1 3.9 AESTHETICS, LIGHT, AND GLARE

2 This section describes the existing aesthetic conditions within the study area, including visual resources 3 and existing sources of light and glare. This section also describes potential impacts to visual resources 4 and assesses the potential for visual impacts using accepted methods of evaluating visual landscape 5 quality and predicts the type and degree of effects the Project will likely have on those attributes. Potential 6 mitigation measures are also identified.

7 3.9.1 Study Methodology

8 The study area for aesthetics is the area surrounding the location of the WTGs to a distance of fifteen 9 miles. This distance was chosen because it is typically considered the maximum distance at which WTGs 10 will be distinguishable by the naked human eye (BLM 1986).

11 There are no established methods for conducting impacts analysis on aesthetics and visual resources at 12 the local or state level. Therefore, the methodology used to identify potential impacts within the study 13 area was a combination of the Scenery Management System defined in the USFS’s Landscape Aesthetics, 14 A Handbook for Scenery Management (USFS 1995) and the Federal Highway Administration’s (FHWA) 15 Guidelines for the Visual Impact Assessment of Highway Projects (FHWA 2015) and Visual Impact 16 Assessment for Highway Projects (FHWA 1988).

17 This methodology portrays the differing viewer groups and their sensitivity to visual change, defines 18 distances zones (foreground, middle ground, and background), and evaluates the contrast between pre‐ 19 and post‐Project conditions as seen from the different viewpoints, by different viewer groups, and from 20 different distances.

21 This analysis of visual effect was based on field observations and review of wind energy facilities’ visual 22 effects, public perception, design measures to reduce visual impacts, and local planning documents. 23 Project maps, drawings, technical data, and computer‐generated viewshed maps were used to determine 24 areas where the Project WTGs will be visible within the study area, and visual simulations were generated 25 to illustrate the change from the existing conditions if the Project is implemented. The analysis included 26 systematic documentation of the visual setting, evaluation of visual changes associated with the Project, 27 and measures designed to mitigate these visual effects.

28 3.9.1.1 Scenic Quality Assessment

29 Scenic quality ratings were developed based on observations in the field, photographs of the affected 30 area, methods for assessing visual quality, and research on public perceptions of the environment and 31 scenic quality ratings of landscape scenes. The final assessment of scenic quality was made based on 32 professional judgment that took a broad spectrum of factors into consideration, including the following:

33  Natural features, including topography, waterways, rock outcrops, and vegetation 34  The positive and negative effects of human alterations and built structures on visual quality 35  Visual composition, including an assessment of the vividness, intactness, and unity of patterns in 36 the landscape, defined as:

3.9‐1 1 o Vividness refers to the memorability of the visual impression received by the viewer from 2 contrasting landscape elements as they combine to form a striking and distinctive visual 3 pattern 4 o Intactness is the integrity of visual order in the natural and human landscape and the extent 5 to which the landscape is free from visual encroachment 6 o Unity is the degree to which the visual resources of the landscape join together to form a 7 coherent and harmonious visual pattern. 8 Each viewpoint was assigned a final rating based on the rating scale shown in Table 3.9‐1. This rating scale 9 incorporates the landscape assessment concepts developed in the USFS and FHWA methodologies.

10 Table 3.9‐1. Landscape Scenic Quality Scale

Visual Quality Rating Explanation Outstanding This rating is reserved for landscapes with exceptionally high visual quality. These 6 landscapes are significant nationally or regionally. They usually contain natural or cultural features that contribute to this rating. They are what we think of as “picture postcard” landscapes. People are attracted to these landscapes to view them. High This rating includes landscapes that have high quality scenic value. This may be due to 5 cultural or natural features contained in the landscape or to the arrangement of spaces contained in the landscape that causes the landscape to be visually interesting or a particularly comfortable place for people. These landscapes have high levels of vividness, unity, and intactness. Moderately High This rating includes landscapes that have above average scenic value but are not of high 4 scenic value. The scenic value of these landscapes may be due to human or natural features contained within the landscape, to the arrangement of spaces in the landscape, or to the two‐dimensional attributes of the landscape. Levels of vividness, unity, and intactness are moderate to high. Moderate This rating includes landscapes that are common or typical landscapes with average 3 scenic value. They usually lack significant human or natural features. Their scenic value primarily results from the arrangement of spaces contained in the landscape and the two‐dimensional visual attributes of the landscape. Levels of vividness, unity, and intactness are average. Moderately Low This rating includes landscapes that have below average scenic value but not low scenic 2 value. They may contain visually discordant human alternations, but these features do not dominate the landscape. They often lack spaces that people perceive as inviting and provide little interest in terms of two‐dimensional visual attributes of the landscape. Low This rating includes landscapes that how below average scenic value. They may contain 1 visually discordant human alterations, and often provide little interest in terms of two‐ dimensional visual attributes of the landscape. Levels of vividness, unity, and intactness are below average. 11 Source: FHWA (1988), FHWA (2015), and USFS (1995)

12 3.9.1.2 Visual Sensitivity Assessment

13 The analysis also assessed visual sensitivity, which involves predicting the general impact on the quality 14 of views from a given viewpoint. A combination of three factors determines how sensitive a landscape 15 scene is:

16  The number and type of viewers

3.9‐2 1  The viewing conditions 2  The quality of the view.

3 Residential areas with unobstructed views of a regionally important and notable scene will be very 4 sensitive to objects or structures that will impede views. A view from a seldom‐traveled rural road where 5 motorists have only distant, oblique views of WTGs in an unremarkable setting will likely qualify as an area 6 of low sensitivity.

7 The main types of viewers in the Project Area who have predictably high levels of sensitivity to visual 8 impacts include:

9  Resident viewers 10  Roadway viewers (drivers and passengers) 11  Recreating viewers such as hikers, water recreationists, and mountain bikers.

12 This analysis defines three levels of visual sensitivity:

13  Low: Viewer types representing low visual sensitivity include agricultural and 14 industrial/warehouse workers. Compared with other viewer types, the number of viewers is 15 generally considered small and the duration of view is short. Low levels of sensitivity are assigned 16 to areas 5 miles or more from the closest WTG, where a wind power Project will be a distant and 17 a relatively minor element in the overall landscape. 18  Moderate: Viewer types representing moderate visual sensitivity include highway and local 19 travelers. The number of viewers can vary depending on location; however, on average they tend 20 to be moderately large, based on overall densities of surrounding areas and highway commuters. 21 Viewer awareness and sensitivity are also considered moderate because destination travelers 22 often have a focused orientation. Moderate levels of sensitivity were assigned to areas where 23 WTGs will be visible from 0.5 mile to 5 miles within the primary view of residences and roadways. 24 The primary view refers to the central area that the eye can see clearly without moving and is 25 surrounded by the peripheral vision. In distinguishing between moderate and low levels of 26 sensitivity in the 0.5‐mile to 5‐mile zone, contextual factors were also considered, including the 27 viewing conditions in the immediate foreground of the view. 28  High: Residential, recreational, and viewers congregating in public gathering places (churches, 29 schools, trails, designated scenic viewpoints, etc.) are considered to have comparatively high 30 visual sensitivity. The visual setting may in part contribute to the enjoyment of the experience. 31 Views may be of long duration and high frequency. High levels of sensitivity are generally assigned 32 in those cases where WTGs will be potentially visible within 0.5 mile or less from residential 33 properties, heavily traveled roadways, or heavily used recreational facilities. The principal types 34 of viewers in the Project Area who have predictable high levels of sensitivity to visual impacts 35 include residential viewers, roadway viewers (drivers and passengers) and recreating viewers 36 such as hikers, water recreationists, and mountain bikers.

