Letter Stephanie Tidwell, Executive Director O6 Friends of the Response June 14, 2019 7 7.6 O6-1 The commenter states that while Friends of the Eel River (FOER) supports the development of renewable energy facilities in general, the construction and maintenance of the project in a sensitive ecosystem like the Eel River watershed has the potential for significant environmental impacts. The commenter states that FOER’s concerns have not been adequately addressed, although the organization expressed them both in person and in writing during the scoping phase. The commenter states that FOER is particularly concerned that impacts and risks of the transmission corridor were not included on the list of “Known Areas of Controversy.”

The commenter does not state which of FOER’s concerns have not been addressed or refer to specific significant environmental impacts or specific impacts and risks of the transmission corridor. This comment does not raise specific questions or request information that pertains to the adequacy of the DEIR for addressing adverse physical impacts associated with the project, nor does it contain an argument raising significant environmental issues. No further response is required.

O6-2 The commenter states that FOER is focused on problems associated with the transmission corridor, possible directional drilling under Eel River, and other aquatic impacts. The commenter states that FOER shares the concerns expressed by the Tribe, allied conservation organizations (EPIC, Humboldt Baykeeper, Audubon Society) and local communities (Scotia and Rio Dell).

The commenter does not identify specific problems associated with the transmission corridor, drilling under Eel River, and other aquatic impacts. Please refer to the responses to comment letters R1 (City of Rio Dell), R3 (Town of Scotia), O6 (EPIC), O16 (Redwood Audubon Society), and T2 (Wiyot Tribe) for specific responses to comments submitted by the agencies and organizations cited by the commenter. No letter was received from the Humboldt Baykeeper organization.

O6-3 The commenter states that Alternative 2 should be more fully evaluated, particularly the alternative gen- tie alignment, and that the potential for bird collisions with a new line across the river could be as bad as the potential risks to aquatic habitat from directional drilling under the river. The commenter asks for more information to assess the potential impacts. The commenter states that the decades of timber processing that took place next to the proposed drilling site could have contaminated the soil with pollutants. Per the commenter, FOER previously recommended that the soil be tested, “which does not appear to have been done,” so any drilling done for the project should minimize soil disturbance to avoid chemical contamination and erosion.

As originally described in the DEIR, the project proposed to underground the gen-tie line under the Eel River using horizontal directional drilling. After consultation with the County and the National Marine Fisheries Service, which expressed a concern about potential frac-outs during drilling, the project applicant has agreed to cross the Eel River with an overhead realignment as described in Alternative 2 in the DEIR.

Humboldt Wind Energy Project FEIR AECOM Humboldt County 7.6-1 Organizational Comments and Responses

O6-4 The commenter states that the DEIR greatly underestimates the potential for significant and unavoidable environmental impacts from the transmission line. The commenter states that most of the lines would cross over forest, some of it old-growth, yet there is neither a timber harvest plan nor a vegetation management plan. The commenter adds that the lines would cross multiple streams that host protected salmonid species, and that birds such as murrelets have collided with lines and been killed. The commenter questions the efficacy of the DEIR’s proposed mitigation measures for birds, including using design to drive protected species away (which per the commenter could worsen habitat degradation) and improving trash facilities at nearby parks. The commenter also questions the lack of details about the DEIR’s creation of marbled murrelets, and states that Mitigation Measure 3.5-12 does not mention impacts or potential mitigation of the gen-tie’s operational impacts.

As discussed in Section 3.1, Master Response 1, “Site Planning and Avoidance Measures,” the project applicant has made changes to the project to avoid and minimize impacts on sensitive resources throughout the planning and concept design process. Please also refer to Chapter 1 of this FEIR for “Refinements to the Project Description Since Circulation of the DEIR” for details on the most recent refinements. These project description revisions are also shown in FEIR “Revisions to the DEIR,” and include a reduction of the disturbance area from 900 acres to approximately 655 acres (due to narrowing the 500-foot corridor); re-alignment and shortening of the gen-tie to avoid northern spotted owl habitat; reduction of the gen-tie length from 25 to 22 miles and co-location with existing roads wherever possible; reduction in the number of turbines from 60 to 47 and micro siting of turbines to avoid known cultural and sensitive biological resources; overhead crossing of the gen-tie line over the Eel River and relocating it 1.8 miles east of the previous route and other slight routing adjustments; and a re-aligned access route, adopting the “realigned Jordan Creek access” presented in Alternative 2 in the DEIR. Please see Figure 1- 1 in Chapter 1 of this FEIR for the revised project footprint. With these reductions in the area of ground disturbance, the amount of potential sedimentation is also reduced.

