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COLUMBUSICLEVELAND Ms. Betty McCauly CINCINNATI-DAYTON Administration/Docketing MARIETTA Ohio Power Siting Board th BRICKER&ECKLERLLP 180 East Broad Street, 11 Floor 100 South Third Street Columbus, OH 43215-4291 Columbus, Ohio 43215-3793 MAIN: 614.227.2300 FAX: 614.227.2390 Re: Northwest Ohio Wind Energy www.bricker.com Case No. 13-197-EL-BGN [email protected] Dear Ms. McCauly: Sally W. Bloomfield 614.227.2368 [email protected] Enclosed, please find an original and five copies of the Amended Application of Northwest Ohio Wind Energy for a Certificate of Environmental Compatibility and Public Need under Chapter 4906-17 of the Ohio Administrative Code (OAC). Pursuant to OAC 4906-5-03(A)(3), the applicant makes the following declarations:

Name of Applicant: Northwest Ohio Wind Energy LLC c/o National Wind, LLC 706 Second Avenue South, Suite 1200 Minneapolis, MN 55402

Name/Location of Proposed Facility: Northwest Ohio Wind Energy wind farm Townships of Blue Creek and Latty Paulding County, Ohio

Authorized Representative Technical: Marcus V. da Cunha National Wind LLC 706 Second Avenue South, Suite 1200 Minneapolis, MN 55402 Telephone: (612) 746-6617 E-Mail: [email protected]

6555997v1 #2/-0.2 ! $-01.2 "**'(&$,) "* %"+

Ms. Betty McCauly August 9, 2013 Page 2 of 2

Authorized Representative Legal: Sally W. Bloomfield Bricker & Eckler LLP 100 South Third Street Columbus, OH 43215 Telephone: (614) 227-2368; Facsimile: (614) 227-2390 E-Mail: [email protected]

Notarized Statement: See Attached Affidavit Kristin Skoog, on behalf of Northwest Ohio Wind Energy LLC

Sincerely on behalf of NORTHWEST OHIO WIND ENERGY LLC

Sally W. Bloomfield

Enclosure

6555997v1

BEFORE THE OHIO POWER SITING BOARD Amended Application of Northwest Ohio Wind Energy, LLC Table of Contents

Page No.

LIST OF FIGURES ...... viii

LIST OF TABLES...... ix

LIST OF ATTACHMENTS ...... x

GLOSSARY ...... xi

4906-17-02 Project Summary and Facility Overview...... 1

(A) PROJECT SUMMARY AND OVERVIEW OF THE PROPOSED PROJECT...... 1

(1) General Purpose of the Facility...... 1 (2) Facility Description...... 2 (3) Site Selection Process ...... 3 (4) Principal Environmental and Socioeconomic Considerations...... 3 (a) Ecological ...... 3 (b) Land Use and Community Development...... 5 (c) Socioeconomics ...... 5 (d) Cultural resources ...... 6 (e) Noise and Visual Impacts ...... 6 (5) Project Schedule...... 7

4906-17-03 Project Description and Schedule ...... 8

(A) PROPOSED FACILITY DESCRIPTION...... 8

(1) Project Description...... 9 (a) Types of Turbines ...... 9 (b) Area Requirements...... 9 (2) Description of Equipment...... 12 (a) Wind Energy Turbines...... 13 (b) Electrical Collection System and Step-Up Facilities...... 14 (c) Transmission Lines ...... 14 (d) Substations ...... 14 (e) Met Mast ...... 14 (f) SODAR...... 14 SODAR was not conducted for the development of the Facility...... 14 (3) Description of New Transmission Lines...... 14

(B) DETAILED PROJECT SCHEDULE...... 14

i NORTHWEST OHIO WIND ENERGY, LLC (1) Project Schedule...... 14 (a) Land Acquisitions and Land Rights...... 15 (b) Wildlife Studies/Surveys ...... 15 (c) OPSB Application Preparation ...... 15 (d) OPSB Application for Certificate Submittal...... 15 (e) Issuance of the OPSB Certificate...... 15 (f) Preparation of Final Design ...... 15 (g) Facility Construction...... 16 (h) Placement of Facility in Service ...... 16 (2) Delays ...... 16

4906-17-04 Project Area Analyses...... 17

(A) SITE SELECTION STUDY...... 17

(1) General...... 17 (a) Description of Study Area ...... 17 (b) Maps of Evaluated Sites...... 17 (c) Siting Criteria...... 17 (d) Relevant Factors in the Site Selection Process ...... 23 (e) Process for Determining Sites...... 23 (2) Constraint Map...... 23

(B) SUMMARY TABLE OF EVALUATED SITES...... 23

4906-17-05 Technical Data ...... 24

(A) PROJECT AREA SITE ...... 24

(1) Geography and Topography ...... 24 (a) Proposed Facility ...... 24 (b) Major Population Centers and Geographic Boundaries...... 24 (c) Major Transportation Routes and Utility Corridors...... 24 (d) Bodies of Water ...... 24 (e) Topographic Contours ...... 24 (f) Major Institutions/Parks/Recreational Areas ...... 24 (g) Residential, Commercial Buildings and Installations...... 24 (h) Air Transportation Facilities, Existing and Proposed...... 24 (2) Aerial Photograph ...... 24 (3) Site Mapping...... 25 (a) Topographic Contours ...... 25 (b) Existing Vegetative Cover ...... 25 (c) Land Use and Classifications...... 25 (d) Individual Structures and Installations...... 25 (e) Surface Waters...... 25 (f) Water and Gas Wells ...... 25

ii NORTHWEST OHIO WIND ENERGY, LLC (g) Vegetative Cover Removed ...... 25 (4) Geology and Seismology ...... 25 (a) Site Geology...... 25 (b) Soil Suitability ...... 26 (c) Geologic Hazards...... 30 (5) Hydrology and Wind...... 32 (a) Water Budgets...... 32 (b) Floods and High Winds ...... 35 (c) Maps...... 37

(B) LAYOUT AND CONSTRUCTION...... 37

(1) Project Area Site Activities...... 37 (a) Test Borings...... 37 (b) Removal of Vegetation ...... 38 (c) Grading and Drainage...... 39 (d) Access Roads ...... 40 (e) Removal and Disposal of Debris ...... 41 (f) Post-Construction Reclamation ...... 42 (2) Layout ...... 42 (a) Wind-Powered Electric Generation Turbine Locations...... 42 (b) Transformers and Collection Lines...... 42 (c) Construction Laydown Areas ...... 42 (d) Transmission Lines ...... 42 (e) Substations ...... 42 (f) Transportation Facilities and Access Roads ...... 42 (g) Security Facilities...... 42 (h) Grade Elevations...... 42 (i) Other Pertinent Installations ...... 43 (3) Structures ...... 43 (a) Estimated Overall Dimensions ...... 43 (b) Construction Materials...... 43 (c) Color and Texture of Facing Surfaces ...... 44 (d) Photographic Interpretation or Artist’s Pictorial Sketches ...... 44 (e) Unusual Features...... 44 (4) Plans for Construction...... 44 (5) Future Plans ...... 45

(1) Wind-Powered Generation Equipment...... 45 (a) Wind Energy Turbines...... 45 (b) Nacelle ...... 46 (c) Rotors...... 47 (d) Tower ...... 47 (e) Foundation ...... 48 (f) Electrical Components...... 48

iii NORTHWEST OHIO WIND ENERGY, LLC i. 34.5kV Electric Collection System...... 48 ii. Step-Up Facility...... 48 (2) Safety Equipment...... 48 (a) Description of All Proposed Public Safety Equipment...... 48 (b) Description of the Reliability of the Equipment...... 50 (c) Description of Turbine Manufacturer’s Safety Standards...... 50 (3) Any Other Major Equipment ...... 51

(D) REGIONAL ELECTRIC POWER SYSTEMS...... 51

(1) Interconnection Queue...... 51 (a) Name of the Queue ...... 51 (b) Web Link of the Queue...... 51 (c) Queue Number...... 51 (d) Queue Date...... 51 (2) System Studies...... 51 (a) Feasibility Study ...... 51 (b) System Impact Study ...... 51 (c) Facilities Study...... 51

4906-17-06 Financial Data ...... 52

(A) OWNERSHIP ...... 52

(B) CAPITAL AND INTANGIBLE COSTS ...... 53

(1) Capital and Intangible Cost Estimates ...... 53 (2) Cost Comparison...... 53 (3) Tabulation of Present Worth and Annualized Capital Costs ...... 54

(1) Estimate of Annual Operation and Maintenance Costs ...... 55 (2) Cost Comparison...... 55 (3) Present Worth and Annualized Capital Costs...... 56

(D) DELAYS...... 56

4906-17-07 Environmental Data ...... 57

(A) GENERAL...... 57

(B) AIR...... 57

(1) Preconstruction ...... 57 (a) Ambient Air Quality ...... 57 (b) State/Federal New Source Performance Standards...... 57 (c) List of Required Permits ...... 59

iv NORTHWEST OHIO WIND ENERGY, LLC (d) Compliance Plans...... 59 (2) Construction...... 59

(1) Pre-construction ...... 60 (2) Construction...... 60 (a) Permits ...... 60 (b) Aquatic Discharges ...... 62 (c) Mitigation Plans...... 64 (d) Changes in Flow Patterns and Erosion ...... 65 (3) Operation...... 66 (a) Quantitative Flow Diagram...... 66 (b) Conservation Practices...... 66

(D) SOLID WASTE...... 67

(1) Preconstruction ...... 67 (2) Construction...... 67 (a) Debris and Solid Waste Generated ...... 67 (b) Storage and Disposal Methods...... 67 (3) Operations...... 68 (a) Solid Wastes Generated ...... 68 (b) Treatment, Transport, and Disposal...... 68 (4) Licenses and Permits...... 69

4906-17-08 Social and Ecological Data ...... 70

(A) HEALTH AND SAFETY...... 70

(1) Demographic Characteristics...... 70 (2) Noise ...... 72 (a) Construction Noise Levels...... 74 (i) Dynamiting activities...... 74 (ii) Operation of earthmoving equipment ...... 74 (iii) Driving of piles ...... 75 (iv) Erection of structures ...... 75 (v) Truck traffic ...... 75 (vi) Equipment installation ...... 76 (b) Operational Noise Levels...... 76 (c) Location of Noise Sensitive Areas...... 77 (d) Mitigation of Noise Emissions...... 79 (3) Water...... 80 (a) Impact on Public and Private Water Supplies...... 80 (b) Construction Water Impacts ...... 81 (c) Operation Water Impacts ...... 81 (4) Ice Throw...... 82

v NORTHWEST OHIO WIND ENERGY, LLC (5) Blade Shear ...... 83 (6) Shadow Flicker ...... 85

(B) ECOLOGICAL IMPACT...... 88

(1) Project Site Information...... 88 (a) Mapping ...... 90 (b) Vegetative Survey...... 90 (c) Animal Life Survey...... 94 (d) Summary of Ecological Studies...... 99 (e) Major Species List ...... 100 (2) Construction...... 108 (a) Impact of Construction ...... 108 (b) Impact of Construction on Major Species ...... 110 (c) Mitigation of Short- and Long-term Construction Impacts ...... 111 (3) Operation...... 114 (a) Estimate the Impact of Operation on Areas...... 114 (b) Estimate the Impact of Operation on Major Species ...... 115 (c) Mitigation of Impacts...... 116 (d) Post-Construction Monitoring of Wildlife Impacts ...... 118

(1) Land Uses...... 119 (a) Land Use Map...... 119 (b) Habitable Residential Structures...... 119 (c) Wind Turbine Structure Locations...... 119 (i) Distance from base to property line...... 120 (ii) Distance from blade to habitable residential structures...... 120 (iii) Waiver of minimum setback...... 120 (iv) Distances from Pipelines...... 120 TransCanada Pipeline to T-06: Approximately 607 feet ...... 120 Dominion Gas Pipeline to T-32: Approximately 1,855 feet...... 121 Panhandle Gas Pipeline to T-09: Approximately 656 feet ...... 121 (d) Impact of Proposed Facility...... 121 (e) Identification of Structures to be Removed or Relocated...... 122 (f) Plans for Future Use...... 122 (g) Concurrent or Secondary Uses...... 122 (2) Economics...... 123 (a) Estimated Payroll...... 123 (b) Estimated Employment...... 124 (c) Estimated Tax Revenue ...... 125 (d) Estimated Economic Impact ...... 125 (3) Public Services and Facilities ...... 127 (4) Impact on Regional Development ...... 129 (a) Description...... 129

vi NORTHWEST OHIO WIND ENERGY, LLC (b) Compatibility ...... 134

(D) CULTURAL IMPACT ...... 134

(1) Map of Landmarks of Cultural Significance and Recreational Areas ...... 134 (2) Estimated Impact on Landmarks ...... 136 (3) Consideration of Landmarks...... 137 (4) Mapping Landmarks ...... 137 (5) Recreational Areas...... 137 (6) Visual Impacts ...... 137

(E) PUBLIC RESPONSIBILITY ...... 139

(1) Public Information Program ...... 139 (a) Local Office and Staff...... 139 (b) Local Advisory Board...... 139 (c) Landowner and Community Meetings...... 140 (d) Project Newsletters and Mailings ...... 142 (e) Project Website ...... 142 (f) Landowner Participation in Micrositing ...... 143 (g) Future Public Information Programs ...... 143 (h) Local Media, Local Government and Elected Officials ...... 144 (2) Liability Insurance ...... 144 (3) Evaluation of Interference with Radio and Television ...... 145 (4) Evaluation of Interference with Military Radar...... 147 (5) Evaluation of Impact to Roads and Bridges ...... 147 (6) Plan for Decommissioning...... 147

(F) AGRICULTURAL DISTRICT IMPACT ...... 151

(1) Agricultural District Mapping...... 151 (2) Impact Assessment on Agricultural Land...... 151 (a) Acreage Impacted ...... 151 (i) Field operations...... 151 (ii) Irrigation...... 152 (iii) Field drainage systems...... 152 (b) Mitigation...... 152 (3) Viability Assessment ...... 153

(G) Additional Information ...... 154

vii NORTHWEST OHIO WIND ENERGY, LLC LIST OF FIGURES

List Project Schedule, maps, photographs, renderings, isopleths or other figures referenced in the application.

Figure 3-1 Site Layout Figure 3-2 Project Schedule Figure 4-1 Constraints Figure 5-1 Geology and Topography Figure 5-2 Aerial Photography Figure 5-3 Existing Features Figure 5-4 Ecological Impact Figure 8-1 Land Use Figure 8-2 Agricultural District Lands

3059952v6 viii NORTHWEST OHIO WIND ENERGY, LLC LIST OF TABLES

List all Tables referenced, such as sound levels, wildlife observations, recreational areas, etc.

Table 3-1: Land Requirements for Construction and Operation of the Facility

Table 5-1: Generalized Project Area Subsurface Conditions

Table 5-2: Geologic and Geotechnical Hazard Summary

Table 5-3: Temporary Piezometer Readings

Table 6-1: Estimated Capital Tangible and Intangible Costs

Table 8-1: Summary Population Statistics – Counties

Table 8-2: Summary Population Statistics – Communities and Townships

Table 8-3: Common Sound Sources and Sound Levels

Table 8-4: Noise Emission Levels Typical of Construction Equipment

Table 8-5: Modeled Maximum Sound Levels: Turbine Sound [dB(A)]

Table 8-6: Residential Structures Realistic Shadow Flicker Distribution Within 1,500 Meter from Turbines

Table 8-7: Land use within the Project area

Table 8-8-: Wetland Impact Summary Table

Table 8-9: Rare Species known to occur in Paulding County identified by the Ohio Division of Wildlife Natural Heritage Database (11/8/2012)

Table 8-10: Historic Architectural/Standing Structure Resources Within the Project area and Five-Mile Buffer

3059952v6 ix NORTHWEST OHIO WIND ENERGY, LLC LIST OF ATTACHMENTS or APPENDICIES

Appendix A Motion of Waivers Appendix B Typical O&M Facility Example Appendix C Raptor Nest Survey Appendix D Geotechnical Engineering Report Appendix E Wind Energy Turbine Manufacturer Information Appendix F Wind Energy Turbine Manufacturer Safety Manuals Appendix G Feasibility Study Appendix H System Impact Study Appendix I Acoustic Assessment Appendix J Shadow Flicker Assessment Appendix K Bat Assessment Survey Reports Appendix L Northern Harrier Surveys Appendix M Wetland Delineation Report Appendix M-1 ODNR DOW and USFWS Correspondences Appendix N Breeding Bird Species Richness in Ohio Appendix O ODNR Natural Heritage Comment Letter Appendix P FAA Aeronautical Studies Appendix Q Cultural Resource Reconnaissance Survey Appendix R OSHPO Correspondences Appendix S Visual Impact Assessment Appendix T Communication Studies Appendix U Decommissioning Plan

3059952v6 x NORTHWEST OHIO WIND ENERGY, LLC GLOSSARY

AEP – AEP Energy

AEPS – Alternative Energy Portfolio Standard

BAT – Best Available Technology

BMP – Best Management Practice

CECPN – Certificate of Environmental Compatibility and Public Need

CFR – Code of Federal Regulations dB – decibels

DOE – United States Department of Energy

FAA –Federal Aviation Administration

FEMA – Federal Emergency Management Agency

FERC – Federal Energy Regulatory Commission

GIS – Geographic Information System

HDD – Horizontal Directional Drilling

MW – megawatt

NAAQS – National Ambient Air Quality Standard

NWI – National Wetlands Inventory

NCDC – National Climatic Data Center

NLCD – National Land Covered Data

NPDES – National Pollutant Discharge Elimination System

NRHP – National Register of Historic Places

NSPS – New Source Performance Standards

NSA – Noise Sensitive Areas

NWOWE – Northwest Ohio Wind Energy, LLC

3059952v6 xi NORTHWEST OHIO WIND ENERGY, LLC O&M – Operations and Maintenance

OAC – Ohio Administrative Code

ODNR – Ohio Department of Natural Resources

ODNR DOW – Ohio Department of Natural Resources Division of Wildlife

ODOT – Ohio Department of Transportation

Ohio EPA – Ohio Environmental Protection Agency

OHPO – Ohio Historic Preservation Office

OPSB – Ohio Power Siting Board

OWI – Ohio Wetlands Inventory

PPA – Power Purchase Agreement

PTC – Production Tax Credit

PTI – Permit to Install

PUCO – Public Utilities Commission of Ohio

ROW – Right-of-Way

SPCC – Spill Prevention, Control & Countermeasures Plan

SWPPP – Storm Water Pollution Prevention Plan

USACE – United States Army Corps of Engineers

USDA – United States Department of Agriculture

USEPA - United States Environmental Protection Agency

USFWS – United States Fish and Wildlife Service

USGS - United States Geological Survey

WWH - Warm Water Habitat

3059952v6 xii NORTHWEST OHIO WIND ENERGY, LLC 4906-17-02 Project Summary and Facility Overview

(A)PROJECT SUMMARY AND OVERVIEW OF THE PROPOSED PROJECT

Northwest Ohio Wind Energy, LLC (the “Applicant”) is proposing to construct up to 100 megawatts (MW) in nameplate capacity of wind-powered energy generation in northwestern Ohio, specifically in portions of Blue Creek and Latty Townships and the Village of Haviland in Pauld- ing County (the “Facility”). Trishe Wind Energy Holdings, Inc. (Trishe) is the sole owner of Northwest Ohio Wind Energy, LLC, and employs the services of its wholly-owned subsidiary, National Wind LLC, for the day-to-day development activities of the project. National Wind’s team has several thousand megawatts of wind development experience in the US and abroad. Trishe and National Wind employ the services of top-tier industry consultants in the development of the portfolio of projects, notably, AWS Truepower, Bechtel Enterprises, Bricker and Eckler, Burns & McDonald, CH2MHILL, EAPC Engineers, Fredrikson and Byron, Resource Systems Group, Inc. (“RSG”), Stoel Rives, Tragus Environmental Consulting, Inc. (“Tragus”), Terracon Consultants, Inc. (“Terracon”) and Westwood Professional Services, Inc. (“West- wood”).

(1) General Purpose of the Facility

The general purpose of the Facility is to produce clean and reliable renewable energy to utility customers though a power purchase agreement (PPA) and/or through merchant mechanisms with a Federal Energy Regulatory Commission (FERC) licensed wholesale power purchaser, such as an energy company, an electric utility or a power marketer. The energy generated by the Facility will be integrated into the transmission grid through an interconnection agreement with the regional transmission organization, PJM. PJM coordinates the movement of wholesale electricity through all or parts of Delaware, Indi- ana, Illinois, Kentucky, Michigan, Maryland, New Jersey, North Carolina, Ohio, Penn- sylvania, Tennessee, Virginia, West Virginia and the District of Columbia. The energy produced could be sold inside Ohio or to other states within the PJM grid system.

Applicant designed the Facility to help Ohio meet the Ohio Alternative Energy Portfolio Standard (AEPS) set by law. The current Ohio AEPS (Amended Substitute Senate Bill

3059952v6 4906-17-02 1 NORTHWEST OHIO WIND ENERGY, LLC 221) requires that by 2025, at least 25% of the electricity in Ohio be generated by alternative energy resources. Of that 25%, at least half of the energy must come from renewable energy such as wind, and half of that must be generated within Ohio. On a statewide level, the project will assist Ohio in meeting its renewable energy goals and the local ownership, lease payments, job creation, and tax base generation will aid the economic development goals of the local community.

(2) Facility Description

The Facility will be located within an approximately 21,000-acre Project area in portions of Blue Creek and Latty Townships and the Village of Haviland in Paulding County. Land use within in the Project area is almost exclusively agricultural. Land lease and wind easements have been signed with approximately 274 landowners/signatures representing approximately 12,750 acres of land. Sufficient land is under lease to build the project. A further breakdown of the land use types within the Project area is provided in Section 4906-17-08(C)(1).

Applicant is proposing to install up to 59 wind turbines (depending on the nameplate capacity of the turbine selected), along with all associated infrastructure, including underground collection lines, access roads, voltage step-up facility, a temporary staging and construction laydown area, most probably a temporary concrete batch plant and an operation and maintenance facility. The operation and maintenance facility may include either a new structure or an existing structure converted to that use. Turbine locations were provisionally sited to generate maximum efficiency within the leased area. This was accomplished by: (1) establishing developable area envelopes based on the boundaries of leased land overlaid by the applicable setbacks; (2) using computer software, generating an optimized layout for up to 60 turbines based on wind resource data collected on site; and (3) refining the optimized layout to ensure it complies with Ohio standards for sound and shadow flicker.

The Facility will interconnect to an existing 138kV American Electric Power (AEP) transmission line which runs through the southern part of the Project area. The point of interconnection (POI) is at the existing AEP Haviland substation, just south of Haviland,

3059952v6 4906-17-02 2 NORTHWEST OHIO WIND ENERGY, LLC Ohio. Interconnection will be secured through an interconnection agreement with PJM. Voltage from the 34.5 kV underground electrical collection system will be stepped up to 138 kV at a step-up transformer facility immediately adjacent to the Haviland substation, obviating the need for an overhead interconnection transmission line.

(3) Site Selection Process

On April 10, 2013, Applicant was granted a waiver from the requirement to perform an extensive site selection study as required by Rule 4906-17-04(A), O.A.C. (Appendix A). However, in section 4906-17-04 of this application, Applicant supplies a general discussion regarding the selection of the site. The site was selected based on: (1) a demonstrated strong wind regime (confirmed by multiple years of onsite wind resource data); (2) very strong community support; (3) ready access to existing transmission; and (4) environmental factors that make the site well suited for a utility scale wind farm.

(4) Principal Environmental and Socioeconomic Considerations

During Facility development Applicant conducted analyses of potential environmental and socioeconomic impacts resulting from construction and operation of the Facility. Section 4906-17-07 provides detailed discussion of potential direct and indirect environmental impacts and potential mitigation measures for such impacts. Section 4906-17-08, provides detailed discussion of the social and ecological impacts. Provided below is a summary of the major environmental and socioeconomic considerations, including ecological, land use and community development, socioeconomic, cultural resources, noise, and visual impact.

(a) Ecological

Applicant retained consultants to conduct site visits to the Project area to charac- terize ecological features and identify wetlands and waterbodies. Applicant designed the Facility to avoid impacts to wetlands. Some wetland impacts are anticipated during Facility construction. Permanent wetland impacts will be limited to access road crossings less than 0.5 acre total to ensure coverage by United State Army Corps of Engineers (USACE) Nationwide permit 51. Further, Applicant will mitigate impacts resulting from temporary access roads and underground col-

3059952v6 4906-17-02 3 NORTHWEST OHIO WIND ENERGY, LLC lection cable installation by restoring impacted wetlands to pre-construction conditions. The Project area is predominantly agricultural (95%) with approximately 1.5% percent woodland. Facility design is configured to avoid direct impacts to forested wetlands and to minimize impacts to upland woodlots and windbreaks.

Prior to initiating wildlife field surveys, Applicant reviewed ODNR’s On-shore Bird and Bat Pre-Construction Monitoring Protocol for Commercial Wind Facili- ties in Ohio (ODNR 2009) and contacted the ODNR DOW and USFWS for Facil- ity-specific guidance. In January 2010, the ODNR issued wildlife survey recommendations for the Project area and in February 2010, the U.S. Fish and Wildlife Service (USFWS) concurred with ODNR recommendations. The ODNR Divi- sion of Wildlife (DOW) determined the Facility would require the “minimum” level of sampling effort based upon the location and land-use practices of the site, stating: “Over 95% of this project’s the leased land is currently in active agriculture, and thus, not suitable habitat for most species of birds or bats. The DOW has no records of protected species of raptor (hawks, falcons and eagles) nesting or bat observations within 5-miles of the project site.” Additionally, the ODNR Nat- ural Heritage database was reviewed for the Project area and “no records of rare or endangered species” were found. Applicant also conducted desktop biological studies to assess potential impacts to commercial and recreational species and those species designated threatened or endangered.

Wildlife field studies were conducted on-site in May, June and July of 2010 and April and May, 2013 and consisted of raptor nest searches (including the northern harrier), bat acoustic and mist net surveys and incidental wildlife observations during other field survey efforts. Pursuant to ODNR guidance, breeding bird surveys were not conducted because all turbines were sited in active cropland. Based on raptor nest surveys in both 2010 and 2013, no known raptor nests will be affected by the Facility. No northern harrier nests were found. Neither mist net or acoustic bat surveys detected Indiana bats, a federally listed endangered species and no potentially suitable summer maternity roosting habitat will be affected by the Facility. USFWS has indicated that Indiana bats migrate through the area and

3059952v6 4906-17-02 4 NORTHWEST OHIO WIND ENERGY, LLC that a turbine-related fatality occurred at an adjacent wind farm during fall migration. Applicant is working with the USFWS to explore whether participating in a regional multi-species Habitat Conservation Plan (HCP) currently under development is an appropriate approach to minimizing the potential for adverse impacts to this species.

Because the Project area is intensively farmed and encompasses minimal wildlife habitat, impacts due to construction and operation of the Facility are expected to be minimal. The land is currently and has historically been disturbed frequently for farming activities. Soil disturbance due to construction will almost exclusively occur in areas which have previously been disturbed for plowing and harvesting activities. Some turbine-related avian and bat fatalities are anticipated but the number of fatalities is expected to be commensurate with the limited wildlife habitat in the surrounding area. Ongoing coordination with ODNR and USFWS will continue throughout Facility design, construction and operations to minimize potential impacts to threatened or endangered species.

(b) Land Use and Community Development

The Facility will be located in Blue Creek and Latty Townships, Paulding County. Agriculture is the dominant land use within the Project area and the land in a five- mile radius. Residential development within and around the Facility consists almost entirely of single-family homesteads situated along rural roads. Applicant has leased land from private landowners, collectively comprising approximately 12,750 acres. The Facility will be compatible with the agricultural land uses that dominate the project area.

The Facility will benefit the economy of Paulding County in a variety of ways. Landowner lease payments are based on a percentage of gross revenues, so as the project creates profits, a portion of those are passed onto the landowners. This additional income will filter into the local economy through increased spending in

3059952v6 4906-17-02 5 NORTHWEST OHIO WIND ENERGY, LLC local businesses, increased tax revenues and the wind project participant agreements.

(d) Cultural resources

Desktop analysis of cultural resources was conducted by Westwood in March 2013. Field investigations were conducted in April and May 2013. As of May 20, 2013 the archaeological investigations identified 13 previously unrecorded prehistoric period sites and relocated the single previously recorded site located within the Project area. Nine of the sites consist of isolated finds (single artifacts) and the other five consist of lithic scatters. None of the sites identified to date are considered significant and, therefore, not eligible for listing on the National Register of Historic Places (NHRP). Applicant will avoid impacts to identified archaeological and historic resources to the extent possible. If archaeological or historic resources are found during construction, integrity and significance will be assessed. If the resource is found to be eligible for the NHRP, adverse effects will be avoided through Facility design. If avoidance is not possible, appropriate mitigation measures will need to be developed in consultation with Ohio Historic Preserva- tion Office (OHPO).

Current interaction with OHPO is included in Appendix Q-1 “OHPO Correspond- ence”. No future correspondence is anticipated beyond specific avoidance protocols, if required.

(e) Noise and Visual Impacts

Applicant commissioned noise studies and conducted visual impact studies, the results of which are presented in more detail in section 4906-17-08. Sound and visual impact concerns will be addressed through turbine placement setbacks including 750ft. from occupied residences and 541.3 ft. from property boundaries and major roadways.

3059952v6 4906-17-02 6 NORTHWEST OHIO WIND ENERGY, LLC (5) Project Schedule

" Wind measurement May 2008 to present

" LLC Formation Oct 2008

" Feasibility analysis Dec 2008

" Bulk of land acquisition Mar 2009 to Dec 2010

" Bat studies Mar 2010 to Nov 2010

" First avian studies Apr 2010 to June 2010

" Permitting Jan 2013 to Dec 2013

" Parcel and easement acquisition Jan 2013 to May 2013

" Field technical studies Mar 2013 to May 2013

" Second avian studies Apr 2013 to May 2013

" Location-specific geotechnical survey Sep 2013 to Oct 2013

" Civil, electric and foundation design Sep 2013 to Nov 2013

" Interconnection Services Agreement Sep 2013

" Production Tax Credit equity investment Nov 2013

" PUCO CECPN Dec 2013

" Turbine down payment Dec 2013

" Construction crew mobilization Apr 2014

" Electric backfeed Aug 2014

" Commercial operation date Nov 2014

3059952v6 4906-17-02 7 NORTHWEST OHIO WIND ENERGY, LLC 4906-17-03 Project Description and Schedule

(A)PROPOSED FACILITY DESCRIPTION

Applicant is proposing to develop, construct, own, and operate a wind-powered electric generation facility, along with all associated infrastructure, including underground collection lines, access roads, step-up facility, a temporary staging and construction laydown area, a possible temporary concrete batch plant and an operation and maintenance facility. The operation and maintenance (O&M) facility may either be a new structure or an existing structure converted to that use. To the extent possible, Applicant will endeavor to use local suppliers for concrete to be used in turbine foundations. However, in case local supplies may be insufficient, Applicant has also included a temporary on-site concrete batch plant in the project plans.

The Facility will consist of up to 59 turbines, each with a nameplate capacity rating of between 1.7 and 2.0 MWs (depending on the final turbine model selected), but with a total net generating capacity not to exceed 100 MWs. To allow for flexibility in final turbine site selection (e.g., se- lecting one turbine site over another based on additional collection of site-specific wind data, and/or if a cultural resource is discovered upon excavation), Applicant seeks approval for 60 potential turbine sites.

AWS Truepower performed several studies in March and April 2013. A recently completed wind speed forecast at the various contemplated hub heights vary from 7.17 to 7.27 m/s (or 16 to 16.3 mph), and the net capacity factor for the respective turbines was found to be approximately 42.5%, generating approximately 370,000 MWh (based on 100 MWs) of electricity each year, depending on the final turbine selected. This net capacity factor is significantly higher than other adjacent and nearby wind farms and it is mainly due to the advancement in technology in the last three-four years to better suit wind regimes such as the Project area. These technological advancements are notably in tower height, blade length and mass, gear box ratios, cut-in and cut- off speeds and inertia reaction. Applicant considers the energy production supporting information to be highly proprietary and a trade secret. However, the OPSB Staff may review this information at the offices of Bricker & Eckler, LLP 100 South Third Street, Columbus, Ohio as has been the practice in other applications.

3059952v6 4906-17-03 8 NORTHWEST OHIO WIND ENERGY, LLC (1) Project Description

(a) Types of Turbines

The Facility has been designed to accommodate the following turbine models:

• Up to 59 General Electric (GE) 1.7MW turbines with 100-meter rotor diameter, 96-meter rotor hub height and 146-meter total height; or

• Up to 50 Gamesa 2.0MW turbines with 114-meter rotor diameter, 93-meter rotor hub height and 150-meter total height or

• Up to 56 Vestas 1.8MW turbines with 100-meter rotor diameter, 95-meter rotor hub height and 145-meter total height.

These turbines utilize tubular towers and are the most likely to be used due to proven track records and reliable energy output curves. Due to the very uniform wind resource and turbine operational similarities, any of the three turbine technologies listed above can be accommodated using the 60 potential turbine locations shown in Figure 3-1. Applicant’s decision on turbine selection will consider multiple factors that affect project economics. These will include, but are not limited to, equipment availability from the manufacturers, electric production, equipment reliability and warranties, turbine pricing, commercial terms and installation costs.