37 These criteria were used to establish the sensitivity levels of each view using a systematic approach based 38 on the distance of the Project from the viewpoint, the number of WTGs or percentage of the Project Area 39 that could be viewed from this viewpoint, and the dominant viewer types for each view. Through this 40 analysis, an overall sensitivity rating was established for each existing landscape view.

3.9‐3 1 3.9.1.3 Visibility Analysis

2 The Applicant conducted a visibility analysis to identify locations within the surrounding area from which 3 the Project will be visible. The analysis was done to support the Applicant’s goal to locate the WTGs such 4 that they will have minimal visual impact on the surrounding area. Computer viewshed analyses were 5 conducted (using 30‐meter‐grid cell resolution, generated from 1:24,000 Digital Elevation Model data 6 from the USGS) to identify the sensitive viewing areas within boundaries of the visual sphere of influence 7 (VSOI). The results represent a “typical” viewshed for the Project Area. Figure 3.9–1 shows the visibility 8 analysis results for the area within a 15‐mile radius in all directions from the Project. This figure illustrates 9 the location of the WTGs used in the analysis, and illustrates in shading those locations from which 10 turbines will be visible, and how many turbines will be seen by a viewer. This figure also illustrates the 11 locations from which gen‐tie line structures will be visible.

12 This analysis is conservative because it does not take into account the presence of visual obstructions, for 13 example buildings or vegetation, which may prevent a viewer from seeing a WTG even if the topography 14 permitted a view. As discussed in the analysis below, “viewed sensitivity” alone is not a measure of “visual 15 impact”.

3.9‐4 Tumwater ¤£161 FIGURE 3.9-1 VISIBILITY ANALYSIS RESULTS NUMBER OF VISIBLE TURBINES ¤£702 Yelm ¤£121 0 Proposed Turbine Location Rainier Number of Turbines Visible* 1 - 5 Eatonville 6 - 10 Tenino ¤£507 - 11 - 15 - 16 - 20 - 21 - 30 L] Project Area Gen-Tie Micrositing Corridor ¤£5 D Project Area - Turbine Micrositing Corridor Centralia

*Viewshed based on a turbine hub height of 269 feet above ground, an observer height of 6 feet, and a 15-mile turbine buffer. Chehalis ¤£7

¤£6

¤£508

Napavine Morton SOURCES: CHAMBERS GROUP 2017, HDR 2018, WDNR 2016, LEWIS CO. 2016, THURSTON CO. 2016, USGS 2017, WSDOT 2017

Mossyrock 0 2½ 5 Miles I I Winlock I I I F 0 2½ 5 Kilometers 9/16/2018 ¤£505 SKOOKUMCHUCK WIND PROJECT 1 3.9.1.4 Visual Impact Assessment

2 The visual impact assessment was based on evaluating the changes to the existing visual resources that 3 will result from construction and operation of the Project. These changes were assessed, in part, by 4 evaluating them to the existing visual environment. Consideration was given to the following factors in 5 determining the extent and implications of the visual changes:

6  Changes in the affected visual environment’s composition, character, and valued qualities 7  The affected visual environment’s context, including distance 8  The extent to which the affected environment contains places or features that have been 9 designated in plans and policies for protection or special consideration 10  The number of viewers, their activities, and the extent to which these activities relate to the 11 aesthetic qualities affected by the changes 12  The distance factor was considered in the sensitivity rating for establishment of baseline and 13 therefore becomes a factor in the impact assessment.

14 Levels of impact were classified as high, moderate, or low:

15  High ‐ High levels of impact were assigned where WTGs will be highly visible in areas with a high 16 number of sensitive viewers and will greatly alter levels of vividness, unity, and intactness, 17 decreasing the level of visual quality. This is the largest number of viewers from that key 18 viewpoint. The assessment accounts for the number of viewers and will add that into the 19 discussion. 20  Moderate – Moderate levels of impact were assigned in situations where WTGs will be visible in 21 areas with moderate levels of visual sensitivity and viewers, where the presence of the WTGs will 22 moderately alter levels of landscape vividness, unity, and intactness. 23  Low – Low levels of visual impact were found in situations when the Project will have relatively 24 small effects on the overall landscape levels attributes, where existing levels of landscape 25 aesthetic quality are low, or where there are low levels of visual sensitivity and a low number of 26 viewers. 27 3.9.1.5 Visual Simulations

28 Visual simulations were developed using photographs taken with a 35 mm digital SLR camera. Various 29 focal lengths from 40 to 70 mm were used, with the intent to capture the maximum pixels and resolution 30 for the simulation. Visual Nature Studio, a widely‐used three‐dimensional GIS software, manufactured by 31 3D Nature, LLC, was used to model the WTGs locations on terrain built from USGS digital elevation model 32 data. The photograph locations were camera‐matched in the software to render the WTGs from the same 33 viewpoint as the photographs taken on the ground. The resulting rendered WTG images were then photo‐ 34 composited into the photographs to create the simulations. Existing topographic and site data provided 35 the basis for developing the initial digital model.

36 In preparing the visual simulations, a standard WTG model with a rotor diameter of 446 feet (136 meters), 37 a tip height of 270 feet (82 meters), and an overall turbine maximum tip height (blade in the vertical 38 position) of 499 feet (152 meters) was utilized, which was considered a likely model to be selected. The

3.9‐6 1 actual WTG size has not been determined, but for purposes of this analysis, potential WTGs are estimated 2 to have a height to nacelle of 270 feet and an overall blade length of 223 feet.

3 In evaluating impacts, the WTG is considered visible if any part of a vertical WTG blade is visible. In 4 practice, WTGs with only a part of the blade visible will not be seen when the blade is moving or is 5 stationary but not vertical.

6 Atmospheric haze varies by location, season, time of day, and weather patterns. In creating photo‐ 7 composite visual simulations, the aim is to match the haze level on the rendered WTGs to the observable 8 haze present in the photograph. This is done by comparing the haze effects on the photographed terrain 9 near the WTGs to the rendered haze effects on the rendered terrain. This is then translated into a lower 10 than expected haze visibility setting for the WTG renders. The result is that the WTGs will be slightly more 11 visible in the final composites than they will actually be if an observer were standing on the ground viewing 12 them from the exact place, date, and time that the photos were taken. The sky depicted in some of the 13 visual simulations includes clouds, simulating the cloudy conditions that are common at the site.

14 Site plans and specifications for the proposed WTGs were used to create three dimensional digital models 15 of the planned WTG placements. These models were combined with the digital terrain model to produce 16 a complete computer model of the WTGs. For each viewpoint, a render camera was placed in the Visual 17 Nature Studio software. The aspect ratio of each render was then matched to the corresponding 18 photograph, and the rendered terrain was visually matched to the photographed terrain to confirm scale. 19 Finally, the resulting WTG images were matched in perspective, scale, and aspect ratio, are photo‐ 20 composited into the original digital photo base using Adobe Photoshop. This process produces accurate 21 portrayals of how the given WTG models and placements will look on the given terrain and from the 22 specified viewpoints after construction. Seasonal conditions including weather, air quality, vegetation 23 (foreground and background) and color impact the quality of the compositions. These compositions are a 24 representative example of the area without subjectivity.

