These comments concern the Draft Environmental Impact Statement (DEIS) and the Draft Habitat Conservation Plan (DHCP) for the Beech Ridge Wind Energy Project (BRE) in Greenbrier and Nicholas Counties, West Virginia. I am submitting these comments due to concern about the environmental impacts of utility-scale wind energy development in the central Appalachian mountain region.
Because of flaws and insufficiencies in the information and analysis provided in both the DHCP and the DEIS, I recommend that the U.S. Fish and Wildlife Service (FWS) adopt Alternative 1, the “No Action” alternative presented in the DEIS. The specific reasons for this recommendation follow.
(1) Failure to evaluate project benefits.
(2) Failure to account for the effects of White Nose Syndrome.
(3) Uncertainty associated with estimates of mortality and population impacts.
(4) The need for a more-objective and quantitative analysis of cumulative impacts.
Conservation Law Center:
Comment 1. The DHCP’s proposed operational measures do not satisfy the “minimize to the maximum extent practicable” permit issuance criterion of the ESA or the DHCP’s goal of avoiding and minimizing potential take.
Comment 2.1. The alternatives studied in the DEIS do not constitute a reasonable range of alternatives.
Comment 2.2. Of the three action alternatives presented in the DEIS, alternative 3 should be the Agency’s preferred environmental alternative.
Comment 2.3. The DHCP omits cut-in speed alternatives in its discussion of alternative actions to the proposed takings.
Comment 3. The DHCP does not fully address ESA section 7 criteria.
Comment 4.1. The DHCP does not adequately describe how federal listing of species will be treated as a changed circumstance.
Comment 4.2. The DEIS and DHCP do not adequately explain how the changed circumstance of white-nose syndrome will affect BRE’s responsibilities under the terms of its ITP/HCP.
Comment 5. The DEIS does not, but should, take a hard look at the biological implications of cumulative impacts by using a Leslie Matrix model.
Comment 6. The proposed biological goals improperly include the proposed conservation plan.
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