Shawn Smallwood, PhD 3108 Finch Street Davis, CA 95616 Oregon Energy Facility Siting Council c/o Luke May, Siting Analyst Oregon Department of Energy 550 Capitol St. NE Salem, OR 97301
[email protected] 21 February 2019 Re: Summit Ridge Wind Farm – Request for Amendment 4 Dear Chair Beyeler and Members of the Council, On behalf of Friends of the Columbia Gorge, Oregon Wild, the Oregon Natural Desert Association, Central Oregon LandWatch, the Audubon Society of Portland, and East Cascades Audubon Society, I write to comment on the Request for Amendment 4 for the Summit Ridge Wind Farm, which requests a postponement of construction start and end dates for the project and which proposes an amended Habitat Mitigation Plan (January 2019). I primarily wish to comment on (1) the suitability of the habitat assessment underlying the amended Habitat Mitigation Plan, and (2) the need to update baseline surveys, project impact predictions, mitigation measures, and post- construction monitoring protocols. Updated surveys and analyses are needed in part because over the near-decade that has passed since the primary baseline study (Northwest Wildlife Consultants 2010), science has made vast improvements in field survey methods and in our understanding of wind turbine collision factors, displacement effects, and cumulative impacts related to wind projects. Methodology has vastly improved in preconstruction studies needed to predict project-scale and wind turbine-scale impacts, to measure post-construction impacts, and to assess whether and to what degree specific mitigation measures can be tested for efficacy. My qualifications for preparing these comments as expert comments are the following.