At least 60 days before the preconstruction conference, Applicant will file a letter with the Ohio Power Siting Board (OPSB) that identifies which of the turbine models listed in the application has been selected. Applicant expects to select the turbine by the end of 2013.

(b) Area Requirements

The turbine bases, access roads, step-up facility and other associated infrastructure will result in the cumulative conversion of up to 48.7 acres of land from its

3059952v6 4906-17-03 9 NORTHWEST OHIO WIND ENERGY, LLC current agricultural use to wind farm infrastructure (0.38% of the approximately 12,750 acres of leased land).

i. Turbine Requirements

Table 3-1 provides estimated impact parameters for various wind farm infrastructure components.

Table 3-1: Impact Assumptions for Facility Components

Area of Total Soil Dis- Area of Permanent Typical Area of Vege- Facility Components turbance (temporary Disturbance (fill & tation Clearing and permanent) structures) Turbines and Work- 0.065 acre (pedestal 200' radius per turbine 200' radius per turbine spaces plus crane pad) Normal disturbance width is 58’ and special 16' (to 34’ worst-case) 75' to 250’ wide per lin- Access Road turning radii disturbance wide per linear foot of ear foot of road is 250' wide per linear road1 foot of road Underground Electrical 60' wide per linear foot 60' wide per linear foot None Collection Cable of cable of cable O&M Facility (and as- 2.5 acres 2.5 acres 2.5 acres sociated storage yard)1 Laydown Area2 20-22acres 20-22acres none Step-up Facility 9acres 9acres 5acres Meteorological Towers 1acrepertower 5.6acrepertower3 0.2 acre per tower 1. Assumes that the O&M facility will be a new structure. If an existing structure is converted to serve as an O&M facility, this impact will be reduced or eliminated. 2: The laydown area will be approximately 20 acres in size. To ensure the worst case scenario is evaluated for impacts, a size of 22 acres has been assumed for impact calculation. 3: Total disturbance area includes area of potential vehicle traffic within fields that will not require vegetation clearing.

Approximately 988.4 acres of soil will be disturbed during construction. Much of this disturbance will be temporary, and subject to restoration activities at the end of construction.

ii. Turbine Assembly Area

3059952v6 4906-17-03 10 NORTHWEST OHIO WIND ENERGY, LLC Turbines will be assembled in the 200-foot temporary disturbance area around each turbine location.

iii. Access Roads

The Facility will require the construction or improvement of up to 16.5 miles of roads to provide access to the turbines. The location of access roads is shown on Figure 3-1. The roads will be gravel-surfaced and typically 16 feet in finished width. However, to assure a worst-case analysis and to account for side slope grading, a maximum finished width of 16 feet is assumed for purposes of impact calculation estimates, as shown in Table 3-1.

iv. Cable Disturbance Routes

60 Feet Wide, 31.4 Miles

v. Temporary Staging and Construction Laydown Areas

It is anticipated that construction will require the development of one temporary laydown yard for staging, to be located on leased private lands (see Figure 3- 1).The laydown area will accommodate material and equipment storage, and construction management trailers. The temporary laydown yard is anticipated to be approximately 20-22 acres. Parking lighting of the temporary laydown yard may be installed as needed.

vi. Operation and Maintenance Facility

An O&M facility and associated storage yards will be required to permanently house operations personnel, equipment, and materials, and to provide operations staff parking. Existing structures in the vicinity of the Facility are being considered for purchase and refurbishment for O&M activities. If new facilities are needed, they are not expected to exceed 6,000 square feet or permanently disturb an area of greater than 5 acres, and will be designed to resemble an agricultural building similar in style to those found throughout the area (see Appendix B,

3059952v6 4906-17-03 11 NORTHWEST OHIO WIND ENERGY, LLC which provides photographic examples of O&M facilities and a typical schemat- ic). Figure 3-1 depicts locations for the O&M facility.

vii. Temporary Concrete Batch Plant

Applicant is evaluating the option of including a temporary concrete batch plant for concrete production during construction. The temporary concrete batch plant will potentially be constructed on approximately 5-10 acres to provide the concrete necessary for turbine foundations. This facility would be located adjacent to the existing AEP substation. This parcel will also encompass the step-up facility and temporary construction headquarters. A temporary above ground water storage tank may also be constructed at this location to provide water to the batch plant during Facility construction. The temporary batch plant and associated infrastructure would be dissembled and removed upon completion of construction. Should a reliable local resource for concrete be identified, a temporary concrete batch plant would not be necessary.

(2) Description of Equipment

The Facility consists of up to 59 turbines. In addition to the turbines, the Facility will include approximately 16.5 miles of access roads, approximately 31.4 miles of buried 34.5 kV electrical collection cable, voltage step-up facility, one temporary laydown yard for construction staging, an O&M facility, and up to three permanent meteorological towers. Additional information about each of these components is presented below.

3059952v6 4906-17-03 12 NORTHWEST OHIO WIND ENERGY, LLC (a) Wind Energy Turbines

Applicant is evaluating three turbines: General Electric (GE) 1.7-100 1.7MW on 96-meter towers, the Gamesa G114 2.0MW on 93-meter towers, and the Vestas V100 1.8MW on 95-meter towers.

The GE 1.7-100 1.7MW turbine has proven reliability with thousands of turbines in 19 countries, with millions of operating hours. The turbine is a three-blade, upwind, horizontal-axis turbine with a 100-meter rotor diameter (7,850m2 swept area) for a total height on a 96-meter tower of 146 meters or 479 feet.

The GE 1.7-100 1.7 MW turbine has a cut-in wind speed of 3.0m/s (rate at which electricity starts being produced) and a cut-out wind speed of 23m/s (rate at which the wind turbine automatically shuts down). The turbine reaches its rated capacity at wind speeds of 8.0 m/s.

The Gamesa G114 2.0MW turbine has a proven reliability with thousands of MWs installed worldwide and millions of operating hours. The turbine is a three- blade, upwind, horizontal axis turbine with a 114-meter rotor diameter (10,207m2 swept area) for a total height on a 93-meter tower of 150 meters or 492 feet.

The Gamesa G114-2.0MW has a cut-in wind speed of 2.5m/s. The turbine reaches its rated capacity at wind speeds of 10m/s.

The Vestas V100 1.8MW turbine is a three-blade, upwind, horizontal-axis turbine with a 100-meter rotor diameter (7,850 m2 swept area) for a total height on a 95- meter tower of 145 meters, or 477 feet. Over 5,000 Vestas units of this class have been installed throughout the world since 2003.

The Vestas V100 1.8MW turbine has a cut in wind speed of 4.0m/s and a cut-out wind speed of 20m/s.

A more detailed description of the wind turbines is provided in Section 4906-17- 05 (C), Equipment.

3059952v6 4906-17-03 13 NORTHWEST OHIO WIND ENERGY, LLC (b) Electrical Collection System and Step-Up Facilities

Applicant does not anticipate constructing a substation. Each individual turbine connects to the underground collection system through its individual step-up transformer. The turbines generate power at 690 volts. The turbine-based step-up transformers convert the power to 34.5 kV. The power is then transmitted through the 34.5kV underground collection system to the main step-up facility. The main step-up facility then converts the power to 138 kV. Approximately, 31.4 miles of underground collection lines will be installed. A layout for the underground collection system is provided in Figure 3-1.

No new overhead transmission lines are proposed. The voltage step-up facility will be immediately adjacent to the point of interconnection at the existing AEP 138kV Haviland substation located within the Project area.

(d) Substations

The Facility does not require a new substation.

(e) Met Mast

Local landowners erected two 60-meter meteorological masts in the Project area in May 2008. Applicant subsequently purchased three operational metrological masts from the owner of the Blue Creek wind farm. One meteorological mast was decommissioned in 2012. Four meteorological masts are operational today.

(f) SODAR

SODAR was not conducted for the development of the Facility.

(3) Description of New Transmission Lines

The Facility does not require a new transmission line.

(B) DETAILED PROJECT SCHEDULE

(1) Project Schedule

See Figure 3-2.

3059952v6 4906-17-03 14 NORTHWEST OHIO WIND ENERGY, LLC (a) Land Acquisitions and Land Rights

Applicant started signing land lease and wind easements in March 2009. To date approximately 12,750 acres have been secured in the Project area. Land control is complete. Applicant is finalizing administrative and legal steps towards a real estate title insurance policy.

(b) Wildlife Studies/Surveys

On March 19, 2013, Westwood provided the ODNR DOW with an updated shape file of the amended Project area (as described in this application) and requested updated survey recommendations. On May 15, 2013, Applicant notified the ODNR and USFWS that, as no new survey recommendations had been received; Applicant was continuing to utilize the original recommendations, dated December 12, 2009. Westwood conducted updated nest surveys for northern harriers between April and May, 2013, again finding no harrier nesting activity in the Project area. Because all turbine locations continue to be on active cropland, no breeding bird surveys were required or performed. No new bat surveys were recommended or performed. Memoranda summarizing the 2013 raptor nest survey are supplied in Appendix C.

The OSPB application preparation has been ongoing since January 2013.

(d) OPSB Application for Certificate Submittal

Applicant plans to submit the application for Certificate to the OPSB in May 2013.

(e) Issuance of the OPSB Certificate

Applicant anticipates the OPSB Certificate will be issued in the fourth quarter of 2013.

(f) Preparation of Final Design

3059952v6 4906-17-03 15 NORTHWEST OHIO WIND ENERGY, LLC The final design is expected to be completed in the third quarter of 2013. (Note: The alternative turbines under consideration are sufficiently similar that the final design can be completed prior to the final turbine selection.)

(g) Facility Construction

Wind farm construction crew mobilization is expected in April 2014.

(h) Placement of Facility in Service

Construction is expected to be completed by year end 2014.

(2) Delays

The largest timeline risk is the issuance of the OPSB Certificate. The Facility’s economic viability is contingent on the federal production tax credit (PTC) set to expire on Decem- ber 31, 2013. Applicant does not have sufficient tax liability to optimize the PTC, and will therefore seek a PTC equity investor to complement the financial obligations of the development of the Facility. Typically, PTC equity investors do not invest in projects without site permits or a clear path for obtaining site permits. Thus, a timely issuance of the OPSB Certificate is paramount for this investment and new jobs in Ohio.

The second largest timeline risk is the electric transmission network upgrades. AEP expects to complete the upgrades and provide electric backfeed in June 2014. Applicant has filed this application in the expectation the upgrades will be completed accordingly.

3059952v6 4906-17-03 16 NORTHWEST OHIO WIND ENERGY, LLC 4906-17-04 Project Area Analyses

(A)SITE SELECTION STUDY

(1) General

Given the unique nature and constraints associated with the siting and development of the Facility, Applicant requested a waiver of the requirement of a full Project area site selection study that would include all practical project sites in Paulding County. The requested waiver was approved on April 10, 2013.

(a) Description of Study Area

Local landowners and investors initially selected the site for suitability for a utility-scale wind farm and subsequently confirmed through studies of the wind resource and geographic constraints. The Facility boundary was established on results of these studies and the distribution of available land. The following sub- sections discuss the factors that led to the selection of the site.

(b) Maps of Evaluated Sites

Not applicable. See map of Facility’s site in Figure 3-1.

i. High Quality Wind Resource

According to the Ohio 80m Wind Resource Map from the U.S. Department of Energy (DOE) and the National Renewable Energy Laboratory (NREL) (http://www.windpoweringamerica.gov/wind_maps.asp), the average yearly wind speed in the Project area is 6.5 to 7.5 m/s. According to DOE, areas with annual average wind speeds of 6.5m/s and greater at an 80m height are generally considered to have a wind resource suitable for wind development. Utility-scale, land- based turbines are typically installed between 80 and 100-m high. In 2010 NREL reviewed the 80m height map estimates for a subset of states and showed that for most regions of the U.S. the wind resource estimates were well within 10 percent,

3059952v6 4906-17-04 17 NORTHWEST OHIO WIND ENERGY, LLC which confirms that these wind resource maps are a valuable tool for wind energy prospecting.

Local landowners confirmed the quality of the wind resource when they independently erected two 60-meter meteorological masts in May 2008. Those landowners then asked National Wind to assess the site’s suitability for a utility-scale wind project. National Wind performed or commissioned several wind resource analyses and energy production estimates since project inception and throughout the development phase. The goals of these studies have been to: (1) build a long- term and high-confidence wind and energy regime; and (2) gauge the best-suited turbine for that regime. AWS Truepower performed several studies in March and April 2013. A recently completed wind speed forecast at the various contemplated hub heights vary from 7.17 to 7.27 m/s (or 16 to 16.3 mph), and the net capacity factor for the respective turbines was found to be approximately 42.5%. These figures are very robust for this region of the country and support a third viable wind farm in Paulding County. This net capacity factor is significantly higher than other adjacent and nearby wind farms and it is mainly due to the advancement in technology in the last three-four years to better suit wind regimes such as the Project area. These technological advancements are notably in tower height, blade length and mass, gear box ratios, cut-in and cut-off speeds and inertia reaction. Applicant considers the energy production supporting information to be highly proprietary and a trade secret. However, the OPSB Staff may review this information at the offices of Bricker & Eckler, LLP 100 South Third Street, Co- lumbus, Ohio as has been the practice in other applications.

ii. Suitable Transmission

A large scale wind farm must be located within a reasonable distance to an interconnection point on a transmission line with sufficient capacity to allow for the economical delivery of power to customers on the transmission grid. The AEP 138kV line and 138kV Haviland substation are already located in the Project area. AEP is a member of the PJM system operator. AEP and PJM performed several interconnection and transmission studies for the Facility, and refer to it as number

3059952v6 4906-17-04 18 NORTHWEST OHIO WIND ENERGY, LLC V1-011. This desired transmission system supports the Facility after some system upgrades. AEP and PJM will make available their studies and projected upgrade costs by June 2013. Applicant, AEP and PJM expect to execute the Facilities Construction Agreement and the Interconnection Service Agreement in Septem- ber 2013, and AEP expects to be able to install all upgrades and provide backfeed power in June 2014.

iii. Available Land and Land Use

The Facility will be located within an approximately 21,000-acre Project area surrounded by the communities of Haviland, Scott, Grover Hill, Broughton, Latty, and Payne in Blue Creek and Latty Townships in Paulding County. The Project area is predominately flat, 95% tilled agricultural with little vegetative cover, few wetlands or forested areas, and has a minimal threat of impacting avian, bat and endangered species populations. Land lease and wind easements have been signed with approximately 274 landowners/signatures representing approximately 12,750 acres of land. A substantial percentage of the leased land is suitable for siting, though some acreage is not suitable due to setback requirements or environmental constraints. The Facility layout incorporates the various setbacks discussed in Section 4906-17-08 (C)(1)(c) to ensure it complies with OPSB requirements and minimizes the potential for impacts on residents within and proximal to the Pro- ject area.

iv. Environmental or Ecological Considerations

Since December 2008, Westwood performed multiple Geographic Constraint Analyses to confirm the Facility has no “fatal flaws” and identify constraints that would affect design. These analyses include geographic information systems (GIS) data compiled and analyzed for the Project area along with reports explain- ing the data and site development factors that could not be fully articulated with mapping. Numerous GIS layers were analyzed using more than 20 sources of data to determine the potential for constraints. The GIS data were verified and sup- plemented by onsite field reviews of the Project area on multiple visits since

3059952v6 4906-17-04 19 NORTHWEST OHIO WIND ENERGY, LLC 2008. Field studies have been scheduled and/or completed as recommended by the ODNR DOW, USFWS, Ohio EPA and OHPO. Categories studied include, and not limited to:

• Infrastructure

• Occupied residences

• Floodplains

• Wetlands and streams

• Soils and Terrain

• Land Cover

• Public Lands

• Geographic Features

• Threatened and Endangered Species

• Historic Structures

• Archaeological Properties

The Facility was determined to have an overall low risk of affecting sensitive resources and to consist almost entirely of cultivated cropland, virtually no grasslands, wetlands, wooded areas or unaltered streams.

v. Site Accessibility

The Project area is easily accessible using the extensive existing network of public roads. Township roads are generally laid out on a one-mile grid, following section lines. State Route 114 running east to west, State Route 637 running north to south and US Highway 127 cross the Project area. Applicant expects that various segments of these roads will be utilized during construction of the Facility, some of such usage for personnel transportation, some of such usage for small and light deliveries, some of such usage for oversized and overweight deliveries. A delivery route plan will be formulated once Applicant finalizes the choice of turbine for the Facility, as different turbine manufacturers have different locations in the

3059952v6 4906-17-04 20 NORTHWEST OHIO WIND ENERGY, LLC U.S. and abroad for fabrication and assembly of turbine components. Applicant will provide the final delivery route plan and the results of any traffic studies to Staff and the Paulding County Engineer 30 days prior to the preconstruction conference. Accordingly, Applicant will pursue special hauling permits with the ODOT after the delivery route plan is formulated and approved by the Paulding County Engineer.

Applicant’s Field Representative uses the Project area roads extensively and reports the roads are in good condition. Other Applicant’s staff, vendors and consultants also use the Project area roads on a regular basis report the roads are very well maintained. OPSB Staff has visited the Project area at least twice in 2013, and to Applicant’s knowledge, OPSB Staff has not negatively commented on the overall current status of the roads in the Project area. Applicant will be required, per the “Agreement for Use, Repair, and Improvement of Roads” currently under negotiation between Applicant and the Paulding County Engineer, and prior to begin construction of the Facility, to hire an independent professional engineering firm licensed to do business in the State of Ohio to perform a comprehensive road condition report prior to Applicant transporting overweight materials through Paulding County. Test borings may be required depending on the independent engineer’s scope of work. Applicant does not expect to create new temporary roadways or bridges for construction and operation of the Facility. However, Appli- cant expects the temporary widening of a limited number of roads and intersections to accommodate the turning radii of the long trucks, especially those transporting turbine blades. Once the Facility is operational, most of the Facility’s vehicular traffic will be with small vehicles such as sedans and pickup trucks. If large turbine components such as blades and gear boxes need repair or replacement, and the public and permanent access roads are not adequate for large transportation rigs, then Facility staff will install and remove temporary roadways where necessary. The installation, removal and restoration of all temporary improvements will be managed by the “Agreement for Use, Repair, and Improve- ment of Roads” and the lease agreements with the landowners.

3059952v6 4906-17-04 21 NORTHWEST OHIO WIND ENERGY, LLC There are approximately 50 publicly-owned and -maintained waterway crossings such as bridges and culverts in the Project area. All such crossings support small vehicles. The independent engineer’s road condition report will determine which crossings are suitable for overweight loads and which, if any, must undergo a structural improvement.

The Project Area is extremely flat, lacking all undulation and relief. The vertical profile of the public roads and bridges within the Project area is nil. On the basis of the inexistent vertical profile of the public roads and bridges within the Project area, no improvement is required for the public roads and bridges.

Active rail lines pass directly to the north and to the south of the Project area and such rail lines may be part of the delivery route plan. Access roads within the Pro- ject area are being designed to avoid significant modification to the local drainage ditch and tile systems. Applicant has solicited input from participating landowners to minimize interference with drainage and farming operations in the siting and construction of access roads and underground cables. Studies have been conducted to aid in the development of a construction plan that will minimize impacts to local watercourses and transportation routes. Comparable efforts have been taken to maximize convenience for Facility staff, as well as landowners within or proximal to the Facility’s footprint. During Facility development and design, Appli- cant has coordinated with federal, state, county, and local permitting agencies to ensure that all appropriate federal, state, county, and local permits are applied for and obtained.

vi. Community Support

Local landowners joined together and started the project by determining the local wind resource through the purchase and installation of two 60-meter meteorological masts in May 2008. Throughout 2008, they worked with National Wind to perform feasibility studies and in October 2008, the landowners and National Wind formed Northwest Ohio Wind Energy, LLC, an Ohio limited liability corporation. Until January, 2012 when transferred to Trishe, Northwest Ohio Wind

3059952v6 4906-17-04 22 NORTHWEST OHIO WIND ENERGY, LLC Energy, LLC was owned in the majority by local land-owners and investors, with important participation from the LLC’s advisory board. National Wind served as the managing member and a minority owner of the project.

Throughout the development of the Facility, the advisory board has been comprised of six well-respected landowners and community leaders from each of the townships in the Project area. The board acts as a conduit for communication with the surrounding community. The board meets monthly to discuss the project’s progress in terms of community acceptance and how to best develop a viable project that meets the community’s needs. The board also meets regularly with Na- tional Wind senior personnel. In December 2011, Trishe Wind Energy Holdings, Inc. (“Trishe”) purchased all shares of National Wind LLC. In January 2012, Trishe purchased all shares of Northwest Ohio Wind Energy, LLC. In excess of 30 meetings have been held with landowners, stakeholders, the advisory board, agencies and public officials since the inception of the project. Overall, the local community and its leaders support the project with enthusiasm and have provided feedback that they look forward to another source of renewable energy being established in their community.

(d) Relevant Factors in the Site Selection Process

Please refer to (c) above.

(e) Process for Determining Sites

Please refer to (c) above.

(2) Constraint Map

Figure 4-1 is a detail map of all constraints and developable area for the Facility.

(B) SUMMARY TABLE OF EVALUATED SITES

Not applicable.

(C)OPTION TO PROVIDE THE SELECTION STUDY

Not applicable.

3059952v6 4906-17-04 23 NORTHWEST OHIO WIND ENERGY, LLC 4906-17-05 Technical Data

(A)PROJECT AREA SITE

The technical data used by Applicant in this application came from various sources as indicated throughout the application, as well as from the Paulding County engineers and GIS staff. County data, including floodplain data, are used wherever available and have been validated with County GIS staff to be the most recent available data.

(1) Geography and Topography

Figure 5-1 depicts the geography and topography of the Project area, and the surrounding area within a 5-mile radius. This mapping was developed from these United States Geo- logical Survey (USGS) 7.5 minute, 1:24,000 topographic quadrangles: Antwerp, Con- voy, Dixon, Garrett, Grabill, Hicksville, Hoagland, Latty, Maples, Mari Center, Paulding, Payne, Scott, Shenivood, St. Joe, Woodburn North, and Woodburn South. Among other information, Figure 5-1 shows the following features:

(a) Proposed Facility

(b) Major Population Centers and Geographic Boundaries

(d) Bodies of Water

(e) Topographic Contours

(f) Major Institutions/Parks/Recreational Areas

(g) Residential, Commercial Buildings and Installations

(h) Air Transportation Facilities, Existing and Proposed

(2) Aerial Photograph

Figure 5-2 depicts the location of the Facility in relation to surface features within a one- mile radius. This mapping was developed using custom 2013 aerial photographs.

3059952v6 4906-17-05 24 NORTHWEST OHIO WIND ENERGY, LLC (3) Site Mapping

Figure 5-3 shows the following features:

(a) Topographic Contours

(b) Existing Vegetative Cover

(d) Individual Structures and Installations

(e) Surface Waters

(f) Water and Gas Wells

(g) Vegetative Cover Removed

(4) Geology and Seismology

A desktop review and preliminary geotechnical exploration was conducted to gather the salient geologic, geotechnical and hydrogeological information specified in the OPSB’s current OAC rules (Chapter 4906-17) pertaining to preparation of a certificate application to site a wind-powered electric generation facility. The information summarized below was obtained from Terracon geotechnical report dated January 2, 2013included in Appendix D.

(a) Site Geology

The Project area lies entirely within the glaciated Maumee Lake Plains Region of the Huron-Erie Lake Plains Section of the Central Lowland Physiographic Prov- ince. The region is characterized as a flat-lying Ice-Age lake basin containing beach ridges, bars, dunes, deltas and clay flats. The region formerly contained the Black Swamp, which was a regional wetland extending southwest from present-day western Lake Erie through northwest Ohio into northeastern Indiana. The Black Swamp consisted of extensive swamps and marshes, with interspersed higher dry ground. Low physiographic relief (less than 5 feet) is generally present in the region, which has been slightly dissected by modern streams. Surface elevations in the Maumee Lake Plains Region range from approximately 570 to 800 feet above mean sea level (Brockman, 1998).

3059952v6 4906-17-05 25 NORTHWEST OHIO WIND ENERGY, LLC The surface topography within the Project area is the result of ice-deposited ground moraine planned by waves in glacial lakes following deposition. This process has created flat surficial topography. Surficial soils in the Project area are primarily comprised of lake deposited (e.g., lacustrine) silt or clay. Glacial till deposits are present at the surface within the extreme south-western portion of the Project area. The lacustrine deposits are generally laminated and were formed in the calm waters of glacial lakes (Pavey et al., 1999). Lacustrine deposits are a heterogeneous mixture of all sizes of soil particles inclusive of clay, silt, sand and gravel. Lacustrine deposits may also contain streaks, seams, layers or lenses of sand and gravel, which may or may not be water-bearing. The deposits have a rather uniform distribution with the depth to bedrock varying from 10 to 40 feet in the Project area. The area was passed over by both the Illinoian and Wisconsinan glaciation.

The uppermost bedrock unit within the majority of the Project area is the Salina Formation of Silurian age. The unit consists predominantly of dolomite, anhy- drite, gypsum, salt and shale (Slucher at al., 2006). The northwest portions of the Project area are underlain by the Detroit River Group of middle and lower Devo- nian age. This unit is comprised of dolomite, sandstone and shale. The bedrock topographic surface is included in Appendix D. A review of well logs in the two townships indicates bedrock is typically encountered at depths ranging from 20 to 30 feet. A generalized geologic cross-section has been prepared (see Appendix D) to illustrate the major geological features of the Project area based on publicly available information (e.g., ODNR well logs and bedrock topographic maps, etc.) pursuant to rule 4906-17-05(A)(4).

(b) Soil Suitability

Surface soils within the Project area consist mostly of Latty silty clay, Hoytville silty clay, and Paulding Clay. The soil survey information suggests the Hoytville and Latty silty clays are poorly drained, have a low-to-moderately-high capacity to transmit water (0.01 to 0.20 inches/hour), with the depth to water table being zero to 12 inches. The Paulding clay is very poorly drained has a low capacity to transmit water (0.06 to 0.2 inches/hour) with the depth to water table being 0.5

3059952v6 4906-17-05 26 NORTHWEST OHIO WIND ENERGY, LLC feet above to 1.5 feet below the ground surface. The soil surveys specify that these soils do not frequently flood; however, they frequently pond surface water runoff.

Applicant coordinated with Paulding County engineers and GIS staff to obtain current floodplain maps and data. Paulding County staff indicated that FEMA floodplain maps are the most current and that no floodways have been designated. All turbine locations except T-39 lie outside mapped floodplain boundaries. Portions of access roads to turbines T-17, T-21, T-39 and T-45 lie partially within mapped 100-year floodplains but outside of stream channels. None of these access roads will increase the 100-year flood base elevation of the adjacent stream because all such roads will be constructed at grade (i.e. flush with the existing ground surface) to avoid detaining surface water or reducing flood storage volume. Also, none of these access roads involve crossing the stream channel so there will be no conveyance structures required that might restrict flows. In five locations, underground collector cables will cross mapped floodplains but all such cables will be installed with horizontal directional drilling techniques to avoid impacts. One construction crane path between turbines T-38 and T-39 would cross the mapped 100-year floodplain along the same alignment as a cable crossing between these two turbines. A temporary culvert and fill section would be needed to cross the stream channel and construction mats would be used to minimize compaction and surface disturbance within the adjacent floodplain. The crossing location consists of crop land on both sides and no riparian vegetation would be affected. Applicant will work with the Paulding County Engineer, pursuant to the “Agreement for Use, Repair, and Improvement of Roads”, to properly size the temporary culvert and schedule the crossing to minimize the potential for impacts. The temporary culvert and associated temporary fill will be promptly removed after the crane crossing has been completed. If a separate floodplain alteration permit is required, Applicant will obtain one from the Paulding County Engineer. A section 404 permit will also be obtained from the USACE for this crossing.

3059952v6 4906-17-05 27 NORTHWEST OHIO WIND ENERGY, LLC To maintain soil stability during construction, adequate surface water run-off drainage will be established and properly controlled at each proposed construction site to minimize any increase in the moisture content of the subgrade material. Positive drainage of each construction site will be created by gently sloping the surface toward drainage swales. It should be noted that sub-grade soils are subject to shrinking and swelling due to variation in seasonal moisture contents. Consideration should be given during constructability reviews to determine best management practices for potential moisture fluctuations (Hull, 2009).

Based on experience with soils similar to those in the region, conventional, shallow foundations may be able to support the turbines and the step-up facility. However, this assumption will need to be confirmed by a detailed geotechnical exploration and evaluation for each turbine, access road and step-up facility location. If it is determined that shallow foundations are not suitable for structural support, deep foundation systems (such as driven H-piles or auger cast piles) may be necessary to bear in suitable material or on bedrock. Additionally, other suitable foundation types may be utilized according to their compatibility with the geotechnical parameters of the specified turbine-site and substation location.

Based on the information collected to date, it is anticipated there will be no atypi- cal construction concerns related to the access roads. However, this assumption will need to be confirmed by the detailed geotechnical exploration and evaluation.

Based on a review of the soil survey information and on experience with earthwork in the Project area, the soils should be suitable for grading, compaction and drainage when each turbine-site is prepared as discussed in this application. Due to the anticipated depth of bedrock, bedrock blasting will probably not be necessary; however, this assumption must be confirmed with geotechnical test borings prior to construction. On November 6, 2012, Terracon Consultants Inc. (Terra- con) completed soil borings and associated laboratory testing for a preliminary geotechnical engineering study for the Facility. The report is available in Appen- dix D.

3059952v6 4906-17-05 28 NORTHWEST OHIO WIND ENERGY, LLC For this geotechnical study, five borings were completed to depths ranging between about 20 and 33 feet below ground surface at potential turbine locations and two borings to a depth of about 3½ feet in the general locations of potential access roads. In conjunction with the test boring operations, temporary piezometers were installed at two of the potential turbine locations. A generalized summary of the Project area subsurface conditions is in Table 5-1 below.

Subsurface conditions encountered at the boring locations are indicated on the individual boring logs attached in Appendix D. Stratification boundaries indicated on the boring logs represent the approximate depths of changes in soil and rock type; in-situ, the transition between materials may be gradual.

Table 5-1: Generalized Project Area Subsurface Conditions

Stratum Description Approximate Depth to Base of Stratum (Feet)

Surface Soils 0.5 – 1.0 Lacustrine Soils (Glacial Lakebed Sediment) 16.0 – 27.0

Till Sediment 19.5 – 32.0

Bedrock Not Applicable.

Once turbine locations are confirmed, Applicant will complete a full detailed geotechnical exploration and evaluation at each turbine site to confirm there are no issues to preclude construction of the Facility. The geotechnical exploration and evaluation will include borings at each turbine location to provide subsurface soil properties, static water level, rock quality description, percent recovery, and depth and description of the bedrock contact and recommendations needed for the final design and construction of each turbine foundation, as well as the final location of the step-up facility. Applicant will fill all boreholes, and borehole abandonment will comply with state and local regulations. Applicant will provide

3059952v6 4906-17-05 29 NORTHWEST OHIO WIND ENERGY, LLC copies of all geotechnical boring logs to OPSB Staff and to the ODNR Division of Geological Survey prior to construction.

Information obtained from the ODNR, Division of Geological Survey and the Paulding County Engineer indicates there are no known or probable karst areas within the Project area. The nearest karst areas are located approximately 60 miles to the east-southeast in northwestern Wyandot County and approximately 65 miles to the southeast in north-central Logan County and south-central Shelby County.

Geologic structural and seismic information was assessed for the Project area. Structural features and earthquake epicenters within Ohio and Indiana are shown on Figure 5-3. A review of the information showed no known structural features or earthquake epicenters within the Project area. The nearest known structural feature to the Project area is the Fort Wayne Rift, located approximately 18 miles southwest of the Project area at its nearest point. Other faults and fault systems in the vicinity of the Project area include the Anna-Champaign Fault, situated about 30 miles south-southeast at its closest proximity and the Bowling Green Fault System, located nearly 33 miles east of the Project area.

Recorded seismic information does not show any known earthquakes as having originated in Paulding County. The closest earthquake was reported to have originated in north-central Mercer County, Ohio, located approximately 20 miles southeast of the Project area. The epicenter of the highest magnitude earthquake (5.4) recorded in Ohio to date occurred in 1937 in the vicinity of Anna, Ohio, located approximately 42 miles southeast of the Project area (Hansen, 2007). A review of data from the Indiana Geologic Survey did not indicate the presence of any earthquake epicenters in the vicinity of the Project area (Kirby, 2006). The region is rated with an acceleration value of 4. This refers to the minimum peak horizontal ground acceleration value as a percent of gravity.

Information obtained from the ODNR, Division of Geological Survey and phone discussions with Paulding County Engineer’s Offices indicated no information

3059952v6 4906-17-05 30 NORTHWEST OHIO WIND ENERGY, LLC available that suggests under-ground or surface mines are located within the Pro- ject area. Soil survey information provided by the U.S. Department of Agricul- ture (USDA) indicates no former gravel pits or quarries located within the Project area. Figure 5-3 indicates no known abandoned mine shafts or probable abandoned mines located within the Project area. Table 5-2 summarizes potential geologic hazards examined for the Project area and the likelihood of occurrence based on a desktop assessment.