Please see Master Response 2, “Marbled Murrelet,” and Compensatory Mitigation Strategy for Marbled Murrelets Impacted by Operation of the Humboldt Wind Project, prepared by H. T. Harvey & Associates, dated September 2019, and Supplement to Compensatory Mitigation Strategy for Marbled Murrelets Impacted by Operation of the Humboldt Wind Project prepared by H.T. Harvey & Associates and Stantec Consulting, Inc., dated October 3, 2019, in Appendix B of the FEIR. Please also see the responses to Comments O9-25, O9-26, and O9-28.

Please see the “Revegetation, Reclamation, and Weed Control Plan” in Appendix B of this FEIR for a discussion of proposed vegetation management. Please also see the response to Comment O6-17 regarding timber harvest.

O6-5 The commenter states that the gen-tie’s construction and maintenance impacts on listed fish is potentially significant, but not mentioned in the summary of project impacts and mitigation measures. The commenter states that the Eel River watershed is one of the most erosive watersheds in the country, but this is not thoroughly addressed in the DEIR.

Please see the responses to Comments O6-3 and O9-11.

O6-6 The commenter states that if a revised DEIR or FEIR is prepared, it must include a transmission corridor that is designed to minimize habitat fragmentation. The commenter suggests placing the transmission line

AECOM Humboldt Wind Energy Project FEIR Organizational Comments and Responses 7.6-2 Humboldt County underground along existing roadways or, if an overhead line to the Bridgeville station is chosen, the commenter asks that that site poles and other ground infrastructure be placed as far away from streams as possible to minimize erosion and pollution and protect listed salmonids. The commenter states that the use of the Rio Dell PG&E substation would have a lower impact, but this is not discussed in the DEIR although it should have been evaluated as part of the environmentally superior alternative.

Please see the responses to Comments O6-3, O6-4, and O9-11.

O6-7 The commenter calls the DEIR’s statement that the Humboldt Redwood Company’s (HRC) logging and silviculture operations would serve as a method of wildfire management “a dangerous assumption.” The commenter states that CalFire identifies the project area as having a high or very high fire severity rating, that it is well-established that above-ground transmission lines in forested areas increase fire risk, and that HRC’s logging operations plan does not take the transmission lines into account. The commenter refers to the DEIR’s acknowledgement of increased fire risk from construction and turbine fires, but criticizes its lack of specifics regarding how increased fire response capacity would be paid for. The commenter notes that the fire safety and management and vegetation management plans have not been developed, so the public cannot fully assess the potential risks. The commenter states that PG&E has not met its targets for placing power lines underground, and that the proposed project adds to the fire risks posed by the existing infrastructure.

Section 3.13, “Fire Protection Services and Wildfire Hazards,” of the DEIR provides an analysis of fire department preparedness and wildfire impacts. As discussed in Mitigation Measure 3.13-1a (Prepare and Implement a Fire Services Financing Plan) of Section 3.13, the project applicant would be required to develop and implement a fire services financing plan in consultation with Humboldt County Fire Chiefs’ Association and Rio Dell Fire Protection District. Please also see Master Response 10, “Wildfire,” of this FEIR, which provides further discussion of the history of wildfire in the region and regulatory requirements and updated mitigation measures that can reduce the potential for wildfires.

O6-8 The commenter states that Jordan Creek Road would incur heavy industrial traffic and two staging areas during project construction, and that road widening and roadside logging would take place, but no maps or descriptions have been provided to show where adverse environmental impacts might occur. The commenter states that the site envelop is in the Jordan Creek watershed, and that Jordan Creek is listed by CDFW as an impaired watershed where the geology is unstable and prone to heavy erosion. The commenter states that the DEIR downplays the threat of landslides during the rainy season that could result in sediment loads to the watershed. The commenter states that Jordan Creek is documented as a northern spotted owl flyway. The commenter states that the project’s potentially dire impacts on the struggling watershed are insufficiently addressed in the DEIR.

Please see the responses to Comments O6-4, O6-4, and O9-11.