25 Simulations were not developed for nighttime conditions. Night simulations are inherently inaccurate, 26 since they do not show the periodic flashing of the air warning lights, which is the impact most often 27 mentioned. The potential impact of air navigation warning lights is discussed in Section 3.9.4

28 3.9.2 Regulatory Framework

29 3.9.2.1 Aesthetics

30 SEPA establishes requirements for assessing impacts on aesthetics and visual resources. Per WAC 197‐11‐ 31 960, aesthetics, light, and glare need to be addressed. Aesthetics require the following information at a 32 minimum:

33 1. Height, principal building materials, and appearance of the tallest proposed structures 34 2. Views in the immediate vicinity which will be altered or obstructed 35 3. Proposed measures to reduce or control aesthetic impacts.

36 Lewis County does not have specific guidelines for aesthetics for activities in forest resource lands (LCC 37 17.30) (Lewis County 2017).

3.9‐7 1 Landscaping and screening standards are provided in TCC Chapter 20.45, which includes provisions for 2 tree and vegetation retention, permitted plant types, and maintenance (Thurston County 2017).

3 3.9.2.2 Light and Glare

4 SEPA requirements related to light and glare include:

5 1. Light or glare that will be produced by the Project, and what time of day it will occur 6 2. Determining if light or glare could be a safety hazard or interfere with views 7 3. Identify offsite sources of light or glare which may affect the Project 8 4. Proposed measures to reduce or control light and glare.

9 Lewis County does not have specific guidelines for light and glare for activities in forest resource lands 10 (LCC 17.30) (Lewis County 2017).

11 Per TCC 20.40.060, lighting must be designed to shield direct light from adjoining streets and properties 12 (Thurston County 2017).

13 3.9.3 Affected Environment

14 Each landscape has a specific quality that gives a geographic area its visual and cultural image, and consists 15 of the combination of physical, biological, and cultural attributes that make each landscape identifiable 16 or unique. The character of an existing landscape may range from a predominantly natural landscape to 17 landscapes that are heavily culturally influenced. The existing scenic quality of an existing landscape 18 includes the natural scenic attributes of the landscape in combination with the existing land use patterns. 19 The sensitivity of a landscape or view of that landscape is based on the scenic integrity of the landscape 20 and the types of viewers. Both the natural and built features contribute to the public’s appreciation of the 21 environment. This section describes the broad‐scale regional and local landscape settings that were used 22 to establish appropriate viewpoints from which the Project will be visible.

23 3.9.3.1 Regional Landscape Setting

24 The Project is located near the Cascade Range near the towns of Centralia and Chehalis. The WTGs will be 25 entirely located within the Weyerhaeuser Vail Tree Farm in Lewis County on lands used for commercial 26 forestry. The gen‐tie line is also located in Lewis County areas zoned for commercial forestry, mineral 27 resource lands, rural development, and county urban growth area. A small portion of the gen‐tie line is 28 also located adjacent to public right‐of‐way abutting mineral resource zoned lands. The O&M Facility will 29 be located in Thurston County in an area zoned Rural Residential. Rural residential development occurs 30 outside of the Project Area in nearby towns such as Vail, Rainier, Alpha, Onalaska, and Cinebar. The 31 nearest town is Vail, approximately 6.3 miles northwest of the northernmost WTG site. The nearest 32 populated area is Rainier, which is approximately 8.6 miles from the northernmost WTG site. Commercial 33 forestry and industrial and mining activities occur in the vicinity of the gen‐tie line corridor.

34 The landscape throughout the Project Area is relatively rugged; however, stream valleys and some 35 reservoir areas exist in the area and form open valley areas with rural residences and small towns. The 36 terrain of the Project Area where WTGs will be placed consists of a ridgeline and associated sloping terrain.

3.9‐8 1 Elevations of the Project Area ridgeline range from 1,476 feet (450 meters) to 3,445 feet (1,050 meters), 2 with lower elevation stream‐lined valleys on either side.

3 Although recreational permits for hunting are available on a limited basis for the Vail Tree Farm; few 4 publicly accessible recreation areas or designated scenic areas are located in the vicinity of the Project 5 Area. Some recreational parks or trails in the surrounding towns include the Chehalis Western Trail, the 6 Yelm Tenino Trail, Longmire Community Park in Yelm, Bucoda Volunteer Park in Bucoda, Ike Kinswa State 7 Park and Mayfield County Park on Mayfield Lake, and Schaeffer County Park in Centralia.

8 The only National Scenic Area within Washington State is the Columbia River Gorge Scenic National Scenic 9 Area, which is over 100 miles east of the Project Area. The Project Area is outside of any scenic area 10 management plan, and no visual quality objectives or management designations have been established 11 for the area.

12 US 12 (White Pass Scenic Byway) south of the Project Area is a recognized scenic roadway. Typically, this 13 designation means that a scenic corridor management plan will be prepared to provide policy‐level 14 guidance in the local adoption of comprehensive plan policies, zoning, and other land use regulation. The 15 White Pass Scenic Byway Corridor Management Plan outlines local priorities for improvements and 16 assisting communities with coordinating activities related to marketing and tourism. The plan does not 17 contain specific recommendations for visual impacts or analysis and does not impose any regulatory 18 restrictions.

19 3.9.3.2 Local Landscape Setting

20 The landscape in most of the Project Area, including the core area in which WTG development is proposed, 21 is characterized by steep hills forested with conifer or mixed conifer‐deciduous stands. The landscape in 22 this area has been substantially modified by commercial logging activities, resulting in a mosaic of recent 23 clear‐cut sites mixed with timber stands of varied ages that creates a notable patchwork appearance. The 24 industrial forest land in this portion of the Project Area is served by a relatively dense network of logging 25 roads that create additional visual contrast, particularly in recently harvested areas.

26 The Project Area is on land managed for commercial forestry by Weyerhaeuser Company. All of the parcels 27 on which the WTGs will be located are managed for a continual cycle of growth, harvest, and replanting. 28 As a longstanding commercial forestry site, no old‐growth forest exists in areas where the Project is 29 proposed. As indicated above, the gen‐tie line corridor will be located on land managed for commercial 30 forestry, mineral resource extraction or adjacent to public right‐of‐way adjacent to lands with an emphasis 31 on rural development.

32 The local landscape visual appearance is of moderate visual quality with a moderate level of sensitivity. 33 The levels of vividness (memorability), intactness (freedom from visual encroachment), and unity are 34 average within the broader landscape. The Project Area is characterized by several types of visual 35 disturbance. These include:

36  Existing electrical transmission and utility lines, the existing TransAlta Centralia Coal Power Plant, 37 and corresponding quarries, cell towers, etc. 38  Forest openings from clear‐cutting throughout and surrounding the Project Area 39  Land clearing for agricultural purposes, especially west of the Project Area

3.9‐9 1  Scattered rural residential and commercial development.

2 Existing sources of light and glare in and near the Project Area are limited and are found mostly in the 3 small communities located in the valley areas, or communities outside of the Project Area. Minimal light 4 and glare occurs within the Vail Tree Farm, as vehicle traffic is quite limited, and there are no buildings 5 with exterior lights. The Applicant’s temporary meteorological towers are equipped with red aviation 6 safety lights for nighttime use.

7 Light and glare sources increase in density and variety with travel through the larger valleys toward the 8 concentration of urbanized activity within the I‐5 corridor. Typical sources of light and glare include large 9 vehicle traffic volumes, exterior lighting for commercial and industrial uses, and warning lights on 10 numerous communications structures. Rural residential developments in the Project Area also contribute 11 to the ambient light environment and, to a small extent, glare from the window glass.

12 3.9.3.3 Viewpoints/Key Observation Points (KOPs)

13 To analyze the Project’s effects on the aesthetics of the area, viewpoints were selected to characterize 14 the visual character of the Project Area and the differing landscapes in or near the Project.