Table 5-2: Geologic and Geotechnical Hazard Summary

Hazard Present in Project Comment Area? Flooding Yes No turbines are proposed within mapped 100-year floodplains. High groundwater Yes The Project area is prone to high groundwater due to flat topography and presence of poorly and very poorly drained hydric soils. However, the site is very extensively ditched and tiled. Slope failure/landslides No The Project area is very flat and is not conducive to slope failures or landslides. Subsidence from Pumping No The Project area contains to irrigated cropland that would rely on groundwater pumping. Agricultural drainage in the project area is accomplished by gravity using ditches and tiles and involves no pumping. Subsidence from Mining No No mining activity is known to exist within the project area. The ODNR does not have any abandoned bedrock mines mapped within Paulding County. Subsidence due to karst topog- No ODNR mapping does not indicate any raphy known or likely areas of karst topography in Paulding County. Earthquake/Seismicity Unlikely The ODNR does not list any documented earthquake epicenters in Paulding County. The nearest documented epicenter is over

3059952v6 4906-17-05 31 NORTHWEST OHIO WIND ENERGY, LLC Table 5-2: Geologic and Geotechnical Hazard Summary

Hazard Present in Project Comment Area? 20 miles to the south in Mercer County. Swelling/Shrinking soils Yes The Project area consists predominantly of clays and silty clays of glacial lake origin. Many of these soils are prone to shrinking and swelling. Corrosive soils Yes Clay soils exist throughout the project area, which are potentially corrosive to steel. Made ground No The Project area does not any significant relief associated with artificially raised grades. Collapsible soils No Collapsible soils are not known or likely to be present. Volcanic activity No No current volcanic activity exists in the region. Quick clay No Quick clay conditions are not known or likely to be present.

(5) Hydrology and Wind

The Facility is expected to have a low impact on surface and groundwater resources in the Project area. The increase in impervious surface, surface water runoff volume, surface water runoff water quality and increase in water demand are all expected to be negligible for the Facility.

(a) Water Budgets

i. Surface Water Resources

Paulding County contains approximately 163 linear miles of major streams and rivers as estimated from river basin maps, Ohio Department of Natural Resources (ODNR) Division of Water. In addition, 315 miles of county-maintained ditches and numerous miles of privately-maintained ditches are used for land drainage. According to the Ohio State University Extension (Ohio State University 1982) 3059952v6 4906-17-05 32 NORTHWEST OHIO WIND ENERGY, LLC the majority of Paulding County lies in the vast Maumee River Basin. Twenty- three percent of Paulding County drains into the Maumee River. The remaining 77 percent of the county drains into the Auglaize River before the Auglaize enters the Maumee. Major rivers in the county include the Maumee, Auglaize and the Little Auglaize. The Maumee River flows east-northeast in the northwestern part of the county. The Auglaize River is a major tributary of the Maumee River and is located in the eastern part of the county. The following streams flow into the Auglaize River in Paulding County: Six Mile Creek, Little Flat Rock Creek, Flat Rock Creek, Little Auglaize River, and Blue Creek. Major creeks flowing into the Little Auglaize River include Prairie and Dog creeks. Nearly all these streams flow in an eastern to northern direction and are fed by precipitation and runoff, and discharge from surface and subsurface drainage systems. The Facili- ty is located within the Blue Creek and Prairie Creek drainages.

The county has no major lakes of significant size. However, approximately 1,062 ponds are pre-sent in the county. Ponds are common among homeowners and they are filled by precipitation and surface runoff.

ii. Groundwater Resources

According to the ODNR Ground-Water Resource Map of Paulding County (Ohio DNR 1986) the principal aquifer in the Project area is the limestone bedrock. Yields up to 500 gallons per minute have been obtained at depths exceeding 300 feet. Farm and domestic supplies of about 10 to 15 gallons per minute are usually developed at depths of less than 90 feet. Shallower wells are often attempted to obtain sulfur-free water. Paulding County's primary ground-water source is the carbonate aquifer which is composed of limestone. The limestone aquifer found in the northern part of the county may yield as much as 90 gallons per minute at depths 25 to 64 feet beneath the glacial drift. In the northwestern corner of the county, sand and gravel aquifers are common; depth to water is usually less than 10 feet. The most northern parts of the county may have yields of 10 gallons per minute at depths of 40 to 65 feet.

3059952v6 4906-17-05 33 NORTHWEST OHIO WIND ENERGY, LLC During the drilling operations, groundwater was encountered between 23-27 feet below ground surface, respectively. Immediately following the completion of the test borings, free water was observed in some borings at depths of between 15-20 feet below ground surface, respectively.

Although no groundwater was observed in the other test holes for the short duration the borings were allowed to remain open; this does not necessarily mean the borings terminated above groundwater. Due to the low permeability of the predominantly lean clay soil formations, a relatively long period of time may be necessary for a groundwater level to develop and stabilize in a borehole in these materials.

To better establish groundwater information, temporary piezometers were installed at two of the proposed turbine locations (B-4 and B-8). The piezometers extended to a depth of about 13 feet below ground surface. The water level measurements obtained since the piezometers were installed are noted in Table 5- 3 below.

Table 5-3: Temporary Piezometer Readings

Boring Location Water Level as recorded 11/20/2012 B-4 6.5 feet below ground surface B-8 Dry to 13 feet below ground surface

Based on the groundwater observations conducted to date, it appears likely that the depth of groundwater will vary within the site but will generally be located a few feet above or below the anticipated bearing elevation of the turbine foundations.

iii. Construction Water Usage

Construction and operation of the Facility will not affect the water supply or sanitary service. No installation or abandonment of water supply wells is anticipated for the Facility. It is not anticipated the Facility will require the appropriation of 3059952v6 4906-17-05 34 NORTHWEST OHIO WIND ENERGY, LLC surface water or permanent dewatering. Temporary dewatering may be required during construction for specific turbine foundations and/or electrical trenches. Water use during construction may occur to provide dust control and water for concrete mixes and other construction purposes. Concrete will either be batched at a temporary construction site within the Project area, or more may be batched at a permanent concrete facility nearby and trucked onsite. If temporary dewatering is required during construction activities, discharge of dewatering fluid will be conducted under the requirements of the National Pollutant Discharge Elimi- nation System (NPDES) permit and Storm Water Pollution Prevention Plan (SWPPP) which will be developed for this Facility.

iv. Operation Water Usage

Water use during the operation of the Facility will be minimal. No water use is required for operation of the turbines. The only water use under normal operating conditions will be at the O&M facility, which will use groundwater from wells and generate sewage and wastewater. The usage rates will be highly variable as the building will be occupied on a part time basis. When occupied, the volumes will be comparable to a typical small business office. Wastewater will be disposed of using an on-site septic system. Applicant will obtain a permit to install on-site sewage treatment as necessary. No other Facility components will discharge measurable quantities of wastewater. Because the system includes only one facility with one source and one discharge, a flow diagram is not needed.

The US Department of Energy, Office of Energy Efficiency and Renewable En- ergy issued a report detailing the water conservation benefits of wind energy as compared to thermoelectric power. According to this report, a 100MW wind farm such as the Facility will conserve approximately 158 million gallons of water an- nually because wind-powered electric generation facilities do not use/consume water as do conventional thermal power plants such as coal (NREL 2006).

(b) Floods and High Winds

Ohio is located in the humid continental zone. This continental-type climate is characterized by frequent occurrences of continental polar air throughout the

3059952v6 4906-17-05 35 NORTHWEST OHIO WIND ENERGY, LLC year, with occasional Arctic out-breaks during winter and occasional periods of prolonged heat during the summer, especially when warm air moves in from the Gulf of Mexico and southwestern United States. Pacific Ocean air masses moving across the western United States allow for periods of mild and dry weather conditions during all seasons. While the climate within the Project area is fairly uniform due to relatively little topographic relief and lack of large water bodies, extreme weather events, such as tornadoes, high thunderstorm winds, high winds, and blizzard conditions, do occur and are discussed further in this section.

Specific, long-term climatological data does not exist for the Project area. How- ever, data from a National Weather Service climate station located approximately 25 northeast of the site near Defiance, Ohio (Station KDFI); Latitude: 41° 28' N Longitude: 84° 36' W, was used to represent meteorological conditions at the Project area. The warmest month of the year is July with an average maximum temperature of 84 degrees Fahrenheit, while the coldest month of the year is Jan- uary with an average minimum temperature of 30 degrees Fahrenheit. Tempera- ture variations between night and day tend to be moderate during summer with a difference that can reach 24 degrees Fahrenheit, and more limited during winter with an average difference of 16 degrees Fahrenheit. The annual average precipitation at Defiance is 34.90 inches. Rainfall is fairly evenly distributed throughout the year, with the wettest month being July with an average rainfall of 3.80 inches.

i. Floods

Extreme weather events in the Project area have been recorded by the National Climatic Data Center (NCDC) in the US Storm Events Database for the period of time from January 1950 through August 2012. Extreme weather events during this period include tornadoes, hail, thunderstorm winds, high wind, winter storms, blizzards, extreme cold, heavy snow, excessive heat, dense fog, floods, and flash floods (among others). The NCDC recorded extreme weather events in Paulding County during this time period included five flash floods, three floods and one urban/small stream flood events. Typically, such storms are local in ex-

3059952v6 4906-17-05 36 NORTHWEST OHIO WIND ENERGY, LLC tent, short in duration, and result in damage to relatively small geographic areas (NCDC 2012).

The Federal Emergency Management Agency (FEMA) mapping depicts floodplains along the entire portions of Blue, Prairie, Dry, Maddox and Hoaglin creeks and portions of Hagerman Creek and Dog Run within the Project area.

ii. Winds

Extreme weather events in the Project area have been recorded by the NCDC in the US Storm Events Database for the period of time from January 1950 through August 2012. Extreme weather events during this period include tornadoes, hail, thunderstorm winds, high wind, winter storms, blizzards, extreme cold, heavy snow, excessive heat, dense fog, floods, and flash floods (among others). The NCDC recorded extreme weather events in Paulding County during this time period included 94 thunderstorm wind events and ten tornados. Typically, such storms are local in extent, short in duration, and result in damage to relatively small geographic areas (NCDC 2012).

Facility will not affect the bedrock aquifer so no map is required. The regional bedrock aquifer is protected from surface activities typical during commercial wind farm construction by the low-permeability of the native glacial till soils. No foundations or construction activities will fully penetrate these glacial tills or extend to the bedrock.

(B) LAYOUT AND CONSTRUCTION

(1) Project Area Site Activities

(a) Test Borings

No additional test borings have been conducted beyond those discussed under A(4)(b) “Soil Suitability” above. Applicant received a waiver to defer additional test borings until construction. Once turbine locations are confirmed, Applicant will complete a full detailed geotechnical exploration and evaluation at each location to confirm there are no issues to preclude construction of the Facility. The 3059952v6 4906-17-05 37 NORTHWEST OHIO WIND ENERGY, LLC geotechnical exploration and evaluation will provide subsurface soil properties, static water level, rock quality description, percent recovery, and depth and description of the bedrock contact and recommendations needed for the final design and construction of each turbine foundation, as well as the final location of the step-up facility. Applicant will fill all boreholes, and borehole abandonment will comply with state and local regulations. Applicant will provide copies of all geotechnical boring logs to OPSB Staff and to the ODNR Division of Geological Survey prior to construction.

(b) Removal of Vegetation

Facility construction will be initiated by clearing (as necessary) all turbine sites, access roads, and underground electric collector routes. Prior to clearing trees, Applicant will obtain all necessary permits governing tree clearing. No tree clearing will occur between April 1 and September 30. As described in Table 3-1, it is assumed that up to a 200-foot radius will be cleared around each turbine, a corridor up to 75-foot wide may be cleared along access roads, and an up-to 60-foot- wide corridor may be cleared along all underground electric collector routes that do not parallel access roads. The actual cleared area will vary on a case-by-case basis depending on factors such as topography and vegetation, and where possible, adjusted to avoid sensitive ecological resources. In addition, approximately 5 acres will be cleared for the step-up facility and approximately 20-22 acres for the laydown yard. However, both the step-up and O&M facilities are to be located on agricultural lands, no vegetation clearing will be required. In correspondence with the ODNR DOW and USFWS, concerns were expressed about potential tree clearing near turbines locations T-17 and T-49. These locations have been reviewed in more detail and it has been determined that the disturbance areas around each turbine will be limited to agricultural land and no removal of trees will be necessary. Section 4906-17-08(B)(2)(a) of this application quantifies anticipated temporary and permanent impacts from construction activities, including vegetation removal, to ecological communities in the Project area.

Applicant will have a vegetation management plan. Prior to commencement of construction, Applicant will submit this plan to OPSB Staff for review and con-

3059952v6 4906-17-05 38 NORTHWEST OHIO WIND ENERGY, LLC firmation it complies with the applicable CECPN condition. The plan will identify all areas of proposed vegetation clearing for the Facility, specifying the extent of the clearing, and describing how such clearing work will be done so as to minimize removal of woody vegetation. The plan will also describe how trees and shrubs around structures, along access routes, at the staging area, during operation and maintenance, and in proximity to any other Facility facilities will be protected from damage. Priority will be given to protecting mature trees throughout the Pro- ject area, and all woody vegetation in wetlands and riparian areas, both during construction and during subsequent operation and maintenance of all facilities; low-growing trees and shrubs in particular will be protected wherever possible within the proposed right-of-way. The vegetation management plan will also explore various options for disposing of downed trees, brush, and other vegetation during initial clearing for the Facility, and recommend methods that minimize the movement of heavy equipment and other vehicles within the right-of-way that would otherwise be required for removing all trees and other woody debris off site.

Applicant will also have a streamside vegetation restoration plan that minimizes impacts associated with the clearing of riparian vegetation. At least 30 days prior to the commencement of clearing activities in riparian areas, Applicant will submit the plan to OPSB Staff for review and confirmation that it complies with the applicable CECPN condition.

Graded areas will be smoothed, compacted, freed from irregular surface changes, and sloped to drain. Final earth grade adjacent to equipment and buildings will be below the finished floor slab and sloped away from the building to maintain proper drainage. Slopes of embankments shall be protected against rutting and scour- ing during construction in a manner similar to that required for excavation slopes. Site grading will be compatible with the general topography and use of adjacent properties, right-of-way, setbacks, and easements.

3059952v6 4906-17-05 39 NORTHWEST OHIO WIND ENERGY, LLC In addition, a stringent soil erosion and sedimentation control plan will be developed and implemented as part of the SWPPP required by the NPDES General Permit for the Facility. To protect surface waters, wetlands, groundwater, and storm water quality, silt fence, hay bales, and temporary siltation basins will be installed and maintained throughout site development. The location of these features will be detailed on the construction drawings, approved by the Ohio EPA as part of the NPDES review, and reviewed by the contractor prior to construction. A duly qualified individual will also inspect these features throughout the period of construction to assure they are functioning properly until completion of all restoration work (final grading and seeding). Based upon field conditions, the in- spector may require additional sediment and erosion control, beyond what is depicted on the drawings. Further information on storm water drainage can be found in Section 4906-17-07(c).

(d) Access Roads

Wherever feasible, existing roads and farm drives will be upgraded for use as Fa- cility access roads in order to minimize impacts to active agricultural areas, natural communities, and wet-land/stream areas. Where an existing road or farm drive is unavailable or unsuitable, new gravel-surfaced access roads will be constructed, also in locations selected to minimize potential impacts. Road construction will involve topsoil stripping and grubbing of stumps, as necessary. Stripped topsoil will be stockpiled along the road corridor for use in site restoration. Any grubbed stumps will be removed, chipped, or buried. Following removal of topsoil, subsoil will be graded, compacted, and surfaced with gravel or crushed stone (depth to be determined on a case by case basis), and a geotextile fabric or grid will be installed beneath the road surface if necessary, to provide additional support. To the extent practicable, local sources will be used to obtain gravel and other construction materials that may be needed (e.g., sand) in support of Facility construction.

The typical finished access road will be 16 feet in width with occasional wider pull-offs to accommodate passing vehicles, and earthen shoulders on either side to accommodate crane traffic. Maximum finished road width will be 16 feet. Appro- priately sized culverts will be placed in any wetland/stream crossings in accord-

3059952v6 4906-17-05 40 NORTHWEST OHIO WIND ENERGY, LLC ance with state and federal permit requirements. In other locations, culverts may also be used to assure the roads do not impede cross drainage. Where access roads are adjacent to (or cross) wetlands, streams or drainage ditches/swales, appropriate sediment and erosion control measures will be installed.

During construction, access road installation and use could result in typical temporary disturbance of 58 feet and up to 250 feet for special turning radii, with temporary road horizontal radii of 200 feet. In agricultural areas, topsoil will be stripped and wind-rowed along the access road to prevent construction vehicles from driving over undisturbed soil and adjacent fields. Once construction is complete, temporarily disturbed areas will be restored, including removal of excess road material and rocks greater than 12 inches, and returned to their approximate pre-construction contours.

Applicant will prepare a construction and maintenance access plan based on final plans for the Facility, access roads, and types of equipment to be used. Prior to commencement of construction, Applicant will submit the plan to OPSB Staff for review and confirmation that it complies with the applicable CECPN condition. The plan will consider the location of streams, wetlands, wooded areas, and sensitive plant species, as identified by the ODNR DOW, and will explain how impacts to all sensitive resources will be avoided or minimized during construction, operation, and maintenance. The plan will provide specific details on all wetlands, streams, and/or ditches to be crossed by the Facility, including those where construction or maintenance vehicles and/or Facility components such as access roads cannot avoid crossing the waterbody. In such cases, specific discussion of the proposed crossing methodology for each wetland and stream crossing (such as culverts), and post-construction site restoration, will be included. The plan will include the measures to be used for restoring the areas around all temporary access points, and a description of any long-term stabilization required along permanent access routes. The plan will include a detailed frac-out contingency plan for stream and wetland crossings that are expected to be completed via horizontal directional drilling (HDD).

(e) Removal and Disposal of Debris 3059952v6 4906-17-05 41 NORTHWEST OHIO WIND ENERGY, LLC Construction will generate some solid waste, primarily plastic, wood, cardboard and metal packing/packaging materials, construction scrap, and general refuse. This material will be collected from turbine sites and other work areas, and disposed of in recycling bins and dumpsters located at the laydown yard. A private contractor will empty the dumpsters on an as-needed basis, and dispose of the refuse at a licensed solid waste disposal and recycling facility.

(f) Post-Construction Reclamation

Once construction is complete, temporarily disturbed areas will be restored (including removal of excess road material, de-compaction, and rock removal in agricultural areas) and returned to their approximate pre-construction contours. Ex- posed soils at restored turbine sites, and along access roads will be stabilized by seeding, mulching, and/or agricultural planting.

(2) Layout

Figure 3-1 includes:

(a) Wind-Powered Electric Generation Turbine Locations

Sixty turbine locations have been identified, up to 59 of which may be used depending in turbine selection.

(b) Transformers and Collection Lines

(d) Transmission Lines

(e) Substations

Facility will not require a new substation, but rather a voltage step-up facility.

(f) Transportation Facilities and Access Roads

(g) Security Facilities

(h) Grade Elevations

Final grade elevations will not be available until pre-construction as allowed under the terms of the waiver dated April 10, 2013.

3059952v6 4906-17-05 42 NORTHWEST OHIO WIND ENERGY, LLC (i) Other Pertinent Installations

A possible temporary concrete batch plant

O&M facility

(3) Structures

(a) Estimated Overall Dimensions

Each turbine consists of three major components: the tower, the nacelle, and the rotor. The tallest hub height under consideration for the Facility is 96 meters (315 feet), on the GE 1.7-100; the largest rotor diameter under consideration is 114 meters (374 feet) on the Gamesa G114-2.0. As shown in Section 4906-17- 03(A)(2)(a), the highest total turbine height (i.e., height at the highest blade tip position) may be 479 feet (146 meters), which is associated with the Gamesa G114-2.0 on a 93-meter tower.

The O&M facilities are not anticipated to exceed 6,000 square feet or permanently disturb an area greater than 5 acres. Existing structures within or near the Pro- ject area may be utilized to house O&M staff, equipment, and parts. New structures will be constructed if suitable existing structures cannot be located. Photos of a typical O&M facility are provided in Appendix B.

The step-up facility will be approximately 400 by 325 feet in size (approximately 3-acres), and enclosed by a chain link fence. Equipment within the step-up facility will include a step-up transformer, switches and breakers, meters and a control house.

(b) Construction Materials

All materials and construction practices will meet or exceed safe and reliable engineering and design standards. The turbines will be installed on a concrete foundation surrounded by a gravel skirt. The turbine towers are conical steel structures manufactured in multiple sections, depending on the final turbine selected. The rotor shaft is forged from heat-treated steel, and the rotor blades are manufactured from glass fiber reinforced polyester. The O&M facility, if newly constructed,

3059952v6 4906-17-05 43 NORTHWEST OHIO WIND ENERGY, LLC will consist of standard construction materials for agricultural buildings that currently exist throughout the Project area.

In accordance with FAA aeronautical studies of the Facility, the towers will be painted white to make the structure visible to aircraft (viewing against the ground), while decreasing visibility from ground vantage points.

The O&M facilities may utilize existing structures. If new structures are required, they will be designed to resemble agricultural buildings similar in style to those found throughout the Project area.

(d) Photographic Interpretation or Artist’s Pictorial Sketches

Please see Section 4906-17-08(D)(6) and Appendix S.

(e) Unusual Features

No unusual features are expected, as all Facility components are consistent with typical wind energy facilities.

(4) Plans for Construction

Prior to the commencement of construction activities that require permits or authorizations by federal or state laws and regulations, Applicant will obtain and comply with such permits or authorizations. Applicant will provide copies of permits and authorizations, including all supporting documentation, to OPSB Staff within seven days of issuance or receipt by Applicant. Applicant will provide a schedule of construction activities and acquisition of corresponding permits for each activity at the preconstruction conference.

Construction begins with construction management crew mobilization to the Project area. The crew clears and sets-up the temporary utilities and trailers housing the construction offices. The crew then starts assembling dirt work rigs and receiving the first materials for construction. The earthwork crew starts clearing access roads and improving delivery routes. With access to the turbine locations, the excavation crew starts digging the foundation holes. In sequence, the electric crew starts plowing and/or trenching the underground collecting system. Once the delivery routes are ready, reinforced bars and ply-

3059952v6 4906-17-05 44 NORTHWEST OHIO WIND ENERGY, LLC wood arrive for assembly of the foundation structures. Underground cables also arrive at this time. If needed, the concrete crew starts assembling the batch plant. The foundation and electric crews start building their facilities. In parallel, hydraulic cranes and turbine parts start to arrive, usually lower tower sections. The delivery crews unload turbine parts near specific turbine locations. With several foundation structures ready, the concrete crew starts filling the foundations under the inspection of the quality control crew. At this time other key components arrive, such as the turbine-specific transformers, the main voltage step-up transformer, nacelles, blades and telemetry equipment, and most of the dirt work rigs leave the area. After the foundation concrete is cured, the assembly crew start assembling and erecting the bottom section of the turbine towers. At this time, the assembly crew also assembles a very tall crawler crane. With several bottom and mid tower sections assembled and inspected, the assembly crew start to “walk” the crawler crane from location to location to assemble and erect the top section of the tower, the nacelle, and the rotor with the blades. The quality control crew inspects each assembled turbine and then the mechanical completion crew prepares the turbines for testing. The electric crew finishes installing and testing the turbine-specific transformers, the main step-up facility and receives backfeed electricity from the interconnection company. With electric and telemetry equipment tested and inspected, the testing and commissioning crew starts to generate electricity in quantities suitable for certification. At this point, the clean-up crew starts to restore excess construction areas and turning radii, de-compacting soils and re-seeding cultivated areas, and repairing private and public properties like drainage tiles and delivery roads. Once the management crew is satisfied with the completion of all the work, construction is deemed complete and the commercial operation date is achieved.

(5) Future Plans

At present there are no plans for additions to the site.

(C)EQUIPMENT

(1) Wind-Powered Generation Equipment

(a) Wind Energy Turbines

Applicant has not made a final determination of the turbine model. Included in Appendix E are details of the Gamesa G114-2.0MW, the GE 1.7-100 and the Ves-

3059952v6 4906-17-05 45 NORTHWEST OHIO WIND ENERGY, LLC tas 1.8 100, which represent the range of turbines anticipated for the Facility. Be- cause construction crew mobilization is scheduled to begin in 2014, market factors such as availability and cost will affect this determination and could dictate use of an alternate turbine. However, the turbine ultimately selected will be essentially equivalent to those referenced above in terms of dimensions, appearance, and electrical output. Each turbine results in an operational footprint of approximately 0.065 acre (see Table 3-1), and consists of three major components: the tower sections, the nacelle, and the rotor with blades, as depicted in Appendix E. The hub height will be a maximum of 314.9 feet (96 meters). The nacelle sits atop the tower, and the rotor hub is mounted to the front of the nacelle. The rotor diameter will be a maximum of 373.9 feet (114 meters). The total turbine height (i.e., the height at the highest blade tip position) will be a maximum of 479 feet (146 meters). Descriptions of each of the turbine components are provided below and illustrated in Appendix E.

No commercial signage or advertisements will be located on any turbine, tower, or related infrastructure. If vandalism should occur, Applicant will remove or abate the damage within 30 days of discovery or as extended by OPSB Staff for good cause shown, to preserve the aesthetics of the project. Any abatement other than the restoration to pre-vandalism condition is subject to review by OPSB Staff to ensure compliance with the applicable CECPN condition.

(b) Nacelle

The main mechanical components of the turbine are housed in the nacelle. As depicted in Appendix E, these components include the drive train, gearbox, and generator. The nacelle is housed in a steel reinforced fiberglass shell that protects internal machinery from the environment and dampens noise emissions. The housing is designed to allow for adequate ventilation to cool internal machinery. The nacelle is equipped with an external anemometer and a wind vane that signals wind speed and direction information to an electronic controller. The nacelle is mounted on a yaw ring bearing that allows it to rotate ("yaw") into the wind to maximize wind capture and energy production.

3059952v6 4906-17-05 46 NORTHWEST OHIO WIND ENERGY, LLC Attached to the top of some of the nacelles, per specifications of the Federal Avia- tion Administration (FAA), will be a single, medium intensity aviation warning light. These lights are anticipated to be flashing red strobes (L-864) that operate only at night. Minimizing lighting of the turbines (and the permanent meteorological tower) is a measure to minimize impacts to migratory birds. If the FAA requires turbine lights for aviation safety, the minimum amount of lighting specified by the FAA will be used. Unless otherwise specified by the FAA, only flashing lights will be used at night, and flashes should be of the minimum intensity and frequency allowable. The Facility’s lighting protocol will reflect the minimum amount of lighting specified by the FAA to minimize impacts to migratory birds.

A rotor assembly is mounted to the nacelle to operate upwind of the turbine. Each rotor consists of three composite blades up to 164 feet (50 meters) in length, with a maximum rotor diameter of up to 328 feet (100 meters). The rotor attaches to the drive train at the front of the nacelle. Hydraulic motors within the rotor hub feather each blade according to wind conditions, which enables the turbine to operate efficiently at varying wind speeds. The rotor can spin at varying speeds to operate more efficiently. Depending on the turbine selected, the turbines will begin generating energy at wind speeds as low as 2.5 m/s [7-8 mph], and cut out when wind speeds reach approximately 20-25 m/s (45-56 mph). Rotor speed will be in the range of 9-17 rpm.

(d) Tower

Towers used for megawatt-scale turbines are conical steel structures manufactured in multiple sections. Each tower will have an access door in the base section and internal lighting, along with an internal ladder and/or mechanical lifts to access the nacelle. The towers will be painted white in accordance with FAA regulations designed to make the structures more visible to aircraft when viewed from above, as light colors contrast sharply against the dark-colored ground. This also has the benefit of reducing visibility from ground vantage points, which are generally viewed against the background of the sky.

3059952v6 4906-17-05 47 NORTHWEST OHIO WIND ENERGY, LLC (e) Foundation

The turbines will be installed on a concrete foundation surrounded by a gravel skirt.

(f) Electrical Components

i. 34.5kV Electric Collection System

The turbine transformer will raise the voltage of electricity produced by the turbine generator of 690 V up to the 34.5kV voltage level of the collection system. From the transformer, underground cables will join the collector circuit and underground turbine communication cables to form the underground electrical collection system. All collector cables will be buried to a minimum depth of 36 inches below the surface. The location of the proposed collection system is depicted on Figure 3-1. This 34.5kV underground collection system will connect the individual turbines to the step-up facility. The total length of the buried 34.5 kV collector lines carrying electricity to the step-up facility will be approximately 31.4 miles.

ii. Step-Up Facility

The step-up facility will be located at the corner of State Route 114 and Township Road 27, adjacent to the existing AEP Energy (AEP) Haviland 138 kV substation. The step-up facility will step voltage up from 34.5 kV to 138 kV to allow connection with the existing transmission line. Major equipment will include a step-up transformer, switches, breakers, and a control house. This facility will be approximately 400 by 325 feet in size, enclosed by a chain link fence, and accessed from State Route 114 by a gravel surfaced driveway.

(2) Safety Equipment

(a) Description of All Proposed Public Safety Equipment

Potential public safety concerns associated with the Facility include: 1) movement of large construction vehicles, equipment, and materials on local, public roadways, 2) elevated equipment or materials falling, and 3) falling into excava- tions. These issues are most relevant to construction personnel who will be work-

3059952v6 4906-17-05 48 NORTHWEST OHIO WIND ENERGY, LLC ing in proximity to construction equipment and materials and exposed to construction related hazards on a daily basis. However, the risk of construction- related injury will be minimized through daily safety meetings, regular safety training, and the proper use of appropriate safety equipment. However, because construction activities will adhere to industry safety standards and will occur almost exclusively on leased private land, exposure of the general public to construction-related risks/hazard is expected to be very limited.

Turbines have the potential to present response difficulties to local emergency service providers and fire departments. While turbines contain few flammable components, the presence of electrical generating equipment does create the potential for fire or a medical emergency. Elevated working locations and the enclosed spaces in the tower interior makes response to fire or other emergency difficult, and beyond the capabilities of most local fire departments and emergency service providers.

All turbines and electrical equipment will be installed according to NFPA 70E code standards. Built-in safety systems, minimize the chance of fire occurring in turbines. However, fire at these facilities could result from lighting strike, short circuit or mechanical failure. These occurrences would be sensed by the System Control and Data Acquisition system and reported to Facility staff. The turbines would automatically shut down and Facility maintenance personnel would re- spond. Lightning protection systems are standard components of modern turbines and rely on lightning receptors and diverter strips in rotor blades to provide a path for lightning to follow to the tower grounding.

If a turbine were to catch fire, it would typically be allowed to burn itself out. Fa- cility maintenance and local safety personnel would establish and maintain a safety area surrounding the turbine to ensure that spot ground fires resulting from sparks or falling material are controlled. The circuit of the Facility with the turbine fire would be disconnected.

Emergency situations at turbine sites beyond the capabilities of local service providers will be the responsibility of Applicant. Construction and maintenance per-

3059952v6 4906-17-05 49 NORTHWEST OHIO WIND ENERGY, LLC sonnel will be trained and equipped to deal with emergency situations at the Facil- ity. It is expected that such an incident would not expose local emergency service providers or the general public to public health or safety risks. Applicant will offer local rescue workers training for emergency procedures specific to the turbine model selected for the Facility. This would provide additional trained personnel in the unlikely case of injury or other accident occurring at the Facility.

Turbines will be equipped with appropriate ice detection equipment. Systems will monitor the temperature and conditions on the detection unit. If ice starts to form on this unit, it will send a command to the turbine to shut down. Most turbines monitor wind speed to power output ratio. If ice accumulates on the blades, this ratio becomes too high and the turbine will stop itself. A more detailed discussion of the issue is provided in Section 4906-17-08(A)(4).

(b) Description of the Reliability of the Equipment

Equipment reliability is an important criterion in turbine selection. As described in Section 4906-17-03(A), suitable for this Facility include the GE 1.7-100, the Gamesa G114-2.0, and the Vestas 1.8-100. These turbines are independently certified as meeting international design standards by independent product safety certification organizations such as Gennanischer Lloyd and Underwriters Laborato- ries. These certifications require that the turbines have a design life of at least 20 years for the specified wind regime. The wind regime considers factors such as weather extremes, average wind speed, wind gusts, and turbulence intensity. In addition to stringent design standards, turbines are equipped with monitoring equipment that will shut down the turbines in the event of excessive blade vibrations or when wind speeds exceed maximum values. This equipment is regularly maintained on a preventative maintenance schedule to ensure continued operation.

Appendix F consists of safety manuals for turbines representative of those to be used at the wind farm, including the GE, Gamesa and Vestas. These manuals address safety measures specific to operations and maintenance employees, such as first aid, protection against falls, and personal protective equipment. Applicant

3059952v6 4906-17-05 50 NORTHWEST OHIO WIND ENERGY, LLC will comply with the turbine manufacturer's most current safety manual and will maintain a copy of that safety manual in the O&M facility of the Facility.

(3) Any Other Major Equipment

Applicant does not have plans for any other major equipment.

(D)REGIONAL ELECTRIC POWER SYSTEMS

(1) Interconnection Queue

(a) Name of the Queue

PJM Queue V1

(b) Web Link of the Queue

http://www.pjm.com/planning/generation-interconnection/generation-queue- active.aspx

V1-011

(d) Queue Date

February 26, 2009

(2) System Studies

(a) Feasibility Study

See Appendix G.

