February 27, 2009
Thomas S. Burack, Chairman
Site Evaluation Committee
N.H. Department of Environmental Services
29 Hazen Drive
Concord. NH 03301
Re: Application of Granite Reliable Power, LLC, Docket No. 2008-04
Dear Chairman Burack,
The Audubon Society of New Hampshire is a statewide non-profit organization dedicated to the conservation of wildlife and habitat throughout New Hampshire. We appreciate the opportunity to comment on the application of Granite Reliable Power, LLC for a certificate for site and facility for a wind energy installation in Coos County (Docket 2008-04). In the interests of full disclosure, our staff biologists conducted breeding bird surveys at the project site in contract with Noble Environmental Power during the summer of 2007. A clause in the contract specifically reserved our right to comment on the proposed project once the application was submitted.
New Hampshire Audubon supports appropriately sited wind turbines as one component of New Hampshire’s renewable energy portfolio. We consider appropriate siting to include avoidance of substantial impacts to sensitive habitats and species of conservation concern. The turbines on Dixville Peak, northern Owlhead Mountain, and especially on Mt. Kelsey fail to meet these criteria.
High elevation spruce-fir forests occur from approximately 2500 ft to approximately 3500 ft elevation in New Hampshire’s White Mountains and North Country. While the lower limit of these forests varies with aspect and soil conditions and exists as a transition zone rather than a sharp boundary, 2700 ft is commonly considered a reasonable elevation limit for management guidelines. (We note, however, that the U.S. Forest Service uses 2500 ft. for such purposes.) High-elevation spruce-fir forests are adapted to survive harsh growing conditions. Compared to forests at lower elevations, these sites have shallower, more nutrient-poor soils, higher levels of precipitation, stronger winds, colder temperatures, more frequent exposure to ice damage, and shorter growing seasons. These conditions result in low tree species diversity, very slow growth rates, and high mortality rates. The shallow soils, steep slopes, and high precipitation also create a high risk of erosion when vegetation is removed. It is these conditions that qualify high elevation spruce-fir forests as sensitive habitat, and that led the State of New Hampshire to engage industrial forest landowners of high-elevation spruce-fir forests in special management agreements to protect this unique resource by limiting harvest levels.
Maine’s Land Use Regulation Commission (LURC) includes all land above 2700 ft. elevation within the Mountain Area Protection Subdistrict, where land uses are regulated to “preserve the natural equilibrium of vegetation, geology, slope, soil, and climate in order to reduce danger to public health and safety posed by unstable mountain areas, to protect water quality, and to protect mountain areas for their scenic values and recreational opportunities.” LURC has twice denied the request of Maine Mountain Power to rezone land on Black Nubble Mountain from Mountain Area Protection to Planned Development Subdistrict in order to construct a wind farm there, based, in part on the high ecological value of the high elevation lands and the proposed project’s alteration of a “particularly sensitive area.” These concerns and justifications apply equally to high-elevation lands in New Hampshire.
While many of the road miles required for this project follow existing logging roads and skid trails, forestry roads exist primarily at elevations below 2700 feet, since harvesting is neither economical nor sustainable above this elevation. The impacts of road construction along these high ridgelines will extend far beyond the footprint of the openings. The extensive linear openings in the forest canopy will expose the adjacent forest to increased wind, resulting in significant and progressive blowdown. In addition, road construction at the higher elevations is likely to require significant terrain alteration, including use of explosives, in an area of high erosion risk and fragile soils. Standard road construction in such areas involves minimizing grades with numerous switchbacks. This approach would require more extensive clearing and terrain alteration, while straighter roads would greatly increase erosion risk both during and after construction. There is no minimal-damage strategy for constructing these roads.
In addition to being highly sensitive habitat, the high-elevation forests on Dixville Peak and Mt. Kelsey support several species of conservation concern in the state and region, including American Marten, Bicknell’s Thrush, and possibly American Three-Toed Woodpecker. Turbine placement above 2700 ft. will result in direct habitat loss and additional habitat degradation for these species.
The American Three-Toed Woodpecker was common in the spruce-fir forests of New Hampshire’s White Mountains and North Country prior to extensive harvesting in the late 1800s. This woodpecker and its Eurasian equivalent are now considered species of conservation concern in both the eastern and western hemispheres. American Three-Toed Woodpeckers require large areas of natural spruce-fir forest, and occupy home ranges of nearly 400 ha [988 acres]. Progressive harvesting of large-diameter spruce and fir trees over the course of the twentieth century has left few areas of suitable habitat large enough to support breeding pairs. We acknowledge that our surveys did not definitively document the presence of this woodpecker in the project area. However, habitat conditions at the locations on Mt. Kelsey where potential encounters occurred strongly suggest this species rather than the similar Black-Backed Woodpecker, which favors younger, more open spruce-fir forest. American Three-Toed Woodpeckers were documented during the 1980s in an extensive stand of spruce-fir forest in the Phillips Brook valley, which has since been harvested. Mt. Kelsey is the closest area of suitable habitat, lending further credence to the likelihood of the species’ current presence there.
