Black Rock Wind Farm Meeting with USFWS and WVDNR
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Appendix P Correspondence with WV DNR and USFWS From: Allred, Chase To: Roy, Bob Cc: Sargent, Barbara D; Joshi, Aarty; Peterson, Trevor Subject: Re: [EXTERNAL] FW: Black Rock Wind framework for pre-construction surveys Date: Wednesday, August 01, 2018 7:42:32 AM Bob, Following the Service's review of Black Rock's proposed work plan, the Service has the following comments. The Service has no objections to the proposed plan in the "bat survey " section. However, the Service recommends a study plan be submitted to the Service for concurrence prior to conducting any surveys. Given the typical variability in eagle use across years, we recommend a second year of monitoring and points should be randomly assigned: (D) Sampling design must be spatially representative of the project footprint, and spatial coverage of sample plots must include at least 30 percent of the project footprint. Sample plot locations must be determined randomly, unless the conditions in paragraph (d)(3)(ii)(F) of this section apply. (F) Stratified-random sampling (a sample design that accounts for variation in eagle abundance by, for example, habitat, time of day, season) will often provide more robust, efficient sampling. Random sampling with respect to time of day, month, or project footprint can be waived if stratification is determined to be a preferable sampling strategy after consultation and approval in advance with the Service. (50 CFR 22.26). The Service also recommends that Black Rock design their eagle survey to account for boundary revisions should these be likely to occur over the next two years. Let me know if there are any questions. Regards, Chase Allred U.S. Fish & Wildlife Service West Virginia Ecological Services Field Office 90 Vance Drive Elkins, WV 26241 304-636-6586, ext. 21 [email protected] On Fri, Jul 27, 2018 at 8:25 AM, Roy, Bob <[email protected]> wrote: Hi Barb and Chase, Just following up on my email from a couple weeks ago (please see below). We are looking forward to hearing from you about our efforts and proposed work plan and setting up a time to talk or meet to discuss the project further. Appendix P - 001 As before, please feel free to contact Trevor Peterson or me about this. Thank you, Bob Robert D. Roy Certified Wildlife Biologist Senior Project Manager Direct: 207.406.5516 Mobile: 207.373.8372 [email protected] Stantec 30 Park Drive Topsham ME 04086-1737 US The content of this email is the confidential property of Stantec and should not be copied, modified, retransmitted, or used for any purpose except with Stantec's written authorization. If you are not the intended recipient, please delete all copies and notify us immediately. From: Roy, Bob Sent: Wednesday, July 11, 2018 7:40 AM To: 'Sargent, Barbara D' <[email protected]>; '[email protected]' Appendix P - 002 <[email protected]> Cc: Peterson, Trevor <[email protected]> Subject: FW: Black Rock Wind framework for pre-construction surveys Hi Barb and Chase, I just wanted to follow up on the email and document I sent to you on June 7th regarding a framework of pre-construction wildlife surveys at the Black Rock Wind Project. Based on the stage of lease of agreements for the Project we have suggested that many of the field surveys be initiated in the latter half of this year and in the spring and early summer of 2019. Two efforts that could be, and have been, implemented this year include monthly eagle point count surveys and general bat acoustic detector surveys. We have initiated the eagle surveys late last month and will be deploying a detector in the one on-site MET tower next week. Beyond this, we’d like to discuss the proposed field surveys with each of you prior to implementing any additional effort. Please feel free to contact Trevor Peterson or me at your convenience to verify that you have received the work plan and to let us know when would be a good time to plan a call to discuss the proposed field surveys and any questions, concerns, or considerations you may have. Thank you, Bob Robert D. Roy Certified Wildlife Biologist Senior Project Manager Direct: 207.406.5516 Mobile: 207.373.8372 [email protected] Stantec 30 Park Drive Topsham ME 04086-1737 US Appendix P - 003 The content of this email is the confidential property of Stantec and should not be copied, modified, retransmitted, or used for any purpose except with Stantec's written authorization. If you are not the intended recipient, please delete all copies and notify us immediately. From: Roy, Bob Sent: Thursday, June 07, 2018 7:29 PM To: Sargent, Barbara D <[email protected]>; [email protected] Cc: Peterson, Trevor <[email protected]> Subject: Black Rock Wind framework for pre-construction surveys Barb and Chase, Stantec is