1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Before the Energy Facility Siting Council of the Stat
1 BEFORE THE ENERGY FACILITY SITING COUNCIL OF THE STATE OF OREGON 2 3 In the Matter of the Request for FRIENDS OF THE COLUMBIA GORGE, 4 Amendment 4 of the Site Certificate for ET AL.’S REQUEST FOR A the SUMMIT RIDGE WIND FARM CONTESTED CASE PROCEEDING 5 6 7 I. INTRODUCTION 8 Pursuant to OAR 345-027-0071, Friends of the Columbia Gorge, Oregon Wild, the 9 Oregon Natural Desert Association, Central Oregon LandWatch, and the East Cascades 10 11 Audubon Society (collectively, “Requesters”) request that the Energy Facility Siting Council 12 (“EFSC” or “Council”) conduct a contested case proceeding on the Request for Amendment 4 of 13 the Site Certificate for the Summit Ridge Wind Farm (“Project”), and allow Requesters to 14 participate as parties in the proceeding.1 15 16 It has been nearly ten years since the preliminary application for this Project was filed, 17 and nearly eight years since the Project was first approved. As a point of reference, in 2009, 18 when the Project was first applied for, Ted Kulongoski was Governor of Oregon, and Barack 19 Obama was in his first year as President of the United States. Since then, much has changed. The 20 Project has been abandoned by the initial developer, sold and transferred to a new owner 21 22 (“Pattern Energy,” “Pattern,” or “Applicant”),2 and the Project’s deadlines for beginning and 23 1 24 Requesters incorporate into this Request for Contested Case their February 21, 2019 comment letter to the Council (attached hereto as Exhibit A), the February 21, 2019 comment letter of Shawn 25 Smallwood, PhD to the Council (attached hereto as Exhibit B), and the oral comments of Friends’ Senior Staff Attorney Nathan Baker at the February 22, 2019 public hearing.
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