O6-9 The commenter states that proper project siting is the most critical factor in mitigating the potential for bird deaths from turbines. The commenter states that the inadequate survey period for the main turbine site has shown that it has the potential to significantly impact endangered and threatened species, including marbled murrelets, northern spotted owls, brown pelicans, golden eagles, bald eagles, white- tailed kites, American peregrine falcons, and condors. The commenter states that comprehensive wildlife surveys were not conducted along the proposed transmission corridor, and that

Humboldt Wind Energy Project FEIR AECOM Humboldt County 7.6-3 Organizational Comments and Responses

no “real” mitigation was presented for raven predation on marbled murrelets in the area. The commenter states that the project should not be approved until all biological studies for birds and other protected species are conducted and incorporated into a revised DEIR.

As described in Section 3.5, “Biological Resources,” the DEIR has provided a complete and thorough evaluation of all potentially affected wildlife species and committed the County to the required mitigation measures, presented clear performance standards that have been further refined in this FEIR, and described means of mitigating impacts that would achieve the performance standards.

Studies conducted in 2019 for marbled murrelets, northern spotted owls, eagles, other migratory and special-status birds, and special-status plants have been completed and are available in Appendix B of this FEIR. Please refer to Chapter 1 of this FEIR for a summary of refinements to the project description since circulation of the DEIR and a list of supplemental technical studies completed. The results of the 2019 surveys and the resulting additional technical analysis completed substantiate and corroborate the analyses presented in the DEIR. They did not change any of the conclusions reached in the DEIR.

Please see the responses to comments in letter S4 and please also see Master Responses 2 through 8 for additional details related to the analysis of impacts on biological resources, a discussion of additional surveys conducted since circulation of the DEIR, and additional refinements to the mitigation measures in the DEIR. Please also refer to the responses to Comments 016-5 and I65-1 regarding California condors.

In addition, since circulation of the DEIR, the project applicant has refined the footprint of the proposed project to avoid or minimize impacts on sensitive resources. Please see Master Response 1, “Site Planning and Avoidance Measures,” and Chapter 1 of this FEIR.

O6-10 The commenter states that California condors will soon be reintroduced to California’s north coast by the Tribe. The commenter states that the DEIR proposes using the birds’ tracking systems to detect the presence of condors near the project and shut down operations as needed, but the DEIR also indicates that the technology required for this has not been identified. The commenter notes that the DEIR does not discuss what long-range options there would be if the condors take up permanent residence in the area.

Please refer to the response to comment letter T1 for specific responses to comments submitted by the Yurok Tribe and the responses to Comments 016-5 and I65-1 regarding California condors.

O6-11 The commenter states that the DEIR acknowledges but fails to address the project’s potential impacts on bats, which can be killed not only by collision with turbine blades, but also by barotrauma, the damage that can occur to lungs and other air-containing organs from excessive pressure change. The commenter states that hoary bats seem to be particularly vulnerable. The commenter states that the proposed mitigation measure of a post-construction technical advisory committee is insufficient. The commenter states that no mitigation measure was proposed for the western red bat, and that the measure proposed for the Townsend’s big-eared bats is to slash the bases of old-growth trees to create fake nesting cavities, which is not supported by scientific documentation and would create a secondary impact. The commenter states that nighttime turbine speeds must be limited to fewer than 5 meters a second.

The commenter correctly notes that WTGs can result in bat fatalities from barotrauma in addition to collisions with turbine blades. That level of detail was not a necessary element of the DEIR’s analysis of

AECOM Humboldt Wind Energy Project FEIR Organizational Comments and Responses 7.6-4 Humboldt County operational impacts of the project on bats and would not have changed the conclusions in the DEIR regarding the impacts of the project on bats. Please see Master Response 4, “Bats,” for an additional discussion of the project’s impacts on bats, additional information about how the TAC would operate, and a discussion of the refined language that has been added to Mitigation Measure 3.5-18d (Implement Operational Minimization Measures and Mitigation) in the DEIR to further clarify proposed avoidance and minimization measures to avoid population level impacts on bats. Please note that these measures apply to all bat populations, including western red bats, that could be affected by project operation. Much of the bat impact discussion appropriately focuses on hoary bats because of their high mortality rates associated with wind farms and the exceptionally high numbers of hoary bats documented near the project site at Humboldt Redwoods State Park. However, the analysis also notes that threats associated with the proposed project are similar for the other bat species found in the area, in addition to hoary bats.

Regarding the commenter’s statement about the proposed mitigation for potential impacts on Townsend’s bat roosts, please note that CDFW recommends the creation of artificial roosts as a management approach for Townsend’s big-eared bats. In CDFW’s Status Review of Townsend’s Big-Eared Bat In California (CDFW 2016 page 59) one of their management recommendations is to create artificial roosts: “Implement basal hollow creation projects to increase opportunities for Townsend’s big-eared bats to use tree roosts in coastal redwood forests (and possibly interior forests where large tree species, such as giant sequoia, have the potential to serve as roost sites).”