15 Most of the viewpoints are at publicly accessible locations, which will have the largest number of viewers. 16 Viewpoints or Key Observation Points (KOPs) were selected from which the Project could be seen, 17 including KOPs along roadways, in residential areas, and in recreational areas. These locations are 18 summarized in Table 3.9‐2 and shown in Figure 3.9–2.

19 Individual viewpoints for the analysis were chosen via desk‐top analysis based on the following criteria:

20  Locations that are representative of different roads, population areas, and recreation areas where 21 view of the WTGs will occur 22  Locations that are accessible to the public 23  Locations with the largest number of viewers (including residences).

24 In addition, final KOP selections were determined through consultation with planning staff at the Lewis 25 County Planning Department and Thurston County Resource Stewardship Department (Smith and 26 Witherspoon 2016). Preliminary KOP selections were provided to the departments for review and 27 comment, and some additional KOP locations were added per their request (i.e., KOPs 7, 9, and 10).

28

3.9‐10 Tumwater ¤£161 FIGURE 3.9-2 VISIBILITY ANALYSIS RESULTS KOP 2 KOP 3 ¤£702 KOP 1 Yelm • Selected Key Observation Point (KOP) £121 ¤ KOP 4 • Preliminary KOP Rainier Turbine Viewshed (to a 15-mile radius)* KOP 7 KOP 6 KOP 5 Eatonville - Gen-Tie Viewshed** £507 Tenino ¤ KOP 9 - KOP 10 L] Project Area KOP 8 KOP 12 D Gen-Tie Micrositing Corridor KOP 11 - Turbine Micrositing Corridor ¤£5

KOP 13 Project Area

Centralia *Viewshed based on a turbine hub height of 269 feet above ground and an observer height of 6 feet.

**Viewshed based on a Gen-Tie line height of 115 Chehalis ¤£7 feet above ground.

KOP 14 ¤£6 KOP 15 ¤£508

KOP 17 Napavine KOP 16 KOP 24A Morton KOP 21 KOP 18 KOP 24 SOURCES: CHAMBERS GROUP 2017, HDR 2018, WDNR 2016, KOP 22 LEWIS CO. 2016, THURSTON CO. 2016, USGS 2017, WSDOT 2017 KOP 23 KOP 19 Mossyrock KOP 20 0 2½ 5 Miles Winlock I I I I I I I F 0 2½ 5 Kilometers 9/16/2018 ¤£505 SKOOKUMCHUCK WIND PROJECT 1 Each KOP listed in Table 3.9‐2 was assessed for its scenic quality and viewer sensitivity, and a rating was 2 applied to provide an overall average for the area. This process established the existing conditions for 3 each of the individual viewpoints, from which impact of the Project on these parameters could be 4 measured. The following KOPs scored highest with respect to these criteria and represented populated 5 locations within approximately 15 miles of the WTG locations, from which the potential for significant 6 views of the Project will be anticipated to be the greatest:

7  KOP 1: Roadway users on State Route (SR) 507 near Yelm Avenue 8  KOP 9: Residential viewers near Vail 9  KOP 10: Residential viewers at Lake Lawrence 10  KOP 15: Residential viewers at Alpha 11  KOP 19: Roadway users along US 12 12  KOP 24: Recreational users at Ike Kinswa State Park.

13 However, when the locations were verified in the field, it was determined that views from certain KOP 14 locations selected were obstructed by vegetation and would not result in neither a useful assessment of 15 existing conditions nor simulated future conditions (Lytle‐Bonine 2018). The location of these KOPs was 16 adjusted in the field as follows:

17  The actual views from public locations adjacent to KOP 9 (Residential viewers near Vail) were 18 screened by vegetation; KOP 8 was therefore selected as the nearest representative view of KOP 19 9 conditions. 20  The actual views northward from KOP 24 (campground at Ike Kinswa State Park) are screened by 21 park vegetation. The closest representative view is from the bridge crossing the Tilton River west 22 of the campground (KOP 24A), but still within this state park.

23 Figure 3.9–1 illustrates the locations of these KOPs relative to the Project. These KOPs were selected for 24 additional analysis as described below.

25 Table 3.9‐2. KOP Selection Analysis

KOP # Description Viewer Type Reason for Preliminary Selected for Analysis? Consideration 1 SR 507 ‐ Spanaway Drivers on Major highway located in Yes McKenna Highway roadway McKenna, at northern edge of viewshed 2 Longmire Park users Park within City of Yelm, hosts No; KOP 1 was closer to the Community Park community‐wide events, at Project site and had better northern edge of viewshed views of ridgeline 3 Yelm Avenue Drivers on Significant roadway running No; views obscured by roadway through towns at northern development in area and edge of viewshed nearer hills/ridgelines not associated with the Project

3.9‐12 4 Residences in Residential Concentration of residences No; view obscured by other Yelm/McKenna at northern edge viewshed residences, topography, and trees surrounding properties 5 Yelm – Tenino Trail Trail users A rail trail that connects No; views obscured by trees, communities of Yelm, Rainier, only intermittent views of and Tenino; features multiple northern ridgeline views and multiple parks along trail. 6 Chehalis Western Trail users Along historic railroad, passes No; views obscured by trees, Trail through different ecosystems trail is within forested area and environments. Widely used, at northwestern edge of viewshed 7 148th Avenue Residential Concentration of residences in No; views are intermittent north‐central portion of the and obscured by large trees in viewshed between KOP and northern ridgeline 8 Vail Loop Road, Drivers on Major roadways in proximity Yes, as a representative view Gordon Road SE Roadway to Project of KOP 9 9 Vail residences Residential Concentration of residences in No; although this is a more proximity to Project (Vail Cut sensitive viewpoint than KOP Off Road, Muskrat Drive, 8, long‐range view locations Mulqueen Road) from KOP 9 were screened by vegetation. KOP 8 was therefore selected as the nearest representative view for KOP 9 conditions. 10 Lake Lawrence Residential Concentration of residences Yes at north‐central portion of viewshed 11 Bald Hill Road SE Drivers on Major roadway on eastern No; views obscured by trees roadway portion of viewshed and topography 12 Clear Lake Residential Concentration of residences No; KOP 9 was closer to the residences at eastern portion of Project site, and views are viewshed partially obscured by trees and other vegetation 13 Schaeffer County Park users Day use park with recreational No; views obscured by trees Park facilities in the City of surrounding KOP Centralia 14 Centralia Alpha Drivers on Major roadway connecting No; views are intermittent Road roadway Centralia and Alpha and obscured by trees, and KOP 15 is a more sensitive viewpoint 15 Alpha residences Residential Concentration of residences in Yes southern portion of viewshed 16 Highway 508 Drivers on Major highway with potential No; views are intermittent roadway viewers and obscured by trees, and

3.9‐13 KOP 15 is a more sensitive viewpoint 17 Onalaska Residential Concentration of residences in No; views are intermittent residences on southern portion of viewshed and obscured by trees, and Carlisle Avenue KOP 15 is a more sensitive viewpoint 18 Alpha residences Residential Concentration of residences No; large distance between at southern portion of KOP and southern ridgeline is viewshed behind ridgeline visible from this KOP and KOP 15 represents similar set of viewers 19 US 12 Drivers on Major highway with potential Yes roadway viewers 20 Mayfield Lake Residential Concentration of residences No; views obscured by residences at southeast portion of intervening topography viewshed 21 Silver Creek Road/ Drivers on Roadways in areas with No; views obscured by trees Harmony Road roadway potentially sensitive viewers and intervening topography 22 Mayfield Lake Residential Concentration of residences No; views of southern residences at southeastern portion of alignment obscured by a viewshed ridgeline in between KOP and Project site 23 Mayfield County Park users Year‐round, day use area, No; views obscured by trees Park with campsites, recreational and intervening topography areas with boat launch; potential for sensitive viewers 24 Ike Kinswa State Park users at A 454‐acre camping park, with No; views northward from Park campground fishing and recreational campground are screened by boating, and various park vegetation. The closest recreational facilities; representative view is from potential for sensitive viewers the bridge crossing Tilton River west of the park campground (KOP 24A) 24A Ike Kinswa State Park users SR 22, bridge crossing Tilton Yes Park River 1