(b) System Impact Study

See Appendix H.

In progress. Expected in August 2013.

3059952v6 4906-17-05 51 NORTHWEST OHIO WIND ENERGY, LLC 4906-17-06 Financial Data

(A)OWNERSHIP

Trishe Wind Energy Holdings, Inc. (“Trishe”) owns all shares of Northwest Ohio Wind Energy, LLC (the “Applicant”), and employs the services of its wholly-owned subsidiary, National Wind LLC, for the day-to-day development activities of the Facility. National Wind LLC’s team has several thousand megawatts of wind development experience in the US and abroad. Since its inception in 2007, National Wind LLC has successfully developed and sold three projects totaling 220 MWs. These transaction occurred prior to Trishe’s investment in National Wind LLC in De- cember 2011. Neither Trishe, National Wind LLC nor the Applicant have any interest in those three projects. Trishe is actively developing two other 2014 in-service date wind farm projects. These projects are a 30MW wind farm in northeast Colorado and a 40MW wind farm in central Minnesota. Trishe has four other projects in earlier stages of development in Minnesota and Io- wa.

Applicant is a special-purpose vehicle company with the sole purpose to solely develop the Fa- cility. Applicant capitalization is the extent of the Facility’s tangible and intangible development assets such as lease and easement agreements with landowners, interconnection studies and queue position, meteorological masts and data, etc.

Applicant’s parent, Trishe, is a well-capitalized and private U.S. company with the backing of its own parent company, Trishe Renewable Energy Solutions Private Limited, a well-capitalized and private Indian company.

Trishe lends funds to Applicant for the day-to-day development activities of the Facility, as well as direct its subsidiary, National Wind LLC to perform day-to-day development of the Facility. Trishe will seek a blend of construction bridge loans and third-party PTC equity investment for final and largest investments in the Facility such as turbine acquisition, power off-take security deposits, electrical infrastructure upgrades, etc. Similar to home and vehicle purchases, these loans and equity investments will be collateralized by the Facility itself. Once the Facility is operational, Applicant will be a self-sufficient Ohio limited liability corporation.

3059952v6 4906-17-06 52 NORTHWEST OHIO WIND ENERGY, LLC (B) CAPITAL AND INTANGIBLE COSTS

(1) Capital and Intangible Cost Estimates

The estimated capital and intangible costs of the Facility is approximately $200,200,000.00. These costs are expected to be more than $200 million. The principal items are shown in Table 6-1 below. It assumes high costs of turbines, construction and interconnection upgrades. Applicant is negotiating those items with vendors and counter- parties.

Applicant considers this information to be highly proprietary and a trade secret. Howev- er, the OPSB Staff may review this information at the offices of Bricker & Eckler, LLP 100 South Third Street, Columbus, Ohio as has been the practice in other applications.

Table 6-1: Estimated Capital and Intangible Costs Tangible Costs Turbine Costs , including transportation and installation Civil and Electrical Design and Build Other Total Tangible Costs Intangible Costs Development and Management Insurance Consultants and Legal Total Intangible Costs Total Cost Cost per kW

As described in Section 4906-17-04, the Applicant has not proposed alternative project areas. Therefore, no cost comparison between alternatives is available.

(2) Cost Comparison

3059952v6 4906-17-06 53 NORTHWEST OHIO WIND ENERGY, LLC service date wind farm projects via special-purpose companies. These projects are a 30MW wind farm in northeast Colorado and a 40MW wind farm in central Minnesota. Different nameplates, localities, wind regimes, turbine availability and in-service dates yield different capital and intangible cost estimates. Thus, a comparison between the Fa- cility and its parent company’s other projects would yield an incomparable result.

In August 2012, the DOE’s Office of Energy Efficiency and Renewable Energy issued the “2011 Wind Technologies Market Report”.

(http://www1.eere.energy.gov/wind/pdfs/2011_wind_technologies_market_report.pdf)

In section 4 of the report, starting on page 32, the authors indicate the capacity-weighted average installed cost for wind projects from 50 to 100 MWs is approximately $2.1 million/MW (39 projects aggregating 1,404 MWs) and for projects from 100 to 200 MWs is approximately $2.2 million/MW (56 projects aggregating 4,372 MWs). Further the authors indicate the capacity-weighted average installed cost for wind projects with turbines between 1.75 and 2.5 MWs is approximately $2.1 million/MW (142 projects aggregating 9,448 MWs). And finally, the authors indicate the capacity-weighted average installed cost for wind projects in the Great Lakes region is approximately $2.1 million/MW (34 projects aggregating 3,328 MWs).

Applicant expects the Facility to cost approximately $200,200,000.00 or approximately $2.0 million/MW. The 5 to 10% variance between the DOE’s report and the Facility’s expected cost may be attributable to further stagnated to depressed cost of electricity in the PJM system since the report’s data from 2011, and/or other numerous macro- economic variables outside Applicant’s and Applicant’s parent control

(3) Tabulation of Present Worth and Annualized Capital Costs

Capital costs will include development costs, construction design and planning, equipment costs, and construction costs. The costs will be incurred within a year of start of construction. Therefore, a present worth analysis is essentially the same as the costs presented in Table 6-1.

3059952v6 4906-17-06 54 NORTHWEST OHIO WIND ENERGY, LLC (C)OPERATION AND MAINTENANCE EXPENSES

(1) Estimate of Annual Operation and Maintenance Costs

For the first two years of commercial operation, staffing is estimated to be $280,000.00 per year. The Facility will be under warranty for up to the first 5 years of operation, thus only incurring office consumables. After warranty, maintenance could be approximately $50,000.00 per turbine per year, depending on the maturity of the Facility in a given year of its life cycle and the terms of the turbine maintenance and services agreement. These figures exclude any other ongoing expenses related to environmental monitoring, property taxes, land royalties, reverse power, and insurance costs.

(2) Cost Comparison

Applicant is a special-purpose vehicle company with the sole purpose to solely develop the Facility. Applicant does not have other projects in its portfolio. Applicant’s parent company, Trishe Wind Energy Holdings, Inc. is actively developing two other 2014 in- service date wind farm projects via special-purpose companies. These projects are a 30MW wind farm in northeast Colorado and a 40MW wind farm in central Minnesota. Different nameplates, localities, wind regimes, turbine availability and in-service dates yield different capital and intangible cost estimates. Thus, a comparison between the Fa- cility and its parent company’s other projects would yield an incomparable result.

In August 2012, the DOE’s Office of Energy Efficiency and Renewable Energy issued the “2011 Wind Technologies Market Report”.

(http://www1.eere.energy.gov/wind/pdfs/2011_wind_technologies_market_report.pdf)

In section 4 of the report, starting on page 32, the authors indicate the capacity-weighted average installed cost for wind projects from 50 to 100 MWs is approximately $2.1 million/MW (39 projects aggregating 1,404 MWs) and for projects from 100 to 200 MWs is approximately $2.2 million/MW (56 projects aggregating 4,372 MWs). Further the authors indicate the capacity-weighted average installed cost for wind projects with turbines between 1.75 and 2.5 MWs is approximately $2.1 million/MW (142 projects aggregating 9,448 MWs). And finally, the authors indicate the capacity-weighted average installed

3059952v6 4906-17-06 55 NORTHWEST OHIO WIND ENERGY, LLC cost for wind projects in the Great Lakes region is approximately $2.1 million/MW (34 projects aggregating 3,328 MWs).

(3) Present Worth and Annualized Capital Costs

Applicant is a special-purpose vehicle company with the sole purpose to solely develop the Facility. Applicant does not have other operating facilities in its portfolio. Applicant’s parent company, Trishe Wind Energy Holdings, Inc. does not have operating facilities in its portfolio.

In August 2012, the DOE’s Office of Energy Efficiency and Renewable Energy issued the “2011 Wind Technologies Market Report”. (http://www1.eere.energy.gov/wind/pdfs/2011_wind_technologies_market_report.pdf) In section 4 of the report, starting on page 37, the authors used Berkeley Lab’s compiled O&M cost data for 133 installed wind farms in the U.S., totaling 7,965 MWs of capacity, with in-service dates of 1982 through 2010. The authors then calculate an O&M cost trend for 47 wind farms with 2011 O&M data and conclude the average O&M cost per MW-hour is approximately $10.00, with recent 2008, 2009 and 2010 data varying from the mid-$20’s to approximately $4-$5 per MW-hour.

Applicant expects the Facility to be within this recent national range.

(D)DELAYS

Applicant estimates monthly delays of approximately $1.06 million for each month the Facility fails to meet its in-service date.

3059952v6 4906-17-06 56 NORTHWEST OHIO WIND ENERGY, LLC 4906-17-07 Environmental Data

(A)GENERAL

This section of the application provides environmental data regarding the quality of air, water, and solid waste as it pertains to current (preconstruction) conditions of the Project area, the potential impacts of the Facility, and the proposed mitigation measures for anticipated impacts.

(B) AIR

(1) Preconstruction

(a) Ambient Air Quality

The Ohio EPA Division of Air Pollution Control monitors the ambient air quality in the state. Each year, a summary report is published providing a comparison between the measured air concentration and the ambient air quality standards for a calendar year. The most recent summary of air quality data available for the state is the Ohio Air Quality 2011 report. Included in this report are a summary of 2011 air quality data, a discussion of toxics monitoring projects, and trend studies for selected pollutants. No air monitoring sites are located in Paulding County, or in the adjacent Ohio Counties of Defiance, Putnam, or Van Wert. Pol- lutants monitored in nearby Ohio counties include particulate matter, ozone, and sulfur dioxide in Allen County; lead in Fulton County; particulate matter in Han- cock County; and ozone in Wood County. No other violations of National Am- bient Air Quality Standards (NAAQS) were reported in the vicinity of the Project area (Ohio EPA, 2012).

Air emissions in the general area are related primarily to farm operations, vehicular travel, and manufacturing. Vehicles traveling area roads and operating farm equipment produce exhaust emissions, along with dust from unpaved road surfaces and exposed agricultural soils. In addition, routine odors are associated with certain farming practices (e.g., manure-spreading).

(b) State/Federal New Source Performance Standards

3059952v6 4906-17-07 57 NORTHWEST OHIO WIND ENERGY, LLC In accordance with Section 111 of the Clean Air Act Extension of 1970, the USEPA established New Source Performance Standards (NSPSs) to regulate emissions of air pollutants from new stationary sources. The Ohio EPA regulations do not contain any NSPS regulations for the Project area beyond those promulgated at the federal level. These standards apply to a variety of facilities including landfills, boilers, cement plants, and electric generating units fired by fossil fuels. Because wind turbines generate electricity without releasing pollutants into the atmosphere, NSPSs do not apply to the proposed Facility.

The Clean Air Act, as amended by the Clean Air Act amendments of 1990, requires the USEPA to set NAAQSs (40 CFR part 50) for pollutants considered harmful to public health and the environment. The USEPA Office of Air Quality Planning and Standards has set NAAQSs for six principal pollutants, which are called "criteria" pollutants and include carbon monoxide, lead, nitrogen dioxide, particulate matter, ozone, and sulfur dioxide. As described above, no air quality monitoring occurs in Paulding County. No violations of NAAQSs were reported in the vicinity of the Project area (Ohio EPA, 2011).

All new sources of air emissions in Ohio are required to obtain a Permit to Install (PTI) for Title V facilities, or a Permit to Install and Operate (PTIO) for non-Title V facilities. Because wind turbines generate electricity without releasing pollutants into the atmosphere, the Facility will not require a PTI or PTIO.

Administered by the USEPA, the Acid Rain Program was established by the Clean Air Act Amendments of 1990 to reduce emission of SO2 and NOx through regulatory and market based approaches. Because wind turbines generate electricity without releasing pollutants into the atmosphere, the Facility will not require an acid rain permit.

Prevention of Significant Deterioration (PSD) applies to new major sources of pollutants, and/or major modifications at existing sources for pollutants where the source is located in an area in attainment or unclassifiable with the NAAQS. The

3059952v6 4906-17-07 58 NORTHWEST OHIO WIND ENERGY, LLC Facility will not be a major source of any pollutants; therefore, PSD does not apply.

Wind energy conversion turbines generate electrical power without the release of pollutants into the atmosphere. Air pollution permits are not required for the proposed Facility.

(d) Compliance Plans

As indicated in the previous section, wind energy conversion turbines generate electricity without releasing pollutants into the atmosphere, thereby, requiring no air pollution permits. However, rules concerning fugitive dust adopted as part of the requirements of Chapter 3704, Ohio Revised Code, may be applicable. Ap- plicant will control fugitive dust through the use of several practices, as described in Section 4906-17-07(B)(2). Applicant will comply with fugitive dust rules by the use of water spray or other appropriate dust suppressant measures whenever necessary.

(2) Construction

Construction vehicles will be equipped with standard air pollution control equipment in compliance with applicable state and federal standards. Dust will be controlled by watering roads on an as needed basis. Applicant will work with local landowners and officials to assure visibility is not impaired and dust does not accumulate in or on private or public structures or facilities. No issues or concerns regarding air emissions are anticipated.

Best management practices (BMP) will be utilized and implemented to minimize the amount of dust generated by construction activities. All construction vehicles will be maintained in good working condition to minimize emissions from construction-related activities. In addition, the extent of exposed/disturbed areas on the site at any one time will be minimized and restored/stabilized as soon as possible. Water or a county- approved dust suppressant such as calcium carbonate will be used to suppress dust on unpaved roads (public roads as well as Facility access roads) as needed throughout the

3059952v6 4906-17-07 59 NORTHWEST OHIO WIND ENERGY, LLC duration of construction activities. If necessary, temporary paving (e.g., oil and stone) could be used to stabilize dusty surfaces in certain locations (e.g., the laydown yards). However, oil and stone dust suppression methods will not be applied within or immediately adjacent to sensitive areas such as streams or wetlands. Any unanticipated construction-related dust problems will be identified and immediately reported to the construction manager and contractor.

(C)WATER

(1) Pre-construction

Pre-construction activities do not affect the water supply or sanitary service. No installation or abandonment of water supply wells is anticipated.

(2) Construction

Water use during the operation of the Facility will be minimal. No water use is required for operation of the turbines. The only water use under normal operating conditions will be at the O&M facility, which will use groundwater from wells or a connection to a municipal water system and generate sewage and wastewater. The usage rates will be highly variable as the facility will be occupied on a part time basis. When occupied, the volumes will be comparable to a typical small business office. Wastewater will be disposed of using an on-site septic system. Applicant will obtain a permit to install on-site sewage treatment under as necessary. No other Facility components will discharge measurable quantities of wastewater. Because the Facility includes only one O&M facility with one source and one discharge, a flow diagram is not needed. Water conservation practices beyond typical commercial construction with low-flow lavatory fixtures are not applicable.

(a) Permits

A Section 404 permit will be required from the USACE if any wetland or waters of the U.S. are impacted by dredging or filling associated with Facility construction. Due to the linear nature of most waterbodies in the Project area, temporary impacts for crane paths and underground cables are likely. Some permanent impacts for turbine access road crossings are also possible but will be avoided to the

3059952v6 4906-17-07 60 NORTHWEST OHIO WIND ENERGY, LLC extent practicable. To ensure coverage by one or more USACE Nationwide Permits, the Facility has been designed to hold losses of waters of the United States to less than 1/2 acre for any “single and complete” project, as defined by the USACE. The Facility is also being designed not to trigger any of the Na- tionwide Permit regional conditions applicable in Ohio that would generate the need for an Individual Section 404 Permit. If losses of waters of the United States will exceed the 1/2 acre threshold, an application for an Individual Permit will be submitted to the USACE. If the permanent loss of waters of the United States will exceed 1/10th acre, Applicant will offer compensatory mitigation at a one-to-one ratio. However, every effort is being made to keep impacts under the 1/10th acre threshold to avoid the need for compensatory replacement.

The Facility has been designed to avoid impacts to isolated wetlands. According- ly, an Ohio EPA “Isolated Wetland Permit” should not be required to construct the Facility.

Because it is anticipated that the Facility will be covered by one or more USACE Nationwide Permits, individual Section 401 Water Quality Certification from the Ohio EPA should not be required. Section 401 water quality certification exemp- tions state that “no section 401 water quality certification need be obtained if: (A) The Secretary of the Army has issued a general permit pursuant to section 404(e) of the Federal Water Pollution Control Act.” If an Individual Section 404 Permit is required from the U.S. Army Corps of Engineers is required, Section 401 Wa- ter Quality Certification will be applied for from the Ohio EPA.

The Facility will obtain a NPDES permit from the Ohio EPA to control the discharge of storm water during construction activities. A SWPPP will be prepared and submitted to the Ohio EPA at the time the NPDES permit application is submitted. Appropriate BMPs will be used during construction and operation of the Facility to protect topsoil and to control soil erosion. Typical BMPs include: (1) encompassing excavated material and disturbed soil with silt fence and/or bio-rolls; (2) protecting exposed soil with temporary seed mixes or hydro-

3059952v6 4906-17-07 61 NORTHWEST OHIO WIND ENERGY, LLC mulches; (3) covering slopes with erosion control blankets and mulches, and (4) restoring disturbed areas as soon as practicable.

A water well will likely be required at the O&M facility if the facility is located where a municipal water supply is not located. If a well is required, installation and operations will follow the OAC Chapter 3701-28-Private Water Systems of the Ohio Department of Health.

(b) Aquatic Discharges

To avoid or minimize Facility-related impacts on surface waters and wetlands, preliminary and final Facility design is guided by the following criteria during the siting of wind turbines and related infrastructure:

• Turbines, laydown area, O&M facility, and the step-up facility will be sited to completely avoid wetlands and surface waters.

• The number and size of impacts from access road crossings will be minimized by routing around wetlands and streams whenever possible, and by utilizing existing crossings and narrow crossing locations to the extent practicable.

• Buried electric interconnect lines will avoid crossing wetlands whenever possible, will cross streams at existing or previously disturbed locations, and will utilize installation techniques that minimize construction-related impacts to surface waters and wetlands.

• All Facility components, including access roads and buried interconnects, will be sited to completely avoid forested wetlands.

Applicant will use BMPs when crossings of wetlands or streams are required. BMPs include, but are not limited to, the following:

3059952v6 4906-17-07 62 NORTHWEST OHIO WIND ENERGY, LLC • No Equipment Access Areas: except where crossed by permitted access roads, wetlands will be designated “No equipment Access” to prohibit the use of motorized equipment in those areas.

• Restricted Activity Areas: A buffer zone of 50 feet, referred to as a “Restricted Activity Area”, will be established wherever construction traverses or comes in proximity to wetlands and streams. Restrictions within this zone will include:

• No deposition of slash (woody debris)

• No accumulation of construction debris

• No herbicide applications

• No degradation of stream banks

• No equipment washing or refueling

• No storage of any petroleum or chemical material

Low impact wetland and stream crossing techniques will be used where feasible including but not limited to use of geotextile mats and corduroy for temporary access in wetlands, observing seasonal restrictions for streams, and installing appropriate culverts on crossing to minimize habitat loss and wildlife movement restrictions.

SWPPP: To avoid and minimize impacts to aquatic resources from construction- related siltation and sedimentation, an approved SWPPP will be implemented. Silt fencing, hay bales and other sediment and erosion control measures will be installed and maintained throughout Facility development to protect surface water, wetlands, and groundwater.

Spill Prevention, Containment, and Countermeasure (SPCC) measures will be implemented to prevent the release of hazardous substances into the environment.

3059952v6 4906-17-07 63 NORTHWEST OHIO WIND ENERGY, LLC These measures will not allow refueling of construction equipment within 100 feet of any stream or wetland, and all contractors will be required to keep materials on hand to control and contain a petroleum spill. Any spills will be reported in accordance with ODNR regulations. Contractors will be responsible for ensuring responsible action on the part of construction personnel.

Applicant will comply with any drinking water source protection plan for any part of the facility that is located within drinking water source protection areas of the local villages and cities.

No permanent discharges or changes to existing discharges are expected from the Facility. It is not anticipated the Facility will require the appropriation of surface water or permanent dewatering. Temporary dewatering may be required during construction for specific turbine foundations and/or electrical trenches. Water use during construction may occur to provide dust control and water for concrete mixes and other construction purposes. The Facility will obtain a NPDES permit from the Ohio EPA to control the discharge of storm water during construction activities. A Storm Water Pollution Prevention Plan (SWPPP) will be prepared and submitted to the Ohio EPA at the time the NPDES permit application is submitted.

For both construction and future right-of-way maintenance, Applicant will limit, to the greatest extent possible, the use of herbicides in proximity to surface waters, including wetlands along the right-of-way. Individual treatment of tall- growing woody plant species is preferred, while general, widespread use of herbicides during initial clearing or future right-of-way maintenance would only be used where no other options exist, and with prior approval from the Ohio EPA. Prior to commencement of construction, Applicant will submit a plan to OPSB Staff for review and confirmation it complies with the applicable CECPN condition, describing the planned herbicide use for all areas in or near any surface waters during initial Facility construction and/or future right-of-way maintenance.

3059952v6 4906-17-07 64 NORTHWEST OHIO WIND ENERGY, LLC A Section 404 permit will likely be required from the U.S. Army Corps of Engi- neers if the Facility impacts any wetland or waters of the U.S. Permitting would be authorized under the 2012 Nationwide Permit, Activity 51: Land-Based Re- newable Energy Projects. Any permanent impact over 1/10th acre would require wetland mitigation at a one-to-one ratio. Every effort will be made to keep impacts under 1/2 acre to avoid requiring wetland replacement. If wetland impacts exceed the 1/2-acre threshold, then wetland mitigation will be utilized to replace the impacted wetland. Wetland mitigation will either be in the form of project- specific onsite wetland replacement or through an approved wetland mitigation bank. The U.S. Army Corps of Engineers RIBITS (Regulatory in-lieu Fee and Bank Information Tracking System) website (USACE 2013) indicates there are currently 23 wetland banks in the Buffalo District Corps District in Ohio that have wetland credits available. Wetland bank credit purchase is preferable over onsite wetland creation due to the following: (1) Assuming a USACE-approved wetland bank having the appropriate acreage and type of credits exists within the bank service area encompassing the Facility, the use of wetland bank credits is the preferred wetland replacement method under the USACE’s Compensatory Mitigation Rule (see 33 CFR 332.3 (b)(2)); (2) the scale of impacts is likely to be very small and the feasibility of creating a small (less than 1 acre) site is imprac- ticable and (3) Applicant is leasing land and except for the land of the step-up facility, Applicant does not own property in the Project area where mitigation could be completed.

(d) Changes in Flow Patterns and Erosion

No permanent changes in flow patterns are expected from the Facility. Areas around turbine bases will be re-graded back to surrounding ground elevations after construction. Some temporary diversions may take place during construction. Roads will have culverts placed where required to ensure water flow matches pre-construction conditions. Access road elevations will be at existing grade wherever possible, but will be at raised elevations where ditch crossings are required.

3059952v6 4906-17-07 65 NORTHWEST OHIO WIND ENERGY, LLC Applicant will obtain a NPDES permit from the Ohio EPA to control the discharge of storm water during construction activities. A SWPPP will be prepared and submitted to the Ohio EPA at the time the NPDES permit application is submitted. Appropriate BMPs will be used during construction and operation of the Facility to protect topsoil and to control soil erosion. Typical BMPs include: (1) encompassing excavated material and disturbed soil with silt fence and/or bio-rolls; (2) protecting exposed soil with temporary seed mixes or hydro- mulches; (3) covering slopes with erosion control blankets and mulches, and (4) restoring disturbed areas as soon as practicable.

(3) Operation

(a) Quantitative Flow Diagram

Not applicable. Water use during the operation of the Facility will be minimal. No water use is required for operation of the turbines. The only water use under normal operating conditions will be at the O&M facility, which will use groundwater from wells and generate sewage and wastewater. The O&M facility will be occupied during normal business hours. When occupied, the volumes will be comparable to a typical small business office. Wastewater will be disposed of using an on-site septic system. Applicant will obtain a permit to install on-site sewage treatment under OAC Chapter 3745-42 as necessary. No other Facility components will discharge measurable quantities of wastewater. Because the system includes only one building with one source and one discharge, a flow diagram is not needed.

(b) Conservation Practices

The O&M facility will use water at a rate comparable to a typical small business office. No other Facility components will use measurable quantities of water. Therefore, water conservation practices beyond typical commercial construction with low-flow lavatory fixtures are not applicable.

The US Department of Energy, Office of Energy Efficiency and Renewable En- ergy issued a report detailing the water conservation benefits of wind energy as

3059952v6 4906-17-07 66 NORTHWEST OHIO WIND ENERGY, LLC compared to thermoelectric power. According to this report, a 100MW wind farm such as the Facility will conserve approximately 158 million gallons of water an- nually because wind-powered electric generation facilities do not use/consume water as do conventional thermal power plants such as coal (NREL, 2006).

(D)SOLID WASTE

(1) Preconstruction

Applicant is not aware of any debris or solid waste deposits within the Project area that would require removal in support of the preconstruction development of the Facility. If any such debris or solid waste is generated during the construction or operation of the Fa- cility it will be secured and removed from the Project area and disposed of at a licensed disposal facility.

(2) Construction

(a) Debris and Solid Waste Generated

It is anticipated that a limited amount of debris and solid waste will be generated during the construction of the Facility. The majority of the produced solid waste will result from construction activities and consist of plastic, wood, cardboard, and metal packing/packaging materials, construction debris, and general refuse.

(b) Storage and Disposal Methods

Debris and solid waste generated during construction will be collected from construction sites and secured in recycling bins and dumpsters located within the Project area. It is anticipated that a private contractor will serve to remove the collected debris and solid waste from the Project area on a regular or as needed basis. The contractor will dispose of the collected debris and solid waste at a licensed recycling and disposal facility.

Applicant will not dispose of gravel or any other construction material during or following construction of the facility by spreading such material on agricultural land. All construction debris and all contaminated soil will be promptly removed and properly disposed of in accordance with Ohio EPA regulations. Applicant

3059952v6 4906-17-07 67 NORTHWEST OHIO WIND ENERGY, LLC will have an OPSB Staff-approved environmental specialist on site during construction activities that may affect sensitive areas, as mutually agreed upon between Applicant and OPSB Staff, and as shown on Applicant's final approved construction plan. Sensitive areas include but are not limited to areas of vegetation clearing, designated wetlands and streams, and locations of threatened or endangered species or their identified habitat. The environmental specialist will be familiar with water quality protection issues and potential threatened or endangered species of plants and animals that may be encountered during project construction.

(3) Operations

(a) Solid Wastes Generated

During operation it is anticipated the Facility would generate only small, even negligible, quantities of debris or solid waste. The majority of the solid waste generation would be from the O&M facility, and would be the type and quantity similar to that generated by a small business office. O&M staff members would monitor generation of solid waste and coordinate the waste removal, recycling and disposal with local waste recycling and disposal services, as necessary.

In addition, some used oils/lubricants from the turbines will be generated along with packaging for replacement parts. Applicant will recycle or dispose of these wastes at a licensed solid waste recycling and disposal facility.

(b) Treatment, Transport, and Disposal

3059952v6 4906-17-07 68 NORTHWEST OHIO WIND ENERGY, LLC Waste generated during Facility operation will be recycled or disposed at local solid waste disposal services. No storage, treatment, transportation, and disposal of hazardous wastes will occur.

(4) Licenses and Permits

It is not anticipated that permits for the removal and/or disposal of solid waste will be required.

3059952v6 4906-17-07 69 NORTHWEST OHIO WIND ENERGY, LLC 4906-17-08 Social and Ecological Data

(A)HEALTH AND SAFETY

(1) Demographic Characteristics

The Facility is located in rural Paulding County, approximately eight miles east of the Indiana state line. It is expected that economic activity created by the Facility will reach beyond Paulding County into neighboring counties and nearby communities. For the purpose of evaluating socioeconomic aspects of the area, the Ohio counties of Paulding, Defiance, Putnam, and Van Wert were included as well as Indiana counties of Allen and Adams. Table 8-1 summarizes selected population statistics of Paulding and adjacent counties. It is worth noting that ten-year population projections were not available. Ac- cording to ProximityOne (www.proximityone.com), the populations of Paulding County is expected to decrease approximately 4.99% from 2010 and 2020, of Defiance County is expected to decrease approximately 1.07%, of Putnam County is expected to decrease 2.32%, of Van Wert County is expected to decrease approximately 7.24%, of Allen County is expected to increase approximately 6.99%, and of Adams County is expected to increase approximately 5.63%. Applicant used these estimates to project a ten-year population estimate.

Table 8-1: Summary Population Statistics – Counties

2000-2010 2023 2010 Population 2010 Housing Average 2010 2000 County Percent Population Density Unit Density Household Population Population Change Estimate (per sq. mi.) (per sq. mi.) Size

Paulding, OH 19,614 20,293 -3.34% 18,635 47.1 20.9 2.51

Defiance, OH 39,037 39,500 -1.17% 38,619 94.9 40.4 2.51

Putnam, OH 34,499 34,726 -0.65% 33,699 71.5 28.4 2.66

Van Wert, OH 38,744 29,659 30.63% 35.939 70.3 30.7 2.48

3059952v6 4906-17-05 70 NORTHWEST OHIO WIND ENERGY, LLC Allen, IN 355,329 331,849 7.07% 380,166 538.4 230.6 2.53

Adams, IN 34,387 33,625 2.26% 36,323 101.1 38.3 2.83

There are eight communities and 11 townships within five miles of the Project area. Population statistics for those areas are summarized in Table 8-2. There is one city, Haviland, which is located within the defined Project area boundary.

Table 8-2: Summary Population Statistics –Communities and Townships

2010 Census 2010 Census 2000 2010 2023 Average Population Population Housing Census- Census- Population Household Change Density (per Unit Density Population Population Estimate Size sq. mi.) (per sq. mi.) Communities Paulding 3,595 3,605 +10 3,425 1,527.5 728 2.35 Latty 200 193 -7 183 714.8 296.3 2.76 Broughton 166 120 -46 114 545.5 240.9 2.45 Melrose 322 275 -47 261 319.8 132.6 2.7 Grover 412 402 -10 382 1435.7 653.6 2.53 Hill Haviland 180 215 +35 204 551.3 225.6 2.72 Scott 322 286 -36 265 353.1 155.69 2.58 Payne 1,166 1,194 +28 1,134 1755.9 814.7 2.36 Townships Blue 804 781 -23 742 21.6 8.6 2.84 Creek Latty 1,026 1,017 -9 966 27.9 11.2 2.77 Paulding 4,008 4,022 +14 3,821 111.4 51.8 2.42 Jackson 939 934 -5 912 36.2 13.4 2.83 (Putnam) Washing- 1,521 1,617 +96 1,536 45.3 17.8 2.7 ton Jackson 1,886 1,795 -91 1,705 48.8 21.4 2.51 (Paulding) Hoaglin 605 662 -57 629 20.6 8.3 2.66 Union 2,557 3,052 +495 2,831 100.4 37.4 2.73 Tully 2,119 2,054 -65 1,905 56.7 23.3 2.63 Benton 1,035 1,046 +11 994 28.7 11.7 2.59 Harrison 1,566 1,459 -107 1,386 40.3 18.4 2.41

3059952v6 4906-17-05 71 NORTHWEST OHIO WIND ENERGY, LLC (2) Noise

Noise is commonly used to describe unwanted sound. Sound is an audible variation of air pressure, and can vary in both intensity and frequency. The intensity of a sound wave is measured on a logarithmic scale in units called decibels [dB]. Each 10 dB increase is a doubling of the intensity. Because people are more sensitive to sounds of certain fre- quencies, the A-weighted [dB(A)] scale is used to discuss sound impacts on humans. The dB(A) scale gives more weight to sounds within the normal human hearing range and less weight to sounds that are at the upper and lower range of audible frequency. Table 8-3 shows sound levels associated with some common sources and/or locations:

Table 8-3: Common Sound Sources and Sound Levels

Sound in dB(A) Source 140 Jet Engine (at 80 feet) 130 Jet Aircraft (at 330 feet) 120 Rock and Roll Concert 110 Pneumatic Chipper 100 Jointer/Planer 90 Chainsaw 80 Heavy Truck Traffic 70 Business Office 60 Conversational Speech 50 Library 40 Bedroom 30 Secluded Woods 20 Whisper

Typical ambient night time sound levels for windy rural areas are in the low-to-mid 30 dB(A) range. Ambient levels up to 60 dB(A) may exist near roads, farmsteads and other areas of human activity during normal daytime work hours (USEPA 1974). The windy conditions in the Project area will tend to increase the natural ambient sound levels and mask other sound sources.

Paulding County is a rural agricultural area. Although sound levels may be sporadically elevated in localized areas due to roadway noise, periods of human activity, or farming 3059952v6 4906-17-05 72 NORTHWEST OHIO WIND ENERGY, LLC operations, overall existing ambient sound levels are expected to be relatively low. Background sound levels vary both spatially and temporally, depending on proximity to area sound sources, roadways, and natural sounds. Principal contributors to the existing acoustic environment likely include motor vehicle traffic, mobile farming equipment, farming activities such as plowing and irrigation, all-terrain vehicles, local roadways, periodic aircraft fly-overs and rail movements, and natural sounds such as birds, insects, and leaf or vegetation rustle during elevated wind conditions in areas with established trees or established crops. Diurnal effects result in sound levels that are typically quieter during the night than during the daytime, except during periods when evening and nighttime insect noise dominates in warmer seasons.

