Procedual Background: The Summit Ridge Wind Farm was granted a site certificate by the Oregon Energy Facility Siting Council (EFSC or Council) on August 19, 2011. The Council issued its Final Order on Amendment 1 and granted an amended site certificate on August 7, 2015, which approved a construction timeline extension and allowed flexibility in turbine layout and design. The Council issued its Final Order on Amendment 2 and granted a second amended site certificate on November 4, 2016, which approved a transfer of certificate holder ownership, a construction timeline extension, flexibility in turbine layout and design, and authorized a variance to a road setback requirement for 17 wind turbines. The Council issued its Final Order on Amendment 3 and granted a third amended site certificate on December 15, 2017, which approved a transfer of certificate holder ownership to the current certificate holder owner and parent company, Pattern Renewables. The applicant now seeks a 4th amendment to the certificate. A host of objections have been raised about the project. This page includes comments by K. Shawn Smallwood PhD outlining environmental concerns with the project as submitted. The Friends of the Columbia Gorge, Oregon Wild, the Oregon Natural Desert Association, Central Oregon LandWatch, the Audubon Society of Portland, and the East Cascades Audubon Society (collectively, “Commenters”) presented their own comments. Excerpts of the comments filed with the Council are provided below. The full documents can be downloaded from the links on this page.
Site Description: The Summit Ridge Wind Farm is an approved wind energy generation facility that would consist of up to 72 wind turbines with a peak generating capacity of 194.4 megawatts, located within a site boundary of approximately 11,000 acres.
Status: Under Review/Approved: The facility has not been built. On January 16, 2019, the Department received a complete Request for Amendment 4 (RFA4) of the Summit Ridge Wind Farm site certificate. RFA4 seeks Council approval to extend the construction commencement and completion deadlines for the facility, as established in the site certificate, by two years. The certificate holder requests that it be allowed until August 19, 2020 to begin construction and until August 19, 2023 to complete construction. The Department issued a Draft Proposed Order on Request for Amendment 4 on January 16, 2019.
On February 1, 2019, the certificate holder withdrew its request to proceed under the Type B path and requested to reissue the Draft Proposed Order under the default Type A path. The Department is reissuing the Draft Proposed Order accordingly. All previously submitted comments on the January 16 DPO are valid. The comment period on the reissued DPO will extend until the close of the public hearing.
K. Shawn Smallwood Conclusions
Pattern Energy’s request for extensions of the construction deadlines for the Summit Ridge Wind Farm was submitted with an amended Habitat Mitigation Plan (January 2019) and Pattern’s responses to EFSC standards. I commented on (1) the suitability of the habitat assessment underlying the amended Habitat Mitigation Plan, and (2) the need to update baseline surveys, project impact predictions, mitigation measures, and post-construction monitoring protocols. I found that the habitat assessment was based on a conveniently invented characterization of wildlife habitat that does not find its origin in wildlife ecology and that is inconsistent with the definition of habitat in OAR 635-415-0005. Habitat analysis is needed for each species, separately, and in the context of a wind project it needs to include displacement effects of wind turbines.
The most recent avian use surveys and bat detection surveys at the proposed Summit Ridge site were performed in 2009. In the decade since those surveys, much has been learned about the strengths and weaknesses of methods used in the baseline study (Northwest Wildlife Consultants 2010) and in the proposed post-construction fatality monitoring plan. To be consistent with the applicable law and management guidance, the baseline study needs to be updated. Use surveys are needed at the level of effort recommended by the US Fish and Wildlife Service. Behavior surveys are needed for micro-siting to minimize collision impacts. Bat surveys are needed at many more stations across the project area and at heights above ground that are relevant to wind turbine impacts. All measured variables and metrics need to be reported to scientific standards, including error terms and assessments of potential biases. Impact predictions are needed that are based on careful interpretation of impacts measured at other wind projects, and this interpretation needs to account for the biases and sources of uncertainty that have been quantified since 2010. Of critical importance is the need for a cumulative effects analysis, given the >3-fold increase in USA installed wind energy capacity since this project was initially proposed and the fatality impacts that
have accompanied this increase.
I recommended wind turbine micro-siting to minimize collision impacts of birds and bats because, incredibly, no such effort has yet occurred at the Summit Ridge site. Careful micro-siting has been found to substantially reduce raptor fatality rates at repowered wind projects in the APWRA, so we know it works. Besides careful micrositing to minimize collision impacts of both birds and bats, operational curtailment needs to be formulated as a mitigation measure, and funds need to be committed for wildlife rehabilitation facilities to care for injured wildlife. I also recommended a suite of improvements to the proposed post-construction fatality monitoring, most importantly the use of skilled detection dogs as fatality searchers, a much shorter search interval than proposed, and longer duration.