2 KOP 1: Roadway Users on SR 507 near Yelm Avenue 3 Scenic Quality: KOP 1 is taken from SR 507, which is approximately 13.1 miles from the Project and is a 4 small connector providing regional access. This highway also provides access to several rural communities, 5 including Yelm, Tenino, and Rainier. Most areas are unincorporated, and several of the residences are 6 recreational in nature with some year‐round residences. 7 KOP 1 is a wide panoramic view of the Deschutes River Valley that occurs north of the Project Area, and 8 some ridgelines of forest management areas are also visible in the middle ground of the viewshed. Natural 9 openings are prevalent from this viewpoint, with several natural‐appearing features of openings and 10 vegetation that provide an interesting view. The quality of the views from this viewpoint along SR 507 was

3.9‐14 1 rated as moderate, reflecting the fact that the visible landscape is relatively common in the region and 2 has average scenic value. The northern ridge of the Project provides a degree of topographic interest 3 when viewed with the other natural appearing features. The landscape visual scenic quality from this 4 viewpoint is moderate. 5 Viewer Sensitivity: Traffic volumes along SR 507 are minimal and used for local traffic and recreational 6 traffic in the summer months. Considering the distance of the Project from this viewpoint (approximately 7 13.1 miles), the minimal use of the highway, and the portion of the Project that is visible from the 8 viewpoint, the level of view sensitivity is considered low. This is based on the duration of the view from 9 SR 507, the low level of residential viewers from this viewpoint, and the scenic quality rating. 10 KOP 8: Vail Loop Road/Gordon Rd SE (Representative of KOP 9 Residential Viewers near Vail) 11 Scenic Quality: This viewpoint captures the view near the small residential community of Vail, looking 12 south into the Project Area. This area is accessible by Vail Loop Road, and private Gordon Road and used 13 by residential and private forest management users. The foreground is a mixture of mixed conifer second 14 growth stands, and the middle ground is of mixed timber harvest openings. The background view is 15 similar, and the mixture of vertical and horizon lines and formations detracts from the overall vividness 16 and unity of the view. The intactness of the views is moderated by the changes in line and form. The 17 quality of the view from this viewpoint was rated moderately low to moderate. 18 Viewer Sensitivity: When considering the distance of the Project from this viewpoint (at least 6.63 miles), 19 the duration of the view (middle ground screening), the portion of the Project that is visible from the 20 viewpoint, the viewer types (minimal residential), and the scenic quality rating, the level of sensitivity is 21 considered moderately high. 22 KOP 10: Residential and Recreational Viewers at Lake Lawrence 23 Scenic Quality: This viewpoint captures the view from the small residential community at Lake Lawrence, 24 as well as recreational users at the lake, looking south into the Project Area. This area is accessible by a 25 Thurston County road from SR 507, as well as Vail Cut Off Road, Muskrat Drive, and Mulqueen Road and 26 used by residential, private forest management users, and recreationists, especially during the spring and 27 summer. The foreground is a mixture of scattered residential development, the lake, and mixed conifer 28 second growth stands, and the middle ground is of mixed timber harvest openings. The background view 29 is similar, and the mixture of vertical and horizon lines and formations with scattered residential 30 development detracts from the overall vividness and unity of the view and the visual attraction provided 31 by the lake. The intactness of the view is moderated by the changes in line and form. The quality of the 32 view from this viewpoint was rated moderately low to moderate. 33 Viewer Sensitivity: When considering the distance of the Project from this viewpoint (at least 7.98 miles), 34 the duration of the view (middle ground screening), the portion of the Project that is visible from the 35 viewpoint, the viewer types (residential and recreational), and the scenic quality rating, the level of 36 sensitivity is considered high. 37 KOP 15: Residential Viewers at the Alpha Residences 38 Scenic Quality: This viewpoint captures the view from the small residential community at the Alpha 39 residences in Lewis County, closest to the small community of Alpha Prairie. This area is accessible by a 40 Lewis County road from SR 508 and US 12 via Centralia Alpha Road and used by residential and private 41 forest management users. The view looks north into the Project Area. The foreground is a mixture of 42 scattered rural residential development, open grassland, and mixed tree stands, and the middle ground 43 is of mixed timber harvest openings. The background view is similar, and the mixture of vertical and 44 horizon lines and formations detracts from the overall vividness and unity of the view. The intactness of

3.9‐15 1 the view is moderated by the changes in line and form and the presence of development. The quality of 2 the view from this viewpoint was rated moderately low. 3 Viewer Sensitivity: When considering the distance of the Project from this viewpoint (at least 6.4 miles), 4 the duration of the view (background screening), the portion of the Project that is visible from the 5 viewpoint, the viewer types (residential and recreational), and the scenic quality rating, the level of 6 sensitivity is considered moderately high. 7 KOP 19: Roadway Users along US 12 8 Scenic Quality: This viewpoint is located off of US 12, which is approximately 12.5 miles from the Project 9 and is a small connector providing regional access. This view looks north/northwest towards the Project 10 Area. The ridgelines of forest management areas are visible in the middle ground and background of the 11 viewshed. Natural openings are prevalent from this viewpoint, with several natural‐appearing features of 12 openings and vegetation that provide an interesting view. The quality of the views from this viewpoint 13 along US 12 was rated as low, especially compared to higher quality views in areas to the east from which 14 the Project Area is not visible. The viewshed represented here reflects the fact that the visible landscape 15 is relatively common in the region and has average scenic value. The southern ridge of the Project, as well 16 as a closer ridgeline, provide a degree of topographic interest when viewed with the other natural 17 appearing features. The landscape visual scenic quality from this viewpoint is low. 18 Viewer Sensitivity: Traffic volumes along US 12 are minimal and used for local traffic and recreational 19 traffic in the summer months. Considering the distance of the Project from this viewpoint (approximately 20 12.5 miles), the minimal use of the highway, and the portion of the Project that is visible from the 21 viewpoint, the level of view sensitivity is considered low. This is based on the duration of the view from 22 US 12, the low level of residential viewers from this viewpoint, and the scenic quality rating. 23 KOP 24A: SR 22, Tilton River Bridge (Representative of Recreational Users at Ike Kinswa State Park) 24 Scenic Quality: This viewpoint captures the view from the SR 22 bridge crossing the Tilton River, within 25 Ike Kinswa State Park. Ike Kinswa State Park sits on Mayfield Lake amidst a patchwork of farmland 20 miles 26 east of I‐5 and off of US 12. Ike Kinswa State Park provides opportunities for boating, swimming, and water 27 sports, as well as camping and hiking. The view looks north into the Project Area. The foreground is 28 dominated by views of the mouth of the Tilton before it discharges into Mayfield Lake, and the middle 29 ground is of mixed timber harvest openings. The background view is similar and the mixture of vertical 30 and horizon lines and formations and is dominated by ridgelines. The quality of the view from this 31 viewpoint was rated moderately high. 32 Viewer Sensitivity: When considering the distance of the Project from this viewpoint (at least 9.6 miles), 33 the duration of the view (background screening), the portion of the Project that is visible from the 34 viewpoint, the viewer types (minimal recreation), and the scenic quality rating, the level of sensitivity is 35 considered moderate. 36 3.9.4 Impacts of the Proposed Action 37 Visual impacts from wind power projects result from the alteration of the landscape by the introduction 38 of WTGs. The visual impacts of WTGs on the landscape is a complicated issue, and the factors other than 39 the attributes described above play a part in the observer’s reaction or perception to the visual impacts 40 or change. This analysis examines potential direct aesthetics and light and glare impacts during the 41 construction, operations and maintenance, and decommissioning phases of the Project. Indirect impacts 42 are not anticipated because the Project is not expected to substantially induce regional growth to the 43 extent that it will result in significant changes to the offsite visual landscape.

