The BLM manages more land – 256 million acres – than any other Federal agency. This 

land, known as the National System of Public Lands, is primarily located in 12 Western 

States, including Alaska. The Bureau, with a budget of about $1 billion, also administers 

700 million acres of sub-surface mineral estate throughout the nation. The BLM’s 

multiple-use mission is to sustain the health and productivity of the public lands for the use 

and enjoyment of present and future generations. The Bureau accomplishes this by 

managing such activities as outdoor recreation, livestock grazing, mineral development, 

and energy production, and by conserving natural, historical, cultural, and other resources 

on public lands. 

BLM/WY/PL-10/004+1430 

WY-040-EA09-138 
ENVIRONMENTAL ASSESSMENT FOR THE
 

WHITE MOUNTAIN WIND ENERGY PROJECT, 

SWEETWATER COUNTY, WYOMING 

Bureau of Land Management 

Wyoming High Desert District 

Rock Springs Field Office 

Rock Springs, Wyoming 

In Cooperation With 

Sweetwater County 

City of Rock Springs 

Sweetwater County Conservation District 

The Wyoming Governor’s Office 

Wyoming Game and Fish Department 

Wyoming State Historic Preservation Office 

Wyoming Department of Environmental Quality - Industrial Siting Division 

Wyoming Department of Environmental Quality - Water Quality Division
 

Wyoming Department of Agriculture 

February 2010 
EA, White Mountain Wind Energy Project i 

TABLE OF CONTENTS
 

Page 

1.0 INTRODUCTION ........................................................................................................................... 1-1
 

1.1 BACKGROUND ................................................................................................................ 1-1
 

1.2 PURPOSE AND NEED FOR THE PROPOSED ACTION............................................... 1-2
 

1.3 DECISIONS TO BE MADE .............................................................................................. 1-2
 

1.4 CONFORMANCE WITH BLM LAND USE PLANS....................................................... 1-2
 

1.5 RELATIONSHIP TO KEY STATUTES, REGULATIONS, OR OTHER PLANS .......... 1-5
 

1.6 REQUIRED PERMITS OR AUTHORIZATION .............................................................. 1-5
 

1.7 SCOPING AND ISSUES ................................................................................................... 1-5
 

2.0 THE PROPOSED ACTION AND ALTERNATIVES.................................................................... 2-1
 

2.1 DESCRIPTION OF PROPOSED ACTION....................................................................... 2-1
 

2.1.1 Introduction......................................................................................................... 2-1
 

2.1.2 Health, Safety, and Environmental Commitment and Policy ............................. 2-6
 

2.1.3 Adaptive Management Strategy.......................................................................... 2-6
 

2.1.4 Communication Plan........................................................................................... 2-9
 

2.1.5 Project Schedule ................................................................................................. 2-9
 

2.2 CONSTRUCTION OF FACILITIES ................................................................................. 2-10
 

2.2.1 Health, Safety, and Environmental Plan ............................................................. 2-10
 

2.2.2 Civil Construction Activities .............................................................................. 2-10
 

2.2.2.1 Surveying and Staking ........................................................................ 2-10
 

2.2.2.2 Geotechnical Sampling ....................................................................... 2-11
 

2.2.2.3 Rock Removal..................................................................................... 2-11
 

2.2.2.4 Topsoil Salvage Operations ................................................................ 2-13
 

2.2.2.5 Site Grading ........................................................................................ 2-13
 

2.2.2.6 Road Base Construction...................................................................... 2-13
 

2.2.2.7 Excavation .......................................................................................... 2-13
 

2.2.2.8 Compaction......................................................................................... 2-14
 

2.2.2.9 Erosion Control................................................................................... 2-14
 

2.2.3 Project Construction Plan ................................................................................... 2-14
 

2.2.3.1 Roads and Turbine Pads ..................................................................... 2-15
 

2.2.3.2 Electrical Collection System............................................................... 2-18
 

2.2.3.3 Wind Turbine Foundations ................................................................. 2-18
 

2.2.3.4 Wind Turbine Installation................................................................... 2-19
 

2.2.3.5 Meteorological Tower Installation...................................................... 2-19
 

2.2.3.6 Substation............................................................................................ 2-21
 

2.2.3.7 Overhead Collection Lines ................................................................. 2-21
 

2.2.3.8 Operations and Maintenance Site ....................................................... 2-22
 

2.2.3.9 Construction Schedule and Workforce Requirements ........................ 2-22
 

2.2.4 General Construction Activities.......................................................................... 2-22
 

2.2.4.1 Housekeeping...................................................................................... 2-22
 

2.2.4.2 Traffic ................................................................................................. 2-24
 

2.2.4.3 Materials Receipt, Handling, and Storage .......................................... 2-24
 

2.2.4.4 Fencing and Signage........................................................................... 2-24
 

2.2.5 Structural Construction Activities....................................................................... 2-25
 

2.2.5.1 Concrete Supply.................................................................................. 2-25
 

2.2.5.2 Steel Placement................................................................................... 2-27 
ii EA, White Mountain Wind Energy Project 

TABLE OF CONTENTS (Continued) 

Page 

2.2.5.3 Formwork............................................................................................ 2-27
 

2.2.6 Electrical Construction Activities ....................................................................... 2-27
 

2.2.6.1 Buried Cable Placement...................................................................... 2-27
 

2.2.6.2 Grounding ........................................................................................... 2-27
 

2.2.6.3 Buswork and Electrical Line Connections.......................................... 2-29
 

2.2.6.4 Communications Systems Installation................................................ 2-29
 

2.2.6.5 Aviation Marking and Lighting on Wind Turbines ............................ 2-30
 

2.2.7 Wind Turbine Tower Erection ............................................................................ 2-30
 

2.2.7.1 Turbine Component Delivery and Storage ......................................... 2-30
 

2.2.7.2 Crane Assembly and Movement......................................................... 2-30
 

2.2.7.3 Wind Turbine Component Lifts.......................................................... 2-34
 

2.2.8 Reclamation Following Construction Operations............................................... 2-34
 

2.3 OPERATION AND MAINTENANCE.............................................................................. 2-34
 

2.3.1 Health, Safety, and Environmental Plan ............................................................. 2-34
 

2.3.2 Project Operation and Maintenance Plan............................................................ 2-34
 

2.3.3 Operation Activities............................................................................................ 2-34
 

2.3.3.1 Orientation and Training..................................................................... 2-34
 

2.3.3.2 Wind Facility Performance Monitoring.............................................. 2-34
 

2.3.4 Maintenance Activities ....................................................................................... 2-36
 

2.3.4.1 Project Inspections.............................................................................. 2-36
 

2.3.4.2 Scheduled Wind Turbine Maintenance............................................... 2-37
 

2.3.4.3 Unscheduled Wind Turbine Maintenance .......................................... 2-37
 

2.3.4.4 Balance of Plant Maintenance ............................................................ 2-38
 

2.4 DECOMMISSIONING....................................................................................................... 2-39
 

2.4.1 Health, Safety, and Environmental Plan ............................................................. 2-39
 

2.4.2 Project Decommissioning Plan ........................................................................... 2-40
 

2.4.3 Wind Turbine/Meteorological Tower Removal.................................................. 2-40
 

2.4.3.1 Crane Movement and Assembly......................................................... 2-40
 

2.4.3.2 Wind Turbine/Meteorological Tower Disassembly............................ 2-40
 

2.4.3.3 Component Removal .......................................................................... 2-41
 

2.4.4 Electrical System Removal................................................................................. 2-41
 

2.4.4.1 Buried Cable Removal........................................................................ 2-41
 

2.4.4.2 Substation Disassembly and Equipment Removal.............................. 2-41
 

2.4.4.3 Transmission Line Removal ............................................................... 2-41
 

2.4.5 Operations and Maintenance Building Removal ................................................ 2-41
 

2.4.6 Structural Foundation Removal .......................................................................... 2-41
 

2.4.7 Road Removal..................................................................................................... 2-41
 

2.4.8 Reclamation Plan ................................................................................................ 2-42
 

2.4.8.1 Introduction......................................................................................... 2-42
 

2.4.8.2 Regrading and Retopsoiling Operations ............................................. 2-42
 

2.4.8.3 Topsoil Replacement and Seedbed Preparation.................................. 2-42
 

2.4.8.4 Revegetation Operations..................................................................... 2-42
 

2.4.8.5 Reclamation Monitoring Plan............................................................. 2-44
 

2.4.8.6 Stability and Erosion Control.............................................................. 2-44
 

2.4.8.7 Reclamation/Revegetation Success Monitoring ................................. 2-44 
EA, White Mountain Wind Energy Project iii 

TABLE OF CONTENTS (Continued) 

Page 

2.5 DESIGN FEATURES OF THE PROPOSED ACTION AND ALTERNATIVE A .......... 2-44
 

2.5.1 Public Safety, Occupational Safety, and Hazardous Materials and Waste 

Management .................................................................................................... 2-44
 

2.5.2 Construction and O&M Operations .................................................................... 2-46
 

2.5.3 Decommissioning and Reclamation Operations ................................................. 2-48
 

2.5.4 Transportation..................................................................................................... 2-49
 

2.5.5 Wildlife ............................................................................................................... 2-50
 

2.5.5.1 Raptors................................................................................................ 2-50
 

2.5.5.2 Passerine and Other Small Birds......................................................... 2-50
 

2.5.5.3 Bats ..................................................................................................... 2-51
 

2.5.5.4 Pygmy Rabbits.................................................................................... 2-51
 

2.5.5.5 Mule Deer, Pronghorn Antelope, and Elk .......................................... 2-51
 

2.5.5.6 Greater Sage-grouse............................................................................ 2-52
 

2.5.5.7 Cedar Rim Thistle............................................................................... 2-52
 

2.5.5.8 Colorado River Endangered Fish Species........................................... 2-52
 

2.5.5.9 Midget-faded Rattlesnake and Other Reptiles and Amphibians......... 2-52
 

2.5.5.10 Wildlife Monitoring.......................................................................... 2-52
 

2.5.6 Wild Horses ........................................................................................................ 2-53
 

2.5.7 Livestock............................................................................................................. 2-53
 

2.5.8 Control of Invasive Nonnative Species............................................................... 2-54
 

2.5.9 Air Quality and Fugitive Dust Control ............................................................... 2-54
 

2.5.10 Noise ................................................................................................................. 2-54
 

2.5.11 Water Resource Protection ............................................................................... 2-54
 

2.5.12 Fire Prevention Plan.......................................................................................... 2-55
 

2.5.13 Cultural Resources............................................................................................ 2-55
 

2.5.14 Paleontology ..................................................................................................... 2-55
 

2.5.15 Visual Resources............................................................................................... 2-56
 

2.5.16 Bonding............................................................................................................. 2-57
 

2.6 ALTERNATIVE A - DEVELOPMENT ONLY ON PRIVATE LANDS ......................... 2-57
 

2.7 NO ACTION ALTERNATIVE.......................................................................................... 2-59
 

2.8 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM DETAILED 

STUDY ......................................................................................................................... 2-59
 

2.8.1 Alternative Wind Energy Facility Site................................................................ 2-59
 

2.8.2 Place More Wind Turbines Within the WMWE Project Area............................ 2-59
 

3.0 AFFECTED ENVIRONMENT ....................................................................................................... 3-1
 

3.1 AIR QUALITY AND CLIMATE ...................................................................................... 3-1
 

3.1.1 Air Quality .......................................................................................................... 3-1
 

3.1.2 Climate................................................................................................................ 3-1
 

3.1.3 Global Climate Change....................................................................................... 3-3
 

3.2 CULTURAL RESOURCES (INCLUDING NATIVE AMERICAN CONCERNS) ......... 3-3
 

3.2.1 Cultural Resources.............................................................................................. 3-3
 

3.2.1.1 Cultural Resources Within the APE for Direct Effects....................... 3-4
 

3.2.1.2 Cultural Resources Within the APE for Visual Effects ...................... 3-5
 

3.2.2 Native American Concerns................................................................................. 3-5 
iv EA, White Mountain Wind Energy Project 

TABLE OF CONTENTS (Continued) 

Page 

3.3 GEOLOGY AND PALEONTOLOGY .............................................................................. 3-6
 

3.4 LAND USE......................................................................................................................... 3-8
 

3.4.1 Grazing................................................................................................................ 3-8
 

3.4.2 Recreation ........................................................................................................... 3-8
 

3.4.3 Transportation..................................................................................................... 3-9
 

3.5 NOISE................................................................................................................................. 3-9
 

3.6 SOCIOECONOMICS......................................................................................................... 3-11
 

3.6.1 Demography........................................................................................................ 3-11
 

3.6.2 Health, Safety, and Transportation ..................................................................... 3-12
 

3.7 SOILS ................................................................................................................................. 3-12
 

3.8 THREATENED, ENDANGERED, PROPOSED, CANDIDATE, AND BLM 

SENSITIVE SPECIES.................................................................................................. 3-14
 

3.8.1 TEPC Animal and Plant Species......................................................................... 3-14
 

3.8.2 BLM Sensitive Animal and Plant Species .......................................................... 3-18
 

3.9 VEGETATION (INCLUDING INVASIVE SPECIES AND WETLANDS) .................... 3-27
 

3.10 VISUAL RESOURCES.................................................................................................... 3-29
 

3.11 WILD HORSES................................................................................................................ 3-33
 

3.12 WILDLIFE........................................................................................................................ 3-33
 

3.12.1 Big Game .......................................................................................................... 3-33
 

3.12.1.1 Pronghorn Antelope.......................................................................... 3-33
 

3.12.1.2 Mule Deer ......................................................................................... 3-35
 

3.12.1.3 Elk..................................................................................................... 3-35
 

3.12.2 Small Mammals ................................................................................................ 3-35
 

3.12.3 Bats ................................................................................................................... 3-39
 

3.12.4 Raptors.............................................................................................................. 3-40
 

3.12.5 Upland Game Birds........................................................................................... 3-40
 

3.12.6 Migratory Birds................................................................................................. 3-42
 

4.0 ENVIRONMENTAL CONSEQUENCES ...................................................................................... 4-1
 

4.1 AIR QUALITY AND CLIMATE ...................................................................................... 4-1
 

4.1.1 Proposed Action.................................................................................................. 4-1
 

4.1.1.1 Introduction......................................................................................... 4-1
 

4.1.1.2 Construction Phase ............................................................................. 4-1
 

4.1.1.3 O&M Phase......................................................................................... 4-4
 

4.1.1.4 Decommissioning Phase ..................................................................... 4-4
 

4.1.2 Alternative A - Development Only on Privately Owned Lands ......................... 4-5
 

4.1.3 No Action Alternatives ....................................................................................... 4-5
 

4.1.4 Residual Impacts................................................................................................. 4-6
 

4.1.5 Cumulative Impacts ............................................................................................ 4-6
 

4.2 CULTURAL RESOURCES (INCLUDING NATIVE AMERICAN CONCERNS) ......... 4-7
 

4.2.1 Proposed Action.................................................................................................. 4-8
 

4.2.1.1 Effects to Cultural Resources Within the APE for Direct Effects ...... 4-8
 

4.2.1.2 Effects to Cultural Resources Within the APE for Visual Effects...... 4-9
 

4.2.1.3 Native American Concerns................................................................. 4-9
 

4.2.1.4 Summary of Project Effects................................................................ 4-9
 

4.2.2 Alternative A - Development Only on Privately Owned Lands ......................... 4-10 
EA, White Mountain Wind Energy Project v 

TABLE OF CONTENTS (Continued) 

Page 

4.2.3 No Action Alternative......................................................................................... 4-10
 

4.2.4 Residual Impacts................................................................................................. 4-10
 

4.2.5 Cumulative Impacts ............................................................................................ 4-10
 

4.3 GEOLOGY AND PALEONTOLOGICAL RESOURCES................................................ 4-11
 

4.3.1 Proposed Action.................................................................................................. 4-11
 

4.3.1.1 Construction Phase ............................................................................. 4-11
 

4.3.1.2 O&M Phase......................................................................................... 4-12
 

4.3.1.3 Decommissioning Phase ..................................................................... 4-12
 

4.3.2 Alternative A - Development Only on Privately Owned Lands ......................... 4-12
 

4.3.2.1 Construction Phase ............................................................................. 4-12
 

4.3.2.2 O&M Phase......................................................................................... 4-12
 

4.3.2.3 Decommissioning Phase ..................................................................... 4-12
 

4.3.3 No Action Alternative......................................................................................... 4-13
 

4.3.4 Residual Impacts................................................................................................. 4-13
 

4.3.5 Cumulative Impacts ............................................................................................ 4-13
 

4.4 LAND USE (INCLUDING GRAZING, RECREATION, AND
 

TRANSPORTATION) ................................................................................................. 4-13
 

4.4.1 Proposed Action.................................................................................................. 4-13
 

4.4.1.1 Construction Phase ............................................................................. 4-13
 

4.4.1.2 O&M Phase......................................................................................... 4-15
 

4.4.1.3 Decommissioning Phase ..................................................................... 4-15
 

4.4.2 Alternative A - Development Only on Privately Owned Lands ......................... 4-16
 

4.4.2.1 Construction Phase ............................................................................. 4-16
 

4.4.2.2 O&M Phase......................................................................................... 4-16
 

4.4.2.3 Decommissioning Phase ..................................................................... 4-17
 

4.4.3 No Action Alternatives ....................................................................................... 4-17
 

4.4.4 Residual Impacts................................................................................................. 4-17
 

4.4.5 Cumulative Impacts ............................................................................................ 4-17
 

4.5 NOISE................................................................................................................................. 4-18
 

4.5.1 Proposed Action.................................................................................................. 4-18
 

4.5.1.1 Construction Phase ............................................................................. 4-18
 

4.5.1.2 O&M Phase......................................................................................... 4-19
 

4.5.1.3 Decommissioning Phase ..................................................................... 4-20
 

4.5.2 Alternative A - Development Only on Privately Owned Lands ......................... 4-20
 

4.5.2.1 Construction Phase ............................................................................. 4-20
 

4.5.2.2 O&M Phase......................................................................................... 4-20
 

4.5.2.3 Decommissioning Phase ..................................................................... 4-21
 

4.5.3 No Action Alternatives ....................................................................................... 4-21
 

4.5.4 Residual Impacts................................................................................................. 4-21
 

4.5.5 Cumulative Impacts ............................................................................................ 4-21
 

4.6 SOCIOECONOMICS......................................................................................................... 4-21
 

4.6.1 Proposed Action.................................................................................................. 4-21
 

4.6.1.1 Construction Phase ............................................................................. 4-22
 

4.6.1.2 O&M Phase......................................................................................... 4-26
 

4.6.1.3 Decommissioning Phase ..................................................................... 4-29 
vi EA, White Mountain Wind Energy Project 

TABLE OF CONTENTS (Continued) 

Page 

4.6.2 Alternative A - Development Only on Privately Owned Lands ......................... 4-31
 

4.6.2.1 Construction Phase ............................................................................. 4-31
 

4.6.2.2 O&M Phase......................................................................................... 4-32
 

4.6.2.3 Decommissioning Phase ..................................................................... 4-33
 

4.6.3 No Action Alternative......................................................................................... 4-34
 

4.6.4 Residual Impacts................................................................................................. 4-35
 

4.6.5 Cumulative Impacts ............................................................................................ 4-35
 

4.7 SOILS ................................................................................................................................. 4-35
 

4.7.1 Proposed Action.................................................................................................. 4-35
 

4.7.1.1 Construction Phase ............................................................................. 4-35
 

4.7.1.2 O&M Phase......................................................................................... 4-36
 

4.7.1.3 Decommissioning Phase ..................................................................... 4-36
 

4.7.2 Alternative A - Development Only on Privately Owned Lands ......................... 4-36
 

4.7.2.1 Construction Phase ............................................................................. 4-36
 

4.7.2.2 O&M Phase......................................................................................... 4-37
 

4.7.2.3 Decommissioning Phase ..................................................................... 4-37
 

4.7.3 No Action Alternatives ....................................................................................... 4-37
 

4.7.4 Residual Impacts................................................................................................. 4-37
 

4.7.5 Cumulative Impacts ............................................................................................ 4-37
 

4.8 THREATENED, ENDANGERED, CANDIDATE, PROPOSED, AND BLM 

SENSITIVE SPECIES.................................................................................................. 4-38
 

4.8.1 TEPC Species ..................................................................................................... 4-38
 

4.8.2 BLM Sensitive Species....................................................................................... 4-38
 

4.8.2.1 Construction Phase ............................................................................. 4-38
 

4.8.2.2 O&M Phase......................................................................................... 4-40
 

4.8.2.3 Decommissioning Phase ..................................................................... 4-46
 

4.8.3 Alternative A - Development Only on Privately Owned Lands ......................... 4-46
 

4.8.4 No Action Alternatives ....................................................................................... 4-46
 

4.8.5 Residual Impacts................................................................................................. 4-46
 

4.8.6 Cumulative Impacts ............................................................................................ 4-46
 

4.9 VEGETATION (INCLUDING WETLANDS AND INVASIVE SPECIES) .................... 4-48
 

4.9.1 Proposed Action.................................................................................................. 4-48
 

4.9.1.1 Construction Phase ............................................................................. 4-48
 

4.9.1.2 O&M Phase......................................................................................... 4-49
 

4.9.1.3 Decommissioning Phase ..................................................................... 4-49
 

4.9.2 Alternative A - Development Only on Privately Owned Lands ......................... 4-49
 

4.9.2.1 Construction Phase ............................................................................. 4-49
 

4.9.2.2 O&M Phase......................................................................................... 4-49
 

4.9.2.3 Decommissioning Phase ..................................................................... 4-49
 

4.9.3 No Action Alternatives ....................................................................................... 4-49
 

4.9.4 Residual Impacts................................................................................................. 4-49
 

4.9.5 Cumulative Impacts ............................................................................................ 4-49
 

4.10 VISUAL RESOURCES.................................................................................................... 4-50
 

4.10.1 Proposed Action................................................................................................ 4-50
 

4.10.2 Alternative A - Development Only on Privately Owned Lands ....................... 4-51
 

4.10.3 No Action Alternatives ..................................................................................... 4-53 
EA, White Mountain Wind Energy Project vii 

TABLE OF CONTENTS (Continued) 

Page 

4.10.4 Residual Impacts............................................................................................... 4-53
 

4.10.5 Cumulative Impacts .......................................................................................... 4-53
 

4.11 WILD HORSES................................................................................................................ 4-54
 

4.11.1 Proposed Action................................................................................................ 4-54
 

4.11.2 Alternative A - Development Only on Privately Owned Lands ....................... 4-55
 

4.11.3 Residual Impacts............................................................................................... 4-55
 

4.11.4 Cumulative Impacts .......................................................................................... 4-55
 

4.12 WILDLIFE........................................................................................................................ 4-55
 

4.12.1 Proposed Action................................................................................................ 4-56
 

4.12.1.1 Construction Phase ........................................................................... 4-56
 

4.12.1.2 O&M Phase....................................................................................... 4-59
 

4.12.1.3 Decommissioning Phase ................................................................... 4-66
 

4.12.2 Alternative A - Development Only on Privately Owned Lands ....................... 4-66
 

4.12.2.1 Construction Phase ........................................................................... 4-66
 

4.12.2.2 O&M Phase....................................................................................... 4-67
 

4.12.2.3 Decommissioning Phase ................................................................... 4-67
 

4.12.3 No Action Alternatives ..................................................................................... 4-67
 

4.12.4 Residual Impacts............................................................................................... 4-67
 

4.12.5 Cumulative Impacts .......................................................................................... 4-67
 

4.12.5.1 Wildlife (Including Big Game)......................................................... 4-67
 

4.12.5.2 Bats ................................................................................................... 4-70
 

4.12.5.3 Raptors and Other Birds ................................................................... 4-70
 

4.13 ENVIRONMENTAL PROTECTION MEASURES........................................................ 4-71
 

5.0 CONSULTATION AND COORDINATION.................................................................................. 5-1
 

5.1 INTRODUCTION .............................................................................................................. 5-1
 

5.2 LIST OF AGENCIES, ORGANIZATIONS, AND INDIVIDUALS CONTACTED ........ 5-1
 

5.3 LIST OF PREPARERS....................................................................................................... 5-1
 

6.0 REFERENCES ................................................................................................................................ 6-1
 

APPENDIX A: SCOPING NOTICE 

APPENDIX B: SUMMARY OF NATIVE AMERICAN CONSULTATION 

APPENDIX C: VISUAL SIMULATION REPORT AND VISUAL CONTRAST RATING 

ANALYSIS FOR THE WHITE MOUNTAIN WIND ENERGY PROJECT 

APPENDIX D: CULTURAL RESOURCES WITH POTENTIAL VISUAL EFFECTS 
viii EA, White Mountain Wind Energy Project 

LIST OF FIGURES 

Page 

Figure 1.1 General Location Map .................................................................................................. 1-3
 

Figure 1.2 WMWE Project Area and Wyoming Class 4+ Winds, Areas of Environmental 

Conflict ......................................................................................................................... 1-4
 

Figure 2.1 Typical Wind Turbine Components.............................................................................. 2-2
 

Figure 2.2 Layout of the White Mountain Wind Energy Project................................................... 2-3
 

Figure 2.3 General Wind Turbine Nacelle Components (Adapted from DOE [2004]). ................ 2-6
 

Figure 2.4 Typical Electrical System Components ........................................................................ 2-7
 

Figure 2.5 Typical Turbine String Road and Electrical Collection System Layout....................... 2-8
 

Figure 2.6 Typical Coring Truck and Support Vehicle.................................................................. 2-12
 

Figure 2.7 Typical Coring Tracked Vehicle................................................................................... 2-12
 

Figure 2.8 Constructed Turbine Access Road................................................................................ 2-16
 

Figure 2.9 Typical Road and Turbine Construction Layout........................................................... 2-17
 

Figure 2.10 Typical Mat Foundation Installation (During Construction). ....................................... 2-20
 

Figure 2.11 Typical Pier Foundation Installation (Post-construction) ............................................. 2-20
 

Figure 2.12 Typical Wind Turbine and Crane ................................................................................. 2-21
 

Figure 2.13 Typical Wind Energy Facility O&M Building ............................................................. 2-23
 

Figure 2.14 Typical Wind Turbine Blade Delivery Truck (Photograph Obtained from Vestas)..... 2-26
 

Figure 2.15 Typical Open Trench Placement of the Cable .............................................................. 2-28
 

Figure 2.16 Typical Cable Plowing Machine in Operation.............................................................. 2-28
 

Figure 2.17 Typical Construction of a Substation Buswork. ........................................................... 2-29
 

Figure 2.18 FAA-approved Wind Tower Lighting Layout.............................................................. 2-31
 

Figure 2.19 Typical Schematic of Turbine Assembly Area Plan..................................................... 2-32
 

Figure 2.20 Example of Rotor Assembly......................................................................................... 2-33
 

Figure 2.21 Typical Tracked Crane.................................................................................................. 2-33 
EA, White Mountain Wind Energy Project ix 

LIST OF FIGURES (Continued) 

Page 

Figure 2.22 Typical Midsection Tower Assembly........................................................................... 2-35
 

Figure 2.23 Typical Turbine Nacelle Placement.............................................................................. 2-35
 

Figure 2.24 Typical Complete Rotor Pickup.................................................................................... 2-36
 

Figure 2.25 Layout of WMWE Project, Alternative A .................................................................... 2-58
 

Figure 3.1 Surface Geology, WMWE Project................................................................................ 3-7
 

Figure 3.2 Grazing Allotment, WMWE Project............................................................................. 3-10
 

Figure 3.3 Location of Level 12 HUC ........................................................................................... 3-13
 

Figure 3.4 Soil Types, WMWE Project ......................................................................................... 3-15
 

Figure 3.5 Upland Game Bird Areas and Greater Sage-grouse Core Habitat Area, 

WMWE Project............................................................................................................. 3-25
 

Figure 3.6 Vegetation, WMWE Project ......................................................................................... 3-28
 

Figure 3.7 National Wetland Inventory Information, WMWE Project.......................................... 3-30
 

Figure 3.8 Visual Resource Management Areas (Public Lands Only), WMWE Project............... 3-32
 

Figure 3.9 Wild Horse Management Areas, WMWE Project........................................................ 3-34
 

Figure 3.10 Pronghorn Antelope Habitat Ranges, WMWE Project................................................. 3-36
 

Figure 3.11 Mule Deer Habitat Ranges, WMWE Project................................................................ 3-37
 

Figure 3.12 Elk Habitat Ranges, WMWE Project............................................................................ 3-38
 

Figure 3.13 General Location of 2008 Active Raptor Nests and Seasonal Buffers ......................... 3-41
 

Figure 4.1 Location of Proposed Action and RFFAs..................................................................... 4-2
 

Figure 4.2 Total Number of Jobs Created, Proposed Action. ........................................................ 4-23
 

Figure 4.3 Jobs Created in Rock Springs/Green River, Proposed Action...................................... 4-23
 

Figure 4.4 Greater Sage-grouse Core Habitat Area, Northeast of WMWE Project Area .............. 4-45
 
x EA, White Mountain Wind Energy Project 

LIST OF TABLES 

Page 

Table 1.1 Supplemental Authorities Considered .......................................................................... 1-6
 

Table 1.2 Major Federal, State, and Local Permits, Approvals, and Authorizing Actions for 

the WMWE Project, Sweetwater County, Wyoming, 2009 ......................................... 1-8
 

Table 1.3 Issues............................................................................................................................. 1-11
 

Table 2.1 Landownership Within the WMWE Project Area ........................................................ 2-4
 

Table 2.2 Estimated Acres of Surface Disturbance Within the WMWE Project Area 

(Proposed Action)......................................................................................................... 2-4
 

Table 2.3 Estimated Acres of Surface Disturbance on BLM-administered Land Within the 

WMWE Project Area.................................................................................................... 2-5
 

Table 2.4 List of Typical Equipment Used for Construction of Wind Energy Facilities ............. 2-11
 

Table 2.5 Typical Construction Schedule for One Phase of Approximately 60 Turbines............ 2-23
 

Table 2.6 Estimated Number Vehicle Loads for Component Delivery ........................................ 2-25
 

Table 2.7 Estimated Number Vehicle Trips During Construction Operations ............................. 2-26
 

Table 2.8 Reclamation Seed Mixture............................................................................................ 2-43
 

Table 2.9 Season Restrictions for Surface Disturbance Activities ............................................... 2-51
 

Table 2.10 Estimated Acres of Surface Disturbance Within the WMWE Project Area Under 

Alternative A................................................................................................................. 2-59
 

Table 3.1 Selected National, Colorado, and Wyoming Air Quality Standards (μg/m3

). .............. 3-2
 

Table 3.2 Geologic Formations and Fossil Potential, WMWE Project .......................................... 3-9
 

Table 3.3 Noise Levels of Commonly Heard Sounds................................................................... 3-11
 

Table 3.4 Federal Threatened, Endangered, Proposed, and Candidate Species and Their 

Potential Occurrence Within the Proposed Project Area, 2009 .................................... 3-16
 

Table 3.5 Wyoming BLM Sensitive Species, Habitat Preference, and Occurrence of Habitat 

and Observational Data, WMWE Project, 2009........................................................... 3-20
 

Table 3.6 BLM Visual Resource Management Class Objectives ................................................. 3-31 

Table 3.7 Bat Species Determined from Range Maps as Likely to Occur Within the 

WMWE Project Area, Sorted by Call Frequency......................................................... 3-39
 
EA, White Mountain Wind Energy Project xi 

LIST OF TABLES (Continued) 

Page 

Table 3.8 Avian Species Recorded Within the WMWE Project Area and Vicinity During 

2008 Project-related Studies ......................................................................................... 3-43
 

Table 4.1 Project Emission Profile ............................................................................................... 4-3
 

Table 4.2 Potential Air Quality Emissions from Mobile Concrete Batch Plant Emissions, 

Proposed Action............................................................................................................ 4-4
 

Table 4.3 Potential Air Quality Emissions from the Mobile Concrete Batch Plant, 

Alternative A................................................................................................................. 4-5
 

Table 4.4 Comparison of Annual Air Emissions from Wyoming Electric Generation 

Sources.......................................................................................................................... 4-7
 

Table 4.5 Cumulative Impacts for Land Use ................................................................................ 4-18
 

Table 4.6 Annual Sales and Use Tax Revenue Generated During the Construction Phase of 

WMWE Project, Proposed Action................................................................................ 4-24
 

Table 4.7 Projected Property Tax Revenue Generated During the Construction Phase of the 

WMWE Project, Proposed Action................................................................................ 4-25
 

Table 4.8 Population and Housing for Communities in the Rock Springs/Green River Area...... 4-26
 

Table 4.9 Annual Sales and Use Tax Revenue Generated During the O&M Phase of 

WMWE Project, Proposed Action................................................................................ 4-28
 

Table 4.10 Annual Sales and Use Tax Revenue Generated During the Decommissioning 

Phase of the WMWE Project, Proposed Action ........................................................... 4-30
 

Table 4.11 Cumulative Impacts Due to Direct Disturbance to BLM Sensitive Species................. 4-47
 

Table 4.12 Design Features to Minimize Impacts to Visual Resources ......................................... 4-52
 

Table 4.13 Wind Energy Facilities in the U.S. with both Preconstruction Anabat Sampling 

Data and Post-construction Mortality Data for Bat Species ......................................... 4-63
 

Table 4.14 IAAs for Wildlife Resources ........................................................................................ 4-68
 

Table 5.1 Record of Persons, Groups, and Governmental Agencies Contacted or Provided 

Comments ..................................................................................................................... 5-1
 

Table 5.2 List of EA Preparers ..................................................................................................... 5-6
 
EA, White Mountain Wind Energy Project xiii 

LIST OF ACRONYMS AND ABBREVIATIONS 

AML Appropriate Management Level 

ASTM American Society for Testing and 

Materials 

AUM Animal unit months 

AWEA American Wind Energy 

Association 

BLM Bureau of Land Management 

BMPs Best management practices 

BOP Balance of Plant 

CAAQS Colorado Ambient Air Quality 

Standards 

CBNG Coal bed natural gas 

CERCLA Comprehensive Environmental 

Response, Compensation, and 

Liability Act 

CFR Code of Federal Regulations 

CO Carbon monoxide 

CO2 Carbon dioxide 

dBA A-weighted decibels 

DOC U.S. Department of Commerce 

DOE U.S. Department of Energy 

EA Environmental assessment 

EIS Environmental impact statement 

EPA Environmental Protection Agency 

FAA Federal Aviation Administration 

FR Federal Regulation 

Ft Foot or feet 

GAO General Accounting Office 

GHG Greenhouse Gases 

GIS Geographic Information System 

Ha Hectare 

HSE Health, Safety, and Environment 

HUC Hydrologic Unit Code 

I-80 Interstate 80 

IAA Cumulative impact assessment 

areas 

IEC International Electrotechnical 

Commission 

JEDI Job and Economic Development 

Impact 

kHz Kilohertz 

km kilometer 

KOPs Key Observation Points 

kV Kilovolt 

KWh Kilowatt hours 

LLC Lloyd Levy Consulting, LLC 

met Meteorological tower 

mi 

mph 

MW 

MWh 

NAAQS 

NEPA 

NHPA 

NO2 

NOx 

NRHP 

NWI 

O&M 

OHV 

PA 

PAWG 

PEIS 

PEMC 

PFYC 

PLS 

PM2.5 

PM10 

POD 

PSB 

PSD 

PUSA 

RFFA 

RIP 

RLB 

RMP 

ROD 

ROW 

RSFO 

RSGA 

RV 

SCADA 

Mile 

Miles per hour 

Megawatt 

Megawatt hour 

National Ambient Air Quality 

Standards 

National Environmental Policy 

Act 

National Historic Preservation 

Act 

 Nitrogen dioxide 

 Nitrogen oxide 

National Register of Historic 

Places 

National Wetland Inventory 

Operations and maintenance 

Off-highway vehicle 

Programmatic Agreement 

Pinedale Anticline Working 

Group 

Programmatic environmental 

impact statement 

Palustrine seasonally flooded 

wetland 

Probable Fossil Yield 

Classification 

Pure live seed 

Particulate matter <2.5 μg/m3 

Particulate matter <10 μg/m3 

Plan of Development 

Passerine and small birds 

Prevention of Significant 

Deterioration 

Palustrine unconsolidated bed, 

temporarily flooded 

Reasonably foreseeable future 

actions 

Recovery and Implementation 

Program 

Raptors and large birds 

Resource Management Plan 

Record of Decision 

Right-of-way 

Rock Springs Field Office 

Rock Springs Grazing Association 

Recreational vehicle 

Supervisory control and data 

acquisition 
xiv EA, White Mountain Wind Energy Project 

LIST OF ACRONYMS AND ABBREVIATIONS (Continued) 

SGIT Sage-grouse Implementation 

Team 

SHPO State Historic Preservation Office 

SO2 Sulfur dioxide 

SPCCP Spill Prevention, Control, and 

Countermeasure Plan 

SWPPP Storm Water Pollution Prevention 

Plan 

TCP Traditional Cultural Properties 

TEPC Threatened, endangered, and 

proposed, and candidate 

Teton Teton Wind, LLC 

TRC TRC Environmental Corporation 

TSP Total suspended particulates 

UGBMA Upland Game Bird Management 

Area 

μg/m3 Micrograms per cubic meter of air 

U.S.C. United States Code 

USDOC U.S. Department of Commerce 

USFWS U.S. Fish and Wildlife Service 

VMT Vehicle-mile traveled 

VOC Volatile organic compounds 

VRM Visual Resource Management 

WAAQS 

WAQS&R 

WDEQ/AQD 

WDEQ/WQD 

WECC 

WGFD 

WHHMA 

Wind Energy 

PEIS 

WMWE 

WNDD 

W.S. 

WYGISC 

Wyoming Ambient Air Quality 

Standards 

Wyoming Air Quality Standards 

and Regulations 

Wyoming Department of 

Environmental Quality/Air 

Quality Division 

Wyoming Department of 

Environmental Quality/Water 

Quality Division 

Western Electricity Coordinating 

Council 

Wyoming Game and Fish 

Department 

Wild Horse Herd Management 

Area 

Wind Energy Programmatic 

Environmental Impact Statement 

White Mountain Wind Energy 

Wyoming Natural Diversity 

Database 

Wyoming Statute 

Wyoming Geographic 

Information System Center 
EA, White Mountain Wind Energy Project 1-1 

1.0 INTRODUCTION 

This environmental assessment (EA) has been 

prepared to analyze the potential environmental 

consequences of the proposed White Mountain 

Wind Energy (WMWE) Project as proposed by 

Teton Wind, LLC (Teton), a wholly owned 

subsidiary of Tasco Engineering, Lehi, Utah. 

The project site is located on top of White 

Mountain, which is west-northwest of the city of 

Rock Springs, Sweetwater County, Wyoming, in 

portions of T19N-T20N, R105W-106W. The 

project area encompasses 13,165 acres of which 

8,527 aces are private lands, 240 acres owned by 

the State of Wyoming, and 4,398 are public lands 

managed by the Bureau of Land Management 

(BLM). 

In 2005, the Bureau of Land Management (BLM) 

prepared a programmatic environmental impact 

statement (PEIS) for wind energy development in 

the western U.S.--Final Programmatic 

Environmental Impact Statement on Wind Energy 

Development on BLM-Administered Lands in the 

Western United States (Wind Energy PEIS) 

(BLM 2005). This EA is tiered to the PEIS, and 

presents a site-specific analysis of potential 

impacts that could result from the implementation 

of the Proposed Action and incorporates the 

analysis conducted in that document. 

Additionally, it is BLM policy (IM 2009-043), 

consistent with the Energy Policy Act of 2005, to 

encourage development of wind energy in 

acceptable areas. Further, development of 

renewable domestic energy would help meet 

national security objectives. 

Several agencies having jurisdiction by law and/or 

special expertise elected to become cooperating 

agencies. These agencies include Sweetwater 

County, the City of Rock Springs, Sweetwater 

County Conservation District, and a number of 

State of Wyoming agencies working under the 

direction of the Governor’s Office. Besides the 

Governor’s Office other state agencies 

participating as cooperators include Wyoming 

Game and Fish Department, State Historic 

Preservation Office, Department of Environmental 

Quality - Industrial Siting Division and Water 

Quality Division, and the Wyoming Department of 

Agriculture. Further, where applicable, this 

analysis may be used by those cooperating 

agencies having jurisdiction by law in their 

permitting requirements. 

1.1 BACKGROUND 

Recent national and regional forecasts project an 

increase in consumption of electrical energy 

continuing into the foreseeable future. Renewable 

energy, including wind generation, is expected to 

provide a larger component of the electrical supply 

in the future. Increased consumption requires 

development of new generation facilities to satisfy 

demand, as substantiated by the following sources. 

•	 The Energy Information Administration, a 

statistical agency of the U.S. Department 

of Energy (DOE), states in the Annual 

Energy Outlook 2009 with Projections to 

2030 (DOE 2009) that total electricity 

demand is projected to grow by 1.1% per 

year from 2004 through 2030. Renewable 

sources of electricity are expected to grow 

at a higher rate of 2.2% annually, which 

represents an increase of over 270 billion 

kilowatt-hours (kWh) by 2030. Wind 

energy alone is anticipated to provide 124 

billion kWh of electricity by 2030, 

compared to 26 billion kWh in 2006 

(DOE 2008). 

•	 The Western Electricity Coordinating 

Council (WECC) forecasts electricity 

demand in the western U.S. In the 10-

Year Coordinated Plan Summary 

2006-2015 (WECC 2006), the WECC 

states that capacity margins are declining, 

and from 2006 through 2015, annual 

energy use is projected to increase 2.2% 

(2.0% annual compound growth rate) 

(WECC 2006). 

•	 Further substantiation of the need for 

energy development is provided through 

the Western Governors’ Association goal 

of developing 30,000 megawatts (MW) of 

clean energy by 2015 from traditional and 

renewable energy sources and by the 

Energy Policy Act of 2005, which 
1-2 EA, White Mountain Wind Energy Project 

encourages the development of renewable 

energy resources, including wind energy, 

as part of an overall strategy to develop a 

diverse portfolio of domestic energy 

supplies for the future. 

Teton has applied for a development right-of-way 

(ROW) grant from the BLM, Rock Springs Field 

Office (RSFO) for authorization to use BLMadministered public lands for the construction, 

operation, maintenance, and termination of the 

proposed wind energy generation facility. 

Teton’s proposal consists of developing a 

commercial wind-powered electrical generating 

facility near Rock Springs, Wyoming (Figure 1.1). 

Approval of the proposed action could result in 

construction of up to 240 wind turbine generators 

with an anticipated total generating capacity of up 

to 360 MW. Construction of the project would 

occur in 4 phases. While the Proposed Action 

includes up to 240 wind turbine generators, it is 

possible that not all of the wind turbines would 

ultimately be installed due to the environmental or 

technical constraints or market conditions. This 

EA analyzes the potential impacts as if 240 wind 

turbine generators would be installed. Associated 

components would include an underground 

electrical system to collect energy from the 

turbines, access road system, operations and 

maintenance (O&M) building, and a substation. 

Other facilities required for construction include a 

mobile batch plant and equipment staging areas 

that would be located in the central portion of the 

project area (refer to Figure 2.2). 

The WMWE Project would be located on top of 

White Mountain, which is about 1.3 mi 

west-northwest of the city of Rock Springs, 

Wyoming. A boundary has been defined and 

encompasses 13,165 acres owned by private 

entities (Rock Springs Grazing Association 

[RSGA] and Anadarko), the State of Wyoming, 

and public lands managed by the BLM. 

Electrical power from the proposed project would 

be interconnected to an existing 230-kilovolt (kV) 

power transmission line once the substation is 

constructed. 

The Wyoming Governor’s office prepared a map 

of environmentally sensitive areas within Class 4+ 

wind areas of the State of Wyoming (Wyoming 

Game and Fish Department [WGFD] 2009b). 

Class IV winds are those that have been 

determined to be potentially economically viable 

for commercial wind energy development. The 

map represents known environmentally sensitive 

areas designated by various federal and state 

agencies. This geographic information system 

(GIS) data was overlaid with the Teton WMWE 

project boundary and results are illustrated in 

Figure 1.2. 

1.2 PURPOSE AND NEED FOR THE 

PROPOSED ACTION 

The purpose of the proposed action is to help 

fulfill future domestic demand for electrical power 

and state required renewable energy mandates for 

electrical power utilities. The need to meet future 

electrical power needs is well described 

documented in Section 1.1. 

1.3 DECISIONS TO BE MADE 

The decisions to be made include a determination 

of whether the impacts from the Proposed Action 

or alternatives are significant beyond those 

outlined in the PEIS, and if not, whether BLM 

should approve the application(s) and grant the 

necessary ROW(s) to allow Teton to develop the 

WMWE Project on public lands. If the effects 

present new significant impact (that exceed those 

outlined in the PEIS), BLM would proceed with a 

Notice of Intent to prepare an Environmental 

Impact Statement (EIS). 

This analysis may be used by other state and local 

agencies that have permitting authority on the 

adjacent private or state lands. 

1.4 CONFORMANCE WITH BLM LAND 

USE PLANS 

The Record of Decision (ROD) for the Wind 

Energy PEIS (BLM 2005) amended area land use 

plans, including the Green River Resource 


EA, White Mountain Wind Energy Project 1-5 

Management Plan (RMP). The decision 

implements a comprehensive wind energy 

development program to administer the 

development of wind energy resources on BLMadministered public lands. This decision excludes 

certain public lands from wind energy 

development (e.g., wilderness study areas, natural 

monuments, national conservation areas). The 

lands involved in this project do not contain any 

federally mandated exclusion areas. The decision 

established policies and best management 

practices (BMPs) for the administration of wind 

energy development activities and established 

minimum requirements for mitigation measures. 

BLM released updated wind energy policy for 

implementing the ROD and guidance for 

processing ROW applications for wind energy 

projects on public lands including BMPs (WO IM 

2009-043). 

The ROD for the Green River RMP (BLM 1997) 

provides management direction for resources 

contained within the RSFO area. The objectives 

applicable for this proposal include managing 

public land to support the goals and objectives of 

other resource programs and to respond to public 

demand for land use authorizations. Public lands 

will be made available for ROWs with the 

exception of defined exclusion and avoidance 

areas. The project proposal does not fall within 

any exclusion or avoidance areas (refer to Table 2 

of BLM 1997). 

1.5 RELATIONSHIP TO KEY STATUTES, 

REGULATIONS, OR OTHER PLANS 

As required by the ROD for the Wind Energy 

PEIS, the analysis prepared for the WMWE 

Project is project-specific, tiered to the PEIS, and 

focuses on the critical site-specific issues of 

concern. Use Authorizations under the Federal 

Land Policy and Management Act of 1976, as 

amended (43 United States Code [U.S.C]. 1701 et 

seq.) (i.e., ROWs) for the wind project area and 

off-project access roads and collection systems 

would be processed in accordance with the 

Federal Land Policy Management Act, Title V 

(43 U.S.C. 1761), regulations at 43 Code of 

Federal Regulations (CFR) 2800, and applicable 

federal and state ROW processing instruction 

memorandums. 

The National Environmental Policy Act of 1969 

(NEPA), as amended requires federal agencies to 

use a systematic interdisciplinary approach to 

ensure the integrated use of natural and social 

sciences in planning and decision-making. 

Other authorities may contain procedural 

requirements that pertain to the treatment of 

elements of the environment when the BLM is 

considering an action such as the one proposed. 

These supplemental authorities are outlined in 

Table 1.1 and are noted as to whether individual 

authorities apply to this action. 

1.6 REQUIRED PERMITS OR 

AUTHORIZATION 

Teton would be required to obtain various permits 

from landowners and federal, state, and local 

governments prior to construction or storage of 

equipment use. Table 1.2 lists the authorizations, 

permits, reviews, and approvals anticipated to be 

necessary for the proposed project. 

1.7 SCOPING AND ISSUES 

BLM released a revised NEPA handbook (BLM 

2008) in January 2008. Section 6.4 of the BLM 

NEPA Handbook (2008) formally defines an 

“issue” as a point of disagreement, debate, or 

dispute with a Proposed Action based on some 

anticipated environmental effect. An issue 

•	 has a cause and effect relationship with 

the proposal or an alternative; 

•	 is within the scope of the analysis; 

•	 has not been decided by law, regulation, 

or previous decision; and 

•	 is amendable to scientific analysis rather 

than conjecture. 

The BLM RSFO resource specialists, in 

conjunction with representatives from cooperating 

agencies, reviewed Teton’s proposed project and 

identified a number of potential issues. These 

issues were made part of the scoping notice sent to 

federal, state, and local agencies, interest groups, 

and interested individuals and a list of individuals 
1-6 EA, White Mountain Wind Energy Project 

Table 1.1 Supplemental Authorities Considered. 

Manual Discussed 

Element Authority Section in EA Rationale 

Air Quality The Clean Air Act, as amended 

(42 United States Code [U.S.C.] 7401 

et seq.) 

7300 Yes Fugitive dust 

emissions and 

emissions from 

mobile sources and 

construction 

Cultural Resources National Historic Preservation Act, as 

amended (16 U.S.C. 470) 

8100 Yes 

equipment 

Eligible sites in 

area 

Fish Habitat Magnuson-Stevens Act Provision: 

Essential Fish Habitat (EFH): Final 

Rule 

n/a No No fish habitat or 

fish in project area 

(50 CFR 600; 67 Federal Regulations 

[FR] 2376, January 17, 2002) 

Forests and 

Rangelands 

Healthy Forests Restoration Act of 2003 

(P.L. 108-148) 

n/a Yes Rangeland occurs 

in project area 

Migratory Birds Migratory Bird Treaty Act of 1918, as 

amended (16 U.S.C. 703 et seq.) 

Executive Order 131186, 

“Responsibilities of Federal Agencies to 

Protect Migratory Birds” January 10, 

2001 

n/a Yes Migratory birds 

occur in project 

area 

Native American 

Religious Concerns 

American Indian Religious Freedom Act 

of 1978 (42 U.S.C. 1996) 

8100 Yes Potential Native 

American issues 

exist in project area 

Threatened or 

Endangered Species 

Endangered Species Act of 1983, as 

amended (16 U.S.C. 1531) 

6840 Yes Colorado River 

water depletion 

Paleontological 

Resources 

Federal Land Policy and Management 

Act of 1976 (43 U.S.C. 1701 et seq.); 

National Environmental Policy Act of 

1969 (42 U.S.C. 4321 et seq.) 

8270 Yes Potential vertebrate 

fossils may exist in 

project area 

Wastes, Hazardous 

or Solid 

Resource Conservation and Recovery 

Act of 1976 (43 U.S.C. 6901 et seq.) 

Comprehensive Environmental 

Response, Compensation, and Liability 

Act of 1980, as amended 

(43 U.S.C. 9615) 

9180 

9183 

No No hazardous 

waste issues 
EA, White Mountain Wind Energy Project 1-7 

Table 1.1 (Continued) 

Manual Discussed 

Element Authority Section in EA Rationale 

Water Quality Safe Drinking Water Act of 1977 7240 No No surface water 

Drinking-Ground (43 U.S.C. 300f et seq.) occurs in project 

area 

Clean Water Act of 1977 (33 U.S.C. 9184 No 

1251 et seq.) No surface water 

occurs in project 

area 

Wild and Scenic Wild and Scenic Rivers Act, as amended 8014 No No surface water or 

Rivers (16 U.S.C. 1271) river streams occur 

in project area 

Wilderness Federal Land Policy and Management 8500 No No wilderness or 

Act of 1976 (43 U.S.C. 1701 et seq.); wilderness study 

Wilderness Act of 1964 areas occur in 

(16 U.S.C. 1131 et seq.) project area 

Environmental Executive Order 12898, n/a No Project area does 

Justice “Environmental Justice” not include any 

February 11, 1994 settlements or 

dwellings 

Floodplains Executive Order 1198, as amended, 7260 No No floodplains 

Floodplain Management, 5/24/77 occur in project 

area 

Wetlands-Riparian Executive Order 11990 Protection of 6740 Yes National Wetland 

Zones Wetlands 5/24/77 Inventory (NWI) 

maps indicate 

wetlands in project 

area or waters of 

the U.S. 

Department of W.O. IM2009-04, 12/19/08 n/a No Final consultation 

Defense (DOD) with DOD 4/20/09, 

Military Airspace no military 

operations affected 

Broadcast Signal Federal Communication Commission n/a No Broadcast 

Interference interference 

concerns resolved, 

6/25/09 

Aviation Hazards Federal Aviation Administration (FAA), n/a No No aviations 

Aeronautical Study, 49 U.S.C. 44718 hazard 

determination, 

FAA, 3/26/09 

Fluid Mineral Federal Land Management Policy Act of 2805 No Lessee’s questions 

Leases 1976, Mineral Leasing Act of 1920 3150 on ability to 

explore lease at a 

later time 

answered, 1/22/09 
1-8 EA, White Mountain Wind Energy Project 

Table 1.2 Major Federal, State, and Local Permits, Approvals, and Authorizing Actions for the 

WMWE Project, Sweetwater County, Wyoming, 2009.1 

Agency Permit, Approval, or Action Authority 

Office of the President Protection and enhancement of the Executive Order 11593 

of the United States cultural environment 

Floodplains management Executive Order 11988 

Protection of wetlands Executive Order 11990 

Environmental justice Executive Order 12898 

Indian sacred sites Executive Order 13007 

Invasive species Executive Order 13112 

Protection of migratory birds Executive Order 13186 

Trails for America in the 21st Executive Order 13195 

century 

Preserve America Executive Order 13287 

Bureau of Land 

Management (BLM) 

Right-of-way grants U.S. Department of Interior/Department of 

Agriculture/Department of Transportation 

Public Law 96-487 Federal Regulations (FR) 

6-3-81

 Environmental assessment 

preparation 

National Environmental Policy Act (NEPA), 

40 Code of Federal Regulations (CFR) 

Parts 1500-1508; Federal Land Policy and 

Management Act of 1976 (as amended), 

Public Law 94-579. 

Antiquities and cultural resource 

clearances on BLM-managed land 

Antiquities Act of 1906 (16 U.S.C. 

Section 431-433); Archaeological Resources 

Public Protection Act of 1979 (16 U.S.C. 

Sections 470aa - 470ll); 43 CFR 3; National 

Historic Preservation Act of 1966 (NHPA) 

and Advisory Council Regulations (36 CFR 

800); American Indian Religious Freedom Act 

of 1978, as amended (42 U.S.C. 1996 et seq.); 

Native American Graves Protection and 

Repatriation of 1990, as amended (25 U.S.C. 

3001-3013); and implementing regulations 

U.S. Army Corps of 

Engineers 

Nationwide Permit 12 - Utilities Section 404, Clean Water Act of 1972 

(40 CFR 122-123, 230) 

U.S. Fish and Wildlife 

Service 

Coordination, consultation, and 

impact review on federally listed 

threatened and endangered species 

and other federally protected 

species 

Fish and Wildlife Coordination Act (16 U.S.C. 

Sec. 661 et seq.); Section 7 of the Endangered 

Species Act of 1973, as amended (16 U.S.C. 

et seq.); Bald Eagle Protection Act, as 

amended (16 U.S.C. 668-668dd); Migratory 

Bird Treaty Act (16 U.S.C. 704) 

U.S. Environmental 

Protection Agency 

Spill Prevention Control and 

Countermeasure Plans 

40 CFR 112 
EA, White Mountain Wind Energy Project 1-9 

Table 1.2 (Continued) 

Agency Permit, Approval, or Action Authority 

Wyoming Department Issue industrial siting permit Wyoming Industrial Siting Act (Wyoming 

of Environmental Statute [W.S.] 35-12-101 through 119) 

Quality/Industrial 

Siting Council 

Wyoming Department National Pollutant Discharge Clean Water Act, amended (33 U.S.C. 

of Environmental Elimination System permits for Sections 1251-1376) WDEQ Rules and 

Quality/Water Quality discharging waste water and storm Regulations, Chapter 18. Wyoming 

Division (WDEQ/ water runoff Environmental Quality Act (W.S. 35-11-301 

WQD) through 35-11-311); Section 405 of the Clean 

Water Act (40 CFR 122-124) 

WDEQ/Air Quality Permit to operate a mobile concrete Clean Air Act, as amended (42 U.S.C. 7401 

Division batch plant seq. Wyoming Environmental Quality Act, 

Article 2, Air Quality, as amended 

(W.S. 35-11-201 through 35-11-212) 

Wyoming Department Permits for oversize, overlength, Chapters 17 and 20 of the Wyoming Highway 

of Transportation and overweight loads Department Rules and Regulations 

Wyoming State Permits to appropriate groundwater W.S. 41-121 through 147 (Form U.W.5) 

Engineer’s Office (use, storage, wells, dewatering) 

Wyoming State Cultural resource protection, Section 106 of NHPA and Advisory Council 

Historic Preservation programmatic agreements, Regulations (36 CFR 800) 

Office consultation 

Sweetwater County 2 County road crossing/access Engineer’s Department 

permits 

Small wastewater permits; mineral Planning and Zoning Department 

development permits 

Hazardous material recordation and Emergency Management Coordinator 

storage 

Conditional Use Permit Planning Department

 Construction Permit Planning Department 

Noxious weed control Weed and Pest Department 

Sweetwater County Road Engineering and Community Development 

Maintenance Agreement 

Engineered Drainage Plan Engineering and Community Development 

Engineered Transportation Plan Engineering and Community Development 

Engineered Site Plan Engineering and Community Development

 Engineered As-built Drawings Engineering and Community Development 

 Fire Code Approval Engineering and Community Development 

1 This list is intended to provide an overview of the key regulatory requirements that would govern project 

implementation. Additional approvals, permits, and authorizing actions may be necessary. 2 All engineered plans or as-built drawings would be certified by a Wyoming Licensed Professional Engineer. 
1-10 EA, White Mountain Wind Energy Project 

and groups that submitted comments are provided 

in Section 5.0, Consultation and Coordination. 

The BLM released in scoping notice for the 

WMWE project on November 20, 2008 

(Appendix A). The BLM held an Open House on 

December 11, 2008, in Rock Springs, Wyoming, 

to solicit input and information on the proposed 

project and issues to be analyzed in the EA. 

Although some of the issues identified below may 

not meet the requirements under Section 6.4.1, 

Identifying Issues for Analysis of the BLM NEPA 

Handbook (2008), BLM felt it is warranted to 

document and consider all issues identified 

because this is the first wind energy development 

proposed for the RSFO area. Therefore, the issues 

presented in Table 1.3 will be considered in this 

analysis. 
EA, White Mountain Wind Energy Project 1-11 

Table 1.3 Issues. 

Issue Environmental Effect 

Air Quality/Health 

Paleontology/Geologic Resources 

Soils/Vegetation/Reclamation 

Wildlife Resources 

Fugitive dust from construction, O&M, decommissioning 

Criteria pollutant and HAP emissions from combustion sources and 

construction activities 

Health effects to those sensitive to dust 

Benefit of nonpolluting energy production 

Vertebrate fossils

 Geologic features 

Erosion 

Drainage (i.e., disruption of surface water flows and effect on 

plants/animals) 

 Vegetation loss 

 Invasive species 

Timing and ensuring success of reclamation 

Minimize disturbance during construction and operation 

Crucial winter range for pronghorn antelope 

Crucial winter range, parturition, and yearlong range for elk 

Yearlong habitat for mule deer 

Key/core habitat for greater sage-grouse 

 Pygmy rabbit habitat 

State- and BLM-sensitive species and candidate species and associated 

habitats 

Raptor nesting and hunting habitat 

Mortality to raptors, migrating passerine birds, and bats 

Low-level flights for census counts 

Increased competition for available forage 

Monitoring program for migratory birds, raptors, greater sage-grouse, 

prairie dogs, and bats 

Sighting turbines away from cliff faces and draws 

Habitat fragmentation for affected species 

Consideration of U.S. Fish and Wildlife Service’s (USFWS’s) Voluntary 

Interim Guidelines to Avoid and Minimize Wildlife Impacts from Wind 

Turbines (USFWS 2003) 

Local bird migration pathways 

Bird perching (tubular supports, power lines) 

Seasonal concentration of birds 

Post-construction monitoring for mortality 

Storm water practices to prevent attracting birds 

 Turbine lighting 
1-12 EA, White Mountain Wind Energy Project 

Table 1.3 (Continued) 

Issue Environmental Effect 

Wildlife Resources (continued) 

Wild Horses 

Cultural/Native American Resources 

Socioeconomics 

Viewshed and Recreation 

Habitat mitigation (off-site) 

Potential effects of noise on species 

Potential effects of winter road maintenance (i.e., berms) on big game 

Potential conflicts of construction/operations with hunting activity 

Gathering wild horses to comply with appropriate management 

levels/court order requirements 

Low-level flights for census counts/gathering 

Increased competition for available forage 

Historic roads and trails (i.e., Cherokee Trail North, Rock Springs to 

Lander Stage Road, Old Bryan Road, Overland Trail, New Fork Wagon 

Road, Green River to South Pass City Road, Bryan to South Pass City 

Road, Lincoln Highway)

 Native American concerns 

Natural Historic Trails 

Eligible or listed historic/prehistoric sites 

History of Pilot Butte 

Traditional and rural landscape 

Employment (job creation or displacement) 

 Taxation 

State and national energy needs 

Effects on the communities at large--little or no benefit but subject to 

impacts of the proposal

 Property values 

Traffic and transportation requirements 

 Vandalism 

Existing abuse of the local area environment vs. a well-managed project 

Recognizing landowners’ desire to develop their lands 

Balancing socioeconomics with environmental concerns 

Viewing wild horses 

Turbines on the community views (turbine simulation) 

Consistency in turbine layout and size 

 Turbine lighting 

BLM Class III and IV visual resource 

Sweetwater County scenic overlay 

Recreation (i.e., scenic wild horse loop tour, hunting, hiking, sight-seeing, 

etc.) 

Recreational activities in proximity of the project area (i.e., face of White 

Mountain) 

 Pilot Butte 
EA, White Mountain Wind Energy Project 1-13 

Table 1.3 (Continued) 

Issue Environmental Effect 

Grazing/Rangeland 

Transportation 

Decommissioning 

Project Development/Design 

Features 

Project Development/Public Safety 

Other 

Loss of vegetation 

Vegetation quality due to dust 

Loss of Animal Unit Months (AUMs) and grazing 

Increased competition for available forage 

 Transportation planning 

Surface disturbance required to transport/construct turbines and 

associated facilities 

Winter and year round maintenance of County Road 4-53 

Meeting international fire code standards 

Public access to area due to winter maintenance 

Increased on- and off-road traffic (number of vehicles) 

 New access 

Reclamation 

Retrofitting with newer turbine technology 

Phasing of development 

Reliability of wind energy vs. other forms of energy production 

Benefit of renewable/green energy 

Design features to protect wildlife 

Location of the development 

Assure conveyance of terms, conditions, and stipulation to subsequent 

owner 

Potential conflicts with existing ROWs 

 Project maintenance 

Proper disposal of waste/debris 

Buried collection lines 

Adoption of best management practices as defined in the Wind Energy 

PEIS 

Debris (i.e., ice) throw 

Blade or tower failure 

Meeting international fire code standards 

Noise 

 Shadow flicker 

Setbacks 

 Night lighting 

Acquire all required permits 

Buffers for ephemeral channels 
EA, White Mountain Wind Energy Project 2-1 

2.0 THE PROPOSED ACTION AND ALTERNATIVES 

2.1 DESCRIPTION OF PROPOSED ACTION 

2.1.1 Introduction 

The WMWE Project is a proposed 360-MW 

electrical generating facility consisting of up 

to 240 wind turbines (assuming use of 1.5-MW 

generators). The annual energy output 

from this facility would be approximately 

1,000,000 megawatt hours (MWh) annually. It 

should be emphasized that 240 wind turbines is the 

maximum number of wind turbines that could be 

installed in the project area, and it is likely that 

fewer would actually be constructed due to various 

technical (e.g., unfavorable geotechnical testing 

matters or broadcast signal interference) or 

environmental constraints (e.g., active raptor 

nests) that cannot be fully identified at this time. 

