In September, a coalition of local environmental groups sent a letter to the director of the Humboldt Planning Department to express concerns and recommendations regarding the proposed wind farm to be located on two mountain ridges above Rio Dell—Bear River Ridge and Monument Ridge. The letter reflected opinions of the major conservation organizations of the North Coast, including the Northcoast Environmental Center, EPIC, Friends of the Eel River, California Native Plant Society (North Coast Chapter), the Sierra Club (North Group, Redwood Chapter), and 350 Humboldt.
These organizations are not opposed to wind energy development, understanding that renewable energy development is crucial to address the urgency of the climate crisis. However, projects must include proven mitigation measures to reduce impacts to wildlife. The released Draft Environmental Impact Report lacked these measures. A Final Environmental Impact Report had been expected to be released at the end of September, but was not yet available as EcoNews went to print.
The following (in italics) is excerpted from the letter sent September 11 to Humboldt Planning Department Director John Ford, with regard to Terra-Gen’s proposed Humboldt Wind Project.
Given the largely undeveloped landscape and presence of at-risk species, the Humboldt Wind Project will have significant impacts to the environment. At present, these impacts have not been minimized or mitigated to an acceptable level. In most circumstances, [environmental] impacts can be minimized and mitigated to acceptable levels through sound planning, siting, and imposition of the best available technology. While some of our organizations support the “No Project” alternative, others could support a modified project. Should the project move forward we unanimously insist that the following conditions be met:
Move Turbines Off Bear River Ridge. Bear River Ridge is home to Humboldt’s isolated and unique population of horned larks, sits entirely within the Cape Mendocino Grasslands Important Bird Area, and is home to the majority of the rare plant species in the project area. What’s more, the area is culturally significant to the Wiyot Tribe, who have voiced their opposition to placing turbines at this sensitive location.
Minimize and Mitigate Impacts to Ecosystems and Sensitive Species. It is imperative to complete all survey protocols before the EIR concludes to best understand the nature and magnitude of wildlife impacts. The best way to minimize impacts is to stop operation when sensitive species are present or during survey-defined high-risk periods. Operational curtailment is an industry-standard approach to mitigating wildlife impacts and is a part of other Terra-Gen projects.
Provide Adaptive Management Throughout the Life of the Project. As technology advances, and our ability to reduce impacts and increase efficiency increases, the project should adopt emerging technologies and adapt to changing conditions. The project needs to include an adaptive management program that works to continually refine the project to reduce operational impacts. It is imperative to modify existing mortality monitoring to include canine-assisted searches or other emerging detection technology to ensure that adaptive management uses the best available data and that mortality data be collected throughout the life of the project. The county needs to guarantee a neutral and transparent process for determining necessary project modifications.
Reduce Sediment Impacts to the Maximum Extent Practicable. The project will require significant ground disturbance, a known cause of sediment pollution and landslides. Our organizations are concerned about the impact of this sediment pollution. To the maximum extent practicable, all ground disturbance should occur outside the wet weather period, defined as Oct. 15 to May 15. Further efforts should also be made to reduce impacts from the Gen Tie line, such as by using existing power right of ways and other steps to reduce new ground disturbance and forest fragmentation.