Greater Sage-Grouse Conservation Assessment and Strategy ... · Greater Sage-Grouse Conservation...

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September 13, 2010

Marla Rae

Chair, Oregon Fish and Wildlife Commission

3406 Cherry Avenue, NE

Salem, Oregon 97303

Dear Chair Rae and Members of the Commission,

Thank you for the opportunity to share our comments regarding the

Greater Sage-Grouse Conservation Assessment and Strategy for Oregon

(Draft Plan Revision). The members of the Renewable Northwest Project

(RNP) share the Oregon Department of Fish and Wildlife’s (ODFW) concern

for the health of the greater sage-grouse and its habitat, and hope to work with

the Department to enhance species and habitat protection.

Although we support efforts to enhance species protection and habitat

restoration, we cannot support the Draft Plan Revision. In our view, the Draft

Plan Revision was developed without broad stakeholder participation, reflects

an unreasonably narrow interpretation of the Department’s mandate, and fails

to balance the positive role renewable energy development can play for habitat

protection.

Adopting the Draft Plan Revision would, in our opinion, only increase

tension among the stakeholders who care about wildlife and habitat protection,

decreasing the likelihood affected communities would use the Draft Plan

Revision to guide their land use decisions. Increasing the regulatory burden

associated with sage-grouse and sage-grouse habitat (SGSH) without

supplying new revenue sources to pay for the programs would also decrease

the likelihood local, state, or federal agencies would be capable of adopting

these guidelines. And the failure to create an environment conducive to

responsibly sited renewable energy projects will make it more difficult for

federal land managers to accomplish the mandate from both Congress and the

President to build renewable energy facilities on federal land, thereby robbing

rural communities of the chance to secure badly needed economic investments.

In lieu of adopting the Draft Plan Revision, we respectfully ask the

Commissioners to instruct ODFW senior officials to work collaboratively with

all interested stakeholders to redraft the proposal. By seeking more balanced

input and exploring other conservation strategies to achieve the State’s

conservation goals, we believe the Agency will earn critical stakeholder

support, especially from the communities most directly affected by the

proposed Draft Plan Revision. Working directly with renewable energy

companies to find ways to enable renewable energy projects in certain areas

will not only contribute to the State’s efforts to diversify its renewable energy

mix, it will also create new revenue streams that both local communities and

RNP Members

3Degrees

3TIER

American Wind Energy Assoc.

Blattner Energy

Bonneville Environmental Foundation

BP Wind Energy

Calpine

Center for Energy Efficiency & Renewable Technologies

CH2M Hill

Citizens' Utility Board

Climate Solutions

Clipper Windpower

Columbia Energy Partners

Columbia Gorge Community College

David Evans & Associates

Element Power

Environment Oregon

Environment Washington

enXco, Inc.

E.ON Climate & Renewables North America

Eurus Energy America

EverPower

Gamesa Energy USA

GE Energy

Geothermal Resources Council

Green Mountain Energy

Horizon Wind Energy

Iberdrola Renewables

Jones Stevedoring

Lane Powell PC

Montana Environmental Information Center

MontPIRG

Natural Resources Defense Council

NextEra Energy Resources

Northwest Environmental Business Council

NW Energy Coalition

Northwest Environmental Advocates

OSPIRG

Port of Vancouver, USA

Portland Energy Conservation, Inc.

REC Silicon

REpower

RES America Developments

Ridgeline Energy

Solar Oregon

SolarCity

Stoel Rives, LLP

SunPower Corporation

Tanner Creek Energy

Tonkon Torp LLP

Vestas Americas

Warm Springs Power & Water Enterprises

Washington Environmental Council

WashPIRG

Western Resource Advocates

Western Wind Power

917 SW Oak St, Suite 303 • Portland, OR 97205

phone: 503-223-4544 • fax: 503-223-4554 • www.RNP.org

2

government officials need to implement a comprehensive sage-grouse/sage-grouse habitat

protection and enhancement plan. Building cooperation among stakeholders – not increased

and ineffective additional regulations – will enable local, state, and federal agencies to work

collaboratively with land owners, advocates of all kinds, and renewable energy companies.

On behalf of our members, RNP pledges to work with you and ODFW officials to

develop and implement stronger, more effective measures to enhance the sage-grouse and its

habitat while also advancing important economic development and climate change

objectives.

Respectfully,

John J. Audley, Ph.D

Deputy Director

Renewable Northwest Project

Enclosures:

Appendix 1: A Brief History of Renewable Northwest Project

Appendix 2: Combining Values: ODFW’s Core Area and Corridor Strategy Map and

Renewable Energy Potential

Appendix 3: Renewable Northwest Project Comments on “Greater Sage-Grouse

Conservation Assessment and Strategy for Oregon”

Appendix 4: Renewable Northwest Project’s Proposals for a Way Forward

Supplement: Literature Review – “Greater Sage-Grouse and Wind Energy Development: A

Review of the Issues,” by Greg Johnson, WEST, Inc.