However, for the purpose of this analysis, it is 

assumed that all 240 wind turbines would be 

constructed. It is also possible that a slightly 

larger wind turbine by Teton (e.g., 2.0-3.0 MW) 

could be selected. The final turbine selection 

process would depend on numerous factors, such 

as availability and economics. However, a larger 

wind turbine would require a different layout, and 

fewer wind turbines would be installed because of 

the increased spacing requirements between 

individual wind turbines and turbine strings. Even 

though there would be fewer turbines with the 

larger capacity turbines, the overall dimensions of 

the wind turbine would be in the overall range of 

the wind turbine illustrated in Figure 2.1. As a 

result, the environmental analysis for the larger 

capacity turbine would be identical to the 

environmental analysis for the proposed 1.5-MW 

wind turbine except with larger capacity turbines 

there would be less disturbance. 

While wind energy has traditionally been 

considered an unreliable power resource, 

advancement over the past 10 years have allowed 

power companies to now treat wind energy as a 

schedulable resource to assist in meeting power 

requirements. According to Teton, advancements 

in meteorology monitoring and modeling and 

computer tracking have allowed many wind 

resources to be scheduled on a monthly, weekly, 

and daily basis. Wind energy is also considered a 

clean renewable form of energy that uses a free 

type of fuel, produces no greenhouse gases or 

other pollutants from the generators, has limited 

environmental impacts compared to other forms of 

power production, obtains fewer tax subsidies 

compared with other forms of energy production, 

promotes stable and cost-efficient energy 

production, diversifies local economies, and 

provides jobs to the local economy (DOE 2008). 

The project site is located on top of White 

Mountain, which is west-northwest of the city of 

Rock Springs, Sweetwater County, Wyoming, in 

portions of T19N-T20N, R105W-106W. The 

anticipated layout of the project is shown in Figure 

2.2. The ROW application has been assigned an 

identification number of WYW167597 by the 

BLM. Sweetwater County has already issued a 

conditional use permit for 36 turbines on private 

land but not a construction permit although Teton 

is seeking to modify some locations. Any 

modification of locations would require a new 

conditional use permit. Table 2.1 provides the 

acres and percentage of landownership within the 

project area, and Table 2.2 presents the acres of 

potential disturbance for the entire project. Teton 

would obtain additional conditional use and 

construction permit(s) for the remaining turbines 

located on private lands from Sweetwater County 

prior to each phase of development of the 

Proposed Action. Table 2.3 presents the acres of 

potential disturbance on BLM-administered land 

under the Proposed Action. 

The project would consist of up to 240 wind 

turbines. “Wind turbine” is the collective term for 

the equipment that captures the kinetic energy in 

the wind and converts it to electrical energy. The 

major components include the blades and hub 

(collectively called the rotor), the nacelle, and the 

tower. Inside the nacelle are the gearbox, 

generator, and various other components critical 

for operation of the wind turbine. Depending on 

the specific turbine manufacturer, the transformer 

would be located either in the nacelle or on the 

ground next to the tower. Figures 2.1 and 2.3 are 

general schematics of typical wind turbines. 
2-2 EA, White Mountain Wind Energy Project 

Tower 

Foundation 

200-300 ft 

Blade 

Nacelle 

Hub 

250-300 ft 

Transformer (Possible) 

Figure 2.1 Typical Wind Turbine Components. 

2-4 

1 

EA, White Mountain Wind Energy Project 

Table 2.1 Landownership Within the WMWE Project Area. 

Landowner Acres Percentage 

Bureau of Land Management 4,3981 33.4 

State of Wyoming 240 1.8 

Private landowner 8,527 64.8 

Total 13,165 100.0 

BLM development ROW is 2,640 acres. 

Table 2.2 Estimated Acres of Surface Disturbance Within the WMWE Project Area (Proposed 

Action). 

 Proposed Action 

Disturbance Type	 Initial Disturbance (acres) Life-of-project Disturbance (acres) 

Corridor access roads1

 317.5 152.8 

Staging area and O&M building 2.0 0.8 

Substation and transmission line 11.0 0.3 

Turbine pads2

 176.3 35.3 

Collector line trenches3

 356.8 0.0 

Concrete batch plant 2.0 0.0 

Total 865.6 189.2 

1 Initial disturbance: 48.5 mi x 54 ft = 317.5 acres; life-of-project disturbance: 48.5 mi x 26 ft = 152.8 acres. 2 Initial disturbance: 160 ft x 200 ft x 240 turbines = 176.3 acres; life-of-project disturbance: 80 ft x 80 ft x 

240 turbines = 35.3 acres. 3 Initial disturbance: 64.0 mi x 46 ft = 356.8 acres; life-of-project disturbance: 0.0 acres, all temporary 

construction-related disturbances would be reclaimed immediately. 
EA, White Mountain Wind Energy Project 2-5 

Table 2.3 Estimated Acres of Surface Disturbance on BLM-administered Land Within the WMWE 

Project Area. 

Disturbance on BLM-administered Lands 

 Initial Disturbance (acres) Life-of-project Disturbance (acres) 

Corridor access roads1

 78.5 37.8 

Staging area and O&M building 0.0 0.0 

Substation and transmission line 0.0 0.0 

Turbine pads2

 51.4 10.3 

Collector line trenches3

 106.5 0.0 

Concrete batch plant 0.0 0.0 

Total 236.4 48.1 

1 Initial disturbance: 12.0 mi x 54 ft = 78.5 acres; life-of-project disturbance: 12.0 mi x 26 ft = 37.8 acres. 2 Initial disturbance: 160 ft x 200 ft x 70 turbines = 51.4 acres; life-of-project disturbance: 80 ft x 80 ft x 

70 turbines = 10.3 acres. 3 Initial disturbance: 19.1 mi x 46 ft = 106.5 acres; life-of-project disturbance: 0.0 acres, all temporary 

construction-related disturbances would be reclaimed immediately. 

During the design phase of this project, Teton 

undertook numerous studies and evaluations to 

assist in the siting of the project components to 

minimize potential impacts to the environment and 

existing man-made facilities in the general project 

area. Some of these studies and evaluations 

include a communication interference study and an 

obstruction evaluation and airport airspace 

analysis. Results of these studies and evaluations 

have been considered. In cases where turbines 

conflict with broadcast signals, with other existing 

facilities (transmission power lines), with 

unfavorable geotechnical testing results, or with 

other resource issues (active raptor nest), those 

turbines would either be moved or eliminated. 

The wind turbines that would be used in the 

WMWE Project would be placed in locations that 

would provide the best balance of energy capture, 

safe construction, and minimum impacts to the 

environment. The environmental impacts of the 

project would be closely monitored during the 

construction, O&M, and decommissioning of the 

project. The environmental impacts, mitigation 

measures, and monitoring activities are presented 

in the Plan of Development (POD) (TRC 

Environmental Corporation [TRC] 2009a). 

Wind turbines operate autonomously with 

computer control based on wind speed and 

direction data. When the anemometer on a wind 

turbine senses winds within the operational range 

of the turbine and power sensors find the electrical 

grid available to accept power, the wind turbine 

turns itself on and begins to generate power. It 

continues to generate electricity until the wind 

speed is above or below the turbine operational 

range, the grid is no longer available, or the 

turbine detects a fault with one of its components. 

If a fault occurs, the turbine shuts itself down and, 

depending on the nature of the fault, either waits 

for the condition to clear itself or signals for 

maintenance. 

Wind turbines are connected through an 

underground electrical collection system to a 

central substation, where the power is raised to the 

voltage of the electrical grid (Figure 2.4). The 

turbines and towers sit atop large concrete and 

steel foundations. Access roads interlink each 

turbine site (Figure 2.5). A permanent O&M 

building and substation, as well as a temporary 

construction trailer pad, material storage area, and 

batch plant site, would be built on land owned by 

the RSGA within the central portion of the project 
2-6 EA, White Mountain Wind Energy Project 

Figure 2.3 General Wind Turbine Nacelle Components (Adapted from DOE [2004]). 

area (Section 1, T19N, R106W) near the existing 

230-kV line. If required, other temporary work 

areas related to this project (such as the crane 

assembly area) would be located on previously 

disturbed land within the ROW grant area or on 

privately owned lands. 

2.1.2 Health, Safety, and Environmental 

Commitment and Policy 

Teton and its employees, partners, and contractors 

are concerned with health, safety, and the 

environment. They would develop and implement 

a Health, Safety, and Environment (HSE) Plan for 

each phase of this project. 

To avoid, reduce, or mitigate potential 

environmental impacts associated with 

construction of the WMWE Project, Teton has 

evaluated potential environmental consequences of 

this project and developed specific design features 

that would be implemented during each phase of 

the project. 

2.1.3 Adaptive Management Strategy 

Adaptive management is a core environmental 

management principle of this project. It has 

guided planning for the design, development, 

management, and operation of the WMWE 

Project. It is intended to improve decisions 


EA, White Mountain Wind Energy Project 2-9 

regarding the planning, design, development, 

management, and operation of large engineering 

projects in relationship to their setting. 

Adaptive management is based on the premise that 

ecosystems are complex and inherently 

unpredictable over time. It approaches the 

uncertainties of ecosystem responses by evaluating 

and optimizing management actions using a 

systematic method from which “learning over 

time” is a critical tool. For the WMWE Project, 

learning and adapting are based on a rigorous 

process of long-term monitoring and incorporation 

of best available science to determine impacts to 

the environment. 

2.1.4 Communication Plan 

For the portion of the project located on BLMadministered land, the BLM would play an active 

role during the development and construction of 

the WMWE Project. The State of Wyoming, 

Sweetwater County, and private landowners would 

play a similar role for the portion of the project 

affecting state and private lands. Teton would 

coordinate the project design using the adaptive 

management approach endorsed by the BLM and 

other affected land interests. BLM 

representatives, as well as appropriate state and 

Sweetwater County agencies and private 

landowners, would be consulted at critical 

development stages of the project, including 

transportation, construction, commissioning, 

reclamation, and decommissioning. 

Teton expects that the BLM Authorized Officer, or 

assigned staff, and/or officials from Sweetwater 

County would be present at the project site during 

construction as appropriate and would observe 

construction activities to confirm these activities 

with this plan. The Teton construction project 

manager would communicate directly with the 

BLM Authorized Officer and officials from 

Sweetwater County on-site to keep the BLM and 

county apprised of the construction progress and 

the results of environmental mitigation measures 

and monitoring efforts. This collaboration would 

continue as necessary to explore and evaluate 

alternative mitigation measures. Any deviations 

from the POD requested by Teton would be 

reviewed by the BLM Authorized Officer and 

Sweetwater County, and written approval would 

be obtained before such changes are made. 

The BLM and Sweetwater County would also 

receive monthly reports during the construction, 

operation, and decommissioning of the project that 

contain the anticipated upcoming activities and 

results of recent environmental monitoring. These 

reports are intended to maintain constant 

communication and keep the BLM and 

Sweetwater County informed on mitigation 

results. 

Teton would maintain open communications with 

the landowners, livestock operators, and state and 

local governments, including agencies of the State 

of Wyoming, Sweetwater County, and the cities of 

Rock Springs and Green River. Informational 

updates would be provided to these local 

governments regarding activities that could impact 

their jurisdictions, including schedules for 

construction and truck traffic. If necessary, 

meetings or other mechanisms for coordination 

would be used to discuss relevant issues, project 

status, scheduling, or other concerns. 

Teton would request that each government entity 

appoint a contact person to whom project updates 

would be sent. These government agencies would 

be given as much advanced notice as possible for 

major project activities, as well as any changes to 

these schedules. 

2.1.5 Project Schedule 

The WMWE Project (up to 240 turbines) would be 

constructed in four phases over a 3- to 4-year 

period. The proposed schedule for each 

construction phase is discussed in detail in Section 

2.2.3.10. Teton expects that all construction 

operations would occur during daylight hours, 

5 days a week. Once in operation, Teton expects 

that each phase of the project would have an 

approximate 20-year life of operation (24-year 

total). It is possible that Teton would evaluate 

repowering the project as the life of the project 

comes to an end as opposed to decommissioning 

the project. However, repowering is not 

considered part of the current project and would be 
2-10 EA, White Mountain Wind Energy Project 

discussed with the BLM, landowners, and state 

and local agencies in the future. Teton expects 

decommissioning to also be completed in phases 

and over a 3- to 4-year period. Revegetation 

operations would be completed as soon as 

practical following equipment removal. 

2.2 CONSTRUCTION OF FACILITIES 

The actions necessary to construct the WMWE 

Project are summarized below and include 

development of a HSE Plan, civil construction 

activities, project construction activities, general 

construction activities, structural construction 

activities, wind turbine tower erection, reclamation 

plan, potential environmental impacts, and 

mitigation and monitoring activities. Where 

helpful, photographs of similar activities from the 

construction of other wind energy projects have 

been added for illustration purposes. A list of 

typical construction equipment used to build a 

wind energy facility is presented in Table 2.4. 

Teton would provide licensed certifications for all 

appropriate project elements in accordance with 

federal, state, and county regulations. 

2.2.1 Health, Safety, and Environmental Plan 

The WMWE Project HSE Plan as outlined in the 

POD addresses HSE risks and requirements during 

the construction stage of the project. As the 

project moves into the operational stage, the 

components of the HSE Plan would be modified to 

adapt to O&M activities. Teton could coordinate 

the HSE Plan and modifications with all 

appropriate federal, state, and county agencies. 

Components of the management system that 

would be addressed in the HSE Plan include, but 

are not limited to, risk management analysis, 

emergency response, HSE planning and 

procedures, implementation, monitoring and 

reporting results, setting performance targets, 

incident classification, investigation and reporting 

results, audits and inspections, as built 

certification, and HSE management review. 

Minimum contractor HSE requirements would be 

included in the HSE Plan. These requirements 

include personal protective equipment, 

housekeeping, maintaining a safe workplace, fire 

prevention, safe work practices, etc. Contractors 

are expected to comply with these requirements at 

a minimum, and contractor safety plans would be 

reviewed for compliance. 

Development of the HSE Plan is a collaborative 

effort between Teton and the contractors. 

Contractor BMPs would be reviewed and 

incorporated into the HSE Plan as appropriate. 

Also included in the HSE Plan is a risk register, 

which identifies potential hazards and the risks 

associated with them. Contractors are expected to 

address these risks and develop mitigation plans 

for incorporation into the register. The risk 

register is a document that would be used and 

updated on a continuous basis to identify and 

mitigate risks as they surface. It is conceivable 

that mitigation plans as developed may not prove 

to be sufficient as anticipated. In this case, the 

HSE Plan would be adjusted to provide a suitable 

solution to project risks. 

Observation of HSE performance is key to 

avoiding incidents. Project personnel would be 

expected to regularly observe work practices and 

to provide positive reinforcement and guidance to 

fellow employees. Work practices that may be 

considered to place employees or the environment 

at risk would be identified, evaluated, and 

modified as necessary to eliminate or substantially 

reduce the risk. 

2.2.2 Civil Construction Activities 

2.2.2.1 Surveying and Staking 

Construction surveying and staking are the first 

construction activities associated with the project. 

Field crews would use survey equipment and 

known reference points to locate points in the field 

that correspond to critical project design locations. 

When a critical point is found, it is marked with a 

survey stake (a wooden stake with a colored 

plastic flag that is driven into the ground 1 to 2 ft). 

The project site is accessed by a pickup truck or 

similar vehicle. Teams of two or more surveyors 

would walk across the site to perform surveying 

and staking. 
 

EA, White Mountain Wind Energy Project 2-11 

Table 2.4 List of Typical Equipment Used for Construction of Wind Energy Facilities. 

Equipment Use 

Tracked-bulldozer Road and pad construction 

Grader Road and pad construction 

Water trucks Compaction, erosion, and dust control 

Roller/compactor Road and pad construction 

Backhoe Digging foundations and trenches for utilities 

Trenching machine Digging trenches for underground utilities 

Truck- or track-mounted drill rig Drilling geotechnical sample holes 

Concrete trucks and pumps Pouring tower and other structure foundations 

Cranes Tower and turbine erection 

Dump trucks Hauling road and pad material 

Flatbed trucks Hauling towers and other equipment 

Pickup trucks General use and hauling small equipment 

Small hydraulic cranes and forklifts Loading and unloading equipment 

Fuel truck Fueling of mobile equipment 

Rough terrain forklifts Lifting equipment 

2.2.2.2 Geotechnical Sampling 

The primary objective of the geotechnical 

sampling is to investigate the strength 

characteristics of the bedrock and to determine 

dynamic properties for the turbine foundation 

design. The investigation would consist of coring 

specific locations along the turbine alignment. 

Coring would be completed using moderate-sized 

geotechnical drilling equipment mounted to either 

a truck or tracked vehicle (Figures 2.6 and 2.7). 

The coring process would obtain samples of rock 

that would be logged. Core samples would be sent 

to a geotechnical laboratory for strength testing. 

Since the coring process leaves holes at the test 

site approximately 3 inches in diameter and up to 

40 ft deep, each hole would be backfilled in 

accordance with applicable requirements. Test 

pits dug with a backhoe or similar equipment may 

also be utilized to evaluate whether the bedrock 

can be excavated. 

Additional geotechnical investigations include 

several seismic refraction survey lines. The 

seismic refraction lines would be used to 

determine dynamic soil properties of the 

underlying bedrock and would also be used to 

confirm bedrock strength. The seismic refraction 

lines would be completed using an extremely lowenergy source (a sledgehammer and plate). The 

seismic analysis would also include multichannel 

surface-wave analysis, which utilizes background 

vibrations such as vehicles to generate seismic 

noise. 

2.2.2.3 Rock Removal 

Bedrock at the site is generally composed of 

sandstone material, which does not require 

blasting to remove. Excavation would be 

completed using conventional earth-moving 

equipment and sound engineering practices. 

Methods and techniques would be utilized to 
2-12 EA, White Mountain Wind Energy Project 

Figure 2.6 Typical Coring Truck and Support Vehicle. 

Figure 2.7 Typical Coring Tracked Vehicle. 
EA, White Mountain Wind Energy Project 2-13 

minimize overbreak beyond the limits indicated on 

the drawings and to preserve the rock beyond 

these limits in the soundest possible condition. 

2.2.2.4 Topsoil Salvage Operations 

Prior to the construction of any project-related 

equipment, structures, or facilities, all available 

vegetation and all available topsoil would be 

salvaged, based on an on-site evaluation, used for 

reclamation in other areas (live haul), if possible, 

and if not, then stockpiled for future reclamation 

operations. If less than 6 inches of topsoil are 

available, topsoil along with an appropriate 

quantity of other suitable subsoil (with BLM or 

landowner/county approval) would be salvaged so 

that a minimum of 6 inches of plant growth 

material would be available for use during 

revegetation operations. Topsoil and suitable 

subsoil would be stockpiled separately, and 

appropriate signs would be installed on each 

topsoil or subsoil pile. Care would be taken to 

avoid mixing topsoil and subsoil. Where possible, 

topsoil would be live-hauled to minimize topsoil 

stockpiling and encourage improved vegetation. 

Topsoil salvage operations would apply to all 

construction activities except for the construction 

of any required overhead transmission power 

lines. Topsoil salvage operations are not required 

for the construction of overhead power lines 

because these activities would result in minimal 

disturbance from wheeled vehicles driving over 

the vegetation and soil. In addition, natural 

revegetation would occur more rapidly if the 

vegetation and soil is left in place. 

2.2.2.5 Site Grading 

There are three phases associated with the grading 

activities for the project. The first phase 

(road grading) is the construction of the roadways 

associated with the project. The roads would be 

constructed based on the lines and grades 

indicated on the detailed design drawings. At the 

same time the roads are being constructed, or very 

shortly after they are completed, the second phase 

(rough grading) associated with the turbine sites, 

substation, and O&M building would begin. Once 

the turbine sites, substation, and O&M building 

are completed, the third phase (final grading) 

activities would be completed with these facilities. 

All surface areas disturbed by construction 

activities would be graded. The grading would be 

finished to the contours and elevations indicated 

on the drawings or match contours and elevations 

of the original undisturbed ground surface. The 

final grading would provide a smooth uniform 

surface and minimize the impact to existing water 

runoff patterns. 

The overall goal of the detail design associated 

with grading activities is to achieve a cut and fill 

balance. Such a balance ensures that a minimum 

of material is required to be transported on or off 

the site. Any required material or excess material 

would be obtained or disposed of at a properly 

permitted facility. 

2.2.2.6 Road Base Construction 

The road base (aggregate) would be placed on 

graded turbine access roads and turbine areas in 6­

to 12-inch (maximum) deep compacted layers. 

The depth of a compacted layer would be based on 

the compaction standard required in the 

engineering drawings. Geotextile may be required 

for separation between the road subgrade and the 

aggregate, except where otherwise specifically 

noted. 

Aggregate materials would be made from crushing 

the excavated rock from the foundation holes to 

the extent possible. Any additional aggregate 

materials would be from private sources located 

off-site. Since the access roads would need to be 

built before any foundations are excavated, initial 

quantities of aggregate would need to be imported 

from an off-site commercial source. 

2.2.2.7 Excavation 

Excavation involves the removal of earth and rock 

to allow for the construction of roads and 

foundations. Excavation for structures would be 

completed to the designated lines and elevations 

indicated on the detail design drawings. Machine 

excavation would be controlled to prevent 
2-14 EA, White Mountain Wind Energy Project 

undercutting the subgrade elevations indicated on 

the drawings. 

Excavated materials that meet the specified 

requirements may be used for the fills, 

embankments, and backfills. Vertical faces of 

excavations would not be undercut to provide for 

extended footings. 

Excavated materials would be either crushed for 

road aggregate or placed back into the center of 

the foundation hole, although most rock material 

would be used as road aggregate. The road 

material would be crushed at the location where it 

was excavated. Crushing operations would be 

conducted using small portable rock crushing 

equipment with manufacturer provided or 

approved dust control equipment. Remaining 

excess excavated materials, if any, would be used 

on-site for road maintenance and would not be 

hauled off-site unless absolutely required and 

approved by the BLM Authorized Officer. 

2.2.2.8 Compaction 

During construction of roads and foundation 

structures, it is critical that the earth under them is 

solid. To achieve this, the earth is compacted. 

Compaction associated with the WMWE Project 

would meet the following standards. 

•	 For roads, the requirements outlined in the 

BLM Road Standards (Manual 

Section 9113) would be adhered to. The 

manual indicates that the top 12 inches of 

subgrades of all roads that are to be 

surfaced would be compacted to 95% of 

the maximum density as determined by 

AASHTO T-99. 

•	 Rock fill would be compacted in 8-inch 

uncompacted thickness to 70% relative 

density as determined by American 

Society for Testing and Materials (ASTM) 

D4253 and D4254. Compaction would be 

performed with vibrating mechanical 

compactors. 

2.2.2.9 Erosion Control 

A Storm Water Pollution Prevention Plan 

(SWPPP), which includes erosion control 

measures, would be prepared and implemented for 

the project area. The SWPPP would be based on 

the 1992 Environmental Protection Agency (EPA) 

document entitled Storm Water Management for 

Construction Activities-Developing Pollution 

Prevention Plans and Best Management Practices 

(EPA 1992). The SWPPP would be developed 

with the civil design of the project. Teton would 

continue to implement the SWPPP and county 

drainage and road maintenance agreement and 

would monitor the project area for erosion or soil 

instability and take appropriate action should 

problems become evident. 

Teton would not conduct any construction, O&M, 

or decommissioning activities when soils in the 

work area are too wet to adequately support 

construction equipment. If construction 

equipment creates ruts greater than 4 inches deep, 

support would be deemed inadequate and activities 

would be discontinued until soil conditions 

improve or appropriate remediation action is taken 

to ensure operations could continue without deep 

rutting. 

2.2.3 Project Construction Plan 

This section contains a general description of the 

construction steps for each phase of the major 

components of the project as outlined in the 

associated POD. This plan discusses the general 

activities and design approaches as currently 

understood and anticipated. Teton would remain 

in contact with the BLM as the project designs are 

finalized and specifics on construction are 

available. 

In general, the design approach for the WMWE 

Project would have two primary objectives. The 

first is the concept of minimizing the overall 

environmental impact of the project while 

maintaining cost effectiveness and safety 

standards. This would include minimizing the 

amount of cut and fill required for the roads and 

foundations and using as much excavated soil and 

rock as possible on project roads. 

The second design objective is the concept of 

“adaptive management,” in which the project 

design would be done to complement the natural 
EA, White Mountain Wind Energy Project 2-15 

characteristics of the site. Adaptive management 

would also be employed during construction by 

allowing for some specifics to be modified, 

adapting to actual site conditions (subsequent to 

BLM approval). 

In accordance with the approved engineering 

grading and drainage plans, prior to the start of 

construction, Teton would review and document 

the general condition of the site, including soil 

characteristics, the type and levels of vegetation, 

and areas of disturbance. When construction is 

completed, Teton would complete revegetation 

and reclamation operations to return the areas not 

needed during operations to near preconstruction 

condition as detailed in Section 2.4.8. This 

includes returning land contour and drainage, 

replacement and preparation of topsoil, seeding, 

and weed control as necessary in order to restore 

the area to conditions similar to those that existed 

prior to construction. 

Teton understands that portions of the land in the 

WMWE Project area are public lands managed by 

the federal and state government, and as such, the 

public has a right to expect access to the area. 

Public access would only be temporarily limited 

during construction of the WMWE Project to 

those specific areas where construction activities 

could cause public safety concerns. These 

activities include, but may not be limited to, wind 

turbine erection, foundation excavation, electrical 

collection system trenching, and substation 

construction. Once these specific activities are 

completed, full public access would resume to its 

current state. 

2.2.3.1 Roads and Turbine Pads 

In order for equipment and personnel to reach the 

wind turbine locations, existing roads would be 

used whenever possible; although, some existing 

two-track roads would need to be upgraded and 

new roads would need to be constructed. The 

existing County Road 53 and Fourteenmile Road 

from Highway 191 to the top of the WMWE 

Project area are sufficient to allow for truck traffic 

during the project construction. Additionally, 

access roads running adjacent to each turbine site 

and the project substation, O&M and wareyard, 

batch plant would be required. All access roads 

would be designed, engineered, and constructed in 

accordance with BLM and county standards and 

would be located to minimize disturbance, to 

avoid sensitive resources (e.g., raptor nests, 

cultural resource sites, etc.), and to maximize 

transportation efficiency during construction and 

O&M activities. An example of a constructed 

access road at the Bridger Butte Wind Energy 

Project in southwest Wyoming is shown in 

Figure 2.8. During the life of the project, Teton 

would be responsible for maintenance on all 

project roads, including specific portions of 

County Road 53 and Fourteenmile Road located 

within the project area and those portions of 

Fourteenmile Road that are used to access the 

project area. These activities would be conducted 

in accordance with a Road and Maintenance 

Agreement between Teton and Sweetwater 

County. 

Many of the trucks used to haul wind turbine 

components to the site would be extra-long 

(for blade transport) and heavy-load (for wind 

turbine nacelles). Figure 2.2 notes the access 

roadways, but the exact locations may vary 

slightly. However, the access roadways would be 

generally along each of the turbine strings. 

The tentative location of each wind turbine site is 

illustrated on Figure 2.2. Construction zones 

would be built around each wind turbine site. 

Typical construction areas for each turbine would 

be approximately 160 x 200 ft (0.73 acre) in size 

with a life-of-project disturbance area of 80 x 80 ft 

(Figure 2.9). The area around each site would 

need to be clear of obstacles and level enough to 

allow for the wind turbine components to be 

delivered and for a crane to be set-up. Designers 

would work to minimize the amount of work area 

required at each site, and, where possible, only a 

minimal amount of vegetation would be removed 

to allow for component delivery. It is likely that, 

at most sites, the location for the crane would 

require the same amount of earthwork as the roads 

(described below), although these pads can then be 

removed and the site restored to a natural state 

once construction is complete. 
2-16 EA, White Mountain Wind Energy Project 

Figure 2.8 Constructed Turbine Access Road. 

To the greatest extent possible, the area of 

construction and operation of the project 

(often referred to as the project footprint) would be 

consolidated for efficient land use in order to 

minimize disturbance to the existing ecosystem. 

When practical, existing roads would be improved 

rather than constructing new ones. It is not 

anticipated that County Road 53 would require 

any widening to allow equipment access. 

However, if necessary, Teton would work with 

Sweetwater County Road and Bridge Department 

and the Wyoming Department of Transportation to 

obtain the necessary approvals to improve this 

road and/or the turnoff from U.S. Highway 191. 

The cut and fill required for the access road would 

be balanced to minimize the amount of materials 

that would need to be brought onto or removed 

from the site. 

The design of access and turbine string roads 

would utilize the flow of the natural contours; 

however, in order to maintain safety during 

construction and maintenance activities, the 

following design criteria would also be 

implemented: 

•	 Sweetwater County or BLM design 

standards such as Manual 9113 (BLM 

1985) or the design standards suitable for 

wind energy development approved by the 

BLM (indicated below); 

•	 maximum access road slope of 10%; 

•	 maximum road slope between turbines 

(turbine string road) between 7 and 10%; 

•	 access roads would generally have a 

maximum width of 26 ft; 

•	 turbine string roads would have a 

maximum width of 54 ft (required for 

crane movement on-site) or 26 ft with an 

extra track about 28 ft off the road for 

crane movement (refer to Figure 2.9); 

•	 minimum turn radius (inside radius of 

road way) of 115 ft (based on transporting 

three turbine blades at a time) wherever 

possible or 76 ft (based on transporting 

one turbine blade at a time) where 

necessary; 
EA, White Mountain Wind Energy Project 2-17 

Figure 2.9 Typical Road and Turbine Construction Layout. 
2-18 EA, White Mountain Wind Energy Project 

•	 road surfaces would be that of an all 

weather gravel road; 

•	 design speed of 15 miles per hour (mph) 

maximum on the turbine string road and 

25 mph on the site access road; and 

•	 where necessary, culverts and road 

crossings of stream or wash crossings 

would be designed, installed, maintained, 

and monitored so as to accommodate and 

safely pass the 10-year storm event; and 

•	 culverts installed where roadways exceed 

5% slope would receive additional 

monitoring to ensure that they continue to 

function properly. 

The access and turbine string roads would 

generally be constructed in the following 

sequence: 

•	 stake centerline of access and turbine 

string roads; 

•	 install temporary stabilization features 

such as silt fences, straw bales, and other 

controls at the limits of construction; 

•	 clear and grub area associated with the 

access and turbine string road; 

•	 separate and stockpile topsoil for later use; 

•	 grade roads to slopes/design indicated on 

construction drawings; 

•	 compact subgrade; 

•	 install aggregate all weather road surface; 

•	 install final stabilization/revegetation on 

disturbed areas associated with the 

roadway corridor; and 

•	 remove temporary stabilization measures 

once final stabilization measures are 

established. 

Once construction of the roads and turbine pads is 

complete, reclamation would be performed around 

the areas disturbed by the civil construction 

operations. Cut materials used during the road 

construction would be used to return contours to 

near preconstruction conditions. Any remaining 

cut materials would be distributed in previously 

disturbed areas in a manner that would not 

increase dust and erosion or change drainage 

conditions. Any exposed areas that are not 

covered by road materials would be revegetated 

using a seed mixture specified by the BLM or the 

landowner. Control of invasive nonnative species 

would continue on-site during the revegetation 

process and during the life of the project. Sterile 

nonnative plant species could be used in certain 

areas. 

2.2.3.2 Electrical Collection System 

Each wind turbine in the WMWE Project would 

be connected to an underground electrical cable to 

allow the generated energy to be sent to the project 

substation. These cables could be direct-buried 

(rather than placed in conduit) using cable 

specifically designed for this application. The 

voltage of this system would be 34.5 kV, but could 

potentially be from 12 kV to 46 kV. 

If possible, the cables would be buried directly 

into the soil and materials found on-site. 

However, if those native materials are found to 

provide insufficient thermal conductivity 

(i.e., allow heat to dissipate from the cables), 

Teton may need to bring in engineered backfill, 

which would be a soil of a type sufficient to 

radiate the heat from the cables. The engineered 

backfill would only be used in the trenches with 

the cables and only to an amount sufficient to 

radiate the heat from the cables. The remaining 

depths of the cable trenches would be filled with 

native material. 

In almost all areas, the cable would be run directly 

between the turbines. The cable would not be run 

in the center of the road to avoid unnecessary 

stress due to vehicle traffic, as well as the potential 

for cable damage during road maintenance. For 

areas near the substation where several runs of 

cable would all be in the same area, Teton may use 

both sides of the road for the cable trenches, where 

practical. Cables would be installed in a manner 

similar to that described below and then 

recontoured to a state similar to preconstruction 

and revegetated with BLM-approved seed. 

2.2.3.3 Wind Turbine Foundations 

The wind turbine base foundation anchors the 

wind turbine structure (consisting of the tower, 

hub, blades, and nacelle) securely to the ground. 

For most projects, the construction of the wind 

turbine foundation constitutes the largest volume 
EA, White Mountain Wind Energy Project 2-19 

impact of earth excavation, although some 

foundation designs allow for much of the 

excavated material to be backfilled in and around 

the foundation itself. 

Two foundation designs are typically used for 

wind turbine installations in the U.S. The specific 

one for the project would be determined by the 

soil and geotechnical conditions and wind turbine 

requirements. The first foundation type is a “mat” 

foundation and is shown in Figure 2.10. The 

second foundation type is a “pier” foundation and 

is shown in Figure 2.11. Mat foundations are wide 

and shallow, and pier foundations are narrow and 

deep. There can be variations of these 

foundations. The exact foundation type depends 

on completion and results of the geotechnical 

investigation. Under known conditions, most 

foundations would be pier design. 

At the top of both foundation types is the turbine 

base. The base consists of a metal ring and series 

of anchor bolt connections to mate the foundation 

to the bottom of the wind turbine tower. The 

turbine base is cast into the concrete reinforced 

structure that makes up the remainder of the 

foundation. The casting and the subsequent 

backfilling of the foundation are typically done 

prior to the delivery of the wind turbine tower to 

allow the lowest sections of the wind turbine tower 

to be placed upon delivery. 

The BLM has indicated that all excavated 

materials from their lands should be used within 

the boundaries of their land. If Teton determines 

that some native materials would need to be 

removed from BLM-administered land, Teton 

would obtain approval from the BLM before 

undertaking any such activities. 

Teton would perform an extensive geotechnical 

investigation prior to construction to determine the 

soil conditions at each site. While very unlikely, it 

is possible that when the foundation site is 

excavated, the soil conditions could be very 

different from expected and not conducive to wind 

turbine installation. In that case, the excavated 

soils would be placed back into the hole and 

compacted to a level as close to pre-excavation as 

possible. The surface of the site would be 

recontoured, retopsoiled, and revegetated using 

BLM-approved seed. 

2.2.3.4 Wind Turbine Installation 

The wind turbines themselves are the primary 

generation equipment in the project. Their 

installation requires specialized equipment and 

crews and careful planning. Once construction has 

fully begun, components would be delivered 

directly to their installation locations as they arrive 

at the project. Lower tower sections would be 

placed immediately on foundations, while the 

remaining components would be placed around the 

site in planned staging arrangements. Crane crews 

would erect the turbines soon after all components 

arrive to minimize the amount of time the 

equipment is on the ground. The only exception 

may be if components begin to arrive in the spring 

before the site is available for construction (e.g., 

snow on-site). In such an instance, some 

components may be temporarily stored near the 

O&M facility site until full project site access is 

available. Figure 2.12 provides an example of a 

wind turbine and crane. 

2.2.3.5 Meteorological Tower Installation 

Two temporary meteorological (met) towers have 

already been installed within the project area, 

Additional met towers may be installed later (for 

control means) prior to the construction of each 

phase of development. If additional met towers 

are required, Teton would obtain all required 

federal, state, and county permits before the 

structure would be installed. The permanent met 

towers would be self-supporting and unguyed to 

minimize impacts to avian species. These towers 

would be located within the specific phase of 

development, but specific location cannot be 

determined at this time. However, these towers 

would be located next to existing access roads and 

would result in minimal disturbance (less than 

0.25 acre of disturbance) and would likely remain 

in place throughout the life of the project and 

would be removed during the decommissioning 

phase of the project. 
2-20 EA, White Mountain Wind Energy Project 

Figure 2.10 Typical Mat Foundation Installation (During Construction). 

Figure 2.11 Typical Pier Foundation Installation (Post-construction). 
EA, White Mountain Wind Energy Project 2-21 

Figure 2.12 Typical Wind Turbine and Crane. 

2.2.3.6 Substation 

Teton is currently negotiating a power purchase 

agreement and interconnection grant for this 

project. These agreements would be in place prior 

to construction of the project. 

The energy generated by the wind turbines would 

be delivered to the substation via the underground 

collection system. The location of the substation 

is illustrated on Figure 2.2. At the substation, 

voltage of the energy would be increased from the 

collection system level of 34.5 kV to the 

transmission line voltage of 230 kV. Also, 

capacitor banks and other equipment would be 

installed at the substation to provide the voltage 

support necessary to meet the interconnection 

requirements for the project. A small control 

building would be installed within the substation 

for electrical metering equipment and the 

supervisory control and data acquisition (SCADA) 

system for control of the wind turbines. 

2.2.3.7 Overhead Collection Lines 

The substation of the WMWE Project would be 

interconnected directly with the existing 

PacifiCorp 230-kV transmission line, and no 

overhead transmission lines would be required 

(refer to Figure 2.1). 

However, in a few select locations where buried 

cable power collector lines cannot be installed due 

to topography or rock conditions, short segments 

of low-voltage overhead power line could be 

installed. These low-voltage power lines (less 

than 46 kV) would consist of a single pole 

configuration with an overhead line to allow 

power generated at the wind turbines to be 

transmitted to the substation where the voltage 

would be stepped up and fed into the existing 

PacifiCorp transmission line. 

The overhead lines would follow the general route 

of the buried collector lines, and the collector lines 
2-22 EA, White Mountain Wind Energy Project 

would return to a buried or underground 

configuration where it is technically feasible to do 

so. No additional roads would be required 

because the power lines would generally follow 

the planned access roads and construction crews 

would drive cross-country during construction of 

the power line, thereby minimizing surface 

disturbance. The only disturbance associated with 

the power lines would be as a result of the drilling 

of the holes for each individual power pole 

(less than 4 ft2

), and the amount of disturbance for 

the overhead power line would be far less than the 

comparable distance of buried collector line. The 

exact location of where these short segments of 

overhead power lines would be installed cannot be 

determined at this time. However, based on a 

preliminary evaluation of the project area, Teton 

believes that only approximately 2.0 mi of 

overhead power lines of the planned 64.0 mi of 

buried collector line may be needed. 

The power lines would be designed, constructed, 

operated, and maintained in conformance with the 

National Electrical Safety Code and other 

applicable codes and standards. The power lines 

would also be designed in accordance with 

Suggested Practices for Raptor Protection on 

Power Lines: the State of the Art in 2006 (Avian 

Power Line Interaction Committee 2006). 

2.2.3.8 Operations and Maintenance Site 

The WMWE Project would require an O&M 

building for use during the life of the project. This 

site would include a building to house storage for 

small parts, offices for the project staff, computers 

and control equipment for the wind turbines, and 

shop facilities. This building would be preengineered, assembled, and finished on-site. The 

building would meet Sweetwater County Building 

Code Requirements. It would be located on 

private land in the south-central portion of the 

project area. The location of the O&M building is 

shown on Figure 2.2. A picture of the O&M 

building from the Colorado Green project near 

Lamar, Colorado, is shown in Figure 2.13. To 

minimize visual impacts, the O&M building 

would be painted a shale green color. The O&M 

building would utilize a septic system for waste 

water disposal. In addition, Teton would use 

motion detectors on exterior lighting at the O&M 

building and would not use high intensity (e.g., 

sodium vapor) lights. 

2.2.3.9 Construction Schedule and Workforce 

Requirements 

The exact schedule of construction would depend 

on the approval date for the project; weather; 

delivery schedules for the turbines, steel, concrete, 

and electrical components; and seasonal 

restrictions during which construction must be 

delayed for wildlife protection. The project would 

be developed in phases. In general, a typical 

schedule for one construction phase (e.g., 

60 turbines) of the wind energy project is shown in 

Table 2.5. Typical construction operations would 

occur during daylight hours 5 days per week. It is 

anticipated that approximately 187 full- and parttime employees would be required during the 

construction phase. 

2.2.4 General Construction Activities 

2.2.4.1 Housekeeping 

Good housekeeping is important for all 

construction sites, and wind energy projects are no 

different. Good housekeeping can drastically 

reduce the incidents of injuries on-site, as well as 

minimize the environmental impact. At the end of 

each work shift, debris would be removed from 

turbine sites and disposed of in a county-approved 

landfill. Materials still needed at the turbine site 

would be assembled and secured at the site, and 

those materials no longer needed would be 

returned to the construction staging area. 

One designated area would be used for washing 

out concrete trucks. The washout area would 

include catchment with an impermeable liner. 

Washout water would be recycled in the batch 

plan or pumped into tank trucks and removed from 

the site. The location for disposal would be at an 

approved disposal facility. 
EA, White Mountain Wind Energy Project 2-23 

Figure 2.13 Typical Wind Energy Facility O&M Building. 

Table 2.5 Typical Construction Schedule for One Phase of Approximately 60 Turbines. 

Activity Amount of Time (Months) 

Mobilization 1 

Access roads, staging areas complete 3 

Substation construction 3-6
 

Transmission construction 3-6 

Foundations 3-6 

Wind turbine generator erection 3-6 

Commissioning 4-8 

Acceptance testing 4-8 
2-24 EA, White Mountain Wind Energy Project 

2.2.4.2 Traffic 

Construction of the wind energy project would 

occur over a 4-year period utilizing various 

vehicles for installation of project components and 

for the delivery of equipment and personnel. The 

majority of the vehicles used during the 

construction would include pickup trucks, small 

flatbed trucks, water trucks, flatbed semis with a 

flatbed trailer, concrete delivery trucks, etc. 

Table 2.6 presents the estimated number of vehicle 

trips for component delivery. The single largest 

vehicle used for component delivery would be the 

blade truck (Figure 2.14). Table 2.7 presents 

information on the estimated number of vehicle 

trips that might occur during the construction 

phase of the Proposed Action. 

Vehicle traffic would be confined within the site 

boundary for safety, fire control, and the control of 

invasive nonnative species. Signs on the public 

roads utilized by these trucks would be erected to 

warn the public of the increased construction 

traffic, and all signage would be coordinated 

through the Wyoming Department of 

Transportation and the Sweetwater County Road 

and Bridge Department. In addition, all vehicles 

would be washed down at a location approved by 

the BLM for the control of invasive nonnative 

species prior to entering the site. 

2.2.4.3 Materials Receipt, Handling, and Storage 

With the large number of items and materials 

arriving on-site, a plan has been developed for 

receipt, handling, and storage. A construction 

staging area would be developed at the site of the 

O&M building along the side of the substation 

0.75 mi west of County Road 53 where most 

construction materials would be off-loaded and 

stored (refer to Figure 2.1). This temporary 

construction staging area would be approximately 

2.0 acres in size. The staging area would be for 

deliveries taken before the site is available, either 

due to weather or road construction. Otherwise, 

wind turbine components would be taken directly 

to the site where they would be installed. 

Materials needed for the concrete batch plant, 

substation construction, and electrical collection 

system would be off-loaded near their use sites. 

2.2.4.4 Fencing and Signage 

Teton would post warning signs along the access 

roads, including County Road 53 and 

Fourteenmile Road. Signage would include speed 

limit signs and signs informing the public of 

construction activities and recommending the 

public proceed with caution and watch for large 

vehicles and equipment. The content and location 

of such signs would be coordinated with Wyoming 

Department of Transportation and Sweetwater 

County officials. The existing access roads 

(County Road 53 and Fourteenmile Road) would 

remain open at all times except when they are 

physically and temporarily blocked by the 

movement of project-related vehicles or 

equipment. Teton would coordinate with the 

BLM, landowners, appropriate agencies, and 

Sweetwater County officials prior to equipment or 

component deliveries. 

For those areas where public safety risks may exist 

and site personnel would not be available to 

control public access (such as excavated 

foundation holes and electrical collection system 

trenches), temporary fences would be erected. 

Similarly, temporary fencing would be installed 

around any staging areas or other areas deemed 

hazardous or where issues with security or theft 

are of concern. Teton would coordinate the 

fencing/security with the appropriate entity (e.g., 

BLM Authorized Officer, landowner, county 

personnel). The project substation and O&M 

building would be permanently fenced for public 

safety. 

The staging area would be temporarily fenced with 

chain-link fencing. Temporary fencing around 

unfinished turbine bases is designed to warn 

people of the potential danger rather than to 

prevent physical access; therefore, this fencing is 

typically a high visibility plastic mesh material. 

Excavations would be fenced with chain-link 

fencing or other livestock fencing to prevent 

livestock from entering or falling into the open 

excavations. 
 

EA, White Mountain Wind Energy Project 2-25 

Table 2.6 Estimated Number Vehicle Loads for Component Delivery. 

Component Type 

Number of 

Components Required 

per Turbine 

Number of 

Components per 

Truck Load 

Number of Truck 

Loads per Turbine 

Tower section 3 1 3 

Turbine blades 3 1 3 

Nacelle 1 1 1 

Rotor hub 1 1 1 

Foundation components 2.5 1 2.5 

Foundation concrete (cubic yards) 70 10 7 

Total truck loads (components per 

turbine) 

17.5 

Number of truck loads for 

component delivery (240 turbines) 

4,200 

Number of truck loads for 

component deliveries for the 

substation 

50 

Number of truck loads for 

component deliveries for the O&M 

building 

20 

Number of trips for delivery of all 

components 

4,270 

2.2.5 Structural Construction Activities 

2.2.5.1 Concrete Supply 

A batch plant would be set up on-site (refer to 

Figure 2.2) to provide for the significant 

amounts of concrete necessary for the base 

foundations of the wind turbines and substation 

equipment. Attempting to bring trucks onto the 

site with premixed concrete is not feasible given 

the distances to the nearest concrete batch plants 

and the time needed to reach the various 

construction areas. Attempting such deliveries 

also would pose a hazard to public safety and 

have a greater impact on the environment. 

A batch plant capable of producing 

approximately 50 yd3

 of concrete per hour 

would be needed for this project. To operate 

such a plant, a total of 30 tons of sand, 45 tons 

of aggregate, 15 tons of cement, and 

3,000 gallons of water would be needed per hour 

while mixing concrete at peak production. The 

gravel and cement would be trucked to and 

temporarily stored next to the batch plant. The 

gravel and cement would be obtained from 

private sources that would be properly permitted 

by the appropriate state and county agencies 

located off-site, and water would be stored in a 

temporary aboveground storage tank. Teton 

would minimize the size of material stockpiles 

by ensuring that the gravel and cement would be 

trucked to the site on as close to an on-time use 

schedule as possible. Teton would also comply 

with applicable dust control requirements of the 

Wyoming Department of Environmental 

Quality/Air Quality Division (WDEQ/AQD). 

Based on previous experience, Teton would use 

a total of 420 acre-ft of water for dust abatement 

and concrete production during the construction 

phase of the Proposed Action. All water would 

be secured from existing permitted water 
2-26 EA, White Mountain Wind Energy Project 

Figure 2.14 Typical Wind Turbine Blade Delivery Truck (Photograph Obtained from Vestas). 

Table 2.7 Estimated Number Vehicle Trips During Construction Operations.1 

Number of 

Activity Number of Units Vehicle Trips per Unit Vehicle Trips 

Deliver components2 4,270 

Road construction 49 mi 50 2,450 

Batch plant construction and demo 1 plant 100 100 

Turbine and foundation construction 240 turbines 80 19,200 

Water Delivery3

 111 acre-ft 414 4,551 

Substation construction 1 substation 500 500 

Crane delivery and removal 1 crane 40 40 

O&M building construction 1 building 250 250 

Total number of vehicle trips 31,361 

1 These vehicle trips would occur over a 4-year period. 2 Details on number of vehicle trips for component delivery are presented in Table 2.6. 3 Water for both dust abatement and for concrete mixing. 4 Assumes an 8,000-gallon water truck. 
EA, White Mountain Wind Energy Project 2-27 

sources, and the water would be transported to the 

project area via water trucks. 

2.2.5.2 Steel Placement 

The construction of the numerous turbine 

foundations would require a considerable amount 

of steel reinforcement. Therefore, the staging area 

would also be used to store this rebar material 

until it is needed in the construction process. A 

fabrication area within the staging area would also 

be established to prefabricate sections of rebar 

before they are transported to the individual 

turbine base excavations. 

2.2.5.3 Formwork 

Depending on the type of turbine foundation 

selected, formwork may be necessary. Formwork 

with either timber or steel shuttering would be 

used to form a shape into which rebar is placed, 

and then the concrete is poured. The formwork 

shuttering is then removed when the concrete has 

cured. The shuttering may be re-used, but in 

the case of timber shuttering, it may be discarded 

at a proper disposal site when it is no longer fit for 

re-use. 

2.2.6 Electrical Construction Activities 

2.2.6.1 Buried Cable Placement 

To protect all existing pipelines, cables, or other 

buried utilities and prior to the installation of any 

buried cables, Teton would properly locate and 

mark all existing pipelines, cables, or other buried 

utilities. Marking would prevent accidental or 

inadvertent disturbance or damage to these 

existing utility lines, and equipment traveling over 

these utility lines would not be heavy enough to 

damage any of these existing facilities. 

There are two methods for the placement of the 

electrical collection system cable. The first is 

open trench placement, where a trench is dug 

using backhoe-type machines to the required depth 

of cable placement, the cable is placed in the 

trench, and the trench is then refilled. An example 

of an open trench is shown in Figure 2.15. If the 

geotechnical investigation shows that the soils 

present on-site would not conduct heat away from 

a buried cable properly, it would be necessary to 

install an engineered backfill material around the 

cable to improve heat dissipation. If such backfill 

is necessary, the open trench approach would be 

required. Until the geotechnical investigations are 

completed, it is not known which method would 

be used at the WMWE Project. As discussed in 

Section 2.2.2.7, excess materials excavated from 

the open trenches would be used for road fill or 

aggregate. 

The second placement method is direct cable 

placement using a trenching or cable plowing 

machine. These types of machines cut an opening 

with a plow-type device just large enough for the 

cable, place the cable in the ground, and then refill 

the hole in a combined single pass with the cut 

material (Figure 2.16). While very efficient, these 

machines are hampered in areas where the soil 

conditions are very rocky. 

The medium-voltage electrical collection system 

cable used for this project would be placed a 

minimum of 48 inches below grade, and the fiber 

optic communications cable used to control and 

communicate with the wind turbines would be 

placed a minimum of 18 inches below grade. 

The final depths would be determined by the 

geotechnical conditions of the area and the manner 

in which the cable is installed. Direct buried cable 

would have warning tape placed over the top at a 

depth of 12 inches, which would act as a visual 

reminder of the cable’s presence for future site 

work. 

2.2.6.2 Grounding 

Every wind turbine foundation would have a 

grounding mat cast in place when the base is 

constructed. This consists of a copper cable mat 

that discharges electric energy into the earth when 

the wind turbine is struck by lightning or 

experiences an equipment malfunction. The 

substation would also have a grounding grid laid 

below grade in trenches around the substation site 

to protect equipment and personnel in the case of 

electrical malfunction or lightning strike. 
2-28 EA, White Mountain Wind Energy Project 

Figure 2.15 Typical Open Trench Placement of the Cable. 

Figure 2.16 Typical Cable Plowing Machine in Operation. 
EA, White Mountain Wind Energy Project 2-29 

Transmission poles also require grounding. The 

grounding crew would follow behind the pole 

assembly and erection crew installing the grounds. 

This crew would install the proper number of 

ground rods and measure the ground resistance. If 

the proper ground resistance is not initially 

achieved, they would install additional ground 

rods until the acceptable ground resistance is 

obtained. 

2.2.6.3 Buswork and Electrical Line Connections 

The majority of the electrical connection systems 

would be installed underground. However, some 

overhead electrical lines and buswork (rigid 

overhead meter conductors) connections would be 

made at the project substation. The electrical 

collection system would come into the substation 

underground then transition overhead into the 

34.5-kV buswork. This buswork connects the 

wind turbines on different feeder lines (each 

feeder line connects 10 to 12 wind turbines) to a 

common bus. Any necessary voltage regulation 

devices would also connect to this buswork, which 

then connects to the low-voltage side of the 

substation transformer. On the high-voltage side 

of the transformer, an overhead connection would 

be made to the project transmission tie-line using a 

riser structure. 

This buswork would be constructed using small 

overhead cranes, scissor-lifts, and other similar 

devices. These components would be bolted 

together on-site and placed on small foundations 

for support. All of this work would be performed 

within the fenced substation area. Figure 2.17 

illustrates an example of buswork construction 

being performed. 

2.2.6.4 Communications Systems Installation 

Communications between the wind turbines and 

the substation would be achieved by installing 

underground fiber optic cables. These cables 

would be buried above the electrical collection 

system cables utilizing the same trenches in order 

to minimize the impact to the environment. 

Communications to the substation would also be 

achieved by using a buried fiber optic line to the 

O&M building. 

Figure 2.17 Typical Construction of a Substation Buswork. 
2-30 EA, White Mountain Wind Energy Project 

2.2.6.5 Aviation Marking and Lighting on Wind 

Turbines 

Federal Aviation Administration (FAA) 

regulations require that an aeronautical study be 

conducted on structures taller than 200 ft. The 

purpose of the aeronautical study is to determine if 

the proposed structure poses a threat to air 

navigation in the area and to also determine 

marking and lighting requirements for the 

structure. The wind turbines proposed for this 

project would be taller than 200 ft, so an 

aeronautical study by FAA has been conducted. 

In accordance with FAA regulations, Teton 

submitted an individual Notice of Proposed 

Construction to the FAA for each of the 240 wind 

turbines for their review. The FAA has completed 

their review and determined that none of the 240 

wind turbines exceed obstruction standards and 

would not be a hazard to air navigation with the 

following conditions: Teton would need to 

construct white turbines that meet marking 

requirement and night time flashing (L-864) and 

install synchronized red lights for select wind 

turbines. 

Marking and lighting of each wind turbine 

complies with FAA guidance presented in FAA 

Advisory Circular, AC 70/7460-1K, Obstruction 

Marking and Lighting (FAA 2007). For the 

WMWE Project, the FAA approved white towers, 

nacelles, and blades and a medium intensity red 

strobe synchronized flashing warning light 

(L-864) on top of the nacelle of the turbines 

located at the end of each turbine “string” plus 

lighting on every third or fourth turbine. 

Figure 2.18 illustrates the FAA-approved lighting 

plan for each wind turbine within the WMWE 

Project. If Teton wants to change the location of 

any of the wind turbines, they are required by 

FAA to submit an alteration application and obtain 

formal approval from FAA prior to making any 

such change in tower location. In order to 

minimize potential impacts to avian species, 

flashing lights would be used on wind turbines or 

met towers requiring FAA pilot warning lights. 

This design feature complies with Gehring et al. 

(2009). 

2.2.7 Wind Turbine Tower Erection 

2.2.7.1 Turbine Component Delivery and Storage 

As wind turbine components arrive at the WMWE 

Project site, they would be routed to the individual 

turbine sites where they would be installed. When 

trucks arrive at each site, a small crane mounted 

on rubber tires (rather than tracks) would remove 

the cargo. Each site would have a plan for the 

arrangement of major components before erection. 

These major components include the tower 

sections, nacelle, rotor hub, and blades (Figure 

2.19). If the wind turbine foundation has had 

sufficient time to cure before the lowest tower 

section arrives, that section would be off-loaded 

directly onto the foundation. If turbine 

components arrive before the individual sites are 

ready, the major components would be off-loaded 

and temporarily stored at the staging area near the 

O&M building. These components would then be 

moved to the turbine site as soon as feasible. 

While most of the major components would arrive 

in completed form, the rotor (consisting of the hub 

and blades) would need to be assembled. The 

rotor would be placed with the nose up, and a 

small crane would lift the blades so they can be 

attached to the rotor. Once these blades are 

attached and any hydraulic or electrical 

connections are made between the hub and blades, 

the completed rotor package would be lifted and 

connected to the turbine shaft located in the 

nacelle. A picture of a rotor being assembled is 

shown in Figure 2.20. 

2.2.7.2 Crane Assembly and Movement 

The crane used to lift the wind turbine components 

would arrive on-site disassembled, and the crane 

components would be taken to the crane assembly 

area, typically located at or near the first turbine 

site. Once the crane is assembled, the crane would 

be “walked” to the tower site, where the tower and 

turbine would be erected. After all of the large 

components of the wind turbines are erected, the 

crane would be “walked” to the next turbine site 

using the crane’s tracked base (Figure 2.21). The 

requirements for walking the crane would set 

many of the design parameters for the turbine 

2-32 EA, White Mountain Wind Energy Project 

Figure 2.19 Typical Schematic of Turbine Assembly Area Plan. 
EA, White Mountain Wind Energy Project 2-33 

Figure 2.20 Example of Rotor Assembly. 

Figure 2.21 Typical Tracked Crane. 
2-34 EA, White Mountain Wind Energy Project 

string road, including road width and slope. At 

locations where the road cannot be built within the 

tolerances for the crane, the crane would have to 

be disassembled, moved to the next site, and reassembled. 

2.2.7.3 Wind Turbine Component Lifts 

Wind turbines are installed in large pre-assembled 

components that are interconnected in the field. 

The tower, which usually consists of three or four 

sections, is installed first. The first section is 

installed and bolted to the tower foundation, then 

subsequent sections are lifted one at a time and 

bolted together in place as shown in Figure 2.22. 

Once the last tower section is in place, the turbine 

nacelle is secured to the top of the tower as shown 

in Figure 2.23. Finally, the rotor (hub and blades) 

is lifted into place and secured onto the nacelle 

(Figure 2.24). 

Once the crane and all wind turbine components 

have arrived at a site, the assembly of the major 

components typically takes 1-2 days. The lifting 

of large turbine components can only be done 

during periods of low winds and good visibility. 

Weather delays may occur at some sites. 

To reduce the amount of time needed to complete 

the project, two or more large cranes may be used 

simultaneously to install the various wind turbines. 

2.2.8 Reclamation Following Construction 

Operations 

Teton would implement reclamation (described in 

Section 2.4.8) for those areas of temporary 

disturbance no longer needed during the O&M 

phase of the Proposed Action. 

2.3 OPERATION AND MAINTENANCE 

2.3.1 Health, Safety, and Environmental Plan 

Prior to the start-up and operation of the wind 

energy facilities, the HSE Plan would be reviewed 

to incorporate additional requirements for O&M 

for the project. Specific procedures for complying 

with the BLM requirements that have not already 

been addressed in the plan would be added to 

ensure the continued focus on health, safety, and 

environmental awareness. 

2.3.2 Project Operation and Maintenance Plan 

The WMWE Project would require an O&M plan 

to achieve reliable and safe operation. The plan 

would be prepared in conjunction with the 

manufacturer of the turbines. Teton expects that 

full-time maintenance persons would be required 

for the entire 240 wind turbine project. 

As with all operating equipment, some amount of 

unscheduled maintenance and repair would be 

necessary. It is just as important that these 

activities, while often important and urgent, still 

be performed according to the requirements of the 

POD, equipment specifications, and good industry 

practice. 

As with the construction phase of the project, 

Teton understands that the project site is part of 

the public trust. As much as feasible, the site 

would be maintained and operated in a manner 

safe and compatible with public recreation, 

livestock grazing, Native American sensitivities, 

and other uses. During some maintenance or 

emergency response situations, it may be 

necessary to temporarily control access to a small 

portion of the project site to maintain public 

safety. Such situations would be discussed in the 

detailed project O&M plan. 

2.3.3 Operation Activities 

2.3.3.1 Orientation and Training 

All maintenance employees of the project would 

receive training regarding safe work on wind 

turbines and the specific tasks necessary to 

provide scheduled and unscheduled wind turbine 

maintenance. All employees (regardless of job 

requirements) would be trained in the 

environmental management and monitoring 

requirements of the project ROW grant. 

2.3.3.2 Wind Facility Performance Monitoring 

Wind turbines generally operate autonomously, 

guided by sophisticated computers and software. 
EA, White Mountain Wind Energy Project 2-35 

Figure 2.22 Typical Midsection Tower Assembly. 

Figure 2.23 Typical Turbine Nacelle Placement. 
2-36 EA, White Mountain Wind Energy Project 

Figure 2.24 Typical Complete Rotor Pickup. 

The site manager and staff monitor the 

performance of the turbines and initiate manual 

control only as needed for maintenance and 

troubleshooting. 

Periodically, plant management would analyze the 

performance trends of individual wind turbines 

and the overall project to ascertain the overall 

efficiency of operation. This analysis would 

utilize data collected from the wind turbines and 

the permanent met towers. It is possible some 

scheduled maintenance activities would be added 

or adjusted to improve the performance of the 

project-related equipment. 

2.3.4 Maintenance Activities 

The activities necessary to perform preventive 

maintenance, as well as equipment repairs as 

needed, are described in general below. 

2.3.4.1 Project Inspections 

As proponent personnel drive through the project 

area to perform scheduled activities, they would 

also perform a visual inspection of the project. 

The purpose of this inspection is to identify any 

obvious problems with the wind turbines that may 

require maintenance. If staff identifies a turbine 

that may be operating in an unsafe manner, that 

turbine would be stopped (remotely) until the 

condition can be fixed. This inspection is a 

redundant check because the turbine has many 

internal sensors that watch for any potentially 

unsafe operational condition. 

Staff would also review, along with the turbines, 

the condition of the project roads and other visible 

aspects of the project infrastructure. This would 

include reviewing the condition of substation 

fencing and components, looking for any loose 
EA, White Mountain Wind Energy Project 2-37 

trash on-site, and checking for any vandalism. 

Any conditions found that could impact public 

safety, wildlife, livestock, or the environment in 

general that cannot be immediately fixed would be 

reported to the BLM Authorized Officer or other 

appropriate authority (e.g., landowners or county 

personnel). 