In areas with elevated background sound levels, sound may be obscured through a mech- anism referred to as acoustic masking. For example, crickets chirping, farming activities, and wind-generated ambient noise as airflow interacts with foliage can contribute to this masking effect. The variation of background noise with wind speed is dependent on several site-specific factors including topographic shielding, and locations of established woodlots and open areas. There are also seasonal differences in background sound levels. The loss of leaf cover during fall decreases background sound masking effects. Also, during wintertime windows are typically closed de-creasing the transmission of sound.

Westwood reviewed regulations at the federal, state, and county level. There are no regulations with numerically defined decibel limits directly applicable to the Facility. While federal laws do not specifically limit sound from wind energy facilities, the USEPA published noise guidelines in their landmark 1974 report on the effects of environmental noise. The USEPA criteria are guidelines and are not used as a basis for regulatory compliance in the state of Ohio, but may be useful guidelines to determine the likelihood of adverse community noise impacts. These guidelines were implemented for the Facility as a voluntary acoustic design goal to assist in identification of potential adverse noise impacts. The USEPA guideline criteria are absolute and independent of the existing acoustic environment.

3059952v6 4906-17-05 73 NORTHWEST OHIO WIND ENERGY, LLC A summary of the acoustic criteria used to assess sound levels at existing noise sensitive areas (NSAs) during Facility operation is provided below:

• OSHA regulatory limits for worker and public safety exposure to high noise levels, • USEPA 70 dBA Leq(24) at publicly accessible property lines or extents of work areas where extended public exposure is possible, • USEPA 55 dBA Leq(24) in outdoor areas where limited time is spent, and • 55 dBA Ldn(24) [48.6 dBA Leq] outdoors at all NSAs where extended periods of time are spent outdoors, i.e., yards around residential structures.

Compliance with USEPA guidelines will likely result in reduced instances of annoyance and noise complaints. However, the noise criteria identified cannot be used to infer audi- bility thresholds. Inaudibility under all operating conditions is an unrealistic expectation, and one that is not required of any industrial, commercial, or agricultural activity in the state of Ohio (Tetra Tech, 2010).

(a) Construction Noise Levels

Noise from construction activities will likely cause a temporary impact to some of the homes in proximity to the Project area. These construction sounds can vary significantly depending on the age and condition of equipment and the particular stage of construction and equipment necessary to that particular stage. The expected noise levels at the nearest property boundary will be variable and are expected to be within the ranges found in Table 8-4.

(i) Dynamiting activities

Applicant will not use blasting during Facility construction.

(ii) Operation of earthmoving equipment

Site clearing: This first phase typically includes establishing temporary site offices, storage areas, and construction staging areas as well as the installation of erosion and sedimentation control measures.

3059952v6 4906-17-05 74 NORTHWEST OHIO WIND ENERGY, LLC Excavation: This phase typically includes the construction and preparation of access roads, laydown yards, and excavation for turbine foundations.

Foundation work: This phase consists of the construction of the concrete turbine foundations and the network of collection lines.

(iii)Driving of piles

Applicant will not use driving of piles during Facility construction.

(iv)Erection of structures

Turbine installation: The final phase includes the delivery and erection of the turbines. The primary equipment utilized during this phase includes flat-bed semis transporting the materials to the turbine site via access roads and the track-mounted erection crane.

(v) Truck traffic

Over-the-road transport trucks will deliver the majority of equipment and components to the site. The majority of such materials will be delivered directly to the turbine site for off-loading and installation. Some materials will be delivered to the lay-down yard for staging until required for a particular state of construction.

The transportation of personnel is likely to impact local traffic at the beginning and end of construction shifts. The transportation is light equipment is unlikely to impact local traffic, as those small trucks will easily blend with the already-present transportation of farming materials. The transportation of heavy equipment is likely to momentarily impact local traffic, especially at intersection where long rigs must make special ma- neuvers to turn. All drivers will be required to obey all traffic codes. Local road closings and/or detours will be managed via the “Agreement for Use, Repair, and Improvement of Roads” currently under negotiation between Applicant and the Paulding County Engineer.

3059952v6 4906-17-05 75 NORTHWEST OHIO WIND ENERGY, LLC (vi)Equipment installation

The typical pieces of equipment used during construction and their average near (50 feet) noise levels are summarized in Table 8-4.

Table 8-4. Noise Emission Levels Typical of Construction Equipment Estimated Sound Level at Estimated Sound Level at Equipment 50 feet (dBA) 2000 feet (dBA) Backhoe 80 48 Grader 85 53 Crane 85 53 Loader 85 53 Roller 75 50 Bulldozer 85 51-56 Truck 88 52 Compressor 80 48 Concrete Pump 77 45 Source: Federal Transit Administration, 1995, USDOT, 2006

(b) Operational Noise Levels

Applicant performed sound impact analysis for all preliminary turbine layouts using sound data supplied by the turbine manufacturers, collected wind data, site topography and adjacent operational wind farms. Local obstacles such as trees and buildings may further attenuate sound and lessen impact, but were not included in the model. Sound modeling was done using the ISO-9613-2 general method for calculating the attenuation of sound outdoors. Modeling used the sound power for each turbine that corresponds to the maximum sound power for that turbine (6 m/s for the Gamesa G114, 7 m/s for the GE 1.7-100, and 11 m/s for the Vestas V100-1.8), along with downwind sound propagation conditions from each source. A ground absorption factor of G = 0.5 was used. The ground absorption factor indicates the acoustical reflectiveness of the ground. Soft, porous ground (G = 1), such as foliage, absorbs sound while hard non-porous ground (G = 0), such as pavement or water, reflects sound. G = 0.5 indicates mixed ground.

3059952v6 4906-17-05 76 NORTHWEST OHIO WIND ENERGY, LLC Operational locations and turbine information from the adjacent Blue Creek and Timber Road wind farms were specifically included in the model. The modeled maximum L50 sound level at any receptor within the Project area for a single turbine using the above assumptions is shown in Table 8-5:

Table 8-5: Cumulative Modeled Maximum Sound Lev- els: Turbine Sound [dB(A)]

Turbine Model dB(A) GE 1.7-100 1.7MW turbine 48 Gamesa G114-2.0MW turbine 48 Vestas V100-1.8MW turbine 48

The results of the cumulative sound impact analysis indicate the sound impact for the turbine layouts is lower than 50 dB(A). A 50 dB(A) sound level is less than is typically encountered in conversational speech or in a library setting. Infor- mation in Appendix I show 40, 45, and 50 dB(A) cumulative sound lines for the turbine layout.

During operation of the Facility, the primary source of sound from the step-up facility will be the transformer, which can emit a low frequency humming sound. An Option Agreement for purchase of up to 25 acres for the step-up facility has been executed between Applicant and the parcel landowner. The final location of the step-up facility within that parcel has not been finalized and is contingent upon further civil design work, collector line routing, and coordination with the transmission owner in locating the interconnection facilities.

The nearest occupied home to locations being considered for the step-up facility within the parcel is located more than 750 feet away and sound associated with normal operation of the step-up facility is not expected to be audible at this farmstead/home. (c) Location of Noise Sensitive Areas

3059952v6 4906-17-05 77 NORTHWEST OHIO WIND ENERGY, LLC Resource Systems Group, Inc. (“RSG”) performed a noise impact study for the Facility in June 2013. It’s worth noting the 2010 populations of Latty and Blue Creek townships were 1,017 and 781 respectively and that of the Village of Haviland was 215 inhabitants. The Village of Haviland, thus accounts for approximately 12% of the Project area’s population, and is approximately at the center of the Project area.

Sound level monitoring was conducted at five locations in the Project area from May 24, 2013 through May 31, 2013. One of the monitoring sites was located in the center of Haviland on a main commuter road. However, since this site was not included in the data set as the higher levels in town could be considered as not representative of the larger area around the project. As such, Monitor A is not included in the results described in the noise impact study.

Temperatures during the monitoring period temperatures ranged 41° to 86° F, and average one-minute wind speeds (5-foot height) ranged from 0 to 21 mph with gusts as high as 26 mph. Most of the periods of higher winds occurred on May 28, 29, and 30. There were some light rainy periods on May 27 (6:30 a.m. to 10:00 a.m. and 1 p.m. to 6 p.m.) and May 28 (4:30 a.m. to 6:30 a.m.).

Sound level data was collected using either ANSI/IEC Type 2 Rion NL-22 sound level meters or ANSI/IEC Type 1 Cesva SC310 sound level meters. The Rions were set to log equivalent A-weighted sound levels every one second and the Cesvas were set to log 1/3 octave band sound levels every one second. The Rions were set to record audio clips of sound events that exceeded 55 dBA and the Cesvas were connected to Roland R-05 or R-09 HR continuous mp3 sound re- corders. The microphones were mounted on 1.5 meter (5 foot) tall wooden stakes and covered with 7-inch ACO-Pacific weather resistant windscreens.

Data was summarized into 10-minute periods. All periods that contained precipitation and sustained wind speeds above 11 mph were filtered out during post- processing.

3059952v6 4906-17-05 78 NORTHWEST OHIO WIND ENERGY, LLC In summary, the monitoring results show that in all cases the nighttime sound levels are less than daytime sound levels, which is typical. Also, the soundscapes at most sites are dominated by intermittent sounds (such as car passbys and air- plane overflights) instead of constant sound sources (such as streams and distant traffic). Also, the Blue Creek Wind Farm produces 48 dBA both at day and night, whereas the Facility would generate 48 dBA during the day and 45 dBA during at night with noise reduced operations (NROs).

(d) Mitigation of Noise Emissions

Over the last decade, the wind industry has invested heavily in reducing turbine noise through improvements in turbine technology, engineering, and insulation. According to a 2006 report prepared by the Renewable Energy Research Labora- tory, sound levels emitted by turbines have decreased as technology has ad- vanced. Improvements in blade airfoil efficiency have resulted in more wind energy being converted into rotational energy, and less into acoustic energy. Vibra- tion dampening and improved mechanical design have also significantly reduced noise from mechanical sources. Furthermore, aerodynamic sound generation is very sensitive to speed at the blade tips. Modern variable speed turbines, like those proposed for the Facility, rotate at slower speeds in low winds, increasing in higher winds. This results in quieter operation in low winds when compared to older, constant speed turbines (Rogers et al., 2006). These findings are consistent with a recent Department of Energy Report (2008), which concluded, "advances in engineering and insulation ensure that modern turbines are relatively quiet; concerns about sound are primarily associated with older technology, such as the turbines of the 1980s, which were considerably louder."

Although residential sound impacts are anticipated to be minor, additional mitigation measures will include the following:

3059952v6 4906-17-05 79 NORTHWEST OHIO WIND ENERGY, LLC • Implementing best management practices for sound abatement during construction, including use of appropriate mufflers, proper vehicle maintenance, and limiting hours of construction.

• General construction activities will be limited to the hours of 7:00 a.m. to 7:00 p.m., or until dusk when sunset occurs after 7:00 p.m. Impact pile driving, hoe ram, and blasting operations, if required, will be limited to the hours between 10:00 a.m. to 5:00 p.m., Monday through Friday. Construc- tion activities that do not involve noise increases above ambient levels at sensitive receptors may be performed outside of daylight hours when necessary. Applicant will notify property owners or affected tenants within the meaning of OAC Section 4906-5-08(C)(3), of upcoming construction activities including potential for nighttime construction activities.

• Notifying landowners of certain construction sound impacts in advance, e.g., if blasting becomes necessary.

In addition, if adverse sound impacts are identified from turbine operations that exceed the USEPA acoustic guidelines, a reasonable complaint resolution procedure will be implemented to ensure any complaints regarding construction or operational sound are adequately investigated and resolved. Facility staff will formally document all noise complaints, which will then be investigated by on-site Facility staff. This will involve a review of equipment performance to determine if sound levels fall outside normal tolerances; any faulty equipment identified will be repaired.

(3) Water

The Facility is expected to have low impact on surface and groundwater resources in the Project area. The increase in impervious surface, surface water runoff volume, surface water runoff water quality and increase in water demand are all expected to be negligible for the project.

(a) Impact on Public and Private Water Supplies

3059952v6 4906-17-05 80 NORTHWEST OHIO WIND ENERGY, LLC Construction and operation of the Facility will not affect the water supply or sanitary service. No installation or abandonment of water supply wells is anticipated for the Facility. A water well may be required at the O&M facility if located away from an accessible municipal water supply. If a well is required, installation and operations will follow the Ohio Department of Health’s Rules Chapter 3701- 28, Private Water Systems. Water use will be negligible and no impact on any public or private water supply is expected from the project.

(b) Construction Water Impacts

Construction of the Facility will not affect the water supply or sanitary service. No installation or abandonment of water supply wells is anticipated for the Facili- ty. It is not anticipated the Facility will require the appropriation of surface water or permanent de-watering. Temporary dewatering may be required during construction for specific turbine foundations and/or electrical trenches. Water use during construction may occur to provide dust control and water for concrete mixes and other construction purposes. Concrete will either be batched at a temporary construction site within the Project area, or more may be batched at a permanent concrete facility nearby and trucked onsite. If temporary dewatering is required during construction activities, discharge of dewatering fluid will be conducted under the requirements of the NPDES permit and SWPPP which will be developed for this project.

Water use during operation of the Facility will be minimal. No water use is required for operation of the turbines. The only water use under normal operating conditions will be at the O&M facility, which will use either a municipal water supply or groundwater from wells and generate sewage and wastewater. The volumes will be comparable to a typical small business office. Wastewater will be disposed of using an on-site septic system. Applicant will obtain a permit to install on-site sewage treatment under OAC Chapter 3745-42 as necessary. No other Facility components will discharge measurable quantities of wastewater. Be-

3059952v6 4906-17-05 81 NORTHWEST OHIO WIND ENERGY, LLC cause the Facility includes only one O&M facility with one source and one discharge, a flow diagram is not needed.

Because of the low volume of water usage, water conservation practices beyond typical commercial construction with low-flow lavatory fixtures are not applicable. The US Department of Energy, Office of Energy Efficiency and Renewable Energy issued a report detailing the water conservation benefits of wind energy as compared to thermoelectric power. According to this report, a 100MW wind farm such as the Facility will conserve approximately 158 million gallons of water an- nually because wind-powered electric generation facilities do not use/consume water as do conventional thermal power plants such as coal (NREL, 2006).

(4) Ice Throw

Ice throw or ice shedding refers to the phenomenon when ice accumulates on the blades, and subsequently breaks free and falls to the ground. Under certain weather conditions, ice may build up on the blades and/or sensors, slowing the rotational speed, and potentially creating an imbalance in the weights of the individual blades. Such effects of ice accumulation can be sensed by the turbine's computer controls and results in the turbine being shut down automatically until the ice melts. As ice builds up on the blades of an operating turbine, it can lead to vibration, caused by both the mass of the ice and the aerodynamic imbalances. Modern turbines, included the turbines under consideration, are equipped with vibration monitors, which shut the turbine down when vibrations exceed a pre-set level (Garrad Hassan, 2007).

Field observations and studies of ice shedding indicate that most ice shedding occurs as air temperatures rise and the ice on the rotor blades begins to thaw. Therefore, the ten- dency is for ice fragments to drop off the rotors and land near the base of the turbine (Morgan et al., 1998). Although less common, ice can potentially be "thrown" when ice begins to melt and stationary turbine blades begin to rotate again (although turbines do not restart until the ice has melted and fallen straight down near the base). There has been no reported injury caused by ice being "thrown" from an operating turbine (Global Ener- gy Concepts, 2005).

3059952v6 4906-17-05 82 NORTHWEST OHIO WIND ENERGY, LLC The distance traveled by a piece of ice depends on a number of factors, including the position of the blade when the ice breaks off, the location of the ice on the blade when it breaks off, the rotational speed of the blade, the shape of the ice that is shed (e.g., spheri- cal, flat smooth), and the prevailing wind speed. The risk of ice landing at a specific location is found to drop dramatically as the distance from the turbine increases. Data gathered at existing wind farms documented ice fragments on the ground at distances of 50 to 328 feet from the base of the tower. These fragments were in the range of 0.2 to 2.2 pounds in mass (Morgan et al., 1998). The European Union Wind Energy in Cold Cli- mates research collaborative studied ice throw at operational wind farms throughout Eu- rope. The data gathered shows that ice fragments typically land within 328 feet (100 meters) of the wind turbine (Morgan et al., 1998). Ice throw observations are also available from a turbine near Kincardine, Ontario, where the operator conducted 1,000 inspections between December 1995 and March 2001. Only 13 of the 1,000 inspections noted ice fragments, which were documented on the ground at a distance up to 328 feet (100 meters) from the base of the turbine, with most found within 164 feet (50 meters) (Garrad Hassan, 2007).

The Facility's current setback distances from permanent residences and adjacent property lines should adequately protect the public from falling ice. In addition, unauthorized public access to the site will be limited. Based upon the results of studies/field observations at other wind power projects, modern turbine technological controls, the Facility's siting criteria, limited public access to the turbine sites, and the fact there has been no reported injury caused by ice being "thrown" from an operating wind turbine, it is not anticipated that the Facility will result in any measurable risks to the health or safety of the general public due to ice shedding.

(5) Blade Shear

The possibility of a blade dropping or being thrown from the nacelle is referred to as blade shear. While extremely rare, such incidents can be dangerous. To the Applicant knowledge there are no reported instances of a member of the public having been injured as a result of a blade failure.

3059952v6 4906-17-05 83 NORTHWEST OHIO WIND ENERGY, LLC The reasons for a turbine collapse or blade throw vary depending on conditions and tower type. Past occurrences of these incidents have generally been the result of design de- fects during manufacturing, poor maintenance, control system malfunction, or lightning strikes. Evidence suggests the most common cause of blade failure is human error in in- terfacing with control systems. Manufacturers have reduced that risk by limiting human adjustments that can be made in the field. Most instances of blade throw and turbine collapse were reported during the early years of the wind industry. Technological improvements and mandatory safety standards during turbine design, manufacturing, and installation have largely eliminated such occurrences. The reduction in blade failures coincides with the widespread introduction of turbine design certification and type approval. The certification bodies perform quality control audits of the blade manufacturing facilities and perform strength testing of construction materials. These audits typically involve a dynamic test that simulates the life loading and stress on the rotor blade. This approach has largely eliminated blade design as a root cause of blade failures (Garrad Hassan, 2007).

Modern utility-scale turbines are certified according to international engineering standards. These include ratings for withstanding different levels of hurricane-strength winds and other criteria (AWEA, 2009b). The engineering standards of the turbines proposed for the Facility are of the highest level and meet all applicable federal, state, and/or local codes. In the design phase, state and local laws require that licensed professional engineers review and approve the structural elements of the turbines. State of the art braking systems, pitch controls, sensors, and speed controls on turbines have greatly reduced the risk of tower collapse and blade throw. The turbines proposed for the Facility will be equipped with two fully independent braking systems that allow the rotor to be brought to a halt under all foreseeable conditions. In addition, the turbines will automatically shut down at wind speeds over the manufacturer’s threshold (i.e. 45 mph for the GE 1.7-100, 56 mph for the Gamesa G114-2.0 and 45 mph for the Vestas). As described above, the turbines will also cease operation if significant vibrations or rotor blade stress is sensed by the monitoring systems. For all of these reasons, the risk of catastrophic tower collapse or blade shear is negligible. See Section 4906-17-05(A)(5)(b) for additional information regarding structural integrity as it relates to wind speeds. 3059952v6 4906-17-05 84 NORTHWEST OHIO WIND ENERGY, LLC There is no available calculation to determine where a blade (or portion thereof) will land in the event of blade failure. However, a report by the California Wind Energy Collabo- rative (CWEC) provides a literature review of turbine blade failure. The range of blade throw is highly dependent on the release velocity, which is a function of the blade tip speed. Because the blade tip speed of turbines tends to remain constant with turbine size, turbine hub height has little effect on potential throw distance. When compared with the blade failure rates of earlier turbine models from the 1980's and 1990's, the overall blade failure rate of modern commercial turbines has declined by a factor of three. This is primarily due to the improved reliability of modern commercial wind turbines (CWEC, 2006).

Facility setbacks between turbine and permanent residences and property lines should protect the public from the already minimal risk of blade throw.

(6) Shadow Flicker

Shadow flicker from turbines can occur when moving blades pass in front of the sun, creating alternating changes in light intensity or shadows. These flickering shadows can cause an annoyance when cast on nearby residences ("receptors"). The spatial relation- ship between a turbine and a receptor, along with weather characteristics such as wind direction and sunshine probability, are key factors related to shadow flicker impacts. At distances beyond 10-rotor diameters (maximum of 1,000 meters [3,281 feet] for the Fa- cility), shadow flicker effects are essentially undetectable (BLM, 2005; BERR, 2009). This is because shadow flicker intensity diminishes as the distance between receptors and turbines increases.

There is some public concern that flickering light can have negative health effects, such as triggering seizures in people with epilepsy. According to the British Epilepsy Founda- tion (2007), approximately 5% of individuals with epilepsy have sensitivity to light. Most people with photo-sensitive epilepsy are sensitive to flickering around 16-25 Hz (flashes per second), although some people may be sensitive to rates as low as 3 Hz and as high as 60Hz. Because the maximum turbine rotor speed of 17 rpm translates to a

3059952v6 4906-17-05 85 NORTHWEST OHIO WIND ENERGY, LLC blade pass frequency of 0.28 Hz (less than one flash per second), health effects to individuals with photosensitive epilepsy are not anticipated.

Although setback distances for turbines will significantly reduce shadow flicker impacts to homes within the Project area, some impact will occur. No existing national, state, county, or local standards exist for frequency or duration of shadow flicker from wind turbines. However, international regulations, studies, and guidelines from Europe and Australia have suggested 30 hours of shadow flicker per year as the threshold of significant impact, or the point at which shadow flicker is commonly perceived as an annoyance (Dobesch & Kury, 2001; Sustainable Energy Authority Victoria, 2003). According- ly, a threshold of 30 hours of shadow flicker per year was used for this analysis.

EAPC conducted a shadow flicker analysis for the Facility, attached hereto as Exhibit P. The study evaluated each of the turbines proposed for the Facility, including GE 1.7-100, Vestas V100-1.8, and Gamesa G114-2.0. To calculate potential shadow flicker impacts, EDR (2010b) used WindPRO, a computer model based on the following data:

• Turbine coordinates

• Shadow receptor coordinates

• USGS 1:25,000 topographic mapping and USGS digital elevation model (DEM)

• Turbine specifications (height, rotor diameter, etc.)

• Joint wind speed and direction frequency distribution

• Monthly sunshine probabilities

The model calculation for the turbines includes the cumulative sum of shadow hours for all 60 turbine locations. This omnidirectional approach reports total shadow flicker results at a receptor, regardless of the presence or orientation of windows at the receptor residence (i.e., it assumes shadows from all directions can be perceived at a residence, which may or may not be true). A receptor in the model is defined as a one square meter area, one meter above ground level; the actual dimensions of the house are not taken into

3059952v6 4906-17-05 86 NORTHWEST OHIO WIND ENERGY, LLC consideration. All residences within 1,500 meters of the nearest turbine were analyzed, resulting in predicted shadow flicker effects ranging from 0 hour/year to approximately 30 hours/year, depending on the turbine. As shown in Table 8-6, depending on the turbine, 100% of residences within 1,500 meters are modeled to experience shadow flicker less than 30 hours/year.

Table 8-6: Residential Structures Realistic Shadow Flicker Distribution Within 1,500 Meter from Turbines Realistic Gamesa G114 GE 1.7-100 Vestas V100 Shadow # of # non- # of # non- # of # non- Flicker Structures participating Structures participating Structures participating (hrs/year) 0 122 120 122 120 122 120 0 to 5 44 41 51 47 52 48 5 to 10 29 26 33 29 32 28 10 to 15 27 23 26 24 28 26 15 to 20 15 14 22 20 21 19 20 to 25 19 18 12 10 11 9 25 to 30 10 8 0 0 0 0 30 plus 0 0 0 0 0 0

Note that Table 8-6 includes multiple entries for some receptors, as the amount of shadow flicker will vary depending on the turbine model constructed. The complete WindPRO output for the shadow flicker analysis is included in Appendix K, including both tabular and graphical calendars for each receptor with shadow flicker predicted to exceed 30 hours/year. These calendars provide the exact times of day and year when residences could be affected by shadow flicker.

It is important to note the shadow flicker model assumptions are conservative, and as such, the analysis is expected to over-predict the impacts. For example, model inputs do not reflect local conditions at the receptor site that could block shadow flicker, such as trees and neighboring structures. The model also assumes the receptor always has a win- 3059952v6 4906-17-05 87 NORTHWEST OHIO WIND ENERGY, LLC dow facing the direction of the sun, and the receptor is occupied at all hours when shadow flicker may occur (i.e., from sunrise and sunset). In reality, site-specific factors such as trees, buildings, and window locations could significantly reduce the actual shadow flicker experienced at a given receptor. In addition, many of the modeled shadow flicker hours are expected to be of very low intensity, due to the distance of the proposed turbines from the affected receptors. Therefore, the analysis presented herein is expected to be an inclusive and conservative prediction of the shadow flicker effects from the Facili- ty.

With respect to primary roads, the shadow flicker maps in Appendix K depict the expected shadow flicker at all areas (including roads) in the vicinity of the Facility. How- ever, the model results generated by WindPRO assume a stationary object, which remains fixed 24 hours/day, 365 days/year. Therefore, because primary road users are mobile (typically in a motorized vehicle traveling at a relatively high speed), any Facility- related shadow flicker experienced by such users would be a fraction of that experienced by a stationary object. Furthermore, most vehicle operators are already accustomed to shadow flicker while driving, since shadows cast from near-by objects (e.g., trees, roadside/overhead signage, etc.) will "flicker" across the windows of a moving vehicle.

(B) ECOLOGICAL IMPACT

(1) Project Site Information

In support of the preparation of this application, independent environmental consultants from various firms made several visits to the Project area from 2010 to date to conduct habitat, wildlife and avian surveys. The protocols for these studies based on guidelines from the ODNR for pre-construction monitoring at commercial wind energy facilities. The Project area qualifies for the minimum level of survey effort based on these guidelines, which typically includes breeding bird surveys and raptor nests surveys. However, because the Project area is 93% agricultural, breeding bird surveys are not warranted by ODNR.

Applicant has coordinated with the Farm Services Agency (FSA) regarding lands en- rolled in the any federal conservation program (e.g. CRP, CSP, WHIP, EQIP, etc.). FSA

3059952v6 4906-17-05 88 NORTHWEST OHIO WIND ENERGY, LLC can only release in-formation on conservation program enrollment with consent from the participant. Applicant has supplied all participating landowners with information release consent forms and requested executed copies be supplied. Executed consent forms are being supplied to the FSA with requests for access to participant files. If any Facility infrastructure is found to be on lands participating in one of the FSA programs, Applicant will work directly with FSA to determine whether modification or termination of applicable contracts is required and whether refunds of expended federal funds will be required. Any such contract modifications or terminations will be carried out in accordance with the provisions of the participant’s contract. To-date and to the best of Applicant’s knowledge, there are no such conservation programs in the Project are that could adversely affect the Facility. In January 2010, the Ohio Department of Natural Resources Division of Wildlife (DOW) in co-ordination with the U.S. Fish and Wildlife Service prepared survey recommendations specific to the Project area. The DOW determined the Facility required the “minimum” level of sampling effort based upon the location and land-use practices of the site. “Over 95% of this project’s land is currently in active agriculture, and thus, not suitable habitat for most species of birds or bats. The DOW has no records of protected species of raptor (hawks, falcons and eagles) nesting or bat observations within 5-miles of the project site.” Further coordination, conducted on site in late April 2010 with repre- sentatives from the wildlife agencies and Facility development team, minimized the avian survey recommendations further to include only Northern Harrier monitoring (state-listed endangered) due to lack of suitable habitat for Ohio breeding birds, especially those with federal and/or state conservation status. In a recent meeting in March 2013, the ODNR and USFWS confirmed that little has changed in the Project area with regard to wildlife and sensitive species and that survey recommendations provided in 2010 remain appropriate for the Facility.

In order to estimate the seasonal and spatial use by bats in the Project area, Tragus conducted a mist-netting survey from July 1 to July 4, 2010 and an acoustic bat monitoring survey from March 15 to November 15, 2010 (Appendix K). From April to June 2010, Westwood conducted avian surveys which focused on the Northern Harrier (Appendix L).

3059952v6 4906-17-05 89 NORTHWEST OHIO WIND ENERGY, LLC Westwood conducted additional natural resource studies in April and May, 2013 which included a raptor nest survey (Appendix C), monitoring for the Northern Harrier (Appen- dix L), and field wetland delineations (Appendix M).

(a) Mapping

Figure 5-4 shows the Project area and immediate vicinity along with mapped water resources, recreational areas, and conservation areas. This mapping was developed from 2009 USDA Farm Service Agency (FSA). As shown on the aerial photography, the Project area is predominately agricultural with few water features and woodlots. Note that managed lands such as state parks, preserves, and scenic areas are not displayed on this mapping. These features are not present within the Project area or within one-half mile of the Project area.

(b) Vegetative Survey

In May, 2013, Westwood conducted a vegetation survey within the Project area and within a quarter mile of the Project area. Prior to conducting field visits, land cover types within the Project area were mapped on recent custom aerial photography and subsequently field verified. The primary purpose of the vegetation surveys was to identify areas of potential habitat for state or federally listed species. Table 8-7 summarizes pre- and post-construction land use types within the Project area based on Ohio DNR mapping resources1 and estimated temporary and permanent impact acreages. The Facility will result in approximately 941.5 and 45.6 acres of temporary and permanent land use impacts, respectively; 98.3 and 98.1 percent of temporary and permanent impacts will affect cultivated lands, respectively.

Table 8-7: Pre- and Post-Construction Land Uses within the Project area.

LandUse Type Pre-Construction Post-Construction Land Use Impacts (Acres) Land Use

1 ODNR acreages for wetlands, forested habitats and cropland were refined based on desktop and field wetland delineation results.

3059952v6 4906-17-05 90 NORTHWEST OHIO WIND ENERGY, LLC Area Percent Area Percent (Acres) of Total Temporary Permanent (Acres) of Total CultivatedLands 19,935.0 94.69 925.00 44.80 19,890.2 94.47 Farmsteads 319.6 1.52 6.00 0.20 319.4 1.52 Upland forest 34.4 0.16 6.70 0.30 34.1 0.16 Residential 93.2 0.44 1.30 0.00 93.2 0.44 Shallow marsh wet- lands4 7.3 0.04 0.00 0.00 7.3 0.04 Excavatedponds 20.1 0.10 0.00 0.00 20.1 0.10 Forestedwetland 276.8 1.32 0.00 0.00 276.8 1.32 Channelized streams 88.7 0.42 0.56 0.00 88.7 0.42 Un-channelized streams 85.8 0.41 0.12 0.00 85.8 0.41 Excavated ditches in crop fields & alongroads 51.6 0.25 1.55 0.37 51.23 0.24 Utilities 7.1 0.03 0.30 0.00 7.1 0.03 Pasture Lands 24.8 0.11 0.00 0.00 24.8 0.11 Other 108.3 0.51 0.00 0.000 153.95 0.73 Total1 21,054.0 100.00 941.23 45.67 21,054.0 100.00 Notes: 1. Acreage values have been rounded to the nearest tenth of an acre. Resulting to- tals may vary by one tenth of an acre. 2. Locations of permanent met tower are currently uncertain and were not included in this analysis. However, the location to be selected will likely be one of the alternate turbine locations, which have been included in the figures in this table. 3. Agricultural land use types from Paulding County Land Use/Land Cover shape- file (ODNR, 1980 & 1995). 4. Wetland impact acreages derived from Table 8-8. 5. Includes acreage converted to wind farm infrastructure.

Based on land cover mapping, approximately 94.7% of the Project area currently consists of cropland and this percentage will remain almost unchanged at 94.5% after completion of the Facility. Farmsteads represent approximately 1.5% of the Project area. Water resources (wetlands, ponds, streams and ditches) collectively represent about 2.29% of the Project area. Water resource impacts are discussed in detail under Wetland Habitat below.

i. Upland Habitat

3059952v6 4906-17-05 91 NORTHWEST OHIO WIND ENERGY, LLC Based on the National Land Cover Dataset (NLCD) mapping (refined by desktop wetland mapping), agricultural areas, mostly corn and soybean fields, constitute approximately 95 percent of the Project area. Of the remaining 5 percent about 2.8 percent consists of upland areas comprised of developed areas (open space and low, medium, and high intensity), pasture, upland deciduous forest and other upland uses. Most forested areas within the project area are associated with water resources (discussed under Wetland Habitat below). Upland forest acreage, which consists mainly of windbreaks around farmsteads, is very limited and rep- resents only about 0.16 percent of the Project area. As indicated by the on-site vegetation surveys and data resources, very little upland habitat is available on the Project area that would be suitable for rare species.

ii. Wetland Habitat

Paulding County contains approximately 163 linear miles of major streams and rivers as estimated from river basin maps, ODNR Division of Water. In addition, 315 miles of county-maintained ditches and numerous miles of privately- maintained ditches are used for land drainage. According to the Ohio State Uni- versity Extension (Ohio State University 1982) the majority of Paulding County lies in the vast Maumee River Basin. Twenty-three percent of Paulding County drains into the Maumee River. The remaining 77 percent of the county drains in- to the Auglaize River before the Auglaize enters the Maumee. Major rivers in the county include the Maumee, Auglaize and the Little Auglaize. The Maumee Riv- er flows east-northeast in the northwestern part of the county. The Auglaize River is a major tributary of the Maumee River and is located in the eastern part of the county. The following streams flow into the Auglaize River in Paulding County: Six Mile Creek, Little Flat Rock Creek, Flat Rock Creek, Little Auglaize River, and Blue Creek. Major creeks flowing into the Little Auglaize River include Prai- rie and Dog creeks. Nearly all these streams flow in an eastern to northern direction and are fed by precipitation and runoff, and discharge from surface and subsurface drainage systems. The Facility is located within the Blue Creek and Prai- rie Creek drainages.