1

Enclosures:

• Appendix 1: A Brief History of Renewable Northwest Project

• Appendix 2: Combining Values: ODFW’s Core Area and Corridor

Strategy Map and Renewable Energy Potential

• Appendix 3: Renewable Northwest Project Comments on “Greater

Sage-Grouse Conservation Assessment and Strategy for Oregon”

• Appendix 4: Renewable Northwest Project Proposals for a Way

Forward

• Supplement: Literature Review – “Greater Sage-Grouse and Wind

Energy Development: A Review of the Issues,” by Greg Johnson,

WEST, Inc.

RNP Members

3Degrees

3TIER


Blattner Energy


BP Wind Energy

Calpine


CH2M Hill


Climate Solutions

Clipper Windpower




Element Power

Environment Oregon


enXco, Inc.



EverPower

Gamesa Energy USA

GE Energy



Horizon Wind Energy


Jones Stevedoring

Lane Powell PC


MontPIRG




NW Energy Coalition


OSPIRG



REC Silicon

REpower


Ridgeline Energy

Solar Oregon

SolarCity

Stoel Rives, LLP


Tanner Creek Energy

Tonkon Torp LLP

Vestas Americas



WashPIRG


Western Wind Power



1

Appendix 1: A Brief History of Renewable Northwest Project

Since 1994, Renewable Northwest Project (RNP) has been working to

increase the amount of new renewable energy in our electricity portfolio in

Oregon, Washington, Idaho, and Montana. Building on the region’s renewable

energy foundation in hydroelectric and biomass, the goal of RNP is to further

expand and diversify the energy stream with the implementation of responsibly

sited, new renewable energy.

From our very beginning, the work of RNP has involved the

responsible siting of new renewable energy projects. In the mid-‘90s, RNP

played an instrumental role in efforts to discourage geothermal energy

development in the area near Borax Lake. More recently, we led efforts in

Washington and Oregon to develop and implement voluntary siting guidelines

for wind projects in the Columbia Gorge. In our opinion, “clean energy” must

also be “green energy” by meeting the highest standards for minimal

environmental impact.

RNP is a 501(c)3. Our strength stems from the diversity of our

membership, including the largest renewable energy manufacturers and

developers in the world, the most effective environmental advocates for

solutions to climate change, and organizations that make sure renewable

energy is priced within reach of average citizens. A simple majority of our

board members are representatives from environmental organizations -

including Climate Solutions, Natural Resources Defense Council, and

Environment Oregon - and our Board Chair also represents a non-profit

organization (Northwest Energy Coalition). Sixty percent of our funds come

from membership dues; the balance of our operating funds come from

foundations that care about climate change and the quality of life in the

Northwest.

For more information about RNP, please visit www.rnp.org.

RNP Members

3Degrees

3TIER


Blattner Energy


BP Wind Energy

Calpine


CH2M Hill


Climate Solutions

Clipper Windpower




Element Power

Environment Oregon


enXco, Inc.



EverPower

Gamesa Energy USA

GE Energy



Horizon Wind Energy


Jones Stevedoring

Lane Powell PC


MontPIRG




NW Energy Coalition


OSPIRG



REC Silicon

REpower


Ridgeline Energy

Solar Oregon

SolarCity

Stoel Rives, LLP


Tanner Creek Energy

Tonkon Torp LLP

Vestas Americas



WashPIRG


Western Wind Power



1

Appendix 2: Combining Values: ODFW’s Core Area and Corridor

Strategy Map and Renewable Energy Potential

The Department of Energy’s (DOE) Core Area Strategy maps combine

the Agency’s sage-grouse data with its land categorization policy to prioritize

certain land parcels as either category 1 or category 2.

Using both actual data samplings and statistical estimations, the Oregon

Department of Fish and Wildlife (ODFW) created the new “core area

strategy.” The Agency proposes using its current land categorization policy

criteria to designate critical sage-grouse land as either category 1 (habitat that

is irreplaceable, essential to sage-grouse viability) or category 2 (essential).

The accompanying two maps introduce wind and solar resources onto

the ODFW core area map. These maps were developed to determine whether

or not (or how) the Agency could entertain parcel category adjustments using

more current, detailed, biological information provided by private landowners

or renewable energy developers who work with professional biologists to

achieve siting best-practices prior to pursuing their work. Effectively, without

consulting the Oregon Department of Energy (ODOE), the Energy Facility

Siting Council, or the developers who depend upon these processes to make

important investment decisions, ODFW land categories re-write ODOE’s

process for developing renewable energy siting proposals. These two maps

showcase the prominence of the core areas and connectivity corridors, which

essentially removes the potential development of responsibly sited renewable

energy projects throughout southeastern Oregon.

RNP Members

3Degrees

3TIER


Blattner Energy


BP Wind Energy

Calpine


CH2M Hill


Climate Solutions

Clipper Windpower




Element Power

Environment Oregon


enXco, Inc.