While normal project operations would allow 

these inspections to occur frequently, there may be 

periods when the site cannot be accessed and these 

inspections are suspended. Conditions causing 

such suspensions could include extremely high 

winds, blizzards, or heavy rain. The criteria for 

conditions in which the site would not be 

accessible would be described in detail in the HSE 

Plan and would also be subject to the judgment of 

the project manager and maintenance staff. 

2.3.4.2 Scheduled Wind Turbine Maintenance 

As with all machinery, regularly scheduled 

preventive maintenance is the best way to ensure 

that wind turbines operate in a safe and efficient 

manner. The project O&M Plan would include the 

scheduled minor and major maintenance and 

inspection activities anticipated during the 

calendar year. 

Various inspections would be performed on a 

daily, weekly, or monthly basis. Results of these 

inspections are logged and used to plan future 

maintenance activities. Visual inspections inside 

the rotor head, nacelle, and tower bottom are done 

on a regularly scheduled basis. Information 

collected in these inspections is utilized to plan 

future maintenance activities. Particular attention 

would be paid to identify minor oil leaks so that 

appropriate repair work can be performed before 

the leaks pose a potential environmental issue. 

Regularly scheduled preventive maintenance 

activities also are performed on a daily, weekly, or 

monthly basis. A list of all scheduled preventive 

maintenance activities would be included in the 

O&M Plan. 

Two annual wind turbine maintenance cycles are 

anticipated. These would be planned for the 

spring and fall months of each year. While not 

currently anticipated, it may be necessary for blade 

washing to also be performed to improve wind 

turbine performance. 

Over the project operational period, major 

maintenance or repair events are recorded so that 

underlying causes can be determined and 

analyzed. These analyses may lead to 

modifications to the turbines, project operation, or 

maintenance practices to improve the efficiency 

and safety of the project. 

Teton anticipates that a maximum of 

approximately 57 direct O&M jobs would be 

required to service the project. In addition, 

pickups and other small service trucks would be 

used by on-site personnel, and Teton anticipates 

that 20 road trips per day would be required to 

perform maintenance activities on the entire 

project. This would result in approximately 5,000 

road trips per year. The typical activities 

necessary to operate and maintain the WMWE 

Project are described below. 

2.3.4.3 Unscheduled Wind Turbine Maintenance 

Introduction 

Wind turbine maintenance and internal inspection 

activities are normally performed on a scheduled 

basis. However, when problems occur, 

unscheduled maintenance would be required in 

order to maintain the operating efficiency of the 

project. 

During the first several years of operation, the 

turbines would be new and major repairs are not 

anticipated; however, they cannot be ruled out. 

Any turbine experiencing mechanical difficulties 

that could result in safety or environmental risks or 

damage to the equipment would be taken offline 

until repairs can be completed. Otherwise, repairs 

would be planned for the first convenient 

opportunity. 

The three levels of unscheduled maintenance are 

discussed below. All potential repair activities 

would be described in more detail in the manuals 

for the wind turbine design chosen for the project. 
2-38 EA, White Mountain Wind Energy Project 

Minor Repairs and Component Replacement 

Making minor repairs to the turbines or replacing 

faulty internal components are the most common 

form of unscheduled turbine maintenance. 

All of these repairs can be done using small tools 

and the turbine-integrated winch system. It should 

not be necessary to bring even a small crane onto 

the site. No vehicles other than the project 

pickups and sport utility vehicles would likely be 

needed. These vehicles would stay on the project 

roads or in the clearing beneath each wind turbine. 

Major Repairs and Component Replacement 

Although far less common, it is possible that 

major components could need to be replaced 

during the operational phase of the project. These 

components could include the following: 

• blades, 

• generator, 

• gearbox, and 

• transformer (if in the nacelle). 

Such a replacement may require at least one large 

crane be brought back to the site, and trucks would 

be needed to bring the crane to the turbine 

location. If the crane pad installed for the 

construction phase of the project was no longer 

available, such a pad would need to be installed. 

If a major component becomes damaged and 

requires replacement, the turbine would be 

stopped and placed out of service until the 

component replacement is completed. Once the 

crane and replacement component arrive on-site 

and are prepared for service, the actual component 

replacement would only take 1 or 2 days. Once 

the new component is installed, the crane would 

be removed from the site and the turbine returned 

to service. This activity would be planned to 

minimize crane time on-site and the overall impact 

to the environment. 

Wind Turbine Replacement 

The replacement of a complete wind turbine at a 

project prior to decommissioning the facility is 

uncommon. It would only be necessary if there 

were problems with the wind turbine tower or 

foundation, as all other components can be 

replaced without removing the entire turbine. 

The replacement of a wind turbine would require 

the same crane assembly as described above. The 

wind turbine components would be removed in the 

reverse order they were installed. Each of the 

removed components not used on the replacement 

wind turbine would then be loaded onto trucks and 

removed from the site. After the old components 

have been removed, replacement components 

would be brought to the site and arranged in a 

manner similar to that discussed above. The wind 

turbine would once again be erected using the 

appropriate combination of original and 

replacement components. Given the need to 

remove old components and bring new 

components to the site after the original wind 

turbine was disassembled, the entire wind turbine 

replacement activity could require the crane to 

remain on-site for a week or longer. 

2.3.4.4 Balance of Plant Maintenance 

Introduction 

While the wind turbines are the major components 

of the project expected to require the most 

maintenance services, some maintenance would be 

needed for the balance of the project. Those 

maintenance services are described below. 

Substation Maintenance 

The project substation would be inspected 

periodically to look for any obvious problems or 

areas of concern. Additionally, the substation 

would undergo an annual inspection and 

maintenance cycle to ensure all protection 

equipment is functioning properly. This generally 

involves inspection of the breakers and switches to 

be certain they would operate as needed in a fault 

or emergency. Electrical connections would also 

be inspected and tested as needed to ensure no 

unsafe situations exist. 

Maintenance to the substation transformer, 

switchgear, and buswork would require the 

substation be de-energized and, therefore, the 
EA, White Mountain Wind Energy Project 2-39 

project shutdown. Teton would schedule this 

maintenance for low wind months of the year as 

much as possible. Most maintenance activities can 

be performed during a single day each year. 

All substation equipment is within a fenced area, 

minimizing any potential impacts to the public, 

wildlife, or livestock. 

Road Maintenance 

Road maintenance within the WMWE project area 

would be performed by Teton on an as needed 

basis. Regular snow removal is expected to be 

required during the winter months to maintain 

access to the turbines and substation. Teton would 

also plow openings at least every 0.25 mi, or as 

directed by the BLM, in the snow berms to allow 

big game species to move off of and away from 

road activities. During periods of heavy snow, 

Teton may use snowmobiles to access some wind 

turbines. All snowmobile use would be restricted 

to existing roads and no off-road travel would be 

allowed. It is expected that minor amounts of 

surface dragging, blading, or grading would be 

required after the spring thaw to remove vehicle 

ruts. Other similar surface work may be needed 

after periods of heavy rainfall or just periodically 

due to maintenance traffic. Any identified needed 

repairs would be promptly addressed. Also, any 

culverts, drains, or other water management 

devices would be kept clear to allow effective 

drainage. 

To mitigate against dust, the road surfaces would 

be watered or otherwise treated with dust control 

measures. These treatments would occur as 

needed based on weather conditions and the 

amount of traffic on the road. Teton estimates that 

approximately 14 acre-ft of water would be 

required annually over the life of operation for 

dust control. Water would be secured from 

existing permitted water sources, and it would be 

hauled by truck to the project area. Any treatment 

substance other than water would only be used 

after consultation with the BLM Authorized 

Officer or county personnel, if applicable. 

O&M Building Maintenance 

Any maintenance requirements for the O&M 

building are expected to be typical for a building 

of this type of construction and would be 

performed on an as-needed basis. Exterior 

maintenance would be performed in a timely 

manner to maintain a presentable appearance to 

the general public. Housekeeping and area 

cleanup would be done on a regular basis to avoid 

the buildup of litter and other unsightly materials. 

2.4 DECOMMISSIONING 

As with any energy project, the WMWE Project 

would have a fixed time after which it may no 

longer be cost effective to continue operation. At 

that time, the project would be decommissioned, 

and the existing equipment, facilities, and 

structures would be removed and the disturbed 

areas revegetated. While it is possible the project 

owners may want to work with the BLM, 

landowners, state, and county to repower the site 

(replace the existing wind energy project with a 

new project on the same site), repowering is not 

being considered in this plan. 

2.4.1 Health, Safety, and Environmental Plan 

When the project moves into the decommissioning 

stage, the operation’s HSE Plan would be 

modified to include the decommissioning 

activities. Decommissioning requires outside 

contractors, cranes, and large equipment to be 

brought back to the site. 

Components of the management system that 

would be addressed in the plan include, but are not 

limited to, risk management analysis, emergency 

response, HSE planning and procedures, 

implementation, monitoring and reporting results, 

setting performance targets, incident classification, 

investigation and reporting results, audits and 

inspections, and HSE management review. 

Minimum contractor HSE requirements would be 

included in the plan. These are typically such 

requirements as personal protective equipment, 

housekeeping, maintaining a safe workplace, fire 

prevention, safe work practices, etc. Contractors 
2-40 EA, White Mountain Wind Energy Project 

are expected to comply with these requirements at 

a minimum. Contractor safety plans would be 

reviewed for compliance. Contractor BMPs 

would be reviewed and incorporated into the plan 

as appropriate. 

Once the framework of the plan is completed, the 

project would be reviewed for site-specific HSE 

requirements and would be modified to 

incorporate them. 

Also included in the HSE Plan is a risk register 

that identifies potential hazards and the risks 

associated with them. Contractors are expected to 

address these risks and to develop mitigation plans 

for incorporation into the register. The risk 

register would be used and updated on a 

continuous basis to identify and mitigate risks as 

they arise. It is conceivable that mitigation plans 

as developed may not prove to be sufficient. In 

this case, the plan would be adjusted to provide a 

suitable solution to project risks. 

Observation of HSE performance is key to 

avoiding incidents. Project personnel would be 

expected to regularly observe work practices and 

to provide positive reinforcement and guidance to 

fellow employees. Work practices that may be 

considered to place employees or the environment 

at risk would be identified, evaluated, and 

modified as necessary to eliminate or substantially 

reduce the risk. 

2.4.2 Project Decommissioning Plan 

The goal of project decommissioning is to remove 

the installed power generation equipment and 

return the site to a condition as close to a 

preconstruction state as feasible. 

These activities are discussed in more detail in the 

subsequent sections. The specific requirements 

and approach for each activity is an estimate since 

the technologies and construction techniques 

available when the project is decommissioned are 

expected to change. 

2.4.3 Wind Turbine/Meteorological Tower 

Removal 

The decommissioning activity most notable to the 

general public would be the removal of the wind 

turbines and met towers. The disassembly and 

removal of this equipment would essentially be the 

same as its installation but in reverse order. 

2.4.3.1 Crane Movement and Assembly 

When a large crane first arrives onto the project 

site, it would be taken to the location for the first 

turbine removal. The crane would be assembled 

on that site, and then used to disassemble the wind 

turbine. Once the turbine at that site is 

disassembled, the crane would be “walked” to the 

next turbine site using the cranes tracked base (see 

Figure 2.12). If the requirements for walking the 

cranes to the met towers on the project roads 

cannot be accomplished, road improvements may 

be necessary. At locations where the road cannot 

be improved to within the tolerances for walking 

the crane, the crane would be dissembled, moved 

to the next site, and re-assembled. 

If the crane pads built for the construction of the 

project were subsequently removed or no longer 

meet the requirements for the crane, then crane 

pads would need to be installed or improved. 

2.4.3.2 Wind Turbine/Meteorological Tower 

Disassembly 

The large components that make up a wind turbine 

would be dissembled in the reverse order that they 

were assembled. The rotor (hub and blades) are 

removed from the nacelle and, with the help of a 

smaller crane, turned horizontally and set on the 

ground. Next, the nacelle would be removed from 

the top of the tower, followed by each portion of 

the tower. The met tower would similarly be 

disassembled by a crane, starting with the upper 

tower section and moving downward. 

Once the turbine rotor has been removed, a crew 

and small crane would disassemble it into the hub 

and three loose turbine blades. 
EA, White Mountain Wind Energy Project 2-41 

2.4.3.3 Component Removal 

The most efficient manner for component removal 

(other than the rotor) would involve individual 

parts being lowered from the turbine and placed 

directly onto a truck bed. These trucks can then 

immediately take the component off-site. This 

approach would limit the need for clearing an area 

around the turbine base to set down the rotor. 

When the rotor is disassembled, the blades would 

be placed into a carrying frame. The blades in the 

frame can then be loaded onto a truck for removal 

from the site. The hub can also be removed once 

it is disassembled from the blades. 

2.4.4 Electrical System Removal 

2.4.4.1 Buried Cable Removal 

The buried electrical cable and fiber optic cable 

located between each turbine would be cut off 

24 inches below grade and left in place. 

2.4.4.2 Substation Disassembly and Equipment 

Removal 

Once the project and transmission line is deenergized, the substation would be disassembled. 

Major components would be removed from their 

foundations and placed onto trucks using a small 

crane. The steel structures and control building 

would be disassembled and removed from the site. 

The fence would be taken down, and fence posts 

would be removed. The gravel placed in the 

substation would be removed if it was not native 

rock that had been removed from excavations and 

crushed. Native rock would be scattered on-site. 

Once again, buried grounding equipment would be 

cut off at least 24 inches below grade and left in 

place. 

2.4.4.3 Transmission Line Removal 

Assuming the transmission line no longer serves a 

purpose for this project, it would be disassembled 

and removed. Initially, the wires would be 

removed from the tower hangers and collected for 

recycling. The power line structures would then 

be disassembled and removed, including 

grounding rods to 24 inches below grade. The 

areas around the poles, along with any two-track 

access roads that were necessary, would be 

reclaimed. 

2.4.5 Operations and Maintenance Building 

Removal 

All equipment and furniture in the O&M building 

would be removed, and then the building would be 

disassembled or demolished and removed from the 

site. All debris from the demolition would be 

removed from the project site and either disposed 

of at an approved landfill, recycled, or re-used. 

Any installed septic system would also be 

abandoned in a manner consistent with state and 

local regulations. 

2.4.6 Structural Foundation Removal 

When the wind turbines, met towers, and 

substation components are removed from their 

foundations, the foundations would be removed 

according to the requirements of the ROW grant 

and/or landowner agreement. Teton expects that 

the concrete and steel in the foundations would be 

broken up and removed to a depth of 24 inches 

below grade. Shallow foundations (like that for 

the O&M building) would be removed in their 

entirety. All concrete and steel debris would be 

removed from the site and either disposed of at an 

approved landfill, recycled, or re-used. 

2.4.7 Road Removal 

The BLM, in conjunction with the landowners, 

would have the choice when the project is 

decommissioned as to whether the access roads 

constructed for this project would be removed or 

left in place to facilitate public access in the area. 

However, if the BLM, in conjunction with the 

landowner, chooses to leave the roads in place, 

they would become the responsibility of the BLM 

and/or the landowners. 

Once all the necessary equipment and materials 

have been removed from an area and the road to 

that area is no longer needed, it can be removed. 

The road surface and bed materials would be 
2-42 EA, White Mountain Wind Energy Project 

removed down to the original grade. Any native 

materials would be used for reclamation of the 

site, and foreign materials would be removed and 

properly disposed. 

2.4.8 Reclamation Plan 

2.4.8.1 Introduction 

Teton would be responsible for stabilizing and 

reclaiming all disturbance created by the 

WMWE Project, and Teton would use appropriate 

stabilization and reclamation methods and 

materials for the area. Teton would also reclaim 

all temporary disturbances in accordance with 

these procedures as soon as physically possible. 

2.4.8.2 Regrading and Retopsoiling Operations 

For areas where equipment or materials are 

removed, those areas would be regraded back to 

preconstruction contours (if possible), and 

stockpiled subsoil would be replaced and 

hipped/disced to reduce compaction. Holes where 

foundations have been removed would be refilled 

with native material. Removed roads would be 

regraded to original contours, if cuts and fills 

make such regrading practical. Crane pads would 

also be regraded. 

2.4.8.3 Topsoil Replacement and Seedbed 

Preparation 

Once regrading operations have been completed, 

available stockpiled topsoil would be replaced on 

the disturbed areas. After the topsoil has been 

replaced, compacted soils or disturbed soils would 

be lightly disced or harrowed to loosen soils and 

break soil clods; surfaces would be roughened to 

provide a suitable seedbed to reduce the potential 

for wind and water erosion and to improve the 

infiltration. Use of fertilizers or other soil 

amendments is not anticipated because fertilizers 

tend to promote weed growth. If reclamation is 

unsuccessful, the need for fertilizers would be reevaluated in consultation with the BLM and the 

landowners. 

2.4.8.4 Revegetation Operations 

The seed mixture to be used for revegetation 

operations is presented in Table 2.8. Species 

selection is based on existing species composition, 

establishment potential, growth characteristics, 

soil stabilizing qualities, palatability to wildlife, 

commercial availability, existing land uses, and 

agency recommendations. 

Certified seed of native species adapted to 

conditions along the project area would be 

purchased. Alternative species may be used, with 

prior approval from the BLM Authorized Officer 

and/or private landowners if any of these species 

become unavailable or if alternative species would 

be better suited to site-specific conditions. All 

seed mixtures would be tested for purity; noxious, 

poisonous, and/or prohibited plant species; and 

viability. The seed mixture would not contain any 

noxious weed seeds. Test results would be 

submitted to and approved by the 

BLM Authorized Officer and landowner, unless 

certified weed-free seed is procured for this 

reclamation project. 

Grass seed would be planted using a rangelandtype of drill equipped with a depth regulator to 

ensure proper depth of planting. Each species 

would be planted at an appropriate depth, 

generally 0.25 to 0.50 inch. Forb and shrub seeds 

would be planted using a cyclone-type broadcast 

seeder, and seeding rates would be doubled. In 

areas where it is not possible to drill seed, seed 

would be hand-broadcast or broadcast using a 

cyclone-type broadcast-seeder and seeding rates 

would be doubled. The seeded area would then be 

raked with a harrow or chain to cover seed and 

would be packed with a multipacker or similar 

implement to ensure appropriate soil/seed contact. 

In areas that are not accessible with revegetation 

equipment, broadcast-seeded areas would be handraked to cover seed. Areas where vegetation was 

only driven over (e.g., along the transmission line 

corridor) during construction would be broadcast 

seeded and raked to facilitate soil stabilization and 

vegetative regrowth. Temporary forage around 

the turbines may be necessary to facilitate the 

establishment of designated vegetation due to 

impacts from livestock, wildlife, and wild horses. 
1 

EA, White Mountain Wind Energy Project 2-43 

Table 2.8 Reclamation Seed Mixture. 

Species Seeding Rate (lbs PLS/acre)1 

Grasses (Three to four species would be selected) 

Indian ricegrass (Oryzopsis hymenoides) 2.0 

Bottlebrush squirreltail (Elymus elymoides) 2.0 

Thickspick wheatgrass (Elymus lanceolatus) 6.0 

Sandberg bluegrass (Poa secunda) 6.0 

Forbs (Two species would be selected) 

Blue flax (Linium lewisii) 0.5 

Scarlet globemallow (Sphaeralcea coccinea) 0.5 

Rocky Mountain beeplant (Cleome serrulata) 0.5 

Shrubs (Two species would be selected) 

Gardner’s saltbush (Atriplex gardneri) 2.0 

Winterfat (Krascheninnikovia lanata) 2.0 

Wyoming big sagebrush (Artemisia tridentata 1.0 

wyomingensis) 

Sterile Nonnative Species (May be used for site stabilization) 

Sterile Triticale (quick guard) 8.0-10.0 

Sterile wheatgrass, barely, or rye 8.0-10.0 

PLS = pure live seed. 
2-44 EA, White Mountain Wind Energy Project 

2.4.8.5 Reclamation Monitoring Plan 

Teton would be responsible for annual monitoring 

of reclamation success along the project area until 

it can be demonstrated to the BLM that 

revegetation success criteria have been met. 

Monitoring would also be conducted to ensure that 

erosion control, weed management, and 

revegetation efforts continue to meet the 

objectives of stabilization and productivity along 

the ROW. These efforts would continue until 

erosion control, weed management, and 

revegetation is deemed successful by the 

BLM/landowner or until the BLM/landowner 

determines that continued efforts are not 

necessary. 

2.4.8.6 Stability and Erosion Control 

Teton would implement stability and erosion 

control practices for all temporary and permanent 

reclamation in accordance with the SWPPP. 

Reclaimed areas within the project area would be 

considered stable if there are no large rills or 

gullies, no substantial soil movement, no 

headcutting in drainages, no slope instability, no 

subsidence, and no slumping that can be attributed 

to construction, operations, or maintenance. Teton 

would be responsible for annual inspections for 

the following types of problems as determined by 

the BLM Authorized Officer or landowner: 

•	 soil movement where the depth of recent 

deposits around obstacles is greater than 

0.5 inch; 

•	 surface litter movements where more than 

25% of surface litter has been transported 

and redeposited against obstacles 

downslope; 

•	 development of rills greater than 3 inches 

deep at intervals of 10 ft or less; 

•	 gully formation at intervals of 200 ft or 

less; and 

•	 channel erosion where more than 25% of 

the channel bed and walls show active 

erosion, gully formation, and/or 

headcutting or bank failure. 

If these features are discovered during reclamation 

inspections and their existence can be attributed to 

construction, O&M, or decommissioning 

operations of the WMWE Project, Teton would, in 

consultation with BLM and landowner, implement 

appropriate remedial action until reclamation 

objectives are met. 

2.4.8.7 Reclamation/Revegetation Success 

Monitoring 

Reclamation and revegetation would be 

considered successful on BLM-administered land 

when the Wyoming Rangeland Standard (BLM 

2009a) has been met. On private and state-owned 

land, revegetation would be considered successful 

if it meets the specific standards established in the 

applicable agreements. 

Reclaimed areas would be monitored by Teton for 

as long as determined by the BLM Authorized 

Officer or landowner. If any noxious weed 

species are discovered on project-related 

reclamation, Teton would implement appropriate 

weed control measures. 

2.5 DESIGN FEATURES OF THE 

PROPOSED ACTION AND 

ALTERNATIVE A 

The following design features would be 

implemented by Teton. Design features are based 

on applicable policies and BMPs provided in IM 

2009-043, land use plan requirements, or other 

best management practices. Prior to construction, 

Teton would implement appropriate avoidance in 

areas and/or setbacks (discussed below) in order to 

minimize impacts to public safety, operation of 

existing facilities, and environmental resources. 

2.5.1 Public Safety, Occupational Safety, and 

Hazardous Materials and Waste 

Management 

The project cannot limit public access to the site to 

a level lower than it was prior to the start of 

construction, except in those areas where public 

safety could be jeopardized (or where theft control 

measures are appropriate). The existing access 

roads (County Road 53 and Fourteenmile Road) 

would remain open at all times except when the 

roads are physically and temporarily blocked by 
EA, White Mountain Wind Energy Project 2-45 

the movement of project-related vehicles or 

equipment. 

During construction activities such as wind turbine 

assembly, Teton would have crews on-site 

performing the activity and monitoring overall 

safety. Construction personnel would comply 

with all applicable federal and state safety 

regulations. Construction crew members and 

safety monitors would be trained to ask members 

of the public to maintain a safe distance from the 

work zone. Neither the crew members nor the 

safety officers have the authority or responsibility 

to keep members of the public away from the 

construction zone, especially if members of the 

public choose to ignore posted signs. 

During the operation phase of this project, Teton 

would attempt to minimize vandalism and 

trespassing by having secured and locked access to 

wind turbine towers and electrical equipment and 

having O&M staff regularly patrol the area. In 

addition, the area around the substation and O&M 

building and storage area would be fenced for 

public safety. Fencing would be a minimum of 6 

ft high and would be equipped with Sweetwater 

County approved screening material to minimize 

visual intrusion. Fencing will be maintained. No 

other permanent fencing is currently anticipated, 

but this plan could be adjusted if additional 

fencing is needed. During some scheduled or 

unscheduled maintenance activities that could 

involve open pits or other potentially unsafe areas, 

temporary safety fencing would be installed. 

Teton would also install speed limit signs in the 

project area in cooperation with Sweetwater 

County officials. 

Teton would post warning signs along the access 

roads, including County Road 53 and 

Fourteenmile Road, informing the public of 

construction activities and recommending the 

public proceed with caution and watch for large 

vehicles and equipment. The existing access roads 

(County Road 53 and Fourteenmile Road) would 

remain open at all times except when they are 

physically and temporarily blocked by the 

movement of project-related vehicles or 

equipment. 

A project web site would be established during 

construction to describe the project and would 

explain current activities and provide 

recommendations regarding safe practices on the 

project site. Additional outreach would be 

performed as necessary. The goal of this program 

is to provide information to the curious public 

without them needing to physically access the site. 

Because of the improvements in wind turbine, 

tower, and blade designs over the past 10 years, 

Teton does not anticipate that ice throws from 

blades or tower failures would be a concern for 

public safety. 

Teton has evaluated the Proposed Action for 

shadow flicker and determined that shadow flicker 

would not likely be visible outside of the project 

area, and there would be no impacts to any 

residences in the Rock Springs/Green River area 

since the closest residence is located 0.92 mi east 

and 700 ft below the rim of White Mountain. 

Teton would provide a setback of 110% for all 

wind turbines (as measured from the ground to the 

top of the blade) from all property lines not 

included in the proposed project, from the ROW 

of all county roads in the project area, and from 

existing aboveground facilities. Teton would 

coordinate with the owners of the facilities 

(including buried facilities) to ensure that such 

facilities would be protected from disturbance and 

that existing operators are protected. 

All terms and conditions regarding private, state, 

and federal leases would be conveyed to any 

subsequent property owner. The proposed project 

would not impact any existing cathodic protection 

equipment located within the proposed project 

area. All geotechnical holes or test pits would be 

backfilled in accordance with applicable 

requirements. Any required material or excess 

material would be obtained or dispersed of at a 

properly permitted facility. 

During construction and decommissioning, 

portable toilets would be provided for workers onsite, and the waste would be properly disposed of 

through an approved waste disposal facility on an 

as-needed basis. During the O&M phase, 
2-46 EA, White Mountain Wind Energy Project 

permanent toilet facilities would be placed in the 

O&M building, and waste would be disposed of 

through a state and county approved septic system. 

Solid waste such as garbage and other discarded 

solid materials would be collected at designated 

collection sites and disposed of at an approved 

solid waste management facility. Solid waste 

would not be imported into or disposed of within 

the WMWE project area. Some large equipment 

would be fueled on-site, and some small spills of 

petroleum products may occur due to periodic 

equipment maintenance and/or accidents. If such 

spills occur, petroleum-contaminated soils would 

be disposed of in accordance with the Spill 

Prevention, Control, and Countermeasures Plan 

(SPCCP) and direction from the BLM and/or 

WDEQ as appropriate. Typical hazardous 

chemicals and petroleum products used in 

equipment during the construction and 

decommissioning phases of a wind energy facility 

include diesel fuel, gasoline, gearbox oils, 

hydraulic fluids, lubricants, cleaning fluids, paints, 

degreasers, and other similar substances. Typical 

hazardous chemicals and petroleum products used 

in equipment during the O&M phase of the wind 

energy project include mineral oil, diesel fuel, 

gasoline, gearbox oils, hydraulic fluids, lubricants, 

and cleaning fluids. All nonhazardous wastes 

would be disposed of in accordance with 

appropriate county, state, and federal regulations. 

Operators would handle and dispose of all 

hazardous wastes in accordance with applicable 

state and federal rules and regulations. Any 

release of hazardous substances in excess of 

reportable quantities, established in 40 CFR 117, 

would be reported as required by Comprehensive 

Environmental Response, Compensation, and 

Liability Act (CERCLA) (as amended). If a 

release of a reportable quantity of any hazardous 

substances occurs, a report would be provided to 

WDEQ and all other appropriate federal, state, and 

county agencies. 

Teton has evaluated potential interference to 

existing radio transmitters and microwave 

reflector facilities and made appropriate 

adjustments to the turbine layout to avoid any 

potential areas of interference. 

Teton has submitted and received “determinations 

of no hazard to air navigation” from the FAA for 

all 240 wind turbines in the WMWE project area. 

There are no known military operating areas 

within or near the WMWE project area that could 

pose a hazard to military flight operations. 

Prior to the construction of specific phases, Teton 

would obtain all required permits from all 

appropriate federal, state, and county agencies. 

2.5.2 Construction and O&M Operations 

Prior to the construction of any project-related 

equipment, structures, or facilities, all available 

vegetation and all available topsoil would be 

salvaged and stockpiled for future reclamation 

operations. If less than 6 inches of topsoil are 

available, topsoil along with an appropriate 

quantity of other suitable subsoil (with BLM or 

landowner approval) would be salvaged so that a 

minimum of 6 inches of plant growth material 

would be available for use during revegetation 

operations. Topsoil and suitable subsoil would be 

stockpiled separately, and appropriate signs would 

be installed on each topsoil or subsoil pile. 

Topsoil salvage operations would apply to all 

construction activities except for the construction 

of any required overhead transmission power 

lines. Topsoil salvage operations are not required 

for the construction of overhead power lines 

because these activities would result in minimal 

disturbance from wheeled vehicles driving over 

the vegetation and soil. In addition, natural 

revegetation would occur more rapidly if the 

vegetation and soil is left in place. 

Teton would not conduct any construction, O&M, 

or decommissioning activities when soils in the 

work area are too wet to adequately support 

construction equipment. If construction 

equipment creates ruts greater than 4 inches deep, 

support would be deemed inadequate, and 

activities would be discontinued until soil 

conditions improve or appropriate remediation 

action is taken to ensure operations could continue 

without deep rutting. 
EA, White Mountain Wind Energy Project 2-47 

In order for equipment and personnel to reach the 

wind turbine locations, existing roads would be 

used whenever possible; although, some existing 

two-track roads would need to be upgraded and 

new roads would need to be constructed. 

Designers would work to minimize the amount of 

work area required at each site, and, where 

possible, only a minimal amount of vegetation 

would be removed to allow for component 

delivery. 

Once construction of the roads and turbine pads is 

complete, reclamation would be performed around 

the areas disturbed by the civil construction 

operations. Cut materials used during the road 

construction would be used to return contours to 

near preconstruction conditions. Any remaining 

cut materials would be distributed across the 

mountain in a manner that would not increase dust 

and erosion or change drainage conditions but 

would keep the materials on the mountain. Any 

exposed areas that are not covered by road 

materials would be revegetated using a seed 

mixture specified by the BLM. Control of 

invasive nonnative species would continue on-site 

during the revegetation process and during the life 

of the project. 

The BLM has indicated that all excavated 

materials from their lands should be used within 

the boundaries of their land. If Teton determines 

that some native materials would need to be 

removed from BLM-administered land, Teton 

would obtain approval from the BLM before 

undertaking any such activities. 

If additional met towers are required, Teton would 

obtain all required federal, state, and county 

permits before the structure would be installed. In 

addition, all new met towers would be selfsupporting and would not require any guy wires. 

The O&M building would meet Sweetwater 

County Building Code requirements, and it would 

be painted a shale green color. 

All engineered plans and/or as-built drawings 

would be provided to BLM and Sweetwater 

County and would be certified by a Wyoming 

licensed Professional Engineer. 

One area within the project area would be 

designated and used for washing out concrete 

trucks. The washout area would include 

catchment with an impermeable liner. Washout 

water would be recycled in the batch plant or 

pumped into tank trucks and removed from the 

site. The location for disposal would be at an 

approved disposal facility. 

For those areas where public safety risks may exist 

and site personnel would not be available to 

control public access (such as excavated 

foundation holes and electrical collection system 

trenches), temporary fences would be erected. 

Similarly, temporary fencing would be installed 

around any staging areas or other areas deemed 

hazardous or where issues with security or theft 

are of concern. Teton would coordinate the 

fencing/security with the appropriate entity (e.g., 

BLM Authorized Officer, landowner, county 

personnel). The project substation and O&M 

building would be permanently fenced for public 

safety. 

The staging area would be temporarily fenced with 

chain-link fencing. Temporary fencing around 

unfinished turbine bases is designed to warn 

people of the potential danger rather than to 

prevent physical access; therefore, this fencing is 

typically a high visibility plastic mesh material. 

Excavations would be fenced with chain-link 

fencing or other livestock fencing to prevent 

livestock from entering or falling into the open 

excavations. 

The gravel and cement for this project would be 

obtained from private sources that would be 

properly permitted by the appropriate state and 

county agencies located off-site, and water would 

be stored in a temporary aboveground storage 

tank. Teton would minimize the size of material 

stockpiles by ensuring that the gravel and cement 

would be trucked to the site on as close to an ontime use schedule as possible. Teton would also 

comply with applicable dust control requirements 

of the WDEQ/AQD. 

Concrete forms (i.e., shuttering) may be re-used, 

but in the case of timber shuttering, it may be 
2-48 EA, White Mountain Wind Energy Project 

discarded at a proper disposal site when it is no 

longer fit for re-use. 

Marking and lighting of wind turbine and met 

towers complies with FAA guidance presented in 

FAA Advisory Circular, AC 70/7460-1K, 

Obstruction Marking and Lighting (FAA 2007). 

For the WMWE Project, the FAA would require 

that all wind towers be painted white and a 

medium intensity red strobe (flashing) warning 

light would be placed on top of the nacelle of the 

turbines located at the end of each turbine “string,” 

plus lighting on every third or fourth turbine. In 

order to minimize potential impacts to avian 

species, flashing lights would be used on wind 

turbines or met towers requiring FAA pilot 

warning lights. 

Any conditions found that could impact public 

safety, wildlife, livestock, or the environment in 

general that cannot be immediately fixed would be 

reported to the BLM Authorized Officer or other 

appropriate authority (landowner, county 

personnel). 

2.5.3 Decommissioning and Reclamation 

Operations 

During the decommissioning phase of this project, 

all above-grade project-related facilities (e.g., 

wind turbines, towers, roads, buildings, and 

substation) would be removed from the site to a 

depth of at least 24 inches below grade and 

backfilled with native materials. The gravel 

placed in the substation would be removed if it 

was not native rock that had been removed from 

excavations and crushed, and native rock would be 

scattered on-site. 

The BLM, in conjunction with the landowners, 

would have the choice when the project is 

decommissioned as to whether the access roads 

constructed for this project would be removed or 

left in place to facilitate public access in the area. 

However, if the BLM, in conjunction with the 

landowner, chooses to leave the roads in place, 

they would become the responsibility of the BLM 

and/or the landowners. 

Once all the necessary equipment and materials 

have been removed from an area and the road to 

that area is no longer needed, the road itself would 

be removed. The road surface and bed materials 

would be removed down to the original grade. 

Any native materials would be used for 

reclamation of the site, and foreign materials 

would be removed and properly disposed. 

During reclamation operations, available 

stockpiled topsoil would be replaced on the 

disturbed areas. After the topsoil has been 

replaced, compacted soils or disturbed soils would 

be lightly disced or harrowed to loosen soils and 

break soil clods; surfaces would be roughened to 

provide a suitable seedbed to reduce the potential 

for wind and water erosion and to improve the 

infiltration. 

Teton would use the reclamation seed mixture 

presented in Table 2.8 and only certified seed of 

native species adapted to conditions along the 

project area would be purchased. Alternative 

species may be used, with prior approval from the 

BLM Authorized Officer and/or private 

landowners, if any of these species become 

unavailable or if alternative species would be 

better suited to site-specific conditions. All seed 

mixtures would be tested for purity; noxious, 

poisonous, and/or prohibited plant species; and 

viability. The seed mixture would not contain any 

noxious weed seeds. Test results would be 

submitted to and approved by the 

BLM Authorized Officer, unless certified weedfree seed is procured for this reclamation project. 

Grass seed would be planted using a rangelandtype of drill equipped with a depth regulator to 

ensure proper depth of planting. Each species 

would be planted at an appropriate depth, 

generally 0.25 to 0.50 inch. Forb and shrub seeds 

would be planted using a cyclone-type broadcast 

seeder, and seeding rates would be doubled. In 

areas where it is not possible to drill seed, seed 

would be hand-broadcast or broadcast using a 

cyclone-type broadcast-seeder, and seeding rates 

would be doubled. The seeded area would then be 

raked with a harrow or chain to cover seed and 

would be packed with a multipacker or similar 

implement to ensure appropriate soil/seed contact. 
EA, White Mountain Wind Energy Project 2-49 

In areas that are not accessible with revegetation 

equipment, broadcast-seeded areas would be handraked to cover seed. Areas where vegetation was 

only driven over (e.g., along the transmission line 

corridor) during construction would be broadcast 

seeded and raked to facilitate soil stabilization and 

vegetative regrowth. 

Teton would be responsible for the monitoring of 

reclamation success within the project area until it 

can be demonstrated that revegetation success 

criteria have been met. Monitoring would also be 

conducted to ensure that erosion control, weed 

management, and revegetation efforts continue to 

meet the objectives of stabilization and 

productivity along the ROW. These efforts would 

continue until erosion control, weed management, 

and revegetation is deemed successful by the 

BLM/landowner or until the BLM/landowner 

determines that continued efforts are not 

necessary. 

Teton would implement stability and erosion 

control practices for all temporary and permanent 

reclamation in accordance with the SWPPP. 

Reclaimed areas within the project area would be 

considered stable if there are no large rills or 

gullies, no substantial soil movement, no 

headcutting in drainages, no slope instability, no 

subsidence, and no slumping that can be attributed 

to construction, operations, or maintenance. Teton 

would be responsible for annual inspections for 

the following types of problems as long as the 

ROW grant(s) are still active: 

•	 soil movement where the depth of recent 

deposits around obstacles is greater than 

0.5 inch; 

•	 surface litter movements where more than 

25% of surface litter has been transported 

and redeposited against obstacles 

downslope; 

•	 development of rills greater than 3 inches 

deep at intervals of 10 ft or less; 

•	 gully formation at intervals of 200 ft or 

less; and 

•	 channel erosion where more than 25% of 

the channel bed and walls show active 

erosion, gully formation, and/or 

headcutting or bank failure. 

If these features are discovered during reclamation 

inspections and their existence can be attributed to 

construction, O&M, or decommissioning 

operations of the WMWE Project, Teton would, in 

consultation with BLM, implement appropriate 

remedial action until reclamation objectives are 

met. 

Reclaimed areas would also be monitored by 

Teton for as long as the ROW grant(s) are still 

active for invasive nonnative weeds annually in 

late spring. If any noxious weed species are 

discovered on project-related reclamation, Teton 

would, in cooperation with the landowners and 

Sweetwater County officials, implement 

appropriate weed control measures. 

2.5.4 Transportation 

Where possible, the design of access and turbine 

string roads would utilize the flow of the natural 

contours and the cut and fill required for the 

access road would be balanced to minimize the 

amount of materials that would need to be brought 

onto or removed from the site. 

During the life of the project, Teton would be 

responsible for maintenance on all project roads 

including those roads described in the Sweetwater 

County Road Maintenance Agreement as 

approved by County Board of County 

Commissioners. The Sweetwater County Road 

Agreement would outline the procedures and 

responsibilities for use and maintenance of utilized 

county roads. This Agreement would address all 

on and off project site county roads utilized by 

Teton and their contractors including 

transportation planning, construction/alteration, 

dust control, access, drainage, parking, signage, 

traffic control, maintenance, snow removal, road 

use, compliance, phasing, bonding and other road 

related issues. Teton would obtain all required 

approvals from the Wyoming Department of 

Transportation, including possible improvements 

to the intersection of the County Road 4-14 and 

U.S. Highway 191. 

During the life of the project, Teton or its 

subcontractors would not access County Road 
2-50 EA, White Mountain Wind Energy Project 

4-53 through the City of Green River to move 

large equipment or components or resources. 

Teton would post warning signs along the access 

roads, including County Road 53 and 

Fourteenmile Road. Signage would include speed 

limit signs and signs informing the public of 

construction activities, recommending the public 

proceed with caution and watch for large vehicles 

and equipment. The content and location of such 

signs would be coordinated with the Wyoming 

Department of Transportation and Sweetwater 

County officials. The existing access roads 

(County Road 53 and Fourteenmile Road) would 

remain open at all times except when they are 

physically and temporarily blocked by the 

movement of project-related vehicles or 

equipment. Such road closures would be 

coordinated with Sweetwater County officials. 

Vehicle traffic would be confined within the site 

boundary for safety, fire control, and the control of 

invasive nonnative species. Signs on the public 

roads utilized by these trucks would be erected to 

warn the public of the increased construction 

traffic, and all signage would be coordinated 

through the Wyoming Department of 

Transportation and the Sweetwater County Road 

and Bridge Department. In addition, all vehicles 

would be washed down at a location approved by 

the BLM for the control of invasive nonnative 

species prior to entering the site. 

Road maintenance within the WMWE project area 

would be performed by Teton on an as-needed 

basis. Regular snow removal is expected to be 

required during the winter months to maintain 

access to the turbines and substation. Teton would 

also plow openings in the snow berms to allow big 

game species to move off of and away from road 

activities. 

Teton would also obtain all required permits 

associated with the proposed project from 

appropriate federal, state, and local government 

agencies. 

2.5.5 Wildlife 

2.5.5.1 Raptors 

To avoid impacts on the nesting raptors, Teton has 

adopted established seasonal restriction areas in 

accordance with BLM policy (BLM 1997). Teton 

would comply with these buffers during the 

construction and O&M phases of this project. 

Table 2.9 lists the seasonal restrictions and no 

surface occupancy buffers. In addition, all 

electrical systems and components would be 

designed, constructed, operated, and maintained in 

conformance with the National Electrical Safety 

Code and other restrictions, and no surface 

occupancy buffers for various raptor species are 

expected to occur in the project area. Teton would 

not place any wind turbines within the designated 

applicable codes and standards, as well as 

Suggested Practices for Raptor Protection on 

Power Lines: The State of the Art in 2006 (Avian 

Power Line Interaction Committee 2006). Teton 

would not place any wind turbines within 50 m 

(164 ft) of the eastern edge of White Mountain. 

2.5.5.2 Passerine and Other Small Birds 

To minimize potential impacts to passerine and 

other small birds, the removal of natural 

vegetation (grassland and shrub communities) 

would be minimized to the extent possible during 

construction. In addition, the movement of 

personnel and equipment on-site would be limited 

to the extent possible to construction areas to 

avoid inadvertent compaction of vegetation. To 

minimize potential impacts to birds flying at night, 

Teton would utilize flashing lights on any wind 

turbines or met towers that require FAA lighting. 

In order to minimize potential impacts to avian 

species, wind turbines would be setback at least 

50 m (164 ft) from the east edge of White 

Mountain and at least 50 m (164 ft) from 

drainages within the project area. In addition, to 

the extent possible, surface disturbance would be 

minimized during the nesting season to avoid 

taking of nests, eggs, or individuals. 
2-51 

1 

EA, White Mountain Wind Energy Project 

Table 2.9 Season Restrictions for Surface Disturbance Activities.1 

No Surface 

Species Construction Restriction Seasonal Restriction Area Occupancy Buffer 

Golden eagle nest February 1 - July 31 Within 0.5-mi radius from 

active nest 

Within 600 m of active 

nests 

Ferruginous hawk 

nest 

February 1 - July 31 Within 1.0-mi radius from 

active nest 

Within 400 m of active 

nests 

Burrowing owl nest April 1 - September 10 Within 0.5-mi radius from 

active nest 

Within 250 m of active 

nests 

Other raptors February 1 - July 31 Within 0.5-mi radius from 

active nest 

Within 250 m of active 

nests 

BLM RMP for the Rock Spring Field Office (BLM 1997). 

2.5.5.3 Bats 

During construction, to minimize potential impacts 

to bats, wind turbines would be setback at least 

50 m (164 ft) from drainages within the project 

area. To minimize potential impacts to bats during 

the O&M phase of the project, Teton would work 

with the BLM to develop and implement an 

operational protocol to modify the cut-in speeds of 

wind turbines within the WMWE project area. 

These protocols would be implemented during a 

portion of evening and night time hours of 

operations during the peak bat migration season. 

This protocol would be developed based on the 

preliminary results of the Arnett et al. (2009) study 

that documented reduced bat fatalities by changing 

the cut-in speed of wind turbines. In this study, 

the experimental cut-in speeds ranged between 

11.1 mph (5.0 m/s) and 14.5 mph (6.5 m/s) with a 

corresponding nightly reduction in bat fatalities 

from 53 to 87%. The results of on-site postconstruction avian and bat mortalities would be 

used by Teton and the BLM to fine tune the cut-in 

speed protocol. 

2.5.5.4 Pygmy Rabbits 

To mitigate potential impacts to pygmy rabbits, 

the removal of natural vegetation (grassland and 

shrub communities) would be minimized to the 

extent possible during construction. In addition, 

the movement of personnel and equipment on-site 

would be limited to the extent possible to 

construction areas to avoid inadvertent compaction 

of soil. In addition, presence/ absence surveys for 

pygmy rabbits and their associated habitat would 

be conducted prior to vegetation removal and 

construction. If pygmy rabbits are found, Teton 

would work with the BLM to modify turbine 

placement to avoid habitat to the extent possible. 

2.5.5.5 Mule Deer, Pronghorn Antelope, and Elk 

The loss of habitat (i.e., disturbance) would be 

minimized to the extent possible. Indirect effects 

that could cause degradation of remaining habitat 

would be minimized by controlling activities that 

could result in the spread of invasive nonnative 

species, avoiding impacts to areas not associated 

with the project, and revegetating areas with native 

vegetation. 

A small portion (519 acres) of the WMWE project 

area is located in crucial winter/yearlong range for 

elk. Based on the layout for the Proposed Action, 

approximately 80.0 acres of initial disturbance and 

33.9 acres of life-of-project disturbance would 

occur in crucial elk winter/yearlong range located 

on privately owned land. In addition, 

approximately 1,011 acres of the WMWE project 

area occurs in pronghorn antelope habitat the 

WGFD has designated as crucial winter/yearlong 

range. In order to minimize potential impacts to 

elk and pronghorn antelope in these areas, Teton 

would comply with seasonal restrictions and 

would not conduct any project-related construction 
2-52 EA, White Mountain Wind Energy Project 

activities within elk and antelope crucial/yearlong 

range from November 15 to April 30. However, 

Teton may request an exception from the seasonal 

restriction stipulation from the landowner and the 

BLM, and the request would be evaluated on a 

case-by-case basis, and the landowner and BLM 

would inform Teton if the exception would be 

granted. 

Construction and O&M personnel would be 

informed that big game occurs in the project area. 

They are not allowed to haze or harass the 

animals, and they should minimize any direct 

disturbance to the animal whenever possible. Any 

incidents of poaching would be immediately 

reported to the WGFD. 

2.5.5.6 Greater Sage-grouse 

Construction and O&M personnel would be 

informed that greater sage-grouse occur in the 

project area. They are not allowed to haze or 

harass greater sage-grouse, and they should 

minimize any direct disturbance to the greater 

sage-grouse whenever possible. 

2.5.5.7 Cedar Rim Thistle 

To mitigate potential impacts to cedar rim thistle, 

Teton would conduct surveys for cedar rim thistle 

and their associated habitat prior to vegetation 

removal and construction. If any cedar rim thistle 

is found, Teton would work with the BLM to 

modify turbine/road placement to avoid impacts to 

these plants. 

2.5.5.8 Colorado River Endangered Fish Species 

In order to mitigate potential impacts of the project 

on endangered fish species found in the upper 

Colorado River Basin, Teton would provide a 

financial contribution to the Colorado River 

Recovery Program as determined by the USFWS 

for water depletion exceeding 100 acre-ft. 

2.5.5.9 Midget-faded Rattlesnake and Other 

Reptiles and Amphibians 

Teton would conduct surveys in rock outcroppings 

for rattlesnake dens and other reptiles. These 

surveys would be conducted in the spring when 

temperatures are conducive to locate rattlesnakes. 

If den(s) and/or foraging areas are found, Teton 

would work with the BLM and WGFD to 

determine the appropriate mitigation measures 

(e.g., road and turbine placement) to eliminate or 

reduce these impacts. Any observations of 

amphibians would be noted and appropriate 

mitigation determined. 

2.5.5.10 Wildlife Monitoring 

During the construction and decommissioning of 

the project, active raptor nests would be visually 

monitored on a weekly basis to determine which 

nests could potentially be impacted during the 

construction period. Teton would coordinate with 

the BLM Authorized Officer or landowner to 

ensure that potentially impacted nests are being 

monitored and that the seasonal restrictions are 

being enforced or if a waiver is appropriate. 

Presence/absence surveys for mountain plover and 

pygmy rabbits and their habitat would be 

conducted prior to vegetation clearing and 

construction. 

During the construction phase, Teton would 

visually monitor the project area on a weekly 

basis, at a minimum, to ensure that construction 

sites, staging areas, roadways, and associated 

activities potentially impacting habitat are limited 

to areas agreed to prior to construction. 

Irregularities would be reported immediately to 

project management and corrective actions would 

be taken. 

Teton would conduct a 3-year post-construction 

avian and bat mortality study for the project unless 

sufficient evidence determines that continued 

monitoring is unnecessary. This study would 

collect data on the number of avian species 

(including birds and bats) that have been struck by 

wind turbines in the project area. The specific 

protocols to be used in this study would be 

developed in cooperation with the BLM, the 

WGFD, and the USFWS. 

To evaluate spatial distribution and potential 

effects of turbine construction on big game (elk, 
 

EA, White Mountain Wind Energy Project 2-53 

mule deer, pronghorn, and greater sage-grouse), 

pellet count distribution surveys will be 

conducted. Surveys will be conducted 

preconstruction, during construction, and postconstruction. The surveys will consist of the 

following: 

•	 Six survey plots per proposed turbine 

location will be established next to a 

maximum of 35 proposed wind turbines 

(210 plots) that will be located on BLMadministered lands. 

•	 Survey plots will be established at random 

distances from 10 to 80 m (33 to 265 ft) 

from each proposed turbine along a 

transect line. 

•	 For reference (or control) data, six plots 

will also be established along transect 

lines at an equal number of random points 

located in an area of similar topography 

and vegetation as the turbine survey plots 

(a maximum of 210 plots). The reference 

survey plots will be located at least 1 mi 

from the nearest turbine in an area defined 

by the assigned BLM RSFO wildlife 

biologist on BLM-administered lands and 

would be surveyed at the same time as the 

turbine plots are surveyed. 

•	 Each plot will be marked with a 12-inch 

piece of rebar, and the location will be 

recorded with a global positioning system 

unit. 

•	 All pellet groups within a 2-m (7-ft) radius 

of the center of the survey plot will be 

identified by species, counted, and then 

removed from the survey plot area. 

•	 Surveys will be conducted during the 

spring and fall. The spring count surveys 

will document the previous winter’s use, 

and the fall surveys will evaluate the 

previous summer’s use. 

•	 Preconstruction surveys will be conducted 

during the fall of 2009 and the spring of 

2010. 

•	 Construction surveys will be conducted 

during the fall of 2010 and the spring of 

2011. 

•	 Post-construction surveys will be 

conducted in the spring of 2015 and the 

fall of 2015. During the fall of 2014, plots 

will be visited, and all pellet groups will 

be cleared off; no data will be collected. 

Teton would report all incidents of poaching in the 

project area immediately to the WGFD. 

2.5.6 Wild Horses 

Despite the loss of a limited amount of grazing 

habitat and noise, wild horses are expected to 

adjust to the increased traffic during construction, 

as well as the presence of the wind turbines and 

associated structures and facilities. It is possible 

that wild horses could be involved in an accident 

with construction vehicles or harmed by becoming 

trapped in open trenches or excavations. Speed 

limit signs would be posted, and construction and 

O&M personnel would be informed that wild 

horses occur in the project area. They are not 

allowed to haze or harass wild horses, and they 

should minimize any direct disturbance to the wild 

horses whenever possible. Should an accident 

occur, the BLM Authorized Officer would be 

notified immediately. To facilitate wild horse 

roundups and/or surveys, the BLM would 

coordinate with Teton, who would agree to shut 

wind turbines down for a maximum of 4-6 hours 

at any one time for a course of 2 days. 

2.5.7 Livestock 

Teton would coordinate with grazing permittees 

during each phase of development to ensure that 

permittees are aware of construction activities. 

Initial mitigation would be in the form of 

revegetation efforts applied to areas disturbed by 

construction activities. Re-establishment of 

desirable native vegetation is expected to take 

several years; however, Teton expects native plant 

communities to become re-established, and there 

would be minimal long-term impacts to livestock. 

Construction and O&M personnel would be 

informed that they are working in an area of open 

livestock grazing and to drive the posted speed 

limit and to watch for livestock and wildlife that 

may be on the roads. In addition, open trenches or 

excavations that are left unattended overnight 

would be fenced for safety, and existing cattle 

guards would be left in place. If livestock are 

involved in an accident involving Teton vehicles, 

the responsible party would be liable to provide 

appropriate compensation to the livestock owner. 
2-54 EA, White Mountain Wind Energy Project 

If necessary, Teton would place livestock crossing 

signs, where appropriate. 

2.5.8 Control of Invasive Nonnative Species 

The control of invasive nonnative species is 

difficult, and some weeds can enter the project 

area on equipment and vehicles, while others may 

spread from distant areas by spores blowing onto 

the site in the wind. Teton would design and build 

the project so that the least amount of ground 

disturbance occurs, thereby exposing the least 

amount of soil possible. Large construction 

equipment that travels off project roads would be 

cleaned prior to entering the site. Teton would 

work with the BLM, landowners, other county or 

state agencies as appropriate, and the Sweetwater 

County Board of Weed and Pest Control to 

establish a weed control and monitoring program 

for the life of the project. This may entail spot 

spraying with an approved herbicide along 

disturbed areas for invasive nonnative species. 

Teton would also use only certified-weed-free 

reclamation materials. 

2.5.9 Air Quality and Fugitive Dust Control 

During the construction, O&M, and 

decommissioning phases of this project, some 

localized increases in dust levels would be 

unavoidable. To minimize these levels, Teton 

would use water or other dust control measures on 

heavily used project-related roads and other 

construction areas should dust become a problem. 

Teton would coordinate with Sweetwater County 

and Sweetwater County Conservation District 

officials on dust control measures on county roads 

and agency staff or landowners on project roads. 

Traffic speed would also be held to appropriate 

levels. In addition, disturbed areas would 

be revegetated as soon as possible 

following disturbance, and engines would be 

maintained in accordance with manufacturer 

recommendations to minimize emissions. 

2.5.10 Noise 

The largest source of noise during construction 

and decommission phases of the operation 

would be diesel-powered equipment. Therefore, 

all equipment would be operated with the 

manufacturer’s suggested noise control systems 

(e.g., mufflers and noise dampening materials), 

and all construction operations would take place 

during daylight hours. Additional information 

concerning noise during the O&M phase is 

addressed in Section 4.5.1.2 of this EA. 

2.5.11 Water Resource Protection 

Before the construction and decommissioning 

phases of this project, an SWPPP would be 

prepared for the project, and the construction 

contractor would implement the appropriate BMPs 

for each specific situation. The use of appropriate 

BMPs would reduce the amount of sediment being 

produced and would minimize the amount of 

sediment being released into the environment, 

thereby mitigating impacts to water resources. A 

detailed description of the specific BMPs would 

be presented in the SWPPP and would be 

submitted to Sweetwater County and BLM 

officials with the construction permit application. 

A SPCCP is required under federal regulation, and 

Teton would prepare and implement a SPCCP that 

would be used to control the release of fuels, oil, 

or other fluids, and BMPs are included in the 

SWPPP and will not be repeated here. Any spills 

would be reported to the appropriate federal, state, 

and/or county agencies. 

A SWPPP would be prepared for the construction 

and O&M phase of this project, and O&M 

personnel would implement the appropriate BMPs 

for each specific situation. The use of appropriate 

BMPs would reduce the amount of sediment being 

produced and would minimize the amount of 

sediment being released into the environment, 

thereby mitigating impacts to water resources. 

This includes design and installation of culverts, 

rip rap, and catchment basins where appropriate. 

An SPCCP would be required during the 

construction and O&M phases of this project, and 

Teton would have an SPCCP prepared in 

accordance with applicable federal regulations and 

guidelines. The BMPs in the SPCCP would 

control the release of fuels or oil. 
EA, White Mountain Wind Energy Project 2-55 

To minimize impacts to surface water drainages, 

wind turbines would be set back at least 50 m 

(164 ft) from major drainages within the project 

area. 

2.5.12 Fire Prevention Plan 

The project HSE Plan would provide a list of 

emergency contacts and protocols in case of a 

wildfire. During the construction, O&M, and 

decommissioning phases of this project, fire 

extinguishers, 5-gallon backpack hand water 

pumps, and fire-fighting hand tools such as 

shovels, Pulaskis, or McLeods would be located in 

the base of each wind turbine tower, in each 

project construction vehicle, in the substation 

control building, and in the O&M building. 

Personnel performing “hot work” such as welding 

would be required to have the same fire-fighting 

equipment listed above. The water tank truck used 

for dust abatement would be left full of water and 

fuel at a location designated by the Teton project 

manager so that it is in a condition where it could 

be readily used in case of a fire. Smoking and offroad parking would be restricted to designated 

areas. Signs would be posted in strategic locations 

on-site to remind personnel of the emergency 

response procedures, liabilities, and telephone 

contact numbers for fire emergencies. 

Mitigation would depend on specific fire 

conditions and other special circumstances 

prevailing in the project area. If necessary, sitespecific actions could include, but are not be 

limited to, actions such as the following: 

•	 establishment of spotter positions on key 

locations within the project area; 

•	 prepositioning fire suppression 

capabilities (e.g., contracted engine crews) 

under high or extreme fire conditions; 

•	 restriction of certain on-site high risk 

activities (e.g., welding) or suspension of 

all construction activities under high or 

extreme fire conditions; 

•	 avoidance of sensitive sites and/or those 

having high fire potential when extreme 

fire conditions occur; and 

•	 travel restrictions for contractor personnel 

when fire dangers are high. 

Determinations of need for additional protection 

measures would be made by the Teton project 

manager in cooperation with the BLM Authorized 

Officer. 

2.5.13 Cultural Resources 

Prior to ground-disturbing activities, Teton would 

contract to have a qualified archaeological firm 

conduct a Class III cultural resource inventory of 

areas to be disturbed or additional ROW areas 

located on BLM-administered, privately owned, 

and state-owned land that had not been previously 

inventoried. If a cultural resource site considered 

eligible for or already listed on the National 

Register of Historic Places (NRHP) is identified, 

Teton would utilize avoidance as the preferred 

method of mitigating potential adverse effects to 

the property. 

Teton would mitigate adverse effects to 

cultural/historical properties that cannot be 

avoided by the preparation and implementation of 

a BLM/State Historic Preservation Office 

(SHPO)-approved Data Recovery Plan and/or 

Programmatic Agreement (PA) before authorizing 

surface disturbing activities. Teton, the BLM, 

SHPO, and other interested parties would 

complete the Section 106 process and appropriate 

mitigation measures would be implemented as part 

of the PA. 

Construction and O&M personnel would be 

instructed that they are not allowed to search for 

cultural resources (i.e., arrowhead hunting) while 

working on this project. If any cultural resources 

are discovered on BLM-administered, privately 

owned, or state-owned lands during construction, 

O&M, or decommissioning operations, all 

construction activities within the immediate 

vicinity would be suspended, and the 

BLM Authorized Officer would be immediately 

notified. Work in the area would not resume until 

a Notice to Proceed is issued by the BLM. 

2.5.14 Paleontology 

If required by the BLM, an on-the-ground survey 

of areas to be impacted would be performed by a 

qualified paleontologist holding a BLM 
2-56 EA, White Mountain Wind Energy Project 

Paleontological Resources Use Permit prior to 

approval of any surface disturbing activities. The 

need for an on-the-ground survey could be waived 

by the BLM if it is determined that the proposed 

activities would not impact important geologic 

outcrop areas, the area has previously been 

surveyed for paleontological resources, or the area 

has been previously disturbed. If a survey is 

conducted and significant fossils are discovered 

during the survey, BLM may require the 

proponent to alter the construction plan to avoid 

disturbing the locality or mitigate the site by either 

collecting a sample of the fossil material or fully 

excavating the locality. The BLM may require, 

based on the paleontologist’s recommendation, 

that construction activities be monitored during 

surface disturbances for the presence of previously 

undocumented scientifically important fossils. 

If paleontological resources are discovered during 

construction operations, the find would be 

reported to the BLM Authorized Officer 

immediately and construction operations would be 

suspended within 250 ft of said find. An 

evaluation of the paleontological discovery would 

be made by a BLM-approved professional 

paleontologist within 5 working days, weather 

permitting, to determine the appropriate action(s) 

to prevent the potential loss of any significant 

paleontological value. Operations within 250 ft of 

such discovery would not be resumed until written 

authorization to proceed is issued by the BLM 

Authorized Officer. Teton would bear the cost of 

any required paleontological appraisals, surface 

collection of fossils, or salvage of any large 

conspicuous fossils or important scientific interest 

discovered during the operations. 

Teton would inform all field personnel not to 

search for, scavenge, or remove any 

paleontological resources found while working in 

the WMWE project area. 

2.5.15 Visual Resources 

To minimize visual impacts, Teton would adopt 

the following visual mitigation measures: 

• The design of the WMWE Project would 

provide visual order and unity among 

clusters of turbines (visual units) to avoid 

visual disruptions and perceived “disorder, 

disarray, or clutter.” 

• To the extent possible given the terrain of 

a site, Teton would create clusters or 

groupings of wind turbines when placed in 

large numbers, avoid a cluttering effect by 

separating otherwise overly long lines of 

turbines or large arrays, and insert breaks 

or open zones to create distinct visual 

units or groups of turbines. 

• Teton would create visual uniformity in 

the shape, color, and size of rotor blades, 

nacelles, and towers. 

• Teton would use tubular towers. Tubular 

towers present a simpler profile and less 

complex surface characteristics and 

reflective/shading properties. 

• Components of the wind turbines would 

be in proper proportion to one another. 

Nacelles and towers would be planned to 

form an aesthetic unit and would be 

combined with particular sizes and shapes 

in mind to achieve an aesthetic balance 

between the rotor, nacelle, and tower. 

• Color selection for turbines would be 

applied uniformly to tower, nacelle, and 

rotor in accordance with FAA 

requirements. 

• The wind turbines would use nonreflective 

coatings to reduce reflection and glare. 

• The O&M building would be painted 

before or immediately after installation 

with a green shale color. 

• Uncoated galvanized metallic surfaces 

would be avoided whenever possible 

because they would create a stronger 

visual contrast, particularly as they oxidize 

and darken. 

• Commercial messages on turbines and 

towers would be prohibited. 

• The site design would be integrated with 

the existing landscape by using as many of 

the existing roads as possible. 

