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Whistling Ridge energy project

This letter is written on behalf of Friends of the Columbia Gorge (“Friends”) and Save Our Scenic Area (“SOSA”). Friends and SOSA are nonprofit conservation advocacy organizations dedicated to the protection and enhancement of the resources of the Columbia River Gorge region. Friends’ and SOSA’s members live in the communities and use and enjoy the resources that would be affected by the Whistling Ridge Energy Project (“Project” or “WREP”), proposed by Whistling Ridge Energy LLC (“WRE” or “Applicant”).

As organizations and individuals interested in the Whistling Ridge project and the future of the Columbia Gorge, we write today to ask that Bonneville Power Administratio (“BPA”) deny the generation interconnection request (“GIR”) sought by WRE.

In addition, for the reasons explained below, BPA must prepare and issue a supplemental environmental impact statement (“EIS”) for the Project prior to making a decision on the interconnection request. Given that the basic Project details, likely impacts, and mitigation measures have yet to be disclosed by the Applicant and have yet to be reviewed or decided by the State of Washington, BPA should coordinate with the Washington Energy Facility Site Evaluation Council (“EFSEC”) in the preparation and issuance of a supplemental EIS. …


1. Background

  1. The Proposal
  2. The Project Site
  3. Procedural History
  4. The Current Status of the Project

2. The project details for the proposed Whistling Ridge Project are currently unknown, making any generation interconnection approval premature and inappropriate.

3. BPA should not act on the interconnection request until the System Impact Study is revised and updated.

4. Because the Applicant concedes that the Whistling Ridge Energy Project is not economically viable as approved by Governor Gregoire, BPA should deny the interconnection request.

5. Because the Project has been substantially changed by the decisions of EFSEC and Governor Gregoire, BPA must prepare and issue for public comment a supplemental EIS.

6. A supplemental EIS, jointly prepared by BPA and EFSEC, is necessary to review the numerous unresolved and undecided aspects of the Project.

7. The cumulative impacts analysis in the 2011 final EIS must be updated in a supplemental EIS.

  1. Because installed wind energy capacity has increased dramatically since 2011, the cumulative impacts analysis in the FEIS is outdated and inadequate.
  2. The cumulative impacts analysis in the FEIS must be supplemented to evaluate the cumulative impacts of several large-scale transmission and energy projects (other than wind projects) within the analysis area.

8. BPA should evaluate whether the dramatic increases in regional wind energy capacity and transmission capacity since the 2011 FEIS affect the stated purposes and need for the Whistling Ridge Project.

9. An SEIS is required to evaluate new information regarding impacts to wildlife and to fully disclose the Project’s impacts to wildlife.

  1. Noise Impacts
  2. Failure to Quantify Impacts to Birds and Bats from Mortality Caused by Blade Strikes
  3. Golden Eagles and Bald Eagles
  4. Failure to Evaluate Relative Abundance of Sensitive-Status Species
  5. Failure to Include Critical Information on Impacts to Bats
  6. Mitigation Measures for Adverse Impacts to Wildlife
  7. BPA should review the most recent science on wildlife impacts.

10. The Project and proposed interconnection require permits under the Bald and Golden Eagle Protection Act and the Migratory Bird Treaty Act.

11. An SEIS is required to evaluate new information regarding impacts to scenic resources and to fully disclose the Project’s impacts to scenic resources.

12. BPA should review recent studies on the adverse effects of wind energy development on human health and on the human environment.

13. Conclusion

Download original document: “Comments to Bonneville Power Administration – Friends & SOSA – Whistling Ridge energy project [1]

Katey Grange, Environmental Lead
Amy M. Gardner, Project Manager
Bonneville Power Administration
WRE Project (DOE/EIS-0419)

Nathan Baker, Staff Attorney, Friends of the Columbia Gorge
Gary K. Kahn, Attorney for Friends of the Columbia Gorge
J. Richard Arambaru, Attorney for Save Our Scenic Area