EverPower

Gamesa Energy USA

GE Energy



Horizon Wind Energy


Jones Stevedoring

Lane Powell PC


MontPIRG




NW Energy Coalition


OSPIRG



REC Silicon

REpower


Ridgeline Energy

Solar Oregon

SolarCity

Stoel Rives, LLP


Tanner Creek Energy

Tonkon Torp LLP

Vestas Americas



WashPIRG


Western Wind Power



297

226

44

141

8

71

31

7

99

74

47

242

245

232

140

78

228

45

216

227

82

14

140

14

224

230

205

35

221

126

427

37

78

27

21

22

129

16

58

126

207

138

6611

244

203

214

209

140

237

99

52

19

204

201

3

206

21118

293

380

126

11

55

51

39

503

218

55

86

142

238

62

219 197

395

95

9795

20

97

26

30

26

97

27

20

395

20

97

26

95

26

395

395

395

84

84

84

84

82

84

5

Coburg

Condon

Cottage Grove

Cove

Creswell

Culver Dayville

Deschutes River Woods

Detroit

Donald

Dufur

Eagle Point

Echo

Elgin

Enterprise

Estacada

Eugene

Fairview

Carson RiverValley

Washougal

Bickleton

Wallula

Amboy

Yamhill

Woodburn

Walla Walla East

Wilsonville

White City

Venersborg

Vancouver

Weston

West Haven-Sylvan

Wasco

Warm Springs

Wamic

Trout Lake

Wallowa

Vernonia

Vale

Unity

Union

Umatilla

Ukiah

Tygh

Valley

Tutuilla

Turner

Touchet

Tigard

Stevenson

Three Rivers

Tangent

Talent

Satus

Sweet Home

Sunnyside

Sumpter

Summerville

Salmon Creek

RooseveltStanfield

Springfield

Spray

Orchards

South Lebanon

Sisters

Silverton

North Bonneville

Shaniko

Shady Cove

Seneca

Scio

Sandy

Salem

Meadow GladeMaryhill

Terrebonne

Rockcreek

Boise City

Riverside

Richland

Redmond

Rainier

Prineville

Prescott

Prairie City

Portland

CambridgeCascade

Pine Grove

PilotRock

Phoenix

Lyle

Council

Crouch

Parkdale

Paisley

Oregon City

Ontario

Longview Heights

Odell

Oakridge

Donnelly

Eagle

EmmettNyssa

North Powder

Longview

Garden City

GrandView

Mount Hood Village

Mount Angel

Moro

Grangeville

Rogue

River

Monument

Greenleaf

Homedale

Molalla

Horseshoe Bend

Mitchell

La Center

Mission

Kuna

McCall

Marsing

Yacolt

Milton-Freewater

Melba

Millersburg

Mill City

Metolius

Mehama

Klickitat

Midvale

Medford

Nampa

MaupinNew Meadows

New Plymouth

Kalama

Notus

Marion

Madras

Lowell Parma

Highland

Lostine

Long Creek

Lonerock

Lexington

La Pine

Lakeview

Payette

La Grande

Lafayette

Labish Village

Klamath Falls

Goldendale

Riggins

Woodland

Wishram

Star

Weiser

White Bird

Joseph

JordanValley

McDermitt

John Day

Owyhee

Adams

Adrian

Irrigon

Albany

Ione

Altamont

Amity

Antelope

Idanha

Huntington

White Salmon Arlington

Ashland

Hines

Hermiston

Baker City

Heppner

Banks

Helix

Beaverton

Bend

Boardman

Halsey

Bonanza

Halfway

Burns

Haines

Gresham

Greenhorn

Grass Valley

Granite

Butte Falls

Centerville

Glide

Canby

Gaston

Carlton

Four Corners

Central Point

Chenoweth

Chiloquin

City of The Dalles

Fossil

0 10 20 30 40 50

Miles

Oregon Wind Resource& Sage Grouse Core Areas

Existing Transmission Line

ODFW Sage Grouse Core Areas (2010)

Habitat Category 1

Habitat Category 2

Wind Power Class (NREL 2006)

2 (Marginal)

3 (Fair)

4 (Good)

5 (Excellent)

6 (Outstanding)

7 (Superb)