3059952v6 4906-17-05 92 NORTHWEST OHIO WIND ENERGY, LLC The county has no major lakes of significant size. However, approximately 1,062 ponds are present in the county, most of which are excavated ponds on residential property. Most natural wetlands in the Project area are located along stream corridors (Figure 5-4), though some isolated remnants of pre-existing forested wetland still exist where agricultural drainage facilities are inadequate or lacking. U.S. Fish and Wildlife Service (USFWS) National Wetlands Inventory data show 55 wetlands covering approximately 142.4 acres in the Project area. ODNR data show 75 wetlands covering 50.0 acres. Many of these mapped wetlands were depicted along existing creeks and drainages in the Project area.

Desktop wetland mapping was performed to refine the above-described ODNR and USFWS mapping and to assist in impact minimization as the Facility layout was prepared. This refined mapping indicates the Project area encompasses: (1) 4 wet meadow/shallow marsh wetlands totaling 7.3 acres; (2) 31 excavated ponds totaling 20.1 acres; (3) 47 wooded wetlands totaling 276.8 acres; 85.8 acres of unchannelized creeks; 88.7 acres of channelized creeks; and 51.6 acres of excavated ditches was identified within the Project area for a total of 530.3 acres of water resources. A very intensive and well-defined system of ditches and drain tiles was evident in aerial photography reviewed for the Project area. Desktop wetland mapping was followed up with standard USACE wetland delineations, which were conducted in the spring of 2013 and encompassed the construction corridors surrounding Facility infrastructure. The delineation report for the Facility is provided in Appendix M. The more precise water resource boundaries developed during field delineations were used during turbine siting and in calculating the impact estimates provided in Tables 8-8 and 8-8a (due to its size, Table 8-8 is provided after the figures accompanying this application narrative).

Table 8-8 (attached) provides a detailed listing of water resource crossings, with proposed crossing methods and estimates of temporary and permanent impacts to wetlands, streams and ditches. The Facility layout has been developed in a manner that minimizes impacts to natural wetlands and streams. No natural marshes, forested wetlands or excavated ponds will be affected by the Facility. Construc-

3059952v6 4906-17-05 93 NORTHWEST OHIO WIND ENERGY, LLC tion of the Facility will entail 2.23 and 0.37 total acres of temporary and permanent water resource impacts, respectively. The vast majority of water resource impacts will be limited to man-made ditches, excavated within crop lands or along roads. Of the above-mentioned 2.23 and 0.37 acres of temporary and permanent impact, 1.67 and 0.25 acres (74.9 and 67.6 percent) will affect excavated ditches only.

Construction of the Facility will not result in any permanent impacts to channelized or unchannelized streams. Crane paths using culverts and temporary fills will generate a total of 0.68 acre of temporary impact to streams. With one exception, these temporary stream crossings involve historically channelized streams that are bordered by little or no woody riparian vegetation. One crane path accessing turbine location T-21 will involve 0.12 acre of temporary impact for a crane path crossing of what appears to be an unchannelized reach of Prairie Creek. However, woody riparian vegetation at this crossing point has largely been removed and is now limited to a very narrow band of trees along the stream channel. Tree removal will be minimized to the degree possible in accomplishing this crossing and any unavoidable impacts to woody riparian vegetation will be addressed in the vegetation management and streamside vegetation restoration plans described in Section 4906-17-05(B)(1)(b).

Prior to on-site wildlife surveys, Applicant consulted the ODNR and USFWS, as well as a number of desktop resources, to obtain background information on major species that may be present in the Project area. Major species would include species of commercial or recreational value, as well as federal- or state-listed rare, threatened or endangered species. Desktop data sources that were consulted include the U.S. Geological Survey (USGS) North American Breeding Bird Sur-vey (BBS) (Sauer et al. 2009), the National Audubon Christmas Bird Count (CBC) (National Audubon Society 2002), the U.S. Geological Survey Geographical Ap- proach to Planning (GAP) Breeding Bird Richness in Ohio, the Ohio Frog and Toad Calling Survey, the Ohio Salamander Monitoring Program, and state and 3059952v6 4906-17-05 94 NORTHWEST OHIO WIND ENERGY, LLC federal conservation lists (threatened and endangered species). A request was also made to the ODNR for a review of the Natural Heritage Database.

Wildlife survey protocols were based on ODNR’s On-shore Bird and Bat Pre- Construction Monitoring Protocol for Commercial Wind Facilities in Ohio (ODNR 2009) and Facility-specific ODNR survey recommendations dated Janu- ary 28, 2010. Correspondence with ODNR and USFWS on wildlife issues and survey protocols is provided in Appendix M-1. Field surveys were performed in May, June and July, 2010 and April and May, 2013, consisting of raptor nest searches (including the northern harrier), bat acoustic and mist net surveys and incidental wildlife observations during other field survey efforts. Pursuant to ODNR guidance, breeding bird surveys were not conducted because all turbines were sited in active cropland.

Information from the above-described sources has been synthesized and is presented below for birds, mammals, reptiles/amphibians, and state- and federally- listed species with potential to occur in the Project area.

i. Birds

This section summarizes available information regarding avian use of the Project area and surrounding areas, based on review of existing data compiled by BBS and CBC which together present a master list of potential avian species throughout the year. The BBS provides data on bird abundance and diversity during summer, while the CBC provides a source of winter data.

The BBS, conducted by the USGS Patuxent Wildlife Research Center, is a long- term database available for monitoring the status and trends of bird populations. The BBS began in 1966 with roadside survey routes covered during June of each year. Each route is 24.5 miles long, with stops at 0.5-mile intervals for auditory and visual counts within a 0.25-mile radius. There are no BBS routes in Paulding County. The Berne route is located approximately 9 miles southwest of the Pro- ject area in adjacent Allen and Adams Counties, Indiana. There are several other

3059952v6 4906-17-05 95 NORTHWEST OHIO WIND ENERGY, LLC routes within 20 miles of the Project area; however, these routes include land cover types that aren’t representative of the Project area, such as predominant hay and riparian areas.

The CBC was initiated in 1900. Each count takes place within a circle 15 miles in diameter, and the circle location, once established, rarely changes. The count period is determined each year by the National Audubon Society and consists of about 17 days from mid-December to the beginning of January. Each count takes place on a single day within the count period. The closest CBC location is in northern Paulding County called the Black Swamp CBC.

Birds observed on these routes are generally common and abundant species. These common species include turkey vulture, American robin, European starling, common grackle, brown-headed cowbird, eastern meadowlark, red-winged black- bird, mallard, and Canada goose. All of these species were also observed during a windshield survey of the Project area in early May 2010. The state endangered northern harrier has been observed during both the breeding and non-breeding seasons. No other state-listed threatened or endangered birds have been observed on the Berne BBS route. Additional state-listed birds observed during the winter counts include Sandhill crane (endangered), and bald eagle (threatened).

Furthermore, the USGS Geographical Approach to Planning (GAP) for Biological Diversity analysis includes a Breeding Bird Species Richness analysis for Ohio (USGS 2001). This analysis is derived from location data from the Ohio Breed- ing Bird Atlas and provides an indication of the habitat use by birds based on the number of breeding bird species in a particular area. The Breeding Bird Species Richness data from the GAP analysis program show low breeding bird species richness in the vicinity of the Project area (Appendix N). Richness is a term to describe the number of species; breeding bird species richness therefore describes the number of breeding bird species in a particular area. Generally, breeding bird species richness is higher in eastern Ohio, where more suitable habitat is available for a variety of species. This portion of the state is predominately woodlands in-

3059952v6 4906-17-05 96 NORTHWEST OHIO WIND ENERGY, LLC terspersed with some cropland, hay fields, and water features creating several types of habitats to support a variety of breeding birds. The low breeding bird species richness in the Project area vicinity can be attributed to the predominant agricultural land cover with few wooded areas and wetlands interspersed. This analysis supports the rationale that the Project area is especially suitable for wind energy development and the ecological risk of the Facility to wildlife in the area is low.

ii. Raptor Study

Ohio DNR indicates the Facility is situated in a low ecological risk setting and recommendations on wildlife surveys are “minimum” on a 4-point scale that includes “minimum”, “moderate”, “moderate where applicable”, and “extensive”. The minimum survey effort includes breeding bird surveys in suitable habitat, raptor nest searches for threatened or endangered raptors (bald eagle, peregrine falcon, osprey, and northern harrier in Ohio), and bat acoustic monitoring. ODNR did not recommend breeding bird surveys at turbine locations sited on active cropland. Since all turbine locations for the Facility are on active crop land, no breeding bird surveys were performed. Raptor surveys at the Project area were conducted in April and May 2013 using protocols set forth in ODNR guidelines. Observations are summarized in Appendix C.

iii. Mammals

Due to a lack of existing data regarding mammals in the vicinity of the Project area, the occurrence of mammalian species was documented primarily through evaluation of available habitat, species range, and incidental observation from a windshield survey of the Project area the first week of May 2010, and again during 2013 surveys for wetlands and habitat.

Survey efforts suggest at least 40 species of mammal could occur in the area, including white-tailed deer, eastern cottontail, eastern chipmunk, coyote, red fox, raccoon, opossum, woodchuck, gray squirrel, fox squirrel, striped skunk, beaver,

3059952v6 4906-17-05 97 NORTHWEST OHIO WIND ENERGY, LLC muskrat, mink, long-tailed weasel, big brown bat, little brown bat, red bat, eastern pipistrelle, hoary bat, silver-haired bat, and a variety of small mammals such a mice, voles, and shrews (ASM 2010; NatureServe 2009; ODNR 2010a). Most of the mammal species likely to occur in the area are common, abundant, and widely distributed throughout the eastern United States.

Applicant contracted with Tragus to conduct the required Bat Acoustic Monitor- ing program. Two AnaBat units were purchased and installed on the met mast located within the Project area in February of 2010 which was in advance of DOW’s required monitoring period beginning March 15, 2010. Tragus was responsible for collecting and analyzing all bat acoustic data. The DOW has reviewed and approved Tragus’s scope of work.

In July 2010, Tragus conducted field surveys on two sites using mist nets for a total of 16 net nights (see Appendix K). Results of the mist netting survey found only two species of bats; the red bat and the big brown bat. Both of these species are considered common species and well adapted to agricultural settings, though they have recently been accorded Species of Concern status by the ODNR. Tragus further noted the low numbers observed for these common bats is indicative of the overall poor habitat for bats within the Project area.

Tragus also performed an acoustic bat survey utilizing two Anabat detectors mounted on an existing meteorological tower at altitudes of 5 and 45 meters. Calls from five bat species were detected using the acoustic detectors. In addition to the big brown and red bats mentioned previously, silver haired, hoary and evening bats were also detected. Silver-haired and hoary bats were recently designated Species of Concern and evening bats designed Special Interest by the ODNR DOW. Acoustic detectors were monitored from March 15 to November 15, 2010. The total number of survey nights for the 5 and 45 meter Anabat units were 215 and 246, for a total of 461 survey nights. As indicated in the Tragus report (see Appendix K), the 5-meter Anabat unit was inadvertently not powered up between September 27 and October 20. This resulted in the loss of data from 31

3059952v6 4906-17-05 98 NORTHWEST OHIO WIND ENERGY, LLC survey nights during that period. As stated in the Tragus report, a total of 2,954 bat passes of > 2 echolocation pulses were recorded during the entire survey period. This equates to 6.41 bat passes per survey night.

iv. Reptiles and Amphibians

Reptile and amphibian presence In the vicinity of the Project area was determined through review of the Ohio Frog and Toad Calling Survey, the Ohio Salamander Monitoring Program, and ODNR data. Based on this information, along with documented species ranges and existing habitat conditions, it is estimated that approximately 30 reptile and amphibian species could occur in the Project area. Species likely to occur within the vicinity include eastern American toad, gray treefrog, northern spring peeper, western chorus frog, American bullfrog, northern green frog, northern leopard frog, mudpuppy, redback salamander, snapping turtle, midland painted turtle, common watersnake, eastern ratsnake, eastern milk- snake, eastern gartersnake, and common five-lined skink (Davis & Lipps 2010; ODNR 2009a & 2010b). These species are generally common, abundant, and widely distributed throughout Ohio.

(d) Summary of Ecological Studies

Applicant contacted Keith Lott at the ODNR Division of Wildlife (DOW) on De- cember 1, 2009 to present the Facility and start the DOW review process. On De- cember 12, 2009 Applicant received an initial list of survey recommendations from the DOW which covered the entire Project area. A summary of the commu- nications and recommendations of the DOW are provided in Section 4906-17- 08(B)(1). In an e-mail dated January 28, 2010 it was determined “the U.S. Fish and Wildlife Service worked with ODNR to develop the appropriate survey recommendations for the proposed project site…..We agree that the pre-construction survey recommendations included in the attachment below are sufficient to document the status of birds and bats within the Project area.” The USFWS will be providing general project comments under a separate cover.

3059952v6 4906-17-05 99 NORTHWEST OHIO WIND ENERGY, LLC Applicant also submitted the Project area to the Division of Natural Areas and Preserves (ODNR). The database search preformed uncovered no records of rare or endangered species in the Project area.

(e) Major Species List

Major species are defined by the OPSB as species of commercial or recreational value, and species designated as endangered or threatened in accordance with the U.S. and Ohio threatened and endangered species lists. Commercial species consist of those trapped or hunted for fur, while recreational species consist of those hunted as game.

i. Commercial Species

The ODNR regulates the hunting and trapping of the following furbearers in Paulding County: muskrat, raccoon, red fox, gray fox, coyote, mink, opossum, striped skunk, long-tailed weasel, and beaver (ODNR 2010c, 2010d, and 2010e).

• Muskrat: Muskrat are abundant throughout Ohio, and typically inhabit water features with slow-moving currents, such as creeks and wetlands. This species is likely to occur in the Project area, specifically in Blue Creek or Prairie Creek.

• Raccoon: Raccoon are common statewide, occupying a wide variety of habitats, including forests, cropland, and developed land. This species has high potential to occur in the Project area, and was observed during the early May 2010 windshield survey as road kill.

• Red Fox: Red fox are common statewide, occupying a wide variety of habitats, including forests, cropland, and developed land. This species has high potential to occur in the Project area.

• Gray Fox: This species is less common in Ohio than the red fox. Gray fox typically inhabit forested and shrubland habitats, avoid- 3059952v6 4906-17-05 100 NORTHWEST OHIO WIND ENERGY, LLC ing open areas. Because the Project area is predominately open agricultural land, this species has low potential to occur in the Project area.

• Coyotes: Once extirpated in Ohio, coyotes are now common statewide, occupying a wide variety of habitats including forests, cropland, and shrubland. This species is likely to occur in the Pro- ject area.

• Mink: This semi-aquatic weasel has a statewide distribution, and prefers forested areas wetlands with abundant cover. This species has moderate potential to occur in the Project area in limited areas such as the wetlands surrounding Blue Creek and Prairie Creek.

• Opossum: Opossum are common statewide, occupying a wide variety of habitats, including forests, cropland, and developed land. This species is likely to occur in the vicinity of the Project area.

• Striped Skunk: Skunk are common statewide, occupying a wide variety of habitats, including forests, cropland, and developed lands. This species is likely to occur in the Project area.

• Long-tailed Weasel: This is Ohio’s most common weasel and it characteristically in-habits a wide variety of habitats including forests, cropland, and shrubland. It is likely to occur in the Project area.

• Beaver: Beaver are common statewide, inhabiting and modifying permanent water sources of almost any type, particularly low gra- dient streams and small lakes and ponds with outlets. This species is likely to occur in the Project area.

ii. Recreational Species

3059952v6 4906-17-05 101 NORTHWEST OHIO WIND ENERGY, LLC The ODNR (2010e and 2010f) regulates the hunting of the following species in Paulding County: white-tailed deer, gray squirrel, red squirrel, fox squirrel, eastern cottontail rabbit, woodchuck, wild boar, ring-necked pheasant, wild turkey, various waterfowl, American crow, and other migratory game birds.

• White-tailed deer: Deer are common statewide, occupying a wide variety of habitats, such as forests, shrubland, cropland, and developed land. This species is very likely to occur in the Project area.

• Gray, red, and fox squirrels: The fox squirrel is typically occupies open woodlands, while the gray squirrel and the red squirrel prefer more extensive forested areas. However, all three species had adapted well to landscaped suburban areas, and are often found around structures. All three species are likely to occur in the Pro- ject area.

• Eastern cottontail rabbit: Cottontails are common and abundant statewide, as they typically inhabit open areas bordered by brush and open woodlands. Like the squirrels, rabbits have adapted well to developed areas. This species is very likely to occur in the Pro- ject area.

• Woodchuck: Woodchuck are common statewide, occupying a wide variety of habitats including pastures, grasslands, and open woodlands. This species is likely to occur in the Project area.

• Wild boar: Wild boar is not native to Ohio, but have established breeding populations in several locations, occupying a wide variety of habitats such as forests, cropland, and shrubland. According to ODNR distribution maps (2008), the nearest population of feral swine occurs north of the Project area, along the Defiance- Paulding County line. Wild boars are unlikely to occur in the Pro- ject area due to lack of habitat.

3059952v6 4906-17-05 102 NORTHWEST OHIO WIND ENERGY, LLC • Ring-necked pheasant: Although not native to North America, the pheasant is naturalized in northern and western Ohio, and inhabits open areas such as agricultural areas. This species is recorded on both the BBS and CBC counts and is very likely to occur in the Project area vicinity.

• Wild turkey: once extirpated in Ohio, this species has reestab- lished populations statewide, and is especially common in the southern and eastern parts of the state. Wild turkey is an adaptable species that prefers mature forest habitats. This species was recorded on the CBC data as recent at 2009.

• American crow: Crow are common statewide, typically inhabiting a wide variety of habitats, including forests, cropland, shrubland, and developed land. This species has been documented on both BBS and CBC counts in the Project area vicinity and is very likely to occur in the Project area.

• Waterfowl: The following waterfowl species have been observed in the Project area vicinity, according to BBS and CBC data: Can- ada goose, wood duck, mallard, red-breasted merganser. The Pro- ject area lacks abundant wetland habitat for waterfowl species; however they have potential to occur in the Project area during migration periods.

• Other migratory game birds: Mourning doves are migratory game species that have been recorded in the Project area vicinity on BBS and CBC routes. Mourning doves are common across Ohio, inhabiting a wide variety of habitats, including cropland, shrub-land, and developed land.

iii. Federally-Listed Species

3059952v6 4906-17-05 103 NORTHWEST OHIO WIND ENERGY, LLC According to USFWS (2009), there are two federally-listed species known to occur in Paulding County: the endangered Indiana bat and the candidate eastern massasauga.

• Indiana bat: This species is listed in all of Ohio’s Counties. Indi- ana bats may use wooded stream corridors for feeding and summer roosting. However, these riparian corridors are discontinuous in the Project area vicinity and more suitable riparian corridors exist along the Auglaize and Maumee Rivers in eastern and northern Paulding County, respectively. Additionally, the Project area lacks caves which could serve as winter hibernacula.

• Eastern massasauga: this rattlesnake and federal candidate species has low potential to occur in the Project area. Massasauga rattle- snakes are found in wet prairies, sedge meadows, and early succes- sional fields. Preferred wetland habitats are marshes and fens. Natural succession of woody vegetation is a leading cause of recent habitat deterioration throughout its range. Given the overall scarcity of wetlands within the Project area, there appears to be minimal potential habitat for these snakes. If they are present, they would most likely be found in emergent wetlands (i.e., marshes and wet meadows) that lie along streams.

iv. State-Listed Species

The Ohio Division of Wildlife Natural Heritage Database was consulted for State listed species recorded in Paulding County. Based on the listing (current as of 11/8/2012) there were 15 state-listed species known to occur in Paulding County (ODOW 2012). As described in more detail in Section 4906-17-08(B)(1)(c)(iii), several bat species documented in 2010 mist net and acoustic bat surveys have recently been ascribed Species of Concern or Special Interest status by the ODNR DOW. Table 8-9 provides a combined listing of the federal and state-listed species that have been documented or may potentially occur within the Project area. 3059952v6 4906-17-05 104 NORTHWEST OHIO WIND ENERGY, LLC Overall, the potential for rare species to occur in the Project area is low, primarily due to the predominant agricultural land use and therefore lack of suitable habitat for rare species. Generally, state-listed plant species have the most potential to occur in the Project area along water bodies. However, because water features are limited in the Project area and most have been modified by agriculture, the potential to state-listed wetland or aquatic species to occur in the Project area is low de- spite records in the County.

Rare vertebrates also generally have low potential to occur in the Project area. Similar to the rare plant species, these species’ habitats either do not exist in the Project area or the habitat is very limited (i.e., wetlands and streams). The state- endangered northern harrier was not identified in the Natural Heritage Database as occurring in the Project Area. However, ODNR DOW staff has indicated this species may potentially utilize the Project area during the breeding season. Sur- veys for northern harriers were conducted in mid-May 2010 and were repeated in May 2013. Harriers are more at risk of habitat displacement rather than turbine collisions. These birds characteristically fly below the rotor swept zone of turbine blades, hunting close to the ground. They are not known to soar like other hawks, such as red-tail hawks and Swainson’s hawks.

With recent changes in listing status, the five bat species documented by surveys within the Project Area are now state-listed. Eastern red, big brown, silver-haired and hoary bats are now designated Species of Concern and the evening bat is designated Special Interest. While now state-listed, none of these species are rare. Species of Concern species are those which might become threatened in Ohio under continued or increased stress or are subjects of some concern but for which information is insufficient to permit an adequate status evaluation. Special interest species are those that occur periodically and are capable of breeding in Ohio but are at the edge of a larger, contiguous range that has viable population(s) at the core of that range.

3059952v6 4906-17-05 105 NORTHWEST OHIO WIND ENERGY, LLC The state and federally endangered Indiana bat has not been documented within the Project area and summer maternity roosting habitat is lacking. No project infrastructure has been sited within 5 miles of a documented Indiana bat capture and mist net and acoustic surveys yielded negative results for this species. However, an adjacent wind farm recently experienced an Indiana bat fatality during the fall migration period. Accordingly, the Facility does have the potential for migration period Indiana bat fatalities.

Amended Table 8-9:

Table 8-9: Federal and State-Listed Species known to occur in Paulding County (identified by the Ohio Division of Wildlife Natural Heritage Database (11/8/2012) or documented in the Project area during 2010 Animal Life Surveys. Potential to Common Scientific Federal State Group Occur in Pro- Comments Name Name Status2 Status2 ject Area

Purple Cyclonaias Lack of habitat in Pro- SC Low Wartyback tuberculata ject area Mollusks Truncilla trun- Lack of habitat in Pro- Deertoe SC Low cate ject area Potentially in stream Uniomerus Pondhorn T Low channels and ponds, tetralasmus tolerates emersion Four-toed Hemidactylium Lack of habitat in Pro- SC Low Salamander scutatum ject area Blanding’s Emydoidea Lack of habitat in Pro- SC Low Turtle blandingii ject area Potentially wet mead- Kirtland’s Clonophis T Low ows and ponds along Snake kirtlandii stream corridors Sharp- Accipiter stria- Lack of breeding habi- shinned SC Low Vertebrates tus tat. Potential migrant. Hawk Documented flying through Project area Northern Circus cya- E Moderate but not breeding there harrier neus due to lack of grassland habitat. Low during Minimal potential for Indiana Bat Myotis sodalis EE breeding sea- roosting or feeding son/Moderate to along Project area

3059952v6 4906-17-05 106 NORTHWEST OHIO WIND ENERGY, LLC Table 8-9: Federal and State-Listed Species known to occur in Paulding County (identified by the Ohio Division of Wildlife Natural Heritage Database (11/8/2012) or documented in the Project area during 2010 Animal Life Surveys. Potential to Common Scientific Federal State Group Occur in Pro- Comments Name Name Status2 Status2 ject Area High during mi- stream corridors. Like- gration periods ly migrates through Project area in small numbers. Big Brown Eptesicus Documented in Project SC High Bat fuscus area surveys Lasiurus bore- Documented in Project Red Bat SC High alis area surveys Silver- Lasionycteris Documented in Project SC High haired Bat noctivagans area surveys Lasiurus ci- Documented in Project Hoary Bat SC High nereus area surveys Nycticeius Documented in Project Evening Bat SI High humeralis area surveys Potentially in streams; Greater Moxostoma FSC T Low highly intolerant to Redhorse valenciennesi pollution Armoracia Lack of habitat in Pro- Lake-cress T Low lacustris ject area Ravenfoot Carex crus- Potentially along wet- P Low Sedge corvi lands and streams False Hop Carex lupuli- Potentially along wet- P Low Vascular Sedge formis lands and streams Plants Cuspidate Cuscuta cus- Parasitic plant along E Low Dodder pidata creeks and streams Leafy Blue Potentially along wet- Iris brevicaulis T Low Flag lands and streams Prairie Vernonia fas- Potentially in wet prai- P Low Ironweed ciculate ries

1Information adapted from Ohio Division of Wildlife. 2Federal and State Status of listed species: T – Threatened, E – Endangered, SC – Species of Concern, SI – Spe- cial Interest and P – Potentially Threatened. Note SC only applies to wildlife species and P only applies to plant species.

3059952v6 4906-17-05 107 NORTHWEST OHIO WIND ENERGY, LLC The ODNR Natural Heritage comment letter dated March 8, 2013 (Appendix O) indicated there are no records of rare or endangered species in the Project area or one mile buffer. Additionally, there are no records of unique ecological sites, geologic features, animal assemblages, or federal- or state-protected natural areas (such as nature preserves, parks, wildlife refuges etc.). The ODNR inventory program has not completely surveyed Ohio and relies on information supplied by many individuals and organizations. Therefore, a lack of records for any particular area is not a statement that rare species or unique features are absent from that area. Instead, it may indicate the area has not been surveyed. The state invento- ries all types of plant communities, but only maintains records on the highest quality areas.

(2) Construction

(a) Impact of Construction

Ecological impacts may occur during construction as a result of installation of turbines, access roads, and electrical interconnects; the upgrade of local public roads or intersections; the development and use of the laydown area and temporary workspaces around the turbine sites; and the construction of the step-up facility and O&M facility. Potential impacts to upland and wetland communities are discussed below.

i. Upland Habitats

Facility construction will result in minimal temporary and permanent impacts to upland vegetation within the Project area. Construction activities that may result in impacts to vegetation include site preparation, earth-moving, and excavation/backfilling activities associated with construction/installation of the laydown area, access roads, foundation, and underground collector system. These activities would result in cutting and clearing of vegetation and increased exposure/disturbance of soil. Along with direct loss of (and damage to) vegetation these impacts can result in a loss of wildlife food and cover, increased soil erosion and sedimentation, increased risk of colonization by non-native invasive species,

3059952v6 4906-17-05 108 NORTHWEST OHIO WIND ENERGY, LLC and disruption of normal nutrient cycling. However, it is not anticipated that any plant species occurring the Project area will be extirpated or significantly reduced abundance as a result of construction activities. Since upland woods and grassland represent less than 1% of total cover, these habitats will not be impacted as a result of Facility activities. Most of the area proposed for impacts is currently agricultural where frequent recurring disturbance is commonplace, as are the resulting erosion and invasive species colonization. Table 8-7 quantifies impacts to ecological communities, based on the typical area of vegetation clearing column presented in Table 3-1.

Agricultural lands have been included in the Table 8-7 to fully account for all anticipated upland impacts. Native vegetation or agricultural crops will be reestab- lished during restoration of areas disturbed during construction.

ii. Wetlands and Water Bodies

Results of desktop review for the presence of wetlands indicated wetlands and waterbodies account for less than 0.1% of the Project area. Further, all of the proposed turbines are located in active agricultural fields, consequently direct and indirect impacts to wetlands and surface waters in the vicinity of turbine workspaces will be negligible. The greatest potential for surface water and wetland impacts will be in the construction of turbine access roads and installation of electrical interconnections among the turbine arrays.

To identify and evaluate wetlands and surface waters that could be affected by the Facility, in May 2013 Westwood conducted a field delineation of wetlands based on the methodology described the USACE Wetland Delineation Manual (1987) and the Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Northcentral and Northeast Region (2012). A quantitative assessment of wetland value has been conducted using the Ohio Rapid Assessment Method for Wetlands (ORAM) Version 5.0 and wetlands will be categorized as defined by the Ohio Water Quality standards Anti-degradation Policy for Wetlands (OAC Section 3745-1-54). 3059952v6 4906-17-05 109 NORTHWEST OHIO WIND ENERGY, LLC (b) Impact of Construction on Major Species

Minimization of impacts will primarily be accomplished by siting Facility components away from sensitive habitats such as wetlands, streams, and forestland. Construction-related impacts to wildlife are anticipated to be limited to incidental injury and mortality due to construction activity and vehicular movement, construction-related silt and sedimentation impacts on aquatic organisms, habitat disturbance/loss associated with clearing and earth-moving activities, and displacement of wildlife due to increased noise and human activities. Based on the studies described to date, none of the construction-related impacts will be significant to affect local populations of any resident or migratory wildlife species.

Incidental injury and mortality should be limited to sedentary/slow moving species such as small mammals, reptiles, and amphibians that are unable to move out of the area being disturbed by construction. Since most Facility components are sited in active agricultural land that provides limited habitat to sedentary/slow moving species, such impacts are anticipated to be very minor.

Earth moving activities associated with the Facility have the potential to cause siltation and sedimentation impacts down slope of the area of disturbance; however Facility components have been sited away from wetlands and streams to the extent practicable to minimize potential impacts. To prevent any adverse effects to water quality during construction, runoff will be managed under an NPDES construction storm water permit and associated SWPPP. An erosion and sediment control plan will be developed prior to construction that will use appropriate runoff diversion and collection devices. Virtually all Facility components will be sited in active agricultural land where soil disturbance from regular plowing, tilling and harvesting is routine.

Some wildlife displacement will occur due to increased noise and human activity as a result of Facility construction. However, since the Facility is located on active agricultural land, the only species likely to be affected are those utilizing such

3059952v6 4906-17-05 110 NORTHWEST OHIO WIND ENERGY, LLC habitat. In general, the degree of impact will vary by species and timing of construction activities.

The potential for habitat disturbance/loss from construction activities is minimal since less than 2% of the Project area consists of grassland, wetland, and forestland combined. Agricultural lands, where most of the Facility is to be constructed, generally provides limited habitat for wildlife. Species that typically use agricultural land for habitat are generally accustomed to frequent disturbance. Based on the Facility layout, 971 acres of agricultural land will be subject to temporary impacts and there will be no permanent impacts to natural communities.

Several procedures for impact minimization, site restoration, and mitigation will be conducted to address short and long-term construction impacts.

i. Impact Minimization

Mitigation measures to avoid or minimize impacts to vegetation will include iden- tifying/delineating sensitive areas (such as wetlands) where no disturbance will be allowed, limiting areas of disturbance to the smallest area practicable, siting Facil- ity components in previously disturbed areas, employing best management practices during construction, and maintaining a clean work area within the designated construction sites. Following construction activities, temporarily disturbed areas will be seeded (and stabilized if necessary) to reestablish vegetative cover in these areas. Native species will be allowed to re-vegetate these areas, except in active agricultural fields.

Applicant will contact OPSB Staff, ODNR, and the USFWS within 24 hours if state or federal threatened or endangered species are encountered during construction activities. Construction activities that could adversely impact the identified plants or animals will be halted until an appropriate course of action has been agreed upon by Applicant, OPSB Staff, and ODNR in coordination with the USFWS. Nothing in any forthcoming CECPN condition shall preclude agencies

3059952v6 4906-17-05 111 NORTHWEST OHIO WIND ENERGY, LLC having jurisdiction over the Facility with respect to threatened or endangered species from exercising their legal authority over the Facility consistent with law.

To avoid or minimize Facility-related impacts on surface waters and wetlands, preliminary and final Facility design is guided by the following criteria during the siting of turbines and related infrastructure:

• Turbine, laydown area, O&M facility, and the step-up facility will be sited to completely avoid wetlands and surface waters.

• The number and size of impacts from access road crossings were minimized by routing around wetlands and streams whenever possible, and by utilizing existing crossings and narrow crossing locations to the extent practicable.

• Underground electric lines will avoid crossing wetlands whenever possible, will cross streams at existing or previously disturbed locations, and will utilize installation techniques that minimize construction-related impacts to surface waters and wetlands.

• All Facility components, including access roads and underground lines, are sited to completely avoid forested wetlands.

Applicant will use BMPs when crossings of wetlands or streams are required. BMPs include, but are not limited to, the following:

• No Equipment Access Areas: except where crossed by permitted access roads, wetlands will be designated “No equipment Access” to prohibit the use of motorized equipment in those areas.

