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Chapter 7.6 Friends of the Eel River

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Chapter 7.6 Friends of the Eel River Letter Stephanie Tidwell, Executive Director O6 Friends of the Eel River 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 Wiyot 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.
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