assisting NRG in the development of the Black Rock Wind Project in Grant and Mineral Counties. The Project would be located on private property and is still in its pre-permit stage. Stantec conducted a desktop and field characterization of the site for biological resources and prepared the attached framework that outlines pre-construction wildlife surveys for the Project. We have prepared the attached framework based on a meeting held with WVDNR, USFWS, and NRG on June 8, 2017, more recent correspondence with your agencies, and recent experience of our staff (particularly Trevor Peterson) on other wind projects in the vicinity of this Project. The framework outlines the avian, bat, and rare species studies to complete at the site in 2018 and 2019. Given the time of year, eagle point count surveys and bat acoustic surveys at met tower locations will be initiated this year, with most other surveys completed at seasonably appropriate times in 2019. We believe that this suite of surveys is consistent with investigations performed at other nearby wind facilities and that this project will also benefit from the availability of similar information from those sites. We would very much appreciate your review of this plan, as we want to make sure that the surveys proposed would support a decision regarding compliance with the Endangered Species Act, requirements for the state’s CPCN licensing process, and meet the practices typically suggested by state and federal guidelines (such as the USFWS Land-Based Wind Energy Guidelines). We Appendix P - 004 understand that some agency survey protocols, such as rare bat mist-netting, could evolve but we anticipate that survey efforts such as those would be developed further in close consultation with USFWS and WVDNR. Additionally, considering that those surveys would be completed in 2019 we have time for this type of collaborative work plan development. Please feel free to contact me or Trevor with any questions about these surveys or if you would like to set up a time to more formally discuss the proposed studies. We look forward to hearing from you, Bob Roy Robert D. Roy Certified Wildlife Biologist Senior Project Manager Direct: 207.406.5516 Mobile: 207.373.8372 [email protected] Stantec 30 Park Drive Topsham ME 04086-1737 US The content of this email is the confidential property of Stantec and should not be copied, modified, retransmitted, or used for any purpose except with Stantec's written authorization. If you are not the intended recipient, please delete all copies and notify us immediately. Appendix P - 005 From: Sargent, Barbara D To: Roy, Bob Cc: Joshi, Aarty; Peterson, Trevor; Chase Allred ([email protected]) Subject: RE: [EXTERNAL] FW: Black Rock Wind framework for pre-construction surveys Date: Thursday, August 02, 2018 8:14:09 AM All, We are in agreement with the proposed work and plan, and with the Service’s comments. The WVDNR recommends that aerial eagle surveys should also be conducted in February and March, and should extend to 5mi outside the project buffer. Since our last review, a new eagle nest has been documented above the Linton Creek Reservoir (39.273672 -79.13973). This nest was visited on April 3, 2018, and adults were present at the nest. Please let me know if you have any questions. Barb Barbara Sargent WVDNR – Wildlife Resources Section Operations Unit Environmental Coordination PO Box 67 738 Ward Road Elkins, WV 26241 304/637-0245 (voice) 304/637-0250 (fax) www.wvdnr.gov “It is always the same with mountains. Once you have lived with them for any length of time, you belong to them. There is no escape.” ― Ruskin Bond From: Allred, Chase [mailto:[email protected]] Sent: Wednesday, August 01, 2018 10:42 AM To: Roy, Bob Cc: Sargent, Barbara D; Joshi, Aarty; Peterson, Trevor Subject: Re: [EXTERNAL] FW: Black Rock Wind framework for pre-construction surveys Bob, Following the Service's review of Black Rock's proposed work plan, the Service has the following comments. The Service has no objections to the proposed plan in the "bat survey " section. However, the Service recommends a study plan be submitted to the Service for concurrence prior to conducting any surveys. Appendix P - 006 Given the typical variability in eagle use across years, we recommend a second year of monitoring and points should be randomly assigned: (D) Sampling design must be spatially representative of the project footprint, and spatial coverage of sample plots must include at least 30 percent of the project footprint. Sample plot locations must be determined randomly, unless the conditions in paragraph (d)(3)(ii)(F) of this section apply. (F) Stratified-random sampling (a sample design that accounts for variation in eagle abundance by, for example, habitat, time of day, season) will often provide more robust, efficient sampling.