This letter to the US Army Corps of Engineers details the deficiencies in Noble Environmental Power's application to build a 99-megawatt wind energy facility in Coos County, New Hampshire. The US Fish and Wildlife Service makes a powerful case for why a full Environmental Impact Statement (EIS) should be undertaken in accordance with the National Environmental Policy Act (NEPA).

This letter to the US Army Corps of Engineers details the deficiencies in Noble Environmental Power's application to build a 99-megawatt wind energy facility in Coos County, New Hampshire. The US Environmental Protection Agency makes a powerful case for why a full Environmental Impact Statement (EIS) should be undertaken in accordance with the National Environmental Policy Act (NEPA).

The Nature Conservancy of New Hampshire submitted the below comments to the New Hampshire Site Evaluation Committee in response to a proposal pending before the committee. The proposal, known as the Granite Reliable Power (GRP, LLC) Wind Park, seeks to erect thirty-three 3.0MW turbines along the Kelsey, Owlshead, and Dixville peaks located in Coos County, NH. GRP, LLC is owned by Noble Environmental Power.

The Audubon Society of New Hampshire submitted comments to the New Hampshire Site Evaluation Committee in response to a proposal pending before the committee. The proposal, known as the Granite Reliable Power (GRP, LLC) Wind Park, seeks to erect thirty-three 3.0MW turbines along the Kelsey, Owlshead, and Dixville peaks located in Coos County, NH. GRP, LLC is owned by Noble Environmental Power.

Noble Environmental, operating under the name Granite Reliable Power, LLC is proposing to erect a 99 MW wind energy facility in northern New Hampshire. The New Hampshire Fish and Game has submitted prefiled testimony to the State's Site Evaluation Committee expressing its concerns with the impacts to wildlife.

This document includes studies in Maine, Maryland, Minnesota, New Hampshire, New York, Pennsylvania, Vermont, Virginia and West Virginia.

Why did you petition to become an intervenor in this matter before the NH SEC?

With New Hampshire’s recent reinstatement of PILOT agreements and legislative efforts to a Renewable Portfolio Standard, the regulatory groundwork is being laid for more wind facilities to enter the state. Yet, New Hampshire, like many states, has no consistent regulatory process in place for reviewing these projects to ensure our environmental, societal, and economic interests are protected. The work the NH SEC has agreed to undertake in reviewing this application is precedent setting. How the committee approaches its review and the weight it places on arguments presented by all sides will impact other developments in the State as pertains to renewable energy projects.

There are a multitude of conflicting issues at play when considering any wind project. My commitment to this process is to help provide, to the best of my ability, valuable and timely information that will assist the Committee in making an informed decision on this application.

Below are two Phase I Avian Risk Assessments reports, prepared by Paul Kerlinger, for Vermont's East Haven Wind Farm (July 2003) and New Hampshire's Lempster Mountain Wind Power Project (June 2005). Phase I assessments have proven inadequate in assessing mortality at several sites in the U.S. including Mountaineer in West Virginia and Meyersdale in Pennsylvania. The US Fish and Wildlife Interim Wind/Wildlife Guidelines calls for multi-year evaluation of avian and bat activity using remote sensing.

Starting with our first interagency meeting on April 8, 2005, we have generally discussed three broad categories of activities that pose a potential concern for fish and wildlife resources. These include the potential for bird and bat collisions with turbines, habitat fragmentation effects on wildlife and impacts to waters/wetlands. At the April 8, 2005 interagency meeting, we recommended that CEI collect three (3) years of radar data on spring and fall bird/bat migrations to document the spatial and temporal use of the airspace by these flying vertebrates. Three years of radar data should be sufficient to gather information on the spatial and temporal distribution of birds in the airspace, including the year-to-year variability in migration patterns at this site, and represent our normal request for these data at wind projects. We have consistently requested that this data be collected at our meetings and field visits and continue to make this request for radar information.