enough to prevent the mortality.

Science Recommendations on bats and Wind Farms:

Although Spring Valley is not within the California Desert, the DRECP Independent Science Advisors' recommendations for bats will apply to the Great Basin (Public Review Draft Recommendations of Independent Science Advisors for The California Desert Renewable Energy Conservation Plan (DRECP), Prepared For Renewable Energy Action Team: California Department of Fish & Game, U.S. Fish & Wildlife Service, U.S. Bureau of Land Management, andCalifornia Energy Commission, Prepared By The DRECP Independent Science Advisors, August 2010):

"Bats. Basic conservation needs of bats are met by ensuring that roosts, foraging areas, and free water are maintained within a few km of one another. However species of bats differ in the types of structures used as roosts, types of habitat favored for foraging, and nightly distances travelled to reach foraging and drinking areas. Therefore, conservation and mitigation efforts must take care to ensure that proposed actions are species-specific and maintain viable juxtaposition between important resources. For instance, loss of cave roost habitat in one area cannot be mitigated via protection of rock face or tree roost habitat elsewhere, as it would be unlikely to be used by the affected species. Similarly, loss of roost habitat cannot be offset through provision of foraging habitat. The success even of in-kind (e.g., protection of foraging habitat to offset loss elsewhere) habitat substitution should be verified through an adaptive management process before it is widely implemented as a mitigation tool."

and

"Hoary bat (Lasiurus cinereus). Although this species is widely distributed and unlikely to be listed as threatened or endangered in the near future, hoary bats are the most frequently killed species at wind energy developments in North America (Arnett et al. 2008) and have been recorded as fatalities at wind energy facilities within the DRECP (Chatfield et al. 2009). Given the cumulative impacts of massive expansion of utility-scale wind energy development in the United States, combined with low reproductive rates of bats, there is some potential for hoary bats to be added to one or more special status lists within the next 30-50 years."

Birds:

It is our view that approval of this project would be a violation Executive Order 13186, the Migratory Bird Treaty Act. We do not believe that the BLM nor the applicant has proven that their project will not remove a substantial amount of avian wildlife from the region.

Large raptors are the birds that suffer the highest mortality. Please review the following references:

Please review the following video documenting a fatal collision with a large raptor and a wind turbine: http://www.wind-watch.org/video-vulture.php

The following article details the concerns of avian mortality from wind energy:
http://seattletimes.nwsource.com/html/localnews/2012048835_windbirds07m.html

Bald and Golden Eagles are common on the project site. Spring Valley is known as a wintering region for bald eagles. How will death of bald eagles be waived under the Bald and Golden Eagle Protection Act? A Section 7 take based on research could not be justified in this case. How many Take permits would be issued for bald eagles? Additionally, the presence of WTGs would increase the risk of nest abandonment in and near the project area. How is this being allowed under the Bald and Golden Eagle Protection Act? 

As of January 2008 San Gorgonio wind farm near Palm Springs, California consists of 3,218 turbines. Raptors and waterbirds are killed here, but a study by McCrary (1986) evidenced that passerines were also being killed in numbers: "an overall estimate of as many as 6,800 birds killed per year, most of them nocturnal passerine migrants."www.iberica2000.org/documents/EOLICA/6800_bird_fatalities.doc

From the Programmatic Wind EIS:

“Turbines and other project facilities should not be located in areas with known high bird usage; in known bird and/or bat migration corridors or known flight paths; near raptor nest sites; and in areas used by bats as colonial hibernation, breeding, and maternity/nursery colonies, if site studies show that they would pose a high risk to species of concern. Project is in an area with several raptor nest sites nearby and a major bat hibernacula. The Alternate Development Alternative locates facilities away from raptor sites. An ABPP (see Appendix F) has been prepared to address the potential impacts associated with both birds and bats.” The project boundary should be at least 10 miles distant from raptor nests, and this is not being done.

And

“Locations that are heavily used by migratory birds and bats should be avoided.” The avian and bat mitigation plan does not address the mortality that will probably happen, and defers mitigation to future studies. This is unacceptable. The Spring Valley Wind Project EA is not following the recommendations of the PEIS.

Sage Grouse (Centrocercus urophasianus):

 
The project will disturb sage grouse habitat. Sage grouse need large undisturbed areas of sagebrush, not cut by roads or fences, to nest and feed in. The impacts of industrial wind farms in sage grouse habitat will involve further fragmentation of the large patches of pristine sagebrush that harbor these birds. There is about 3,643 acres of sage grouse habitat within the project site.

The major threat to Greater Sage-Grouse is the continued degradation and destruction of sagebrush habitats across the West. Agriculture has completely eliminated millions of hectares of native shrub-steppe habitat dominated by sagebrush, while additional millions of hectares of shrub-steppe have been stripped of their sagebrush vegetation. Overgrazing and urban development also contribute to the degradation of shrub-steppe habitat.