Modified Date: 8/10/2010

380

19

209

204

201

3

233

206

211

234

18

207

19

293

214 203

99

335

240

244

35

99

219

66

126

11

220

55

138

207

39

503

218

55

161

22

58

237

6

36

16

372

74

13

22

162

70

245

140

21

27

78

78

213

228

50

37

427

202

126

31

221

205

14

230

7

51

224

227

232

140

82

14

45

216

242

47

71

99

238

125

141

226

29718

7

142

370

86

62

422

129

52

3804

14

140

140

221

8

170

20

95

20

30

395

26

395

95

395

26

97

27

9597

20

26

395

730

97

2620

395

26

12

197

30

95

12

84

84

5

5

84

82

84

5

84

Caldwell

College Place

Camas

Battle Ground

Woodburn

White City

Vancouver

Troutdale

Tigard

Talent

Sweet Home

Salmon Creek

Sunnyside

Stayton

Springfield

Silverton

Sherwood Sandy

St. Helens

Rockcreek

Redmond

Prineville

Wilsonville

Portland

Pendleton

Ontario

Molalla

Milton-Freewater

Medford

Madras

McMinnville

Lebanon

La Pine

Minnehaha

La Grande

Kennewick

Klamath Falls

Keizer

Independence

Hood River

Walla Walla

Hermiston

Four Corners

Forest Grove

Eugene

Dallas

Cottage Grove

Corvallis

City of The Dalles

Central Point

Canby

Bend

Baker City

AshlandAltamont

Aloha

Albany

Weiser

Payette

NampaMeridian

Kuna

Garden City

Emmett

Eagle

0 10 20 30 40 50

Miles

Oregon Solar Resource& Sage Grouse Core Areas


ODFW Sage Grouse Core Areas (2010)

Habitat Category 1

Habitat Category 2


GHI Solar Resouce (NREL 2010, 10km)

Annual W/m2/day

3171 - 3445

3446 - 3669

3670 - 3880

3881 - 4099

4100 - 4314

4315 - 4511

4512 - 4709

Modified Date: 8/10/2010

1

!

Appendix 3: Renewable Northwest Project Comments on Greater Sage-

Grouse Conservation Assessment and Strategy for Oregon

1. The Draft Plan Revision Does Not Include Climate Change as an

Important Threat to Wildlife and Habitat Throughout Oregon

In response to the growing concern over the effects of climate

change on both the human and natural environments, in 2008 the

Oregon legislature passed the Oregon Renewable Energy Act.1 By

2025, certain Oregon utilities are required to expand their use of new

renewable energy to 25%. Along with neighboring California and

Washington – and 26 other states and the District of Columbia –

Oregon’s state policy is leading the way towards cleaner, healthier,

energy for all.

a. Climate Change is an ODFW Concern:

Oregon Department of Fish and Wildlife has embraced

climate change as a critical challenge to wildlife and wild

places. We support its plans to include climate change when it

next revises the State’s Conservation Strategy. However, given

its importance to the State, and to the Department, we are

puzzled why this critical issue was not included in the list of

potential threats to sage-grouse and sage-grouse habitat

(SGSB). Academic studies predict that average temperatures

for the Great Basin may increase by 2.8 to 6 degrees Celsius,

resulting in a loss of as much as 200,000 square miles of

Oregon sage brush habitat.2 Scientists at the National Wildlife

Federation argue “big sagebrush habitats throughout the

western U.S. could decline by 59 percent.”3 Climate change-

induced effects would also include an increase in fire

frequency and intensity, clearing more ground for invasive

species like Cheatgrass in the high desert.4 Climate change

models also predict that, as a result of global warming, the

Pacific Northwest will experience warmer and drier summers,

thereby reducing the food supply for owls, as well as colder

1 http://www.oregon.gov/ENERGY/RENEW/docs/sb0838.en.pd

2 Miller, R.F., S.T. Knick, D.A. Pyke, C.W. Meinke, S.E. Hanser, M.J. Wisdon, and A.L. Hild. 2009.

Characteristics of Sagebrush Habitats and Limitations to Long-Term Conservation. Section III:

Ecology of Sagebrush: Chapter 11. In: Marti, C.D., ed. Ecology and Conservation of Greater Sage-

Grouse: A Landscape Species and Its Habitats. A Release of a scientific monograph with permission of

the authors, the Cooper Ornithological Society, and the University of California Press. Edited by

Studies in Avian Biology, Boise, Idaho. 3 National Wildlife Federation, 2006. Fueling the Fire: Global Warming, Fossil Fuels and the Fish and

Wildlife of the American West. Report prepared by Patty Glick, Global Warming Specialist, National

Wildlife Federation. Page ii. http://www.targetglobalwarming.org/files/FuelingtheFire.pdf 4 Baker, W.L. 2009. Pre-Euro-American and recent fire in sagebrush ecosystems. Section III: Ecology

of sagebrush: Chapter 12. In: Marti, C.D., ed. Ecology and Conservation of Greater Sage-Grouse: A

Landscape Species and Its Habitats. A Release of a scientific monograph with permission of the

authors, the Cooper Ornithological Society, and the University of California Press. Edited by Studies in

Avian Biology, Boise, Idaho.

RNP Members

3Degrees

3TIER


Blattner Energy


BP Wind Energy

Calpine


CH2M Hill


Climate Solutions

Clipper Windpower




Element Power

Environment Oregon


enXco, Inc.