O6-12 The commenter states that several state-listed species may be taken by the project. The commenter states that TerraGen seeks to comply with the California Endangered Species Act through a Fish and Game Code 2081 incidental take permit. The commenter lists the requirements of the code, and states that they have not been met in the DEIR.

Please see the response to Comment O5-8.

O6-13 The commenter states that the Wiyot Tribe has expressed concerns about the project’s impacts on tribal cultural areas. The commenter states that Alternative 4 addresses the most serious cultural impacts, but will still have significant impacts on sacred cultural sites.

Supplemental information regarding tribal cultural resources in the FEIR provides additional information based on site-specific studies conducted since circulation of the DEIR. Please also refer to the response to comment letter T2 for specific responses to comments submitted by the Wiyot Tribe. The Board of Supervisors will ultimately determine if any of the alternatives are feasible and/or meet the project’s objectives.

O6-14 The commenter states that there are 400 acres of sensitive plant communities, especially coastal grasslands, and 8 acres of sensitive plans in the project area, but Terra-Gen has not completed the plant surveys. The commenter states that the proposed deferred mitigations are neither justifiable nor sufficient. The commenter states that the DEIR fails to address Rank 3 and Rank 4 species or invasive species management in association with road changes or the gen-tie corridor.

Please see the Revegetation, Reclamation, and Weed Control Plan in Appendix B of this FEIR for a discussion of additional surveys conducted since circulation of the DEIR and additional refinements to the

Humboldt Wind Energy Project FEIR AECOM Humboldt County 7.6-5 Organizational Comments and Responses

mitigation measures in the DEIR. None of the DEIR’s conclusions regarding sensitive plant communities require any revisions based on the additional surveys.

O6-15 The commenter refers to comments from the City of Rio Dell and the Town of Scotia Company, and states that the project would significantly alter the character, unique environment, and property values of the communities.

Please also refer to the responses to comment letters R1 and R3 for specific responses to comments submitted by tCity of Rio Dell and the Town of Scotia, respectively.

O6-16 The commenter states that assessments of viewshed impacts have focused on Rio Dell residences, but Humboldt Redwoods State Park, Grizzly Creek State Park, and Van Duzen County Park are within 5 miles of the proposed site. The commenter states that the DEIR failed to include modeling, although it is “well-established” that the project would be visible from Humboldt Redwoods State Park on the Thornton Multi-Use Trail, the Peavine Multi-Use Trail, the Peavine Ridge Spur at Prairie Road, and parts of the Grasshopper Trail and Grasshopper Peak, all within park areas of special natural significance. The commenter asks that these other viewshed impacts be evaluated and minimized.

Please also the responses to Comments R3-8, R3-9, R3-10, R3-18, and I149-1, which address visual impacts.

O6-17 Per the commenter, the DEIR acknowledges that it does not comply with the Habitat Conservation Plan (HCP). The commenter states that the DEIR offers no correction for this and does not provide a timber harvest plan for the gen-tie corridor and 300+-acre clear cut area. The commenter states that the project must be in compliance with laws, agreements, and plans applicable to the project’s footprint and transmission lines. The commenter refers to the California Timberland Productivity Act of 1982 and states that timberland may not be taken for electricity generation.

The project is proposed on land owned by HRC, which owns and manages 209,200 acres of forestland in southern Humboldt County. Timber harvest and forestry management are the primary activities on HRC lands, with approximately 203,000 acres of landholdings, including the project site and gen-tie corridor, available for harvest if such activity is conducted consistent with the conservation protocols required by the HRC HCP. Project-related timber harvest within the gen-tie corridor would be conducted by HRC crews operating under a Timber Harvest Plan that will be prepared in accordance with Forest Practice Rules. Please also see the response to Comment O9-11 and Master Response 8, “Conflict with Adopted HCP.”

O6-18 The commenter states that historic harm to the project area resulting from deforestation and the cannabis industry, as well as project impacts already addressed in the letter, culminate in a level of serious concern from a CEQA perspective. The commenter disagrees with the DEIR’s assertion that the project would not contribute to potential significant cumulative impacts stemming from wildfire or water pollution, and states that the DEIR must be revised to include cumulative watershed effects models.

Please see the response to Comment O9-11.