3.9‐16 1 WTGs are relatively large structures, and the need for windy locations requires the WTGs to be located 2 on areas such as ridgelines which may be open and somewhat visible. Viewers’ impacts to the visual 3 impacts of WTGs on the landscape is a complex issue and is influenced by the generally positive perception 4 of wind as a renewable energy alternative. However, many supporters of renewable energy projects 5 express a desire that the projects be placed elsewhere. This message was voiced by several people in open 6 houses conducted by the Applicant and public scoping meetings for this DEIS. Studies have shown that 7 some negative opinions change once the wind projects are constructed and are placed in operation. Other 8 Project elements such as the O&M Facility and the substation, 3.9 miles of new access roads, the gen‐tie 9 line, and additional power lines are discussed only where there is a likelihood that visual impacts will 10 occur. 11 This assessment included a viewshed analysis to determine the visibility of the Project WTGs within the 12 surrounding area, selection of KOPs representative of locations of interest within the study area, and 13 photographic simulations of the appearance of the Project from KOPs with a clear view of the Project. 14 Many of the stands of trees on the sections of land that will have WTGs on them are recently harvested 15 and reforested. An additional 2,000 acres per year are planned for harvest in the Vail Tree Farm as part of 16 ongoing commercial forestry operations (Lowe 2018). 17 In areas surrounding the proposed WTGs that have not been recently harvested or that are not planned 18 to be harvested before Project construction, trees will be harvested, and most of the land will be replanted 19 with seedlings. This clearing will allow for safe construction and will reduce the potential for tree growth 20 to interfere with the wind resource on the site during the commercial life of the Project. Low vegetation 21 will be maintained in some areas to provide safe areas around the WTGs. 22 3.9.4.1 Construction 23 Aesthetics 24 Project construction activities and associated equipment are described in Section 2.5. During construction, 25 large earth‐moving equipment, trucks, cranes, and other heavy equipment will be highly visible from 26 public roads as deliveries are made to the Project construction site. Views of construction activities will 27 be limited to persons located in the vicinity of construction sites. The public will be excluded during 28 construction activities on private lands, e.g., commercial forestry lands where the WTGs, access roads, 29 gen‐tie line, collector system, and Project substation will be located. These construction activities will only 30 be visible to Project construction workers and workers associated with commercial forestry activities at 31 the same locations.

32 At certain times, small, localized clouds of dust created by road building and other grading activities may 33 be visible in the Project Area. Because of construction‐related grading activities, areas of exposed soil and 34 fresh gravel that contrast with the colors of the surrounding undisturbed landscape will be visible. Since 35 most of the public views of such occurrences are from distant locations, the visual effects of construction 36 dust emissions and contrast of newly cleared areas will be relatively minor and will have little to no impact 37 on the quality of the views.

38 New and modified access roads required for construction and maintenance of the Project will require 39 additional forest clearing, grading, and construction of gravel roadway surfaces. The new road segments 40 will have the same appearance as the existing network of logging roads. These road features will be visible 41 only at relatively close distances and by people traveling within the locations where the roads are 42 constructed and will have minimal visual impact.

3.9‐17 1 From more distant view points, or from locations where vegetation is cleared and allows views of the gen‐ 2 tie line right‐of‐way, construction of the gen‐tie line component of the Project will result in a brief, 3 transitory view of a cleared swath coming down from the ridgeline on which the WTGs are constructed, 4 and for travelers on existing adjacent commercial forestry access roads. Some construction activities will 5 occur adjacent to public right‐of‐way where the gen‐tie line crosses Big Hanaford Road near its 6 interconnection point at the Tono substation; these activities will be visible to motorists travelling on Big 7 Hanaford Road.

8 Light and Glare

9 During WTG erection, some construction activities may occur during evening (dusk) hours, and lighting 10 may be needed. The effects of construction lighting will be temporary, lasting only during the specific 11 activity period (for WTG erection, estimated at six months). Hours of construction will be limited from 7 12 a.m. to 6 p.m.

13 3.9.4.2 Operation

14 Visibility Analysis

15 Human activity within the Vail Tree Farm and within close viewing distance of the Project is quite limited; 16 with their substantial height and the complex terrain in the area, only the WTGs will be visible from 17 locations where people will likely be present.

18 The visibility analysis results are documented in Figure 3.9–1 representing a map identifying the proposed 19 WTG locations and the potential viewshed within the 15‐mile radius study area. A general pattern evident 20 from the figure is that hilly terrain will block views of the WTGs for a majority of the area within a 10‐mile 21 radius. The VSOI also takes into account the visibility of existing development (roadways/highways, 22 residential/commercial land uses, silvicultural operations, mining operations, and other industrial 23 development), as well as the most visible Project components. Other variables affecting potential visibility 24 of the Project include orientation of the viewer, duration of view, atmospheric conditions, wind‐blown 25 dust and/or poor air quality, lighting (daylight versus nighttime), and visual absorption capability. Visual 26 absorption capability is the extent to which the complexity of the landscape can absorb new elements 27 without changing the overall visual character of the area.

28 Visual Impact Assessment

29 This section of the analysis rates the potential levels of visual impacts from key viewpoints through the 30 use of simulations of the built Project.

31 KOP 1: Roadway Users on SR 507 near Yelm Avenue

32 From KOP 1, the majority of WTGs and gen‐tie line structures are either difficult to see or are not visible 33 at all with the nearest WTG approximately 13.1 miles away. Figure 3.9–3 shows the simulated view. At 34 this distance, viewers will have to scan the horizon to find the WTGs, and views of the WTGs will not 35 dominate the landscape. Consequently, minor effects to the scenic quality is expected, especially because 36 the majority of the viewers will be focused on operation of their vehicle and the exposure is relatively 37 short.

38 Therefore, the potential visual impact from this KOP is low.

3.9‐18 1 KOP 8: Vail Loop Road/Gordon Road SE (Representative of Residential Viewers near Vail)

2 The majority of WTGs and gen‐tie line structures are either difficult to see or are not visible at all from 3 KOP 8, with the nearest WTGs approximately 6.63 miles away. Figure 3.9–4 shows the simulated view. 4 Because the WTGs will be seen against the sky at medium range and screened in many residential views, 5 they will still be visible in the background. This will reduce the visual unity and intactness minimally when 6 compared to the existing components in the landscape. The WTGs will be arrayed uniformly along the 7 ridgeline and will create a moderate change in the setting’s existing low to moderate visual quality.

8 The potential visual impact from KOP 8 will be low.

9 KOP 10: Residential and Recreational Viewers at Lake Lawrence

10 None of the WTGs or gen‐tie line structures will be visible from KOP 10, with the nearest WTGs 11 approximately 7.98 miles away. Figure 3.9–5 shows the simulated view. WTGs and gen‐tie structures are 12 obscured from view by topography and therefore, there the visual impact at this location will be low.