 From the Programmatic Wind EIS:

“Avoid, when possible, siting energy developments in breeding habitats. Potential breeding habitat occurs in the project area at low frequencies; however, the project is 2 miles from the closest lek and individuals likely use habitat west of SR 893 and the nearby overhead transmission line, thereby avoiding physical barriers. This is not mitigation, nor avoidance. Off-site mitigation should be considered, such as retiring a grazing allotment in Sage grouse habitat. Fragmentation will greatly increase, and is not mitigated.” This has not been followed.
 
Pygmy rabbit (Brachylagus idahoensis):

Biologists mapped two burrows of this small animal in the northern part (SWCA 2009). These small herbivores require tall dense sagebrush stands to hide from predatory hawks and eagles. At least 3 individuals were seen in 3 separate habitat patches in the project site. About 89 acres of good habitat for this rabbit, and 61 acres of occupied habitat with active burrows were found on the project area. The EA states that is it hoped that the Pygmy rabbits will move away, "to avoid mortality associated with daily operations such as crushing by vehicles"

Because pygmy rabbits are restricted to sagebrush habitats with deep soils, they have always been rare and patchily distributed across their range. Biologists agree that the main threats to pygmy rabbits across their range are habitat loss and fragmentation caused by:
• conversion of sagebrush rangeland to agriculture;
• development, including oil and gas production; and wildfire frequency in some areas

If the Proposed Action is selected, relocation of pygmy rabbits by live trapping prior to construction should be considered in consultation with the USFWS and NDOW to avoid direct mortality. This is unacceptable, as the public does not have a chance to review any Pygmy rabbit relocation plan after project approval. How does trapping impact the rabbit? Please reference past trapping studies and give mortality numbers. How will rabbits be prevented from returning to home ranges? Where will rabbits be relocated to? Will these areas have other disturbance, and how will Pygmy rabbits already present be affected?

Elk, Pronghorn and Wildlife Connectivity:

The wind farm we believe will result in impacts to resident elk, deer, and pronghorn antelope, by noise impacts, habitat fragmentation, and increased human presence.
The project will disrupt connectivity for wintering elk and pronghorn antelope. Turbines would be bisected by roads, concrete, electric cables and other disturbances. Wildlife in general would be blocked by the proposed project.


Rare Plants:


No surveys for rare plants were undertaken on the site, only a few casual observations. Parish's phacelia (Phacelia parishii) has the potential to be found on the site, as records of it are found 250 feet from the project boundary. It is found on clay and alkaline soils by the playas and springs.
Shadescale spring parsley (Cymopterus basalticus) is state ranked as “critically imperiled
Broad-pod freckled milkvetch (Astragalus lentiginosus v. latus) is state ranked as “imperiled due to rarity or other demonstrable factors.”

Encroachment into ACEC:

The project would be built next to the Swamp Cedars Area of Critical Environmental Concern. The unique Swamp Cedars Area of Critical Environmental Concern lies on a "perched watertable," where seasonal wetlands and springs are common, and allowing a savanna of junipers to come down from high elevations.

The EA states”

“Cement foundations for each turbine will be made on site using a new 5-acre cement batch plant. Gravel would be trucked in from an existing mine tailings pile nearby and will also be taken from a new 10-acre gravel pit on the site. The turbine foundations would be 8 feet deep into the ground. The turbine base diameter is 15 feet. Each turbine would require a 400-foot diameter (2.9 acres) temporary construction pad for the crane to lift the steel tower. This area would be bulldozed, graded, and compacted to level. Each foundation would use 400 tons of gravel, 250 tons of sand and 120 tons of cement.”

We are very concerned that the construction of the project will disrupt the delicate hydrology of the ACEC causing localized cone of depression effects that would dry up parts of the ACEC. We do not believe it is wise for BLM to allow the project so close to this habitat.
 
p. 108 of EA states:
“Additionally, site-specific geotechnical analysis would occur at each proposed turbine location prior to any construction activities, and specific measures would be developed as needed to address geotechnical issues”

How does the public get to know if each turbine will impact groundwater in the Swamp Cedar ACEC when analysis will be done after approval?
 
 
The Programmatic Wind EIS states:

“If survey results indicate the presence of important, sensitive, or unique habitats (such as wetlands and sagebrush habitat) in the project vicinity, facility design should locate turbines, roads, and support facilities in areas least likely to impact those habitats.”

The project site is right next to a sensitive and unique wetland, and should be moved to an already disturbed area outside of the groundwater basin so as not to impact this wetland, Swamp Cedar ACEC.

Wildfires:

Industrial wind turbines often experience malfunctions. Oils and lubricants will often for hours during chemical fires. Lighting strikes and electrical malfunctions do happen. The applicant should have a wild fire plan and that should be discussed in an EIS.

Conclusion:

We believe that this EA is an unfortunate attempt to streamline approval of a project that could impact important wildlife and scenic resources in a negative way. This should not have been considered without an EIS. The EA lacks important information required to allow meaningful and timely input from the public.

The site should be designated inappropriate for Wind Energy Development.

 

 

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