EverPower

Gamesa Energy USA

GE Energy



Horizon Wind Energy


Jones Stevedoring

Lane Powell PC


MontPIRG




NW Energy Coalition


OSPIRG



REC Silicon

REpower


Ridgeline Energy

Solar Oregon

SolarCity

Stoel Rives, LLP


Tanner Creek Energy

Tonkon Torp LLP

Vestas Americas



WashPIRG


Western Wind Power

2

and wetter springs, resulting in a reduction in the survival chances of owl

fledglings during nesting season.5

By leaving climate change out of its analysis of SGSB threats, the

ODFW eliminates the positive role renewable energy can play in providing

Oregon and the rest of the region with clean, reliable, energy. Omission of the

potential contribution renewable energy can play in SGSB protection also

makes it easier to propose land use plans that greatly restricts or eliminates

renewable energy development potential.

b. Possible Tension with Federal Mandates:

The failure to include climate change into its comprehensive SGSH

sends conflicting signals to federal land use managers. The Energy Act of

2005 and Presidential Executive Order 13514, and Department of Interior

Order Number 3295, all direct federal land management agencies to promote

the responsible development of renewable energy on federal land.

Secretary of the Interior Ken Salazar emphasized this mandate in the

Agency’s press release announcing the sage-grouse “warranted but precluded”

determination when he said:

“We must find common sense ways of protecting, restoring, and

reconnecting the Western lands that are most important to the species’

survival while responsibly developing much-needed energy resources.

Voluntary conservation agreements, federal financial and technical

assistance and other partnership incentives can play a key role in this

effort.”6

By designating nearly three quarters of federal land in southeastern

Oregon category 1 or 2 habitat for sage-grouse, ODWF places the Bureau of

Land Management in a potentially awkward position of removing nearly all of

Oregon’s renewable energy development potential from the region.

Designation of federal land with state categories also raises questions

regarding the BLM’s compliance with National Environmental Protection Act

processes, especially when the federal agency defers to ODFW for land use

decisions.

United States Fish and Wildlife Service (USFWS) officials also argue

for the incorporation of climate change into their land use and wildlife

protection plans. According to their draft climate change strategy,

cooperation to address the threat to wildlife and habitat posed by climate

change is critical to any successful effort:

“The crisis of climate change is, in the final analysis, an unparalleled

opportunity to bring people together, nationally and internationally, to

solve a world problem, not through conflict but through collaboration

. . . Mission success in fish and wildlife conservation over the coming

decades will require unprecedented cooperation and partnership

5 http://ir.library.oregonstate.edu/jspui/bitstream/1957/11326/1/EGlennDisseration2009.pdf. For more information

regarding sage grouse and climate change, see pages 7-9 in the attached literature review of sage grouse and renewable

energy, prepared for RNP by Greg Johnson 6 “Western Bird Found ‘Warranted but Precluded’ from Endangered Species Act Protection”, U.S. Fish & Wildlife, News

Release, March 5, 2010.!

3

among governments, private sector and non-government

organizations, and individual citizens.”7

2. Narrow interpretation of ODFW’s Wildlife Policy Increases the Chances for

Constituent Disagreement:

We support the ODFW’s attempt to propose SGSB strategy plan revisions

designed “to prevent serious depletion of any indigenous species and to provide the

optimum recreational and aesthetic benefits for present and future generations of the

citizens of this state.”8 However, by not factoring the other seven co-equal objectives

of the Oregon Wildlife Policy, in our view Department staff is proposing a

conservation plan without regard to the serious repercussions for landowners, the

communities in which they live, and the economic development opportunities they

need to sustain rural lifestyles. As we have seen in other parts of Oregon, responsible

development of renewable energy projects generates new revenue streams that help

landowners avoid parceling their property – or abandoning rural lifestyles.9

We respectfully ask the Commissioners to consider these co-equal goals, most

especially “to regulate wildlife populations and the public enjoyment of wildlife in a

manner that is compatible with primary uses of the lands and waters of the state,” and

“to make decisions that affect wildlife resources of the state for the benefit of the

wildlife resources and to make decisions that allow for the best social, economic, and

recreational utilization of wildlife resources by all user groups.”10

We would like to

see policy recommendations made that are both practical and effective, and we worry

a conservation plan that fails to consider its impact on communities will not be

successfully implemented.

3. Unbalanced input into the Draft Plan Revision Process:

ODFW staff told us that the Draft Plan Revisions contributors and editors

were selected based largely on the group responsible for developing the 2005 Oregon

Sage Grouse Conservation Plan. While we respect their contributions, in our view

the list leaves important perspectives out of SGSB protection plan development. The

failure to include a wider representation of interests in the Draft Plan Revision’s

drafting results in a number of serious flaws, including the following:

a. Mischaracterize Wind Energy Development:

While the Draft Plan Revision acknowledges “… there is a lack of

specific information about the effects of renewable energy development on

sage-grouse ecology,” the authors justify the development and implementation

of the “core area habitat and conservation” approach using studies of

subsurface mining activities. This analogy is inappropriate for a number of

reasons. First, there is no justification for extrapolating from studies of

subsurface mining activities to renewable energy development. As the

accompanying Google satellite images demonstrate, the footprint of an oil and

gas field is dramatically different from that of a wind farm.

