On March 1, the Oregon Department of Fish and Wildlife in a letter to the Oregon Department of Energy recommended against the issuance of a site certificate for the Antelope Ridge Wind Farm proposed by Horizon Wind Energy for development above Union.
Fifty pages long, the letter is rich in detail and includes the use of dozens of acronyms. However, I encourage anyone interested in the proposed wind energy facility to read the document carefully. I believe that the letter reveals that Horizon has demonstrated a repeated pattern of critical failures: failure to negotiate in good faith with ODFW, failure to provide ODFW with requested information and failure to effectively accommodate ODFW’s concerns for the impact of the project on the area’s wildlife. All statements within quotations are taken from the letter.
The letter initially describes ODFW’s responsibility to assure wind energy developers’ compliance with Oregon’s laws and regulations regarding wildlife. The letter then states that the ARWF is “one of the first wind power projects in Oregon proposed to be sited in critical big game winter range and very productive wildlife habitat, resulting in the potential construction of a large industrial facility that negatively impacts Oregon’s wildlife.” Despite the wide array of negative impacts to the area’s wildlife, which are listed throughout in great detail, the letter states, “Unfortunately, after a number of meetings, Horizon withdrew from the discussions (with ODFW).”
The letter describes an area within the proposed project boundary called the Zone of Multiple Biological Values within which ODFW recommended that “no construction of wind turbines, associated road systems or associated infrastructure take place.” ODFW recommended not developing the area for wind energy because the area is so rich in wildlife (listed in detail) that “Mitigation for impacts to this habitat and species dependent on it, while not impossible, will be very difficult to achieve.”
The letter states that during the earlier development of the Elkhorn Wind Energy Facility near North Powder, Horizon agreed not to place turbines within the zone. However, “Despite ODFW’s concerns and recommendations not to develop on the (zone) during siting of (Elkhorn) …the applicant continues to propose turbine sitings on Ramo Flat and on the low elevation bench southwest of Union as part of the ARWF – the heart of the Zone of Multiple Biological Values.” That is, despite Horizon’s earlier acknowledgement of the zone as an area too biologically sensitive for development, the corporation has chosen to make the ecologically fragile zone the “heart” of the Antelope Ridge Wind Energy Facility.
I was unaware of the fragile nature of bats until I read in the letter of the threat posed to this economically important species by the proposed wind development. “Bats are long-lived (up to 31 years) with low productive rates. Females usually only have one to two young per year, depending on the species. Young are entirely dependent on parental care … the death of an adult female would therefore also cause the death of her dependent young.”
The letter states that, “The ARWF Monitoring and Mitigation Plan (offered by Horizon) fails to address any actions that may minimize direct impacts to bats, it only suggests monitoring bat fatalities and including those number in project reports.”
The significance of Horizon’s failure to offer greater protection to bats is revealed in a later paragraph which states, “The cumulative effects of sustained high mortality from ever-increasing wind energy projects and the introduction of White-nose Syndrome, a devastating disease that has killed over a million bats in the eastern U.S. and is moving westward, could be catastrophic to populations of hibernating bats in the west. Avoiding or minimizing bat fatalities is essential to prevent population crashes that could lead to Endangered Species Act listing of the hardest hit species, some of which are already in decline.”
In regards to the impact to elk and deer within the proposed energy development, the letter states, “ODFW manages wildlife in a manner that is compatible with the primary uses of the land. In the case of placing a wind farm in established big game habitat, the primary use of the land changes. A large industrial site in productive wildlife habitat is a significant alteration of the current primary use. The Applicant (Horizon) fails to address how big game use will be mitigated.”
“Most of the proposed project is on either big game winter range or big game critical wildlife habitat, and extremely critical to the continued welfare of the deer and elk dependent on it.”
Any reader, pro or anti-Antelope Ridge, will be impressed with the amount of work and research that went into the writing of this letter. Their recommendation is the product of thoughtful effort and they deserve the thanks of every Union County resident.
Charlie Gillis is a La Grande attorney who represents Friends of the Grande Ronde Valley.
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