AECOM Humboldt Wind Energy Project FEIR Organizational Comments and Responses 7.6-6 Humboldt County O6-19 The commenter states that mitigation measures presented in the DEIR are mostly pro forma and many would take place after harm has occurred. The commenter states that the DEIR does not provide a “transparent” assessment of the likelihood of mitigation measure success.

The County believes that the DEIR has provided a complete and thorough evaluation of all potentially affected wildlife species and committed the County to the required mitigation measures, presented clear performance standards that have been further refined in this FEIR, and described the means of mitigating impacts that would achieve the performance standards.

In addition, mitigation measures may specify performance standards that would mitigate the significant effects of the project and may be accomplished in more than one specified way. The specific details of a mitigation measure, however, may be developed after a project’s approval when it is impractical or infeasible to include those details during the project’s environmental review, provided that the agency (1) commits itself to the mitigation, (2) adopts specific performance standards that the mitigation will achieve, and (3) identifies the type(s) of potential action(s) that can feasibly achieve that performance standard and that will be considered, analyzed, and potentially incorporated in the mitigation measure. Compliance with a regulatory permit or other similar process may be identified as mitigation if compliance would result in the implementation of measures that would be reasonably expected, based on substantial evidence in the record, to reduce the significant impact enough to meet the specified performance standards (Guidelines Section 15126.4).

O6-20 The commenter states that the DEIR is premature because the wildlife surveys are incomplete, limiting the information the public has about potential impacts. The commenter states that the applicant wants to qualify for tax credits that will soon expire, so there is a “pre-decisional bias” that conflicts with CEQA.

Please see the responses to Comments O6-4 and O9-11. Please also see Master Responses 2 through 8 for additional details related to the analysis of impacts on biological resources, a discussion of additional surveys conducted since circulation of the DEIR, and additional refinements to the mitigation measures in the DEIR. The additional surveys corroborate and substantiate the conclusions of the DEIR and do not disclose any new significant impacts not already disclosed and analyzed in the DEIR.

With respect to tax credits, neither the DEIR nor this FEIR is intended to address social or economic impacts. “An economic or social change by itself shall not be considered a significant effect on the environment” (CEQA Guidelines Sections 15131 and 15382).

O6-21 The commenter states that the expected take of marbled murrelets exceeds what is approved in HRC’s HCP. The commenter states that the HCP is outdated, and that an update should be “triggered” by the project but is not covered in the DEIR.

Please see the response to Comment O9-11 and Master Response 8, “Conflict with Adopted HCP.”

O6-22 Per the commenter, the DEIR states that the project will implement the wet-weather BMPs of HRC’s HCP. The commenter states that the HCP does not address wind farms or their infrastructure, so the applicant’s erosion control plan must exceed what is described in the DEIR.

Please see the response to Comment O9-11 and Master Response 8, “Conflict with Adopted HCP.”

Humboldt Wind Energy Project FEIR AECOM Humboldt County 7.6-7 Organizational Comments and Responses

O6-23 The commenter states that no geotechnical report or grading plan is provided, although most of the project site has slopes greater than 30 degrees and therefore the report and plan are required by the Humboldt County General Plan. The commenter states that earthquakes occur regularly in the area, so an earthquake hazard risk assessment should be part of the project’s evaluation.

Please see the responses to Comments 171-6 and 171-7 regarding geologic technical reports, grading plans, and seismicity. As stated in these responses, the project applicant would be required to comply with state and local regulations related to the preparation of geotechnical reports and grading plans. A site- specific, design-level geotechnical report must be prepared by a licensed geotechnical engineer, per California Building Code requirements in association with the building permit issued for the project. This report is a final, design-level geotechnical subsurface investigation report that includes subsurface testing of soil and groundwater conditions to identify site-specific geology and soil characteristics that the final engineering design should take into account during the preparation of grading and building plans. Recommendations of the geotechnical engineering report are incorporated into the plans submitted for grading and building permits. The geotechnical engineering report is subject to review by and approval of the County’s Planning & Building Department. In addition, the project applicant and its contractors would be required to implement Mitigation Measure 3.10-1 (Implement Wet-Weather BMPs Consistent with the Humboldt Redwood Company Habitat Conservation Plan). Because the project applicant would be required to comply with state and local regulations and implement Mitigation Measure 3.10-1, impacts associated with geologic technical reports, grading plans, and seismicity would be less than significant.

