Comment on Humboldt Wind Energy Project DEIR by June 14th

The energy company Terra-Gen (DBA Humboldt Wind LLC) is proposing a wind energy development on Bear and Monument ridges in the Eel River watershed near the towns of Scotia and Rio Dell. The Humboldt Wind Energy Project would include approximately 60 600 foot tall towers, 17 miles of new road, support facilities, and a 30+ mile transmission line on an approximately 2,218 acre footprint. The Draft Environmental Impact Report is out for review, with comments due on June 5th.

While Friends of the Eel strongly believes that an accelerated transition to clean energy is needed to stem the worst impacts of climate change, infrastructure project siting is critical to a project’s suitability, and one of this size at this particular site could have dire impacts on imperiled wildlife and their habitat. You may remember that Shell Energy had a similar proposal for the same site many years ago that was withdrawn in the face of strong community opposition.

Please send comments to Humboldt County Planning Department by June 14th to express your concerns. See below for suggested talking points.

Talking points to consider using:

Primary Concerns Directly Impacting Eel River Watershed Health

1. Transmission corridor/Gen-tie: The approximately 30-mile-long transmission line from the turbine site to the sub-station in Bridgeville (with a 100 foot cleared buffer) could have significant environmental impacts on the Van Duzen River and wildlife. Most of the land the lines would pass over is forested, and some of it old-growth. It is almost wholly Humboldt Redwood Company timber lands. There are multiple streams along the way that host protected salmonid species. Transmission lines also kill birds. However, the DEIR’s analysis of this corridor seems to be little more than a perfunctory add-on to its impact analysis and proposed mitigations for the primary site.
2. Transmission line fire risk: The project area is listed as a high hazard zone for fire, which the DEIR attempts to downplay, stating “The project site is subject to HRC’s logging and silviculture operations. These activities lower fuel loads and understory compared to non-managed lands, thus serving as a method of wildfire management.” This is a dangerous assumption that does not conform to the facts of wildlands fire as we know it. PG&E was recently found culpable for the fires that devastated entire communities in northern California 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. This proposal appears to continue with the high fire risk status quo transmission line infrastructure.
3. Drilling under the Eel River in Scotia: Directional drilling under the Eel River for the transmission line could cause something called a ‘frack out,’ in which polluted drilling slurry ends up in the waterway. 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).

Additional Concerns

1. Impacts to Marbled murrelets: The DEIR estimated that it will ‘take,’ i.e. kill, more than 20 of these protected birds. This exceeds the number of take allowed under HRC’s Habitat Conservation Plan. The proposed mitigation measures are inadequate to address the impacts.
2. Impacts to bats: Bats are perhaps 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. Local hoary bat populations look to be particularly vulnerable. The DEIR acknowledges this but fails to adequately address it. The proposed CEQA mitigation of a post-construction technical advisory committee to recommend additional mitigation measures is insufficient. To protect bats, nighttime turbine speeds need to be limited to less than 5 meters/second.
3. Impacts to the California condor: The site has been identified as prime habitat for the condors that are to be reintroduced by the Yurok Tribe. The project would seriously degrade this habitat for them and potentially poses a threat of death from turbine collision.
4. 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 downstream salmonid and amphibian habitat as well.
5. Tribal concerns: The Wiyot Tribe has expressed serious concerns about impacts on tribal cultural areas and is opposed to the project.

Friends of the Eel River is currently working on our technical comments. If you would like more details on our concerns, please email stephanie@eelriver.org. You can find the full DEIR here.