7 U.S. Fish & Wildlife Service. Rising to the Challenge: Strategic Plan for Responding to Accelerating Climate Change.

September 21, 2009 Draft. Pages 6 and 17. http://www.fws.gov/home/climatechange/pdf/CCDraftStratPlan92209.pdf 8 Oregon Wildlife Policy, 496.012.

9 Renewable Energy & Economic Development: Real Examples from the Pacific Northwest. RNP Factsheet. August 2010.

Visit "##$%&&'''()*$(+),&-.#/-&0/1234#&1.4/-&$01-&56!78+*!9/:!;28#-"//#!<=>3,?@)/:($01 to download the factsheet. 10

Oregon Wildlife Policy, 496.012(5) and (7)

4

Gas field (left) and wind facility (right) near Evanston, WY.

Traffic, noise, and service requirements between wind and oil and gas

facilities are quite different. According to the U.S. Department of Energy’s

report 20% Wind Energy by 2030, the land used for wind is very different

from coal mining or drilling for natural gas. The actual footprint for wind

development is immensely smaller (100,000-250,000 hectares of disturbed

land for wind, as opposed to 1,700,000 hectares permitted or covered and

about 425,000 hectares of land disturbed for coal mining). “An important

factor to note is that wind energy projects use the same land each year; coal

and uranium must be mined from successive areas, with total disturbed land

increasing each year.”11

Second, the Draft Plan Revision fails to report the

growing body of anecdotal evidence that suggests wind farms and sage-grouse

can co-exist. Groups of 5 and 8 individual sage-grouse were documented at

the Elkhorn wind farm in Oregon.12

Studies of prairie chicken leks in Kansas,

Minnesota, and sage-grouse leks in Wyoming show continued activity among

leks located from 0.38 to 0.85 miles from the nearest wind turbine.13

We are not arguing that scientists know enough about the relationship

between sage-grouse viability and renewable energy development; indeed,

there is a great deal more to learn. What we object to is the

mischaracterization of the current state of knowledge, and the apparent

unwillingness of the Draft Plan Revision authors to consider and report this

information. We would prefer a more thoughtful approach to learning about

the relationship between sage-grouse and renewable energy development,

such as the decision by the Washington Fish and Wildlife Agency (WDFW) to

permit the construction and operation of a 28 turbine wind farm in Douglas

County, Washington, adjacent to one of the last two remaining sage-grouse

11

http://www.nrel.gov/docs/fy08osti/41869.pdf 12

Jeffrey, J.D. and W.P. Erickson, K. Bay, M. Sonneberg, J. Baker, J. boehrs, and A. Palochak. 2009. Horizon Wind

Energy, Elkhorn Valley Wind Project, post-construction avian and bat monitoring, fist annual report, January-December

2008. Technical report prepared for Horizon Wind Energy, Portland, Oregon. Report prepared by Western EcoSystems

Technology, Inc. 13

See G. Johnson, Greater Sage-Grouse & Wind Energy Development: A Review of the Issues. 2010. Western

EcoSystems Technology, Inc. A report commissioned by the Renewable Northwest Project. Page 12. Please note; ODFW

biologist and Draft Plan Report principal author Christian Hagen was one of the report reviewers.

Gas field

development area.

Wind facility

turbine strings.

5

populations in the state.14

In this example, agency officials worked with wind

developers and the Douglas County Public Utility District to reduce the

number of wind turbines, enlarge their nameplate capacity, and locate them to

minimize possible negative implications to SGSH.

b. Failure to Consider ODFW’s Role in Oregon’s Renewable Energy Siting

Process:

During a public presentation in Portland of the Draft Revision Plan,

ODFW officials suggested wind energy developers lack knowledge of the

biological issues affected by wind (or other forms of renewable energy)

development. This is simply not true. To secure a permit from the Oregon

Energy Facility Siting Council (EFSC) to build and operate a renewable

energy facility, companies must submit detailed biological information to

ODFW.15

Historically, the data has been used to determine land

categorization and develop appropriate mitigation programs. Oregon

voluntary wind energy guidelines call for a minimum of one year of biological

studies – two years if the proposed site is relatively new to renewable energy

development.16

To minimize the negative implications of turbine placement,

the process of “micro-siting” of a wind project – the specific placement of

each turbine within the proposed parcel – involves integrating detailed

biological information, wind data, and other factors (such as Department of

Defense and Federal Aviation Administration input). Renewable energy

companies work hard to earn their credentials as both “green” and “clean”

energy companies.

