Thankfully, there is a growing body of science to suggest what can be done. Instead the DEIR kicks the can down the road, requiring the establishment of a technical advisory committee to be formed after impacts are measured to examine what can be done. The DEIR correctly recognizes that the wind project is capable of producing significant impacts-including the localized extinction of the population or a species-level population impact-but fails to do much of anything to avoid, minimize, or mitigate the harm.

Every fall, thousands of hoary bats descend upon Humboldt Redwoods State Park, exhibiting a “swarming” behavior that appears to be unique to this region. This project is particularly worrisome because it is so close to an important bat migration hotspot.

All three are migratory bats that exhibit behaviors that put them at high risk for collision and death from wind projects. BatsĪcoustical surveys of the project area found that it is used by numerous bats, including those most frequently killed by wind projects: hoary bats, silver-haired bats, and western red bats. A curtailment policy should be developed by a panel of species-specific experts based on the best available information. Even if the benefits were certain, this appears to be a Faustian bargain-accepting additional and unnecessary murrelet deaths instead of avoiding them where possible.Īt a minimum, the project needs to be reformed to avoid murrelet flight paths, as identified through radar surveys, and include operational curtailment during high-risk periods. Such mitigation measures are important, but the purported benefits of this work is largely speculative. Instead, the project tries to compensate for murrelets deaths by funding projects that seek to increase murrelet nesting success by deterring corvids that prey on murrelet eggs. The current project, as outlined in the DEIR, fails to do either. Harm could also likely be minimized by the curtailment of blade-spinning operations during high-risk periods. There are no known measures to avoid harm to murrelets, except avoidance of areas that are likely within the flight paths of murrelets. Given the high uncertainty of impacts, it is critically important that the project avoid impacts first. If the avoidance rate dips to 96 percent, the total number of murrelets killed would double. A small change in data makes a huge difference. The collision risk model, however, is very sensitive to the avoidance rate. Based on this projected avoidance rate, the DEIR concludes that the project is likely to kill about 20 murrelets over the 30 years of the project. Absent better data, the project assumes- by looking at other avoidance rates for other species-that murrelets will avoid wind turbines 98 percent of the time they fly through the project area. There currently are no operational large-scale wind projects within the murrelet’s range, so there is no data concerning murrelets and wind turbines. The project is likely to result in the deaths of some murrelets from collisions. This pigeon-sized bird is identified as threatened under both the federal and California Endangered Species Act and is in alarming decline in both Washington and Oregon. The marbled murrelet, a small seabird that nests in the mossy branches of coastal old-growth forests, is one of the most iconic species of the environmental movement. As it stands, the DEIR does not account fully for impacts to bird and other species, such as risks to bats and murrelets. While we acknowledge the urgency to develop renewable energy projects to limit the harm of global climate change, the environmental costs must still be fully analyzed and understood before this project can be fully evaluated. Our organizations urge the project proponents and Humboldt County to undertake additional consultation and outreach efforts to fulfill their obligations to the County’s citizens and our wildlife. The project as described in the DEIR does not meet the environmental standards nor have the environmental protections we demand. Our detailed comments are available on our websites. Photo: Wikipedia CC.ĮPIC and the Northcoast Environmental Center submitted comments in June on the draft environmental impact report (DEIR) for the proposed Terra-Gen Humboldt Wind Energy Project proposed for Monument and Bear River Ridges outside of Scotia. Alta Wind Energy Center in Tehachapi, CA, developed by Terra-Gen.

Terragen wind