• Restricted Activity Areas: A buffer zone of 50 feet, referred to as a “Restricted Activity Area”, will be established wherever Facility construction traverses or comes in proximity to wetlands and streams. Restrictions within this zone will include:

3059952v6 4906-17-05 112 NORTHWEST OHIO WIND ENERGY, LLC • No deposition of slash • No accumulation of construction debris • No herbicide applications • No degradation of stream banks • No equipment washing or refueling • No storage of any petroleum or chemical material

Low impact wetland and stream crossing techniques will be used where feasible including but not limited to use of geotextile mats and corduroy for temporary access in wetlands, observing seasonal restrictions for streams, and installing appropriate culverts on crossing to minimize habitat loss and wildlife movement restrictions.

SPCC measures will be implemented to prevent the release of hazardous substances into the environment. These measures will not allow refueling of construction equipment within 100 feet of any stream or wetland, and all contractors will be required to keep materials on hand to control and contain a petroleum spill. Any spills will be reported in accordance with ODNR regulations. Contrac- tors will be responsible for ensuring responsible action on the part of construction personnel.

ii. Site Restoration

Following completion of construction, temporarily impacted areas will be restored to their pre-construction condition. Restoration activities are anticipated to include the following:

3059952v6 4906-17-05 113 NORTHWEST OHIO WIND ENERGY, LLC " Damaged drain tile segments will be reconnected with the appropriate sized repair segment. To prevent drain tile from sagging after trench backfilling is complete, Applicant will reinforce each repaired tile segment with a rigid PVC sleeve or other structural support acceptable to landowners.

" The 200-foot radius turbine workspaces will be reduced to the permanent 0.2-acre foot-print.

" To the extent practicable, pre-construction contours and soil conditions will be re-established in all disturbed areas.

" Underground electrical lines routes will be restored to pre-construction contours and allowed to regenerate naturally.

" Disturbed agricultural fields will be restored by de-compacting soil, removing rocks, and re-spreading stockpiled soil.

" Disturbed soils throughout the Project area will be re-seeded with an annual cover crop for stabilization of exposed soils. Native seed will be used for areas outside of agricultural fields.

" Disturbed stream banks will be stabilized per the conditions of any formal state-issued permit.

iii. Mitigation Measures

Applicant will provide suitable on-site or off-site compensatory mitigation for unavoidable permanent impacts to wetlands and streams. Compensatory mitigation will be developed in co-ordination with the USACE and Ohio EPA during the permitting process.

(3) Operation

(a) Estimate the Impact of Operation on Areas

3059952v6 4906-17-05 114 NORTHWEST OHIO WIND ENERGY, LLC The Facility is located entirely on leased private land, consequently its operation will not result in physical disturbance/impacts to recreational areas, parks, wildlife areas, nature preserves, or other conservation areas. No disturbance to plants, vegetative communities, wetlands, or surface waters is anticipated aside from mi- nor disturbance associated with routine maintenance activities.

Visual impact of the turbines varies widely depending on location, number of turbines visible, adjacent land use, viewer sensitivity, and proximity to viewer. The greatest impact is most likely to occur where turbines are particularly incongruous with adjacent land use such as natural areas. However, since 95 % of the Project area consists of agricultural fields, it is unlikely visual impacts will be an issue.

(b) Estimate the Impact of Operation on Major Species

Operational impacts to wildlife will likely be limited to potential displacement of wildlife from the presence of turbines and some level of avian and bat mortality as a result of collisions with the turbines.

Habitat alteration and disturbance resulting from the operation of turbines and other Facility infrastructure have the potential to make a site unsuitable or less suitable for nesting, foraging, resting, or other wildlife use. However, since the footprint of turbine pads, roads, and other Facility infrastructure represent a very small percentage of the Project area following construction, land use is relatively unchanged by the Facility. There is however the possibility of impact to wildlife that extends beyond the Project area due to the presence of tall structures and human activity. Whether wildlife becomes habituated to the presence of turbines is unknown since long term studies of this question have not been conducted. How- ever, since 98.4% of the Project area consists of a combination of agricultural fields and developed land, wildlife species present are more accustomed to repeated disturbance typical of those types of land use.

There currently is no predictive model available to quantify expected avian collision mortality as a result of wind power project operation. Therefore, risk assessments must be based on pre-construction indices and indicators of risk (e.g., avian 3059952v6 4906-17-05 115 NORTHWEST OHIO WIND ENERGY, LLC use surveys), along with empirical data from operating facilities (e.g., avian mortality surveys). Because pre-construction surveys revealed no indicators of elevated risk (e.g., unusually high numbers, habitat that would act as an ecological magnet, or abundance of rare species), collision risk to avian species in the Pro- ject area is likely to be limited.

As with avian risk, there are currently no predictive models available to quantify expected bat collision mortality as a result of wind energy facility operation, and risk assessments must be based on preconstruction indices and indicators of risk (e.g., acoustic surveys), along with empirical mortality data from operating facilities. Because the Project area reveals no indicators of elevated risk (e.g., land- scape position, survey results indicating large numbers of bats), collision risk to bats in the Project Area is likely to be consistent with other wind energy projects in agricultural landscapes in the mid-west. Due to recent changes in state listing status, a number of bat species documented within the Project area are now state- listed Species of Concern or Special Interest bat species. These bat species will almost certainly incur some level of collision-related mortality. However, none of these species are rare and survey data collected to date suggest that they are not present in large numbers. While the Project area lacks suitable summer habitat for Indiana bats, Applicant is aware that this species migrates through the Project area vicinity and that one fall migration period fatality was recently documented on an adjacent wind farm. It is likely that the Facility will generate a small number of Indiana bat fatalities over its operational life, primarily during migration periods.

Short- and long-term impacts to threatened or endangered species habitat by wind farm operations are effectively mitigated by designing wind farms so as to not site roads, turbines, cables in the habitats of threatened or endangered species. The Facility has been designed to minimize bird and bat collision mortality by placing

3059952v6 4906-17-05 116 NORTHWEST OHIO WIND ENERGY, LLC turbines farther apart than older wind farms where higher mortality was reported. Turbines will be placed in agricultural fields avoiding wooded areas that provide habitat for bats. Towers will be tubular structures, which discourages nesting and perching opportunities for birds, and towers will be lighted in a manner that re- duces collision risk, yet adheres to FAA guidelines. Turbine blades will be feathered, i.e., remain stationary or nearly stationary, when wind speeds are below the manufacturer’s cut-in speed.

The Facility has been designed to avoid the clearing of forested habitat. Accord- ingly, it is very unlikely that Applicant will be removing any potentially trees that represent potentially suitable Indiana bat roosting habitat. However, if avoidance measures cannot be achieved and some trees need to be removed, Applicant has committed to adhere to seasonal cutting dates of September 30 through April 1. This timing will protect migratory bird nests while they are active and any roosting Indiana bats that might be present. If any suitable Indiana bat habitat trees are found, cannot be avoided and must be cut during the summer season of April 2 through September 29, a mist-netting survey will be conducted in May or June prior to such cutting.

While the Project area lacks suitable summer habitat for Indiana bats, Applicant is aware this species migrates through the Project area vicinity and that one fall migration period fatality was recently documented on an adjacent wind farm. Given the potential for periodic Indiana bat fatalities during migration, the USFWS has recommended that Applicant either adopt operational mitigation measures that would definitively avoid the taking of migrating Indiana bats or pursue an Inci- dental Take Permit (ITP). The ITP process would involve either the submission of a project-specific Habitat Conservation Plan (HCP) or participation in a regional multi-species HCP currently under preparation by the USFWS. Applicant anticipates participation in the regional HCP and is coordinating with the USFWS regarding the ITP process and operational mitigation measures most appropriate for the Facility. The USFWS is the lead agency in preparing the HCP and ODNR was originally is considered a planning partner in the HCP effort. However, the

3059952v6 4906-17-05 117 NORTHWEST OHIO WIND ENERGY, LLC ODNR has since withdrawn from involvement in HCP development. According- ly, Applicant will continue coordination with the USFWS regarding the HCP and will maintain separate coordination with ODNR.

It is anticipated that operational mitigation measures will include seasonal increases in turbine cut-in speed, with turbines blades feathered at lower wind speeds. Applicant will continue working with the USFWS to determine the most appropriate cut-in speed(s) and seasonal time periods to which operational modifications would be applied. Applicant anticipates that operational modifications would apply from one-half hour before sunset to one-hour after sunset during periods when the air temperature is above 50 degrees F. In addition to minimizing the potential for impacts to Indiana bats, such operational mitigation measures will also minimize potential impacts to other state-listed Species of Concern and Special Interest bat species.

(d) Post-Construction Monitoring of Wildlife Impacts

Sixty days prior to the first turbine becoming commercially operational, Applicant will submit a post-construction avian and bat monitoring plan for DOW and OPSB Staff review and confirmation that it complies with the applicable CECPN condition. Applicant will also provide the monitoring plan to and seek confirmation from the USFWS. Applicant’s plan will be consistent with ODNR-approved, standardized protocol, as outlined in ODNR's On-Shore Bird and Bat Pre- and Post-Construction Monitoring Protocol for Commercial Wind Energy Facilities in Ohio. Applicant will obtain the necessary permits from ODNR and USFWS to collect bat and migratory bird carcasses. The post-construction monitoring will begin within two weeks of operation and be conducted for a minimum of two seasons (April 1 to November 15), which may be split between calendar years. If monitoring is initiated after April 1 and before November 15, then portions of the first season of monitoring will extend into the second calendar year (e.g., start monitoring on July 1, 2011 and continue to November 15, 2011; resume monitoring April 1, 2012 and continue to June 30, 2012). Applicant may request that the second monitoring season be waived at the discretion of ODNR and OPSB Staff. 3059952v6 4906-17-05 118 NORTHWEST OHIO WIND ENERGY, LLC The monitoring start date and reporting deadlines will be provided in the DOW approval letter and the OPSB concurrence letter. If it is determined that significant mortality, as defined in ODNR's approved, standardized protocols, has occurred to birds and/or bats, Applicant understands that the DOW and OPSB Staff will require Applicant to develop a mitigation plan. If required, Applicant will submit a mitigation plan to the DOW and OPSB Staff for review and approval within 30 days from the date reflected on ODNR letterhead, in coordination with OPSB Staff, in which the DOW is requiring Applicant to mitigate for significant mortality to birds and/or bats. Mitigation initiation timeframes will be outlined in the DOW approval letter and the OPSB concurrence letter.

(C)ECONOMICS, LAND USE AND COMMUNITY DEVELOPMENT

(1) Land Uses

(a) Land Use Map

Land uses within the five-mile study area of the Facility are shown on Figure 8-1. The land use mapping was developed from 1995 ODNR Land Use/Land Cover data, and the 2001 USGS National Land Cover Dataset (NLCD).

(b) Habitable Residential Structures

Field-verified habitable residential structures are depicted on Figure 8-1. There are five residences within 100 feet of the boundary of the Facility (identified on Figure 8-1). One residence is located within 100 feet of an underground electrical collection line, one is within 100 feet of a potential laydown yard, two are within 100 feet of an access road, and one is within 100 feet of a crane path. There are 43 residences in the Project area within 1,000 feet of turbines, access roads, underground collection lines, the potential laydown yard, and the potential O&M facility. The distance between turbines and residential structures range from 846 feet (a participating landowner) to 3,014 feet. Additional information on the distances between turbines and residential structures is provided below.

3059952v6 4906-17-05 119 NORTHWEST OHIO WIND ENERGY, LLC Turbines are sited in locations consistent with setbacks from property lines and residential structures. These setbacks are described below.

(i) Distance from base to property line

Section 4906-17-08(C)(1)(c)(i) requires that "the distance from a wind turbine base to the property line of the wind farm property shall be at least one and one-tenth times the total height of the turbine structure as measured from its tower's base (excluding the subsurface foundation) to the tip of its highest blade." The maximum height of turbines under consideration for the Facility is 492 feet (150 meters), which yields a property line setback of 541 feet (165 meters). All turbine base locations will comply with these setbacks.

(ii) Distance from blade to habitable residential structures

Section 4906-17-08(C)(1)(c)(ii) requires that "the wind turbine shall be at least seven hundred fifty feet in horizontal distance from the tip of the turbine's nearest blade at ninety degrees to the exterior of the nearest habitable residential structure, if any, located on adjacent property at the time of certification application." The maximum rotor diameter of turbine under consideration for the Facility is 328 feet (100 meters). If the turbine blade were at ninety degrees, the tip would extend from the base of the tower one-half the length of the rotor diameter, or 164 feet (50 meters), which added to 750 feet, yields a total setback from the tower of 914 feet. All turbine locations exceed the requirements. As currently sited, the distance between turbine towers and the nearest habitable residential structure ranges from 846 (a participating landowner) to 3,014 feet.

(iii)Waiver of minimum setback

Applicant does not anticipate any setback waiver will be required.

(iv)Distances from Pipelines

TransCanada Pipeline to T-06: Approximately 607 feet

3059952v6 4906-17-05 120 NORTHWEST OHIO WIND ENERGY, LLC Dominion Gas Pipeline to T-32: Approximately 1,855 feet

Panhandle Gas Pipeline to T-09: Approximately 656 feet

(v) Distance to Floodplain and Watercourse

The distance from T-21 to the nearest floodplain is approximately 32 feet and the distance to the nearest watercourse is approximately 155 feet. The foundation design will accommodate temporary saturated soil conditions that will exist during seasonal flooding.

(d) Impact of Proposed Facility

Agriculture is the predominant land use in the vicinity of the Project area. Table 08-8 summarizes land use impacts, based on the typical area of vegetation clearing column presented in Table 3-1. As measured by percent of total area, agricultural land occupies over 98% of the total impacts. The predominantly agricultural land use in and around the Project area demonstrates the rural character of the region. The land is made up of generally flat terrain consisting of croplands, with scattered farmsteads and a few small, isolated woodlots. Residential development within and around the Facility consists almost entirely of single-family homesteads along rural roads.

Construction and operation of the proposed Facility will not result in any impacts to the following land uses: urban, manufacturing and commercial, mining, recreational, transport, utilities, or water and wetlands. Construction of the Facility will involve the leasing of private land, collectively comprising approximately 12,750 acres. This land is currently being used almost exclusively for agricultural purposes. While both temporary impacts and permanent impacts to land use could occur, these changes will affect a very small percentage of leased lands, and the Facility has been designed to be compatible with the agricultural land uses that dominate the Project area.

3059952v6 4906-17-05 121 NORTHWEST OHIO WIND ENERGY, LLC Movements of construction equipment and transportation of material could impact growing crops, fences and gates, subsurface drainage systems (tile lines), and/or temporarily block farmers' access to agricultural fields. However, construction impacts will be temporary in nature, and confined to the properties of participating landowners. As described in the Section 4906-17-08(F)(2)(b), Ap- plicant has developed construction specifications for construction activities occurring partially or wholly on privately owned agricultural land. These specifications, along with special siting considerations, will minimize impacts to agricultural land uses in the Project area.

Only very minor changes in land use are anticipated within the Project area as a result of Facility operation. The presence of the turbines bases, step-up facility, and other ancillary structures will result in the cumulative conversion of approximately 48.7 acres of land from its current use to build facilities (approximately 0.38% of the 12,750 acres of leased land). During Facility operation, additional impacts over the years on land use should be infrequent and minimal. Aside from occasional maintenance and repair activities, Facility operation will not interfere with on-going farming activities.

(e) Identification of Structures to be Removed or Relocated

The construction of the Facility is not expected to require the removal or reloca- tion of any existing structure.

(f) Plans for Future Use

There are no known formally adopted land use plans for Paulding County.

(g) Concurrent or Secondary Uses

Applicant has no plans for concurrent or secondary uses of the site. However, because wind power projects are compatible with agricultural practices, and because this Facility has been sited and designed to maximize such compatibility, existing land uses will continue concurrently with Facility operation.

3059952v6 4906-17-05 122 NORTHWEST OHIO WIND ENERGY, LLC (2) Economics

Information provided in this section was obtained primarily from Assessing the Econom- ic Impacts of Timber Road II Wind Farm, a report prepared by Camiros, Ltd. (2010). In their evaluation of economic impacts, Camiros used the Job and Economic Development Impact Wind Model (JEDI), specifically designed to assess economic impacts of wind powered electric generation facilities. The model was developed in 2002 for the National Renewable Energy Laboratory, under the auspices of the U.S. Department of Energy's "Wind Powering America" project. Originally developed with state-specific parameters, subsequent refinements make it possible to analyze impacts on regional and county level economies. Using this information, an input-output model with data specific to Ohio and the local economy was used to estimate the economic impacts of the Facility. The model evaluates both the construction phase of the Facility, and the ongoing operations and maintenance phase of the Facility.

(a) Estimated Payroll

Construction of the Facility will take approximately 8 months. The size of the construction crew will vary based on weather conditions and the stage of construction. Over the construction period, there are generally three phases. The first and last phases typically call for smaller construction crews, while the peak phase of construction requires a full complement of employees working on-site. Appli- cant’s policy is to maximize the number of local workers, subject to the nature of the construction process. It is expected that approximately half of all workers will be hired locally, including managers, technicians, and administrative staff. The remaining workers, those who have specialized skills in constructing wind farms, will likely come from other locations. Construction of the Facility will employ a total work force of approximately 125-150 employees over the 8-month period. Payroll for these workers is anticipated to be approximately $6.35 million.

Once the Facility is operational, wages and salaries from new jobs will continue to add to the local economy. Operations and maintenance of the Facility will create approximately 14 new full-time jobs in the local economy, totaling about

3059952v6 4906-17-05 123 NORTHWEST OHIO WIND ENERGY, LLC $540,000.00 in wages and salaries. Approximately 6 of these new jobs will directly support the operations of the Facility, and earnings from those jobs will total about $320,000.00.

(b) Estimated Employment

Jobs created by the Facility will include workers who will be directly employed to construct and subsequently operate and maintain the Facility. It is expected that approximately half of all workers will be hired locally, including managers, technicians, and administrative staff. The remaining workers, those who have specialized skills in constructing wind farms, will likely come from other locations. Construction of the Facility will employ a total work force of approximately 125- 150 employees over an 8-month period. In addition, approximately 7 other jobs will be created that play a supportive role. The increased wealth from jobs and spending will have a ripple effect in the local economy thereby creating the need for additional jobs in the area, as the wages of the locally based workers go toward the support of households and local businesses.

During the construction phase of the Facility, approximately 132-157 full-time jobs will be created in the local economy, generating about $6.9 million in wages and salaries. As indicated above, approximately 125-150 of these new jobs will be in those industries that directly support the Facility, and earnings from those jobs are expected to total about $6.35 million. Another 7 jobs and $0.55 million in earnings are expected to be generated by the indirect impacts, which result from the inter-industry economic activity created by the Facility. The induced impacts, which result from changes in local household spending, will bring another estimated 101 jobs and approximately $3.93 million in wages and salaries to the local economy. These figures were calculated using the National Renewable Energy Laboratory’s (NREL) Joint Economic Development Impact (JEDI) model for on- shore wind energy development, release W1.10.03.

Once operational, the Facility is expected to employ 6 full-time workers. These positions will consist of an operations manager/supervisor, operations and

3059952v6 4906-17-05 124 NORTHWEST OHIO WIND ENERGY, LLC maintenance technicians, parts/logistics personnel, and customer service repre- sentatives. Total wages for the Facility’s full-time employees are estimated to be approximately $320,000 per year.

The Facility will have a positive impact of $9,000.00 per megawatt on the local tax base, including local school districts and other taxing districts that service the Facility’s area. Taxing districts within the Project area include Paulding County, Blue Creek Township, Latty Township and Wayne Trace School District. Agree- ments regarding tax or payment in lieu of taxes are currently being negotiated, so no values are available to report at this time. It is important to note the Facility will make few, if any, demands on local government services. Therefore, payments made to local governments will be net positive gains and represent an important economic benefit to the local area.

(d) Estimated Economic Impact

Wind power development can expand the local economy through ripple effects. Ripple effects stem from subsequent expenditures for goods and services made by first-round income from the development. A direct effect or impact arises from the first round of buying and selling. Direct effects include the purchase of inputs from local sources, the spending of income earned by workers, annual labor revenues, and the income effect of taxes. These direct effects can be used to identify additional, subsequent rounds of buying and selling for other sectors and to identify the effect of spending by local households. The indirect effect or impact is the increase in sales of other industry sectors in the region, which include further round-by-round sales. The induced effect or impact is the expenditures generated by increased household income resulting from direct and indirect effects. The total effect or impact is the sum of the direct, indirect, and induced effects (NWCC, 2004b).

Utilizing NREL’s JEDI model referenced above, 330 jobs will be created in the turbine and supply chain process during construction, resulting in earnings of

3059952v6 4906-17-05 125 NORTHWEST OHIO WIND ENERGY, LLC $15.15 M. An additional 101 jobs will be created through induced impacts with earnings of $3.93 M. During the operation of the Facility and in addition to the 6 direct onsite jobs, and additional 22 jobs will be created through local revenue, supply chain impacts and induced impacts resulting in earnings of $0.9 M.

The Facility will have a beneficial impact on the local economy, both during construction and over the life of the Facility. In addition to the jobs created during construction and the wages paid to the work force, the Facility will have a direct economic benefit from the first round of buying and selling, which includes the purchase of goods from local sources (such as concrete, gravel and fuel), the spending of income earned by workers, annual labor revenues, and the income effect of taxes. These direct effects will result in additional, subsequent rounds of buying and selling in other sectors. In addition, local governments will see net gains in revenue for a period of 30 years, and participating landowners will re- ceive revenue from lease and participation payments.

Annual lease payments will be provided to local landowners participating in the Facility through a Land Lease and Wind Easement and to those landowners participating through a wind project participant agreement, which will provide annual payments to those who live near a turbine and choose to participate in the Fa- cility. These annual payments are estimated to be $460,000 on year one of operation, and then escalated per the consumer price index.

The lease and participant payments are a direct financial benefit to all participating landowners, and will enhance the ability of those in the agricultural industry to continue farming. Like other local expenditures, the lease and participation payments will also enhance the ability of participating landowners to purchase additional goods and services. To the extent that these purchases are made locally, they will have a broader positive effect on the local economy.

3059952v6 4906-17-05 126 NORTHWEST OHIO WIND ENERGY, LLC (3) Public Services and Facilities

The Facility is not expected to have significant growth-inducing effects on the surrounding communities. Therefore, no significant impact on local public services and facilities is expected.

Wind farms generally are very low incident and accident facilities. Applicant expects virtually no additional impact to local emergency services. The Facility will hire experienced workforce and/or train inexperienced employees in appropriate safety techniques. Continuing safety training will be in place during the operation of the Facility. The Facil- ity will be furnished with diverse safety equipment and such equipment will be replaced before the end of the useful life.

Local emergency services personnel already benefit of training from the adjacent wind farms. Further, Facility’s staff will continue such training and provide specific addresses and routes for each piece of Facility’s equipment. Facility’s staff will provide staff’s emergency contacts and special medical histories to emergency services personnel’s files. Facility’s staff will provide access to the O&M facility to local emergency services personnel.

In case of an emergency, the Facility will be furnished with conventional wired telephones and telephone lines, cordless telephones, state-of-the-art smart mobile telephones, radios and internet to immediately contact local emergency services. Staff will be trained to remain calm, provide specific and pertinent information about the incident, to follow emergency personnel instructions and to fully collaborate with such personnel, including the lending of vehicles and equipment if necessary to aid in the emergency.

Workers will commute to the work site on a daily basis. Local employees would be hired to the extent possible. Hiring of non-resident workers would occur only when local residents with the required skills were not available or competitive. It is expected that non- resident temporary construction workers would commute or stay in regional transient housing or motels, and not require new housing and most would not bring families that might require family healthcare or additional school facilities. The principal impact on

3059952v6 4906-17-05 127 NORTHWEST OHIO WIND ENERGY, LLC public services in the site locale would be a temporary increase in traffic on roads leading to the site, due to deliveries of equipment and materials during construction.

Applicant will coordinate with the appropriate authority regarding any temporary or permanent road closures, lane closures, road access restrictions, and traffic control necessary for construction and operation of the proposed facility. Coordination shall include, but not be limited to, the county engineer, Ohio Department of Transportation, local law enforcement, and health and safety officials. This coordination will be detailed as part of a final traffic plan submitted to OPSB Staff prior to the preconstruction conference for review and confirmation that it complies with the applicable CECPN condition.

Applicant will provide the final delivery route plan and the results of any traffic studies to OPSB Staff and the Paulding County Engineer 30 days prior to the preconstruction conference. Applicant will complete a study on the final equipment delivery route to determine what improvements will be needed in order to transport equipment to the Facility construction sites. Applicant will make all improvements outlined in the final delivery route plan prior to equipment and wind turbine delivery. Applicant’s delivery route plan and subsequent road modifications will include, but not be limited to, the following:

a) A survey of the final delivery routes to determine the exact locations of vertical constraints where the roadway profile will exceed the allowable bump and dip specifications and outline steps to remedy vertical constraints.

b) Identification of locations along the final delivery routes where overhead utility lines may not be high enough for over-height permit loads and coordinate with the appropriate utility company if lines must be raised.

c) Identification of roads and bridges which are unable to support the projected loads from delivery of the wind turbines and other facility components and describe arrangements to make all necessary upgrades.

d) Identification of locations where wide turns would require modifications to the roadway and/or surrounding areas and make all necessary alterations. Any

3059952v6 4906-17-05 128 NORTHWEST OHIO WIND ENERGY, LLC alterations for wide turns will be removed and the area restored to its preconstruction condition unless otherwise specified by the Paulding County Engineer.

As set forth in the “Agreement for Use, Repair, and Improvement of Roads”, currently under negotiation between Applicant and the Paulding County Engineer, Applicant will repair damage to government-maintained (public) roads and bridges caused by construction or maintenance activity. Any damaged public roads and bridges will be repaired promptly to their previous condition by Applicant under the guidance of the appropriate regulatory agency. Any temporary improvements shall be removed unless the County Engineer requests that they remain. Applicant will provide financial assurance to the county that it will restore the public roads it uses to their condition prior to construction or maintenance. Applicant will execute the Agreement for Use, Repair, and Improvement of Roads with Paulding County prior to construction and subject to OPSB Staff review and confirmation that it complies with the applicable CECPN condition. The Agreement for Use, Repair, and Improvement of Roads will contain provisions for the following:

a) A preconstruction survey of the conditions of the roads.

b) A post-construction survey of the condition of the roads.

c) An objective standard of repair that obligates Applicant to restore the roads to the same or better condition as they were prior to construction.

d) A timetable for posting of the construction road and bridge security prior to the use or transport of heavy equipment on public roads or bridges.

(4) Impact on Regional Development

(a) Description

This section provides a summary overview of the potential impacts the Facility may have on local and regional residential, commercial, and industrial development as well as local and regional transportation system development.

i. Housing

3059952v6 4906-17-05 129 NORTHWEST OHIO WIND ENERGY, LLC The cumulative population of the townships within five miles of the Facility is projected to decrease from 17,572 in 2000 to approximately 16,430 by 2020. The townships are projected to experience a net loss in population of approximately 1,142 by 2020. Given population decline estimates, an average housing vacancy rate of 11.2% within the region, and an unemployment rate of 6.5% in Paulding County, it is unlikely that demand for housing will significantly increase due to the construction or operation of the Facility. While the Facility will result in a substantial increase in temporary jobs during its construction phase, these jobs are short term in nature and will not have an impact on demand for new housing development over the long term. Permanent jobs created as a result of the Facility will not have an appreciable effect on housing demand within the region.

ii. Commercial and Industrial Development

The construction and operation of the Facility will have a positive impact on commercial and industrial development in Paulding County, as well as throughout northwest Ohio and the entire State. Following is a summary of the positive impacts on commercial activity. More comprehensive explanations are described above in Section 4906-17-08(C)(2).

It is expected that approximately half of all workers will be hired locally, including managers, technicians and administrative staff. Construction of the Facility will employ approximately 125-150 workers over an 8-month period. Payroll is anticipated to be approximately $6.35 million. And approximately 7 other jobs will be created in a supportive role to bring the overall wages to $6.9 million.

Operations and maintenance of the Facility will create approximately 14 new full- time jobs in the local economy, totaling about $540,000.00 in wages and salaries. Approximately 6 of these new jobs will directly support the operations of the Fa- cility, and earnings from those jobs will total about $320,000.00.

Three Hundred and Thirty jobs will be created and/or maintained in the turbine and supply chain process during construction, resulting in earnings of $15.15 mil-

3059952v6 4906-17-05 130 NORTHWEST OHIO WIND ENERGY, LLC lion. Approximately 101 jobs will be created from changes in local household spending with earnings of $3.93 million. (Calculation using NREL’s Joint Eco- nomic Development Impact model.)

The Facility will have a direct economic benefit from the first round of buying and selling goods from local sources (such as concrete, gravel and fuel), the spending of income earned by workers, annual labor revenues, and the income effect of taxes. These direct effects will result in additional, subsequent rounds of buying and selling in other sectors. Local governments will see net gains in revenue for a period of 30 years.

Annual lease payments will be paid to landowners through a Land Lease and Wind Easement and through a wind project participant agreement, which will provide annual payments to those who live near a turbine and choose to participate in the Facility. These annual payments are estimated to be $460,000 on year one of operation.

The lease and participant payments are a direct financial benefit to all participating landowners, and will enhance the ability of those in the agricultural industry to continue farming. Like other local expenditures, the lease and participation payments will also enhance the ability of participating landowners to purchase additional goods and services. To the extent these purchases are made locally, they will have a broader positive effect on the local economy.

In terms of industrial development, wind power projects typically require a substantial number of inputs from outside the local area, as is the case with the proposed Facility. These inputs from outside the local area may be turbines, blades, transformers, high-voltage copper cables, special cranes, etc. However, there is

3059952v6 4906-17-05 131 NORTHWEST OHIO WIND ENERGY, LLC substantial growth potential in Ohio for renewable energy production and the manufacturing sectors that support it, according to a 2012 report by the National Resources Defense Council (NRDC) entitled “At Wind Speed: How the U.S. Wind Industry is Rapidly Growing Our Local Economies”. Job creation in the manufacturing sector will include those companies already involved in wind infrastructure production.

The NRDC report more closely examined the Canton, OH and Stark county area and assessed the current state of manufacturing and labor related to the wind industry. There are 19 companies directly involved in the wind energy supply chain with thousands of employees, many of which are highly paying professional and engineering positions. Through the industry partnership with Stark State College and the founding of the $11.8 M Wind Energy Research and Development Center, new wind turbine technicians are trained and those average salaries in the Canton area are $86,350 with starting salaries at $71,100.

While difficult to gauge the Facility’s exact impact on job creation and investment, and additional report by the NRDC in 2012 entitled “American Wind Farms: Breaking Down the Benefits from Manufacturing to Production” estimates that a wind farm of 250 MWs will create 1,079 jobs over the lifetime of the project. If this formula were applied to the 100MW Facility, approximately 432 jobs would be created or maintained over the lifetime of the Facility. Because Ohio already has wind turbine manufacturing infrastructure in place, the state is poised to benefit from such job creation.

iii. Transportation System Development

Due to the rural nature of Project area and surrounding areas, public transportation is not widely available and residents must rely heavily on personal automo- bile travel. This is accomplished through a network of interstate, U.S, and state highways, as well as county and township roads. This existing roadway network provides access to the Fort Wayne, Indiana metropolitan area, as well as to nearby smaller communities, including Paulding, Antwerp, Defiance, Lima, and Van 3059952v6 4906-17-05 132 NORTHWEST OHIO WIND ENERGY, LLC Wert, Ohio and Woodburn and Monroeville, Indiana. There are three interstate highways serving the greater region, the nearest being 1-69/469 to the west in Fort Wayne. Interstate 90/80 to the north and 1-75 to the east also serve the region. The Project area is also served by U.S. Routes 24, 30, 127, and State Routes 49, 111, 114, 500, and 613. Given the limited population and the existence of alternate routes around the proposed project site, temporary road closures during construction are not expected to create any significant adverse impacts on the vehicular transportation network.

Two rail lines located in the vicinity of the Facility provide the area with freight access to and from various regional locations. The Maumee & Western Railroad runs north of the site through Defiance County, while the Norfolk Southern is an east-west route located south of the Project area. Neither construction nor operation of the Facility is expected to create any significant adverse impacts on the existing railroad network, although both rail lines will be consider as part of the delivery route plan.

There are three airports located within 20 miles of the proposed Facility: Paulding Airport, Defiance County Regional Airport, and Fort Wayne International Air- port. Paulding Airport is a 29-acre, privately owned, airport located approximately 7 miles east of the Facility, north of the Village of Paulding. Defiance County Regional Airport, is a publicly owned, 314-acre airport located outside the Village of Defiance, approximately 20 miles northeast of the proposed Facility. These small regional airports are used primarily for private recreational travel. In addition, the Fort Wayne International Airport is located approximately 20 miles west of the proposed Facility.

Applicant will meet all recommended and prescribed FAA and ODOT Office of Aviation requirements to construct an object that may affect navigable airspace. This includes submitting coordinates and heights for all towers exceeding 200 feet AGL for ODOT Office of Aviation and FAA review prior to construction, and the non-penetration of any FAA Part 77 surfaces.