• The operator would bury power collection 

cables or lines on the site in a manner that 

minimizes additional surface disturbance. 

• Site design would minimize security 

lights, and any security lights located at 

the O&M building would be turned off 

except when activated by motion 

detectors. All lighting fixtures shall be 

down focused and full cut-in design. 
EA, White Mountain Wind Energy Project 2-57 

Minimum wattage should be selected for 2.5.16 Bonding 

the luminaries. 

• Teton would minimize ground disturbance Teton would provide appropriate reclamation 

and control erosion by avoiding steep bonding for each project component (e.g. roads, 

slopes and by minimizing the amount of wind turbine, substation, O&M building, etc). The 

construction and ground clearing needed amount of the bond on BLM-administered public 

for roads, staging areas, and turbine pads. lands would be determined in accordance with 

• Dust suppression techniques would be BLM IM 2009-043 or subsequent instruction 

employed where and when required to memoranda. Bonding on State of Wyoming lands 

minimize impacts of vehicular and would be determined in accordance with an 

pedestrian traffic, construction, and wind approved wind energy lease agreement issued by 

on exposed surface soils. the Wyoming Office of State Lands & Investment. 

• Disturbed areas would be regraded as soon Bonding on private lands would be determined by 

as possible to their original contour and the land owner. Sweetwater County wind farm 

revegetated immediately after, or as zoning regulations also require reclamation 

contemporaneously as possible with bonding for wind energy projects; however, Teton 

construction. Teton would be prompt to would provide acceptable evidence demonstrating 

limit erosion and to accelerate restoring that an adequate reclamation bond has been 

the preconstruction color and texture of approved or accepted by the specific landowners. 

the landscape. Therefore, separate bonding for Sweetwater 

• Teton would maintain the WMWE Project County would not be required. The amount of 

during operation as inoperative or each bond would include the cost of removal and 

incomplete turbines cause the surface restoration obligations. 

misperception to viewers that “wind 

power does not work” or that it is 

unreliable. Inoperative turbines would be 

2.6 ALTERNATIVE A - DEVELOPMENT 

ONLY ON PRIVATE LANDS 

completely repaired, replaced, or 

removed. Except during specific Under Alternative A, up to 170 wind turbines 

maintenance operations, nacelle covers could be constructed on private lands or State of 

and rotor nose cones would always be in Wyoming lands. No wind turbines would be 

place and undamaged. constructed on public lands administered by the 

• The WMWE Project would evidence BLM (Figure 2.25). The BLM would authorize as 

environmental care, which would also needed, ROWs for access roads, and collector 

reinforce the expectation and impression lines that would have to cross BLM-administered 

of good management for benign or clean land to allow the project to be feasible. Details of 

power. Nacelles and towers would also be how this alternative would be implemented during 

kept clean to remove any spilled or the construction, O&M, and decommissioning 

leaking fluids and the dirt and dust that phases would be identical to those described in the 

would accumulate. Proposed Action. Table 2.10 presents the acres of 

• Facilities would be kept clean of debris, potential disturbance associated with 

“fugitive” trash or waste, and graffiti. Alternative A. 

• Scrap heaps and material dumps would be 

prohibited and prevented. Applicant proposed design features outlined in 

• The material stored at the O&M building Section 2.5 would apply with the exception of 

would be kept to an absolute minimum. required turbine bonding on public land since no 

Any surplus, broken, or disused materials turbines would be constructed on public lands. 

and equipment would be maintained in an Other design features could be modified in order 

orderly manner. to recognize that construction of turbines would 

• Teton would prepare a decommissioning not occur on public land or to meet the needs of 

plan, and it would include the removal of the landowner. 

all turbines and ancillary structures and 

reclamation and revegetation of the site. 

EA, White Mountain Wind Energy Project 2-59 

Table 2.10 Estimated Acres of Surface Disturbance Within the WMWE Project Area Under 

Alternative A. 

Disturbance Type Initial Disturbance (acres) Life-of-project Disturbance (acres) 

Corridor access roads1

 244.1 117.6 

Staging area and O&M building 2.0 0.8 

Substation and transmission line 11.0 0.3 

Turbine pads2

 124.9 25.0 

Collection line trenches3

 273.2 0.0 

Concrete batch plant 2.0 0.0 

Total 657.2 143.7 

1 Initial disturbance: 37.3 mi x 54 ft = 244.1 acres; life-of-project disturbance: 37.3 mi x 26 ft = 117.6 acres. 2 Initial disturbance: 160 ft x 200 ft x 170 turbines = 124.9 acres; life-of-project disturbance: 80 ft x 80 ft x 

170 turbines = 25.0 acres. 3 Initial disturbance: 49.0 mi x 46 ft = 273.2 acres; life-of-project disturbance: 0.0 acres, all temporary 

construction-related disturbance would be reclaimed immediately. 

2.7 NO ACTION ALTERNATIVE 

Under the No Action Alternative, the proposed

wind energy facility would not be authorized or

approved. No ground would be disturbed, and no

impacts to the existing physical or biological

environment would take place beyond those that 

already exist. 

The analysis of a No Action Alternative provides a 

benchmark, enabling decision-makers to compare 

the magnitude of environmental effects of each

action alternative. Under the No Action 

Alternative, the BLM would deny the request for a

ROW grant for the proposed wind energy facility 

or components (e.g., buried cables, access roads) 

on public lands, thereby preventing most, if not 

all, development on the adjacent private and state

lands. 

2.8 ALTERNATIVES CONSIDERED BUT 

ELIMINATED FROM DETAILED 

STUDY 

2.8.1 Alternative Wind Energy Facility Site 

Lands outside of the proposed project area were 

considered for development of the wind energy 

facility. However, the other sites were eliminated 

because wind resources were not as favorable as 

they were within the existing WMWE project area 

or public lands already have testing and 

monitoring ROWs held by other entities that 

preclude consideration by Teton. Therefore, this 

alternative was eliminated from detailed 

consideration in this EA. 

2.8.2 Place More Wind Turbines Within the 

WMWE Project Area 

Teton has considered the placement of more wind 

turbines within the WMWE project area; however, 

based on the size of wind turbines to be used for 

this project, the spacing required for the wind 

turbines, topography, and the available wind 

resources, Teton has designed the maximum 

number of wind turbines within the project area. 

Therefore, Teton is not interested in placing any 

additional wind turbines within the project area, 

and this alternative was eliminated from further 

consideration in this EA. 
EA, White Mountain Wind Energy Project 3-1 

3.0 AFFECTED ENVIRONMENT 

The proposed WMWE project area is located in 

southwestern Sweetwater County approximately 

3.0 mi northwest of the town of Rock Springs, 

Wyoming (refer to Figure 1.1). The project area is 

located on the eastern edge of White Mountain, a 

prominent local mesa that rises approximately 

1,000 ft above the elevation of Rock Springs. 

County Road 53 bisects the project area from 

north to south. Vegetation consists primarily of 

shortgrass and sagebrush-scrub habitat and is 

uniform throughout. The escarpment of the east 

side of White Mountain (outside the project area) 

is steep with eroded gullies and dense pockets of 

buckbrush and juniper. 

This chapter describes the existing conditions of 

the physical, biological, cultural, and 

socioeconomic resources. The resources 

addressed in this chapter were identified during 

the internal and public scoping processes as 

having the potential to be affected by projectrelated activities. 

3.1 AIR QUALITY AND CLIMATE 

3.1.1 Air Quality 

The impact assessment areas (IAA) for air quality 

is the project boundary plus a 31-mi buffer. A 

total of 62,726 acres (2.50%) of the 2,505,739­

acre IAA has been disturbed, primarily by roads 

and cities. 

The WDEQ/AQD has been authorized by the EPA 

to enforce national ambient air quality standards 

set forth in the Clean Air Act, as amended (42 

U.S.C. §7401 et seq.) through Article 2 of the 

Wyoming Environmental Quality Act (Wyoming 

Statute [W.S.] 35-11-201 et seq.) and the 

Wyoming State Implementation Plan. The 

Wyoming and National Ambient Air Quality 

Standards (WAAQS and NAAQS) set upper limits 

for specific air pollutant concentrations at all 

locations where the public has access, expressed in 

micrograms per cubic meter (μg/m3

). Relevant 

WAAQS and NAAQS are presented in Table 3.1. 

Relevant WAAQS and NAAQS are presented in 

Table 3.1. Wyoming Air Quality Standards and 

Regulations (WAQS&R) define ambient air as 

“that portion of the atmosphere, external to 

buildings, to which the general public has access” 

(WDEQ/AQD 2000a). 

No site-specific air monitoring efforts have been 

conducted in the project area, and the proposed 

facility area is located in a rural setting with 

minimal industrial sources or vehicular traffic 

emission contributions to the airshed. 

While there is no site-specific air quality 

monitoring within the project area, air quality 

monitoring has been conducted in Rock Springs 

(approximately 3.0 mi southeast of the project 

area). For 2008, the annual mean for PM2.5 was 

7.18 μg/m3

 and the annual mean for PM10 was 

25μg/m3

. 

3.1.2 Climate 

The IAA is located in the ecoregion described as 

the Intermountain semi-desert province (U.S. 

Forest Service 2009). This province covers the 

plains and tablelands of the Columbia-Snake River 

Plateaus and Wyoming Basin. The higher overall 

elevation of the Wyoming Basin gives it slightly 

lower average temperatures and precipitation than 

on others portions of the province. Winters in 

southwest Wyoming are cold, and summers are 

short and cool. The climate of the Wyoming 

Basin is semiarid and cool. The annual mean 

temperature for Rock Springs is 42.6F (1971­

2000) and the average annual precipitation in 

Rock Spring is 9.42 inches (1971-2000) (Curtis 

and Grimes 2004). Precipitation is fairly evenly 

distributed throughout the year, ranging from an 

average monthly low of 0.52 inches in February to 

an average monthly high of 1.36 inches in May 

(Curtis and Grimes 2004) with an average growing 

season of approximately 112 days (Curtis and 

Grimes 2004). Winds average approximately 12.1 

mph and are primarily from the west-southwest 

(Martner 1986). 
3-2 EA, White Mountain Wind Energy Project 

Table 3.1 Selected National, Colorado, and Wyoming Air Quality Standards (μg/m3

). 

Pollutant/Averaging Time NAAQS1 CAAQS2 WAAQS3 

PSD Class I 

Increment4 

PSD Class II 

Increment4 

Carbon Monoxide (CO) 

1-hour5 

8-hour5

 40,000 

 10,000 

40,000 

10,000 

40,000 

10,000 

-­ 6 

-­

-­ 6 

-­

Nitrogen Dioxide (NO2) 

Annual7

 100 100 100 2.5 25 

Ozone 

1-hour5

 -­ 8 235 -­ 9 -­ 6 -­ 6 

8-hour10 157 157 157 -- --

Particulate Matter at Less than 

10 Microns (PM10) 

24-hour5

 150 150 150 8 30 

Annual7

 -­ 8 50 50 4 17 

Particulate Matter at Less than 

2.5 Microns (PM2.5) 

24-hour11 35 35 35 -­ 6 -­ 6 

Annual7 15 15 15 -- --

Sulfur Dioxide (SO2) 

3-hour5 

24-hour5

 1,30012

 365 

 700 

365 

1,300 

260 

25 

5 

512 

91 

Annual4 80 60 60 2 20 

1 NAAQS = National Ambient Air Quality Standards (adapted from 40 CFR 50.5-50.12). Primary standard 

unless otherwise noted. National Primary Standards establish the level of air quality necessary to protect public 

health from any known or anticipated effects of a pollutant, allowing a margin of safety to protect sensitive 

members of the population. 2 CAAQS = Colorado Ambient Air Quality Standards. 3 WAAQS = Wyoming Ambient Air Quality Standard. 4 The prevention of significant deterioration (PSD) demonstrations serve information purposes only and do not 

constitute a regulatory PSD increment consumption analysis. 5 No more than one exceedance per year. 6 No PSD increments have been established for this pollutant. 7

 Annual arithmetic mean. 

8 The NAAQS for this averaging time for this pollutant has been revoked by EPA. 9 There is no 1-hour WAAQS established for ozone. 10 Average of annual fourth-highest daily maximum 8-hour average. 11 An area is in compliance with the standard if the 98th percentile of 24-hour PM2.5 concentrations in a year, 

averaged over 3 years, is less than or equal to the level of the standard. 12 Secondary standard. National Secondary Standards establish the level of air quality to protect the public 

welfare by preventing injury to agricultural crops and livestock deterioration of materials and property and 

adverse impacts to the environment. 
EA, White Mountain Wind Energy Project 3-3 

3.1.3 Global Climate Change 

Ongoing scientific research has identified the 

potential impacts of “greenhouse gas” (GHG) 

emissions (including carbon dioxide, CO2; 

methane; nitrous oxide; water vapor; and several 

trace gasses) on global climate. Through complex 

interactions on a regional and global scale, these 

GHG emissions are thought to cause a net 

warming effect of the atmosphere (making surface 

temperatures suitable for life on earth), primarily 

by decreasing the amount of heat energy radiated 

by the earth back into space. Although GHG 

levels have varied for millennia (along with 

corresponding variations in climatic conditions), 

recent industrialization and burning of fossil 

carbon sources are thought to have caused CO2 

concentrations to increase dramatically, and likely 

to contribute to overall climatic changes, typically 

referred to as global warming. Increasing CO2 

concentrations also lead to preferential fertilization 

and growth of specific plant species. 

The assessment of GHG emissions and climate 

change is in its formative phase; therefore, it is not 

yet possible to know with confidence the net 

impact to global climate. However, the 

Intergovernmental Panel on Climate Change 

(2007) recently concluded that “warming of the 

climate system is unequivocal” and “most of the 

observed increase in globally average 

temperatures since the mid-20th century is very 

likely due to the observed increase in 

anthropogenic [man-made] greenhouse gas 

concentrations.” 

The lack of scientific tools designed to predict 

climate change on regional or local scales limits 

the ability to quantify potential future impacts. 

However, potential impacts to air quality due to 

climate change are likely to be varied. For 

example, if global climate change results in a 

warmer and drier climate, increased particulate 

matter impacts could occur due to increased 

windblown dust from drier and less stable soils. 

Cool season plant species’ spatial ranges are 

predicted to move north and to higher elevations, 

and extinction of endemic threatened/endangered 

plants may be accelerated. This could be due to 

loss of habitat, or due to competition from other 

species whose ranges may shift northward, the 

population of some animal species may be 

reduced. Less snow at lower elevations could 

likely impact the timing and quantity of snowmelt, 

which, in turn, could impact aquatic species. 

3.2 CULTURAL RESOURCES (INCLUDING 

NATIVE AMERICAN CONCERNS) 

The IAA for cultural resources is the 

project boundary plus a 20-mi zone. A total of 

38,289 acres (3.26%) of the 1,175,515-acre IAA 

has been disturbed, primarily by cities. 

3.2.1 Cultural Resources 

Cultural resources are the nonrenewable physical 

remains of past human activity and are protected 

under the Antiquities Act (1906), Section 106 of 

the National Historic Preservation Act (1966, as 

amended) (NHPA), the Archaeological Resources 

Protection Act (1979, as amended), the Native 

American Graves Protection and Repatriation Act 

(1990), and other statutes. The evaluation of a 

cultural resource’s significance is based on criteria 

set forth in 36 CFR 60.4. 

The quality of significance in American history, 

architecture, archaeology, engineering, and culture 

is present in districts, sites, buildings, structures, 

and objects that possess integrity of location, 

design, setting, materials, workmanship, feeling, 

and association, and: 

A) That are associated with events that have 

made a significant contribution to the 

broad patterns of our history; or 

B) That are associated with the lives of 

persons significant in our past; or 

C) That embody the distinctive characteristics 

of a type, period, or method of 

construction, or that represent the work of 

a master, or that possess high artistic 

values, or that represent a significant and 

distinguishable entity whose components 

may lack individual distinction; or 

D) That has yielded or may be likely to yield 

information important in prehistory or 

history. 
3-4 EA, White Mountain Wind Energy Project 

A cultural resource may be eligible for inclusion in 

the NRHP if it meets one of the four criteria 

outlined above and retains sufficient integrity to 

convey its significance. 

Archaeological investigations in the Green River 

Basin indicate that human activity has occurred 

across the landscape over the past 12,000 years, 

beginning during the Paleoindian period and 

continuing to the present. Throughout the 

prehistoric past, mobile hunters and gatherers 

traversed the area and exploited a wide variety of 

natural resources (Frison 1991). Historically, this 

portion of the Green River Basin was utilized as a 

corridor for early transportation routes, including 

emigrant trails, regional stage/freight roads, 

railroads, and communication networks. Historic 

settlement of the area occurred in association with 

these routes and was primarily fostered by natural 

resource extraction and ranching. 

The area of potential effect (APE) for cultural 

resources consists of the block area encompassing 

the proposed project area to address direct effects 

plus a 20-mi zone around the project area to 

address visual effects. 

3.2.1.1 Cultural Resources Within the APE for 

Direct Effects 

A file search was conducted at the SHPO, Cultural 

Records Office, on February 9, 2009 (Wyoming 

SHPO 2009). The database review encompassed 

all the sections within the proposed project area, 

including Sections 6, 7, 18, and 19, T19N, 

R105W; Sections 1, 2, 11-13, 23-26, 35, and 36, 

T19N, R106W; Sections 19, 30, and 31, T20N, 

R105W; Sections 3, 11, 13, 14, 23-25, 35, and 36, 

T20N, R106W; and Section 31, T21N, R106W. 

According to the review, 21 projects have been 

completed within and adjacent to the current 

project area, and 19 sites have been discovered as 

a result. 

Of the 21 projects, 12 were linear inventories for 

five seismic lines, five pipelines, one access road, 

and one powerline; five were block inventories 

completed for three miscellaneous projects, one 

range improvement project, and one well pad; and 

four were block/linear inventories conducted for 

two well/access road projects, one cell tower/ 

power line/access road project, and one 

miscellaneous project. Of the total 21 projects, 

only two were conducted prior to 1980 and do not 

reflect current standards for archaeological 

inventories. 

In addition to the 21 projects identified during the 

review, a Class III inventory of approximately 

2,650 acres of the total 13,165-acre WMWE 

project area was conducted in October and 

November 2008. The inventoried area consisted 

of 11 BLM-managed parcels (development ROW), 

representing approximately 20% of the total 

project area, and included some areas that were 

previously inventoried during the aforementioned 

projects. On March 10 and June 15, 2009, the 

BLM sent the reports (Fleming et al. 2009a and 

2009b) to the SHPO for review and concurrence. 

A SHPO concurrence letter dated July 14, 2009, 

was received by the BLM, and the project was 

recently accessioned into the SHPO database. 

Of the 19 sites, 15 were recorded during the 

21 previous projects identified in the database, and 

four were recorded during the recent Class III 

inventory. The 19 sites consist of 15 prehistoric 

sites, three historic sites, and one multicomponent 

site. The 15 prehistoric sites consist of 10 lithic 

scatters and five open camps; the three historic 

sites consist of one foundation, one cairn, and one 

debris scatter; and the one multicomponent site is 

composed of a prehistoric open camp and historic 

debris scatter. Of the 19 sites, two are 

recommended as eligible for listing on the NRHP, 

seven are unevaluated, and 10 are recommended 

as not eligible for listing on the NRHP. Of the two 

NRHP-eligible sites, one is located within the 

proposed project area, while the other is located 

more than 0.5 mi west of the proposed project 

area. 

The identification and evaluation of potential rural 

historic and traditional cultural landscapes within 

the APE for direct effects is ongoing. 

Prehistoric Site Types 

The 15 prehistoric sites and the one prehistoric 

component from the multicomponent site located 
EA, White Mountain Wind Energy Project 3-5 

in the proposed project area can be grouped into 

two categories: open camp/habitation sites and 

lithic scatters/knapping stations. Five sites and the 

prehistoric component from the multicomponent 

site are classified as open camp habitation sites 

based on the presence of hearths, heat-altered 

rock, lithic debris, and diverse artifact assemblages 

(tools, milling implements, etc.). The prehistoric 

component from the multicomponent site is 

recommended as eligible for listing on the NRHP 

based on the potential for buried cultural deposits. 

The 10 prehistoric sites classified as lithic 

scatters/knapping stations are characterized by the 

presence of debris from the modification/reduction 

of stone and are generally associated with no other 

artifact types or features. One lithic scatter is 

recommended as NRHP-eligible based on the 

potential for buried cultural deposits. Based on 

existing regional data and the project area 

topography, additional prehistoric site types within 

the proposed project area may include rock 

alignments and cairns. These sites could possess 

traditional cultural importance for Native 

Americans and, following consultation with 

Native American Tribes, could potentially be 

classified as Traditional Cultural Properties 

(TCPs). 

Historic Site Types 

A total of three historic sites and one historic 

component from the multicomponent site have 

been recorded within the proposed project area. 

The sites consist of one foundation, one cairn, and 

one debris scatter, and the historic component 

from the multicomponent site is a debris scatter. 

The foundation has not been formally recorded 

and is currently unevaluated with regard to the 

NRHP. The two debris scatters are likely 

associated with historic stock-herding activities in 

the area, and both are not eligible for the NRHP. 

3.2.1.2 Cultural Resources Within the APE for 

Visual Effects 

In order to assess potential visual effects from the 

proposed project, a viewshed analysis was 

conducted using GIS software to delineate areas 

within the 20-mi visual APE from which the 

proposed project would be visible. Locations of 

previously recorded sites within the visual APE 

were obtained from the SHPO, Cultural Records 

Office, and merged with the results of the 

viewshed analysis. Any sites within areas from 

which the proposed project would not be visible 

due to intervening topography were eliminated 

from the visual effects analysis. A summary of the 

163 identified prehistoric and historic sites for 

visual effects analysis is provided below. 

Additionally, the identification and evaluation of 

potential rural historic landscapes and traditional 

cultural properties within the APE for visual 

effects is ongoing. 

Prehistoric Sites 

The BLM, in consultation with Native American 

tribes, determined that sites for visual effects 

analysis would be identified based on site type 

rather than NRHP eligibility. The sites consist of 

those that contain sensitive features or remains 

that likely possess traditional cultural importance 

to modern Native Americans. Examples of such 

prehistoric sites include human burials, rock 

alignments, petroglyphs, rock cairns, stone circles, 

and modern-day Native American use for resource 

extraction, or religious sites. A total of 

35 prehistoric sites were identified for visual 

effects analysis in areas within the visual APE 

where the proposed project would be visible. 

Historic Sites 

A total of 128 historic sites were identified for 

visual effects analysis in areas within the visual 

APE where the proposed project would be visible. 

These sites were identified based on NRHP 

eligibility status and consist of 87 eligible or listed 

sites and 41 unevaluatued sites. All historic sites 

that are not eligible were excluded from visual 

effects analysis as were sites that are eligible only 

under Criterion D in accordance with Appendix C 

of the State Protocol (BLM and SHPO 2006). 

3.2.2 Native American Concerns 

In accordance with the American Indian Religious 

Freedom Act (1979), the Native American Graves 

Protection and Repatriation Act, the NHPA, BLM 

Manual 8160-1 Handbook, and other statutes and 
3-6 EA, White Mountain Wind Energy Project 

guidelines, Native American tribes were consulted 

during the preparation of this EA. The tribes 

retain all rights not explicitly ceded in the treaties 

transferring ownership to the federal government. 

The Northern Arapaho, Northern Ute, Eastern 

Shoshone, and Shoshone-Bannock tribes were sent 

letters requesting their comments concerning any 

religious or cultural areas within or near the 

WMWE project area. The scoping request for 

information regarding important cultural resources 

does not eliminate the need to consult with the 

tribes regarding claims made during the 

development stage. Consultation with each of the 

four tribes is ongoing. A summary of the activities 

conducted as part of the Native American 

consultation process through January 27, 2010, are 

provided in Appendix B. 

Several known sensitive sites exist in the 

surrounding area, including Boars Tusk, the White 

Mountain Petroglyph Site, the Cedar Canyon 

Petroglyph Site, and Pilot Butte. These sites have 

the potential to be formally designated as TCPs by 

the federal government after implementing and 

completing formal Native American consultation. 

Furthermore, the identification and evaluation of a 

potential sacred landscape within the APE for 

visual and direct effects is ongoing. 

3.3 GEOLOGY AND PALEONTOLOGY 

The IAA for paleontological resources is the 

WMWE project area. A total of 420 acres 

(3.19%) of the 13,165-acre IAA has been 

disturbed, primarily by existing roads. 

The WMWE project area is located on the western 

flank of the Rock Springs Uplift and the Green 

River Formation outcrops in the project area. The 

Green River Formation was formed during the 

Eocene Age, approximately 54.8 to 33.7 million 

years ago (Roehler 1992, 1993), and represents the 

deposits of an ancient lake system. The Green 

River Formation complexly intertongue is the 

result of expansions and contractions of the lake 

system (Roehler 1991). Paleontological resources 

in southwest Wyoming span the time from the late 

Cretaceous to early Tertiary and include remains 

of dinosaurs, mammals, turtles, crocodiles, and 

other reptiles, fish, snails, and plants. 

The Green River Formation has a combined total 

thickness of 2,763 ft, measured in the Green River 

Basin (Roehler 1993), and the Green River 

Formation is an important sequence of ancient 

lake deposits occurring in three former lake areas: 

the Fossil Basin (ancient Fossil Lake), the Greater 

Green River Basin (ancient Lake Gosiute), and the 

combined Uinta-Piceance Creek Basins (ancient 

Lake Uinta). It is a famous source of fossils, 

especially in the Fossil Basin but also in all other 

areas, and has produced significant vertebrate, 

invertebrate, and plant fossil materials. In the 

WMWE project area, the Green River Formation 

is divided (from the bottom upwards) into the 

Wilkins Peak Member and the Laney Shale 

Member (Roehler 1992). 

The Wilkins Peak Member of the Green River 

Formation is found south of Rock Springs. It, like 

the Cathedral Bluffs Tongue, has the WasatchianBridgerian boundary within it, and much of the 

Wilkins Peak Member is evaporitic in nature and 

was deposited during times when lake levels were 

low and minerals became concentrated. It 

contains highly valuable trona deposits that are 

actively being mined west of Rock Springs. Much 

of the Wilkins Peak Member in the area near Rock 

Springs and White Mountain contains many 

radioactive beds that are both uraniferous and 

phosphatic, and it forms much of the eastern 

slopes of White Mountain (Love 1995). The 

Wilkins Peak Member characteristically weathers 

in a white color and presumably gave White 

Mountain its name. The Wilkins Peak Member is 

located along the east edge of the WMWE project 

area (Figure 3.1). 

The Laney Shale Member of the Green River 

Formation consists of oil shale and resistant 

sandstone lentils at or near the base of the unit and 

an overlying unit of shale, mudstone, and 

limestone (Roehler 1993). South of Green River, 

oil shales are common near the base of the Laney 

Member (Culbertson 1962). The massive 

sandstone lenses in this lower unit appear to be 

restricted to the west-central part of the Greater 

Green River Basin, occurring mainly on 

White Mountain and for few miles to the west and 

southwest of it. The upper unit of the Laney Shale 

is much more widespread and occurs from the 

3-8 EA, White Mountain Wind Energy Project 

west side of the Flaming Gorge Reservoir 

northwards into Sublette County and eastwards 

into the Washakie Basin. This unit is locally 

fossiliferous, with numerous localities in the 

Washakie Basin (Uinta Paleontological 

Associates, Inc. 2009). The Laney Shale Member 

makes up the majority of bedrock formation found 

within the WMWE project area (refer to 

Figure 3.1). 

In order to assess the importance of various 

geological formations and the related 

paleontological resources associated with these 

formations, the BLM in Wyoming has adopted a 

classification system called the Probable Fossil 

Yield Classification (PFYC) system that provides 

broad probabilities for the occurrence of 

paleontological resources. The PFYC system is 

composed of five classes with Class 1 having the 

lowest probability of fossils to Class 5 having the 

highest probability of fossils. Class 5 areas are 

highly fossiliferous geologic units that regularly 

and predictably produce vertebrate fossils and/or 

scientifically significant nonvertebrate fossils. 

Based on the PFYC system, the BLM has 

designated the Green River Formation (including 

the Wilkins Peak Member and Laney Shale 

Member) as Class 5 (Table 3.2). Despite this 

classification, no fossil localities are known to 

exist within the WMWE project area (Uinta 

Paleontological Associates, Inc. 2009). 

However, several important fossil localities are 

known to occur in the general area. Even though 

there are no known fossil localities within the 

project area, the presence of rock units that have 

yielded important fossils elsewhere indicate that 

the probability of construction activities impacting 

important fossils may be high. 

3.4 LAND USE 

Land holdings within the project area are a 

checkerboard land pattern, with every other 

section alternating between public and private 

ownership. The checkerboard pattern is a result of 

land grants given to the railroad companies to 

develop transportation corridors in the west. The 

public lands are administered by the BLM RSFO. 

The RSGA has the grazing lease and is currently 

in control of a majority of the private lands within 

the project area. 

3.4.1 Grazing 

The IAA for grazing is the Rock Springs grazing 

allotment (Figure 3.2) located west of U.S. 

Highway 191 and north off Interstate 80 (I-80). A 

total of 9,734 acres (2.33%) of the 418,506-acre 

(20.31% of the allotment boundary) IAA has been 

disturbed primarily by major industrial facilities. 

Livestock grazing on BLM-administered lands is 

authorized under the Taylor Grazing Act of 1934. 

The proposed project would be located within the 

Rock Springs grazing allotment (WY13018), 

which encompasses approximately 2,061,062 

acres (refer to Figure 3.2). 

The Rock Springs Allotment consists primarily of 

checkerboard land. Sections alternate from federal 

to private land, with approximately half being 

private land owned or leased by RSGA. There are 

a few others who own land within this allotment 

and are issued BLM permits. These are called “inholders” because their land is found within RSGA 

holdings. Ninety-two percent of use occurs from 

December 1 to May 15 for cattle and sheep. 

3.4.2 Recreation 

No developed recreational sites or facilities exist 

within the WMWE project area; however, the 

BLM has established a scenic drive and wild horse 

viewing route along the rim of White Mountain 

utilizing County Road 53. Numerous dispersed 

recreational activities (e.g., hunting, camping, 

hiking, mountain biking, rock hounding, 

photography, wildlife and wild horse viewing, offroad vehicle [ORV] use, and sightseeing) are also 

available throughout the year due in part to the 

proximity of the WMWE project area to Rock 

Springs. In fiscal year 2008, 55,104 visitors 

accessed the Pilot Butte turnout at the center of the 

backcounty byway, and two outfitters are currently 

permitted to operate in the White Mountain/Little 

Colorado Wild Horse Herd Management Areas 

(WHHMAs) for the purpose of bringing tourists to 

view wild horses. All BLM-administered lands 
EA, White Mountain Wind Energy Project 3-9 

Table 3.2 Geologic Formations and Fossil Potential, WMWE Project. 

Formation Member 

Geology Map 

Abbreviation 1 

PFYC Rating 

Class 2 

Fossils Known 

in Formation/ 

Member 

Records of Fossils 

in Project Area 

Green River Laney Tgl 5 Yes No 

 Wilkins 

Peak 

Tgwt 5 Yes No 

1 Tgl = Tertiary Laney Member of the Green River Formation, Tgwt = Tertiary Wilkins Member of the Green 

River Formation 2 PFYC rating (based on Potential Fossil Yield Classification system; BLM Instruction Memorandum No. 2009

001; October 10, 2008), where: 1 = very low potential; 2 = low potential; 3 = moderate or unknown potential; 

4 = high potential; and 5 = very high potential (Uinta Paleontological Associates, Inc. 2009). 

­

within the WMWE Project are currently open for 

public use. 

3.4.3 Transportation 

Access to the proposed project area is by way of 

County Road 53 and Fourteenmile Road from U.S. 

Highway 191. County Road 53 is the only 

maintained road in the proposed project area that 

runs the entire length of the proposed project area 

from north to south. A short segment of 

Fourteenmile Road is located within the northern 

portion of the proposed project area. Numerous 

two-track roads and trails occur throughout the 

project area. 

3.5 NOISE 

The IAA for noise resources is the project 

boundary plus 2.0 mi. A total of 4,402 acres 

(7.13%) of the 61,750-acre IAA has been 

disturbed, primarily by the city of Rock Springs 

and adjacent development. 

Traffic on local and county roads, state highways, 

and I-80; recreational and off-road vehicle 

activity; road construction activities; trains; and 

wind are the primary sources of noise that may be 

audible within the project area. Noise-sensitive 

areas in the IAA include residential areas, hunting 

areas, occupied raptor nests, greater sage-grouse 

leks during the breeding and nesting season, and 

crucial big game winter range during critical 

winter periods. 

The A-weighed sound pressure level, or A-scale, 

is used extensively in the U.S. for the 

measurement of community and transportation 

noise. The A-weighted decibel (dBA) scale 

measures sound levels over the entire range of 

audible frequencies, weighted to accommodate the 

fact that humans hear middle range frequencies 

better than high or low frequencies. The dBA of 

commonly heard sounds is presented in Table 3.3. 

Noise levels in rural landscapes are generally 

lowest in the early morning and in the evening 

when wind speeds are lower and highest in the 

afternoon when wind speeds are higher. A truck 

operating at 30 mph generates about 65 dBA at a 

distance of 300 ft; farm equipment likely is 

somewhat noisier (British Wind Energy 

Association 2009). Passenger cars traveling 

50 mph generate about 65 dBA at 50 ft, and diesel 

trucks generate about 85 dBA at 50 ft, so near U.S. 

Highway 191 and I-80, traffic noise levels are 

likely in the range of 65 to 85 dBA (refer to 

Table 3.3). 

Background noise was measured on White 

Mountain as part of the BLM wind energy 

program policies and BMPs on February 5 and 11, 

2009. Noise measurements were taken every 

0.5 mi along County Road 53 using an Extech 

sound level meter. Ambient noise levels ranged 

from 28 to 68 dBA on a calm day (February 5), 

EA, White Mountain Wind Energy Project 3-11 

Table 3.3 Noise Levels of Commonly Heard Sounds.1 

Source/Activity dBA 2 

Threshold of hearing 0 

Rural night-time background 20-40 

Normal conversation (at 3 ft) 60 

Wind project at 1,100 ft 35-45 

Car at 40 mph at 300 ft 55 

Busy office 60 

Truck at 30 mph at 300 ft 65 

Jet aircraft at 800 ft 105 

Threshold of pain to hearing 140 

1 Source: British Wind Energy Association (2004) and Rau and Wooten (1980). 2 dBA = A-weighted decibels. 

whereas ambient noise levels on an average windy 

day ranged from 47 to 90 dBA (Teton 2009). 

The expected sound level for individual turbines at 

130 ft is expected to be 55-65 dBA (Teton 2009), 

which is equivalent to a normal conversation. 

Therefore, on windy days when the turbines are 

turning, actual noise from the turbines is expected 

to be less than the ambient noise or near to the 

background noise levels. 

3.6 SOCIOECONOMICS 

3.6.1 Demography 

Based on U.S. Census Bureau statistics (U.S. 

Department of Commerce [USDOC] 2009a), 

Sweetwater County’s 2006 population was 

estimated at 38,763, a 3.1% increase in population 

from that of the 2000 decennial census, and only 

60 people fewer than the population recorded in 

the 1990 decennial census (USDOC 2009b). In 

comparison, the State of Wyoming experienced a 

4.3% increase in population between 2000 and 

2006 (USDOC 2009b, 2009c). 

According to the 2000 decennial census, 

Sweetwater County’s labor force (individuals 16 

years of age or older) was 70.6% of the population 

(20,022 individuals), with the number increasing 

to 73.6% (21,621) of the population in USDOC’s 

2005-2007 American Community Survey 

(USDOC 2009d, 2009e). In comparison, the U.S. 

labor force was only 64.7% of the population in 

the 2005-2007 surveys (USDOC 2009f). Most 

recent preliminary data place Sweetwater 

County’s unemployment rate in July of 2009 at 

6.5%, compared to a statewide 6.5% 

unemployment rate. The unemployment rate for 

Sweetwater County has increased 1.5% since July 

of 2009; whereas the Wyoming unemployment 

rate has remained the same. Nevertheless, 

Sweetwater County’s December 2008 

unemployment rate is approximately half of the 

July 2009 national average of 9.4% (Wyoming 

Department of Employment, Research & Planning 

2009). 

According to 2000 census data, Sweetwater 

County occupations in Wyoming were dominated 

by sales and office jobs (23.4% of the workforce); 

management, professional, and related occupations 

(23.3%); and construction, extraction, and 

maintenance jobs (21.1%); with production, 

transportation, and material moving (16.1%); 

service (15.9%); and farming, fishing, and forestry 

(0.2%) providing the remaining jobs (USDOC 

2009d). Industry, education, health, and social 
3-12 EA, White Mountain Wind Energy Project 

services (18.2%); agriculture, forestry, fishing, and 

mining (14.8%); and transportation, warehousing, 

and utilities (11.9%) dominated jobs in 

Sweetwater County, with all other industry classes 

comprising less than 10% each. Private wage and 

salary workers comprise 76.5% of the Sweetwater 

County workforce, followed by government 

workers (17.7%), self-employed/unincorporated 

business workers (5.6%), and unpaid family 

members (0.2%) (USDOC 2009d). Major 

employers in the county include FMC Wyoming 

Corporation (844 employees), Haliburton (755), 

Sweetwater County School District #1 (720), 

General Chemical (531), Solvay Minerals (428), 

OCI (428), PacifiCorp (393), Sweetwater 

Memorial Hospital (372), Schlumberger (335), 

Bridger Coal (319), and Sweetwater County 

School District #2 (290) (Why Wyoming.org 

2009). 

Annual per capita income for Sweetwater County 

in USDOC’s 2005-2007 3-year Community 

Survey was $28,835 (in 2007 inflation-adjusted 

dollars) compared to $16,810 in 1990 (an increase 

of 71.5% over 17 years) (USDOC 2009e). The 

cost of living index for the county in the fourth 

quarter of 2008 was 107, compared to 97 in the 

second quarter of 2002 (Wyoming Economic 

Analysis Division 2003, 2009). The index uses 

100 as the statewide average; thus, the cost of 

living was seven points below the statewide 

average in 2002, but by the end of 2008, it had 

climbed to seven points above the statewide 

average. In 2000, 7.8% of the Sweetwater County 

population was living below the poverty level 

(USDOC 2009d). That number increased to 8.1% 

in 2004 (USDOC 2009a, 2009b), but the 2005­

2007 American Community Survey reported a 

drop to 7.2% (USDOC 2009e). In that same 

survey, the statewide percentage was considerably 

higher at 8.9%, although still well below the 

national average of 13.3% (USDOC 2009g). 

As of the 2000 census, Sweetwater County 

reported 15,921 housing units, with one-unit 

detached structures comprising 58.8%, and mobile 

homes comprising 23.2%. No other structure type 

exceeded 4.2% of the total (USDOC 2009h). 

Occupancy was 88.6% of the total units, with 

11.4% vacancies and 1.5% seasonal/recreational 

residences (USDOC 2009i). The 2005 through 

2007 American Community Survey shows 16,480 

housing units with 91.7% occupancy (an increase 

of 3.1% over the 2000 decennial census for both 

housing units and occupancy rate) (USDOC 

2009e). The occupancy rate of Wyoming reported 

in the same 2005-2007 survey was 85.9 or 5.8% 

lower than that of the county (USDOC 2009j). 

Thirty-one schools in two school districts served 

6,964 students in the 2006-2007 school year, and 

the average student to teacher ratio was 

approximately 15:1. Western Wyoming 

Community College also enrolled 3,967 students 

in that year (Why Wyoming.org 2009). 

The adjusted crime rate in Sweetwater County 

declined between 1995 and 2003, but is higher 

than the statewide crime rate (Pinedale Anticline 

Working Group [PAWG] 2005). 

Electric power is provided to the county by 

Bridger Valley REA and Rocky Mountain Power. 

Costs (cents per KWh) range from $0.0502 

(industrial) to $0.0837 (residential) for the former, 

and from $0.0381 (industrial) to $0.0688 

(residential) for the latter (Why Wyoming.org 

2009). 

3.6.2 Health, Safety, and Transportation 

The proposed project area is undeveloped, and no 

permanent residential structures occur within the 

proposed project area. County Road 53 runs the 

length of the project area. Access to the proposed 

project area is by way of County Road 53 and 

Fourteenmile Road from U.S. Highway 191. 

Therefore, the primary safety risks for people 

working or traveling in the general project area are 

related to vehicle accidents. 

3.7 SOILS 

The IAA for soil resources is the boundary of the 

level 12 Hydrologic Unit Code (HUC) 

(Figure 3.3). A total of 19,954 acres (7.43%) of 

the 268,613-acre IAA has been disturbed, 

primarily by cities. 

3-14 EA, White Mountain Wind Energy Project 

The project area is primarily composed of Ustic 

haplargids soils (Figure 3.4). A second type, Ustic 

torriorthents, occurs along the extreme east side of 

the project area and is associated with the eastern 

side of the project area along the rim and 

sideslopes of White Mountain (BLM 1996; Munn 

and Arneson 1999). 

The Ustic haplargids soils (Munn and Arneson 

1999) are composed of Blackhall, Renrsac, 

Carmody, Grieves, Renot, Thermopolis, Elk 

Mountain, Blazon, Delphill, Redwash, Red Creek, 

and Shinbara soil types. These soils are shallow 

and moderately drained and formed on sloping 

upland plains with deep steep-sided ravines. 

The Urtic torrienthents (Munn and Arneson 1999) 

are composed of Huguston, Wint, Spool, and 

Lamarsh soils, which occur on shallow soil rock 

outcrops, are well-drained, and were formed on 

steep ridges, escarpments, and mountain slopes. 

Soils susceptible to surface disturbing activities 

include unstable soils, sandy soils, and erosive 

soils. Unstable soils are those soils or soil groups 

susceptible to landslides or slumping activity and 

may be a hazard to permanent structures. None of 

the soils within the WMWE project area are 

categorized as unstable soils (BLM 1996). Sandy 

soils are very susceptible to wind erosion when the 

protective vegetative cover is removed. The 

Huguston soil type is categorized as a sandy soil. 

Erosive soils are a result of their depth, texture, 

and/or position on the landscape. Huguston, 

Redwash, Thermopolis-Outcrop, Shinbara, 

Thermopolis, and Redwash-Spool-Outcrop are 

categorized as erosive soil types. 

3.8 THREATENED, ENDANGERED, 

PROPOSED, CANDIDATE, AND 

BLM SENSITIVE SPECIES 

The federal Endangered Species Act (16 U.S.C. 

1531-1543) protects listed threatened and 

endangered plant and animal species and their 

critical habitats. A list of federally listed 

threatened, endangered, proposed, and candidate 

(TEPC) species that potentially occur in the 

vicinity of the proposed project was provided by 

the BLM RSFO through correspondence with the 

USFWS Wyoming State Office. Records of 

known occurrences of federal, state, and BLM 

sensitive species were queried from the Wyoming 

Natural Diversity Database (WNDD 2009). 

TEPC species are those that have been specifically 

designated as such by the USFWS. Threatened 

species are those that are likely to become 

endangered in the foreseeable future throughout all 

or a significant portion of their range. Endangered 

species are those that are in danger of extinction 

throughout all or a significant portion of their 

range. Proposed species are those for which the 

USFWS has published proposed rules in the 

Federal Register for listing of the species but for 

which a final rule has not been adopted. 

Candidate species are those for which the USFWS 

has sufficient data to list as threatened or 

endangered but for which proposed rules have not 

yet been issued. BLM sensitive species are those 

that may warrant designation as candidate species 

but sufficient data are not currently available for 

such a designation decision; these species may be 

designated as BLM sensitive species by the BLM. 

Based on WNDD (2009), no TEPC species 

occurrences have been documented in the project 

area; however, black-footed ferret and gray wolf 

have historically recorded occurrences within 

6.0 mi of the project area. 

3.8.1 TEPC Animal and Plant Species 

The black-footed ferret (Mustela nigripes), a 

federal endangered species; the Canada lynx 

(Lynx canadensis), a federal threatened species; 

the gray wolf (Canis lupus), part of a nonessential 

experimental population; yellow-billed cuckoo 

(Coccyzus americanus), a federal candidate 

species; four Colorado River endangered fish 

species--bonytail chub (Gila elegans), Colorado 

pikeminnow (Ptychocheilus lucius), humpback 

chub (Gila cypha), and razorback sucker 

(Xyrauchen texanus); blowout penstemon 

(Penstemon haydenii); and Ute ladies’-tresses 

(Spiranthes diluvalis), a federal threatened species 

have been identified by the USFWS and BLM 

RSFO as having potential to occur within or in the 

vicinity of the proposed project area (Table 3.4). 

No other TEPC species have been identified as 

3-16 EA, White Mountain Wind Energy Project 

Table 3.4 Federal Threatened, Endangered, Proposed, and Candidate Species and Their Potential 

Occurrence Within the Proposed Project Area, 2009.1 

Potential Occurrence 

Common Name Scientific Name Federal Status2 

Within the Proposed 

Project Area3 

MAMMALS 

Black-footed ferret Mustela nigripes E X 

Canada lynx Lynx canadensis T X 

Gray wolf Canis lupus XN R 

BIRDS 

Yellow-billed cuckoo Coccyzus americanus C R 

FISH 

Bonytail (Roundtail chub) Gila elegans E X 

Colorado pikeminnow Ptychocheilus lucius E X 

Humpback chub Gila cypha E X 

Razorback sucker Xyrauchen texanus E X 

PLANTS 

Blowout penstemon Penstemon haydenii E X 

Ute ladies’-tresses Spiranthes diluvialis T X 

1 Adapted from USFWS (2008) and BLM (2009b). 2 Federal status (USFWS 2008): 

C = candidate 

E = listed as federally endangered 

T = listed as federally threatened 

XN = nonessential experimental population 3 Species occurrence, based on WNDD (2009) and BLM (2009) 

R = Rare; species may pass through or be in the project area for just a few days or hours (e.g., stopping over 

during migration). Encounters during project construction are unlikely. 

U = Uncommon; species may be present in the project area but in such low numbers or in such small and widely 

scattered populations that an encounter during field development and operation is unlikely. The species 

could be present for a significant part of the year (e.g., breeding season and/or summer resident). 

X = Unlikely; no habitat present; there has been no recent or historical records of the species occurrence in the 

project area (WNDD 2009); probability of encountering the species during project construction is very 

unlikely. 
EA, White Mountain Wind Energy Project 3-17 

potentially occurring within the project area 

(USFWS 2008). 

Black-footed ferret. The black-footed ferret, a 

federally endangered species, was once distributed 

throughout the high plains of the Rocky Mountain 

and western Great Plains regions (Clark and 

Stromberg 1987; Forrest et al. 1985). Prairie dogs 

are the main food of black-footed ferrets (Sheets 

et al. 1972); few black-footed ferrets have been 

historically collected away from prairie dog towns 

(Forrest et al. 1985). The last known wild 

population of black-footed ferrets was discovered 

in the Pitchfork area near Meeteetse in 1981. Due 

to the fear that canine distemper would wipe out 

this population, all remaining black-footed ferrets 

were captured from the Pitchfork area and placed 

into a captive breeding project in 1985 (WGFD 

1997). WNDD has three records of black-footed 

ferrets occurring within 6.0 mi of the project area; 

however, these records date to 1965 on the 

Seedskadee Wildlife Refuge area. The nearest 

known currently viable population of black-footed 

ferrets is located in the Coyote Basin Black-footed 

Ferret Management Area, southwest of Dinosaur 

National Monument, approximately 110.0 mi 

southwest of the proposed project area. The 

Black-footed Ferret Survey Guidelines for 

Compliance with the Endangered Species Act 

(USFWS 1989) defines potential black-footed 

ferret habitat as any white-tailed prairie dog town 

or complex greater than 200 acres. Although 

potential black-footed ferret habitat may occur 

within the WMWE project area, it is located 

outside any area requiring black-footed ferret 

surveys (USFWS 2004). In addition, no recent 

black-footed ferret observations have been 

recorded in the vicinity of the WMWE project area 

(WNDD 2009); therefore, it is unlikely that any 

black-footed ferrets would occur in the WMWE 

project area, and the species is not discussed 

further in this EA. 

Canada Lynx. Canada lynx, a federally threatened 

species, are typically found at elevations above 

4,000 ft in a mosaic of forest conditions ranging 

from early successional to mature coniferous and 

deciduous stands (Meaney and Beauvais 2004). 

Snowshoe hares are their primary prey, though 

tree squirrels, voles, and mice are also eaten. No 

potential habitat for Canada lynx occurs within the 

project area, and no known observations of 

Canada lynx within 6.0 mi of the project have 

been recorded (WNDD 2009); therefore, Canada 

lynx are not discussed further in this EA. 

Gray Wolf. The gray wolf was re-introduced into 

the Greater Yellowstone ecosystem in 1995. Gray 

wolves in Wyoming are considered part of that 

nonessential experimental population (a 

nonessential experimental population designation 

refers to an experimental population whose loss 

would not be likely to appreciably reduce the 

likelihood of the survival of the species in the 

wild and is treated like proposed species under 

Section 7 of the Endangered Species Act), and 

they are managed as a proposed species outside of 

National Park Service or National Refuge System 

lands. Although those wolves remain listed and 

protected under the Endangered Species Act, 

additional flexibility is provided for their 

management under provisions of the final rule and 

special regulations promulgation for the 

nonessential experimental population on 

November 22, 1994 (published in 59 Federal 

Register 60252). 

Gray wolves are large carnivores that are capable 

of living in a wide variety of habitats within 

specific established territories and depend on 

ungulates for food. The primary prey for wolves 

in the Yellowstone area is elk (87%), as well as 

moose, deer, antelope, and bison (Greater 

Yellowstone Winter Wildlife Working Group 

1999; Clark and Stromberg 1987). At least 218 

wolves in 25 packs were present within the greater 

Yellowstone ecosystem by the end of 2001 (Smith 

and Guernsey 2002). WNDD (2009) has a historic 

record of a gray wolf occurrence in the vicinity of 

the project area. While it is possible that gray 

wolf may pass through the project area, it is highly 

unlikely that the wolf would reside in the project 

area due to the lack of suitable habitat. In 

addition, based on regulatory status of the gray 

wolf as nonessential experimental population, the 

project would have no effect on this species; 

therefore, it is not discussed further in this EA. 

Yellow-billed Cuckoo. Yellow-billed cuckoo is 

the only candidate species in Wyoming that may 

occur in the project area or vicinity (USFWS 
3-18 EA, White Mountain Wind Energy Project 

2008). In Wyoming, the yellow-billed cuckoo is a 

rare summer breeder that arrives from wintering 

grounds in South America in late May and departs 

from September to October. The yellow-billed 

cuckoo is primarily found in open streamside 

deciduous woodland with low scrubby vegetation 

undergrowth bordering Wyoming’s larger rivers. 

Cottonwood stands and willow thickets are 

preferred for nesting and foraging. The yellowbilled cuckoo has been identified as potentially 

occurring in the riparian areas west of the 

Continental Divide; however, it is highly unlikely 

that the yellow-billed cuckoo occurs in the project 

area since no riparian habitat is present and no 

observations have been recorded in the vicinity 

(WNDD 2009). The nearest potential yellowbilled cuckoo habitat is likely located along the 

Green River, approximately 6.5 mi southwest of 

the project area. Therefore, the yellow-billed 

cuckoo is not discussed further in this EA. 

Colorado River Endangered Fish Species. The 

Recovery and Implementation Program (RIP) for 

Endangered Species in the Upper Colorado River 

Basin was initiated in January 1988 as a 

reasonable and prudent approach for projects to 

avoid jeopardizing the continued existence of the 

four species of Colorado River endangered fish-­

bonytail, Colorado pikeminnow, humpback chub, 

and razorback sucker. Under the program, any 

depletions of water from tributaries within the 

Colorado River drainage system (which includes 

the project area) are considered by the USFWS to 

jeopardize the continued existence of these 

species. The USFWS has determined that 

progress made under the RIP has been sufficient to 

merit a waiver of the mitigation fee for depletions 

of 100 acre-ft or less (Memorandum dated 

March 9, 1995, to Assistant Regional Director, 

Ecological Services, Region 6, from Regional 

Director 6, “Intra-Service Section 7 Consultation 

for Elimination of Fees for Water Depletions of 

100 acre-feet or Less from the Upper Colorado 

River Basin”). 

Blowout Penstemon. Blowout penstemon, a 

federally endangered species, is a perennial herb 

associated with blowout depressions in sparsely 

vegetated active sand dunes. Individual plants 

have deep root systems and multiple stems that 

can survive shifting sands. This species is known 

to occur in the sandhills of western Nebraska and 

in the Ferris Mountains of south-central Wyoming 

(Fertig 1999). No suitable habitat occurs in the 

project area; therefore, blowout penstemon is not 

discussed further in this EA. 

Ute Ladies’-tresses. Ute ladies’-tresses, a federal 

threatened species, is a perennial member of the 

orchid family that inhabits moist streambanks, wet 

meadows, and abandoned stream channels at 

elevations of 4,500-6,800 ft (Fertig 1994; 

Spackman et al. 1997). Although the species will 

tolerate mildly alkaline conditions, it is unlikely to 

be found in association with Gardner’s saltbush, 

greasewood, or other alkaline vegetation. Where 

it occurs in ephemeral drainages, groundwater is 

typically shallow (i.e., within approximately 18 

inches of the ground surface) (personal 

communication, March 16, 2000, with Pat Deibert, 

USFWS; personal communication, March 22, 

2000, with Walt Fertig, WNDD). 

The species has been documented in Goshen, 

Converse, and Niobrara counties in Wyoming 

(Wyoming Rare Plant Technical Committee 1997) 

and along the Front Range in northern and central 

Colorado (Spackman et al. 1997). It also has been 

reported below the dam at Flaming Gorge 

Reservoir (personal communication, March 22, 

2000, with Walt Fertig, WNDD). Although, in 

recent years, much time has been devoted to 

determining areas in Wyoming where the species 

occurs, it has not been documented within or near 

the proposed project area or in Sweetwater County 

(WNDD 2009) or within the BLM RSFO (BLM 

2009b). Based on visual observation of the project 

area and descriptions for vegetation communities 

in the project area, there is no suitable habitat for 

Ute ladies’-tresses within or near the proposed 

project area, and Ute ladies’-tresses are not 

discussed further in this EA. 

3.8.2 BLM Sensitive Animal and Plant Species 

Based on habitat preference and geographic 

location, numerous BLM sensitive species may 

potentially occur or have been documented in the 

proposed project area (email communication, 

February 2, 2009, with Teri Deakins, BLM RSFO; 
EA, White Mountain Wind Energy Project 3-19 

WNDD 2009; TRC 2009b) (Table 3.5). Potential 

habitat for long-eared myotis, fringed myotis, 

spotted bat, Townsend’s big-eared bat, whitetailed prairie dog, Wyoming and Idaho pocket 

gophers, bald eagle, ferruginous hawk, mountain 

plover, burrowing owl, midget faded rattlesnake, 

and Cedar Rim thistle occurs within or in the 

vicinity of the proposed project area (WNDD 

2009). Sagebrush-obligate species on the BLM 

sensitive animal species list that might also occur 

in project area include pygmy rabbit, greater sagegrouse, sage thrasher, loggerhead shrike, Brewer’s 

sparrow, and sage sparrow. BLM sensitive 

species observed (TRC 2009b) or recorded 

(WNDD 2009) in the project area include pygmy 

rabbit, ferruginous hawk, greater sage-grouse, sage 

thrasher, loggerhead shrike, Brewer’s sparrow, and 

sage sparrow (refer to Table 3.5). Species listed 

on Table 3.5 as not having any potential habitat 

are not discussed further in this EA. 

Pygmy Rabbit. Pygmy rabbits prefer areas of 

dense and tall sagebrush in predominantly sandy 

soils (Clark and Stromberg 1987). Burrows are 

typically located in areas with greater cover and 

shrub densities, taller vegetation, and high forb 

density (Ulmschneider 2004). Pygmy rabbit 

habitat occurs throughout the project area as 

inclusions of preferred vegetation densities and 

heights within Wyoming big sagbrush 

communities. Potential pygmy rabbit habitat also 

occurs in drainage bottoms where sagebrush and 

vegetation tend to be taller and denser and soils 

are deeper, thereby providing good cover and 

easier burrow excavation areas. Pygmy rabbits 

were observed by TRC during the 2008 avian 

migration studies and occur in the WMWE project 

area. 

Wyoming Pocket Gopher. The Wyoming pocket 

gopher is exclusive to Wyoming. Specifically, it 

is only found in south-central Wyoming in Carbon 

and Sweetwater counties (Clark and Stromberg 

1987). The WMWE Project is along the 

western-most edge of the known geographic 

range of this species. Two similar looking species 

of pocket gophers, the northern and Idaho 

pocket gopher, may occur within the range of 

the Wyoming pocket gopher, making field 

identification difficult. Positive identification 

requires karyotype (chromosomal) analysis, but 

morphological differentiating characteristics are 

being developed. Because the Wyoming pocket 

gopher is similar in appearance to more common 

and widely distributed northern pocket gopher, 

many earlier collections and observations of the 

Wyoming pocket gopher were misidentified; 

therefore, little is known about the population 

status of this species. Studies have recently been 

conducted to determine the distribution and 

population of this species, as well as the 

development of predictive models to determine 

potential habitat (Keinath and Beauvais 2006; 

Hayden-Wing Associates, LLC 2008; Keinath and 

Griscom 2009). The Wyoming pocket gopher 

prefers to inhabit dry gravelly ridges as opposed to 

valley bottoms with deeper soils, areas where 

other gophers prefer (Hayden-Wing Associates, 

LLC 2008). Recent studies have found Wyoming 

pocket gophers in small islands of low vegetation 

within a sagebrush matrix with cushion plants, 

grass, rabbitbrush, and low shrubs. Wyoming 

pocket gophers have not been found in flats 

dominated by greasewood, valley bottoms, sand 

dunes, or areas where medium to high Wyoming 

big sagebrush dominated the vegetation 

community (Keinath and Griscom 2009). Pocket 

gophers in general spend most of their life 

underground and are important in soil 

development, soil aeration, and promoting water 

storage in soil during spring runoff (Keinath and 

Beauvais 2006). No recorded occurrences of 

Wyoming pocket gopher are documented in the 

WMWE project area (WNDD 2009). The nearest 

known records of the Wyoming pocket gopher are 

east of Rock Springs (Hayden-Wing Associates, 

LLC 2008). Predictive models developed by 

Keinath and Griscom (2008) indicate that the 

WMWE project area is in a “predicted absentmarginal” and “predicted present-marginal” area 

for Wyoming pocket gopher. 