Compliance with a regulatory permit or other similar process may be identified as mitigation if compliance would result in the implementation of measures that would be reasonably expected, based on substantial evidence in the record, to reduce the significant impact enough to meet the specified performance standards (Guidelines Section 15126.4[a][1][B]).

O6-24 The commenter states that a fire safety and management plan should have been part of the DEIR and not deferred.

Please see Master Response 10, “Wildfire,” of this FEIR, which provides a further discussion of the history of wildfire in the region and the regulatory requirements and mitigation measures that can reduce the potential for wildfires.

O6-25 The commenter states that the DEIR is vague on vegetation management, and that there must be a vegetation management plan that includes BMPs to reduce fire and pollution risks. The commenter states that FOER recommends mechanical treatment for the site pads, gen-tie, and roadsides. The commenter states that herbicides should be avoided in order to protect protected species, especially salmonids.

Please see the “Revegetation, Reclamation, and Weed Control Plan” in Appendix B of this FEIR.

O6-26 The commenter states that CEQA does not permit the piecemealing of a project’s analysis. The commenter states that all surveys, reports, and plans need to be completed and the DEIR recirculated for comment.

Please see the responses to Comments O6-4, O6-19, and O9-11.

AECOM Humboldt Wind Energy Project FEIR Organizational Comments and Responses 7.6-8 Humboldt County O6-27 The commenter states that no reasonable alternatives to the use of large turbines have been presented and that FOER requests that solar energy be considered as well as less harmful types of wind generators.

The DEIR’s alternatives analysis meets the CEQA requirements. As stated in Chapter 6, “Alternatives,” of the DEIR, each alternative was evaluated according to the “rule of reason” and general feasibility criteria suggested by the State CEQA Guidelines Section 15126.6, as follows:

“The range of alternatives required in an EIR is governed by a ‘rule of reason’ that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. The alternatives shall be limited to ones that would avoid or substantially lessen any of the significant effects of the project. Of those alternatives, the EIR need examine in detail only the ones that the lead agency determines could feasibly attain most of the basic objectives of the project. The range of feasible alternatives shall be selected and discussed in a manner to foster meaningful public participation and informed decision making.”

The County has considered a range of alternatives that could feasibly attain most of the basic project objectives identified in Section 2.2.2, “Project Objectives,” of Chapter 2, “Project Description,” and avoid or substantially lessen one or more significant effects. Please also see Master Response 11, “Alternatives,” for further discussion. A solar energy generation project at this location is not feasible due to the hilly terrain and frequent cloud cover and would not feasibly attain the project’s objective of generating 155 MW of renewable energy.

O6-28 The commenter states that the DEIR fails to discuss a decommissioning plan, although the facility will likely become outdated, so more information is needed.

Project decommissioning is discussed in Section 2.5, “Project Decommissioning and Restoration,” in Chapter 2, “Project Description,” of the DEIR. As stated in Section 2.5, a decommissioning plan would be developed and implemented and would require additional discretionary approval by the County, thus requiring its own CEQA review. The decommissioning plan would require the removal of all above-grade structures and facilities from the project site. In addition, a minor stormwater management plan would be prepared in accordance with County requirements, outlining plans for decompaction, recontouring, hydroseeding, and, if necessary, installation of BMPs to prevent significant impacts on water quality. After the facilities have been removed and the project site is returned to preconstruction and operation condition, the project applicant would implement a restoration plan in accordance with County requirements, similar to the plan used during construction. No significant environmental impacts that are different or greater than the impacts of the construction of the project are anticipated.

O6-29 The commenter describes FOER’s mission and history and its goal of ensuring that the County fully complies with CEQA by approving projects that do not adversely affect wildlife and plants, especially protected species. The commenter states that FOER has not seen the careful planning and mitigation necessary to prevent harm to the Eel River watershed. The commenter states that although Alternative 5 comes the closest to achieving that goal, it does not address the impacts of a transmission corridor. The commenter concludes that FOER cannot support the project at the proposed location.

Humboldt Wind Energy Project FEIR AECOM Humboldt County 7.6-9 Organizational Comments and Responses

The commenter supports Alternative 5 and expresses opposition to the proposed project. This comment does not raise specific questions or request information that pertains to the adequacy of the DEIR for addressing adverse physical impacts associated with the project, nor does it contain an argument raising significant environmental issues. This comment is published in this Response to Comments document for public disclosure and for decision maker consideration.

AECOM Humboldt Wind Energy Project FEIR Organizational Comments and Responses 7.6-10 Humboldt County