13 KOP 15: Residential Viewers at the Alpha Residences

14 Portions of the WTG string may be seen from KOP 15, with the nearest WTGs approximately 6.4 miles 15 away. Figure 3.9–6 shows the simulated view. At this distance, the contrast will have a relatively minor 16 effect on the overall visual impact. Consequently, because the prominence of the WTGs in the view will 17 be low, the WTGs will have a minor effect on the vividness, unity, and intactness from this viewpoint.

18 The potential visual impact from KOP 15 will be moderate.

19 KOP 19: Roadway Users along US 12

20 The majority of WTGs and gen‐tie line structures are either difficult to see or are not visible at all from 21 KOP 19, with the nearest WTG approximately 12.5 miles away. Figure 3.9–7 shows the simulated view. 22 Although some of the WTGs or gen‐tie line structures will be visible to travelers on the far horizon, their 23 presence is not expected to decrease the existing quality of this view because of their relatively small size 24 at this viewing distance. The visible WTGs and gen‐tie line structures will have a minimal effect on this 25 view’s vividness, unity, and intactness.

26 The potential visual impact from KOP 19 will be low.

27 KOP 24A: SR 22, Tilton River Bridge (Representative of Recreational Users at Ike Kinswa State Park)

28 From KOP 24A, most of the WTGs and gen‐tie line structures are either difficult to see or are not visible at 29 all to recreational users of the park and river. The nearest WTGs will be approximately 9.6 miles away. 30 The view looks north into the Project Area. Figure 3.9–8 shows the simulated view. Although the WTGs 31 will be visible to the viewers on the far horizon, it is not expected to decrease the existing quality of this 32 view to a great degree because of their relatively small size at this viewing distance. The visible WTGs will 33 have a minimal effect on this view’s vividness, unity, and intactness.

34 The potential visual impact from KOP 24A was considered to be moderate.

35

3.9‐19 Figure 3.9–3. KOP 1 Simulation

Existing

WTG Blade WTG Blade

Proposed: From KOP 1, the majority of WTGs and gen‐tie line structures are either difficult to see or are not visible at all with the nearest WTG approximately 13.1 miles away

3.9‐20 Figure 3.9–4. KOP 8 Simulation

Existing

WTG Blade

Proposed: The majority of WTGs and gen‐tie line structures are either difficult to see or are not visible at all from KOP 8

3.9‐21 Figure 3.9–5. KOP 10 Simulation

Existing

Proposed: Due to shielding from vegetation and landscape, none of the WTGs or gen‐tie line structures will be visible from KOP 10

3.9‐22 Figure 3.9–6. KOP 15 Simulation

Existing

WTG Blade WTG Blade

Proposed: Portions of the WTG string may be seen from KOP 15, with the nearest WTGs approximately 6.4 miles away

3.9‐23 Figure 3.9–7. KOP 19 Simulation

Existing

WTG Blades WTG Blades WTG Blade

Proposed: The majority of WTGs and gen‐tie line structures are either difficult to see or are not visible at all from KOP 19

3.9‐24 Figure 3.9–8. KOP 24A Simulation

Existing

WTG Blades

Proposed: WTGs and gen‐tie line structures are either difficult to see or are not visible at all to recreational users of the park and river

3.9‐25 1 Table 3.9‐3. Anticipated Level of Visual Impact

Existing Scenic Quality Anticipated Distance from Key Observation Point Viewer Level of Visual Nearest WTG Visual Quality Sensitivity Impact KOP 1: Roadway Users on SR 507 near Yelm 13.5 miles Low Low Low Avenue KOP 8: Vail Loop Road and Gordon Road Moderately (Representative of Residential Viewers near 6.6 miles Moderate Low High Vail) KOP 10: Residential Viewers at Lake Moderately 8.0 miles High Low Lawrence High KOP 15: Residential Viewers at the Alpha Moderately Moderately 6.4 miles Moderate Residences Low High KOP 19: Roadway Users along US 12 12.5 miles Low Low Low KOP 24A: SR22, Tilton River Bridge Moderately (Representative of Recreational Users at 9.6 miles Moderate Moderate High Ike Kinswa State Park) 2 .

3 Aesthetics

4 The Project has the potential to create high levels of visual impact at several locations, as discussed for 5 each KOP above. Not every potential view receptor in the Project Area has been documented. Selected 6 viewpoints are representative of a variety and range of views in the Project Area. The photos used for the 7 simulations were taken during seasons with the highest potential visual contrast between the WTGs and 8 the primarily green and brown landscape backdrop. The period with the least visual contrast is anticipated 9 to occur when there is snow cover and gray skies.

10 During operation, members of the public who have received recreation permits from landowners may 11 access locations on commercial forest lands in the vicinity of the gen‐tie line corridor, new or modified 12 Project access roads, WTGs, and the Project substation. These elements will be visible to such viewers as 13 a result of their direct proximity. The presence of these new elements will contrast to some degree with 14 the surrounding vegetated or cleared areas; however, such views will not be markedly different from 15 machinery associated with ongoing commercial forestry activity.

16 The O&M Facility will represent a new structural element in the landscape along Vail Loop Road, similar 17 in nature to modern day light‐industrial or agricultural buildings.

18 As indicated in Section 2.4.4, a very small portion of the gen‐tie line will be constructed across the public 19 right‐of‐way. Motorists travelling along Big Hanaford Road will be able to see the additional gen‐tie line 20 structures located adjacent to the public right‐of‐way. Given that a portion of this road traverses rural and 21 industrially used lands and utility lines are already present, such a change will not result in a significant 22 change to the visual landscape. The magnitude of this change will be quite small and likely not noticeable 23 to many viewers. Therefore, visual impacts from the gen‐tie line components of the proposed action will 24 be minor.

25 With respect to nationally managed recreational lands, the Mineral Block Unit of the Gifford Pinchot 26 National Forest is the closest publicly accessible area to the WTG string (see Figure 3.8‐2). As identified in 27 Figure 3.9‐1 (and discussed in Section 3.8.4.4), with the exception of elevated ridge tops, most visitors to

3.9‐26 1 the Gifford Pinchot National Forest will not be able to view the Project. As an additional point of reference, 2 the closest boundary of Mt. Rainer National Park is located approximately 30 miles from the closest 3 Project WTG location, and Paradise Park is located approximately 40 miles from the closest Project WTG. 4 Provided that there is no intervening vegetation or topography, and that meteorological conditions are 5 favorable, Project WTGs may be discernable to the viewers located at higher elevations at Mt. Rainer 6 National Park; however, they will be very far on the horizon and are not expected to decrease the existing 7 quality of this view to a great degree because of their relatively small size at this viewing distance and the 8 overall view range from such elevations.

9 Light and Glare

10 Standards for marking and lighting WTGs and other tall structures are set forth in FAA Advisory Circular 11 70/7460 – 1K. FAA “obstruction lighting” for wind facilities generally require one red blinking light, which 12 federal studies show is easier for pilots to see. Under the recommendations, nacelles at the ends of WTG 13 rows will be lit, with the remaining nacelles lit at half‐mile intervals. In areas with less air traffic, the white 14 paint typically used for WTGs is sufficient for day time marking when combined with a 24‐hour blinking 15 red light. Requirements for lighting and marking are specified in a formal FAA Determination of No Hazard 16 to Air Navigation; this determination by the FAA will occur after the Applicant files notices of construction 17 for specific WTG and meteorological tower locations.