Idaho Pocket Gopher. The Idaho pocket gopher is 

endemic to southwestern Wyoming and 

southeastern Idaho, extending slightly into 

southwestern Montana and northern Utah 

(Beauvais and Dark-Smiley 2005). This species 

prefers shallow stony soils in open sagebrush, 

grassland plains, and subalpine meadow habitats. 
3-20 EA, White Mountain Wind Energy Project 

Table 3.5 Wyoming BLM Sensitive Species, Habitat Preference, and Occurrence of Habitat and 

Observational Data, WMWE Project, 2009. 1, 2 

Potential Habitat 

in or in Vicinity Observed ?/ 

Common Name Scientific Name Habitat of Project Area Occurrence Data 

MAMMALS 

Grizzly bear Sorex nanus Forest, basin prairie, and 

meadows 

No No/No known data 

of occurrence 

Long-eared 

myotis 

Myotis evotis Conifer and deciduous 

forests, caves, and mines 

Yes Yes/2008 bat field 

survey, WNDD 

2009 data within 

6.0 mi of project 

area 

Fringed myotis Myotis thysanodes Conifer forests, Yes Yes/2008 bat field 

woodland-chaparral, survey 

caves, and mines 

Spotted bat Euderma Cliffs over perennial Yes Yes/2008 bat field 

maculatum water, basin-prairie shrub survey 

Townsend’s 

big-eared bat 

Corynorhinus 

townsendii 

Forests, basin-prairie 

shrub, caves, and mines 

Yes Yes/2008 bat field 

survey, WNDD 

2009 data within 

project area 

Pygmy rabbit Brachylagus 

idahoensis 

Basin-prairie and riparian 

shrub 

Yes Yes/2008 avian 

migration studies, 

WNDD 2009 data 

within 6.0 mi of 

project area 

White-tailed 

prairie dog 

Cynomys leucurus Basin-prairie shrub, 

grasslands 

No No towns observed/ 

WNDD 2009 has 

records in area 

Wyoming pocket 

gopher 

Thomomys clusius Dry gravelly shallow soil, 

ridgetops rather than 

Yes No/No known data 

of occurrence 

deeper soiled swales and 

valley bottoms 

Idaho pocket 

gopher 

Thomomys 

idahoensis 

Dry gravelly shallow soil, 

ridgetops rather than 

Yes No/No known data 

of occurrence 

deeper soiled swales and 

valley bottoms 

Swift fox Vulpes velox Grasslands No No/No known data 

of occurrence 

BIRDS 

Bald eagle Haliaeetus 

leucocephalus 

Cliffs, large trees, or 

sheltered canyons for 

No No/No known data 

of occurrence 

nesting, near water sources 

for foraging 

White-faced ibis Plegadis chihi Marshes, wet meadows No No/No known data 

of occurrence 

Trumpeter swan Cygnus buccinator Lakes, ponds, rivers No No/WNDD 2009 

data within 6.0 mi 

of project area 

Northern Accipter gentilis Conifer and deciduous No No/WNDD 2009 

goshawk forests 
EA, White Mountain Wind Energy Project 3-21 

Table 3.5 (Continued) 

Potential Habitat 

in or in Vicinity Observed ?/ 

Common Name Scientific Name Habitat of Project Area Occurrence Data 

Ferruginous 

hawk 

Buteo regalis Basin-prairie shrub, 

grassland, rock outcrops 

Yes Yes/2008 avian 

migration studies, 

WNDD 2009 data 

Peregrine falcon Falco peregrinus Tall cliffs No No/No known data 

of occurrence 

Greater sagegrouse breeding Centrocercus 

urophasianus 

Basin-prairie shrub, 

mountain-foothill shrub 

Yes Yes/2008 avian 

migration surveys 

habitat 

Greater sage- Centrocercus Basin-prairie shrub, Yes Yes/2008 winter 

grouse wintering urophasianus mountain-foothill shrub greater sage-grouse 

habitat surveys 

Long-billed 

curlew 

Numenius 

americanus 

Grasslands, plains, 

foothills, wet meadows 

No No/No known data 

of occurrence 

Mountain plover Charadrius 

montanus 

Grassland and desert 

shrub/grasslands with level 

Yes No/No known data 

of occurrence; none 

areas (<3% slope) with at observed during 

least 30% bare ground 2008 avian surveys 

Burrowing owl Athene cunicularia Grasslands, basin-prairie 

shrub 

Yes No/No known data 

of occurrence 

Sage thrasher Oreoscoptes 

montanus 

Basin-prairie shrub, 

mountain-foothill shrub 

Yes Yes/2008 avian 

migration studies, 

WNDD 2009 data 

Loggerhead 

shrike 

Lanius ludovicianus Basin-prairie shrub, 

mountain-foothill shrub 

Yes Yes/2008 avian 

migration studies 

Brewer’s sparrow Spizella breweri Basin-prairie shrub Yes Yes/2008 avian 

migration studies 

Sage sparrow Amphispiza belli Basin-prairie shrub, 

mountain-foothill shrub 

Yes Yes/2008 avian 

migration studies 

FISH 

Roundtail chub Gila robusta Colorado River drainage, 

mostly large rivers, also 

No No/WNDD 2009 

has record within 

streams and lakes 6.0 mi of project 

area 

Leatherside chub Gila copei Bear, Snake, and Green 

rivers’ drainages, clear, 

No No/No known data 

of occurrence 

cool streams and pools 

Bluehead sucker Catostomus Bear, Snake, and Green No No/WNDD 2009 

discobolus rivers’ drainages, all waters has record within 

6.0 mi of project 

area 

Flannelmouth 

sucker 

Catostomus 

latipinnis 

Colorado River drainage, 

large rivers, streams and 

No No/No known data 

of occurrence 

lakes 

Colorado River 

cutthroat trout 

Oncorhynchus 

clarki pleuriticus 

Colorado River drainage, 

clear mountain streams 

No No/No known data 

of occurrence 

REPTILES 

Midget faded 

rattlesnake 

Crotalus viridis 

concolor 

Mountain foothills shrub, 

rock outcrop 

Yes No/No known data 

of occurrence 
3-22 EA, White Mountain Wind Energy Project 

Table 3.5 (Continued) 

Potential Habitat 

in or in Vicinity Observed ?/ 

Common Name Scientific Name Habitat of Project Area Occurrence Data 

AMPHIBIANS 

Northern leopard 

frog 

Rana pipiens Beaver ponds, permanent 

water in plains and foothills 

No No/No known data 

of occurrence 

Great basin 

spadefoot 

Spea intermontana Spring seeps, permanent and 

temporary waters 

No No/WNDD 2009 

has record within 

6.0 mi of project 

area 

Boreal (Northern 

Rocky Mountain 

Bufo boreas boreas Pond margins, wet 

meadows, riparian areas 

No No/No known data 

of occurrence 

population) toad 

Spotted frog Ranus pretiosa 

(lutieventris) 

Ponds, sloughs, small 

streams 

No No/No known data 

of occurrence 

PLANTS 

Meadow 

pussytoes 

Antennaria arcuata Moist, hummocky meadows, 

seeps or springs surrounded 

No No/No known data 

of occurrence 

by sage/grasslands, 

4,950-7,900 ft 

Small rock cress Arabis pusilla Cracks/crevices in sparsely 

vegetated granite/pegmatite 

No No/No known data 

of occurrence 

outcrops within 

sage/grasslands, 

8,000-8,100 ft 

Mystery 

wormwood 

Artemisia biennis 

var. diffusa 

Clay flats and playas, 

6,500 ft 

No No/No known data 

of occurrence 

Nelson’s 

milkvetch 

Astragalus 

nelsonianus or 

Alkaline clay flats, shale 

bluffs, and gullies, pebbly 

No No/No known data 

of occurrence 

Astragalus slopes and volcanic cinders 

pectinatus in sparsely vegetated 

var. platyphyllus sagebrush, juniper, and 

cushion plant communities 

at 5,200-7,600 ft 

Precocious 

milkvetch 

Astragalus 

proimanthus 

Cushion plant communities 

on rocky clay soils mixed 

No No/No known data 

of occurrence 

with shale on summits and 

slopes of white shale hills, 

6,800-7,200 ft 

Cedar Rim thistle Cirsium aridum Barren, chalky hills, gravelly 

slopes, and fine textured, 

Yes No/BLM personal 

communication 

sandy-shaley draws, 

6,700-7,200 ft 

Ownbey’s thistle Cirsium ownbeyi Sparsely vegetated shaley 

slopes in sage and juniper 

No No/No known data 

of occurrence 

communities, 6,440-8,400 ft 

Wyoming 

tansymustard 

Descurainia 

torulosa 

Sparsely vegetated sandy 

slopes at base of cliffs of 

No No/No known data 

of occurrence 

volcanic breccia or 

sandstone, 8,300-10,000 ft 
EA, White Mountain Wind Energy Project 3-23 

Table 3.5 (Continued) 

Potential Habitat 

in or in Vicinity Observed ?/ 

Common Name Scientific Name Habitat of Project Area Occurrence Data 

Large-fruited 

bladderpod 

Lesquerella 

macrocarpa 

Gypsum-clay hills 

benches, clay flats, 

barren hills, 7,200­

and 

and 

7,700 ft 

NoNo/No known data 

of occurrence 

Stemless 

beardtongue 

Penstemon acaulis 

var. acaulis 

Cushion plant or Bl 

sage grassland 

communities on se 

ack 

miNoNo/No known data 

of occurrence 

barren rocky ridges 

and slopes at 5,900 

, knolls, 

-8,200 ft 

Beaver Rim 

phlox 

Phlox pungens Sparsely vegetated 

on sandstone, siltst 

limestone substrate 

slopes 

one, or 

s, 

NoNo/No known data 

of occurrence 

6,000-7,400 ft 

Tufted twinpod Physaria 

condensata 

Sparsely vegetated 

slopes and ridges, 

6,500-7,000 ft 

shale NoNo/No known data 

of occurrence 

Green River 

greenthread 

Thelesperma 

caespitosum 

White shale slopes 

ridges of Green Riv 

Formation, 6,300 ft 

and 

er 

No No/WNDD 2009 

has record with 

6.0 mi of project 

area 

Uinta greenthread Thelesperma 

pubescens 

Sparsely vegetated 

benches and ridges on 

coarse cobbly soils of 

Bishop Conglomerate, 

8,200-8,900 ft 

No No/No known data 

of occurrence 

1 Based on BLM (2009). 2 Based on WNDD (2009) and TRC (2009b). 
3-24 EA, White Mountain Wind Energy Project 

Population status is unknown due to the lack of 

field data, but the species is assumed to be rare 

with a limited distribution. The Idaho pocket 

gopher is very similar in appearance to other 

pocket gophers such as the Wyoming and northern 

pocket gophers; therefore, a reliable identification 

requires a karyotype analysis. In Wyoming, the 

Idaho pocket gopher is known to occur in Uinta, 

Lincoln, and Sublette counties whereas the 

Wyoming pocket gopher is limited to Sweetwater 

and Carbon counties. The northern pocket gopher 

occurs throughout Wyoming (Beauvais and DarkSmiley 2005). There are no known occurrences of 

the Idaho pocket gopher in or in the vicinity of the 

WMWE project area (WNDD 2009; WGFD 

2004), and this species will not be discussed 

further in this EA. 

Greater Sage-grouse. The IAA for greater sagegrouse is the area north of Bitter Creek, east of the 

Green River, south of the Big Sandy River to 

Farson, then east to Killpecker Sand. A total of 

10,401 (1.91%) of the 545,351-acre IAA has been 

disturbed, primarily by roads. 

As indicated, the WMWE project area occurs 

within Upland Game Bird Management Area 

(UGBMA) #7 (Eden) and is approximately 1.0 mi 

northwest of the adjacent UGBMA #6 (Flaming 

Gorge) (Figure 3.5). UGBMA #7 encompasses 

approximately 4,541 mi2

 and generally is bounded 

on the south by I-80 from Green River east to 

approximately Superior, then north to midway 

between Pinedale and Lander, then southwest to 

Big Piney and southeast back to Green River. 

UGBMA #6 generally encompasses approximately 

3,615 mi2

 in the western approximately two-thirds 

of the south half of Sweetwater County. It 

includes the Flaming Gorge area and is bounded 

on the south by the Wyoming/Colorado border. 

Greater sage-grouse are a BLM sensitive species 

that are being considered for listing under the 

Endangered Species Act. During the spring and 

fall avian surveys, 226 grouse observations were 

recorded as part of the continuous raptor and other 

large bird (RLB) surveys, and passerine and other 

small bird (PSB) surveys. A total of 50 

observations (22%) were made during the spring, 

and 176 observations (78%) were made during the 

fall. Sixty-two percent of the greater sage-grouse 

were seen flying or flushed to flying, and 38% of 

the sightings stayed on the ground (i.e., did not 

flush or fly). For those greater sage-grouse that 

did fly, 100% were observed flying within the 0 to 

35-m flight height category (i.e., below the rotorswept area), and these birds would not be at risk 

for collision with a wind turbine (i.e., risk index 

of 0.0) (TRC 2009b). 

Based on the WNDD (2009) data for the WMWE 

project area, 1,812 greater sage-grouse 

observations have been documented within the 

project area, based on 23 years of observation 

between 1973 and 2006. These data indicated that 

there were 1,545 observations of adults and 267 

observations of juveniles or yearlings. 

As a result of concern for the current and future 

population status of greater sage-grouse and their 

habitat, Wyoming Governor Dave Fruedenthal 

requested a Sage-grouse Implementation Team 

(SGIT) to identify actions and measures that 

would be useful in managing greater sage-grouse 

and their habitats in Wyoming. As a result of this 

effort, initial Core Population Areas for greater 

sage-grouse were identified within the state of 

Wyoming. Those Core Habitat Areas encompass 

habitats and existing populations for at least twothirds of the greater sage-grouse in Wyoming 

(SGIT 2008). SGIT predicted that approximately 

83% of the peak males attending leks in Wyoming 

are within core areas, as are approximately 61% of 

the occupied leks in the state. The SGIT 

recommends that management within the core 

areas focus on maintenance and enhancement of 

grouse habitats and populations in those areas. An 

ongoing mapping and ground-truthing effort is 

being conducted by Wyoming Geographic 

Information System Center (WYGISC) in 

cooperation with SGIT to further evaluate and 

refine the core management areas. 

Approximately 515 acres (3.9%) of the WMWE 

project area are within the identified 2.5-million 

acre South Pass Core Habitat Area for greater 

sage-grouse. The entirety of this specific Core 

Habitat Area occurs in the northernmost portion of 

the project area (refer to Figure 3.5). 

3-26 EA, White Mountain Wind Energy Project 

The project area and vicinity provide suitable 

nesting, brood-rearing, and wintering habitat for 

greater sage-grouse, which rely heavily on 

sagebrush for food, as well as thermal and hiding 

cover during all seasons and throughout all age 

classes. On February 29, 2008, an aerial survey 

was conducted for wintering greater sage-grouse 

within the WMWE project area and an adjacent 

213-mi2

 survey area as requested by BLM RSFO 

(TRC 2008a). Eighty-four greater sage-grouse 

were observed during that winter survey; however, 

none were observed within the WMWE project 

area. The project area, as well as much of the rest 

of the eastern two-thirds of the surveyed area, had 

fairly high snow cover relative to available forage 

at the time of the survey, and numerous golden 

eagles (which prey on greater sage-grouse) were 

observed during the survey. These two factors 

may explain the scarcity of greater sage-grouse 

recorded in the project area and immediately 

adjacent areas during the winter survey (TRC 

2008a). 

An aerial greater sage-grouse lek survey of the 

213-mi2

 above-referenced area was conducted 

from April 4 through April 6, 2008 (TRC 2008b). 

The BLM identified a new lek on May 10, 2009, 

and this is located approximately 3.1 mi west of 

the WMWE project area (personal 

communication, May 11, 2009, with Nick Kaczor, 

BLM RSFO Biologist). Based on results of that 

survey, and BLM and WGFD data, the lek nearest 

to the WMWE project area is approximately 

3.1 mi west, and only one other lek is located 

within 4.0 mi of the project area. 

Greater sage-grouse likely breed and raise their 

broods in or adjacent to the project area. Fifty 

(22%) greater sage-grouse were recorded during 

spring 2008 surveys conducted in conjunction with 

this project (TRC 2009b). Observations occurred 

throughout all three months (April-June) of the 

spring surveys. One hundred and seventy-six 

(78%) individuals were observed during similar 

surveys in the fall (August-October). The majority 

of grouse observations during the spring and fall 

surveys were recorded in October (117 

individuals), followed by September (35) and 

August (27) (TRC 2009b). 

Mountain Plover. Mountain plovers are 

documented as breeding throughout Wyoming 

(WGFD 1999). Graul and Webster (1976), Parrish 

et al. (1993), and Knopf (1996) noted that 

mountain plover nests were found in areas with at 

least 30% bare ground, vegetation was short (<4 

inches) in spaced clumps or mats (e.g., cushion 

plants), and terrain was flat or less than 3% slope. 

Mountain plovers in the general project area are 

found in cushion plant communities and on 

windswept ridges (personal communication, 

June 10, 2002, with Lorraine Keith, BLM RSFO). 

Mountain plover breeding/nesting habitat is often 

associated with active prairie dog towns 

(Dinsmore 2003). In Colorado, the mountain 

plover diet is composed of 99.7% arthropods, with 

beetles, grasshoppers, crickets, and ants as the 

most important food items (Baldwin 1971). 

A portion of proposed project area is composed of 

greasewood fans and flats and basin exposed rock 

with areas that are relatively void of vegetation. 

These areas could provide suitable nesting and 

foraging habitat for mountain plover; however, no 

mountain plovers were observed during 21+ weeks 

of diurnal and nocturnal avian migration studies 

conducted in 2008 (TRC 2009b), and no mountain 

plover observations have been recorded in the 

vicinity of the proposed WMWE project area 

(WNDD 2009). 

Bald Eagle. Bald eagles require cliffs, large trees, 

or sheltered canyons associated with concentrated 

food sources (e.g., fisheries or waterfowl 

concentration areas) for nesting and/or roosting 

areas (Edwards 1969; Snow 1973; Call 1978; 

Steenhof 1978; Peterson 1986). Bald eagles 

forage over wide areas during the nonnesting 

season (i.e., fall and winter) and scavenge on 

animal carcasses such as pronghorn, deer, and elk. 

No bald eagle nests or winter roosts are known to 

occur in the proposed project area or immediate 

project area, and no observations were made 

during avian studies conducted in 2008 (TRC 

2008c, 2009b; WNDD 2009). However, the 

Green River, approximately 6.5 mi southwest of 

the proposed project, provides favorable nesting, 

roosting, and foraging habitat for bald eagles, and 
 

EA, White Mountain Wind Energy Project 3-27 

it is likely that individuals occasionally forage in 

or fly through the WMWE project area. 

Midget Faded Rattlesnake. The midget faded 

rattlesnake is currently considered a subspecies of 

the common western rattlesnake (Crotalus viridis). 

This species mainly occupies the Colorado Plateau 

of eastern Utah, western Colorado, and 

southwestern Wyoming on the Green River 

formation, typically below 7,000 ft in elevation. 

The midget faded rattlesnake is shy and inhabits 

rocky and arid basins. Exposed rocky outcrops 

and ledges are important habitat features because 

they provide safe hibernacula, escape cover, and 

thermal cover and have been identified as the main 

environmental limit to distribution and abundance 

(Travsky and Beauvais 2004). There are recorded 

occurrences of midget faded rattlesnake within the 

WMWE project area and vicinity (WNDD 2009). 

Cedar Rim Thistle. The Cedar Rim thistle is a 

perennial tap-rooted herb with stems up to 30 cm 

tall. The flowering and fruiting period for this 

species is June through July. This species occurs 

on barren slopes, fans, and draws on whitish-gray 

sandstone, chalk, tufaceous colluvium, or clay 

substrates derived from the split Rock, White 

River, Wagon Bed, Wind River, Green River, and 

Wasatch formations. Populations are found in 

sparsely vegetated openings within Wyoming big 

sagebrush grasslands at 5,800 to 7,500 ft (WNDD 

2000). There are no recorded occurrences within 

the WMWE project area, and the nearest known 

population of Cedar Rim thistle is approximately 

40.0 mi south of the WMWE project area (WNDD 

2009). However, the BLM has a historic record 

indicating an observation within 1.5 mi of the 

WMWE project area (personal communication, 

August 31, 2009, with Jim Glennon, BLM, 

RSFO). 

It should be noted that other BLM sensitive 

species such as ferruginous hawks, sagebrush 

obligate species, and BLM sensitive bat species 

are addressed in Section 3.12 of this EA. 

3.9 VEGETATION (INCLUDING INVASIVE 

SPECIES AND WETLANDS) 

The IAA for vegetation resources is the boundary 

of the level 12 HUC. A total of 19,828 acres 

(7.43%) of the 268,613-acre IAA has been 

disturbed, primarily by cities. 

The occurrence of individual species and plant 

communities depend on factors such as 

topography, parent rock material, elevation, 

aspect, and slope. These in turn influence 

moisture levels and solar radiation (Knight 1994; 

Young and Singleton 1977). 

Based on Wyoming Gap Analysis 1:100,000 scale 

mapping (Figure 3.6), three vegetation types occur 

within the proposed project area. Vegetation types 

include 11,452 acres (87%) of Wyoming big 

sagebrush community, 1,097 acres (8%) of 

greasewood fans and flats community, and 

616 acres (5%) of basin exposed rock/soil 

communities (Wyoming Gap Analysis 1996). 

These vegetation communities and species 

occurring in the proposed project area are common 

throughout the region. Vegetation within the 

Wyoming big sagebrush community consists 

primarily of Wyoming big sagebrush and 

rabbitbrush, with scattered bitterbrush, horsebush, 

and winterfat and an understory of grasses and 

forbs such as western wheatgrass, prairie 

junegrass, needle-and-thread grass, Sandberg 

bluegrass, broom snakeweed, and phlox. The 

greasewood fans and flats vegetation community 

is associated with drainages that flow west out of 

the project area (refer to Figure 3.6). Species 

occurring within this type are predominantly 

composed of greasewood and Gardener’s saltbush, 

with an understory of western wheatgrass, needleand-thread grass, alkali sacaton, Sandberg 

bluegrass, and cushion plant communities. The 

basin exposed rock areas are associated with the 

rim along White Mountain where the ground is 

windblown and vegetation is sparse. Gardner 

saltbush and cushion plant species such as phlox, 

sandwort, and buckwheats are the primary species 

occurring in this type. Pockets of mountain 

mahogany and antelope bitterbrush and scattered 

junipers occur in areas downslope of the rim 

EA, White Mountain Wind Energy Project 3-29 

where snow collects and provides additional 

moisture to support more mesic species. 

No riparian communities are identified by the 

Wyoming Gap Analysis; however, a review of 

digital NWI information (USFWS 2003) show the 

occurrence of a linear palustrine seasonally 

flooded wetland (PEMC) and two intermittent 

streams (R4SBA) located in the project area that 

could potentially support seasonal riparian areas 

(Figure 3.7). In addition, NWI data indicate the 

occurrence of several small playa areas (PUSA) 

(refer to Figure 3.7) scattered within the project 

area. The Green River Resource Management 

Plan (BLM 1997) stipulates a 500-ft protection 

buffer for riparian areas and a 100 ft-buffer for 

ephemeral channels. 

Federal agencies are directed by Executive Order 

13112, Invasive Species, to expand and coordinate 

efforts to prevent the introduction and spread of 

invasive plant species (noxious weeds) and to 

minimize the economic, ecological, and human 

health impacts that invasive species cause. Weed 

populations are generally found along main dirt 

roads and two-track roads, in areas of livestock 

concentration, and in areas of intense recreational 

use. The BLM says that recent rangeland health 

monitoring in the RSFO has documented 

significant increases in invader species throughout 

the uplands (BLM 2007). Motorized vehicles 

transporting seeds can be a major source of new 

infestations of weed species. Noxious weed and 

other invasive species have not been documented 

in the project area nor has the Sweetwater Weed 

and Pest Control sprayed for weeds along County 

Road 53 in 2008. The closest known area of 

noxious weeds (Lepidium latifolium), hoary cress 

(Cardaria spp.), and Canada thistle (Cirsium 

arvense) occurs along county roads near the Green 

River located 6.5 mi west of the project area 

(personal communication, February 5, 2009, with 

Gale Lamb, Supervisor, Sweetwater County Weed 

and Pest Control, McKinnon, Wyoming). 

3.10 VISUAL RESOURCES 

The IAA for visual resources is the project 

boundary plus a 20-mi buffer. A total of 

38,289 acres (3.26%) of the 1,175,515-acre IAA 

has been disturbed, primarily by cites. 

The BLM has initiated visual resource 

management (VRM) on the lands under its 

management in the proposed project area, with the 

overall objective to minimize visual resource 

impacts resulting from human activities. The 

VRM inventory process considers the scenic 

quality of the landscape, viewer sensitivity, and 

the distance from the viewer to the landscape. 

VRM relative value of the visual resource is 

indicated by one of four assigned classes. 

According to the BLM VRM objectives, areas 

with VRM Classes I and II are the most valued 

areas, Class III areas are of moderate value, and 

Class IV areas are of least value (Table 3.6). 

VRM Class I and II areas are managed with more 

restrictions on modification of the existing natural 

character than are the other VRM classes. 

The entire BLM RSFO, including the proposed 

project area, has been mapped for VRM (BLM 

1997). While the project area has been evaluated 

for VRM classifications, these classifications do 

not apply to private or state-managed lands. 

Approximately 85% (11,249 acres) of the 

proposed project area is within a Class IV VRM 

area. The remaining 15% (1,916 acres) of the 

proposed project area--the extreme southeastern 

portion and the northern portion of the proposed 

project area--is within an area mapped as a 

Class III VRM area (Figure 3.8). 

The project area is a feature landscape with Pilot 

Butte as the prominent landform. Feature 

landscapes are dominated by a feature or a group 

of feature objects in the distance to which the eye 

is drawn. Such landscapes are vulnerable to 

modification if located near the feature. The 

remainder of the project area consists of gently 

rolling hills with moderate visual variety in the 

surrounding landscape. It is a classic panoramic 

Wyoming landscape that creates a feeling of 

vastness and open space. It is framed by a 

backdrop of snow-covered mountains to the 

northeast and southwest, which enhance the scenic 

value of the lands in the project area. 

3-31 

1 

EA, White Mountain Wind Energy Project 

Table 3.6 BLM Visual Resource Management Class Objectives. 1 

Class Description 

I The objective of this class is to maintain a landscape setting that appears unaltered by 

humans. It is applied to wilderness areas, some natural areas, wild portions of the wild 

scenic rivers, and other similar situations where management activities are to be restricted. 

II The objective of this class is to design proposed alterations so as to retain the existing 

character of the landscape. The level of change to the characteristic landscape should be low. 

Management activities may be seen, but should not attract attention of the casual observer. 

Any changes must repeat the basic elements of form, line, color, and texture found in the 

predominant natural features of the characteristic landscape. 

II The objective of this class is to design proposed alterations so as to partially retain the 

existing character of the landscape. Contrasts to the basic elements (form, line, color, and 

texture) caused by a management activity may be evident and begin to attract attention in the 

characteristic landscape. However, the changes should remain subordinate to the existing 

characteristic landscape. Structures located in the foreground distance zone (0-1/2 mile) 

often create a contrast that exceeds the VRM class, even when designed to harmonize and 

blend with the characteristic landscape. This may be especially true when a distinctive 

architectural motif or style is designed. Approval by the District Manager is required on a 

case-by-case basis to determine whether the structure(s) meet the acceptable VRM class 

standards, and if not, whether they add acceptable visual variety to the landscape. 

IV The objective of this class is to provide for management activities which require major 

modification of the existing character of the landscape. Contrasts may attract attention and 

be a dominant feature of the landscape in terms of scale; however, the change should repeat 

the basic elements (form, line, color, and texture) inherent in the characteristic landscape. 

Structures located in the foreground distance zone (0-1/2 mile) often create a contrast that 

exceeds the VRM class, even when designed to harmonize and blend with the characteristic 

landscape. This may be especially true when a distinctive architectural motif or style is 

designed. Approval by the District Manager is required on a case-by-case basis to determine 

whether the structure(s) meet the acceptable VRM class standards, and if not, whether they 

add acceptable visual variety to the landscape. 

Source: BLM (1997). 

EA, White Mountain Wind Energy Project 3-33 

The Pilot Butte feature introduces a strong vertical 

line in an otherwise horizontal landform. This 

change in line is what makes the feature landscape 

most fragile. Apart from the Pilot Butte feature, 

the lines in the landscape are strongly horizontal in 

nature. They are formed by the shape of the hills 

and differences in concentrations of the 

vegetation. 

Vegetation on Pilot Butte is sparse, short, and 

minimal to nonexistent. Vegetation of the 

surrounding landscape is predominately sagebrush 

and short grasses. Sagebrush is by far the 

dominant vegetative species. For most of the year, 

the landscape has a strong gray color. There are 

subtle variations in color resulting from different 

concentrations, heights, and densities of the 

vegetation. During the spring and early summer, 

the sagebrush is a light gray-green color but 

usually by early August the vegetation matures 

and takes on a characteristic gray color that is 

dominant until the following spring. 

The texture of the land features of the landscape is 

mostly smooth with the exception of Pilot Butte, 

which introduces an extremely coarse point. 

Texture of the vegetation is coarse in the 

immediate foreground and medium to smooth at 

the middle distances. 

The area is substantially natural in character with 

few manmade structures. Within and immediately 

adjacent to the project area, there are existing gas 

pipeline and well facilities, three large 345-kV) 

transmission power lines with metal structures that 

run east to west through the northern section of 

the proposed project area, as well as one smaller 

(230-kV) transmission power line with wooden 

structures that runs east to west through the center 

of the project area (and just north of Pilot Butte), a 

microwave reflecting tower, TV and radio 

broadcasting towers, two unpaved county roads, 

and numerous two-track roads/trails. 

3.11 WILD HORSES 

The IAA for wild horses is the project boundary 

plus a 6.0-mi buffer. A total of 18,013 acres 

(9.13%) of the 197,273-acre IAA has been 

disturbed, primarily by cites. 

The proposed project is within the Rock Springs 

WHHMA, which encompasses approximately 

391,409 acres (Figure 3.9). 

The White Mountain WHHMA encompasses an 

area from I-80 north to the Big Sandy River and 

from U.S. Highway 191 west to the Green River. 

The estimated population of the White Mountain 

herd is approximately 306 horses based on direct 

counts of horses from flights conducted in May 

2009 followed by the June 2009 gather. The wild 

horses in the WHHMA were gathered to the low 

range Appropriate Management Level (AML) of 

215 horses in November 2007 (BLM 2007). The 

genetic diversity in the White Mountain herd is 

relatively high as long as herd populations are 

maintained at a level of greater than 100 animals 

(BLM 2007). 

The AML range for the WHHMA is 215 to 305 

wild horses as described in the Green River RMP. 

In addition, there is a Consent Decree for 

gathering wild horses above the AML. The range 

was utilized moderately to heavy by wild horses 

before they were gathered to the low range AML. 

Range conditions appear to be static in most areas 

that are inhabited by wild horses, and the 

population of wild horses in the herd unit has 

remained at or above objectives since the 

institution of wild horse gathering. 

3.12 WILDLIFE 

3.12.1 Big Game 

Three big game species--pronghorn antelope, mule 

deer, and elk--occur within the proposed project 

area. The population estimates for big game herds 

provided below are based on WGFD model 

estimates from the 2007 big game job completion 

reports (WGFD 2007). 

3.12.1.1 Pronghorn Antelope 

The IAA for pronghorn antelope is Hunt Area 96 

within the Sublette Herd Unit. A total of 

17,409 acres (2.84%) of the 612,496-acre 

cumulative IAA has been disturbed, primarily by 

roads and cites. 

EA, White Mountain Wind Energy Project 3-35 

Pronghorn antelope in the proposed project area 

belong to the Sublette Pronghorn Antelope Herd 

(Herd Unit 401, Hunt Area 96). The WGFD 

population objective for the Sublette Pronghorn 

Antelope Herd is 48,000 animals, and the 10-year 

average is 50,210 animals. The 2007 population 

was estimated at 62,200 animals, approximately 

29% above the population objective for this herd 

(WGFD 2007). Approximately 12,144 acres 

(92%) of the project area occurs in habitat the 

WGFD has designated as yearlong habitat, 1,021 

acres (8%) of the proposed project area occurs in 

habitat the WGFD has designated as crucial 

winter/ yearlong antelope range, which is located 

near the eastern ridge of the project boundary and 

the rim of White Mountain (Figure 3.10) (WGFD 

2006). The nearest pronghorn antelope severe 

winter relief habitat is located 4.0 mi southeast of 

the project area and east of Rock Springs (refer to 

Figure 3.10). There are no known migration 

corridors for pronghorn antelope in the WMWE 

project area. However, there are two corridors 

north of the WMWE project area (refer to 

Figure 3.10). 

3.12.1.2 Mule Deer 

The IAA for mule deer is the Steamboat Herd 

Unit. A total of 27,191 acres (1.03%) of the 

2,554,688-acre IAA has been disturbed, primarily 

by roads and major facilities. 

Mule deer in the proposed project area belong to 

the Steamboat Mule Deer Herd (Herd Unit 430, 

Hunt Area 131). The WGFD population objective 

for the Steamboat Mule Deer Herd is 4,000 

animals, and the 10-year average is 4,246 animals. 

The 2007 population was estimated at 4,540 

animals, approximately 13% above the population 

objective for this herd (WGFD 2007). 

Approximately 12,028 acres (91%) of the 

proposed project area occurs in habitat the WGFD 

has designated as yearlong mule deer range, and 

1,029 acres (8%) is designated as winter yearlong. 

The remaining 108 acres (1%) located in the 

northwest corner of the project area is designated 

as “out” under the WGFD habitat designations, 

meaning that this area is not part of any herd unit; 

this area does not contain enough animals to be 

important habitat or the habitats are of limited 

importance to this species (WGFD 2006) 

(Figure 3.11). No mule deer crucial winter ranges 

or parturition areas occur within the proposed 

project area. The nearest mule deer crucial range 

is located approximately 11.0 mi south of the 

proposed project (WGFD 2006). 

3.12.1.3 Elk 

The IAA for elk is the Steamboat Herd Unit. 

A total of 23,452 acres (0.93%) of the 

2,529,717-acre IAA has been disturbed, primarily 

by roads and major facilities. 

Elk in the proposed project area belong to the 

Steamboat Elk Herd (Herd Unit 426, Hunt 

Area 100). The WGFD population objective for 

the Steamboat Elk Deer Herd is 1,200 animals, 

and the 10-year average is 1,555 animals. The 

2007 population was estimated at 1,300 animals, 

approximately 8% above the population objective 

for this herd (WGFD 2007). Approximately 

11,559 acres (88%) of the project area occurs in 

habitat the WGFD has designated as 

spring/summer/fall habitat, 1,097 acres (8%) of the 

proposed project area occurs in habitat the WGFD 

has designated as winter/yearlong elk range 

(Figure 3.12). Approximately 509 acres (4%) of 

the western project area intersects the boundary of 

habitat designated as crucial winter/yearlong range 

(WGFD 2006) (refer to Figure 3.12). An elk 

parturition area is located 0.5 to 2.0 mi west of the 

project boundary. 

3.12.2 Small Mammals 

Typical predators known to occur or potentially 

occurring in the proposed project area are coyote, 

red fox, raccoon, long-tailed weasel, badger, mink, 

striped skunk, mountain lion, and bobcat. 

Lagomorph species include desert cottontail, 

mountain (Nuttall’s) cottontail, pygmy rabbit, and 

white-tailed jackrabbit. Squirrels known to occur 

or potentially occurring include least chipmunk, 

Richardson/Wyoming ground squirrel, goldenmantled ground squirrel, and thirteen-lined ground 

squirrel. Porcupine may also occur. Other rodents 

include four species of pocket gopher (northern, 

plains, Merriam’s, and Great Basin), two species 

of pocket mouse (olive-backed and northern), 



EA, White Mountain Wind Energy Project 3-39 

Ord’s kangaroo rat, beaver, deer mouse, northern 

grasshopper mouse, bushy-tailed woodrat, six 

species of vole (western, heather, meadow, longtailed, prairie, and sagebrush), and western 

jumping mouse (WGFD 2004). 

3.12.3 Bats 

The IAA for bats is the boundary of the level 

12 HUC. A total of 19,954 acres (7.43%) of the 

268,613-acre IAA has been disturbed, primarily by 

cities. Bats species potentially occurring or that 

may pass through the project area include western 

small-footed, long-legged, little brown, and silverhaired bats, and the BLM sensitive species longeared myotis, fringed myotis, spotted bat, and 

Townsend’s big-eared bat (WGFD 2004). An 

acoustical bat monitoring survey was conducted 

during late summer and early fall of 2008 within 

the proposed WMWE project area (TRC 2008d). 

The purpose of the acoustical bat monitoring study 

was to document bat migration in the project area 

and to provide baseline data that can be used to 

evaluate potential impacts to bats due to wind 

energy development in the project area. Species 

documented in the project area included hoary, 

silver-haired, and big brown bats; however, other 

species of bats with high-frequency calls (i.e., 

greater than 35 kilohertz [kHz]) that may occur are 

listed in Table 3.7 (TRC 2008d). 

There are no known winter hibernacula, diurnal 

roosting sites, or other features that are likely to 

attract bats located within or immediately adjacent 

to the proposed WMWE project area 

(TRC 2008d). In addition, surveys were 

conducted near the project area, and no winter 

hibernacula, diurnal roosting sites, or other 

features that are likely to attract bats are located 

within or immediately adjacent to the proposed 

WMWE project area (TRC 2008d). In addition, 

the WMWE project area does not contain 

topographic features likely to funnel migrating 

bats, and the project area lacks large tracts of 

forest cover, unlike high-mortality sites in the 

eastern U.S. However, the relatively large 

numbers of bat fatalities recently reported in 

northern Iowa (Jain 2005) and southwestern 

Alberta (Baerwald 2006) indicate that an open 

landscape is no guarantee of low mortality. Based 

on the topography and habitats of the WMWE 

project area, it is expected that a majority of bat 

mortalities associated with operation of the wind 

energy facility would occur as individuals migrate 

through the area. 

Table 3.7 Bat Species Determined from Range Maps as Likely to Occur Within the WMWE Project 

Area, Sorted by Call Frequency.1 

Bat Species with High-frequency Calls (≥35 kHz) Bat Species with Low-frequency Calls (<35 kHz) 

Common Name Scientific Name Common Name Scientific Name 

Western small-footed Myotis ciliolabrum Townsend’s big-eared bat Corynorhinus 

bat townsendii 

Western long-eared Myotis evotis Silver-haired bat 2, 3 Lasionycteris 

bat noctivagans 

Little brown bat Myotis lucifugus Hoary bat 2, 3 Lasiurus cinereus 

Long-legged bat Myotis volans Fringed bat Myotis thysanodes 

 Big brown bat 3 Eptesicus fuscus 

1 From Harvey et al. (1999) and Bat Conservation International, Inc. (2002). 2

 Long-distance migrant. 

3 Species documented in fatality studies at other U.S. wind energy facilities. 
3-40 EA, White Mountain Wind Energy Project 

3.12.4 Raptors 

The IAA for raptors is the project area plus a 

14.5-mi buffer. A total of 29,676 acres (4.28%) of 

the 693,604-acre IAA has been directly disturbed, 

primarily by the cities of Rock Springs, Green 

River, and surrounding developments. 

Raptor species most likely to occur or potentially 

occurring within the WMWE project area and 

immediate vicinity include (based on habitat 

preferences) golden eagle; northern harrier; 

Swainson’s, red-tailed, ferruginous, and roughlegged hawks; American kestrel; prairie falcon; 

and great horned, burrowing, and short-eared 

owls. However, osprey; bald eagle; sharp-shinned 

and Cooper’s hawks; northern goshawk; merlin; 

and barn, long-eared, and northern saw-whet owls 

also occur within the project area latilong and may 

occasionally pass through the project area (WGFD 

2004). 

In conjunction with the WMWE Project, a raptor 

nest survey was conducted within a 213-mi2 

survey area that includes the project area and 

surrounding vicinity, particularly to the west and 

south (TRC 2008c). The survey was conducted by 

helicopter between April 24 and 26, 2008. During 

the survey, 245 raptor and corvid nests were 

recorded, including 10 American kestrel, 

27 common raven, 19 ferruginous hawk, 

67 golden eagle, three great horned owl, 18 prairie 

falcon, 18 red-tailed hawk, and 83 nests of 

unidentified species, most of which likely were 

golden eagle or red-tailed hawk nests. Fifty (20%) 

of the nests were occupied in 2008, and an 

additional seven nests were recorded as having an 

unidentified activity status (TRC 2008c). 

Figure 3.13 illustrates the general locations of the 

2008 active raptor nests and the season buffers for 

each nest. 

The project area and surrounding vicinity provide 

suitable foraging habitat for the raptor species 

nesting in the area, as well as for migrants that 

may pass through. In addition, bald eagles and 

rough-legged hawks may winter in and/or adjacent 

to the area, with small mammals and road- or 

winter-killed big game providing a food source for 

those species, as well as resident raptor species. 

3.12.5 Upland Game Birds 

The IAA for upland game birds is the area north 

of Bitter Creek, east of the Green River, south 

of the Big Sandy River to Farson, then east to 

Killpecker Sand. A total of 10,401 (1.91%) of the 

545,351-acre IAA has been disturbed, primarily by 

roads. 

The WMWE project area is located entirely within 

the Eden UGBMA #7, and the Flaming Gorge 

UGBMA #6 extends to within approximately 

1.0 mi of the southeastern corner of the project 

area (WGFD 2009) (refer to Figure 3.4). WGFD 

(2004) lists chukar and BLM sensitive species 

(refer to Figure 3.4) blue grouse, mourning dove, 

and greater sage-grouse as breeding within the 

WMWE project area latilong, and gray partridge 

and ruffed grouse are listed as occasional visitors 

within the latilong. However, based on the habitat 

preferences of these species, only chukar, greater 

sage-grouse, and mourning dove were close and 

within the project area in 2008 (TRC 2009b). 

Chukar was observed in the rocky shrublands west 

of the project area during raptor nesting surveys 

conducted for this project (TRC 2008c, 2009b). 

Although their presence in the project area is 

likely to be infrequent based on their preferred 

habitat of rocky shrublands and foothills, chukar 

may frequent areas to the west and may 

occasionally fly through the project area. 

Mourning doves are found in a wide variety of 

habitats ranging from urban and disturbed areas to 

deserts (near water), agricultural areas, and open 

woodlands (Erlich et al. 1988). They are summer 

residents in Wyoming and are considered 

abundant throughout the state (WGFD 2004). 

During spring and fall point count surveys 

conducted in conjunction with this project, only 

two mourning doves were observed; however, the 

species is common in the general area and are 

known to occur within or adjacent to the project 

area (TRC 2009b). 

Greater sage-grouse is a BLM sensitive species 

and is discussed in Section 3.8.2. 

3-42 EA, White Mountain Wind Energy Project 

3.12.6 Migratory Birds 

The IAA for migratory birds is the boundary of the 

level 12 HUC. A total of 19,954 acres (7.43%) of 

the 268,613-acre IAA has been disturbed, 

primarily by cities. 

During the spring and fall of 2008, avian point 

count and use surveys of the WMWE project area 

were conducted in conjunction with the proposed 

project. Avian surveys were conducted 2 days 

each week for 10 weeks during the spring survey 

period (April 14 through June 17, 2008) and for 

11 weeks during the fall survey period (August 17 

through October 27, 2008). Nine survey plots for 

RLB and 18 survey plots for PSB were established 

in the WMWE project area. Flight heights of each 

species were recorded at each of the avian survey 

plots. Nocturnal observation surveys were 

conducted at seven of the nine RLB point count 

plots. The nocturnal surveys were conducted once 

a week from May 6, 2008, through June 16, 2008, 

during spring surveys and from August 17, 2008, 

through October 26, 2008, during the fall surveys. 

A comprehensive description of survey methods 

and results can be found in TRC (2009b). 

Table 3.8 provides a list of all bird species 

observed during those studies and their likely 

occurrence classification within the latilong. 

Although the list is not comprehensive for all birds 

that might use or fly through the vicinity, it is 

indicative of the species that most likely and 

commonly occur in the project area. Since there 

are no permanent water bodies within the project 

area, it is unlikely that waterfowl and shorebirds 

typically would nest in the area, although birds 

nesting along the Green River to the east, as well 

as migrating birds, may occasionally pass through 

the area. Avian diversity for the WMWE project 

area was slightly higher during the fall than spring 

(at least 14 species vs. 12 species). Equal numbers 

of PSB species were recorded in the WMWE 

project area for spring and fall (30 species each 

season). Horned lark was the most abundant of 

the species documented in the WMWE project 

area during both spring and fall. PSB use in the 

project area for all birds combined in the spring 

averaged 250.65 birds/km2

/8-minute observation 

period compared to 123.67 in the fall (TRC 

2009b). Use for both seasons combined was 

182.49 birds/km2

/8-minute observation period. 

Based on the 2008 avian daytime surveys, the 

project area did not appear to serve as a migratory 

corridor for birds, and the paucity of birds heard 

and observed during the nocturnal surveys may 

indicate a relatively low risk posed to nightmigrating birds that may fly over the project area; 

however, in the absence of calling, small birds 

flying would have been difficult to detect during 

the nocturnal surveys given their small size and 

the limitations of the equipment used. The project 

area did not appear to serve as a major migratory 

stopover site. During spring, the highest numbers 

of birds were recorded in May with the peak 

survey occurring during the week of May 13. 

During the fall surveys, the highest number of 

birds occurred during the first week of surveys 

(August 18), and both the numbers of individuals 

and the numbers of species dropped notably 

thereafter. This suggests that many of the 

migrants may have moved out of the area before 

or concurrent with the initiation of the fall surveys 

in mid-August. All migratory birds are protected 

by the Migratory Bird Treaty Act (16 U.S.C. 

701-715). 
EA, White Mountain Wind Energy Project 3-43 

Table 3.8 Avian Species Recorded Within the WMWE Project Area and Vicinity During 2008 

Project-related Studies. 

Common Name Scientific Name 

Dorn and Dorn (1999) 

Classification1 

WGFD (2004) 

Classification2 

Chukar Alectoris chukar R B 

Double-crested cormorant Phalacrocorax auritus Y B 

Turkey vulture Cathartes aura b B 

Canada goose Branta canadensis R B 

Northern harrier Cyrcus cyaneus R B 

Red-tailed hawk Buteo jamaicensis R B 

Ferruginous hawk Buteo regalis B B 

Rough-legged hawk Buteo lagopus W O 

Golden eagle Aquila chrysetos r B 

American kestrel Falco sparverius R B 

Merlin Falco columbarius R B 

Prairie falcon Falco mexicanus B B 

Greater sage-grouse Centrocercus urophaisianus B B 

Mourning dove Zenaida macroura B B 

Great horned owl Bubo virginianus r B 

Common nighthawk Chordeiles minor b B 

Common poorwill Phalaenoptilus nuttallii b B 

Broad-tailed hummingbird Selasphorus platycercus b b 

Northern flicker Colaptes auratus R B 

Olive-sided flycatcher Contopus cooperi b b 

Western wood-pewee Contopus sordidulus b B 

Least flycatcher Empidonax minimus -- --

Say’s phoebe Sayornis saya B B 

Loggerhead shrike Lanius ludovicianus b B 

Black-billed magpie Pica pica R B 

Common raven Corvus corax r b 

Horned lark Eremophila alpestris R B 

Tree swallow Tachycineta bicolor B B 

Cliff swallow Petrochelidon pyrrhonota B B 

Mountain chickadee Poecile gambeli R B 

Red-breasted nuthatch Sitta canadensis B b 

Rock wren Salpinctes obsoletus b B 

Bewick’s wren Thryomanes bewickii B B 

House wren Troglodytes aedon B B 

Ruby-crowned kinglet Regulus calendula B b 

Blue-gray gnatcatcher Polioptila caerulea B B 
3-44 EA, White Mountain Wind Energy Project 

Table 3.8 (Continued) 

Common Name Scientific Name 

Dorn and Dorn (1999) 

Classification1 

WGFD (2004) 

Classification2 

Mountain bluebird Sialia currucoides B B 

Townsend’s solitaire Myadestes townsendi W b 

Hermit thrush Catharus guttatus b B 

American robin Turdus migratorius R B 

Sage thrasher Oreoscoptes montanus b B 

Virginia’s warbler Vermivora virginiae b B* 

Yellow-rumped warbler Dendroica coronata auduboni b B 

(Audubon’s) 

Common yellowthroat Geothlypis trichas b b 

Western tanager Piranga ludoviciana b b 

Green-tailed towhee Pipilo chlorurus B B 

Chipping sparrow Spizella passerina B B 

Brewer’s sparrow Spizella breweri B B 

Vesper sparrow Pooecetes gramineus b B 

Sage sparrow Amphispiza belli B B 

Grasshopper sparrow Ammodramus savannarum b b 

Fox sparrow Passerella iliaca B B 

Song sparrow Melospiza melodia r B 

Dark-eyed junco Junco hyemalis hyemalis M B 

(slate-colored) 

Dark-eyed junco Junco hyemalis caniceps B B 

(gray-headed) 

Western meadowlark Sturnella neglecta B B 

Brewer’s blackbird Euphagus cyanocephalus b B 

Brown-headed cowbird Molothrus ater b B 

1 Based on Dorn and Dorn (1999) classifications for the project area latilong. R = observed in summer and 

winter, breeding confirmed; r = observed in summer and winter, breeding suspected but unconfirmed; 

B = observed in summer, breeding confirmed; b = observed in summer, breeding suspected but unconfirmed; 

Y = observed in winter and summer, probably nonbreeding; W = observed in winter; m = observed in migration 

season; -- = no classification. 2 Based on WGFD (2004) classifications for the project area latilong. B = nest or young dependent on parent 

birds was observed; b = circumstantial evidence of nesting; * = record has been reviewed and accepted by the 

Wyoming Bird Records Committee; O = the species has been observed, but there was no evidence of nesting. 

The observation may have been recorded during any season of the year, but observations are most likely to 

correspond with seasonal status listed in Table 1 of WGFD (2004). 
EA, White Mountain Wind Energy Project 4-1 

4.0 ENVIRONMENTAL CONSEQUENCES 

In accordance with NEPA (40 CFR 1502.16), this 

chapter of the EA discusses the potential 

environmental consequences of each phase (i.e., 

construction, O&M, and decommissioning) of the 

Proposed Action, Alternative A, and the No 

Action Alternative on each of the affected 

resources. An environmental impact is defined as 

a change in the quality or quantity of a given 

resource due to a modification in the existing 

environment resulting from project related 

activities. Impacts may be beneficial or adverse, 

may be a primary result (direct) or secondary 

result (indirect) of an action, and may be 

permanent and long term or temporary and of 

short duration. Impacts may vary in degree from a 

slightly discernible change to a total change in the 

environment. This impact assessment assumes 

that all 240 wind turbines would be constructed 

and all design features described in the Proposed 

Action would be successfully implemented. If 

such measures were not implemented, additional 

adverse impacts may occur. 

Residual impacts are impacts resulting from the 

Proposed Action after application of appropriate 

design features and/or BMPs (BLM 2008). These 

impacts would remain for some period of time but 

would eventually be ameliorated by natural 

conditions and would not be permanent. For 

example, increased soil erosion would be reduced 

as disturbed soils are stabilized and native 

vegetation is planted and becomes re-established. 

Cumulative impacts result from the incremental 

effects of an action added to other past, present, 

and reasonably foreseeable future actions 

(RFFAs), regardless of who is responsible for such 

actions. Cumulative impacts may result from 

individually minor but collectively significant 

actions occurring over a period of time (40 CFR 

1508.7). The boundaries of individual IAAs for 

this EA are based on the specific resource being 

discussed and evaluated. 

Disturbance due to existing and authorized 

activities, as well as RFFAs, have been quantified 

using data input into a computerized geographic 

information system. RFFAs considered in the 

general area include the TransWest Express, 

Gateway West, and Gateway South Transmission 

Line Projects; the Aspen Mountain and Lonesome 

Bronco Wind Energy Projects; Questar Overthrust 

Loop Expansion Project; one possible route of the 

Regional Watershed Supply Pipeline Project; 

currently approved oil and gas development; and 

the Proposed Action (Figure 4.1). For the purpose 

of the analysis, cumulative disturbance is based on 

estimated life-of-project disturbances (189 acres 

for the Proposed Action and for RFFAs). 

4.1 AIR QUALITY AND CLIMATE 

4.1.1 Proposed Action 

4.1.1.1 Introduction 

Project sources of air emissions, pollutants 

emitted, and factors contributing to the magnitude 

of project emissions are presented in Table 4.1. 

Construction, operation, and decommissioning 

activities would be required to comply with the 

provisions of Wyoming Environmental Quality Act 

(W.S. 35-11-201 et seq.) and the Wyoming State 

Implementation Plan and other applicable state 

and county regulations. 

Possible impacts to air quality as a result of the 

project would occur during the construction, 

O&M, and decommissioning phases due to shortterm increases in particulates (e.g., dust from the 

excavation of wind turbine foundations and 

collector system, construction of access roads, 

operation of the mobile concrete batch plant and 

rock crusher, vehicle traffic) and tailpipe 

emissions from construction and O&M vehicles 

and combustion emissions from generators and 

engines. 

4.1.1.2 Construction Phase 

Construction of access roads and preparation of 

turbine sites and transmission line structure sites 

would involve the use of earth-moving equipment, 

including loaders, various-sized bulldozers, and 

backhoes. Delivery of turbine components and 

EA, White Mountain Wind Energy Project 4-3 

Table 4.1 Project Emission Profile. 

Source/Activity Pollutant Basis for Emission Factors 

Vehicular traffic and construction CO, NOx, VOCs, PM2.5 and PM10, Vehicle-mile traveled (VMT) 

and reclamation equipment SO2, air toxics 

operation 

Fugitive dust from vehicles PM2.5 and PM10 VMT, wet days, control factor, 

traveling on unpaved roads road conditions, tire adjustment 

Fugitive dust from operation of PM2.5 and PM10 Volume of fuel used 

construction equipment 

Operation of concrete batch plant PM2.5, PM10, CO, NOx, VOCs, SO2, Volume of fuel used or hours of 

HAP operations 

transmission line components, as well as electrical 

cable and other ancillary equipment and supplies, 

would involve the use of delivery trucks, semis, 

and assembly cranes over the same time frame. 

Emissions from these activities include fugitive 

dust (e.g., PM2.5 and PM10) and tailpipe emissions 

(CO, NOx, VOCs, particulates, SO2, and HAPs). 

Approximately 865 acres of soil would be initially 

disturbed for construction of the WMWE Project. 

Fugitive dust from construction activities and 

travel on project roads would be controlled. In 

general, water would be used for dust suppression. 

In the event that additional dust control is 

necessary, other commercially available dust 

suppressants may be utilized, including chloride 

compounds, lignin compounds, or tree resin 

emulsion products. 

Activities associated with foundation installation 

include grading, excavating, and concrete batch 

plant installation and operation. The concrete 

batch plant would not have electrical service, so an 

on-site diesel generator would supply power. This 

stage of construction is anticipated to last for 

approximately 6 months for each of the 3-4 

phases. Emissions from these activities include 

fugitive dust, tailpipe emissions, concrete batch 

plant emissions (particulates), and on-site diesel 

generator emissions. Emissions from the mobile 

concrete batch plant are detailed in Table 4.2 and 

would be permitted through the WDEQ/AQD. 

The air quality permit would provide enforceable 

air pollution mitigation measures to reduce air 

emission impacts from operation of the mobile 

concrete batch plant. Tailpipe emissions, the 

relatively small emission levels from the batch 

plant, and fugitive dust emissions would not cause 

a violation of ambient air quality standards or 

degradation of regional air quality. 

Implementation of environmental protection 

measures during construction, including the 

utilization of dust abatement techniques, posting 

and enforcing speed limits, and covering or 

watering batch plant storage piles, would 

minimize impacts on air quality due to fugitive 

dust. 

Teton is committed to controlling air quality 

emissions; however, some localized increases in 

dust levels would be unavoidable. To minimize 

these levels, Teton would use water or other dust 

control measures on heavily used roads and areas. 

Traffic speed would also be held to appropriate 

levels. In addition, disturbed areas would be 

revegetated as soon as possible following 

disturbance. To limit tailpipe emissions, engines 

would be maintained in accordance with 

manufacturer recommendations. 

In addition to the regulated criteria pollutants, 

minor quantities of GHG gases would be emitted 

as a result of fuel combustion from vehicles and 

other mobile equipment. GHG emissions from 

these sources would primarily be in the form of 

CO2. CO2 is not a currently regulated pollutant 
4-4 EA, White Mountain Wind Energy Project 

Table 4.2 Potential Air Quality Emissions from Mobile Concrete Batch Plant Emissions, Proposed

 Action. 

Pollutant Mobile Concrete Patch Plant 1 (tons) Generator Set 2 (tons) Total Emissions (tons) 

VOCs N/A 0.74 0.74 

NOx N/A 13.68 13.68 

CO N/A 5.78 5.78 

PM10 3.03 0.743

 3.77 

TSP 4

 10.08 0.743 10.82 

SO2 N/A 0.42 0.42 

HAP 5

 n/a <0.1 <0.1 

1 Mobile concrete batch plant output for the entire project is estimated at 72,000 yd3

 of concrete. 

Emission estimates utilizing EPA’s AP-42, Volume 1, 5th edition, Chapter 11.12, Concrete Batching, Batch 

Plant Emissions life of project calculated as Truck Mix Loading with no controls. 2 Mobile concrete batch plant generator emissions calculated based on EPA’s AP-42, Volume 1, 5th Edition, 

Chapter 3.4 Large Stationary Diesel and All Stationary Dual-fuel Engines life of project. Teton anticipates that 

a 600-kilowatt diesel engine would supply power to the batch plant. Emissions calculated for 2,324 hours for a 

905-British horsepower diesel engine. 3 For a mobile concrete batch plant diesel generator, it is assumed that 100% of the particulate emissions will be

 PM10 size. 4 TSP = total suspended particles. 5 HAP = hazardous air pollutants. 

and methods for quantifying and assessing GHG 

impacts are not readily available. GHG emissions 

from the construction phase of this project, 

primarily CO2, would be short in duration (3-4 

years) and of such minor quantities as to have no 

measurable effect on climate change. 

4.1.1.3 O&M Phase 

Daily O&M activities that would contribute to a 

limited amount of air emissions include personnel 

access, occasional road maintenance activities, 

ongoing reclamation/revegetation activities, and 

infrequent turbine replacement activities. 

In addition to the regulated criteria pollutants, 

minor quantities of GHG gases would be emitted 

as a result of fuel combustion from vehicles and 

mobile equipment. GHG emissions from these 

sources would primarily be in the form of CO2. 

CO2 is not a currently regulated pollutant and 

basis, GHG emissions during the O&M phase of 

this project, primarily CO2, would be of such 

minor quantities as to have no measurable effect 

on climate change. 

4.1.1.4 Decommissioning Phase 

Decommissioning activities are anticipated to be 

similar to construction activities for vehicle traffic, 

and a limited amount of heavy equipment 

operation such as the lifting crane would be used. 

Only a limited amount of construction activity 

would occur compared to the initial construction 

activity. The decommissioning effort may need to 

re-establish access roads to haul out facility 

components. Additional decommissioning air 

quality impacts could be driven by site 

reclamation activities. Decommissioning air 

quality impacts are expected to be similar in nature 

to construction activities, but of a much lesser 

magnitude. 

methods for quantifying and assessing GHG In addition to the regulated criteria pollutants, impacts are not readily available. On an annual minor quantities of GHG gases would be emitted 
EA, White Mountain Wind Energy Project 4-5 

as a result of fuel combustion from vehicles and 

mobile equipment. GHG emissions from these 

sources would primarily be in the form of CO2. 

CO2 is not a regulated pollutant and methods for 

quantifying and assessing GHG impacts are not 

readily available. GHG emissions from 

the decommissioning phase of this project, 

primarily CO2, would be short in duration 

(3-4 years) and of such minor quantities as to have 

no measurable effect on climate change. 

4.1.2 Alternative A - Development Only on 

Privately Owned Lands 

Potential impacts to air quality resources under 

Alternative A during the construction, O&M, and 

decommissioning phases would be similar in the 

type of impacts (e.g., fugitive dust and tail pipe 

emissions from construction activities and vehicle 

traffic and operation of the mobile concrete batch 

plant). However, because this alternative would 

involve the installation of 170 wind turbines on 

privately owned land, it is expected that only 

about 70% of the total air quality emissions 

expected under the Proposed Action would result 

from implementation of Alternative A. This also 

applies to potential emissions from the mobile 

concrete batch plant under Alternative A, and the 

potential emissions from the mobile concrete batch 

plant are presented in Table 4.3. The potential air 

quality emissions under Alternative A would also 

occur in the same sequence and timing as 

described under the Proposed Action (e.g., 

construction, O&M, and decommissioning 

phases). 

4.1.3 No Action Alternatives 

Under the No Action Alternative, the proposed 

wind energy facility would not be authorized nor 

approved. No ground would be disturbed, and no 

impacts to the existing physical or biological 

environment would take place beyond those that 

already exist. 

Table 4.3 Potential Air Quality Emissions from the Mobile Concrete Batch Plant, Alternative A. 

Pollutant Mobile Concrete Patch Plant1 (tons) Generator Set2 (tons) Total Emissions (tons) 

VOCs N/A 0.52 0.52 

NOx N/A 9.58 9.58 

CO N/A 4.05 4.05 

PM10 2.12 0.523

 2.64 

TSP 4

 7.06 0.523 7.58 

SO2 N/A 0.29 0.29 

HAP 5

 n/a <0.1 <0.1 

1 Mobile concrete batch plant output for the entire project estimated at 50,400 yd3 of concrete. Emission 

estimates utilizing EPA’s AP-42, Volume 1, 5th edition, Chapter 11.12, Concrete Batching, Batch Plant 

Emissions life of project calculated as Truck Mix Loading with no controls. 2 Mobile concrete batch plant generator emissions calculated based on EPA’s AP-42, Volume 1, 5th Edition, 

Chapter 3.4 Large Stationary Diesel and All Stationary Dual-fuel Engines. Teton anticipates that a 600-kW 

diesel engine would supply power to the batch plant. Emissions life of project calculated for 1,627 hours for a 

905-British horsepower diesel engine. 3 For a mobile concrete batch plant diesel generator, it is assumed that 100% of the particulate emissions will be 

PM10 size. 4 TSP = total suspended particles. 5 HAP = hazardous air pollutants. 
4-6 EA, White Mountain Wind Energy Project 

As discussed in Chapter 1 of this EA, the DOE 

predicts that the demand for the electrical energy 

will continue to rise (DOE 2009). If the No 

Action Alternative is selected and the WMWE 

project is not constructed, the electricity that 

would have been produced by this project would 

eventually have to be produced by other electric 

generation facilities such a fossil fuel plant (fueled 

by coal, natural gas, or petroleum), nuclear power 

plants, or other forms of renewable power plants 

(e.g., hydroelectric, solar, or other wind energy). 

As a result, it is important to consider that if the 

No Action Alternative is selected and the WMWE 

project is not constructed, it is possible that air 

quality could be adversely impacted if a fossil fuel 

source of electric generation is eventually 

constructed as the form of replacement electricity 

production. Table 4.4 illustrates, air pollutant 

emissions from typical electric generating 

facilities in Wyoming. This table also illustrates 

that air pollutant emissions from electric 

generation using fossil fuels are orders of 

magnitude greater than emissions from electric 

generation from renewable wind power. 

The Proposed Action would actually result in 

offsetting emissions of criteria pollutants, HAPs, 

aerosols, and GHG emissions when compared to 

other forms of energy production. The proposed 

project would provide a maximum of 360 MW of 

electric generating capacity (approximately 1 

million MW-hours annually) with essentially zero 

air emissions. If this energy demand is not met by 

nuclear power or other forms of renewable energy 

(such as wind, solar, or hydroelectric generation) 

then the demand would likely be met through 

other electric generating facilities fueled by coal or 

natural gas fired power plants and there would be 

a corresponding increase in air pollutant 

emissions. 

4.1.4 Residual Impacts 

Under the Proposed Action, the single largest 

pollutant would likely be particular matter (i.e., 

dust) in the form of total suspended particulates 

and particulate matter (<10μg) (PM10 and PM2.5) 

generated by vehicle traffic, excavations, and other 

ground disturbing activities. In addition, there 

would be tailpipe emissions such as CO, NOx, 

VOCs, PM10, PM2.5, SO2, and HAPs from vehicles 

and the operation of the mobile concrete batch 

plant. Teton is committed to controlling air 

quality emissions; however, some localized 

increases in dust levels would be unavoidable. To 

minimize these levels, Teton would use water or 

other dust control measures on heavily used roads 

and areas. Traffic speed would also be held to 

appropriate levels. In addition, disturbed 

areas would be revegetated as soon as 

possible following disturbance. To limit 

tailpipe emissions, engines would be maintained in 

accordance with manufacturer recommendations. 

In addition to the regulated criteria pollutants, 

minor quantities of GHG gases would be emitted 

as a result of fuel combustion from vehicles and 

other mobile equipment. GHG emissions from 

these sources would primarily be in the form 

of CO2. CO2 is not a currently regulated 

pollutant and methods for quantifying and 

assessing GHG impacts are not readily available. 

GHG emissions from the construction, O&M, and 

decommissioning phases of this project, primarily 

CO2, would be of such minor quantities as to have 

no measurable effect on climate change. 

4.1.5 Cumulative Impacts 

Potential cumulative emissions identified as a 

concern for the Proposed Action include emissions 

of PM, CO, SO2, NOx, VOCs, and HAPs from 

sources that are located within approximately 

31 mi of the Proposed Action and for which 

emissions information is available. 

The largest concentrations of PM, CO, SO2, NOx, 

VOCs, and HAP emissions would likely occur 

during the construction phase of this project (a 3­

to 4-year period of time) and would be associated 

with ground-disturbing activities and the operation 

of mobile equipment, including the temporary 

concrete batch plant. Emissions would then be 

reduced during the subsequent O&M phase and 

decommissioning phase. The cumulative impacts 

of changes in these pollutant concentrations are 

likely to have minimal effect on the near-field, 

far-field, and cumulative concentrations of these 

pollutants. 
4-7 

1 

EA, White Mountain Wind Energy Project 

Table 4.4 Comparison of Annual Air Emissions from Wyoming Electric Generation Sources. 