Studies in Quebec indicate that these woodpeckers favor interior forest, and respond to the presence of clearcuts up to 262 ft [80 m] from the forest edge. By bisecting the extensive high elevation spruce-fir forest at the northern end of the project area, turbines above 2700 feet will reduce suitable habitat for this species well beyond the footprint of the proposed development.
High-elevation spruce-fir forests of northeastern North America provide the only breeding habitat available to the Bicknell’s Thrush, which has the smallest breeding range of any North American bird. For this reason, habitat loss has more significant implications for this bird than for more widely distributed species. While this thrush spends most of its time foraging below the forest canopy, the males perform evening courtship flights which would take them into the rotor-swept zone and increase the risk of mortality.
Impacts of turbine noise on wildlife are essentially unknown. Mechanical noise from turbines is minimal, dissipates rapidly with increasing distance from the source, and is unlikely to impact wildlife behavior. Aerodynamic noise, which varies with the ratio of blade tip speed to wind speed, can be transmitted over considerable distances; sound waves from multiple turbines can combine to amplify the sound in the area of intersection (so noise is greater at a distance from the turbines than along the turbine string itself); and sound waves can bounce off neighboring mountains in unpredictable ways, increasing noise levels in unpredictable locations. The potential for interference with predator-prey relationships and vocal communication of birds during courtship and breeding indicate a need for additional investigation at existing wind energy facilities before this project moves forward.
New York, Pennsylvania, and Iberdrola Renewables, among others, have prepared guidelines for pre- and post-construction bird and bat studies. We strongly urge that the SEC review these documents and consider adopting appropriate guidelines to standardize required wildlife studies for wind energy proposals in New Hampshire.
We also strongly recommend that the SEC adopt siting guidelines for New Hampshire wind energy facilities to guide developers to environmentally appropriate sites for development of this energy source. he proposed guidelines prepared by the ad hoc Wind Energy Facility Siting Guidelines Working Group and delivered to the State of NH Energy Policy Commission (EPC) Wind Siting Subcommittee in May 2007 provide a good starting place for consideration.
In view of the above, we strongly urge the SEC to:
- Deny a license for proposed turbines located above 2700 ft. elevation.
- Adopt siting guidelines for wind energy facilities in New Hampshire,
- Develop standardized guidelines for pre- and post-construction wildlife studies at wind energy facilities in New Hampshire.
Thank you for the opportunity to comment.
Michael J. Bartlett
February 27, 2009
Mr. Richard Roach
U.S. Army Corps of Engineers
696 Virginia Road
Concord, MA 01742
Dear Mr. Roach,
… We strongly encourage the Corps of Engineers to require an Environmental Impact Statement as part of the Section 404 permitting process for this proposed project. The permit application states that there will be 58 acres of impact above 2700 ft. elevation. This level of impact alone is reason for concern. However, to date there has been no comprehensive geotechnical analysis for the routes of proposed roads at these elevations. The soils and topography of these areas suggest that significant terrain alteration will be needed to construct these roads. Fulfillment of curve radius and grade requirements will involve significant cuts and fills, including blasting. These terrain alterations will lead to as yet unidentified impacts to both surface and groundwater hydrology.
The December 2008 testimony of Dr. George Mariani highlights the significant increases in projected acreage of land disturbance and wetlands impacts from the initial SEC application in July to various October permit applications. We believe that actual acreages of proposed impacts have not been adequately assessed to date, and are likely to exceed current projections. Dr. Mariani’s testimony also outlines a number of measures to improve the plan for water quality protection and to monitor its implementation. We strongly urge that the Corps consider these recommendations, including pre-construction baseline surveys, as conditions of any Section 404 permit for this project.
Testimony of Dr. Gary R. Sanford details wetland impacts associated with proposed high elevation turbines and expresses concerns about the overall net loss of wetland values associated with this project. We urge the Corps to take these concerns seriously in evaluating the Section 404 permit application. Dr. Sanford’s supplemental testimony of February 2009 outlines opportunities to reduce wetlands impacts, including steeper side slopes and use of hard engineering measures. Such measures demand a close analysis by your agency to assess their appropriateness in this setting and the attendant environmental impacts of these mitigation measures.
In summary, the Audubon Society of New Hampshire holds significant concerns regarding wetlands and water quality impacts of the proposed Coos County wind energy project. We strongly urge the Corps to require an Environmental Impact Statement that fully documents the areas and associated depths of blasting required; the complete footprint of the project’s roads, including side slopes; and a comprehensive analysis of ground and surface water impacts.
Michael J. Bartlett
Download original document: “Letter from N.H. Audubon Society to Site Evaluation Committee”
Download original document: “Letter from N.H. Audubon Society to U.S. Army Corps of Engineers”
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