3059952v6 4906-17-05 133 NORTHWEST OHIO WIND ENERGY, LLC The FAA conducted aeronautical studies of a final turbine layout as filed in this application under the provisions of Title 49 of the U.S. Code, Section 44718, and applicable Title 14 of the Code of Federal Regulations, part 77. These aeronautical studies concluded the turbines in the final layout do not exceed obstruction standards and will not be a hazard to air navigation (Appendix P).

All applicable structures, including construction equipment, will be lit in accordance with FAA circular 70/7460-1 K Change 2, Obstruction Marking and Light- ing; or as otherwise prescribed by the FAA. This includes all cranes and construction equipment.

Within 30 days of construction completion, Applicant will file the as-built transmission structure coordinates and heights (AGL) with the Ohio Office of Aviation and Federal Aviation Administration.

(b) Compatibility

The State of Ohio does not mandate comprehensive planning, and no adopted land use plans currently exist for Paulding County. The Facility is compatible with the existing agricultural land uses within the Project area.

(D)CULTURAL IMPACT

Data pertaining to historic and prehistoric cultural and archaeological resources was compiled by Westwood and drafted into report form (Sather, et.al. 2013). Full copies of the prepared reports for both archaeological and architectural surveys are included in Appendices Q and R.

(1) Map of Landmarks of Cultural Significance and Recreational Areas

On March 4, 2013 Westwood cultural resource scientist Abraham Ledezma Martinez conducted a review of the records located on the Ohio Historic Preservation Office Online Mapping System to identify any previous surveys and inventory previously documented cultural resources within or surrounding the Project area. Archaeological data was collected for the Project area and a one-mile buffer. Architectural data was collected for the Project area and a five-mile buffer. The background search identified three previ-

3059952v6 4906-17-05 134 NORTHWEST OHIO WIND ENERGY, LLC ous surveys, 37 archaeological sites, and 11 historic architectural resources within the Project area and defined buffers.

Archaeological Sites:

Of the 37 archaeological sites identified, eight are located within the Project area and 29 are located within the surrounding one-mile buffer. Twenty-eight of the sites are recorded as prehistoric, eight are recorded as historic, and five contain both prehistoric and historic components. None of the previously identified sites have been evaluated for listing on the National Register of Historic Places (NRHP).

As of May 20, 2013 the archaeological investigations identified 13 previously unrecorded prehistoric period sites and relocated the single previously recorded site located within the Project area. Nine of the sites consist of isolated finds (single artifacts) and the other five consist of lithic scatters. With the exception of site 33-PA-299 that will marked for avoidance as it may be potentially eligible for listing on the National Register of Historic Places (NHRP), no other sites identified to date are considered significant and, therefore, not eligible for listing on the NHRP. A summary of the archaeological investigations is provided in Appendix Q.

Architectural Investigations:

All previously documented historic architectural/standing structure resources are located outside of the Project area but within a five-mile buffer. None of the historic architectural resources have been evaluated for listing on the NRHP. A summary of these resources is provided in Table 8-10.

Table 8-10: Historic Architectural/Standing Structure Resources Within the Project area and Five-Mile Buffer Structure Project/ Number Name Twp Rng Sec Buffer PAU0000309 Roy Green House 1N 2E 20 Buffer Alfred and Henry PAU0000409 1N 2E 26 Buffer Sherer’s House Hines District School PAU0003205 2N 2E 22 Buffer No 1 3059952v6 4906-17-05 135 NORTHWEST OHIO WIND ENERGY, LLC Table 8-10: Historic Architectural/Standing Structure Resources Within the Project area and Five-Mile Buffer Structure Project/ Number Name Twp Rng Sec Buffer PAU0034106 Smith Property 2N 3E 27 Buffer PAU0034206 McCabe Property 2N 3E 35 Buffer Renville or Hardesty PAU0038205 2N 2E 29 Buffer Farmstead Little Auglaize Aque- PAU0000707 2N 4E 33 Buffer duct St John the Baptist PAU0005008 1N 1E 3 Buffer Catholic Church Middle Creek Zion PAU0005311 1N 4E 21 Buffer Baptist Church PAU0005411 Aaron Bidlack House 1N 4E 21 Buffer Helen and Catherine VAN000170 1S 3E 5 Buffer Lindsay House VAN000780 Grand Victory Church 1S 3E 17 Buffer

(2) Estimated Impact on Landmarks

While Applicant will attempt to avoid archaeological sites and historic resources, the construction activities for the Facility have the potential to impact such resources or to add to the adverse visual impacts in the region of the Project area. In the event an impact would occur, Applicant will determine the nature of the impact and consult with the Ohio Historic Preservation Office (OHPO) on whether or not the resource is eligible for listing in the NRHP.

Mitigation:

Prior to commencement of construction, Applicant will develop a cultural resource avoidance plan in consultation with OPSB Staff and the OHPO, detailing procedures for flagging and avoiding all potentially NRHP-eligible archaeological sites in the Project area. The avoidance plan will also contain measures to be taken should previously- unidentified archaeological deposits or artifacts be discovered during construction of the project. Applicant will attempt to avoid impacts to identified archaeological and historic resources to the extent possible. If archaeological or historic resources are found during

3059952v6 4906-17-05 136 NORTHWEST OHIO WIND ENERGY, LLC cultural resource investigations or during construction, the integrity and significance of such resources will be addressed in terms of the site’s potential eligibility to the NRHP. Also, an assessment of the Facility’s potential impacts upon the resource will be under- taken. If such resources are found to be eligible for the NRHP, adverse effects to the resource will be avoided by adjustment of the array when possible. If avoidance is not possible, appropriate mitigation measures will need to be developed in consultation with OHPO, the State Archaeologist, and consulting American Indian communities. While avoidance would be a preferred action, mitigation for Project-related impacts on NRHP- eligible archaeological and historic resources may include additional documentation through data recovery.

Should previously unknown archaeological resources or human remains be inadvertently encountered during construction and/or operation, the discoveries will be reported to the OHPO. With regard to a discovery of human remains, procedures would be followed to ensure that the appropriate authorities would become involved quickly and in accordance with local and state guidelines.

(3) Consideration of Landmarks

Landmarks to be considered for purposes of this rule are those districts, sites, buildings, structures, and objects which are recognized by, registered with, or identified as eligible for registration by the national registry of natural landmarks, the Ohio Historical Society, or the Ohio Department of Natural Resources.

(4) Mapping Landmarks

See Figure 8-1.

(5) Recreational Areas

See Figure 8-1

(6) Visual Impacts

Mitigation options for potential visual impacts are limited, given the nature of the Facili- ty and siting criteria (tall structures located in open fields).

3059952v6 4906-17-05 137 NORTHWEST OHIO WIND ENERGY, LLC As described in 4906-17-08(B)(1)(a), land use in the Project area is predominantly agricultural and has overall low-density development and has active large wind farms to both the south and west. There are few water features and woodlots in the Project area and no managed lands within the Project area or one-half mile of its boundaries.

Applicant will minimize visual impacts by applying turbine uniformity (same model, height and rotor diameter), least number of turbines to reach the desired nameplate, same white turbine coloration (which blends well with the sky at the horizon and eliminates the need for daytime FAA warning lights), turbine alignment (so when viewed from certain angles, only the most forward turbine can be seen), placing much of the electrical collection system underground, not constructing new above ground transmission lines, siting the step-up facility behind and adjacent to the already-existing AEP 138kV substation, minimizing the number of gates and fences, blending the O&M facility, if new, with already-existing farming facilities, minimizing the number of and synchronizing the FAA nighttime warning lights, and prohibiting signage on the turbines.

Applicant will late-file a detailed visual impact assessment, to be incorporated as Appen- dix S. The independent consulting firm CH2MHILL is performing the assessment. The assessment’s scope of study includes the following:

" GIS viewshed analysis to determine areas within a 5-mile radius of the Project area within the viewshed of proposed wind turbines. Areas obscured by topography or vegetation will not be within the viewshed. " Review and comment of viewshed maps by Applicant and OPSB staff. This review resulted in developing the best Key Observation Points (KOPs) for fieldwork and photo-simulations. " Fieldwork to collect photographs and sub-meter accurate GPS points. " Review of photographs by Applicant to select final KOPs for use in preparing photo- simulations. " Preparation of photo-simulations from final KOPs, preparation of visual assessment report text, and finalization of report mapping.

3059952v6 4906-17-05 138 NORTHWEST OHIO WIND ENERGY, LLC No adverse visual impacts to archaeological or historical landmarks are anticipated from construction and operation of the Facility. A Phase I cultural reconnaissance survey, which assesses the direct and indirect effects of the Facility. is available as Appendix Q. No specific mitigation measures are anticipated at this time.

(E) PUBLIC RESPONSIBILITY

(1) Public Information Program

(a) Local Office and Staff

Applicant has maintained a local office continuously since 2009 at the following address and contact information:

Northwest Ohio Wind Energy, LLC 101 South Main Street P.O. Box 105 Grover Hill, Ohio 45849 Phone: 419-587-3620 Email: [email protected]

This office is open from 9.a.m to 5 p.m. on business days.

Most of Applicant’s public information program has been in the form of local contacts from this office, which has been continuously staffed since its opening by Mr. Brad Norden, Field Specialist. During more intensive leasing activity during the early years of development, the office employed additional field specialists. At this time, Mr. Norden is the only permanent person at this office.

(b) Local Advisory Board

The Local Advisory Board consists of six local farmers and participating landowners who assist Applicant in project decision-making and facilitating communication with other project participants and the community as a whole. The Local Advisory Board has convened meetings on an as-needed basis throughout the life of the Facility’s development, but no less than four times a year. 3059952v6 4906-17-05 139 NORTHWEST OHIO WIND ENERGY, LLC (c) Landowner and Community Meetings

Over the course of the Facility’s development, Applicant’s field specialists in Grover Hill have arranged and participated in hundreds of one-on-one meetings with landowners and local decision-makers. In addition, Applicant has arranged numerous public information events for landowners and the community to invite participation in the Facility and provide updates on development progress. These public information events are summarized as follows:

3/05/09 – Public community meeting held at Paulding County Fairground in Paulding, OH to provide informational about the Facility.

6/16/09 – 6/20/09 – Rented booth at Paulding County Fairgrounds in Paulding to provide public with information and answer questions about the Facility.

9/1/09 – Public community meeting at Trinity Friends Church in Van Wert, OH to provide information about the Facility.

8/31/09 – 9/04/09 – Rented booth at Van Wert County Fair in Van Wert to provide public with information and answer questions about the Facility.

9/25/09 – Neighborhood meeting at Applicant’s office in Grover Hill to answer questions from local community members about the Facility.

10/29/09 – Landowner meeting at Grover Hill office to provide Facility update to landowners.

12/11/09 – Christmas open house at Grover Hill office which included an all-day Christmas brunch for local citizens and landowners.

2/11/10 – Landowner meeting at Wayne Trace High School, Haviland, OH to provide Facility update for landowners.

3/10/10 – Neighborhood meeting at Grover Hill office to provide Facility update and answer questions from public about the Facility.

3059952v6 4906-17-05 140 NORTHWEST OHIO WIND ENERGY, LLC 4/29/10 – Pre-application meeting at Grover Hill office with OPSB, ODNR Divi- sion of Fish and Wildlife and OEPA to introduce Applicant’s Facility and tour the Facility’s footprint.

6/14/10 – 6/19/10 – Rented booth at Paulding County Fair in Paulding to provide public with information and answer questions about the Facility.

7/22/10 – Landowner meeting at Paulding County Fairgrounds to provide Facility update for landowners.

8/30/10 – 9/3/10 – Rented booth at Van Wert County Fair in Van Wert to provide public with information and answer questions about the Facility.

11/9/10 – 11/10/10 – Landowner meetings held at Marsh Hotel in Van Wert to in- form landowners about lease and land trade between Iberdrola and Applicant.

12/10/10 – Christmas Open House at Grover Hill office which included an all-day Christmas brunch for local citizens and landowners.

1/28/11 – Landowner meeting at Grover Hill office to provide Facility update for landowners.

11/7/11 – Landowner meeting at Grover Hill office to provide Facility update for landowners.

1/19/12 – Landowner meeting at Paulding County Fairgrounds to provide Facility update for landowners.

11/6/12 – 11/9/12 – Numerous one-on-one interactions landowners during pre- design geotechnical exploration.

11/8/12 – Meeting with Paulding County Engineer Office in Paulding to discuss Applicant’s Facility plans with County Engineer.

12/4/12 – Landowner Meeting at Paulding County Fairgrounds to provide Facility update for landowners. 3059952v6 4906-17-05 141 NORTHWEST OHIO WIND ENERGY, LLC 12/5/12 – Meeting with Blue Creek and Latty Township Trustees at Grover Hill office to update Trustees on status and answer Facility-related questions.

2/28/13 – Meeting and supper with Local Advisory Board to discuss Facility’s progress.

3/18/13 – Meeting and supper with Local Advisory Board to discuss Facility’s progress.

4/9/13 – Meeting with Blue Creek and Latty Township Trustees and Paulding County Engineer at Paulding County Engineer Office to initiate discussion regarding construction haul road routes and procedures.

4/9/13 – Open-door OPSB Facility Public Informational Meeting at Wayne Trace High School to present and answer numerous procedural, technical, permitting and environmental questions to landowners and regional stakeholders.

5/9/13 – Numerous one-on-one interactions landowners during micrositing.

6/18/13 – Landowner/Investor information meeting at Wayne Trace Junior-Senior High School to update participants on Facility progress and answer Facility- related questions.

(d) Project Newsletters and Mailings

Since 2009, Applicant has issued 10 project newsletters and topic-specific mailings to project participants to update them on project progress and milestones.

(e) Project Website

Since 2009, Applicant has maintained a Facility-specific website at the following URL to keep the public informed about developments, contact information, meeting notices, Advisory Board, photos, etc:

http://www.northwestohiowind.com/

3059952v6 4906-17-05 142 NORTHWEST OHIO WIND ENERGY, LLC (f) Landowner Participation in Micrositing

Throughout the development and design of the Facility, Applicant has sought input from affected landowners regarding issues of concern and siting of infrastructure. This process culminated during infrastructure micrositing in May of 2013. As part of the micrositing process, affected landowners were supplied with maps of their parcels, depicting proposed locations of turbines, access roads, underground electrical system and crane paths. Landowners were asked to mark up these maps with suggested refinements or contact the local Field Specialist regarding their desires. To the degree possible, landowner preferences were incorporated into the design depicted in the Facility layouts accompanying this application. At the landowner meeting held on June 18, 2013, several landowners expressed appreciation for the opportunity to suggest refinements to infrastructure placement.

(g) Future Public Information Programs

In addition of keeping the Grover Hill office staffed during regular business hours throughout the development and construction of the Facility, Applicant plans to meet monthly with stakeholders. These meetings will happen at different venues and hours that suit the local activities, for example, harvest, holidays, etc. Each month, Applicant will meet with landowners or Township Trustees or the Local Advisory Board. The next such meeting is scheduled for the evening of July 22nd. Applicant plans to continue to deliver newsletters with diverse information about the Facility.

Once the Facility is operational, Applicant will maintain a staffed O&M facility within the Project area. Such facility and staff will remain available during regular business hours and accommodate, to the extent possible, unscheduled and schedule visits from landowners, neighbors, governmental employees, visitors, etc. The Facility and staff will be accessible via office telephones, mobile telephones, email and facsimile. It is customary for wind farms to host annual open houses so the public can ask questions and express opinions about wind farms. Wind farms 3059952v6 4906-17-05 143 NORTHWEST OHIO WIND ENERGY, LLC often also participate in community activities such as ground fairs and charitable and sporting events. It is likely the Facility’s staff will continue with such a tradi- tion to the extent possible within their work schedule.

(h) Local Media, Local Government and Elected Officials

Applicant has been and will continue to be engaged with the local media, whether being available for interviews or providing material for stories.

Applicant has met regularly with state, county and township employees and elected officials during the development of the Facility. Once the Facility is operational, Applicant will be required to provide various reports and updates to governmental agencies. Applicant will remain available during regular business hours and accommodate, to the extent possible, unscheduled and schedule visits from governmental employees and elected officials. Applicant will be accessible via office telephones, mobile telephones, email and facsimile.

(2) Liability Insurance

Applicant will, of its own expense, maintain a broad form commercial general liability policy of insurance which protects against claims of loss or liability caused by Applicant or its agents occupation and use of, and activities on, the Facility, in an amount not less than three million dollars ($3,000,000.00) of combined single limit coverage per occurrence, accident or incident. Upon request by landowners, Applicant will deliver a certificate of such insurance to the requesting landowner.

To the extent that public roads will be utilized and potentially damaged resulting from construction related traffic, Applicant will work with the necessary county representa- tives to ensure that such damage is repaired. Applicant will complete a detailed engineering report prior to construction to estimate the capacity of the existing roads. A bond or other similar surety will be established through the pertinent County Engineer’s office to provide adequate funds to repair any damage to public roads.

3059952v6 4906-17-05 144 NORTHWEST OHIO WIND ENERGY, LLC (3) Evaluation of Interference with Radio and Television

As part of the preliminary design process, Applicant contracted with Comsearch to conduct an analysis of the potential impacts of the proposed Facility on microwave systems, radio broad-cast stations (AM/FM), off-air television stations, and cellular and personal communication systems. Results of the analysis are described below. Comsearch reports are included in Appendix T.

i. Microwave

Microwave telecommunication systems are wireless point-to-point links that communi- cate between two antennae and require clear line-of-sight conditions between each antenna. The Comsearch analysis performed in March 2013 identified 29 microwave paths within the Project area. Applicant will avoid impacts to the microwave paths by locating turbines outside of the microwave paths and their associated Fresnel Zones.

ii. Radio

The analysis by Comsearch in March 2013 identified two AM station records (one station with both a day and night licensure) within 30 kilometers (or 19 miles) of the Facility. All of the identified stations are currently operational. Conflicts with AM coverage generally only occur when stations with directive antennae are within 3.2 kilometers (or 2 miles) of a turbine or stations with non-directive antennae are within 0.8 kilometers (or ½ mile) of a turbine. The one AM station identified within the vicinity has a non-directive antenna and is located in excess of 11 kilometers (or 7 miles) of the Project area. No impact on AM coverage is expected.

The analysis also identified six FM station records within 30 kilometers (or 19 miles) of the Facility. All of the identified stations are currently operational. Conflicts with FM coverage generally only occur when stations are within 4 kilometers (or 2.5 miles) of a turbine. One FM station, WKSD, is near the center of the Project area. The possible conflict with WKSD could be mitigated through moving the station antenna outside of the area of impact or increasing the station signal strength. Applicant will coordinate with WKSD to mitigate any impacts to its signal.

3059952v6 4906-17-05 145 NORTHWEST OHIO WIND ENERGY, LLC iii. Television

Off-air stations are television broadcasters that transmit signals that can be received from terrestrially located broadcast facilities by a standard over-the-air television receiver. The analysis by Comsearch in March 2013 identified 105 off-air stations within 150 kilometers (or 93 miles) of the Project area. Those stations within 65 kilometers (or 40 miles) are more likely to provide coverage to the Project area. The analysis indicated that 47 stations are located within 65 kilometers (or 40 miles) of the Project area.

Only 19 of the 47 stations within 65 kilometers (or 40 miles) are operating. Ten of the stations are translators or low-power broadcast stations. The remaining nine are full- power broadcast stations. The nine full-power stations could have their reception degrad- ed on the side of the Facility opposite the station. No individual or community should lose all of their television coverage, but some channels may be lost by the construction of the Facility. Possible mitigation would be to offer cable or direct broadcast satellite services to those individuals who can demonstrate that their television reception was inter- rupted following construction of the turbines.

iv. Cellular and Personal Communication Systems

Applicant notified the National Telecommunications and Information Administration (NTIA) of the U.S. Department of Commerce (USDOC) of the proposed Facility on April 16, 2013. Following the receipt of this notification, the NTIA distributed preliminary plans for of the Facility to the federal agencies included in the Interdepartment Ra- dio Advisor Committee. The results of the NTIA study will be supplied to the OPSB immediately upon receipt.

3059952v6 4906-17-05 146 NORTHWEST OHIO WIND ENERGY, LLC (4) Evaluation of Interference with Military Radar

Applicant notified the NTIA of the proposed Facility on April 16, 2013. Following the receipt of this notification, the NTIA distributed preliminary plans for the Facility to the federal agencies included in the Interdepartment Radio Advisor Committee. The results of the NTIA study will be supplied to the OPSB immediately upon receipt.

(5) Evaluation of Impact to Roads and Bridges

Applicant has been engaged in discussions and exchange of drafts and discussion of a road use agreement with the Paulding County Engineer, and expects to have the agreement concluded in the near future.

(6) Plan for Decommissioning

Applicant will be responsible for decommissioning of the Facility. As specified in its real estate agreements, at the end of the useful life of the Facility, or following any termination of a real estate agreement, Applicant will be obligated at its expense to remove all its facilities to a minimum depth of at least 36 inches below grade within 12 months from the date the real estate agreement terminates. Applicant’s decommissioning plan provides: (Appendix U):

(a) (i) A description of the future use proposed of the land following reclamation.

(ii) A description of (a) engineering techniques proposed to be used in decommissioning and reclamation and a description of the major equipment; (b) a plan for the control of surface water drainage and of water accumulation and; (c) a plan, where appropriate, for backfilling, soil stabilization, compacting, and grading.

(iii) A description how Applicant will implement best management practices to control impacts to surface or ground water resources. If necessary, Appli- cant will obtain permits from the Ohio EPA and/or the USACE.

(iv) A detailed timetable for the accomplishment of each major step in the decommissioning plan, including the steps to be taken to comply with appli-

3059952v6 4906-17-05 147 NORTHWEST OHIO WIND ENERGY, LLC cable air and water quality laws and regulations and any applicable health and safety standards.

(b) A commitment that Applicant shall, at its expense, complete decommissioning of the Facility or individual turbines at the end of the useful life of the Facility, or following any termination of a real estate agreement. If no electricity is generated for a continuous period of 12 months (assuming no force majeure or impediment beyond Applicant’s control), and no and payments have been made to landowners, or if the OPSB deems the Facility or specified individual turbine(s) to be in a state of disrepair warranting decommissioning and Applicant is unable to reason- ably restore the Facility or specified individual turbine(s) to a normal state of operation, the Facility or specified individual turbine(s) will be presumed to have reached the end of its useful life.

(c) A commitment the decommissioning of the Facility and all associated facilities shall include the removal of all physical material pertaining to the Facility to a depth of at least 36 inches beneath the soil surface and restoration of the disturbed area to substantially the same physical condition that existed before erection of the Facility. The foundation for each turbine shall be removed to the depth of 36 inches. Decommissioning shall include the restoration of roads and bridges to substantially the same physical condition that existed immediately before decommissioning; the removal and transportation of turbines off-site; and removal of cabling, electrical components, access roads, and any other associated facilities. Disturbed earth shall be re-graded, re-seeded, and restored to substantially the same physical condition that existed immediately before erection of the Facility. Damaged field tile systems shall be repaired to at least original conditions.

(d) A commitment that if the Applicant does not complete decommissioning within the period prescribed in these conditions, the OPSB may take action as necessary to complete decommissioning, including requiring forfeiture of financial securi- ties. The entry into a landowner agreement constitutes agreement and consent of the parties to the agreement, their respective heirs, successors and assigns, that the

3059952v6 4906-17-05 148 NORTHWEST OHIO WIND ENERGY, LLC Board may take action that may be necessary to implement the decommissioning plan, including the exercise by the Board, OPSB Staff, and contractors, of the right of ingress and egress for the purpose of decommissioning the Facility.

(e) A commitment that the decommissioning funds or financial assurance shall be re- leased by the holder of the funds or financial assurance when Applicant has demonstrated, and the Board concurs, that decommissioning has been satisfactori- ly completed, or upon written approval of the Board in order to implement the decommissioning plan.

(f) A commitment that during decommissioning, all recyclable materials, salvaged and non-salvaged, shall be recycled to the furthest extent possible. All other non- recyclable waste materials shall be disposed of in accordance with state and federal law.

(g) A commitment that Applicant will leave intact any improvements made to the electrical infrastructure, pending approval by the applicable regional transmission organization and interconnection utility.

(h) A commitment that, subject to approval by OPSB Staff, within five years after the start date of commercial operation, an independent and registered professional engineer licensed to practice engineering in the State of Ohio shall be retained by Applicant to estimate the total cost of decommissioning in current dollars, without regard to salvage value of the equipment (Decommissioning Costs), and the cost of decommissioning net salvage value of the equipment (Net Decommissioning Costs). Said estimate shall include: (1) an analysis of the physical activities necessary to implement the approved reclamation plan, with physical construction and demolition costs based on ODOT’s Procedure for Budget Estimating and RS Means material and labor cost indices; (2) the number of units required to perform each of the activities; (3) an amount to cover contingency costs, not to exceed 10 percent of the above calculated reclamation cost. Said estimate should be on a per-turbine basis and shall be submitted for OPSB Staff review and approval within the first five years of Facility operation and every fifth year thereafter. Ap- 3059952v6 4906-17-05 149 NORTHWEST OHIO WIND ENERGY, LLC plicant will post and maintain decommissioning funds in the amounts of the estimate:

The form of financial assurance will be a financial instrument mutually agreed upon by OPSB Staff and Applicant and conditioned on the faithful performance of all requirements and conditions of this application’s approved decommissioning and reclamation plan. Once the financial assurance is provided, Applicant shall maintain such funds or assurance throughout the remainder of the applicable term and shall adjust the amount of the assurance, if necessary, to offset any increase or decrease in the decommissioning costs at the end of the applicable term.

Applicant will repair damage to government-maintained (public) roads and bridges caused by decommissioning activity. Any damaged public roads and bridges shall be repaired promptly to their pre-decommissioning state by Applicant under the guidance of the appropriate regulatory agency. Applicant will provide financial assurance to the county it will restore the public roads and bridges it uses to their pre-decommissioning condition. These terms shall be defined in the Agreement for Use, Repair, and Improvement of Roads between Applicant and Paulding County prior to construction. The Agreement for Use, Repair, and Improvement of Roads shall be subject to OPSB Staff review and confirmation that it complies with the applicable CECPN condition, and will contain provisions for the following:

a) A pre-decommissioning survey of the condition of public roads and bridges conducted within a reasonable time prior to decommissioning activities.

b) A post-decommissioning survey of the condition of public roads and bridges conducted within a reasonable time after decommissioning activities.

c) An objective standard of repair that obligates Applicant to restore the public roads and bridges to the same or better condition as they were prior to decommissioning.

d) A timetable for posting of the decommissioning road and bridge bond pri- or to the use or transport of heavy equipment on public roads or bridges. 3059952v6 4906-17-05 150 NORTHWEST OHIO WIND ENERGY, LLC (F) AGRICULTURAL DISTRICT IMPACT

(1) Agricultural District Mapping

The Project area includes approximately 688 acres of registered agricultural district land in Paulding County (Figure 8-2). The predominant land use is agricultural consisting primarily for row crop farming.

(2) Impact Assessment on Agricultural Land

(a) Acreage Impacted

The Facility would produce a temporary disturbance on approximately 971.0 acres of agricultural lands. It is anticipated the Facility will permanently occupy approximately 46.9 acres of agricultural lands.

Of the 971 acres of temporary disturbance to agricultural land, approximately 37.9 acres are on Agricultural District Land. Of the 46.9 acres of permanent disturbance to agricultural land, approximately 1.6 acres are on Agricultural District Land.

Temporary disturbances would be most prevalent during construction and would include temporary road widening efforts at permanent access road intersections, construction areas immediately adjacent to each turbine, trenching excavation for the placement of underground collection systems, and any temporary work areas associated with construction staging or storage areas. It is anticipated the underground collection lines will be buried to a minimum depth of three feet in agricultural fields to minimize impacts to farming activities during the immediate post- construction and operation phases of the Facility. Design of temporary access roads for the Facility will consider placements to minimize impacts on agricultural processes proximal to construction areas.

(i) Field operations

With the exception of ditch crossings, all 48.7 acres of the disturbed areas designated for turbine pads and access roads will be constructed in leased agricultural fields. Other than the 48.7 acres temporarily used for the wind 3059952v6 4906-17-05 151 NORTHWEST OHIO WIND ENERGY, LLC energy generation, the Facility will have little impact upon agricultural operations. Active farming will continue throughout the Project area in areas where the Facility is constructed. Land adjacent to the Facility will be useable for the same uses they are used for prior to construction. Some minor changes in tillage patterns may be necessary; however, locations for turbines, roads, and cabling were discussed with the affected landowners and all their suggestions and requests to date have been incorporated into the design of the Facility When the Facility is decommissioned, the land used for the Facility will be restored to its original agricultural use.

(ii) Irrigation.

Not applicable. None of the agricultural land affected by the Facility is irrigated. The Facility will not affect future potential for irrigation, because it does not use water, will not affect waterways and will not alter the land- scape in a manner that would affect irrigation potential.

(iii)Field drainage systems.

Applicant has consulted extensively with landowners and addressed their concerns regarding drainage in the design of the Facility. Applicant will avoid, where possible, and minimize to the maximum extent practicable, any damage to field tile drainage systems and soils resulting from construction, operation, and/or maintenance of the Facility in agricultural areas. Damaged field tile systems will be promptly repaired to at least original conditions at Applicant’s expense. If applicable, excavated topsoil shall be segregated and restored in accordance with Applicant’s lease agreement with the landowner. Severely compacted soils will be plowed or otherwise de-compacted, if necessary, to restore them to original conditions unless otherwise agreed to by the landowner.

(b) Mitigation

Mitigation measures to protect agricultural soils have been incorporated into the siting of Facility components. Permanent access road width is limited to 16 feet 3059952v6 4906-17-05 152 NORTHWEST OHIO WIND ENERGY, LLC or less. Where possible, access roads follow property and field edges to minimize loss of agricultural land. To the extent practicable, existing fields have been kept intact, rather than broken up into smaller, irregularly shaped fields that are more difficult to farm. Parking areas, the laydown yard, and other temporary and permanent support facilities have been located outside of active agricultural fields where possible. Known surface and subsurface drainage features (i.e., ditches, diversions, tile lines) have been avoided to the extent possible and will be repaired if affected by the Facility. These mitigation measures are adopted with intent to minimize impacts to agricultural land and practices while considering cost effi- ciencies for Facility design and construction. Applicant will implement appropriate mitigation measures for individual impact issues as necessary.

During operation and maintenance of the Facility, all Applicant’s vehicular and pedestrian traffic will be limited to public and permanent access roads. In the unlikely event of a need to use alternate paths though agricultural land, such usage would be with small vehicles, done with landowner’s understanding and if possible outside of the crop growing season. Facility staff will document such usage and, along with the landowner, monitor drainage tile performance. If any drainage tile (or any other private or public asset) must be repaired, landowner and Facility staff will mutually agree on a repair firm/person and such repair will happen as soon as practicable. If large turbine components such as blades and gear boxes need repair or replacement, and the public and permanent access roads are not adequate for large transportation rigs, then Facility staff will install temporary roadways where necessary. As a result of such temporary roadways, if any drainage tiles (or any other private or public asset) must be repaired, landowner and Facility staff will mutually agree on a repair firm/person and such repair will happen as soon as practicable.

(3) Viability Assessment

The Facility will not have an adverse impact on agricultural viability. As designed, the Facility will occupy a maximum of 48.7 acres of land. This land will be removed from active production during the operation of the Facility. Upon the decommissioning the 3059952v6 4906-17-05 153 NORTHWEST OHIO WIND ENERGY, LLC croplands will be restored as directed in lease agreements established with participating landowners. Applicant worked with landowners and neighbors to obtain their input on the design of the Facility and has incorporated their suggestions and requests into the design.

(G)Additional Information

Requirement Application Section Page Number Number 1 4906-17-08(D)(2) 136 2 4906-17-08(F)(2)(a)(iii) 152 3 4906-17-05(B)(1)(d) 40 4 4906-17-05(B)(1)(b) 38 5 4906-17-05(B)(1)(b) 38 6 4906-17-07(C)(2)(b) 62 7 4906-17-08(C)(3) 127 8 4906-17-08(A)(2)(d) 79 9 4906-17-05(B)(4) 44 10 4906-17-07(D)(2)(b) 67 11 4906-17-08(B)(2)(c)(i) 110 12 4906-17-08(B)(3)(d) 118 13 4906-17-08(B)(3)(c) 116 14 4906-17-07(B)(1)(d) 59 15 4906-17-07(C)(2)(b) 62 16 4906-17-08(C)(4)(a)(iii) 122 17 4906-17-08(C)(4)(a)(iii) 132 18 4906-17-08(C)(4)(a)(iii) 132 19 4906-17-03(A)(1)(a) 9

3059952v6 4906-17-05 154 NORTHWEST OHIO WIND ENERGY, LLC 20 4906-17-05(C)(1)(a) 45 21 4906-17-05(A)(4)(b) 26 22 4906-17-05(C)(2)(c) 50 23 4906-17-08(C)(3) 127 24 4906-17-08(C)(3) 127 25 4906-17-08(D)(2) 136 26 4906-17-08(D)(2) and Appendix V 136 and Appendix V

3059952v6 4906-17-05 155 NORTHWEST OHIO WIND ENERGY, LLC This foregoing document was electronically filed with the Public Utilities

Commission of Ohio Docketing Information System on

8/8/2013 1:48:06 PM in

Case No(s). 13-0197-EL-BGN

Summary: Amended Application Body Text electronically filed by Teresa Orahood on behalf of Sally Bloomfield for Northwest Ohio Wind Energy, LLC