Facility Name Source/Unit Type Fuel Type 

Gross Load 

(MW-hr) 

SO2 

(tons/yr) 

NOx 

(tons/yr) 

CO2 

(tons/yr) 

Dave 

Johnston 1 

Electric Utility / 

Cell burner boiler 

Coal 1.9 million 7,476 5,302 2,172,269 

Naughton 1 Electric Utility / 

Tangentially fired 

Coal 1.3 million 7,268 3,606 1,369,757 

Wygen II 1 Electric Utility / dry 

bottom wall fired 

Coal 778,955 221 270 911,362 

boiler 

Neil Simpson 

II 1 

Electric Utility / 

Combustion turbine 

Natural gas 35,292 0.1 13.8 21,075 

Teton 

(WMWE) 

Proposed electric 

generation / wind 

turbine 

Wind 1.0 million Negligible Negligible Negligible 

Source for coal and gas emissions: USEPA Clean Air Markets website: http://camddataandmaps.epa.gov/gdm/ 

Far-field cumulative effects have been previously 

presented utilizing the extensive modeling results 

performed for the Jonah Infill Drilling Project 

(TRC 2006). The cumulative impacts assessment 

for the Jonah Infill Drilling project reported that: 

• Far-field cumulative pollutant 

concentrations are all below NAAQS and 

WAAQS, as well as PSD Class I and II 

increments. 

• Cumulative visibility impacts on PSD 

Class I and sensitive Class II areas are 

projected to impact visibility in the 

Bridger Wilderness Area (BLM 2006). 

• Contributions to cumulative far-field 

visibility impacts from the Proposed 

Action are anticipated to be insignificant 

due to the distance between the project 

area and the Bridger Wilderness. 

Cumulative impacts on air quality with the 

addition of this project to the airshed, are likely to 

be negligible over the life of the project. The 

impacts of emissions from fugitive dust and 

combustion sources during the construction, 

O&M, and decommissioning phase are minor and 

air emissions from wind generation of electricity 

are near zero. 

4.2 CULTURAL RESOURCES (INCLUDING 

NATIVE AMERICAN CONCERNS) 

Direct and/or indirect impacts to historic 

properties (NRHP-eligible or listed cultural 

resources) can result in one of three possible 

effects as defined by 36 CFR 800 and 

implemented under the State Protocol between the 

BLM Wyoming and the Wyoming SHPO (2006): 

• A “No Effect” determination is made if 

there are no historic properties present, or 

if they are present but would not be 

affected by the undertaking, or if a 

proposed project would not be visible 

from the historic property and there is no 

contrast between the project and the 

setting. 

• A “No Adverse Effect” determination is 

made if a proposed project would cause 

effects to a historic property, but the 

effects would not diminish the aspects of 

integrity nor the characteristics that make 

the property eligible for listing on the 

NRHP as defined in 36 CFR 800.5(b). If 

a proposed project would be visible, but 

there is weak contrast, a determination of 
4-8 EA, White Mountain Wind Energy Project 

“No Adverse Effect” is made. A “Weak 

Contrast” occurs when the proposed 

project elements, or portions of the 

elements, can be seen but would not 

dominate the setting or attract the attention 

of the casual observer because the basic 

elements of form, line, color and texture 

found in the setting are repeated in the 

project’s physical elements (BLM and 

SHPO 2006, Appendix C). 

• An “Adverse Effect” determination is 

found when an undertaking may alter, 

directly or indirectly, any of the 

characteristics of a historic property that 

qualify the property for inclusion in the 

NRHP in a manner that would diminish 

the integrity of the property’s location, 

design, setting, materials, workmanship, 

feeling, or association. Consideration is 

given to all qualifying characteristics of a 

historic property, including those that may 

have been identified subsequent to the 

original evaluation of the property’s 

eligibility for the NRHP. If a proposed 

project would be visible and there is 

moderate or strong contrast, a 

determination of “Adverse Effect” is 

made. A “Moderate Contrast” occurs 

when the proposed project elements, or 

portions of the elements, begin to attract 

attention and begin to dominate the 

characteristic landscape. A “Strong 

Contrast” occurs when the proposed 

project elements, or portions of the 

elements, demand attention, cannot be 

overlooked, and are dominant on the 

landscape. Adverse effects may include 

reasonably foreseeable effects caused by 

the undertaking that may occur later in 

time, be farther removed in distance, or be 

cumulative (36 CFR 800.5(a)(1)). 

Resolution of adverse effects would occur through 

a BLM/SHPO-approved Data Recovery Plan 

and/or with a Programmatic Agreement (PA) 

between Teton, the BLM, the SHPO, and other 

interested parties. A Data Recovery Plan is 

typically used if the historic property is eligible for 

inclusion in the NRHP under Criterion D only, and 

the adverse effect would be minimized by data 

recovery. A PA is used if there are historic 

properties within the APE that would be adversely 

affected and are eligible under National Register 

Criteria A, B, or C. 

4.2.1 Proposed Action 

4.2.1.1 Effects to Cultural Resources Within the 

APE for Direct Effects 

A Class III cultural resource inventory of 

2,650 acres of BLM-administered surface, 

preceded by background research, indicates that 

there is one prehistoric site eligible for the NRHP 

under Criterion D and two NRHP-unevaluated 

sites within the inventoried portion of the project 

area (Fleming et al. 2009a). Project effects to the 

one known NRHP-eligible prehistoric site within 

the inventoried area would be negligible because 

effects would be avoided or mitigated. The two 

unevaluated sites within the inventoried area, 

whose NRHP-eligibility status has not been 

determined, would be treated as if they were 

eligible for the NRHP, and would be avoided or 

mitigated. 

However, because only 20% of the total 

13,165 acres within the project area has been 

inventoried, additional cultural resources may be 

discovered on state-owned or private property or 

public land outside the ROW. Therefore, 

additional cultural resource inventories would be 

conducted on those lands that will be directly 

disturbed by the Proposed Action. If eligible or 

listed cultural resources, including portions of any 

rural historic or traditional cultural landscapes 

cannot be avoided, Teton would resolve the 

adverse effects through a BLM/SHPO-approved 

Data Recovery Plan and/or a PA. Teton, the 

BLM, the SHPO, and other interested parties 

would complete the Section 106 process before 

authorizing surface-disturbing activities. 

Direct Effects to Linear Historic Sites 

Pursuant to the BLM Green River Resource 

Management Plan/Record of Decision, 

“Management of historic roads and trails (on 

public land) that are eligible for the NRHP but are 
EA, White Mountain Wind Energy Project 4-9 

not Congressionally designated will generally be 

the same as for designated trails including a 0.25 

mi protective setback on either side of the 

trails....These trails include the Overland Trail, the 

Cherokee Trail, and Point of Rocks to South Pass 

Road” (1997). Specifically, contributing segments 

of these historic sites should be avoided by 0.25 

mi or the immediate viewshed, whichever is less. 

The shared route of the Cherokee Trail and the 

Old Bryan Stage Road trends through the northern 

portion of the project area on private land, but 

would not be directly impacted by project 

construction because it occurs within an area with 

no proposed project activities. 

4.2.1.2 Effects to Cultural Resources Within the 

APE for Visual Effects 

The Proposed Action may indirectly impact 

cultural resources within the APE for visual 

effects by altering the existing viewshed. The 

viewshed alterations may weaken and/or 

contribute to a loss of integrity of setting to sites 

where setting is considered to be an important 

aspect of site integrity. 

The importance of setting and determination of 

project effect to potentially affected prehistoric 

sites will be determined through ongoing 

consultation between the BLM and Native 

American tribes. For historic sites, the setting 

assessments and visual contrast rating analyses for 

potentially affected sites were not conducted on an 

individual site basis. The BLM determined that 

setting is an important aspect of integrity for each 

of the potentially affected historic sites.. As a 

result of this broad visual contrast rating, the 

proposed project would produce a moderate to 

strong visual contrast for all potentially affected 

historic sites up to a distance of 20 miles. 

A total of 163 sites was identified for visual 

effects analysis and consist of 35 prehistoric sites 

and 128 historic sites. Distances from the sites to 

the proposed project area range from 0 mi (within 

the proposed project area) to the outer limit of the 

20-mile visual APE. 

Prehistoric Sites 

A total of 35 prehistoric sites were identified for 

visual affect analysis within areas from which the 

project would be visible. A table summarizing the 

potentially affected sites is provided in Appendix 

D. Project effects to these sites will be determined 

by the BLM through ongoing consultation with 

Native American tribes. Setting is considered to 

be an important aspect of each site’s integrity and 

although the degree of contrast would likely vary 

from site to site, a moderate to strong contrast is 

assumed for all 35 prehistoric sites. The moderate 

to strong visual contrast would result in the project 

having an adverse effect on the setting of each site. 

Historic Sites 

A total of 128 eligible and unevaluated historic 

sites were identified for visual affect analysis 

within areas from which the project would be 

visible and could be potentially affected by the 

project (see Appendix D). The 128 historic sites 

include 51 buildings located within the city of 

Rock Springs (see Appendix D). Setting is 

considered to be an important aspect of each site’s 

integrity and although the degree of contrast 

would likely vary from site to site, a moderate to 

strong contrast is assumed for all historic sites. 

The moderate to strong visual contrast would 

result in the project having an adverse effect on 

the setting of each site. 

4.2.1.3 Native American Concerns 

Consultation between the BLM and the four 

Native American tribes with regard to potential 

direct and indirect impacts to properties of 

traditional, religious, or cultural importance is 

ongoing. Consultation has indicated that there are 

direct and indirect adverse effects to places of 

cultural importance to Native Americans. Impacts 

to these resources will be resolved through a PA. 

4.2.1.4 Summary of Project Effects 

Under the Proposed Action (construction, O&M, 

and decommissioning phases), no NRHP-eligible 

or NRHP-listed cultural resources within the 

currently inventoried portions of the project area 
4-10 EA, White Mountain Wind Energy Project 

would be physically impacted by the proposed 

WMWE Project due to avoidance. However, 

additional cultural resource inventories would be 

conducted on state-owned land and private 

property and public lands outside of the ROW that 

would be disturbed by the Proposed Action. If 

NRHP-eligible cultural resources are discovered, 

they would be avoided. If they cannot be avoided, 

the direct adverse effects would be mitigated. As 

a result, physical project effects to cultural 

resources would be negligible because adverse 

effects would be avoided or mitigated. 

To avoid additional direct impacts to cultural 

resources, Teton personnel would be instructed 

that they are not allowed to search for cultural 

resources (i.e., arrowhead hunting) while working 

on this project. If any cultural resources are 

discovered on project-disturbed lands, all projectrelated activities within the immediate area would 

be suspended and the appropriate BLM 

Authorized Officer would be immediately notified. 

Work in the area would not resume until a Notice 

to Proceed is issued by the BLM. 

Based on the discussion presented above, 163 sites 

within the APE for visual effects may be indirectly 

impacted by the proposed project. Following the 

determination of project effects, any adverse 

effects to these sites would be reduced or resolved 

through implementation of the PA. In addition, 

any adverse effects to visually sensitive cultural 

resources identified during the inventories of the 

state-owned land and private property and public 

lands outside the ROW would be resolved. 

Teton would resolve all adverse effects to directly 

or indirectly impacted cultural resources through a 

BLM/SHPO-approved Data Recovery Plan and/or 

a PA. Once the PA has been executed through 

signature of all consulting parties, Section 106 of 

the NHPA is concluded, and the PA would be 

implemented. 

4.2.2 Alternative A - Development Only on 

Privately Owned Lands 

Under Alternative A (construction, O&M, and 

decommissioning phases), Teton would not 

construct turbines on BLM-administered lands but 

would still construct access roads and buried cable 

lines on public lands. This would reduce the 

probability of impacts to sites by approximately 

30% but would not eliminate the potential 

effects/impacts to some off-site cultural resources. 

Currently, the occurrence and density of cultural 

resources on private land is unknown, pending 

further inventories. However, in the event that 

cultural resources are identified, impacts to these 

properties would be similar to those for the 

Proposed Action due to avoidance or mitigation 

through a BLM/SHPO-approved Data Recovery 

Plan and/or PA. Teton, the BLM, the SHPO, and 

other interested parties would complete the 

Section 106 process before authorizing surfacedisturbing activities. If any cultural resources are 

discovered during construction operations, all 

construction activities within the immediate area 

would be suspended and the appropriate BLM 

Authorized Officer would be immediately notified. 

4.2.3 No Action Alternative 

Under the No Action Alternative, the proposed 

wind energy facility would not be authorized nor 

approved, and no impacts to cultural resources 

would occur. 

4.2.4 Residual Impacts 

The Proposed Action or Alternative A would not 

result in any unavoidable adverse impacts to 

identified cultural resources. Additionally, the site 

density in the project area is low; however, some 

loss of unidentified cultural resources or artifacts 

may occur. If any cultural resources are 

discovered during construction operations, all 

activities within the immediate area would be 

suspended and the appropriate BLM Authorized 

Officer would be immediately notified. 

4.2.5 Cumulative Impacts 

Based on the disturbance calculations presented in 

Chapter 3.0, approximately 38,289 acres are 

currently disturbed within the IAA. This 

represents 3.26% of the total area within the IAA. 

RFFA (including the Proposed Action) within the 

IAA would result in an additional 2,035 acres of 

disturbance--189 acres of disturbance due to the 
EA, White Mountain Wind Energy Project 4-11 

Proposed Action and 1,846 acres from other 

RFFAs. This represents 40,324 acres of the total 

within the IAA or 3.43% based on the total 

disturbance due to past, present, and RFFAs. 

Because predisturbance inventory surveys and 

resolution of effects are required for all 

developments with a federal nexus, adverse 

cumulative effects would be either avoided, 

mitigated, or resolved in accordance with the 

Section 106 process. Cumulative impacts may 

include reduced use by Native Americans of 

Traditional Cultural Properties in the area because 

development may reduce the utility of these places 

for ceremonial purposes. In addition, increased 

visitation from survey and construction crews and 

from the general public may lead to increased 

vandalism of archaeological sites; however, the 

level of impact would be minimal due to the low 

site density on White Mountain. 

Beneficial cumulative effects would consist of the 

scientific discovery of archaeological sites and 

accumulated evidence of prehistoric lifeways such 

as social organization, subsistence strategies, and 

tool making technologies. 

4.3 GEOLOGY AND PALEONTOLOGICAL 

RESOURCES 

4.3.1 Proposed Action 

4.3.1.1 Construction Phase 

The Proposed Action would not impact the area’s 

physiography or geology. However, minor 

impacts to topography would include temporary or 

permanent changes in the land surface and slope 

due to cut-and-fill activities required to excavate 

foundations and build roads. Following the 

completion of construction activities, open cutand-fill areas would be regraded to the 

approximate original contour and reclaimed in 

accordance with the reclamation operations 

presented in Chapter 2.0 for the Proposed Action. 

During the construction, temporary drainage 

structures such as ditches, culverts, waterbars, 

and/or check-dams would be used, as needed, to 

divert runoff around wind project facilities, but 

overall drainage patterns would be preserved. 

Direct impacts to important paleontological 

resources (i.e., vertebrate fossils) could include the 

inadvertent destruction of scientifically important 

fossils during excavation/construction for the wind 

turbine pads, access roads, substation, and the 

collector lines. The loss of scientifically important 

fossils would be an adverse effect. However, no 

fossil localities are known to occur within the 

WMWE project area; however, several important 

localities are known to occur in the surrounding 

area (Uinta Paleontological Associates, Inc. 2009). 

Even though there are no known vertebrate fossil 

localities within the project area, the presence of 

rock units that have yielded important vertebrate 

fossils elsewhere in the general area indicate that 

the probability of construction impacting 

vertebrate fossils is relatively high. However, 

most of the wind turbine pads would be placed on 

the massive sandstone of the Laney Shale Member 

of the Green River Formation. While the Green 

River Formation as a whole has a PFYC Rating 

Class 5, the Laney Shale Member, a massive 

sandstone layer that caps most of White Mountain, 

is not likely to produce important vertebrate fossils 

(Uinta Paleontological Associates, Inc. 2009). 

Other parts of the Laney Shale Member, east of 

the WMWE project area particularly on the west 

slopes of White Mountain where exposure of the 

Wilkins Peak Member occur in gullies, may 

contain fossil resources; however, no disturbance 

is proposed in these areas. 

Under the Proposed Action, construction of the 

project would initially disturb approximately 866 

acres, and the potential for notable fossils to occur 

and be disturbed is low; therefore, the potential for 

loss of important fossils is low. 

If wind turbines are placed on the Wilkins Peak 

Member located below the massive sandstone 

layer of the Laney Shale Member, fossil resources, 

particularly fish fossils, might be impacted. The 

Wilkins Peak Member on the east side of White 

Mountain is exposed on slopes too steep for 

turbine sites and would therefore not be impacted. 

However, exposures of the Wilkins Peak Member 

in some of the gullies on the western slopes of 

White Mountain have the potential to be impacted. 

Installation of underground cable lines between 

turbines may result in impact to fossil resources. 
4-12 EA, White Mountain Wind Energy Project 

Some monitoring such as a pedestrian 

reconnaissance survey of the staked access routes, 

turbine base sites, and any underground 

connections in the exposed areas of the Wilkins 

Peak Member would reduce the possibility of 

impacts to fossils that might occur during the 

construction of new access roads or the widening 

of older ones. In addition, depending on the 

location of the turbine bases, some monitoring 

during construction might be warranted and 

directed by the BLM. If paleontological resources 

are discovered during construction operations, the 

find would be reported to the BLM Authorized 

Officer immediately, and construction operations 

would be suspended within 250 ft of said find. An 

evaluation of the paleontological discovery would 

be made by a BLM-approved professional 

paleontologist within 5 working days, weather 

permitting, to determine the appropriate action(s) 

to prevent the potential loss of any significant 

paleontological value. Operations within 250 ft of 

such discovery would not be resumed until written 

authorization to proceed is issued by the BLM 

Authorized Officer. By implementing monitoring 

during the construction phase of the project, the 

loss of scientifically important fossils would be 

minimized. 

Indirect impacts to paleontological resources could 

occur from the loss of important fossil material 

due to private collection or vandalism of newly 

exposed areas. To minimize any indirect effects, 

Teton employees would be informed not to collect 

or remove any fossils. Beneficial impacts could 

result from the discovery 

vertebrate fossils located 

implementation. 

and 

during 

analysis 

project 

of 

4.3.1.2 O&M Phase 

No additional impacts beyond those discussed 

under construction impacts are expected to occur 

during the O&M phase of this project. No new 

ground-disturbing activities would be associated 

with the O&M phase of the project; therefore, 

there would be no impact to geology or 

paleontological resources during the O&M phase 

of the Proposed Action. 

4.3.1.3 Decommissioning Phase 

All ground-disturbing activities required for 

decommissioning would occur in previously 

disturbed areas. Therefore, there would be no new 

impacts to geology or paleontological resources 

during the decommissioning phase of the project. 

4.3.2 Alternative A - Development Only on 

Privately Owned Lands 

4.3.2.1 Construction Phase 

Impacts of the implementation of Alternative A 

would be similar to those identified and discussed 

under the Proposed Action. However, 

implementation of this alternative would involve 

the construction of 170 wind turbines on privately 

owned land; therefore, direct impacts to 

paleontological resources could include the 

inadvertent destruction of scientifically important 

fossils during excavation of the turbine pads, 

access roads, the substation, and the collector lines 

on 619 acres of privately owned land. The loss of 

scientifically important fossils would be an 

adverse effect; however, the wind turbines would 

likely be placed on the massive sandstone of the 

Laney Shale Member of the Green River 

Formation where the fossil potential is low. The 

same mitigation measures discussed in the 

Proposed Action would be implemented under 

Alternative A. 

Beneficial impacts under Alternative A could 

result from the discovery and analysis of 

previously unidentified fossils during project 

implementation. 

4.3.2.2 O&M Phase 

Under Alternative A, no additional impacts 

beyond those discussed under construction 

impacts are expected to occur during the O&M 

phase of this project. 

4.3.2.3 Decommissioning Phase 

No additional impacts beyond those discussed 

under the Proposed Action during the 
EA, White Mountain Wind Energy Project 4-13 

decommissioning phase of this project would be 

expected under Alternative A. 

4.3.3 No Action Alternative 

Under the No Action Alternative, the proposed 

wind energy facility would not be authorized nor 

approved. No ground would be disturbed, and no 

impacts to the existing geological and 

paleontological resources would take place beyond 

those that already exist. 

4.3.4 Residual Impacts 

Some previously unidentified fossils could be 

damaged or destroyed by project construction 

activities. 

4.3.5 Cumulative Impacts 

There are no known vertebrate fossil localities 

within the WMWE project area. Implementation 

of the Proposed Action (with the appropriate 

mitigation measures) would not be expected to 

increase cumulative impacts associated with the 

loss of such vertebrate fossils. Mitigation efforts 

included in the Proposed Action would minimize 

any additional adverse impacts and would likely 

add to the knowledge of fossils within the general 

Rock Springs area. 

Based on the disturbance calculations presented in 

Chapter 3.0, approximately 420 acres are currently 

disturbed within the IAA. This represents 3.23% 

of the total area within the IAA. RFFA (including 

the Proposed Action) within the IAA would result 

in an additional 259 acres of disturbance--189 

acres of life-of-project disturbance due to the 

Proposed Action and 70 acres from other RFFAs. 

This represents 679 acres of the total with the IAA 

or 5.22% based on the total disturbance due to 

past, present, and RFFAs. 

Therefore, cumulative impacts to geology and 

paleontological resources would not be important 

because there are no past, present, or RFFAs that, 

when combined with the Proposed Action, would 

result in impacts beyond those that already exist or 

have already been identified and discussed in 

Chapter 4.0 of this EA. In addition, the impacts 

presented here do not exceed the level of impacts 

outlined in the Wind Energy PEIS (BLM 2005). 

4.4 LAND USE (INCLUDING GRAZING, 

RECREATION, AND 

TRANSPORTATION) 

4.4.1 Proposed Action 

4.4.1.1 Construction Phase 

Grazing 

Construction under the Proposed Action would 

have temporary and minor impacts on livestock 

grazing within the affected BLM Rock Springs 

grazing allotment. Livestock may be disturbed by 

construction traffic, equipment activity, and noise. 

Such disturbance may cause poor livestock 

distribution within that part of the allotment 

located with the WMWE project area, which could 

lead to negative impacts to vegetation and soils 

related to localized overgrazing and trampling. 

The operation of construction equipment and 

vehicles during project construction could also 

increase the potential for accidental wildfire, and 

some livestock could be struck by construction 

vehicles. If an accident occurs, the party 

responsible for the accident will be liable to 

provide appropriate compensation to the livestock 

owner. 

The Proposed Action would have little impact on 

the available AUMs within the WMWE project 

area. Construction would initially disturb 866 

acres of rangeland in the Rock Springs grazing 

allotment and based on an average 11.4 acres per 

AUM, 76 AUMs would initially be unavailable in 

the Rock Springs grazing allotment as a result of 

the construction of the Proposed Action. 

Most impacts to grazing (e.g., decrease in quantity 

and quality of forage due to dust accumulation as a 

result of increased vehicle traffic, equipment use, 

invasion of noxious/invasive plant species due to 

surface disturbance, livestock safety) would be 

minimal and short-term in nature if proposed 

environmental protection measures for vegetation 

and soil resources are implemented. Such 

potential impacts would not affect grazing 
4-14 EA, White Mountain Wind Energy Project 

resources in a manner that would cause the 

allotments to be out of compliance with Rangeland 

Health Standards or to not conform to the 

Guidelines for Grazing Management. 

Revegetation of disturbed areas would be designed 

on a site-specific basis in consultation with the 

BLM to maintain or enhance the value of grazing 

allotments. 

Teton would also install speed limit signs in 

cooperation with Sweetwater County officials, and 

construction personnel would also be informed 

that they are working in an area with open 

livestock grazing and to drive the posted speed 

limit and to watch for livestock that might be on 

the road. It is also possible that livestock could be 

involved in an accident with O&M vehicles. 

Should an accident occur, the party responsible 

will be liable to provide appropriate compensation 

to the livestock owner. In addition, open trenches 

or excavations that are left unattended overnight 

will be fenced for safety, and existing cattle guards 

will be left in place. 

Initial reclamation efforts would be conducted 

immediately following the completion of 

construction activities, and approximately 703 

acres of initial disturbance would be revegetated in 

accordance with the reclamation plan presented in 

the Proposed Action. 

Recreation 

Construction, noise, dust, the presence of 

equipment, and associated human activities would 

change the character of the WMWE project area 

and recreational experiences, such as backcountry 

hiking and camping, wildlife observation, 

horseback riding, nature photography, big game 

hunting, and OHV use. Because of the visual 

changes likely to occur during the construction 

phase of the project, the aesthetic sense of a rural 

undeveloped recreational area would be reduced 

for some people. Other individuals could be 

attracted in order to observe construction 

activities. However, public lands would remain 

open during construction unless a public safety 

hazard is determined. Any closure would be 

temporary and limited in duration. 

Transportation 

Under the Proposed Action, impacts to 

transportation would include construction-related 

activities on existing two-track roads located 

within the WMWE project area that would be 

improved and increased traffic on the existing 

roads (including U.S. Highway 191 from I-80 to 

Fourteenmile Road and on County Road 53 from 

Fourteenmile Road to the southern end of the 

WMWE project area). All traffic associated with 

the Proposed Action would enter the project area 

from U.S. Highway 191, and most of the vehicle 

traffic would travel north to the project area on 

U.S. Highway 191 because most of the 

construction workers are expected to reside in 

Rock Springs, North Rock Springs, Reliance, or 

Green River. 

Improvements to the existing roads and 

construction of the new access roads within the 

project area would likely occur in a phased 

approach in conjunction with project phases over a 

3- to 4-year period. In order to minimize 

construction-related impacts to the environment, 

Teton would also use as many of the existing twotrack roads as possible instead of constructing new 

roads within the project area. Impacts to 

vegetation, soil, air quality, and noise are 

specifically addressed in those specific sections of 

this EA and will not be repeated here. 

Improvements to the existing two-track roads and 

the new access roads within the project area would 

be designed to accommodate the number and size 

of vehicles and equipment that would be used 

during the construction phase of the project, and 

these road construction/ improvements would be 

designed in accordance with BLM 9113 Manual or 

the design standards suitable for wind energy 

developments approved by the BLM and other 

authorizing agencies. 

The increase in construction-related vehicle traffic 

on County Road 53 and U.S. Highway 191 would 

likely last throughout the 3- to 4-year construction 

phase of the project. These roads are currently 

designed to handle large and heavy vehicles that 

would be used to transport project components to 

the construction sites. Currently, County Road 53 

experiences a low amount of the industrial-type 
EA, White Mountain Wind Energy Project 4-15 

traffic as there are limited commercial facilities 

(e.g., communication sites and transmission lines 

or land gas facilities, etc.) in the general WMWE 

project area. The increased construction-related 

traffic is not expected to create excessive traffic 

congestion with recreational traffic in the WMWE 

project area because construction traffic would be 

limited to nonweekend periods (i.e., Monday 

through Friday). There may be some increase in 

traffic congestion on U.S. Highway 191 during the 

construction phase of the Proposed Action. 

However, U.S. Highway 191 is designed to handle 

a large volume of traffic, and residents in the area 

are used to seeing large vehicles (e.g., oil field 

equipment) on this stretch of road. These impacts 

should be limited. 

4.4.1.2 O&M Phase 

Grazing 

No additional grazing impacts beyond those 

discussed under construction impacts are expected 

to occur during the O&M phase of this project. A 

limited amount (189 acres and 14 AUMs) of 

rangeland would not be available for livestock 

grazing as a result of the construction of the 

project-related equipment, facilities, and 

structures. However, despite this loss of grazing 

vegetation, livestock are expected to adjust to the 

increased traffic during the O&M phase of the 

project, as well as the presence of the wind 

turbines and associated structures and facilities 

(BLM 2005). 

Teton would also install speed limit signs in 

cooperation with Sweetwater County officials, and 

construction personnel would also be informed 

that they are working in an area with open 

livestock grazing and to drive the posted speed 

limit and to watch for livestock that might be on 

the road. It is also possible that livestock could be 

involved in an accident with O&M vehicles. 

Should an accident occur, the party responsible 

would be liable to provide appropriate 

compensation to the livestock owner. 

Recreation 

The operation and locations of the wind turbines 

would change the overall appearance of the 

landscape from a relatively undeveloped character 

to an industrial character and could change the 

recreational experience of the area for some 

individuals. The aesthetic sense of a rural 

undeveloped recreational area would be reduced 

for the life of the project for some individuals, 

potentially affecting the quality of some dispersed 

recreation experiences such as backcountry hiking 

and camping, wildlife observation, horseback 

riding, nature photography, big game hunting, and 

OHV use within the immediate area. Other 

individuals would not be adversely affected. In 

addition, areas close to the individual wind 

turbines and other project facilities may be 

avoided by hunters, and they may negatively affect 

the hunting experiences and hunting success 

within the project area. With improved access to 

portions of the WMWE project area, poaching and 

disturbance to big game and other wildlife may 

increase, as well as the potential for vandalism and 

litter. However accessibility to public and private 

lands throughout the WMWE project area would 

enhance opportunities for hunting and wildlife 

observation for some recreational users. 

Transportation 

No additional road construction activities would 

be conducted during the O&M phase of the 

Proposed Action, and vehicle traffic would be 

significantly reduced from the volume of traffic 

experienced during the construction phase. 

Vehicle traffic would be expected to use U.S. 

Highway 191 and County Road 53 during the 

O&M phase of the project, and a majority of the 

vehicle traffic would be pickup trucks and small 

maintenance vehicles. It is possible that during 

some major maintenance operations, some large 

and heavy vehicles may still travel to the project 

area, but these are expected to be an uncommon 

event. 

4.4.1.3 Decommissioning Phase 

Grazing 

Decommissioning would result in similar impacts 

to grazing as those described for construction, and 

the same environmental protection measures 

would be implemented. Decommissioning and 
4-16 EA, White Mountain Wind Energy Project 

final site restoration and permanent revegetation 

efforts on the 189 acres of life-of-project 

disturbance would eventually (within 10-20 years) 

restore vegetation cover to predisturbance levels. 

Recreation 

The presence of construction equipment during the 

decommissioning phase and associated human 

activities would likely decrease the recreational 

experience felt during the decommissioning phase 

and would be similar to the levels of activity and 

noise that occurred during the construction phase 

of the project. All project structures and roads 

would be removed and reclaimed, and other 

disturbed areas would be reclaimed to re-establish 

grazing lands and wildlife habitat and to restore 

the area for recreational use. Some roads may be 

retained upon completion, allowing increased use 

of the area subject to private landowner 

permission. The impacts to recreational use and 

level of individual’s recreational experiences 

following decommissioning are unknown but 

would likely return to predisturbance levels 

following the completion of reclamation activities. 

Transportation 

During the decommissioning phase of the 

Proposed Action, wind turbines, towers, and 

associated facilities (the substation) would be 

dismantled and removed from the project area. 

Large trucks would transport the various project 

components from the site using County Road 53 

and U.S. Highway 191, and the impacts would be 

similar to those discussed in the construction 

phase of the Proposed Action. 

4.4.2 Alternative A - Development Only on 

Privately Owned Lands 

4.4.2.1 Construction Phase 

Grazing 

Under Alternative A, no additional impacts to 

livestock grazing beyond those discussed under 

the Proposed Action are expected to occur during 

the construction phase of this project. Under 

Alternative A, construction would initially disturb 

619 acres of rangeland in the Rock Springs 

grazing allotment. Based on an average 11.4 acres 

per AUM, 54 AUMs would be unavailable for 

livestock use in the Rock Springs grazing 

allotment as a result of Alternative A. Given that 

the Rock Springs grazing allotment has an 

estimated 180,234 available AUMs permitted, and 

current usage is approximately 107,902 AUMs 

(60%) annually, implementation of Alternative A 

would reduce the available AUMs by 54 AUM or 

0.03% of the permitted AUMs. 

Recreation 

Potential recreational use impacts under 

Alternative A would be similar to the type of 

impacts as described under the Proposed Action 

(e.g., noise from construction activities and 

vehicle traffic and operation of the mobile 

concrete batch plant). However, because this 

alternative would involve the construction of 170 

wind turbines on privately owned land, 

recreational use would be similar to those 

described under the Proposed Action. 

Transportation 

Impacts to transportation during the construction 

phase under Alternative A would be similar to 

those discussed under the Proposed Action. 

However, it is expected that impacts would be 

30% less because 170 wind turbines would be 

constructed under this alternative. 

4.4.2.2 O&M Phase 

Grazing 

Under Alternative A, no additional impacts to 

livestock grazing beyond those discussed under 

the Proposed Action are expected to occur during 

the O&M phase of this project. With successful 

revegetation following the construction phase, 

approximately 44 AUMs would become available 

for livestock grazing during the O&M phase of the 

project. The remaining 10 AUMs would not be 

available during the O&M phase of the project. 
EA, White Mountain Wind Energy Project 4-17 

Recreation 

Potential noise and visual impacts under 

Alternative A would be similar to the type of 

impacts as described under the Proposed Action 

during the O&M phase of the project. However, 

because this alternative would involve the 

construction of 170 wind turbines on privately 

owned land, it is expected that impacts to 

recreational use of the area would be similar to 

those described under the Proposed Action. 

Transportation 

Impacts to transportation during the O&M phase 

under Alternative A would be similar to those 

discussed under the Proposed Action. However, it 

is expected that impacts would be 30% less 

because 170 wind turbines would be constructed 

under this alternative. 

4.4.2.3 Decommissioning Phase 

Grazing 

Decommissioning would result in similar impacts 

as those described for the construction phase, and 

the same environmental protection measures 

would be implemented. Decommissioning and 

final site restoration and revegetation would 

restore approximately 162 acres to grazing uses. 

Recreation 

Potential impacts under Alternative A to recreation 

would be similar in the type of impacts as 

described under the Proposed Action during the 

decommissioning phase of the project. However, 

because this alternative would involve the 

decommissioning of 170 wind turbines on 

privately owned land, it is expected that impacts to 

recreation use would be similar to those expected 

under the construction phase of the Proposed 

Action. 

Transportation 

Impacts to transportation during the 

decommissioning phase under Alternative A 

would be similar to those discussed under the 

Proposed Action. However, it is expected that 

impacts would be 30% less because 170 wind 

turbines would be constructed under this 

alternative. 

4.4.3 No Action Alternatives 

Under the No Action Alternative, the proposed 

wind energy facility would not be authorized nor 

approved. No ground would be disturbed, and no 

impacts to the existing physical or biological 

environment would take place beyond those that 

already exist. 

4.4.4 Residual Impacts 

The Proposed Action would result in the 

temporary loss of 76 AUMs in the short term and 

14 AUMs for the life of the project. There would 

also be unavoidable impacts to some recreational 

users of the WMWE project area for the life of the 

project, and there would be an avoidable increase 

of vehicle traffic in the WMWE project area and 

along portions of U.S. Highway 191 near Rock 

Springs. 

4.4.5 Cumulative Impacts 

In order to assess potential cumulative impacts to 

livestock grazing, recreation, and transportation, 

various IAAs have been established to evaluate the 

Proposed Action, and quantitative data for the 

various IAAs are summarized in Table 4.5. 

Grazing 

Livestock grazing allotments within the IAA 

would experience only limited impacts due to past, 

present, and RFFAs. Most of the RFFAs would 

result in short-term impacts to vegetation and 

grazing, and the disturbed areas would be 

revegetated as soon as possible following 

completion of the project, and vegetation would 

eventually (within 10-20 years) return to 

predisturbance levels. 

Recreation 

Cumulative impacts to recreation resources due to 

past, present, and RFFAs (including the Proposed 
4-18 EA, White Mountain Wind Energy Project 

Table 4.5 Cumulative Impacts for Land Use. 

Amount of Total Amount 

Amount of Disturbance Related of Current and 

Current to RFFA (Including RFFA 

Total IAA Disturbance Proposed Action) Disturbance 

Resource Description (acres) (acre and %) (acre and %) (acre and %) 

Livestock Rock Springs grazing 418,506 9,734 (2.33%) 1,017 (0.24%) 10,751 (2.57%) 

grazing allotment west of 

U.S. Highway 191 

and North of I-80 

Recreation and WMWE project area 1,175,515 38,289 (3.26%) 2,035 (0.17%) 40,324 (3.43%) 

transportation plus 20 mi 

Action) are expected to be limited because there 

would be no additional construction in the 

WMWE project area beyond those identified in 

the Proposed Action, and the identified RFFAs 

would be highly dispersed over a large area. 

There would be some localized impacts (e.g., 

displacement) to recreational activities (e.g., 

hunting, sightseeing, hiking, etc.) due to the 

individual projects, and these activities would 

possibly be displaced to other locations or not 

available in some specific locations. However, 

members of the public could still use a vast 

majority of the IAA, which would be available for 

outdoor recreational activities. 

Transportation 

Cumulative impacts to transportation due to 

existing and RFFAs (including the Proposed 

Action) are expected to be limited because there 

would be no additional construction in the 

WMWE project area (besides the Proposed 

Action) and the identified RFFAs would occur 

over many years, thereby reducing potential 

cumulative impacts. Many of the RFFAs would 

involve the proposed construction of structures or 

facilities (e.g., transmission lines), the substation 

that, once completed, would require fewer 

employees to operate and maintain, thereby 

reducing vehicle traffic on area roads. Major 

roads in the area are already improved and capable 

of handling the size and volume of potential 

vehicle traffic, and no damage to existing roads is 

anticipated as a result of existing and RFFAs. 

Therefore, cumulative impacts to land use 

(including grazing, recreation, and transportation) 

would not be important because there are no past, 

present, or RFFAs that, when combined with the 

Proposed Action, would result in impacts beyond 

those that already exist or have already been 

identified and discussed in Chapter 4.0 of this EA. 

Additionally, impacts presented here do not 

exceed the level of impacts outlined in the Wind 

Energy PEIS (BLM 2005). 

4.5 NOISE 

4.5.1 Proposed Action 

4.5.1.1 Construction Phase 

Local noise levels in the immediate project area 

may be temporarily affected by construction 

activities such as the operation of mobile 

equipment and the mobile concrete batch plant. 

The project area is remote and unpopulated, and 

there are no residences or businesses located 

within the WMWE project area. The nearest 

occupied residence or sensitive noise receptor is 

located approximately 0.92 mi east and over 700 ft 

below the rim of White Mountain. 

Noise impacts during construction are expected to 

be limited to on-site construction workers and 

wildlife and livestock in the immediate vicinity of 

the actual operation. Some livestock, wildlife, and 

wild horses may temporarily avoid the active 

portion of the project area during daylight hours 

due to construction noise, but for the most part, 
EA, White Mountain Wind Energy Project 4-19 

they are expected to return to the area during 

nonworking hours or upon completion of 

construction operations. The largest source of 

sound during construction of the operation will be 

diesel powered equipment, including mobile 

equipment and the mobile concrete batch plant. 

Based on a discussion of noise resulting from the 

use of diesel-powered heavy equipment, noise 

levels would range from 80 to 92 dBA at a 

distance of 50 ft (Rau and Wooten 1980). In order 

to minimize sound impacts, all equipment will be 

operated with the manufacturer’s suggested noise 

control systems (e.g., mufflers and noise 

dampening materials), and all construction 

operations will take place during daylight hours. 

Through communications with the local 

communities, Teton will be kept informed of any 

noise complaints. If substantial noise complaints 

are received, noise measurements will be taken 

along the project boundary or near the complaint 

sources to ascertain the sources and level of the 

noise. If noise levels are found to be 

unsatisfactory, alternative mitigation measures 

would be explored. 

Therefore, due to the remote nature of the project 

area and the temporary duration of construction 

operations, noise impacts are expected to be 

minimal and are not expected to affect any 

residences. 

4.5.1.2 O&M Phase 

During the O&M phase of the project, noise would 

be generated by the wind turbines, the substation, 

and maintenance equipment such as pickup trucks. 

Noise is typically defined as unwanted sound and 

typically has subjective effects, including 

annoyance, nuisance, and dissatisfaction. 

There are two main sources of wind turbine sound. 

One is mechanical sounds associated with the 

relative motion of mechanical components and the 

dynamic responses. In the case of a wind turbine, 

this includes sound generated in the gearbox, 

generators, yaw drives, cooling fans, and auxiliary 

equipment. The second main source of sound 

from a wind turbine is aerodynamic sound that 

originates as a result of the flow of air around the 

wind turbine blades. Noise was an issue with 

some early wind turbine and blade designs, 

but it has been largely eliminated as a 

problem through improved engineering and 

manufacturing compliance with the International 

Electrotechnical Commission (IEC) standard 

61400-11 (Rogers et al. 2006). According to 

General Electric (an IEC compliance 

manufacturer), the wind turbines identified for this 

project (the GE 1.5 SLE unit) are expected to have 

a maximum sound power level of less than 104 

dBA (General Electric 2004). 

According to the Wind Energy PEIS (BLM 2005), 

considering geometric spreading, a wind turbine 

with a sound power level of 104 dBA will have a 

resulting sound power level of 58 to 62 dBA at a 

distance of 164 ft from the turbine, which is about 

the same level as conversational speech at a 

distance of about 3 ft. At a receptor approximately 

2,000 ft away, the equivalent sound pressure level 

would be approximately 36 to 40 dBA when the 

wind is blowing, which is typical of background 

sound levels of rural environment (BLM 2005). 

Based on this information, noise levels due to the 

operation of the wind turbines would not exceed 

65 dBA outside of the project boundary, which 

complies with the performance standards outlined 

in the Sweetwater County wind farm regulations. 

According to information collected within the 

WMWE project area and discussed in Chapter 3.0 

of this EA, ambient sound levels ranged from 

28 to 68 dBA on a calm day and 47 to 90 dBA on 

a windy day. 

Most modern wind turbines are pitch-controlled 

variable-speed, meaning (in part) that the turbine 

operates at slower speeds in low winds, resulting 

in much quieter operation in low winds compared 

to fixed-speed wind turbines (Mujadi and 

Butterfield 2000). As a result, as wind speed 

increases, the wind itself masks a portion of the 

increasing aerodynamic noise (described as blade 

“swishing” or “whooshing”) of the wind turbine 

(BLM 2005; Rogers et al. 2006). 

Therefore, based on this discussion, the sound 

generated during the operation of the WMWE 

Project is expected to have minimal noise impacts 

inside or outside of the project area. The project 
4-20 EA, White Mountain Wind Energy Project 

site is remote and unpopulated, with the nearest 

residence located approximately 0.92 mi away 

from the eastern project boundary and 700 ft 

below the rim of White Mountain. 

Through communications with the local 

communities, O&M staff will be kept informed of 

any noise complaints. If substantial noise 

complaints are received, noise measurements will 

be taken along the project boundary or near the 

complaint sources to ascertain the noise levels. If 

noise levels are found to be unsatisfactory, 

alternative O&M activities or mitigation measures 

would be evaluated. 

Therefore, the sound generated during the O&M 

phase of the Proposed Action is expected to have 

limited noise impacts inside or outside of the 

project area and are not expected to affect any 

residences. 

4.5.1.3 Decommissioning Phase 

Sound levels in the project area will be affected 

temporarily by decommissioning activities such as 

equipment operation and movement, but due to the 

remote nature of the site, impacts are not 

anticipated to affect any residences or businesses. 

Some livestock, wildlife, and wild horses may 

temporarily avoid the active portion of the project 

area due to decommissioning noise, but, for the 

most part, they are expected to return to the area 

upon completion of decommissioning operations. 

The largest source of noise during 

decommissioning operations will be dieselpowered equipment. Therefore, all equipment will 

be operated with the manufacturer’s suggested 

noise control systems (e.g., mufflers and noise 

dampening materials), and all decommissioning 

operations will take place during daylight hours. 

Teton would also maintain communications with 

the local communities, and the construction staff 

would be kept informed of any noise complaints. 

If significant noise complaints are received, noise 

measurements will be taken along the project 

boundary or near the complaint sources to 

ascertain the noise levels. If noise levels are found 

to be unsatisfactory, alternative construction 

activities or mitigation measures would be 

evaluated. 

Therefore, based on this discussion, the sound 

generated during the decommissioning phase of 

the WMWE Project is expected to have limited 

noise impacts inside or outside of the project area 

and are not expected to affect any residences. 

4.5.2 Alternative A - Development Only on 

Privately Owned Lands 

4.5.2.1 Construction Phase 

Potential noise impacts under Alternative A would 

be similar to the type and level of impacts as 

described under the Proposed Action (e.g., noise 

from construction activities and vehicle traffic and 

operation of the mobile concrete batch plant). 

However, because this alternative would involve 

the construction of 170 wind turbines on privately 

owned land, it is expected that the duration of 

construction noise would be about 70% as long as 

the noise duration expected under the Proposed 

Action. 

Therefore, the sound generated during the 

construction phase of Alternative A is expected to 

have limited noise impacts inside or outside of the 

project area and is not expected to affect any 

residences. 

4.5.2.2 O&M Phase 

Potential noise impacts under Alternative A would 

be similar to the type of impacts as described 

under the Proposed Action during the O&M phase 

of the project. However, because this alternative 

would involve the construction of 170 wind 

turbines on privately owned land, noise impacts 

may be reduced by 30% compared to those 

expected under the Proposed Action. 

Therefore, the sound generated during the O&M 

phase of Alternative A is expected to have limited 

noise impacts inside or outside of the project area 

and is not expected to affect any residences. 
EA, White Mountain Wind Energy Project 4-21 

4.5.2.3 Decommissioning Phase 

Potential noise impacts during the 

decommissioning phase of Alternative A would be 

similar to the type and level of impacts as 

described under the Proposed Action. However, 

because this alternative would involve the 

construction of 170 wind turbines on privately 

owned land, it is expected that the duration of 

construction noise would be about 30% less when 

compared to the Proposed Action. 

Therefore, the sound generated during the 

decommissioning phase of Alternative A is 

expected to have limited noise impacts inside or 

outside of the project area and is not expected to 

affect any residences. 

4.5.3 No Action Alternatives 

Under the No Action Alternative, the proposed 

wind energy facility would not be authorized nor 

approved and noise levels would remain at 

existing levels. 

4.5.4 Residual Impacts 

As a result of the Proposed Action, there would be 

some increased sound or noise within and near the 

WMWE project area. The highest sound levels 

would generally be limited to activity near the 

construction sites or operating wind turbine. 

Teton would comply with and implement all 

specified sound or noise reduction mitigation 

measures. Despite these efforts, some increased 

levels of sound will be generated by the Proposed 

Action. However, sound generating activities are 

not expected to affect any residences. 

4.5.5 Cumulative Impacts 

Sources of sound within the IAA are vehicular 

traffic on local land, county roads, I-80, and 

railroad operations (i.e., in the southern end of the 

IAA) and wind. Construction, O&M, and 

decommissioning operations under the Proposed 

Action would not greatly increase the level of 

noises within the IAA. Because of the remoteness 

of the project area, noise from these activities 

would generally be masked by the wind and noise 

from vehicle or train traffic, so cumulative 

overlapping noise impacts would not be likely. 

During the construction and decommissioning 

phases of the Proposed Action, noise generating 

activities would be limited to specific locations 

where these operations occur, and members of the 

public traveling through the project area would 

notice some equipment noise in these areas. 

Sound from these sources would not likely be 

audible outside of the immediate project area. 

During the O&M phase of the Proposed Action, 

members of the public that travel through the 

project area may notice some levels of increased 

sound during moderate speed winds, but as wind 

speeds increases, the sound generated by the wind 

turbines will be masked by the increased sound of 

the wind. In addition, Teton would continue to 

comply with and implement all specified sound or 

noise reduction mitigation measures. No 

residences located within the IAA would likely be 

impacted by the Proposed Action. 

Based on the disturbance calculations presented in 

Chapter 3.0, approximately 4,402 acres are 

currently disturbed within the IAA. This 

represents 7.13% of the total area within the IAA. 

RFFA (including the Proposed Action) within the 

IAA would result in an additional 418 acres of 

disturbance--189 acres of disturbance due to the 

Proposed Action and 229 acres from other RFFAs. 

This represents 4,820 acres of the total with the 

IAA or 7.81% based on the total disturbance due 

to past, present, and RFFAs. 

Therefore, cumulative impacts from noise would 

not be important because there are no past, 

present, or RFFAs that, when combined with the 

Proposed Action, would result in impacts beyond 

those that already exist or have already been 

identified and discussed in Chapter 4.0 of this EA. 

Additionally, the impacts presented here do not 

exceed the level of impacts outlined in the Wind 

Energy PEIS for noise (BLM 2005). 

4.6 SOCIOECONOMICS 

4.6.1 Proposed Action 

From a socioeconomic perspective, consequences 

are attributable primarily to changes in the area 
 

4-22 EA, White Mountain Wind Energy Project 

economy related to the construction, O&M, and 

decommissioning phases of the proposed project. 

Economic activity attributable to implementation 

of the Proposed Action includes: increase in local 

employment; increase in taxes; purchase of 

materials and services from local sources; and 

expenditures in the local economy by nonlocal 

workers for items such as accommodations, food, 

and recreation. Project-related effects associated 

with the construction and decommissioning of the 

project would be short-lived, while those 

associated with the O&M phase of the project 

would have a longer duration. 

An economic analysis of the proposed project has 

been completed using the Job and Economic 

Development Impact (JEDI) model for wind 

energy projects available from the DOE, National 

Renewable Energy Laboratory (2009), and this 

analysis examined the economic impacts of the 

proposed WMWE Project (Lloyd Levy 

Consulting, LLC [LLC] 2008). Based on the size 

and project life of the WMWE Project, the JEDI 

model predicted the number of direct and indirect 

and induced (secondary) jobs by year that would 

be created over the life of this project, and the total 

number of jobs is illustrated in Figure 4.2. The 

JEDI model also forecasts the number of jobs that 

would be created in the Rock Springs/Green River 

area, and this is illustrated in Figure 4.3. The 

forecast number of local jobs is a subset of the 

information presented in Figure 4.2. 

4.6.1.1 Construction Phase 

Employment and Income 

During the construction phase of the Proposed 

Action, the JEDI model estimates that a maximum 

of approximately 357 full- and part-time jobs 

would be created. Approximately 187 direct 

temporary construction jobs and 170 indirect and 

induced (secondary) part- and full-time jobs would 

be created during the 3- to 4-year construction 

period of the WMWE Project (LLC 2008). It must 

also be noted that the JEDI model includes indirect 

and inducted jobs that would be created but 

located outside of Sweetwater County. During the 

peak construction years (2010-2012), it is 

expected that 166 part- or full-time jobs would be 

created outside of Sweetwater County. An 

additional four secondary part- or full-time jobs 

would be created in the project area, and it is 

expected that all of these workers would already 

reside in the immediate area. Figure 4.2 illustrates 

the employment related to the Proposed Action by 

year. 

Most of the construction tasks require skilled 

workers with specialized wind turbine expertise, 

and many of these skilled workers would not be 

available locally. Thus, it is estimated that 

approximately 150 workers (an estimated 80% of 

the 187 wind turbine workers) (depending on skill 

level and function) would likely temporarily 

relocate from areas outside the immediate project 

area (LLC 2008). While most of the specialized 

wind turbine construction jobs would be filled by 

experienced employees from outside southwest 

Wyoming, the nonwind turbine construction jobs 

(the secondary jobs) would be filled by individuals 

that currently reside in the immediate project area 

(the Rock Springs and Green River area) (refer to 

Figure 4.3). In order to maximize the economic 

benefit to the local economy, Teton is committed 

to and would hire local companies and employees 

when the appropriate firms and employees are 

available. Based on the results of this model, it is 

estimated that the aggregate income of direct and 

indirect workers total approximately $39,090,000. 

Income from direct workers is expected to total 

approximately $25,850,000, and income from 

indirect and induced workers is expected to total 

approximately $13,240,000 during the 3- to 4-year 

construction phase of the Proposed Action (LLC 

2008). A substantial portion of these earnings 

would be spent in the local economy and would 

provide an economic stimulus to the local and 

state economies. 

Sales and Use Taxes 

The JEDI model also provided the annual amount 

of sales and use tax revenue generated during the 

construction phase of the Proposed Action, and the 

results are presented in Table 4.6 (LLC 2008). 

The State of Wyoming levies a 4% sales and use 

tax, and Sweetwater County levies an additional 

2%. During the 3- to 4-year construction phase of 

this project, it is estimated that a total of 
EA, White Mountain Wind Energy Project 4-23 

Figure 4.2 Total Number of Jobs Created, Proposed Action. 

Figure 4.3 Jobs Created in Rock Springs/Green River, Proposed Action. 
4-24 

1 

EA, White Mountain Wind Energy Project 

Table 4.6 Annual Sales and Use Tax Revenue Generated During the Construction Phase of 

WMWE Project, Proposed Action.1 

Construction Year Sweetwater County ($) State of Wyoming ($) 

Year 1 (2009) 15,817 211,827 

Years 2-4 (2010-2012) 30,316 406,001 

Total 46,133 617,828 

Source: LLC (2008). 

approximately $46,000 in sales and use tax 

revenue would be generated for Sweetwater 

County, and approximately $618,000 in sales and 

use tax revenue would be generated for the State 

of Wyoming. The sales and use tax projects take 

into account the Wyoming state exemption on 

renewable generation projects, and this exemption 

applies to sales of equipment used to generate 

electricity from renewable resources, including 

equipment used in wind energy generation. It is a 

broad-based exemption that covers the items 

necessary to make the project operational, but it 

does not apply to the construction of access roads, 

to any purchases made once the project is 

operating, or to equipment not ultimately 

connected to the transmission grid such as a 

building that may be used to house grid-connected 

equipment. The sales and use tax estimated output 

from the JEDI model includes only revenue 

derived from the taxable spending attributable to 

the WMWE Project’s direct effects, and it does 

not attempt to make estimates of the project’s 

“multiplier effect,” which generates some 

additional sales and use tax revenue as new money 

circulates in the regional economy. The sales and 

use tax revenue from the multiplier effect would 

be small compared to the direct sales and use tax 

revenue generated (LLC 2008). 

Property Taxes 

During the construction phase of the Proposed 

Action, property tax revenue would also be 

generated. Based on the results of the JEDI 

model, the WMWE Project is expected to generate 

at total of approximately $10,600,000 in property 

tax revenue during the 3 to 4 years of construction 

(LLC 2008). Annual property tax revenue 

generated during the construction phase is 

presented in Table 4.7. Projected property tax 

revenues would rise to the maximum amount over 

the life of the project during year 4 of construction 

after all project phases have been added to the tax 

roll. The total assessed value and tax revenue 

would decline thereafter during the operational 

phase because of the valuation method used in the 

JEDI model (LLC 2008). 

Housing 

It is estimated that approximately 150 specialized 

nonlocal wind turbine workers would temporarily 

relocate to the Rock Springs/Green River area to 

fill jobs not held by local workers (refer to 

Figure 4.3). 

For the purpose of this discussion, the housing 

project area (the Rock Springs/Green River area) 

includes the U.S. Census Bureau designated 

communities of Rock Springs, North Rock 

Springs, Reliance, and Green River. Because of 

the relatively short duration of construction 

activity, it is unlikely that the nonlocal workers 

would be accompanied by family members, and 

the temporary relocation workers would peak 

during the second construction year of the project. 

The increase of 150 nonconstruction workers 

would comprise less than one-half of one percent 

of the approximate 33,155 residents in the Rock 

Springs/Green River area as of 2000 (U.S. Census 

Bureau 2003). 
4-25 

1 

EA, White Mountain Wind Energy Project 

Table 4.7 Projected Property Tax Revenue Generated During the Construction Phase of the WMWE 

Project, Proposed Action.1 

Year of Construction Projected Property Tax Revenue 

1 (2009) $ 700,000 

2 (2010) $ 2,100,000 

3 (2011) $ 3,300,000 

4 (2012) $ 4,500,000 

Total $10,600,000 

Source: LLC (2008). 

Nonlocal workers would likely temporarily reside 

in Rock Springs, North Rock Springs, Green 

River, or Reliance since these are the closest 

communities to the project area. Assuming a oneway commute time of less than 1 hour, there are a 

number of rental units/homes, hotels, motels, and 

campgrounds that could accommodate these 

nonlocal workers. The primary access into the 

project area is from U.S. Highway 191 near the 

closed Fourteenmile Rest Area, and it is 

approximately 11.0 mi north of Rock Springs, 

approximately 8.0 mi north of North Rock 

Springs, approximately 10.0 mi north of Reliance, 

and approximately 26.0 mi northeast of Green 

River. 

The most current detailed housing data were 

obtained from the U.S. Census Bureau for the year 

2000 (U.S. Census Bureau 2003). As of the 2000 

census, there were 13,796 total housing units in 

the immediate project area (including the 

communities of Rock Springs, North Rock 

Springs, Reliance, and Green River), and 

approximately 1,324 units (9.6%) were vacant 

(Table 4.8). In addition, it should also be noted 

that new housing starts continued in Rock Springs 

in 2008 and 2009. This number does not include 

hotels/motels, mobile home and recreational 

vehicle (RV) spaces, and campgrounds. 

As of the 2000 census, Sweetwater County had a 

total of 14,105 total housing units and 

1,816 vacant housing units (a vacancy rate of 

11.4%); however, the U.S. Census Bureau 

completed a 3-year community estimate for 

Sweetwater County and determined that as of 

2005-2007, 16,480 total housing units were 

occupied in Sweetwater County with 1,373 units 

vacant (a vacancy rate of 8.3%) (U.S. Census 

Bureau 2008). This is an increase of 

2,375 housing units over the 2000 census data (an 

approximate increase of 17%). It also appears that 

the vacancy rate decreased between when the 2000 

census data were collected and when the 2005­

2007 3-year estimate data were collected. The 

2005-2007 census estimates were only available at 

the county level and were not available by 

community; however, it is assumed that a majority 

of the new housing units were in the Rock 

Springs/Green River area because this is the 

largest population area in Sweetwater County. 

According to a rental agent in Rock Springs, they 

have seen a significant increase in the number of 

available rental units in the Rock Springs area in 

the past 6 months to 1 year. This increase appears 

partially related to the recent economic slowdown 

that has also been observed throughout Wyoming. 

The increase in rental units is attributed to the 

economic slowdown, the regular turnover of rental 

units, and an increase in the number of homes that 

were once for sale now being transferred into 

rental properties (personal communication, 

April 3, 2009, with Tina Linkenauger, Manager, 

Alpine Property Management, Rock Springs, 

Wyoming). 
4-26 

1 

EA, White Mountain Wind Energy Project 

Table 4.8 Population and Housing for Communities in the Rock Springs/Green River Area.1 

Total Housing Vacant Housing 

Community Population Units Units Percent Vacant 

Rock Springs 18,708 8,359 1,011 12.1 

North Rock Springs 1,974 739 41 5.5 

Reliance 665 272 23 8.5 

Green River 11,808 4,426 249 5.6 

Total 33,155 13,796 1,324 31.7 

Source: U.S. Census Bureau (2003). 

Therefore, based on current information, it appears 

that the housing of approximately 150 temporary 

construction workers would not result in any 

short-term housing shortages in the Rock 

Springs/Green River area. The temporary 

construction workers would utilize unoccupied 

apartments, mobile homes, rental house, mobile 

home/RV lots, and motel rooms in the Rock 

Springs/Green River area that appear to be 

available. It should also be noted that local 

residents filling the remaining temporary 

construction and indirect jobs created by the 

Proposed Action would already have housing and 

would not place any additional pressure on 

housing resources in the Rock Springs/Green 

River area. 

Community Facilities and Services 

In the absence of sizeable increases in the number 

of temporary workers that might relocate to the 

Rock Springs/Green River area during the 

construction phase of the Proposed Action, 

adverse impacts to community facilities and 

services are expected to be minimal. 

4.6.1.2 O&M Phase 

Employment and Income 

Starting in 2010 of the O&M phase of the 

Proposed Action, Teton expects that nine full-time 

wind plant specialists would be required to operate 

and maintain the WMWE facility (refer to 

Figure 4.1). This includes field technicians, 

administrators, and management personnel. These 

positions would be expected to generate an 

additional nine indirect and induced positions in 

the general project area. As the various phases of 

the wind plant become operational, more O&M 

personnel would be required, reaching a peak of 

employment of approximately 57 wind 

maintenance specialists in 2013. A total of 

107 indirect and induced (secondary) part- and 

full-time jobs would be required, and the level of 

employment would be expected to remain constant 

until 2030. It must also be noted that the JEDI 

model includes indirect and inducted jobs that 

would be created but located outside of 

Sweetwater County. During the O&M phase 

(2013-2030), it is expected that 83 part- or fulltime jobs would be created outside of the 

Rock Springs/Green River area. An additional 

24 secondary part- or full-time jobs would be 

created in the project area, and it is expected that 

all of these workers would already reside in the 

immediate project area. Starting in 2031, the wind 

plant will begin the decommissioning phase, and 

the project would be taken off-line and operational 

personnel would no longer be needed by 2034 

(LLC 2008). 

In summary, the number of direct O&M jobs and 

secondary jobs required in the Rock Springs/ 

Green River area would start in 2010 with 12 jobs 

and would increase to 35 in 2011, 59 in 2012, and 

would reach the maximum of 81 in 2013 and 

continue through to 2030. Then, starting in 2031, 
EA, White Mountain Wind Energy Project 4-27 

the various phases would start to be taken off-line, 

and the facility would start to be decommissioned. 

Only 69 direct O&M jobs and secondary jobs 

would be required. In 2032, this number would 

decrease to 46, and in 2033, this number would 

decrease to 23 jobs. There would not be any 

O&M jobs in 2034 (refer to Figure 4.3). 

Teton expects that during the full O&M phase of 

the WMWE Project (during 2013-2030), 

approximately 80% of the maximum number of 

direct O&M jobs (46 jobs) would be filled by 

individuals that currently reside outside of 

Sweetwater County, and these individuals and 

related families would relocate to the Rock 

Springs/Green River area. The remaining 

11 direct O&M jobs and the 24 secondary jobs 

would be filled by individuals that currently reside 

in the Rock Springs/Green River area. In order to 

maximize the economic benefit to the local 

economy, Teton is committed to and would hire 

local companies and employees when the 

appropriate firms and employees are available. 

Based on the results of the JEDI model, it is 

estimated that the aggregate income of direct and 

indirect workers during the O&M phase of this 

project (24 years) would total approximately 

$113,190,000. Income from direct and secondary 

workers residing in the Rock Springs/Green River 

area is expected to total approximately 

$81,270,000, and income from secondary workers 

that reside outside of the project area is expected 

to total approximately $31,925,000 during the 

O&M phase (LLC 2008). A substantial portion of 

these earnings would be spent in the local 

economy and would provide an economic stimulus 

to the local, county, and state economies. 

Sales and Use Taxes 

As discussed above, the JEDI model also provided 

the annual amount of sales and use tax revenue 

generated during the O&M phase of the Proposed 

Action, and the results are presented in Table 4.9 

(LLC 2008). The State of Wyoming levies a 4% 

sales and use tax, and Sweetwater County levies 

an additional 2%. During the 24-year O&M phase 

of this project, it is estimated that a total of 

approximately $465,000 in sales and use tax 

revenue would be generated for Sweetwater 

County, and approximately $2,780,000 in sales 

and use tax revenue would be generated for the 

State of Wyoming. The sales and use tax 

estimated output from the JEDI model includes 

only revenue derived from the taxable spending 

attributable to the WMWE Project’s direct effects, 

and it does not attempt to make estimates of the 

project’s “multiplier effect,” which generates some 

additional sales and use tax revenue as new money 

circulates in the regional economy. The sales and 

use tax revenue from the multiplier effect would 

be small compared to the direct sales and use tax 

revenue generated (LLC 2008). 

