EPIC and the Northcoast Environmental Center submitted comments to the Humboldt County Planning Department regarding the Draft Environmental Impact Report (DEIR) for the Humboldt Wind Energy Project.
View entire comments: Humboldt Wind Project EPIC.NEC 6.14
Dear Planning Director Ford,
On behalf of the Environmental Protection Information Center and the Northcoast
Environmental Center (collectively “EPIC”), please accept these comments of the
Draft Environmental Impact Report (DEIR) for the Humboldt Wind Energy Project.
Our organizations support the responsible development of wind energy and
recognize the vital need for renewable energy development to combat and mitigate
the impacts of global climate change. Yet renewable energy is not without its
environmental costs, and here the proposed project has many worrying impacts.
Perhaps most fundamentally, the project is proposed in a precarious location—along
Monument and Bear River Ridges between the Eel River and the Ocean, and
overlapping in part with the Cape Mendocino Grasslands Important Bird Area. Due
to its location, the California Department of Fish and Wildlife warned in a scoping
letter to the county that the location was one with “High or Uncertain Impacts to
Wildlife” or was “Inappropriate for Wind Development.” As described in the DEIR,
the environmental costs of this project are often extreme, including potential
species-level population impacts to some wildlife. Because of the high risk project
area and significant environmental impacts, this project will demand more
mitigation than typically required at other wind energy projects to comply with
California law and to be a good neighbor in the community.
EPIC is concerned that the project as presented in the DEIR would present
unacceptable impacts to wildlife. Many of these impacts are capable of being
avoided or minimized. In our conversations with the project developer, EPIC has
been heartened, however, by Terra-Gen’s verbal commitment to work with the
conservation community to devise and implement mitigation measures and other
conditions on the project to ensure that the company is a good and responsible
neighbor. These comments reflect EPIC’s good faith attempt to provide Terra-Gen
and the county with our concerns and possible remedies to these concern. We expect
that these comments will be received in the same spirit.
EPIC further notes the difficulty that developer-imposed timelines create for this
project. The developer has set a construction deadline of December 2020 to take
advantage of tax incentives set to expire in 2021. This deadline has complicated the
review of the project and has introduced uncertainty, as multi-year surveys are still
ongoing (and will be completed only after the public has had an opportunity forcomment). Further, this tight deadline has meant that ordinary best practices to
avoid and reduce impacts, such as wet weather restrictions, may be waived to speed
up construction, increasing potential risk associated with the project. Given the
developer-imposed time conditions, it is appropriate to impose additional project
conditions to account for increased uncertainty and risk.
Lastly, as we more to decarbonize our energy infrastructure, it is imperative that
we proceed in a manner where we can learn from each project, both to increase
energy generation and to reduce impacts to the human and natural environment.
Wind energy development is still in its nascent stage and our knowledge of the best
practices are admittedly weak. In this pursuit of a clean energy future, we ask that
this project serve, in part, as an experiment, whereby new technologies and
techniques can be tested. To that end, we urge the county and developer to: (1)
make all data publicly accessible; (2) open the project site to researchers and to
work with Humboldt State University and other institutions to further our
collective understanding of wind energy development; and (3) be willing to adapt
and change, testing new theories and technology to meet our energy demands while
simultaneously reducing impacts.