As key members of the EFSC process, ODFW officials have

tremendous influence over how land is used. ODFW officials work directly

with renewable energy developers to agree on parcel categorization, and the

appropriate mitigation to address temporary and permanent impacts. An

application to EFSC is not complete until ODFW and the developer reach an

agreement on the category and mitigation (or agree to contest category

designation and mitigation). Should the Commission adopt the plan and its

core area strategy, Agency staff will undoubtedly bring these predetermined

parcel categorizations into their deliberations with landowners and renewable

energy developers, without the benefit of the detailed biological information

that site-specific studies can provide. This approach to land categorization

represents a sea change in renewable energy siting practices.

c. Failure to Propose Habitat Categorization Review:

While the Draft Plan Revision provides detail regarding the criteria for

classifying habitat as Category 1 and 2,17

we could not find the criteria used

14

Douglas County Public Utility District has secured permission to build and operate a 28, 2.5MW turbine wind farm.

Working with state biologists, project developers adjusted the footprint and size of the proposed energy facility to address

concerns raised by biologists and community residents. See

http://www.douglaspud.org/Environment/WithrowWindProject.aspx for more information. 15

See OAR Chapter 469 and OAR Chapter 345. 16

Oregon Columbia Plateau Ecoregion Wind Energy Siting and Permitting Guidelines, September 29, 2008,

http://rnp.org/sites/default/files/pdfs/OR%20wind%20siting%20guidelines%2008Sept29.pdf 17

The analysis contained in this section borrows from input provided RNP by the biologists at Tetra Tech, and

environmental and consulting firm with expertise in renewable energy siting in sagebrush habitat. For more information on

Tetra Tech, please see tetratech.com.

For Category 1: 1) All sagebrush types or other habitats that support sage-grouse that are encompassed by very high, high,

and moderate lek density data strata, 2) Where local connectivity corridors overlapped low lek density strata, 3) Where

winter habitat use polygons overlapped with low lek density strata, either connectivity corridors or occupied habitat. For

Category 2: 1) Where low density overlapped with seasonal connectivity corridors, 2) Where local corridors occurred

6

to justify the inclusion of these factors. Understanding these factors is critical,

as new information may suggest a different categorization, or habitat value

may change over time. For example, Category 2 or 3 grassland habitat would

be modulated to Category 1 if Washington ground squirrels (a state

endangered species) were located. The reverse is possible as well; just as

grassland habitat can be modulated from Category 3 to Category 1 based on

the presence of Washington ground squirrels, the option should exist to

modulate Habitat Category 1 proposed in Fig 29 to lower habitat categories by

using field data and grouse biology. The recommendations on page 79 do not

indicate that the opportunity to conduct studies to better understand the

distribution of grouse and habitat conditions.

We have asked ODFW officials what process they would use to

consider field data and grouse biology to review the proposed parcel

categorization. We have also asked how the predetermined parcel

categorization comports with the EFSC siting process; to date we have not

received any answers to our questions. We believe stakeholders should know

and understand the criteria by which these parcel categorizations were

proposed. We believe landowners and renewable energy developers should

clearly know how the Department plans to consider developers’ site-specific

biological data (point counts, transects, and radio telemetry data) when

determining a land parcel category; in many instances, their data is much

more current and site specific than the coarse data and estimates used by the

Department to develop the Draft Plan Revision.

d. Imbalanced Public Input:

While the Draft Plan Contributors and Editors include representatives

from the John Day/Snake and Southeast Oregon Resource Advisory Councils,

given the gravity of the SGSB conservation plan we believe the potentially

affected counties should have a broader voice in the Plans development. In an

apparent attempt to address this weakness, following a letter of concern by

Harney County Commissioner and Oregon Association of Counties Steven

Grasty, ODFW officials organized a series of public meetings to solicit public

input. But while we support outreach efforts like this, short notice for public

meetings where citizens are given a chance to discuss the completed draft is a

poor proxy for direct involvement in its drafting. We share the concerns

voiced by the Oregon Association of Counties, as well as citizens who

participated in the public hearing sessions, that a failure to include their point

of view in developing the Draft Plan Revision would lead to ineffective action

with serious consequences to all stakeholders involved.

Please do not misunderstand our position; we strongly support

ODFW’s role in the Oregon siting process, and in the past have worked with

Department officials to secure support from the State Legislature for its

involvement. But by limiting the Draft Plan input to such a narrow group of

stakeholders, we believe its authors produced a proposal that relies upon a

faulty predetermination of land parcel categories without engaging either

landowners or potential renewable energy developers. In doing so, ODFW

robs the State of the chance to gather potentially valuable SGSB biological

data, critical financial resources necessary to engage in habitat mitigation,

renewable energy opportunities to contribute to the region’s efforts to reduce

outside of all lek density, 3) Where low density strata occur outside of connectivity corridors, 4) Where seasonal

connectivity corridors occur outside of all lek density strata.

7

our dependence on fossil fuels. In short, this approach alienates possible allies

in the effort to improve the prospects for the health of SGSB habitat.

4. Uncertain Program Funding Makes Implementation Improbable

While the Draft Revision Plan does not include program implementation

estimates, increasing conservation measures across such a large landscape inevitably

costs money. Unfortunately, both state and federal habitat protection plans are

suffering from the malaise of the lingering economic recession. The Draft Revision

Plan suggests no revenue sources to pay for the costs associated with program

implementation.