18 Aviation safety lights installed on Project WTGs will be visible to varying degrees within the surrounding 19 area. Because the lights will be installed on nacelles, the visibility of the Project at night will be less 20 extensive than during the day (for which visibility is calculated based on the blade‐tip height). Some 21 viewers will consider the addition of the red lights to be a new type of intrusion in a rural setting without 22 extensive existing lighting sources.

23 Safety and security lighting will be included at both the Project substation and O&M Facility.

24 Glare (light reflecting off the surface of a WTG) impacts are not anticipated to result from surfaces 25 associated with WTGs (towers and blades) and gen‐tie line poles and structures because these come 26 finished with non‐reflective paint or surface treatments.

27 In summary, the Project includes a number of components that will introduce new sources of visual 28 contrast into the existing setting. Most of those changes will be visible only within a short distance and 29 will be seen by very few viewers. Visibility of the WTGs will be the most noticeable change from the 30 existing visual conditions in the study area. Based on consideration of viewing distance, viewer numbers 31 and sensitivity, and the existing visual context, the visual impacts of the Project will be insignificant.

32 3.9.4.3 Decommissioning

33 Activities resulting from Project decommissioning are described in Section 2.8. During the 34 decommissioning process, similar impacts to those experienced during construction will occur but to a 35 lesser extent because less construction material will be removed than was delivered to the WTG sites.

36 Following decommissioning, Project structures will no longer be visible as the Applicant anticipates that 37 all above‐ground structures will be removed.

38 For several years after decommissioning, site disturbance will be visible until vegetation has established, 39 or the sites are converted to their future use.

3.9‐27 1 3.9.5 Impacts of the No Action Alternative

2 Under the No Action Alternative, the Project would not be constructed or operated and the visual impacts 3 described in this section would not occur. Visual impacts associated with ongoing activities in the area 4 (e.g., commercial forestry, rural residential development, power generation and mine reclamation) would 5 continue.

6 The visual character of the Project Area will remain rural assuming that land uses will continue to follow 7 recent trends and that no area‐wide rezoning will occur in the near future.

8 3.9.6 Mitigation

9 As described in Section 2.11.1.1 and 2.11.1.3, as a result of avoidance of impacts to biological and aviation 10 space related resources, the Applicant not only reduced the number of WTGs originally considered and 11 proposed for the Project, but eliminated altogether the WTGs to be located in Thurston County. 12 Elimination of the WTGs located in Thurston County resulted in avoidance of views of the Project 13 throughout KOPs located in Thurston County (see Table 3.9.2 above). The analysis described above 14 indicates that visual impacts for the key observation points from which WTGs will be visible and other 15 locations surrounding the Project Area will be minor to minimal. The Applicant has identified proposed 16 BMPs that are essentially standard practice within the wind industry and are intended to mitigate, to the 17 extent feasible, a minor yet unavoidable impact.

18 3.9.6.1 Design, Construction, and Decommissioning

19 Visual impacts will be minimized during the Project design process by implementing the following:

20  To the extent consistent with FAA guidelines, use low reflectivity, neutral color finishes for the 21 WTGs and other Project components, to minimize contrast with the sky backdrop and to minimize 22 the reflections that can call attention to structures in the landscape 23  The WTG towers, nacelles, and rotors will be uniform in design throughout the Project Area 24  Restrict exterior lighting on the WTGs to the aviation warning lights required by the FAA, which 25 will be kept to the minimum required number and intensity while still complying with FAA 26 standards 27  Use of carefully selected earth‐tone, non‐reflective finishes, whenever possible, for the O&M 28 Facility to maximize visual integration into the surrounding landscape 29  All insulators in the substation will be non‐reflective and non‐refractive. 30 BMPs will be incorporated into the construction and decommissioning practices to minimize adverse 31 visual impacts as follows:

32  During the construction period, active dust suppression will be implemented to minimize the 33 creation of dust clouds 34  When construction is complete, areas disturbed during the construction process will be restored 35 to conditions specified in the Applicant’s Temporary Construction Restoration Plan 36  Existing roads will be used as much as possible to access WTGs.

3.9‐28 1 3.9.6.2 Operation

2  Restrict outdoor night lighting at the substation and O&M Facility to the minimum required for 3 safety and security. Sensors and switches will be used to keep lighting turned off when not 4 required, and all lights will be hooded and directed to minimize backscatter and offsite light 5 trespass.

6 3.9.7 Connected Action

7 Construction of the interconnection will involve delivery and installation of a step‐up transformer in the 8 Tono substation yard, and conductoring to interconnect the gen‐tie line to the step‐up transformer, and 9 the transformer to the remainder of the substation. All construction activity will occur within the existing 10 Tono substation yard which already contains numerous electrical and transmission‐related equipment 11 and maintenance buildings. The Tono substation is visible to passersby travelling on Big Hanaford Road, 12 except in locations where existing vegetation block the view. The step‐up transformer and associated 13 conductors will not be visibly distinct from the existing substation equipment but may be visible if 14 travelers go by at slow speed. Installation of the step‐up transformer will not alter the existing visual 15 character of the substation.

16 3.9.8 Unavoidable Adverse Impacts

17 Temporary impacts resulting from construction activities may result in visual impacts. The Applicant will 18 implement measures to minimize construction dust emissions and will restore temporarily disturbed 19 areas in accordance with a Temporary Construction Restoration Plan.

20 Project WTGs will be visible from long distances and will create unavoidable aesthetic impacts in some 21 locations by introducing a distinct, new visual element to the landscape. For some viewers, the mere 22 presence of WTGs represents an adverse impact because it alters the appearance of the rural landscape 23 of the area, no matter how little of an alteration occurs. The presence of FAA‐mandated air navigation 24 safety lights marking certain WTGs will introduce a new visible element into the night sky. The degree to 25 which these impacts are adverse depends on the viewer’s location and sensitivity and the impact on view 26 quality. In the final analysis, it is the comparative number of viewers most affected by the Project that 27 determines the overall impact. Based primarily on consideration of the substantial distances at which the 28 WTGs will be visible to the general public and the landscape context in which the WTGs will be seen, these 29 impacts are not considered to be significant. As part of Project design and materials selection, impacts 30 resulting from potential glare will be minimized via selection of non‐reflective finishes; these measures 31 will reduce glare impacts to non‐significance.

32 With the mitigation measures to be implemented by the Applicant adverse impacts will be reduced to 33 non‐significance.

34 3.9.9 References

35 Bureau of Land Management. 1986. Manual H‐8410‐1 – Visual Resource Inventory. January 17, 1986.

36 Lytle‐Bonine, C. 2018. E‐mail to Irina Makarow, HDR, regarding final locations of existing view 37 photographs taken for visual simulations. Re: Skook – Visual Simulations. June 6, 2018.

3.9‐29 1 Federal Highway Administration (FHWA). 1988. Visual Impact Assessment for Highway Projects. 2 Publication No. FHWA‐HI‐88‐054.

3 FHWA. 2015. Guidelines for the Visual Impact Assessment of Highway Projects. January.

4 Lewis County. 2017. Lewis County Code, Chapter 17.30 Resource Lands. Available online: 5 http://www.codepublishing.com/WA/LewisCounty/?LewisCounty17/LewisCounty17.html. Accessed 6 November 6, 2017.

7 Thurston County. 2017. Thurston County Code, Title 20 – Zoning. Available online: 8 https://library.municode.com/wa/thurston_county/codes/code_of_ordinances. Accessed November 3, 9 2017.

10 U.S. Department of Agriculture, Forest Service (USFS). 1995. Landscape Aesthetics | A Handbook for 11 Scenery Management. December.

3.9‐30