Cliff Johnson, Senior Planner
County of Humboldt Planning & Building Department 3015 H Street
Eureka, CA 95501
RE: Humboldt Wind Energy Project NOP for DEIR Dear Mr. Johnson:
Please accept these scoping comments on the Humboldt Wind Energy Project from Friends of the Eel River (FOER). While FOER is supportive of the development of clean, renewable energy generally, the construction and maintenance of such a large infrastructure project in an ecological system as important – and sensitive – as the Eel River watershed has the potential for significant environmental impacts. We therefore have some concerns and questions. Prior to issuing a conditional use permit for the construction and operation of the project, the following must be addressed in the Environmental Impact Report:
- Impacts to birds: It is well-established that industrial wind turbines kill birds. Siting is thus critical. We remain unsure of the suitability of a utility scale wind project in marbled murrelet habitat. Eagles and northern spotted owls have also been documented in the project area. We understand that significant effort is currently being made to monitor wildlife, particularly birds, at the turbine site but are unaware of wildlife surveys to be conducted along the transmission corridor. The project should not be approved until all the biological studies – for birds and other protected species – are complete and those results are incorporated into the DEIR (some of them are 2-year studies, such as for marbled murrelets, which will not be complete until fall of 2019)
- Impacts to bats: Bats are even more sensitive to turbine disturbance, as fatalities can be caused not only by direct collision with blades but also by a phenomenon called barotrauma, in which proximity to the blades causes (often fatal) tissue damage to air- containing structures, such as lungs, from rapid or excessive pressure change. Please evaluate limiting nighttime turbine speeds to less than 5 meters/second to mitigate impacts. Please use best available science to evaluate and mitigate impacts on bats. A study from the EU titled “Mitigating the negative impacts of tall wind turbines on bats: Vertical activity profiles and relationships to wind speed” provides potentially promising new information on mitigation measures.
- Drilling under the Eel River: Please disclose all potential impacts for drilling under the Eel for the transmission line near Scotia. Please evaluate alternatives. Please ensure that, should the plan to drill under the Eel move forward, BMPs are required to minimize erosion and sedimentation.Due to the many decades of timber processing adjacent to the proposed drilling site, it is possible that soils are contaminated (penta, fuerons, and dioxin are the most common legacy pollutants). Soils near the proposed drill site should be tested for contaminants. The proposal should minimize soil disturbance due to both the potential for chemicals and erosion.
- Transmission corridor: Our initial assessment suggests that the approximately 30-mile- long transmission line from the turbine site to the sub-station in Bridgeville could have even more significant environmental impacts than the turbine site itself. A 75-100 foot buffer is proposed to be cleared and maintained for overhead power lines in the Eel and Van Duzen River watersheds. Most of the land the lines would pass over is forested, and some of it old-growth. There are multiple streams along the way that host protected salmonid species. Transmission lines also kill birds. We know that murrelets occasionally collide with power lines with fatal outcome. Two murrelets died in collisions with local utility lines in Prairie Creek State Park several years. Please design a transmission corridor that minimizes habitat fragmentation from logging, water and wildlife pollution from herbicides, erosion from maintenance, etc. Evaluate an alternative that places the transmission line underground along existing roadways. Should you determine that an overhead line in still more ecologically appropriate, site poles and any other ground infrastructure as far away from streams as possible to reduce erosion and pollution potential in order to protect listed salmonids. Use existing roads or other clear areas, retain canopy cover to the fullest extent possible, and bar the use of herbicides to manage plant growth. Manual/mechanical clearing should be the method for keeping the right of way clear.
- Transmission line fire risk: PG&E was recently found culpable for the fires that devastated entire communities in Sonoma and Mendocino counties last year. While they had previously been directed to begin placing power lines underground to eliminate fire risk, they have failed to meet their targets for doing so. How would this transmission line be different from those that cause fires? Could it 1. Be buried instead or 2. Use existingroads and transmission corridors only to reduce the footprint/risk? Heavier/larger diameter lines may be less of a risk, but that should be evaluated.
- Impacts of “up to 17 miles of new roads:” Combined with the grading for the turbine sites, this amount of road construction and maintenance has the potential to impact not only the site itself but areas downstream as well. Please evaluate potential sediment impacts downstream on salmonid/amphibian/aquatic habitats. Please ensure that road standards for the project adhere to the highest levels of environmental sensitivity. Please also clarify potential impacts on existing roads and infrastructure and any necessary upgrades/mitigation for construction, materials transport, and maintenance.
- Viewshed/impacts on Wilderness values: Initial assessments of viewshed impacts have focused on residences in the Rio Dell area. Humboldt Redwoods State Park, Grizzly Creek State Park, and Van Duzen County Park are all within five miles of the proposed site and host thousands of visitors seeking a nature experience. Viewshed impacts on these and other recreation areas should also be evaluated and minimized.
Friends of the Eel River is a non-profit public benefit corporation with its main office in Eureka, California. FOER’s mission is to work for the recovery of the Wild and Scenic Eel River, its fisheries, and communities. Since 1994, FOER has worked to restore and protect the Eel River and its surrounding ecosystems from excessive water diversions, damaging pollution from roads, timber harvests, cannabis operations, and other sediment pollution sources, and ongoing habitat degradation and wildlife disturbances. FOER has focused on efforts to protect salmonids threatened with extinction, including Coho salmon, Chinook salmon, and steelhead trout.
FOER’s members enjoy the natural environment of Humboldt County, including its many rivers and streams and surrounding forestlands. These members regularly enjoy hiking, watching birds, fishing, observing and photographing plants and wildlife, and otherwise experiencing the County’s many watersheds. FOER and its members have a direct and beneficial interest in ensuring that the County fully complies with CEQA and approves projects that do not adversely affect wildlife or plant-life, especially species threatened with extinction like the Marbled murrelet, Northern Spotted owl, Coho and Chinook salmon, and steelhead trout.
FOER strongly supports the transition to a clean, renewable energy economy. However, not all renewable energy is truly green energy, especially when it depletes the landscape around it. We have learned this lesson all too well from our nation’s prior obsession with large dams. While we believe that it is possible to minimize the project’s impacts so that the pluses outweigh the minuses, significant, careful planning and mitigation will need to be conducted to ensure it does not harm the Eel River watershed. We look forward to further evaluating and commenting on the project once the DEIR is released.