Property Taxes 

During the O&M phase of the Proposed Action, 

property tax revenue would also be generated. 

Based on the results of the JEDI model, the 

WMWE Project is expected to generate a total of 

approximately $45,200,000 in property tax 

revenue during the O&M phase of this project 

from 2014 through 2033, and this revenue 

projection is calculated in 2008 dollars (LLC 

2008). This analysis assumes straight-line 

depreciation throughout the O&M phase of the 

project. Therefore, annual property tax revenue 

would be expected to decrease starting in 2014 as 

no new facilities would be constructed and 

existing facilities are depreciated. 

Housing 

As discussed above, the O&M phase of the 

Proposed Action is expected to require a 

maximum of approximately 81 jobs in the local 

Rock Springs/Green River area, and these jobs 

would be needed from 2013-2034 (LLC 2008). 

As discussed above, 57 of these jobs would be 

direct O&M positions, and the remaining 24 jobs 

would be secondary. It is estimated that 

approximately 46 jobs (an estimated 80% of the 

57 direct O&M wind turbine workers) (depending 

on skill level and function) would likely 

permanently relocate from other areas to the Rock 

Springs/Green River area and would require 

permanent housing in the form of a single family 

house, apartment, condominium, or mobile home. 

Temporary housing options such as hotels, motels, 

or campgrounds may be required initially, but 
 

 

 

 

4-28 

1 

EA, White Mountain Wind Energy Project 

Table 4.9 Annual Sales and Use Tax Revenue Generated During the O&M Phase of WMWE 

Project, Proposed Action.1 

Operational Year Sweetwater County ($) State of Wyoming ($) 

2010 3,280 19,644 

2011 9,567 57,296 

2012 15,855 94,947 

2013-2030 398,556 (22,142 per year) 2,386,764 (132,598 per year) 

2031 18,861 112,954 

2032 12,574 75,303 

2033 6,287 37,651 

Total $464,980 $2,784,559 

Source: LLC (2008). 

these options would not be needed long-term 

because most permanent workers would avoid 

these types of housing options. 

While it is difficult to forecast housing trends in 

the Rock Springs/Green River area in 2013 

through 2034, the number of direct O&M jobs 

where employees would relocate to the Rock 

Springs/Green River area would start with seven 

jobs in 2010 and would increase to 20 in 2011, 33 

in 2012, and would reach the maximum of 46 in 

2013, and continue through to 2030. Starting in 

2031, the various phases of the project would start 

to be decommissioned, and the O&M jobs would 

eventually be eliminated by 2034. With the 

expected slow ramp up of housing needs during 

the O&M phase and the current availability of 

housing, the Proposed Action would be expected 

to have a minimum impact on the overall housing 

market in the Rock Springs/Green River area. 

While most of the specialized wind turbine 

construction jobs would be filled by experienced 

employees from outside of southwest Wyoming, 

the remaining 11 O&M jobs and all 24 of the 

secondary jobs would likely be filled by 

individuals that currently reside in the Rock 

Springs/Green River area. Therefore, these 

individuals are assumed to already have housing, 

and no additional housing accommodations would 

be required. 

Community Facilities and Services 

In the absence of sizeable increases in the number 

of O&M workers that might relocate to the 

Rock Springs/Green River area during the O&M 

phase of the Proposed Action, adverse impacts to 

community facilities and services are expected to 

be minimal. 

Property Values 

To address the concern that wind energy 

development projects could have an adverse 

impact on residential property values, three recent 

studies from the U.S. were reviewed. In the first 

study published in 2003 by the Renewable Energy 

Policy Project, commercial-scale wind turbines do 

not harm “viewshed” property values (Sterzinger 

el al. 2003). The study systematically analyzed 

property values data in 10 states across the U.S., 

including over 25,000 transactions of properties in 

view of wind energy projects over 10 MW in size 

from 1998 to 2001. The Renewable Energy Policy 

Project study found no evidence that property 

values were harmed by the presence of wind 

energy facilities (Sterzinger et al. 2003). 
EA, White Mountain Wind Energy Project 4-29 

In a second nation-wide study published in 2002, 

researchers interviewed county tax assessors in 

13 different counties in seven states that had 

recently experienced multiple-turbine wind energy 

developments. The study addressed a total of 19 

specific wind projects that had a total of 1,722 

wind turbines and that been constructed within the 

past 10 years. While not all the locations chosen 

had wind turbines that were visible from 

residential areas, and some development projects 

had been constructed too recently for their full 

impact to be properly assessed, the study found no 

evidence that wind turbines decreased property 

values (ECONorthwest 2002). 

In the third study published in 2006, an analysis of 

280 home sales within 5 mi of the Fenner wind 

energy project in Madison County, New York, 

failed to identify any statistically significant 

relationships between either proximity to or 

visibility of the wind energy project and the sale 

price of homes (Hoen 2006). In addition, the 

study failed to uncover any relationship even when 

concentrating on homes within 1 mi of the wind 

energy project or that sold immediately following 

the announcement and construction of the wind 

energy project. Based on the results of this study, 

the view of the wind energy project did not 

produce either a widespread or localized adverse 

effect (Hoen 2006). 

Property values are affected by many variables, 

and empirically isolating the impacts of one 

variable (a wind energy project) is difficult 

(National Research Council 2007). However, 

based on the results of these studies, there is no 

evidence that residential property values would be 

adversely impacted by the Proposed Action. 

4.6.1.3 Decommissioning Phase 

Employment and Income 

Decommissioning of the WMWE Project is 

expected to start in 2031 and would be completed 

by the end of 2034. Based on the number of direct 

construction jobs required to construct this project, 

it is estimated that approximately one-half of the 

number of direct and secondary jobs required 

during the construction phase would be required 

during the decommissioning phase. Based on this 

assumption, approximately 70 total jobs would be 

created in 2031, and a total of 136 jobs would be 

required in 2032-2034. In 2031, 48 direct 

construction-related jobs and one secondary job 

would be required in the Rock Springs/Green 

River area, and 21 secondary jobs located outside 

of Sweetwater County would be required. In 

2032-2034, the number of required direct 

construction-related jobs in Sweetwater County 

would increase to 94, with two required secondary 

jobs in Sweetwater County and 40 required 

secondary jobs located outside of Sweetwater 

County. 

Teton expects that during the decommissioning 

phase of the WMWE Project, approximately 80% 

of the direct decommissioning construction jobs 

would be filled by individuals that currently reside 

outside of Sweetwater County. The remaining 

direct construction-related, and the few secondary 

jobs, would be filled by individuals that currently 

reside in the Rock Springs/Green River area. The 

remaining secondary jobs would remain located 

outside of the Rock Springs/Green River area. In 

order to maximize the economic benefit to the 

local economy, Teton is committed to and would 

hire local companies and employees when the 

appropriate firms and employees are available. 

Based on the results of the JEDI model for the 

construction phase of the Proposed Action, it is 

estimated that the aggregate income of direct and 

indirect workers during the decommissioning 

phase of this project (4 years) would total 

approximately $19,550,000. Income from direct 

workers is expected to total approximately 

$12,540,000, and income from indirect workers is 

expected to total approximately $7,010,000 for the 

decommissioning phase (LLC 2008). A 

substantial portion of these earnings would be 

earned and spent in the local economy and would 

provide an economic stimulus to the local, county, 

and state economies. 

Sales and Use Taxes 

Based on the results of the JEDI model for the 

construction phase, the annual amount of sales and 

use tax revenue generated during the 
4-30 EA, White Mountain Wind Energy Project 

decommissioning phase of the Proposed Action 

and the results are presented in Table 4.10. The 

State of Wyoming levies a 4% sales and use tax, 

and Sweetwater County levies an additional 2%. 

The sales and use tax projections take into account 

the Wyoming state exemption on renewable 

generation projects, and this exemption applies to 

sales of equipment used to generate electricity 

from renewable resources, including equipment 

used in wind energy generation. It is a broadbased exemption that covers the items necessary to 

make the project operational, but it does not apply 

to the construction of access roads, to any 

purchases made once the project is operational, or 

to equipment not ultimately connected to the 

transmission grid, such as a building that may be 

used to house grid-connected equipment. The 

sales and use tax estimated output from the JEDI 

model includes only revenue derived from the 

taxable spending attributable to the WMWE 

Project’s direct effects, which are expected to be 

only 25% of that generated during the construction 

phase of the project. In addition, this estimate 

does not attempt to make estimates of the project’s 

“multiplier effect,” which generates some 

additional sales and use tax revenue as new money 

circulates in the regional economy. The sales and 

use tax revenue from the multiplier effect would 

be small compared to the direct sales and use tax 

revenue generated (LLC 2008). 

Property Taxes 

Based on the results of the JEDI model, there will 

be no additional property taxes generated during 

the decommissioning phase of this project (LLC 

2008). 

Housing 

It is estimated that in 2031, approximately 

38 specialized nonlocal construction workers 

would temporarily relocate to the Rock 

Springs/Green River area to fill jobs not held by 

local workers. In 2032-2034, the number of 

required specialized nonlocal construction workers 

that would temporarily relocate to the Rock 

Springs/Green River area would increase to 75. 

The maximum increase of 75 nonconstruction 

workers would comprise less than one-half of one 

percent of the approximate 33,155 residents in the 

Rock Springs/Green River area as of 2000 (U.S. 

Census Bureau 2003). 

Nonlocal workers would likely temporarily reside 

in Rock Springs, North Rock Springs, Green 

River, or Reliance since these are the closest 

communities to the project area. Assuming a oneway commute time of less than 1 hour, there are a 

number of rental units/homes, hotels, motels, and 

campgrounds that could accommodate these 

nonlocal workers. The primary access into the 

project area is from U.S. Highway 191 near the 

closed Fourteenmile Rest Area, and it is 

approximately 11.0 mi north of Rock Springs, 

approximately 8.0 mi north of North Rock 

Springs, approximately 10.0 mi north of Reliance, 

and approximately 26.0 mi northeast of Green 

River. 

Table 4.10 Annual Sales and Use Tax Revenue Generated During the Decommissioning Phase of the 

WMWE Project, Proposed Action. 

Construction Year Sweetwater County ($) State of Wyoming ($) 

2031 3,955 52,955 

2032-2034 7,580 101,500 

Total $11,535 $154,455 
EA, White Mountain Wind Energy Project 4-31 

Based on the most current available housing data 

obtained from the U.S. Census Bureau for the year 

2000 (U.S. Census Bureau 2003), there were 

13,796 total housing units in the immediate project 

area (which included the communities of Rock 

Springs, North Rock Springs, Reliance, and Green 

River), and approximately 1,324 units (9.6%) were 

vacant. This number does not include 

hotels/motels, mobile home and RV spaces, and 

campgrounds. It should also be noted that while 

decommissioning efforts are underway, there will 

also be a decrease in the number of O&M workers 

from 57 to 0 over the same period of time (2031­

2034). Therefore, while it is difficult to forecast 

the number of available housing units in 2030, it is 

likely that the addition of a maximum of 

75 temporary works moving into the area during 

the decommissioning phase would have minimal 

impacts on the overall housing market in the 

Rock Springs/Green River area. 

Community Facilities and Services 

In the absence of sizeable increases in the number 

of construction workers that might relocate to the 

Rock Springs/Green River area during the 

decommissioning phase of the Proposed Action, 

adverse impacts to community facilities and 

services are expected to be minimal. 

4.6.2 Alternative A - Development Only on 

Privately Owned Lands 

4.6.2.1 Construction Phase 

Employment and Income 

Under the construction phase of Alternative A, the 

impacts to employment and income would be 

similar to those identified under the Proposed 

Action. Based on the number of wind turbines 

presented under Alternative A, there would be an 

estimated maximum of approximately 250 fulland part-time jobs created. Approximately 131 

direct temporary construction jobs and 119 

indirect and induced (secondary) part- and fulltime jobs would be created during the 3- to 4-year 

construction period of the WMWE Project. Of the 

119 secondary jobs, it is expected that three jobs 

would be created in Sweetwater County, and the 

remaining 116 secondary jobs would be created 

outside of Sweetwater County. 

It is estimated that the aggregate income of direct 

and indirect workers under Alternative A would 

total approximately $27,300,000. Income from 

direct workers is expected to total approximately 

$18,100,000, and income from indirect and 

induced workers is expected to total approximately 

$9,200,000 during the 4-year construction phase of 

Alternative A. 

Sales and Use Taxes 

It is expected that during the 3- to 4-year 

construction phase of Alternative A, a total of 

approximately $32,000 in sales and use tax 

revenue would be generated for Sweetwater 

County, and approximately $433,000 in sales and 

use tax revenue would be generated for the State 

of Wyoming. 

Property Taxes 

During the construction phase of Alternative A, 

property tax revenue would also be generated. It 

is estimated that a total of approximately 

$7,420,000 in property tax revenue would be 

generated during the 4 years of construction. 

Projected property tax revenues would rise to the 

maximum amount over the life of the project 

during year 4 of construction after all project 

phases have been added to the tax roll. The total 

assessed value and tax revenue would decline 

thereafter during the O&M phase because of the 

valuation method used to estimate property taxes. 

Housing 

It is estimated that a maximum of approximately 

105 of the 131 (80%) specialized nonlocal wind 

turbine workers would temporarily relocate to the 

Rock Springs/Green River area to fill jobs not held 

by local workers. As outlined under the Proposed 

Action, it is unlikely that the nonlocal workers 

would be accompanied by family members, and 

the temporary relocation workers would peak 

during the second construction year of the project. 

The increase of 105 nonconstruction workers 

would comprise less than one-half of one percent 
4-32 EA, White Mountain Wind Energy Project 

of the approximate 33,155 residents in Rock 

Springs/Green River area as of 2000 (U.S. Census 

Bureau 2003). 

Nonlocal workers would likely temporarily reside 

in Rock Springs, North Rock Springs, Green 

River, or Reliance since these are the closest 

communities to the project area. Assuming a oneway commute time of less than 1 hour, there are a 

number of rental units/homes, hotels, motels, and 

campgrounds that could accommodate these 

nonlocal workers. The primary access into the 

project area is from U.S. Highway 191 near the 

closed Fourteenmile Rest Area, and it is 

approximately 11.0 mi north of Rock Springs, 

approximately 8.0 mi north of North Rock 

Springs, approximately 10.0 mi north of Reliance, 

and approximately 26.0 mi northeast of Green 

River. 

The most current detailed housing data were 

obtained from the U.S. Census Bureau for the year 

2000 (U.S. Census Bureau 2003). As of the 2000 

census, there were 13,796 total housing units in 

the immediate project area (including the 

communities of Rock Springs, North Rock 

Springs, Reliance, and Green River), and 

approximately 1,324 units (9.6%) were vacant. 

This number does not include hotels/motels, 

mobile home and RV spaces, and campgrounds. 

Therefore, based on current information presented 

under Alternative A, it appears that the housing of 

approximately 105 temporary construction 

workers will not result in any short-term housing 

shortages in the Rock Springs/Green River area. 

The temporary construction workers would utilize 

unoccupied apartments, mobile homes, rental 

house, mobile home/RV lots, and motel rooms in 

the Rock Springs/Green River area that are 

available. It should also be noted that local 

residents filling the remaining temporary 

construction jobs and indirect jobs created by 

Alternative A would already have housing and 

would not place any additional pressure on 

housing resources in the Rock Springs/Green 

River area. 

Community Facilities and Services 

In the absence of sizeable increases in the number 

of temporary workers that might relocate to the 

Rock Springs/Green River area during the 

construction phase of Alternative A, adverse 

impacts to community facilities and services are 

expected to be minimal. 

4.6.2.2 O&M Phase 

Employment and Income 

Under the O&M phase of Alternative A, the 

impacts to employment and income would be 

similar to those identified under the Proposed 

Action. Based on the number of wind turbines 

presented under Alternative A, an estimated 

maximum of approximately 114 full- and parttime jobs would be created inside and outside of 

Sweetwater County. Approximately 39 direct 

O&M jobs and 75 indirect and induced 

(secondary) part- and full-time jobs would be 

created during the 24-year O&M phase of 

Alternative A. Of the 75 secondary jobs, it is 

expected that 17 jobs would be created in 

Sweetwater County and the remaining 58 

secondary jobs would be created outside of 

Sweetwater County. 

It is estimated that the aggregate income of direct 

and indirect workers under Alternative A would 

total approximately $79,200,000. Income from 

direct workers is expected to total approximately 

$57,300,000, and income from indirect and 

induced workers is expected to total approximately 

$21,900,000 during the 24-year O&M phase of 

Alternative A. 

Sales and Use Taxes 

During the 24-year O&M phase of Alternative A, 

it is estimated that a total of approximately 

$325,500 in sales and use tax revenue would be 

generated for Sweetwater County, and 

approximately $1,940,000 in sales and use tax 

revenue would be generated for the State of 

Wyoming. 
EA, White Mountain Wind Energy Project 4-33 

Property Taxes 

During the O&M phase of Alternative A, it is 

expected that a total of approximately $31,600,000 

in property tax revenue would be generated from 

2014 through 2033, and this revenue projection is 

calculated in 2008 dollars. This analysis assumes 

straight-line depreciation throughout the O&M 

phase of the project. Therefore, annual property 

tax revenue would be expected to decrease starting 

in 2014 because no new facilities would be 

constructed and existing facilities would 

depreciate. 

Housing 

The O&M phase of Alternative A is expected to 

require a maximum of approximately 56 direct and 

secondary jobs in the local Rock Springs/Green 

River area, and these jobs would be needed from 

2013-2034. As discussed above, 39 of these jobs 

would be direct O&M positions and the remaining 

17 jobs would be secondary (indirect and 

induced). It is estimated that approximately 31 

jobs (an estimated 80% of the 39 direct O&M 

wind turbine workers) (depending on skill level 

and function) would likely permanently relocate 

from other areas to the Rock Springs/Green River 

area and would require permanent housing in the 

form of a single family house, apartment, 

condominium, or mobile home. Temporary 

housing options such as hotels, motels, or 

campgrounds may be required initially, but these 

options would not be needed long term because 

most permanent workers would avoid these types 

of housing options. 

While it is difficult to forecast housing trends in 

the Rock Springs/Green River area in 2013 

through 2034, the number of direct O&M jobs 

where employees would relocate to the Rock 

Springs/Green River area would start with 

approximately five jobs in 2010 and would slowly 

increase to maximum of 31 in 2013 and continue 

through to 2030. Starting in 2031, the various 

phases of the project would start to be 

decommissioned, and the O&M jobs would 

eventually be eliminated by 2034. With the 

decline of housing needs during the O&M phase 

and the current availability of housing, 

Alternative A would be expected to have a 

minimum impact on the overall housing market in 

the Rock Springs/Green River area. 

While most of the specialized wind turbine O&M 

jobs would be filled by experienced employees 

from outside of southwest Wyoming, the 

remaining eight O&M jobs and all 17 of the 

secondary jobs would likely be filled by 

individuals that currently reside in the Rock 

Springs/Green River area. Therefore, these 

individuals are assumed to already have housing, 

and no additional housing accommodations would 

be required. 

Community Facilities and Services 

In the absence of sizeable increases in the number 

of temporary workers that might relocate to the 

Rock Springs/Green River area during the O&M 

phase of Alternative A, adverse impacts to 

community facilities and services are expected to 

be minimal. 

4.6.2.3 Decommissioning Phase 

Employment and Income 

Under the decommissioning phase of Alternative 

A, the impacts to employment and income would 

be similar to those identified under the Proposed 

Action. Based on the number of wind turbines 

presented under Alternative A, an estimated 

maximum of approximately 96 full- and part-time 

jobs would be created. Approximately 66 direct 

temporary construction jobs and 30 indirect and 

induced (secondary) part- and full-time jobs would 

be created during the 4-year decommissioning 

phase of the WMWE Project. Of the 30 secondary 

jobs, it is expected that two jobs would be created 

in Sweetwater County and the remaining 28 

secondary jobs would be created outside of 

Sweetwater County. 

It is estimated that the aggregate income of direct 

and indirect workers under Alternative A would 

total approximately $13,650,000. Income from 

direct workers is expected to total approximately 

$9,050,000, and income from indirect and induced 

workers is expected to total approximately 
4-34 EA, White Mountain Wind Energy Project 

$4,600,000 during the 4-year decommissioning 

phase of Alternative A. 

Sales and Use Taxes 

It is expected that during the 4-year 

decommissioning phase of Alternative A, a total of 

approximately $16,000 in sales and use tax 

revenue would be generated for Sweetwater 

County, and approximately $216,000 in sales and 

use tax revenue would be generated for the State 

of Wyoming. 

Property Taxes 

As with the Proposed Action, there will be no 

additional property taxes generated during the 

decommissioning phase of this project. 

Housing 

Under Alternative A, it is estimated that in 2031, 

approximately 27 specialized nonlocal 

construction workers would temporarily relocate 

to the Rock Springs/Green River area to fill jobs 

not held by local workers. In 2032-2034, the 

number of required specialized nonlocal 

construction workers would increase to 53. The 

maximum increase of 53 nonconstruction workers 

would comprise less than one-half of one percent 

of the approximate 33,155 residents in the Rock 

Springs/Green River area as of 2000 (U.S. Census 

Bureau 2003). 

Nonlocal workers would likely temporarily reside 

in Rock Springs, North Rock Springs, Green 

River, or Reliance since these are the closest 

communities to the project area. Assuming a oneway commute time of less than 1 hour, there are a 

number of rental units/homes, hotels, motels, and 

campgrounds that could accommodate these 

nonlocal workers. The primary access into the 

project area is from U.S. Highway 191 near the 

closed Fourteenmile Rest Area, and it is 

approximately 11.0 mi north of Rock Springs, 

approximately 8.0 mi north of North Rock 

Springs, approximately 10.0 mi north of Reliance, 

and approximately 26.0 mi northeast of Green 

River. 

Based on the most current housing data (U.S. 

Census Bureau 2003), there were 13,796 total 

housing units in the immediate project area 

(including the communities of Rock Springs, 

North Rock Springs, Reliance, and Green River), 

and approximately 1,324 units (9.6%) were 

vacant. This number does not include 

hotels/motels, mobile home and RV spaces, and 

campgrounds. It should also be noted that while 

decommissioning efforts are underway, there 

would be a decrease in the number of O&M 

workers from 39 to 0 over the same period of time 

(2031-2034). Therefore, while it is difficult to 

forecast the number of available housing units 

from 2030-2034, it is likely that the addition of a 

maximum of 53 temporary construction workers 

moving into the area during the decommissioning 

phase would have minimal impacts on the overall 

housing market in the Rock Springs/Green River 

area. 

While most of the specialized wind turbine 

construction required for decommissioning would 

be filled by experienced employees from outside 

of southwest Wyoming, the remaining 13 

construction jobs and both of the secondary jobs 

would likely be filled by individuals that currently 

reside in the Rock Springs/Green River area. 

Therefore, these individuals are assumed to 

already have housing, and no additional housing 

accommodations would be required. 

Community Facilities and Services 

In the absence of sizeable increases in the number 

of temporary workers that might relocate to the 

Rock Springs/Green River area during the 

decommissioning phase of Alternative A, adverse 

impacts to community facilities and services are 

expected to be minimal. 

4.6.3 No Action Alternative 

Under the No Action Alternative, the proposed 

wind energy facility would not be authorized or 

approved. No jobs would be created, and there 

would be no impacts to socioeconomic resources 

beyond those that already exist. 
EA, White Mountain Wind Energy Project 4-35 

4.6.4 Residual Impacts 

There would be some unavoidable changes in 

employment and housing in the Rock 

Springs/Green River area as a result of the 

Proposed Action. While impacts to housing could 

be seen as detrimental, these impacts would be 

limited given the current availability of housing in 

the area. Other impacts such as tax revenue would 

be positive and beneficial to the local, state, and 

national economies. 

4.6.5 Cumulative Impacts 

The BLM has defined the IAA for socioeconomic 

resources as Sweetwater County. Wind energy 

development associated with the Proposed Action 

within the IAA would add to the economic 

viability of Sweetwater County, the State of 

Wyoming, and the U.S. As described in the 

property tax and sales and use tax sections, the 

various phases of the Proposed Action would be a 

source of tax revenue for municipal, county, state, 

and federal governments--a desirable outcome 

from an economic development perspective--in 

addition to the other ongoing and RFFAs that are 

anticipated within Sweetwater County. The 

Proposed Action would add to the economic 

stability for the various government entities. 

Starting in 2010, the Proposed Action would 

provide approximately 100 part- and full-time jobs 

in Sweetwater County. In 2012, this number 

would steadily increase to a maximum of 249 partand full-time jobs in Sweetwater County for all 

direct and secondary construction and O&M jobs. 

Total employment in Sweetwater County related 

to the Proposed Action would remain steady from 

2013-2030 with approximately 81 direct and 

secondary O&M jobs. The total number of jobs 

would increase slightly from 2031-2032 with 142 

jobs as the Proposed Action is decommissioned. 

The total number of jobs in Sweetwater County 

would then decrease because all decommissioning 

and reclamation work would be completed by the 

end of 2034. 

As discussed above, specialized wind construction 

or O&M workers would relocate to the area, and 

are expected to live in the Rock Springs/Green 

River area and the communities of Rock Springs, 

North Rock Springs, Reliance, or Green River 

since these communities are located within a short 

commute of the WMWE project area. The 

number of combined construction and O&M 

workers that would relocate to the 

Rock Springs/Green River area would increase 

from 78 in 2009 to a maximum of 188 in 2012 

during the construction phase, decrease to 46 

during the 24-year O&M phase of the project 

2013-2030, increase slightly to 101 in 2032, and 

then decreasing to 75 in 2034 during the 

decommissioning phase. As of the 2000 census, 

there were 13,796 total housing units in the Rock 

Springs/Green River area, and approximately 

1,324 units (9.6%) were vacant. This number does 

not include hotels/motels, mobile home and RV 

spaces, and campgrounds. Therefore, based on the 

most recent housing numbers for the 

Rock Springs/Green River area, the Proposed 

Action would result in limited impacts to the 

Sweetwater County housing market, and there 

would be minimal impacts to community facilities 

and services. 

From an employment perspective, the WMWE 

Project itself is a relatively small project and 

would likely contribute little to cumulative 

impacts to socioeconomics. More monies would 

also be available to the Sweetwater County school 

districts. In addition, there would be no impact on 

residential property values. 

4.7 SOILS 

4.7.1 Proposed Action 

4.7.1.1 Construction Phase 

Construction activities associated with the 

Proposed Action would result in the initial 

disturbance of 866 acres of land within the 13,165 

acres of project area, and 162 acres of land would 

remain occupied by roads, turbine foundations, 

and facilities for the life of the project. 

Construction activities, including topsoil salvage, 

grading, cut-and-fill activities, and construction of 

access roads, would compact or destabilize the soil 

surface and increase the potential for soil erosion 
4-36 EA, White Mountain Wind Energy Project 

by water or wind. The most likely time for 

erosion to occur is after initial disturbance and 

before re-establishment of vegetative cover or 

placement of concrete foundations. An increase in 

erosion can result in an increase in runoff and 

sedimentation into receiving waters. In addition, 

erosion can cause a number of problems, including 

damage to foundations, roadways, and other 

structures, loss of topsoil, slowed restoration rates, 

and loss of structure in soils that are disturbed or 

driven on during construction. Impact to soils 

from excavation activities include a mixing of soil 

horizons, susceptibility to wind and water erosion, 

and reduced range productivity. 

Equipment travel throughout the project area 

would result in increased soil compaction. 

Moderate or severe soil compaction would affect 

soil productive potential. The extent of 

compaction would depend in large part on soil 

moisture content and the physical characteristics 

of a particular soil type. Compaction tends to be 

less severe when soils are dry and more severe 

when soils are moist to wet. 

The project area includes soil types that are 

categorized as either sandy or erosive (BLM 

1996). In order to minimize potential erosion and 

prior to the initiation of construction operations, an 

SWPPP, which includes erosion control measures, 

would be prepared and implemented for the 

project area. The SWPPP would be based on the 

1992 EPA document entitled Storm Water 

Management for Construction ActivitiesDeveloping Pollution Prevention Plans and Best 

Management Practices (1992). Implementation of 

the SWPPP would minimize the impact to soils 

and erosion to low levels. All surface-disturbed or 

compacted areas not needed during the O&M 

phase of the project would be regraded, ripped, 

retopsoiled, and revegetated in accordance with 

the reclamation plan outlined under the Proposed 

Action. Application of design features to prevent 

soil erosion would be used throughout the 

implementation of the project. After erosion 

control and reclamation operations have been 

successfully completed, soil stability would likely 

be achieved, and the rate of erosion would return 

to predisturbance levels. 

4.7.1.2 O&M Phase 

No additional impacts beyond those discussed 

under construction impacts are expected to occur 

during the O&M phase of this project. Impacts to 

soils during the O&M phase of the project would 

largely be associated with limited soil erosion 

induced by vehicle traffic on existing roads; 

however, soil erosion from this source is expected 

to be minor. Teton will continue to implement the 

SWPPP for this project and will monitor and 

repair any areas of erosion or soil instability. 

4.7.1.3 Decommissioning Phase 

No additional impacts beyond those discussed 

under construction impacts are expected to occur 

during the decommissioning phase of this project. 

Soil erosion and some compaction are the primary 

impacts that would be expected from removal of 

roads, turbines, and other structures. Control of 

surface runoff and sedimentation during the 

decommissioning phase of the project would be 

accomplished by the continued implementation of 

SWPPP and other design features specified in 

Chapter 2.0 of this EA and would generally reduce 

the impact to soils to low levels. After final 

reclamation operations have been successfully 

completed, soil stability would likely be achieved, 

and the rate of erosion would return to 

predisturbance levels. Reclaimed areas would be 

considered stable if there are no large rills or 

gullies, no slumping or subsidence, no substantial 

soil movement, no headcutting in drainages, and 

no slope instability that can be attributed to 

construction, O&M, and after decommissioning of 

the project. Specifically, for BLM-administered 

lands, Wyoming Rangeland Standards would be 

met, and applicable standards would be met on 

private and state lands. 

4.7.2 Alternative A - Development Only on 

Privately Owned Lands 

4.7.2.1 Construction Phase 

Potential direct and indirect impacts associated 

with soil resources under the construction phase of 

Alternative A would be similar to the type of 

impacts described in the Proposed Action. 
EA, White Mountain Wind Energy Project 4-37 

Implementation of this alternative would involve 

the construction of 170 wind turbines on privately 

owned land; therefore, direct impacts to soil 

resources could include the disturbance of 619 

acres of soils from the excavation of the turbine 

pads, the substation, and the collector lines. The 

potential impact to soils would be 30% less than 

those anticipated under the Proposed Action. 

Control of surface runoff and sedimentation during 

the construction phase of the project would be 

accomplished by the implementation of the 

SWPPP and other design features specified in 

Chapter 2.0 of this EA, and would generally 

reduce the impact to soils to low levels. Teton 

would implement stability and erosion practices 

for all temporary and permanent reclamation in 

accordance with the SWPPP for the project. After 

temporary reclamation operations have been 

successfully completed following construction, 

soil stability would likely be achieved, and the rate 

of erosion would return to predisturbance levels. 

4.7.2.2 O&M Phase 

Under the O&M phase of Alternative A, no 

additional impacts beyond those discussed under 

construction impacts are expected to occur. 

Control of surface runoff and sedimentation during 

the O&M phase of the project would be 

accomplished by the implementation of the 

SWPPP and other design features specified in 

Chapter 2.0 of this EA. 

4.7.2.3 Decommissioning Phase 

Under the decommissioning phase of Alternative 

A, no additional impacts beyond those discussed 

under construction impacts are expected to occur. 

Soil erosion and some compaction are the primary 

impacts that would be expected from removal of 

roads, turbines, and other structures. Control of 

surface runoff and sedimentation during the 

decommissioning phase of the project would be 

accomplished by the implementation of the 

SWPPP and other design features specified in 

Chapter 2.0 of this EA and would reduce the 

impact to soils to low levels. After final 

reclamation operations have been successfully 

completed following decommissioning, soil 

stability would likely be achieved, and the rate of 

erosion would return to predisturbance levels. 

Reclaimed areas would be considered stable if 

there are no large rills or gullies, no slumping or 

subsidence, no substantial soil movement, no 

headcutting in drainages, and no slope instability 

that can be attributed to construction, O&M, and 

after decommissioning of the project. 

Specifically, for BLM-administered lands, 

Wyoming Rangeland Standards would be met, and 

applicable standards would be met on private and 

state lands. 

4.7.3 No Action Alternatives 

Under the No Action Alternative, the proposed 

wind energy facility would not be authorized nor 

approved. No ground would be disturbed, and no 

impacts to soils would take place beyond those 

that already exist. 

4.7.4 Residual Impacts 

Implementation of the Proposed Action or 

Alternative A would result in some temporarily 

increased and unavoidable soil loss and 

sedimentation to the receiving waters as a result of 

water and wind erosion. Productivity of some 

disturbed soils would be reduced due to vegetation 

removal, soil compaction and exposure, mixing of 

horizons, and increased susceptibility to wind and 

water erosion. 

4.7.5 Cumulative Impacts 

Impacts to soil resources would be minimized by 

implementation of the SWPPP and other design 

features specified in Chapter 2.0 of this EA. 

These mitigation measures will address temporary 

disturbance and life-of-project disturbance. 

Within 2-3 years after the BMPs have been 

installed, soil stability would likely be achieved. 

In addition, temporary and permanent reclamation 

operations would eventually (within 10-20 years) 

return vegetation cover to predisturbance levels, 

and the rate of erosion would also return to 

predisturbance levels. 

Based on the disturbance calculations presented in 

Chapter 3.0, approximately 19,954 acres are 
4-38 EA, White Mountain Wind Energy Project 

currently disturbed within the IAA. This 

represents 7.43% of the total area within the IAA. 

RFFA (including the Proposed Action) within the 

cumulative IAA would result in an additional 

1,250 acres of disturbance--189 acres of 

disturbance due to the Proposed Action and 1,061 

acres from other RFFAs. This represents 21,204 

acres of the total within the IAA or 7.89% based 

on the total disturbance due to past, present, and 

RFFAs. 

Provided that reclamation efforts are timely and 

successful, cumulative impacts to soils resources 

should be within acceptable limits and would not 

result in impacts beyond those that already exist or 

have already been identified and discussed in 

Chapter 4.0 of this EA. 

4.8 THREATENED, ENDANGERED, 

CANDIDATE, PROPOSED, AND 

BLM SENSITIVE SPECIES 

4.8.1 TEPC Species 

No federally listed TEPC species were 

documented in the WMWE project area during 

wildlife surveys conducted in association with this 

project (TRC 2008a, 2008b, 2008c, 2008d, 2009b) 

or would be expected to be found in the WMWE 

project area. Therefore, the risk to such species 

during construction, O&M, and decommissioning 

phases of the WMWE Project would be minimal. 

In addition, the BLM consulted with the USFWS 

concerning the 420-acre-ft life of project water 

depletion for the WMWE project and potential 

impacts on Colorado River endangered fish 

species. On October 2, 2009, the USFWS issued a 

biological opinion and in accordance with the RIP 

for Endangered Species in the Upper Colorado 

River Basin determined that annual water 

depletion would require payment to the USFWS in 

order to offset effects of the project. Therefore, 

Teton would make a one-time payment prior to the 

commencement of construction to mitigate water 

depletion and potential impacts to Colorado River 

endangered fish species. 

4.8.2 BLM Sensitive Species 

4.8.2.1 Construction Phase 

Several BLM listed avian sensitive species (BLM 

2002) were documented in the WMWE project 

area including: ferruginous hawk, Brewer’s 

sparrow, sage sparrow, sage thrasher, loggerhead 

shrike, and greater sage-grouse (TRC 2009b). 

Ferruginous hawks could be impacted as a result 

of construction-related disturbance during the 

nesting season (BLM 2005; National Research 

Council 2007; Arnett et al. 2007). The BLM has 

established seasonal and no surface occupancy 

restriction areas that Teton will comply with 

according to BLM policy (BLM 1997). 

Additionally, Teton has committed to adopting a 

50-m (164-ft) minimum setback from the ridgeline 

of White Mountain, as well as the edge of intergorge of large intermittent or ephemeral drainages 

to further reduce impacts to avian species. Table 

2.9 lists the seasonal restriction areas, as well as 

the no surface occupancy buffers, and Teton 

would not place any wind turbines within these no 

surface occupancy buffer areas. In addition, to 

reduce the risk of electrocution to ferruginous 

hawks, all electrical systems and components will 

be designed, constructed, operated, and maintained 

in conformance with the National Electrical Safety 

Code and other applicable codes and standards, as 

well as Suggested Practices for Raptor Protection 

on Power Lines: The State of the Art in 2006 

(Avian Power Line Interaction Committee 2006). 

As a result, implementation of these design 

features would minimize risk to ferruginous hawks 

during construction operations. The risk to 

ferruginous hawks would be low and the impact 

would fall within the range acknowledged in the 

Wind Energy PEIS (BLM 2005). 

Construction impacts to sparrow, sage sparrow, 

sage thrasher, and loggerhead shrike could result 

from habitat disturbance (i.e., the removal of 

vegetation during site preparation) and direct 

injury or mortality (BLM 2005; National Research 

Council 2007; Arnett et al. 2007). However, the 

removal of natural vegetation (grassland and shrub 

communities) would be minimized to the extent 

possible during construction. In addition, ground 

disturbing activity and the movement of 
EA, White Mountain Wind Energy Project 4-39 

construction personnel and equipment on-site 

would be limited to the extent possible to the 

construction areas to avoid inadvertent impacts to 

all wildlife species. The risk to PSB during the 

construction phase of this project would be low, 

and the impact would fall within the range 

acknowledged in the Wind Energy PEIS (BLM 

2005). 

Construction impacts to greater sage-grouse could 

result from habitat disturbance (i.e., the removal of 

vegetation during site preparation), displacement, 

and direct injury or mortality (BLM 2005; 

National Research Council 2007; Arnett et al. 

2007). To minimize potential impacts, 

construction personnel would be informed that 

greater sage-grouse occur in the project area and 

that they are not allowed to haze or harass greater 

sage-grouse, and they should minimize any direct 

disturbance to the greater sage-grouse whenever 

possible. In addition, ground-disturbing activity 

and the movement of construction personnel and 

equipment on-site would be limited to the extent 

possible to the construction areas to avoid 

inadvertent impacts to greater sage-grouse. 

Mountain plover in the general project area are 

found in cushion plant communities and on 

windswept ridges (personal communication, June 

10, 2002, with Lorraine Keith, BLM RSFO), and 

breeding/nesting habitat is often associated with 

active prairie dog towns (Dinsmore 2003). A 

small portion of proposed project area is 

composed of greasewood fans and flats and basin 

exposed rock with areas that are relatively void of 

vegetation, and it is possible that these areas could 

provide suitable nesting and foraging habitat for 

mountain plover. However, no mountain plovers 

were observed during 20+ weeks of diurnal and 

nocturnal avian migration studies conducted in 

2008 (TRC 2009b). No mountain plover 

observations have been recorded in the vicinity the 

proposed WMWE project area (WNDD 2009). To 

minimize potential impacts to nesting mountain 

plover, Teton would conduct presence/absence 

surveys prior to vegetation removal and 

construction. If mountain plovers are found, 

Teton would work with the BLM to modify 

turbine placement to avoid the nesting birds, or 

they would wait to conduct construction activities 

until nesting activities have been completed. It is 

also possible that some mountain plovers could 

collide with a rotating wind turbine blades; 

however, while possible, these events are unlikely 

to occur because of the low density of mountain 

plovers in the WMWE project area. Therefore, the 

Proposed Action is expected to have minimal 

direct impacts on any nesting mountain plovers 

and minimal indirect impacts (through increased 

mortalities due to wind turbine and vehicle 

collisions) on any mountain plovers in the 

immediate project area. The risk to mountain 

plovers would be low, and the impact would fall 

within the range acknowledged in the Wind 

Energy PEIS (BLM 2005). 

Pygmy rabbit habitat occurs throughout the project 

area as inclusions of preferred vegetation densities 

and heights within Wyoming big sagebrush; 

therefore, impacts to pygmy rabbits could result 

from the removal of vegetation (clearing, 

grubbing, etc.) and compaction of soil during site 

preparation. It is also possible that increased 

human presence during the life of the project could 

lead to an increased number of predators such as 

coyotes and red foxes. The increased presence of 

predators could result in increased predation on 

pygmy rabbits and other small mammals. The 

removal of natural vegetation (grassland and shrub 

communities) would be minimized to the extent 

possible during construction. In addition, the 

movement of personnel and equipment on-site 

would be limited to the extent possible to 

construction areas to avoid inadvertent compaction 

of soil. Presence/absence surveys for pygmy 

rabbits and their associated habitat would be 

conducted prior to vegetation removal and 

construction. If pygmy rabbits are found, Teton 

would work with the BLM to modify turbine 

placement to avoid habitat to the extent possible. 

The risk to pygmy rabbits would be low, and the 

impact would fall within the range acknowledged 

in the Wind Energy PEIS (BLM 2005). 

Impacts to other BLM sensitive passerine birds 

(e.g., not recorded in the project area) and 

mammal species (e.g., Wyoming pocket gopher) 

during the construction phase of the Proposed 

Action would likely be the same as discussed for 

wildlife, including birds, presented in Section 4.12 
4-40 EA, White Mountain Wind Energy Project 

of this EA. These potential impacts are within the 

range documented and acknowledged in the BLM 

Wind Energy Programmatic EIS (BLM 2005). 

Impacts to midget-faded rattlesnakes and other 

reptiles or amphibians would be eliminated or 

reduced after the results of the den survey and 

appropriate mitigation can be developed with the 

BLM, WGFD, and Teton if these species are 

found. 

It is possible that cedar rim thistle could be found 

within suitable habitats within the WMWE project 

area. To mitigate potential impacts to cedar rim 

thistle, Teton would conduct surveys for cedar rim 

thistle and their associated habitat prior to 

vegetation removal and construction. If any cedar 

rim thistle is found, Teton would avoid physical 

disturbance to these plants and work with the 

BLM to modify turbine/road placement. 

4.8.2.2 O&M Phase 

During the O&M phase of the project, impacts to 

ferruginous hawk, Brewer’s sparrow, sage 

sparrow, sage thrasher, loggerhead shrike, and 

greater sage-grouse would be different and 

primarily related to potential collisions with the 

operating wind turbines and service vehicles 

(BLM 2005; National Research Council 2007; 

Arnett et al. 2007). 

Ferruginous Hawk. Based on the avian use study, 

20 ferruginous hawk observations were recorded 

during the RLB continuous surveys, and the 

species is known to nest adjacent to the project 

area (TRC 2009b). Forty-five percent of the 

ferruginous hawks were observed flying, and five 

of the nine flying observations (56%) were within 

the rotor swept area. At 0.0270, the risk index for 

ferruginous hawk was seventh highest among 

RLBs but lowest among the raptor species 

observed in the study (TRC 2009b). Based on the 

preponderance of the abovementioned species in 

the project area and/or their flight characteristics, 

it is likely that operation of the proposed wind 

development could result in some ferruginous 

hawk fatalities. However, the risk to ferruginous 

hawks would be low, and the impact would fall 

within the range acknowledged in the Wind 

Energy PEIS (BLM 2005). 

Brewer’s Sparrow and Sage Sparrow. Based on 

the avian use study, Brewer’s sparrow and sage 

sparrow were the second and third most abundant 

PSB species with 325 (14.8% of total PSB 

observation) and 211 (11.2% of total PSB 

observation) individuals documented, respectively. 

Horned larks accounted for the majority of 

observations (933 [41.6%]). Twenty-six percent 

of the Brewer’s sparrows and 21% of the sage 

sparrows were recorded flying, but none were 

observed within the rotor-swept area. Thus, based 

on the data, a valid risk index cannot be 

calculated, meaning that these two species may 

have a negligible or relatively low potential for 

turbine-related collisions compared to other 

species documented in the study area (TRC 

2009b). Based on use studies conducted in the 

WMWE project area, Brewer’s sparrows and sage 

sparrow appear to be locally abundant, and the 

project is unlikely to have an adverse impact on 

these species at the population level (TRC 2009b). 

The risk to Brewer’s sparrow and sage sparrow 

would be low, and the impact would fall within the 

range acknowledged in the Wind Energy PEIS 

(BLM 2005). 

Sage Thrashers. Based on the results of the avian 

use study, sage thrashers were common in the 

WMWE project area, with 196 individuals 

documented (8.8% of the birds observed). Of 

those, 15 were flying, and one was observed in the 

rotor-swept area. Risk value for the sage thrasher 

was low at 0.0027 (TRC 2009b). Based on the use 

study conducted in the WMWE project area, sage 

thrashers appear to be locally abundant, and the 

project is unlikely to have an adverse impact on 

these species at the population level (TRC 2009b). 

The risk to sage thrashers would be low, and the 

impact would fall within the range acknowledged 

in the Wind Energy PEIS (BLM 2005). 

Loggerhead Shrike. One loggerhead shrike was 

recorded during the avian studies, but it was 

recorded as an incidental observation and was not 

flying and would therefore have a negligible or 

low risk index potential for turbine-related 

collisions compared to other species documented 

in the study area (TRC 2009b). The risk to 

loggerhead shrikes would be low, and the impact 
EA, White Mountain Wind Energy Project 4-41 

would fall within the range acknowledged in the 

Wind Energy PEIS (BLM 2005). 

Greater Sage-grouse. Much of the following 

analysis for impacts to greater sage-grouse 

breeding, nesting, brood-rearing, and winter 

activities and habitat changes is from the summary 

article by Becker et al. (2009). Wind energy 

development is relatively new, and few field 

studies have been conducted concerning greater 

sage-grouse and potential impacts of wind energy 

projects (Becker et al. 2009). Lek use is widely 

studied to monitor greater sage-grouse population 

size and distribution locally and at the landscape 

scale. Factors affecting lek use and persistence are 

put forth with information on the effective 

distance of such factors as the time period required 

to detect lek abandonment following oil and gas 

field development (Becker et al. 2009). It is likely 

that similar types of effects would be observed in 

relation to wind energy development. However, it 

should also be recognized that oil and gas 

development and wind energy developments 

involve some important differences in the level of 

disturbance and human activity that are not 

directly comparable to each other (Strickland 

2009). 

In the Powder River Basin of northeastern 

Wyoming from 2001 to 2005, the number of males 

observed on leks inside coalbed natural gas 

(CBNG) fields that had been confirmed active in 

1997 declined more rapidly than leks outside the 

CBNG fields. Lek count indices (counts of birds 

at leks that provide an indication of population 

size [Walsh et al. 2004]) inside gas fields declined 

by 82%, whereas indices outside such 

development declined by 12%. By 2005, leks in 

CBNG fields had 46% fewer males per active lek 

than leks outside the fields. Of leks active in 1997 

or later, only 38% of 26 leks in CBNG fields 

remained active by 2004-2005, compared to 84% 

of 250 leks outside CBNG fields. Persistence of 

110 leks was influenced positively by the 

proportion of sagebrush habitat. Lek persistence 

was influenced negatively by CBNG development 

and the proportion of power lines (considered as 

two separate factors) within about 4 mi of the lek, 

as well as the proportion of (heavily traveled all 

weather) roads within about 2 mi of the lek. Full 

development of the landscape within 2 mi of leks 

reduced the average probability of lek persistence 

from 87 to 5%. Leks disappeared on average 

within 3-4 years of CBNG development. It is 

nevertheless unclear whether declines in lek 

attendance within CBNG fields were caused by 

impacts to breeding birds at the lek, reduced 

survival or productivity of birds in the surrounding 

area, avoidance of developed areas, or some 

combination thereof (Walker et al. 2007). 

Three studies were conducted in the Pinedale 

Anticline area of southwestern Wyoming--one 

during the initial stages of natural gas 

development (Lyon 2000) and two in more full 

stages of development (Holloran 2005; Kaiser 

2006). These studies describe reductions in lek 

fidelity of male and female greater sage-grouse in 

response to natural gas development. 

Holloran (2005) found that in areas subjected to 

full-field natural gas development, populations of 

breeding males on leks declined by an average of 

51% compared to only a 3% decline at undisturbed 

leks. Males at three leks surrounded by natural 

gas development declined by 89%, and two of the 

three leks were abandoned within 3-4 years of 

initiation of gas drilling. Active drilling within 

3.1 mi of a greater sage-grouse lek reduced the 

number of breeding males by displacing adult 

males and reducing recruitment of juvenile males. 

Increases in road traffic and well density also 

reduced the number of breeding males at leks. 

Kaiser (2006) reported that yearling males tended 

to avoid leks (less recruitment) highly immersed in 

developing gas fields and, as distance from drilling 

rigs decreased, there was less recruitment. Hens 

continued to breed and initiated nests despite 

natural gas development; however, yearling hens 

tended to avoid visiting leks as proximity to a 

producing well increased. Both yearling males 

and females (9% and 11%, respectively) showed 

low fidelity to natal leks. Forty-three percent of 

yearling males and 14% of yearling females 

established a lek within 3.1 mi of the nest location 

from which they hatched, indicating some level of 

natal area fidelity but less philopatry than greater 

sage-grouse in other studies, in which 53-100% 

fidelity was observed. 
4-42 EA, White Mountain Wind Energy Project 

Lyon (2000) found a small number of males 

returning to breed on the same lek during 2 years 

despite disturbance from natural gas development. 

However, at the time of the Lyon study, gas 

development in the area was in its initial stages (in 

contrast to being more developed during the later 

studies [Holloran 2005; Kaiser 2006]), and 

impacts on lek fidelity could take longer to detect 

(Holloran 2005; Walker et al. 2007). To maintain 

a stable number of males using a lek, yearling 

recruitment must equal adult mortality. Assuming 

50% mortality (Connelly et al. 2004) and no 

yearling recruitment, the number of males 

attending a lek would decline by 50% per year, 

and the lek would become inactive within 

4-6 years, the approximate amount of time lag 

documented by Walker et al. (2007) and Holloran 

(2005). Thus, the Lyon (2000) study may have 

begun too early during gas development and not 

lasted long enough to detect differences in lek 

attendance. 

Impacts to sage-grouse have been documented up 

to 3.7 mi away from vertical structures such as 

overhead power transmission and communication 

distribution lines (Manville 2004). Collisions with 

power lines and vehicles and increased predation 

by raptors may increase mortality of birds at leks 

(Connelly et al. 2000). Further, direct greater 

sage-grouse mortality associated with roads and 

power lines have been documented year-round 

(Walker et al. 2007). Thus, power lines (i.e, 

vertical structure) may also alter the productivity 

or survival of greater sage-grouse outside the 

reproductive season, thereby indirectly reducing 

the number of birds that use leks, increasing lek 

abandonment (Naugle et al., in press). 

Data on greater sage-grouse indicate that there are 

no greater sage-grouse leks within the WMWE 

project area, and the nearest lek to the WMWE 

project area is located approximately 3.1 mi west 

of the WMWE project area. The next closest lek 

known to occur near the WMWE project area is 

4.4 mi away. Although these leks are located near 

the outer limit of where impacts have been 

documented based on the oil and gas information 

presented above, it is still unknown how taller 

rotating structures would affect persistence for 

these leks. Monitoring of these two leks would 

need to continue to try and evaluate these impacts. 

Other attributes of species reproduction are studied 

to monitor greater sage-grouse populations locally 

and at the landscape scale. This subsection 

synthesizes the results of studies of declines in 

reproductive metrics, such as nest initiation, nest 

area fidelity, and adult and chick survival, which 

are attributed to oil and gas development. Factors 

affecting these declines are put forth with 

information on the effective distance of such 

factors. It is likely that similar types of effects 

could be observed in relation to wind energy 

development. 

In the Pinedale Anticline area, Lyon and Anderson 

(2003) found that the nest initiation rate for 

females from leks disturbed by natural gas 

development was 24% lower than for females 

from undisturbed leks, and that hens from 

disturbed leks traveled twice as far to nest sites 

(Lyon 2000). In habitat fragmented by natural gas 

development, only 26% of hens captured on 

disturbed leks nested within 1.8 mi of the lek of 

capture, whereas 91% of hens from undisturbed 

areas nested within 1.8 mi of the lek of capture. 

Average distance between nests in consecutive 

years was 0.37 mi, indicating hens initially shifted 

nest locations due to disturbance but afterward 

showed fidelity to new-found nest locations (Lyon 

and Anderson 2003). 

Holloran (2005) found that females strongly 

avoided nesting in areas of high well density, and 

there was a 21% decline in the population of 

nesting females compared to undisturbed females 

over the 5 years of the study. Females nesting in 

developed areas had a significantly lower survival 

rate than female grouse in undeveloped areas. 

Although nest success rates were higher in 

developed areas, this increase was not sufficient to 

overcome the reduced female survival rates, 

resulting in an overall 21% decline in greater sagegrouse population growth in developed gas fields 

compared to undeveloped areas. The distance 

between selected nesting sites and gas field 

infrastructure shifted between 2000-2003 and 

2004, with females selecting nesting habitat 

farther from active drilling and producing wells in 
EA, White Mountain Wind Energy Project 4-43 

2004. Population reductions likely resulted from a 

combination of dispersal away from gas fields and 

increased mortality rates for birds affected by 

development. A lag period occurs between the 

time when female greater sage-grouse are affected 

by development and when survival probabilities 

are influenced, suggesting negative fitness 

consequences for females subjected to natural gas 

development during the breeding and nesting 

periods. 

In the Manyberries oil field in southeastern 

Alberta, sage-grouse selected heterogeneous 

patches of moderate sagebrush cover and avoided 

anthropogenic edge habitat for nesting (Aldridge 

and Boyce 2007). Nests were more successful in 

heterogeneous than anthropogenic edge habitats, 

but nest success was independent of anthropogenic 

features. Similarly, broods selected heterogeneous 

high-productivity habitats with sagebrush (at 

>0.6 mi2

) while avoiding human developments, 

cultivated cropland, and high densities of oil wells. 

Chick mortalities tended to occur in proximity to 

oil and gas developments and along riparian 

habitats. Limited source habitats appear to be the 

main reason for poor nest success (39%) and low 

chick survival (12%) (Aldridge and Boyce 2007). 

Risk of chick mortality was 1.5 times higher for 

each additional well site visible within 0.6 mi of 

brood-rearing habitat (Aldridge 2005; Aldridge 

and Boyce 2007). 

Recent studies of greater sage-grouse conducted in 

southwest Wyoming indicated that 64 to 87% of 

hens nest within 3.0 mi of leks where the hens 

were bred (Holloran and Anderson 2005; Slater 

2003). Therefore, it is possible that some nesting 

greater sage-grouse (36 to 13%) may experience 

displacement and/or reduced survival rates. This 

displacement and/or reduction in survival could be 

expected to occur for approximately 2-5 years 

after construction begins, until following 

generations of greater sage-grouse can occupy 

other areas. However, these areas are expected to 

be already occupied by greater sage-grouse, or of 

lower habitat quality, which may reduce 

sustainability. 

The WMWE project area has been anecdotally 

shown to be a greater sage-grouse brood-rearing 

area based on WGFD observations and spring and 

fall avian surveys conducted in 2008 (TRC 

2009b). It is anticipated that greater sage-grouse 

chicks may experience higher mortalities 

(1.5 times higher) in this area and extending out by 

0.6 mi (Aldridge 2005; Aldridge and Boyce 2007) 

as turbines will be visible in most of these areas. 

Reduced survival and decreased recruitment may 

impact the local population and persistence of 

historic breeding grounds and seasonal use areas. 

Avoidance of winter habitat is also known to occur 

in relation to oil and gas development and may 

affect the viability of greater sage-grouse 

populations. In the Powder River Basin, greater 

sage-grouse avoided CBNG development during 

winter at the 2.5 mi2

 scale (Doherty et al. 2008). 

Greater sage-grouse were 1.3 times less likely to 

use otherwise suitable winter habitats that had 

been developed for CBNG at a density of 

12 wells/ 2.5 mi2

. Impacts were indiscernible at 

densities of 1-12 wells within 20 mi2

 of a lek 

(~1 well/640 acres) (Doherty et al. 2008). Impacts 

to winter habitat may have a disproportionate 

effect on regional greater sage-grouse population 

size and persistence if the species uses a small 

percentage of available sagebrush habitat in an 

area (Doherty et al. 2008). 

While no winter concentration areas for greater 

sage-grouse have been identified in or near the 

WMWE project area, sagebrush habitat provides 

shelter and food during this time of the year, and 

habitat selection during the winter is influenced by 

factors such as snow depth and hardness, 

topography (elevation, slope, and aspect), and 

vegetation height and cover (Connelly et al. 2004). 

Although no greater sage-grouse were encountered 

during winter preconstruction surveys within the 

project area (TRC 2008a), it is possible that the 

WMWE project area is used by greater sagegrouse during the winter operations, and the 

WMWE Project could displace greater sagegrouse from using winter habitat within the project 

area. 

Greater sage-grouse were recorded within the 

WMWE project area during spring and fall avian 

surveys conducted in 2008 (TRC 2009b) and 

documented in the WNDD (2009). A potential 
 

4-44 EA, White Mountain Wind Energy Project 

concern for greater sage-grouse is the potential for 

collision with the rotating wind turbine blades. 

Preconstruction avian use surveys conducted at 

Foote Creek Rim wind energy project located in 

south-central Wyoming did not document any 

greater sage-grouse within the project area; 

however, the survey methodology did not include 

incidental observations, lek, or winter 

concentration surveys, which might explain the 

low use in this study. While the avian use surveys 

did not document any greater sage-grouse use, 

greater sage-grouse pellet density surveys did 

indicate the presence and use of the Foote Creek 

Rim project area (a range of a low of 0/hectare 

[ha] in the winter of 1997/1998 to a high of 69/ha 

in the winter of 1994/1995) (Johnson et al. 2000). 

Once the wind farm became operational, postconstruction mortality surveys were conducted for 

3.5 years. During these surveys, no greater sagegrouse were documented as being killed or injured 

as a result of the operation of the wind turbines 

(Young et al. 2003). Therefore, while greater 

sage-grouse use of Foote Creek Rim was assumed 

to be low, no species mortalities were documented 

during subsequent post-construction surveys. 

Information about greater sage-grouse within the 

WMWE project area was collected during avian 

surveys conducted in 2008, and for those greater 

sage-grouse documented as flying, 100% of the 

observations indicated that the grouse flew within 

the 0 to 35-m flight height category (i.e., below the 

rotor-swept area). These birds would not be at risk 

for collision with wind turbines (i.e., risk index of 

0.0) (TRC 2009b). It is also possible that greater 

sage-grouse could collide with vehicles being 

operated in association with the Proposed Action. 

Posted speed limit signs would limit vehicle 

speeds and reduce the chances of accidental 

collisions. 

It is also possible, but unlikely, that some high 

flying migrating individual greater sage-grouse 

might be at an increased risk during the fall if the 

birds migrate into or through the area at higher 

altitudes. Although greater sage-grouse are heavybodied and require time to gain altitude on shortdistance flights (for instance, being flushed by a 

predator), during long-distance flights, these 

strong fliers may fly at greater heights and thus 

may be increasingly susceptible to collision with 

turbines and blades. Therefore, while possible, it 

is unlikely that operation of the WMWE Project 

would result in many greater sage-grouse 

fatalities. 

Approximately 515 acres (3.9%) of privately 

owned lands in the project area in the northwestern 

corner occurs along the southern boundary of the 

South Pass greater sage-grouse core habitat (refer 

to Figures 3.5 and 4.4). The South Pass core 

habitat area encompasses approximately 

2.5 million acres. It is likely that the portion of 

core habitat located within the WMWE project 

area would be of decreased value to greater sagegrouse since this area has three large 345-kV 

transmission lines that bisect this corner of the 

core habitat area. Research has indicated that 

greater sage-grouse prefer areas away from 

overhead transmission lines because the 

transmission line structures can serve as hunting 

perches and nesting locations for raptors (Connelly 

et al. 2000). In addition, Braun (1998) determined 

habitat use by greater sage-grouse was impacted 

by power lines up to a distance of at least 600m. 

Raptor nest surveys conducted in this area in 2008 

(TRC 2008c) have documented two active raptor 

nests (a red-tailed hawk and common raven) on 

transmission power line structures located at the 

northern end of the WMWE project area that could 

affect the usefulness of this area for core greater 

sage-grouse habitat (refer to Figure 4.4) (TRC 

2009b). In addition, it can also be documented 

that no greater sage-grouse were observed within 

the WMWE project area within the greater sagegrouse core area near the three large 345-kV 

transmission lines during the 2008 winter and 

spring aerial surveys and during the 2008 21-week 

long ground-based avian surveys (TRC 2008a, 

2008b, 2009b). As a result, the existing 345-kV 

transmission lines have likely already adversely 

affected the corner of the core habitat area, thereby 

limiting its usefulness in protecting important 

greater sage-grouse habitat. Under the Proposed 

Action, 12 turbines and associated facilities are 

proposed in this area, and all 12 turbines and 

associated facilities would be located on private 

land. The 12 wind turbines and associated 

disturbance would result in approximately 24 acres 

of initial direct disturbance and 5.0 acres of lifeof-project disturbance. Based on this analysis, the 

Proposed Action is expected to add to the existing 

adverse impacts to this specific portion of the 

4-46 EA, White Mountain Wind Energy Project 

South Pass core habitat area by increasing habitat 

fragmentation and vertical structures. 

Other BLM Sensitive Species. Impacts to other 

BLM sensitive passerine birds (e.g., not address 

above or not recorded in the project area), reptiles 

(e.g., midget faded rattlesnake), and mammal 

species (e.g., pygmy rabbits, Wyoming pocket 

gopher) during the O&M phases of the Proposed 

Action would be the same as discussed for 

wildlife, including birds, presented in Section 4.12 

of this EA. 

The O&M phase of the Proposed Action would 

not have any impacts to BLM sensitive plant 

species. 

4.8.2.3 Decommissioning Phase 

During the decommissioning phase, a limited 

amount of area would be redisturbed by crews 

removing the project components, and most of 

these areas would be associated with access roads 

and the tower and turbine lay down areas at the 

turbine pads. The removal of revegetated areas 

would be minimized to the extent possible during 

decommissioning operations. In addition, ground 

disturbing activity and the movement of 

decommissioning personnel and equipment on-site 

would be limited to the extent possible to the 

required areas to avoid inadvertent impacts to all 

wildlife species. No additional impacts to BLM 

sensitive species (including plant and animal 

species) during the decommissioning phase are 

expected beyond those already discussed above, 

and the risk to BLM sensitive species during the 

decommissioning phase of this project would be 

low, and the impact would fall within the range 

acknowledged in the Wind Energy PEIS (BLM 

2005). 

4.8.3 Alternative A - Development Only on 

Privately Owned Lands 

No federally listed TEPC species were 

documented in the project area during the WMWE 

avian surveys (TRC 2009b), so risk to such 

species during the construction of the WMWE 

Project likely would be limited. 