Renewable energy advocates had hoped to participate in a sage-grouse

protection program that would see them as allies; unfortunately, by developing maps

that signal the dramatic reduction of renewable energy potential in southeastern

Oregon, Department officials risk losing an important ally in efforts to promote and

implement SGSB habitat protection efforts. Unlike the fossil fuel industry, the

renewable energy industry designed its business model to include mitigating for the

costs associated with its activity. After siting their projects to minimize temporary

and permanent impact, companies develop and pay for comprehensive mitigation

programs designed to meet Oregon’s standards for impact. We welcome a dialogue

with ODFW, county officials, and local community representatives on how best to

use mitigation dollars to achieve specific SGSB habitat restoration goals, or the

broader conservation goals outlined in the State’s Conservation Strategy.

1

Appendix 4: Renewable Northwest Project Proposals for a Way Forward

RNP and its members support ODFW’s efforts to enhance sage-grouse

and sage-grouse habitat protection. As demonstrated by our involvement in

previous siting efforts, we are committed to collaborative, multi-stakeholder,

problem-solving oriented dialogue. We respectfully suggest that the

Commissioners consider other approaches to reaching consensus on how to

improve SGSB habitat, including the following:

1. BLM/OR process: The State of Oregon and the Bureau of Land

Management are engaged in a dialogue designed to better coordinate

state and federal efforts to protect sage-grouse/sage-grouse habitat in

Oregon, and to facilitate renewable energy siting on federal lands.

Because this process involves a wider group of stakeholders, we would

support using this venue to discuss the ODFW Draft Plan Revision.

2. Federal Advisory Committee (FAC) guidelines: In March 2010,

Secretary Salazar acknowledged the work of the twenty-two member

advisory committee responsible for developing the USFWS wind

energy development guidelines. These guidelines emphasize wind

energy development using the best available science, landscape scale

planning, and a decision making framework that uses “tiers” -- an

iterative decision-making process for collecting information in

increasing detail, quantifying the possible risks of proposed wind

energy projects to wildlife and habitats, and evaluating those risks to

make siting, construction, and operation decisions. According to the

guideline authors:

“…the Committee recognizes that wind energy

developers who voluntarily adhere to these Guidelines

will be undertaking a robust level of wildlife impact

analysis, and a shared responsibility with USFWS to

ensure that the scientific standards of the Guidelines are

upheld and used to make wise development decisions.”1

We would like to explore with ODFW whether or not this approach

offers landowners and community leaders a greater role in developing

enhanced sage-grouse conservation plans that better reflect the

individual nature of each affected community.2

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2 The FAC guidelines were signed by all members of the committee, including the National Audubon

Society, the Massachusetts Audubon Society, Bat Conservation International, The Nature Conservancy,

and Defenders of Wildlife. RNP members Horizon Wind Energy, NextEra, Ridgeline Energy, and

Iberdrola Renewables participated and endorsed the guidelines. For more information regarding the

Federal Advisory Committee’s recommendations for renewable energy development on federal land, see http://www.doi.gov/news/pressreleases/2010_03_05_releaseA.cfm

RNP Members

3Degrees

3TIER


Blattner Energy


BP Wind Energy

Calpine


CH2M Hill


Climate Solutions

Clipper Windpower




Element Power

Environment Oregon


enXco, Inc.



EverPower

Gamesa Energy USA

GE Energy



Horizon Wind Energy


Jones Stevedoring

Lane Powell PC


MontPIRG




NW Energy Coalition


OSPIRG



REC Silicon

REpower


Ridgeline Energy

Solar Oregon

SolarCity

Stoel Rives, LLP


Tanner Creek Energy

Tonkon Torp LLP

Vestas Americas



WashPIRG


Western Wind Power

2

3. Candidate Conservation Agreements: As the sage-grouse is not yet listed under the

ESA, legal entities have the option of negotiating Candidate Conservation

Agreements with Assurances (CCAA’s). Done properly, CCAA’s develop

comprehensive land management plans, generate the resources necessary to

implement them, and give private landowners incentives to modify their own land use

practices to enhance habitat quality. While designed primarily for use by private

landowners, we understand it is possible for CCAA’s to be drafted to cover

neighboring property, regardless of the landowner. Should Oregon counties consider

negotiating CCAA, it would enable federal and state fish and wildlife officials to

tailor landscape-scale approaches to responsible management of all threats to SGSB –

not solely singling out renewable energy projects.

4. Direct Dialogue with ODFW: RNP and its members have enjoyed good working

relations with ODFW officials. Working together, we believe we can find better

solutions to SGSB habitat protection efforts than proposed in the Draft Plan Revision.

To make such a discussion successful, we recommend ODFW add representatives

from the Oregon Association of Counties, members of Oregon’s environment and

conservation community, and renewable energy companies, their biologists, and

associations. We would welcome oversight in this process by members of the Fish

and Wildlife Commission.

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