Potential direct and indirect impacts to BLM 

sensitive species under Alternative A would be the 

same as discussed under the Proposed Action. 

Implementation of this alternative would involve 

the construction of 170 wind turbines on privately 

owned land; therefore, direct impacts to wildlife 

habitat would include the disturbance of 619 acres 

of habitat from the construction of the turbine 

pads, the access roads, the substation, and the 

collector lines. Most of the disturbed area would 

be reclaimed and revegetated, with 115 acres (less 

than 1.0% of the project area) remaining occupied 

by roads, turbines, and facilities for the life of the 

project. The potential impacts to BLM sensitive 

species habitat would likely be reduced by 30%, 

compared with those described under the Proposed 

Action. Teton would also implement the same 

mitigation measures to minimize impacts to these 

species. 

The short­ and long-term impacts 

sensitive species and their habitat 

Alternative A would be minimal. 

to BLM 

under 

4.8.4 No Action Alternatives 

Under the No Action Alternative, the proposed 

wind energy facility would not be authorized nor 

approved. No ground would be disturbed, and no 

impacts to the existing biological environment 

would take place beyond those that already exist. 

4.8.5 Residual Impacts 

There would be no impacts to federally listed 

species. However, under Proposed Action, it is 

possible that there could be some loss of BLM 

sensitive species or their habitat within the 

WMWE project area. Although some individual 

mortality is possible, operation of the WMWE 

Project under Alternative A is not expected to 

impact local population numbers for BLM 

sensitive species, and, in general, mortality rates 

are expected to be relatively low. 

4.8.6 Cumulative Impacts 

All developmental activities would comply with 

the Endangered Species Act, which requires 

avoidance or mitigation for impacts to TEPC 
EA, White Mountain Wind Energy Project 4-47 

species, so no impacts would occur. Therefore, 

there would be no cumulative impacts to federally 

listed TEPC species. 

In order to assess potential cumulative impacts to 

select BLM sensitive species, various IAAs have 

been established to evaluate the Proposed Action, 

and quantitative data for the various IAAs are 

summarized in Table 4.11. 

Cumulative impacts to BLM sensitive species 

would be similar to those described under the 

Proposed Action. Standard mitigation measures 

presented in the Proposed Action would also 

reduce potential short- and long-term impacts to 

BLM sensitive species during the construction, 

O&M, and decommissioning phases of the project. 

In addition, the Proposed Action would not cause 

any BLM sensitive species to be petitioned for 

listing under the Endangered Species Act. 

Implementation of the various mitigation measures 

to limit disturbance and encourage prompt 

reclamation of disturbance and other appropriate 

mitigation measures (including seasonal 

restrictions) presented in the Proposed Action 

would minimize impacts to TEPC species and 

BLM sensitive species. Cumulative impacts to 

populations of these species within the IAA are 

expected to be minimal. Therefore, Proposed 

Action and RFFAs are expected to have only 

minimal adverse impacts on population numbers 

and would be expected to have limited cumulative 

impacts. 

Table 4.11 Cumulative Impacts Due to Direct Disturbance to BLM Sensitive Species. 

Amount of Total Amount 

Amount of Disturbance Related to of Current and 

Current RFFA (Including RFFA 

Total Area Disturbance Proposed Action) Disturbance 

Resource Description (acres) (acre and %) (acre and %) (acre and %) 

Pygmy rabbits WMWE Project 66,189 5,201 (7.86%) 441 (0.66%) 5,642 (8.52%) 

area plus 2.17-mi 

buffer 

Pocket gopher WMWE Project 18,893 573 (3.03%) 281 (1.49%) 854 (4.52%) 

area plus 0.22-mi 

buffer 

Greater sage- Area north of Bitter 545,351 10,508 976 (0.18%) 11,484 (2.11%) 

grouse Creek, east of the (1.93%) 

Green River, south 

of the Big Sandy 

River to Farson, 

then east to 

Killpecker Sand 

Dunes 

Midget faded WMWE Project 44,235 2,061 (4.66%) 356 (0.80%) 2,417 (5.46%) 

rattlesnake area plus 1.3-mi 

buffer 
4-48 EA, White Mountain Wind Energy Project 

4.9 VEGETATION (INCLUDING 

WETLANDS AND INVASIVE SPECIES) 

4.9.1 Proposed Action 

4.9.1.1 Construction Phase 

Direct impacts to vegetation would include initial 

surface disturbance of 865 acres during 

construction. These impacts include disturbance 

and/or removal of native vegetation and grading 

and compaction of soil. Direct impacts to 

vegetation from clearing and grading for new 

roads, wind turbine pads and crane pads, the 

substation, and O&M facilities would be 

permanent because these areas would be occupied 

by the project facilities. Impacts to vegetation 

from installation of the electrical collector system 

between the turbines would be temporary. 

Approximately 841 acres (97%) of the 866 acres 

of initial disturbance would occur in Wyoming big 

sagebrush vegetation. The width of the access 

roads and turbine pad footprints would be reduced 

and reclaimed following construction. In areas 

where potential construction impacts to vegetative 

resources are possible, BMPs from the SWPPP 

would be implemented. Most of the temporarily 

disturbed areas would be reclaimed and 

revegetated upon the completion of the 

construction phase of the project, with 162 acres 

(approximately 1.4% of the project area) of mostly 

preconstruction Wyoming big sagebrush habitat 

remaining occupied by roads, turbine foundations, 

and facilities for the life of the project. Since the 

project footprint would be relatively small 

compared with the overall size of the project area, 

these long-term direct impacts would be minimal. 

A review of digital NWI information (USFWS 

2003) indicates that the occurrence of a linear 

palustrine seasonally flooded wetland (PEMC) and 

two intermittent streams (R4SBA) located in the 

project area could potentially support seasonal 

riparian areas (refer to Figure 3.7). In addition, 

NWI data indicate the occurrence of several small 

playa areas (refer to Figure 3.7) scattered 

throughout the project area. The turbines, 

substation, and O&M project facilities would not 

be located in any NWI-identified wetland or 

riparian areas. Minimization of impacts to any 

wetland or riparian area would be accomplished 

by proper facility siting (i.e., avoidance of 

wetlands and riparian areas), implementation of 

SWPPP, and ensuring proper reclamation and 

revegetation. In addition, project facilities would 

be sited following procedures listed within the 

BLM Green River Management Plan (1997) 

regarding riparian areas and ephemeral channels 

(i.e., 100 ft from the edge of major drainages). To 

reduce avian impacts, this condition has been 

modified to limit placement of turbines within 

50 m (164 ft) of major drainages. Therefore, the 

Proposed Action would have minimal impacts to 

wetlands and riparian areas. 

Few noxious weeds or introduced species occur on 

the site; however, clearing, grading, and 

excavation activities associated with construction 

of the project creates potential new habitat for 

invasive nonnative species. Weed infestations 

could constitute an adverse effect, and the same is 

true where vegetation is crushed, and similar 

actions degrade existing native habitat. The 

effects of these impacts are usually permanent or 

require several years to heal in arid environments 

like that found in the project area. Adjacent 

undisturbed areas are indirectly impacted by the 

invasion of weed species due to proximity. 

Invasive nonnative species can also be introduced 

through the use of reclamation materials such as 

seed and mulch that are not certified weed free. 

The control of invasive nonnative species is 

difficult, and some weeds can enter the project 

area on equipment and vehicles, while others may 

spread from distant areas by spores blowing onto 

the site in the wind. As discussed in Chapter 2.0 

of this EA, Teton would design and build the 

project so that the least amount of ground 

disturbance occurs, thereby exposing the least 

amount of soil possible. Large construction 

equipment that travel off project roads will be 

cleaned prior to entering the site. Teton also 

would work with the BLM and the Sweetwater 

County Board of Weed and Pest Control to 

establish a weed control program (e.g., washing 

construction vehicles before going on-site, 

avoiding weedy areas once on-site, and controlling 

weeds in accordance with landowner wishes or 
EA, White Mountain Wind Energy Project 4-49 

easement agreements) for the project. This may 

entail spot spraying with an approved herbicide 

along disturbed areas for invasive nonnative 

species. Teton would also use only certified weed 

free reclamation materials such as seeds and 

mulch. With implementation of a weed control 

program, impacts from invasive species are 

anticipated to be minimal. 

4.9.1.2 O&M Phase 

No additional impacts beyond those discussed 

under construction impacts to vegetation are 

expected to occur during the O&M phase of this 

project. O&M personnel would continue to 

implement appropriate weed control efforts in 

cooperation with the BLM and the Sweetwater 

County Board of Weed and Pest Control. 

4.9.1.3 Decommissioning Phase 

No additional impacts beyond those discussed 

under construction phase are expected to occur 

during the decommissioning phase of this project. 

With implementation of the project mitigation 

measures, including vehicle washing, the 

reclamation plan, and weed control plan, impacts 

to vegetation after the decommissioning phase of 

the project is complete is expected to be minimal. 

4.9.2 Alternative A - Development Only on 

Privately Owned Lands 

4.9.2.1 Construction Phase 

Potential direct and indirect impacts to vegetation 

resources under the construction phase of 

Alternative A would be similar to the type of 

impacts described under the Proposed Action. 

Implementation of this alternative would involve 

the construction of 170 wind turbines on privately 

owned land; therefore, direct impacts to vegetation 

resources would include the initial disturbance of 

619 acres of vegetation from the excavation of the 

turbine pads, the substation foundations, and 

collector lines. Most of the temporary disturbed 

areas would be reclaimed and revegetated, with 

116 acres (less than 1.0% of the project area) 

remaining occupied by roads, turbine foundations, 

and facilities for the life of the project. The 

potential impact to vegetation would be reduced 

by 30%, compared with those described under the 

Proposed Action. 

4.9.2.2 O&M Phase 

Under Alternative A, no additional impacts 

beyond those discussed under the O&M phase of 

the Proposed Action are expected to occur. 

4.9.2.3 Decommissioning Phase 

Under Alternative A, no additional impacts 

beyond those discussed under the 

decommissioning phase of the Proposed Action 

are expected to occur. 

4.9.3 No Action Alternatives 

Under the No Action Alternative, the proposed 

wind energy facility would not be authorized nor 

approved. No ground would be disturbed, and no 

additional impacts to the existing biological 

environment would take place beyond those that 

already exist. 

4.9.4 Residual Impacts 

Implementation of the Proposed Action would 

result in the temporary but unavoidable removal of 

vegetation from 865 acres. Under the Proposed 

Action, approximately 163 acres would be 

disturbed for the life of the project, but all 

disturbed areas would be permanently reclaimed 

during the decommissioning phase of the project. 

There would also be the potential for an 

unavoidable increase in the population of invasive 

nonnative plant species within the project area. 

4.9.5 Cumulative Impacts 

Based on the disturbance calculations presented in 

Chapter 3.0, approximately 19,954 acres are 

currently disturbed within the IAA. This 

represents 7.43% of the total area within the 

cumulative IAA. RFFA (including the Proposed 

Action) within the IAA would result in an 

additional 1,224 acres of disturbance--163 acres of 

disturbance due to the Proposed Action and 

1,061 acres from other RFFAs. This represents 
4-50 EA, White Mountain Wind Energy Project 

21,178 acres of the total within the IAA or 7.84% 

based on the total disturbance due to past, present, 

and RFFAs. 

Vegetation resources would be protected from 

long-term impacts by implementation of 

temporary and permanent reclamation operations, 

the invasive species control plan, and 

wetland/riparian mitigation measures included in 

the Proposed Action, and the vegetation would 

eventually (within 10-20 years) be capable of 

supporting predisturbance land uses once 

reclamation operations have been completed and 

vegetation becomes established. Nonnative 

invasive species would be controlled, and wetland 

and riparian areas would be protected. There are a 

few proposed linear facilities within the IAA; 

however, the facilities would be expected to 

contribute limited disturbance, and all of the 

disturbed lands would be revegetated. In addition, 

all RFFAs would also comply with the same 

requirements to control nonnative species and 

protect wetland and riparian areas. 

4.10 VISUAL RESOURCES 

4.10.1 Proposed Action 

It is widely acknowledged that aesthetic impacts 

are among the most important impacts associated 

with wind energy development and operations. 

However, it is difficult to determine the relative 

significance of aesthetic impacts. Visual impacts 

are intangible, highly subjective, and dynamic, and 

because they cannot be completely avoided, they 

are one of the greatest sources of objection to wind 

energy development projects. Because of the 

subjective and experiential nature of visual 

resources, the human response to those changes 

and the importance of the impacts cannot be 

quantified, even though the visual impact of a 

proposed development can be described 

specifically (BLM 2005). 

Based on information presented in Chapter 3.0 of 

this EA, approximately 85% of the WMWE 

project area is located in a BLM Class IV VRM 

area, and the remaining 15% is located in a BLM 

Class III VRM area; although, BLM visual 

classifications do not apply to private or stateowned lands. The Proposed Action would not 

impact any important or sensitive viewsheds (i.e., 

VRM Class I or II areas). The primary impact to 

visual resources due to the Proposed Action would 

be the installation and operation of up to 240 wind 

turbines. The construction of the access roads, 

substation, collection lines, and other support 

facilities would likely not be visible to most 

observers since White Mountain slopes off to the 

west and these areas would not be visible from the 

Rock Springs/Green River area. 

Under the Proposed Action, and as a requirement 

of FFA, the wind turbines would be white with no 

daytime lighting and would change the aesthetics 

of the landscape with the addition of tall towers 

and rotating blades, and whether the effect is 

deemed a beneficial or adverse effect depends on 

the perspective and sensitivity of the viewer. The 

WMWE Project would be more visible than any 

other manmade structure in the immediate project 

area because the wind turbines would be located 

on White Mountain, a highly visible topographic 

feature. Other man-made features are visible 

along the face of White Mountain, including 

roads, microwave reflector and commercial 

communication towers, and the 230-kV power 

line. 

In addition, night-time lighting on 84 of the 240 

wind turbines would be required by the FAA, who 

approved the specific location and method of 

lighting to be used on this project. Because the 

FAA requires wind turbines located throughout the 

WMWE project area to be lit, an estimated 31 of 

the wind turbines visible along the 13-mi length of 

White Mountain could be lighted and visible at 

night. 

The WMWE Project would be highly visible 

because of the introduction of turbines into a rural 

or natural landscape that has few other comparable 

structures. Photosimulations have been prepared 

and are presented in Appendix C. The 

photosimulations were developed based on the 

dimensions of a comparably sized wind turbine 

that would be used in the WMWE Project and the 

proposed wind turbine locations in UTM 

coordinates. These photosimulations allow the 

viewer to see the landscape with and without the 
EA, White Mountain Wind Energy Project 4-51 

proposed wind turbines. These photosimulations 

illustrate the visual resource contrast elements 

from the wind energy project on the landscape. 

Visual evidence of wind turbines cannot be 

avoided, reduced, or concealed, owing to their 

color, size, and exposed location; therefore, 

effective mitigation would be limited (BLM 

2005). However, Teton, in cooperation with 

BLM, has developed other design features to 

mitigate potential visual impacts. These design 

features are presented in Table 4.12 and comply 

with the visual resource mitigation measures 

included in the Wind Energy PEIS (BLM 2005). 

In addition to the VRM class and the 

photosimulations, the BLM VRM system also uses 

a visual contrast rating analysis to evaluate visual 

impacts of the proposed project and to develop 

mitigation measures to reduce potential visual 

impacts. The locations where the visual contrast 

rating analyses are conducted are referred to as 

Key Observation Points (KOPs). The degree to 

which a proposed activity would affect visual 

quality depends on the contrast between the 

existing landscape and the proposed development. 

Contrast is measured by comparing the basic 

elements of form, line, color, and texture of the 

existing landscape with the elements introduced by 

the proposed project, and the degree of contrast 

are listed as either none, weak, moderate, or 

strong. Visual contrast ratings were computed for 

eight KOPs located between 1.0 and 17.0 mi from 

the WMWE project area, and the results of these 

analyses are presented in Table C.1 in 

Appendix C. 

As expected, the degree of contrast is directly 

related to the distance the viewer is from the 

proposed project feature (i.e., the wind turbines). 

Those sites that are located closer to the WMWE 

project area tended to have a strong contrast while 

those sites located further from the project area 

have a weak degree of contrast. 

The presence of the wind turbines under the 

Proposed Action would change the aesthetics of 

the landscape with the addition of tall towers and 

rotating blades. Whether the effect is deemed a 

beneficial or adverse effect depends on the 

perspective and sensitivity of the viewer (BLM 

2005). The FAA has determined no hazard to air 

navigation based on the use of white wind turbines 

and towers. To reduce the contrast created by the 

color of the structures, it has been recommended 

that the color of the wind turbines be changed 

from white to light gray, if possible. However, 

according to FAA Advisory Circular AC 70/7460­

1K (Chapter 13, 131F), use of gray turbines 

appears to be significantly less effective in 

providing daytime warning and would require 

daytime and nighttime lighting of all 240 wind 

turbines with medium intensity white strobes, 

which may be more visually intrusive than white 

towers with no daytime lighting (personal 

communication, August 12, 2009, with Michael 

Blaich, FAA, Fort Worth, Texas). Therefore, the 

use of white wind turbines with no daytime 

lighting would have reduced visual impacts 

compared to light gray wind turbines equipped 

with daytime lighting of all 240 wind turbines 

(personal communication, August 12, 2009, with 

Michael Blaich, FAA, Fort Worth, Texas). Visual 

impacts would not exceed those outlined in the 

Wind Energy PEIS (BLM 2005). 

The WMWE Project would be constructed over a 

3- to 4-year period, and the O&M phase would last 

approximately 20 years, after which time the wind 

turbines would be decommissioned and removed 

from the site. The decommissioning phase would 

eliminate most of the visual impacts of the 

WMWE Project. 

4.10.2 Alternative A - Development Only on 

Privately Owned Lands 

Potential direct and indirect impacts to visual 

resources under Alternative A would generally be 

the same as discussed under the Proposed Action, 

except this alternative would involve the 

construction of 170 wind turbines instead of the 

240 planned under the Proposed Action. There 

would be a 30% reduction in the number of wind 

turbines, and some of the visual impacts would 

also likely be reduced depending on the location of 

the observer. However, many of the wind turbines 

would also likely still be visible from the KOPs 

discussed, since the most visible wind turbines 

would be located on private or state-owned lands 

nearest the edge of White Mountain, and there 
4-52 EA, White Mountain Wind Energy Project 

Table 4.12 Design Features to Minimize Impacts to Visual Resources. 

To minimize visual impacts, Teton would adopt the following visual mitigation measures: 

• The design of the WMWE Project would provide visual order and unity among clusters 

of turbines (visual units) to avoid visual disruptions and perceived “disorder, disarray, or 

clutter” (BLM 2005) 

• To the extent possible given the terrain of a site, Teton would create clusters or groupings 

of wind turbines when placed in large numbers; avoid a cluttering effect by separating 

otherwise overly long lines of turbines or large arrays; and insert breaks or open zones to 

create distinct visual units or groups of turbines. 

• Teton would create visual uniformity in the shape, color, and size of rotor blades, 

nacelles, and towers. 

• Teton would use tubular towers. Tubular towers present a simpler profile and less 

complex surface characteristics and reflective/shading properties. 

• Components of the wind turbines would be in proper proportion to one another. Nacelles 

and towers would be planned to form an aesthetic unit and would be combined with 

particular sizes and shapes in mind to achieve an aesthetic balance between the rotor, 

nacelle, and tower. 

• Color selection for turbines would be applied uniformly to tower, nacelle, and rotor in 

accordance with FAA requirements. 

• The wind turbines would use nonreflective coatings to reduce reflection and glare. 

• The O&M building would be painted before or immediately after installation with a 

green shale color. 

• Uncoated galvanized metallic surfaces would be avoided whenever possible because they 

would create a stronger visual contrast, particularly as they oxidize and darken. 

• Commercial messages on turbines and towers would be prohibited. 

• The site design would be integrated with the existing landscape by using as many of the 

existing roads as possible. 

• The operator would bury power collection cables or lines on the site in a manner that 

minimizes additional surface disturbance. 

• Site design would minimize security lights, and any security lights located at the O&M 

building would be turned off except when activated by motion detectors. 

• Teton would minimize ground disturbance and control erosion by avoiding steep slopes 

and by minimizing the amount of construction and ground clearing needed for roads, 

staging areas, and turbine pads. 

• Dust suppression techniques would be employed where and when required to minimize 

impacts of vehicular and pedestrian traffic, construction, and wind on exposed surface 

soils. 

• Disturbed areas would be regraded as soon as possible to their original contour and 

revegetated immediately after, or as contemporaneously as possible with construction. 

Teton would be prompt to limit erosion and to accelerate restoring the preconstruction 

color and texture of the landscape. 

• Teton would maintained the WMWE Project during operation as inoperative or 

incomplete turbines cause the misperception to viewers that “wind power does not work” 

or that it is unreliable. Inoperative turbines would be completely repaired, replaced, or 

removed. Except during specific maintenance operations, nacelle covers and rotor nose 

cones would always be in place and undamaged. 
EA, White Mountain Wind Energy Project 4-53 

Table 4.12 (Continued) 

• The WMWE Project would evidence environmental care, which would also reinforce the 

expectation and impression of good management for benign or clean power. Nacelles 

and towers would also be kept clean to remove any spilled or leaking fluids and the dirt 

and dust that would accumulate. 

• Facilities would be kept clean of debris, “fugitive” trash or waste, and graffiti. 

• Scrap heaps and material dumps would be prohibited and prevented. 

• The material stored at the O&M building would be screened and kept to an absolute 

minimum. Any surplus, broken, or disused materials and equipment would be 

maintained in an orderly manner. 

• Teton would prepare a decommissioning plan, and it would include the removal of all 

turbines and ancillary structures and reclamation and revegetation of the site. 

would be a proportional level of traffic over the 

life of the project compared to the Proposed 

Action. Similar mitigation measures presented in 

the Proposed Action would be implemented under 

Alternative A. 

4.10.3 No Action Alternatives 

Under the No Action Alternative, the proposed 

wind energy facility would not be authorized nor 

approved. No ground would be disturbed, and no 

impacts to visual resources would take place 

beyond those that already exist. 

4.10.4 Residual Impacts 

Residual impacts to visual resources under the 

Proposed Action would include the short-term 

disturbance of 866 acres. Additional residual 

impacts would include the construction and 

operation of 240 wind turbines on White Mountain 

and the perceived visual impacts. At the end of 

the life of the project, the wind turbines would be 

decommissioned and removed from the site. 

4.10.5 Cumulative Impacts 

The IAA for visual resources is the WMWE 

project area plus a 20-mi buffer. Based on the 

disturbance calculations presented in Chapter 3.0, 

approximately 38,289 acres are currently disturbed 

within the IAA. This represents 3.26% of the total 

area within the IAA. RFFA (including the 

Proposed Action) within the IAA would result in 

an additional 2,035 acres of disturbance--189 acres 

of life-of-project disturbance due to the Proposed 

Action and 1,846 acres from other RFFAs. This 

represents 40,324 acres of the total with the IAA 

or 3.43% based on the total disturbance due to 

past, present, and RFFAs. 

In addition to the existing visual intrusions in this 

area and the Proposed Action, the RFFAs include 

two additional commercial wind energy projects 

(one north and one south of the Proposed Action). 

Both of these additional wind energy projects 

would be located in BLM VRM Class III and IV 

areas. Depending on the specific number, 

location, color, and size of the proposed wind 

turbines, these projects could result in cumulative 

visual intrusions on the landscape. As expected, 

the degree of contrast and visual perception would 

be directly related to the number, location, size, 

and color of the wind turbines and distance the 

viewer is from specific project features (i.e., the 

wind turbines). Those sites that are located closer 

to the viewer would tend to have a stronger 

contrast while those sites located farther from the 

various project areas would have a weaker degree 

of contrast and would be less noticeable. 

Cumulative impacts to visual resources would 

result from the addition of two wind energy 

projects and other power line projects within the 

IAA (identified as RFFAs), when combined with 

the Proposed Action, would result in increased 
4-54 EA, White Mountain Wind Energy Project 

localized visual impacts. However, these past, 

present, and RFFAs would not impact any 

important or sensitive BLM viewsheds (i.e., VRM 

Class I or II areas). Impacts would not exceed 

those outlined in the Wind Energy PEIS (BLM 

2005). 

4.11 WILD HORSES 

4.11.1 Proposed Action 

Impacts during the construction and O&M phase 

of the Proposed Action for wild horses would be 

similar to those impacts to big game species. 

These impacts would include loss of foraging 

habitat, displacement, direct mortality due to 

collisions with vehicles, displacement from 

portions of the project area due to the human 

presence, noise, and loss of habitat by alteration 

and/or fragmentation. 

Initially, there would be 865 acres of disturbance 

(6.6% of the project area), and approximately 162 

acres (1.2% of the project area) would be 

unavailable over the life of the project. Since the 

overall footprint of the project would be relatively 

small compared to the size of the project area, loss 

of forage for wild horses would be minimal. 

However, the existing habitat within the footprint 

of the project, including wind turbines, access 

roads, and support facilities, would be disturbed 

and some disruption of grazing by wild horses due 

to habitat fragmentation might occur. However, 

wild horses appear to habituate relatively quickly 

to the presence of humans, so habitat 

fragmentation would likely not result in 

widespread displacement of horses from the 

project area. Reclamation and revegetation of 

temporarily disturbed areas would reduce the 

extent of habitat losses, but these effects would 

likely persist for 2 to 5 years after construction 

until vegetation is re-established. Since the 

number of horses in the White Mountain 

WHHMA is at the appropriate herd objectives, the 

habitat alteration effects would likely cause 

temporary small-scale reduction or temporary 

displacement of the wild horses found in the White 

Mountain project area. Teton would also post 

speed limit signs and inform employees that wild 

horses occur in the project area. These mitigation 

measures would minimize direct impacts to wild 

horses. Therefore, the Proposed Action would not 

be expected to have any long-term impacts on the 

population level of wild horses in the White 

Mountain WHHMA. 

In order to manage wild horses in the White 

Mountain WHHMA, they are occasionally 

rounded up by the BLM using a helicopter. The 

presence of cranes and wind turbines during the 

life of the project would affect the ability of the 

BLM to roundup wild horses from within the 

WMWE project area. Vehicle or horseback 

roundups could still continue within the project 

area, and the nBLM and Teton would coordinate 

access and shutting down wind turbines for 

4-6 hours over 2 days when roundups and surveys 

would be conducted. 

Impacts to wild horses during the 

decommissioning phase of the WMWE Project 

would be similar to impacts associated with 

construction, but of reduced magnitude. Noise 

and visual disturbance to wild horses may 

temporarily increase during decommissioning and 

site restoration relative to conditions during 

project operation. Additional habitat loss would 

be negligible, and wild horse mortality due to 

vehicle collisions would be much lower than 

during construction because of the reduced 

number of personnel. Disturbance to wild horse 

habitats and wild horses during decommissioning 

of the WMWE project facilities are expected to be 

localized, short-term, and minor. The number of 

wild horses and amount of habitat in the project 

area would eventually (10-20 years) return to 

preconstruction levels following site restoration, 

and wild horse habitat would be fully restored 

after decommissioning of the WMWE project 

facilities. 

Impacts to wild horses would be minimized where 

practicable, and the implementation of design 

features during the life of the project, including the 

posting of speed limit signs to reduce the 

likelihood of wild horse/vehicle collisions. Teton 

personnel would be informed that wild horses 

occur in the project area, that they are not allowed 

to haze or harass wild horses, and that they should 

minimize any direct disturbance to the wild horses 
EA, White Mountain Wind Energy Project 4-55 

whenever possible. Should an accident occur, the 

BLM Authorized Officer would be notified 

immediately. 

4.11.2 Alternative A - Development Only on 

Privately Owned Lands 

Under Alternative A, no additional impacts to wild 

horses beyond those discussed under the Proposed 

Action are expected to occur during the 

construction, O&M, and decommissioning phases 

of this project. Under Alternative A, the project 

would initially disturb 619 acres of rangeland in 

the White Mountain WHHMA. This disturbance 

would be reduced to 116 acres during the O&M 

phase of the project, and all disturbed lands would 

be revegetated during the decommissioning phase. 

Total disturbance and related impacts to wild 

horses would be expected to be reduced by 30% 

compared to the Proposed Action. 

Impacts to wild horses would be minimized where 

practicable, and the implementation of design 

features during all phases of Alternative A, 

including the posting of speed limit signs, would 

reduce the likelihood of wild horse/ vehicle 

collisions. Teton personnel would be informed 

that wild horses occur in the project area. They 

are not allowed to haze or harass wild horses, and 

they should minimize any direct disturbance to the 

wild horses whenever possible. Should an 

accident occur, the BLM Authorized Officer 

would be notified immediately. The BLM and 

Teton would coordinate access and shutting down 

wind turbines for 4-6 hours over 2 days when 

roundup and surveys would be conducted. 

4.11.3 Residual Impacts 

Residual impacts to wild horses under the 

Proposed Action would include the short-term 

disturbance of 865 acres and life-of-project 

disturbance of 189 acres of wild horse habitat 

within the WMWE project area. There would also 

be a minor increased risk of collisions with wild 

horses and vehicles. Residual impacts would be 

mitigated by implementation of the appropriate 

design features discussed in the Proposed Action. 

4.11.4 Cumulative Impacts 

Based on the disturbance calculations presented in 

Chapter 3.0, approximately 18,013 acres are 

currently disturbed within the IAA. This 

represents 9.13% of the total area within the IAA. 

RFFAs (including the Proposed Action) within the 

IAA would result in an additional 824 acres of 

disturbance--189 acres of total life-of-project 

disturbance due to existing activities and 635 acres 

of disturbance due to RFFAs. This represents 

18,837 of the total acres with the IAA or 9.53% 

based on the total disturbance due to existing 

activities, the Proposed Action, and RFFAs. 

Cumulative impacts to wild horses would be 

similar to those discussed under the Proposed 

Action (e.g., habitat disturbance and increased risk 

of wild horse/vehicle collisions), and there are no 

RFFAs that, when combined with the Proposed 

Action, would result in anything but minor 

impacts to wild horses. 

4.12 WILDLIFE 

The BLM Wind Energy Programmatic 

Environmental Impact Statement describes 

potential wildlife impacts associated with wind 

energy development in detail (BLM 2005). 

Impacts of Wind Energy Facilities on Wildlife and 

Wildlife Habitat (Arnett et al. 2007) and 

Environmental Impacts of Wind-Energy Projects 

(National Research Council 2007) also provide an 

overview of potential direct and indirect impacts 

to wildlife from wind energy facilities. General 

wildlife data for Wyoming and specifically for the 

WMWE project area also illustrate potential areas 

of wildlife conflict (refer to Figure 1.2). The 

principal impacts to wildlife associated with 

construction and operation of the facilities would 

occur from: 1) habitat loss, 2) disturbance and 

disruption effects on wildlife behavior, and 3) 

potential injury and mortality of wildlife 

associated with collisions with turbines and other 

facilities. 
4-56 EA, White Mountain Wind Energy Project 

4.12.1 Proposed Action 

4.12.1.1 Construction Phase 

Wildlife (Including Big Game) 

Impacts to wildlife species (including big game) 

during the construction phase of the Proposed 

Action could include direct mortality due to 

collisions with vehicles; loss of foraging, nesting, 

brood-rearing, and winter habitats; displacement 

from portions of the project area due to human 

presence, fugitive dust, or noise; and loss of 

habitat by alteration and/or fragmentation (BLM 

2005; Arnett et al. 2007; and National Research 

Council 2007). Construction location and timing 

may also affect migratory and other behavioral 

activities of some species of wildlife and big 

game. It is also possible that big game could be 

struck by construction vehicles; however, posted 

speed limit signs would be installed on project 

roads in cooperation with Sweetwater County 

officials, and mortalities due to vehicular 

collisions should be minimal. Initial direct 

removal of wildlife habitat would include 866 

acres (6.6% of the project area), and 

approximately 189 acres of wildlife habitat (1.4% 

of the project area) would be unavailable over the 

life of the project. 

Since the overall direct footprint of the project 

would be small compared to the size of the project 

area (6.6%), loss of forage would be minimal. 

However, the existing habitat within the footprint 

of the project, including wind turbines, access 

roads, and support facilities, would be disturbed, 

and habitat fragmentation would increase. To 

minimize habitat fragmentation, Teton would 

upgrade as many of the existing access and twotrack roads as possible. Reclamation and initial 

revegetation efforts of the temporarily disturbed 

areas would reduce the extent of habitat loss, but 

these effects would likely persist for 2 to 5 years 

after construction until revegetation of grasses and 

forbs is established. Sagebrush would take longer 

to become re-established (20 years). The 

Wyoming big sagebrush vegetation habitat found 

within the WMWE project area is common in the 

area, and large continuous tracts of similar habitats 

occur adjacent to the project area. However, the 

sagebrush ecosystem is one of the fastest declining 

habitat types (Knick et al. 2003). The effects of 

habitat alteration on big game due to construction 

of wind energy developments are mostly 

unknown. However, a recent study regarding 

interactions of transplanted elk populations during 

the construction and operations phase of a wind 

facility found no evidence that construction or 

operating activities had any significant impacts on 

elk use of the surrounding area (Walter et al. 

2004). However, based on responses of mule deer 

to natural gas development in Wyoming, it is 

likely that some reduction in use and/or 

displacement of local big game species could 

occur (Sawyer et al. 2009). At this time, longterm effects cannot be predicted. Studies are 

being initiated to assess the impact of wind 

development on big game found in Wyoming. 

For pronghorn antelope, approximately 12,144 

acres (92%) of the project area occurs in habitat 

the WGFD has designated as yearlong habitat, and 

1,021 acres (8%) of the proposed project area 

occurs in habitat the WGFD has designated as 

crucial winter/yearlong antelope range and is 

located near the eastern ridge of the project 

boundary and the rim of White Mountain (refer to 

Figure 3.10). In order to minimize potential 

impacts to pronghorn antelope in crucial winter 

ranges, Teton would comply with seasonal 

restrictions and would not conduct any projectrelated activities within antelope crucial/ yearlong 

range from November 15 to April 30. However, 

Teton may request an exception from the seasonal 

restriction stipulation from the BLM or the 

landowner, who would evaluate the request on a 

case-by-case basis. This seasonal mitigation 

measure would minimize impacts to antelope on 

the crucial winter/yearlong range located within 

the WMWE project area during the construction 

period. 

For mule deer, approximately 12,028 acres (91%) 

of the proposed project area occurs in habitat the 

WGFD has designated as yearlong mule deer 

range, and 8% is designated as winter yearlong. 

The remaining 108 acres (1%) located in the 

northwest corner of the project area is designated 

as “out” under the WGFD habitat designations, 

meaning that this area is not part of any herd unit; 
EA, White Mountain Wind Energy Project 4-57 

this area does not contain enough animals to be 

important habitat or the habitats are of limited 

importance to this species (WGFD 2006) (refer to 

Figure 3.11). No mule deer crucial winter range 

or parturition areas occur within the proposed 

project area. Therefore, during construction 

operations, the Proposed Project is not expected to 

have any adverse impacts to important mule deer 

ranges. 

For elk, approximately 11,559 acres (88%) of the 

project area occurs in habitat the WGFD has 

designated as spring/summer/fall habitat, and 

1,097 acres (8%) of the proposed project area 

occurs in habitat the WGFD has designated as 

winter/yearlong elk range. Approximately 509 

acres (4%) of the western project area intersects 

the boundary of habitat designated as crucial 

winter/yearlong range (WGFD 2006) (refer to 

Figure 3.12). An elk parturition area is located 0.5 

to 2.0 mi west of the project boundary. In order to 

minimize potential impacts to elk in crucial winter 

ranges, Teton would comply with seasonal 

restrictions and would not conduct any projectrelated activities within elk crucial/ yearlong range 

from November 15 to April 30. However, Teton 

may request an exception from the seasonal 

restriction stipulation from the BLM or the 

landowner, who would evaluate the request on a 

case-by-case basis. This seasonal mitigation 

measure would minimize impacts to elk on the 

crucial/yearlong ranges located within the WMWE 

project area during the construction period. The 

WMWE project area is approximately 0.5 mi away 

from the nearest elk parturition area, and the 

Proposed Action is not expected to impact elk 

parturition areas. 

Construction noise would also be a potential 

impact to wildlife in the WMWE project area. 

Potential noise sources during construction could 

include heavy trucks and equipment operation, and 

human presence during construction activities are 

likely to temporarily displace wildlife species that 

may be present within or near construction areas. 

The duration and distance an animal is displaced 

are dependent on the individual species, and an 

individual’s response to disturbance may change 

over time (BLM 2005; Arnett et al. 2005; National 

Research Council 2007). The construction of the 

WMWE Project could affect local wildlife by 

disturbing normal behavioral activities such as 

foraging and mating. Wildlife may avoid foraging 

and mating near the active construction areas or 

may vacate the active construction areas. Wildlife 

may temporarily or permanently abandon 

construction area habitats and adjacent habitats 

(BLM 2005; National Research Council 2007). 

Direct impacts from mortality or injury to smaller 

less-mobile species (e.g., reptiles, small mammals) 

could occur during construction if those species 

are present. These impacts are expected to be low 

and of short duration (BLM 2005; National 

Research Council 2007). 

Assuming appropriate design features are 

implemented, erosion and sedimentation, 

contaminant exposure, and fugitive dust from 

construction of the WMWE facility would have 

minimal impacts on wildlife. Surface disturbance 

could increase the introduction and establishment 

of invasive and exotic vegetation. Establishment 

of such vegetation could reduce habitat quality and 

alter the biotic community (BLM 2005; National 

Research Council 2007). Because there are no 

perennial waters in the project area and water 

erosion and sedimentation would be avoided 

through the implementation of appropriate 

protective measures (i.e., the SWPPP), impacts to 

wildlife from a decrease in water quality would be 

minor. Fugitive dust would also be minimized 

through the implementation of appropriate dust 

abatement measures, and impacts to wildlife 

would be minor. Contaminants within the project 

area would be contained, and any potential 

impacts to wildlife from contaminants would be 

short-term, localized, and minimized by 

implementation of appropriate measures (i.e., 

SPCCP). Introduction of invasive vegetation has 

the potential to reduce habitat quality and locally 

affect wildlife occurrence and abundance. These 

potential impacts would be minimized through the 

implementation of appropriate design features to 

manage nonnative invasive species as outlined in 

Chapter 2.0. 

Short-term ground disturbance impacts to small 

wildlife species (e.g., pocket gopher or burrowing 

rodents) would result from direct disruption of 
4-58 EA, White Mountain Wind Energy Project 

soils and vegetation, as well as from the presence 

of humans and vehicles in the construction areas. 

Most of these wildlife species would likely move 

away from the construction activities to 

undeveloped areas located outside of the disturbed 

area. However, some species such as burrowing 

rodents would be vulnerable to mortality from the 

physical disruption of soils and vegetation or 

displacement. These short-term ground 

disturbance impacts would include temporary loss 

of 866 acres of primarily Wyoming big sagebrush 

habitat. Habitat disturbance would include a series 

of string corridors consisting of tower assembly 

areas and pads (160 x 200 ft), the construction or 

upgrading of access roads and the construction of 

the substation area, staging area, O&M building 

area, and concrete batch plant area. 

Impacts include the life-of-project loss of 

163 acres of Wyoming big sagebrush habitat and 

habitat fragmentation due to the presence of the 

access roads, turbine strings, and new facilities, as 

well as regular disturbance from humans during 

periodic maintenance. There would be a 

permanent loss of 9 acres of burrowing rodent 

habitat from below grade concrete pads used to 

support the turbines. 

Bats 

The construction phase of the Proposed Action is 

expected to have minimal impacts on resident or 

migrant bat species that may occur in the WMWE 

project area. The primary impact to bats during 

the construction phase is from collision-related 

mortality with the turbines prior to operation or 

into towers and/or guide wires (BLM 2005; 

National Research Council 2007). Since bats are 

not known to roost in the area, impacts to bats 

during the construction phase are expected to be 

low (TRC 2008d). In addition, the WMWE 

project area does not contain topographic features 

likely to funnel or provide roosting areas for 

migrating bats, and the project area lacks large 

tracts of forest cover, open water, or other suitable 

foraging areas. Based on the topography of the 

WMWE project area, it is expected that a majority 

of bat mortalities during the construction phase of 

the project would occur as individuals migrate 

through the area. While it is possible that bats 

could fly into construction equipment and the 

turbines prior to operation, it is anticipated that bat 

mortality would be minimal during the 

construction phase of the project. While not 

documented as a proven mitigation measure, 

Teton would avoid siting wind turbines within 

50 m (164 ft) of large drainages within the project 

area. 

Raptors and Other Migratory Birds 

Impacts to birds during the construction phase 

would be similar to those discussed for wildlife 

habitat loss and fragmentation due to vegetation 

disturbance, human presence, and noise. 

Additional impacts during the construction phase 

to raptors and other birds may be collisions with 

construction vehicles, turbines, met towers, and 

substation structures (BLM 2005; National 

Research Council 2007; Arnett et al. 2007). 

The Migratory Bird Treaty Act provides protection 

to most PSBs found in or migrating through the 

project area. Impacts to migratory species could 

result from the removal of vegetation (clearing, 

etc.) during site preparation or from inadvertent 

compaction of vegetation. The removal of natural 

vegetation (grassland and shrub communities) 

would be minimized to the extent possible during 

construction. In addition, the movement of 

construction personnel and equipment on-site 

would be limited to the extent possible to the 

construction areas to avoid inadvertent impacts to 

all wildlife species. 

Raptors could be impacted as a result of 

construction-related disturbance during the nesting 

season. The BLM has established seasonal and no 

surface occupancy restriction areas that Teton 

would comply with according to BLM policy 

(BLM 1997). Additionally, Teton has committed 

to adopting a 50-m (164-ft) minimum setback 

from the ridgeline of White Mountain, as well as 

the edge of large drainages to further reduce 

impacts to avian species. Table 2.9 lists the 

seasonal restriction areas, as well as the no surface 

occupancy buffers, and Teton would not place any 

wind turbines within these no surface occupancy 

buffer areas. In addition, to reduce the risk of 

electrocution, all electrical systems and 
EA, White Mountain Wind Energy Project 4-59 

components would be designed, constructed, 

operated, and maintained in conformance with the 

National Electrical Safety Code and other 

applicable codes and standards, as well as 

Suggested Practices for Raptor Protection on 

Power Lines: the State of the Art in 2006 (Avian 

Power Line Interaction Committee 2006). 

4.12.1.2 O&M Phase 

Wildlife (Including Big Game) 

Impacts to wildlife (including big game) during 

the O&M phase of the WMWE Project would 

result from the loss of foraging habitat, avoidance 

of the project area due to vehicle traffic and 

project related noise, and increased wildfire 

potential. During the O&M phase, turbine 

assembly areas would be reduced and revegetated 

to an 80 x 80-ft pad area, and road widths would 

be reduced and revegetated from 54 ft to 

approximately 26 ft. Trenches for collection and 

communications lines would be backfilled and 

revegetated. These temporarily disturbed areas 

would be primarily located adjacent to roads that 

would be utilized by O&M personnel. Temporary 

disturbance areas would be reclaimed and 

revegetated and allowed to return to its previous 

use as wildlife habitat. The timing of seeding 

operations would typically occur during the fall, 

but some reseeding efforts may occur during the 

spring. However, approximately 189 acres of 

wildlife habitat would be occupied by the WMWE 

facility during project operation. The predominant 

habitat type affected by operation on the WMWE 

facility is the Wyoming big sagebrush vegetation 

community. This habitat is common in the area, 

and large continuous tracts of similar habitats 

occur adjacent to the project area. 

The primary noise-generating activities associated 

with routine O&M operations include pickup 

trucks and maintenance equipment noise and wind 

turbine noise. Truck and maintenance equipment 

noise is expected to be minor and periodic and 

associated with vehicle traffic on established 

project roads (as described in Chapter 2.0). O&M 

activity (i.e., maintenance operations) may disturb 

and/or displace some wildlife species from the 

area of activity. Some species may move 

permanently, and some species may be drawn to 

the project due to human activities (e.g., coyotes 

and common ravens could be attracted to human 

activity and these species could adversely impact 

ground-nesting species). New or improved access 

roads in the project area may increase access by 

recreational users, especially during winter, which 

may also disturb wildlife. It is also possible that 

with improved access within the project area there 

could be an increased potential for poaching or 

harassment of wildlife. However, if O&M 

personnel observe such illegal activity, they would 

immediately report it to WGFD. 

As discussed in Section 4.5 of this EA, the wind 

turbines identified for this project (the GE 1.5 SLE 

unit) are expected to have a maximum sound 

power level less than 104 dBA (General Electric 

2004). According to the Wind Energy PEIS 

(BLM 2005), considering geometric spreading, a 

wind turbine with a sound power level of 104 dBA 

would have a resulting sound power level of 58 to 

62 dBA at a distance of 164 ft from the turbine, 

which is about the same level as conversational 

speech at a distance of about 3 ft. This level of 

noise could disturb foraging and reproductive 

behaviors of various wildlife species that could 

lead to habitat avoidance (BLM 2005). However, 

it is unclear what impact this level of noise from 

wind turbines might have on wildlife species, 

including big game, because to date, few wildlife 

studies related to noise impacts of wind energy 

projects have been conducted (BLM 2005). It 

should also be noted that as wind speeds increase, 

background noise levels (from the wind) would 

also increase and would be louder than the 

operating wind turbine (BLM 2005; Rogers et al. 

2006). 

For big game species (pronghorn antelope, mule 

deer, and elk), the O&M phase of the project could 

result in some level of disruption and/or 

displacement of big game in the project area. 

Wind energy development is relatively new and 

few field studies have been conducted concerning 

big game species and potential impacts from wind 

energy projects. A recently completed multi-year 

study of mule deer in west-central Wyoming 

indicates that mule deer populations were 

adversely affected by disturbance from natural gas 
4-60 EA, White Mountain Wind Energy Project 

development and associated human activity 

(Sawyer et al. 2009). As a result, it is possible that 

similar types of effects could be observed in 

relation to wind energy development. However, it 

should also be recognized that oil and gas 

development and wind energy developments 

involve some important differences in the level of 

human activity and disturbance that are not 

directly comparable to each other (Strickland 

2009; Erickson 2009). Typical oil and gas well 

disturbance entails between 0.8 to 2.7 acres during 

operations depending on the type of well whereas 

a typical wind turbine surface disturbance entails 

0.1 to 0.15 acres. However, there are other aspects 

of these developents that are not directly 

comparable (i.e., height of facilities and moving 

parts). 

Disruption and/or displacement during the O&M 

phase of the project would likely be a continuation 

of construction-related impacts discussed above 

(Strickland 2009). However, the level of human 

activity during the O&M phase would be much 

less than during the construction phase of the 

Proposed Action. Two studies related to big game 

species and wind energy facilities documented the 

following results. A study of pronghorn antelope 

at the Foote Creek Rim wind project in southcentral Wyoming conducted in association with 

raptor use studies indicate that no substantial 

change in pronghorn abundance in the immediate 

project area (Johnson et al. 2000). In addition, a 

recent study regarding interactions of transplanted 

elk populations during the construction and O&M 

phases of a wind facility found no evidence that 

the construction or operation of the wind turbines 

had significant impacts on elk use of the 

surrounding area (Walter et al. 2004). 

No linear fences that could interfere with 

movement of big game species would be installed 

as part of the Proposed Action, and fences would 

only be installed around individual structures such 

as the electrical substation and O&M facility to 

protect public health and safety and to protect the 

company’s assets. 

There are no known migratory corridors for mule 

deer or elk within or immediately adjacent to the 

WMWE project area. As discussed in 

Chapter 3.0, no known pronghorn antelope 

migration corridors occur near the project area; 

however, there are several migration routes 

documented north of the WMWE project area 

(refer to Figure 3.10). Based on WGFD migration 

corridor data and range maps (refer to 

Figure 3.10), crucial winter range is located in the 

southeastern and northeastern edge of the WMWE 

project area. During the winter, it appears likely 

that most pronghorn antelope migrate east to 

crucial winter range below White Mountain and 

would likely avoid the top and rim of White 

Mountain due to typically heavy snow 

accumulations. It is possible that some pronghorn 

antelope may cross through the project area in the 

winter/spring and could travel on project roads or 

other roads (such as County Road 53) where snow 

removal operations occur, and they could become 

stranded on top of White Mountain during periods 

of heavy deep snows if the roads become 

impassable. Since Teton would be conducting 

yearlong operations, project roads would be 

plowed and would typically remain open all winter 

long. Any impediment to pronghorn antelope 

movement in the project area would be negated 

since Teton has committed to plowing openings 

(at least one opening every 0.25 mi or as directed 

by the BLM) in the snow berms to allow big game 

species to move off and away from road activities. 

Therefore, the Proposed Action is expected to 

have limited impacts on migrating pronghorn 

antelope. 

In addition, the project would result in the 

unavoidable life-of-project direct loss of 189 acres 

of big game habitat within the project area. It is 

also possible that big game could be struck by 

O&M vehicles; however, posted speed limit signs 

would be installed on project roads in cooperation 

with Sweetwater County officials. Operation of 

the facility is not expected to have any long-term 

effects on big game once they have habituated to 

the increased level of traffic and the presence of 

the wind turbines. O&M personnel will be 

informed that wildlife (including big game 

species) occur in the project area, that they are not 

allowed to haze or harass the animals, and that 

they should minimize any disturbance to the 

animal whenever possible. Any incidents of 
EA, White Mountain Wind Energy Project 4-61 

poaching will be immediately reported to the 

WGFD. 

Increased O&M activity in the project area could 

increase the potential for wildfires. While 

possible, wildfires associated with the O&M phase 

of the Proposed Action are unlikely to occur. In 

the event of a wildfire, impacts to wildlife 

(including big game) would include direct 

mortality, reduction of habitat, and/or reduction in 

habitat quality. Implementation of the wildfire 

prevention plan outlined in the Proposed Action 

would minimize the chance of a wildfire 

occurring. 

While unlikely, wildlife could also be affected by 

exposure to contaminants during operation of the 

WMWE Project. Although petroleum products 

(e.g., fuel, mineral oil, hydraulic oil, lubricating 

oil, etc.) would be stored and used at the facility, 

exposures are not expected under normal facility 

operations. In addition, a SPCCP would be 

implemented to minimize potential impacts from 

any spills that might occur. In general, wildlife 

(including big game) would not be affected by 

contaminant exposure during operation of the 

project. 

The implementation of design features during the 

O&M phase, including using noise reducing 

turbines, employees carrying fire extinguishers to 

prevent the spread of wildfire, disposing of trash 

properly, restricting site maintenance activities to 

the minimum area necessary, designating travel 

corridors with reasonable speed limits, and control 

efforts for nonnative invasive species, would 

minimize potential disturbance or impacts to 

wildlife habitats and species (including big game). 

Bats 

The causes of bat mortality due to wind turbines 

are relatively unknown, and studies are ongoing 

(Kunz et al. 2007). To date, only a limited number 

of post-construction monitoring studies have been 

conducted at wind energy projects in the western 

U.S., and the results of these studies suggest: 

1) migratory species with low frequency calls 

(e.g., hoary and silver-haired bats) comprise 

almost 75% of reported bats killed; 2) the majority 

of bat fatalities occur during the postbreeding or 

fall migration season (roughly August and 

September); and 3) the highest reported fatalities 

occur at wind facilities located along forested 

ridgetops (Arnett et al. 2008; Gruver 2002; 

Johnson et al. 2003; Kunz et al. 2007), although 

recent studies in agricultural regions of Iowa and 

Alberta, Canada, report relatively high fatalities as 

well (Jain 2005; Baerwald 2006). 

Currently, mortality surveys are the only source of 

information on the number of bat fatalities at wind 

energy facilities. The following analysis is based 

on previous bat mortality studies, but differences 

between the proposed project and previous study 

projects, including the number of turbines, 

geographic region, habitat, topography, bat 

populations, weather, and other unknown factors, 

may result in different levels of bat mortality at the 

project. 

It is estimated that the large majority of bat 

fatalities at wind energy facilities involve solitary, 

migratory, and foliage- and tree-roosting species 

such as silver-haired, hoary, and red bats. Hoary 

bats account for nearly half of all bat fatalities at 

wind energy facilities (Arnett et al. 2007; Kunz et 

al. 2007; Erickson et al. 2002; Johnson et al. 2003; 

Johnson 2005). Although variable and periodic, 

bat fatalities consistently peak in late summer and 

fall, coinciding with migration (Arnett et al. 2007). 

Approximately 90% of fatalities occur from midJuly through late September, with over 50% 

occurring in August (Erickson et al. 2002; Johnson 

2004; Johnson 2005). Mortality during the 

breeding season is low. One study showed that, 

although there were relatively large breeding 

populations of bats near an operating wind facility, 

bat collision mortality was low to nonexistent 

(Johnson 2004). Mortality during spring 

migration is also very low (Johnson 2005). Only a 

small fraction of bats that traverse wind energy 

facilities are actually impacted by wind turbines 

(Erickson et al. 2002; Johnson 2005). These data 

suggest that wind energy facilities do not currently 

affect resident breeding or foraging bat 

populations (Erickson et al. 2002; Johnson et al. 

2003; Johnson 2004; Johnson 2005). Studies 

indicate that bat mortality rates were the highest in 

forested environments, moderate in open areas 
4-62 EA, White Mountain Wind Energy Project 

close to forests, and lowest in open areas (Johnson 

2005). 

Based on bat surveys conducted at the WMWE 

Project in 2008, bat activity was highest in August 

compared to any other month of survey. Hoary 

bats were approximately 18.7% of total passes 

detected within the study area, and silver-haired 

and big brown bats were approximately 14.6% of 

the total passes detected within the study area. 

Studies indicate that the most likely species to 

travel within turbine rotor heights include hoary 

bats, western red bats, and silver-haired bats. 

These species would be most susceptible to 

impacts during fall migration. The remaining 

66.7% of the bat passes were from bats with high 

frequency calls such as the little brown bat, longlegged bat, western small-footed bat, and western 

long-eared bat (TRC 2008d). 

Comparisons between bat activity and mortality 

rates at operational wind energy facilities and 

recorded bat activity at the project suggest that 

mortality at the project could be similar to that 

experienced at the Foote Creek Rim wind farm in 

Wyoming. The Foote Creek Rim site contains 

habitat comparable to the project area (i.e., 

primarily mixed-grass prairie and sagebrush 

shrubland). Bat fatalities at Foote Creek Rim 

consisted of hoary bats (80%), little brown bats 

(9%), silver-haired bats (7%), and big brown bat 

(1%) and 3% could not be identified. Based on 

post-construction mortality surveys at the Foote 

Creek Rim wind farm, estimated bat mortality at 

this site is approximately 1.3 bats per turbine per 

year (Young et al. 2003). 

Some bat studies at wind energy facilities have 

included both preconstruction surveys (i.e., Anabat 

detection studies) and post-construction surveys 

(i.e., bat mortality surveys), and the results are 

presented in Table 4.13. Based on the presumed 

relationship between preconstruction bat activity 

and post-construction fatalities, the overall bat 

mortality rates at the WMWE Project is estimated 

to be low, in the range of 1.3 bat fatalities per 

turbine per year (documented in the Foote Creek 

Rim wind farm site) to slightly higher than the 

2.2 bat fatalities per turbine per year documented 

at the Buffalo Ridge wind farm site (TRC 2008d). 

Under the Proposed Action, approximately 312 to 

528 bat deaths per year could occur as a result of 

the operation of the WMWE Project. While 

projects occurring in the eastern U.S. may have 

higher bat activity and mortalities per year, 

population sizes are believed to be much higher in 

these areas when compared to the sagebrush 

ecosystems. Therefore, while total bat mortalities 

may be low in the WMWE Project compared to 

eastern states, impacts to population levels could 

have a larger impact due to greater potential for 

loss of genetic diversity. The expected range of 

bat mortalities at the WMWE Project are within 

the range of bat mortalities documented and 

acknowledged in the Wind Energy PEIS (BLM 

2005). 

To minimize potential impacts to bats during the 

O&M phase of the project, Teton would work with 

the BLM to develop and implement an operational 

protocol to modify the cut-in speeds of wind 

turbines within the WMWE project area. These 

protocols would be implemented during a portion 

of evening and night time hours of operation 

during the peak bat migration season. This 

protocol would be developed based on the 

preliminary results of the Arnett et al. (2009) study 

that documented reduced bat fatalities by changing 

the cut-in speed of wind turbines. In this study, 

the experimental cut-in speeds ranged between 

11.1 mph (5.0 m/s) and 14.5 mph (6.5 m/s) with a 

corresponding nightly reduction in bat fatalities 

from 53 to 87% (165 to 438 fewer animal 

fatalities). Results of on-site post-construction 

avian and bat mortalities would be used by Teton 

and the BLM to fine tune the cut-in speed 

protocol. 

In addition, the proposed WMWE Project is not 

located near any known bat colonies or other 

features that are likely to attract large numbers of 

bats. The WMWE project area does not contain 

topographic features likely to funnel migrating 

bats, and the project area lacks large tracts of 

forest cover, unlike high- mortality sites in the 

eastern U.S. However, the relatively large 

numbers of bat fatalities recently reported in 

northern Iowa (Jain 2005) and southwestern 

Alberta (Baerwald 2006) indicate that an open 

landscape is no guarantee of low mortality. Based 
EA, White Mountain Wind Energy Project 4-63 

Table 4.13 Wind Energy Facilities in the U.S. with both Preconstruction Anabat Sampling Data and 

Post-construction Mortality Data for Bat Species.1 

Activity2 Mortality 

Wind Energy Facility (No./Detector-night) (Bats/Turbine/Year) Reference 

WMWE, Wyoming 2.6 N/A (2008d) 

Foote Creek Rim, Wyoming3 2.2 1.3 Gruver (2002)
 

Buffalo Ridge, Minnesota3 2.1 2.2 Johnson et al. (2004) 

Buffalo Mountain, Tennessee3

 23.7 20.8 Fiedler (2004) 

Top of Iowa, Iowa3 34.9 10.2 Koford et al. (2005)
 

Mountaineer, West Virginia3

 38.3 38.0 Arnett et al. (2005) 

1 Adapted from TRC (2008d). 2 Average detections during study duration. 3 Detection data based only on ground-mounted units. 

on the topography of the WMWE project area, it is 

expected that a majority of bat mortalities 

associated with the operation of the wind energy 

facility would occur as individuals migrate 

through the area. 

Mortality rates of solitary tree-dwelling species are 

expected to be highest during fall migration. 

Resident and foraging bat populations are at the 

lowest risk (Young et al. 2003). With proper 

design and siting of wind projects, bat mortality 

can be greatly reduced and population impacts 

avoided (BLM 2005). The expected range of bat 

mortalities at the WMWE project area are within 

the range of bat mortalities documented and 

acknowledged in the Wind Energy PEIS (BLM 

2005). 

Raptors and Other Migratory Birds 

The majority of impacts to birds from operation of 

the WMWE Project would result from collision 

with the wind turbines. Studies have also shown 

that densities of bird populations in the vicinity of 

wind energy projects may be reduced near turbines 

if continuous noise levels are in the range of 

40 dBA or higher (BLM 2005). Birds hear best 

between about 1 and 5 kHz (Dooling 2002), and 

studies have also shown that blade noise from a 

normally operating wind turbine would simply add 

to the background noise and would be inaudible to 

birds at a distance of approximately 80 ft from the 

turbine when the blade and wind noise levels are 

within 1.5 dBA of one other (BLM 2005). Birds 

cannot hear the noise from wind turbine blades as 

well as humans, and most likely a human with 

normal hearing can hear a wind turbine twice as 

far away as the average bird (Dooling 2002). 

Turbine blade defects that produce whistles may 

be more audible to birds and, at the same time, 

make no measureable contribution to overall noise 

level (Dooling 2002). 

One study suggests that nesting grassland 

passerines may be displaced by wind energy 

facilities (Leddy et al. 1999) and occupy other 

areas. However, another displacement study in 

Montana has not detected any displacement of 

nesting grassland birds within a wind energy 

facility (TRC 2009c). 

It is estimated that bird fatalities at wind energy 

facilities probably represent from 0.01 to 0.02% 

(i.e., 1 out of every 5,000 to 10,000 avian 

fatalities) of the annual avian fatalities in the U.S. 

(Arnett et al. 2007). Bird deaths caused by wind 

turbines are a small fraction of the total 

anthropogenic bird mortality (Committee on 

Environmental Impacts of Wind Energy Projects 

2007). In 2003, it was estimated that turbine 

collisions killed 20,000 to 37,000 birds, with all 

but 9,200 of those deaths occurring in California. 
4-64 EA, White Mountain Wind Energy Project 

In comparison, collisions with buildings kill 97 to 

976 million birds annually, and collisions with 

cars may kill 80 million birds per year (Erickson 

2004). It is estimated wind turbines kill 33,000 

birds annually (Erickson et al. 2001; USFWS 

2002). Data suggest an average of 2.19 avian 

fatalities per turbine per year in the U.S. for all 

species combined, and 0.033 raptor fatalities per 

turbine per year (Erickson et al. 2001). Studies 

show that avian mortality rates from wind energy 

facilities vary greatly by region and species, with 

higher concentrated impacts in northern California 

and Appalachia (General Accounting Office 

[GAO] 2005). Excluding California, an average 

of 1.83 avian fatalities per turbine per year and 

0.006 raptor fatalities per turbine per year have 

been documented (Erickson et al. 2001). Studies 

conducted to date indicate that, in the U.S., 

passerines and raptors appear to be the most 

susceptible to turbine collisions (American Wind 

Energy Association [AWEA] 1995). 

Passerines comprise a large proportion of the 

fatalities at wind facilities and involve both 

residents and migratory species (Erickson et al. 

2002). Expected passerine mortality may be 

approximately 1.2 to 1.8 birds per turbine per year. 

However, this level of mortality is not expected to 

have population-level consequences for individual 

species because of the expected low fatality rates 

for most species and the large population sizes of 

common species (e.g., horned lark and western 

meadowlark). It has been suggested that resident 

birds may have a higher probability of colliding 

with turbines than migrants because residents tend 

to fly lower and spend more time in the area (BLM 

2005). Although population effects may be 

possible for some species, no studies have thus far 

documented such effects (BLM 2005). 

Risk index is the risk exposure to turbine collision 

for each bird species. A risk index value of zero 

for a species does not indicate that there would be 

no risk associated with operation of the wind 

energy facility; any bird flying in the area would 

be at risk of turbine collision. The risk index 

simply identifies species that may be at more risk 

than other species based on observed flight height 

relative to proposed turbine rotor height. Species 

with high relative exposure indices may actually 

not be at high risk of turbine collisions; they are 

just at more risk than species with lower indices 

based on the risk formula. 

Estimating risk exposure is difficult because 

abundance and behavior influence the risk of 

exposure. An extensive preconstruction avian 

survey was conducted at the WMWE project area, 

and among the PSBs, the risk value for horned 

larks (0.0790) was the highest--over seven times 

higher than unidentified sparrows (0.0109), the 

second highest risk value. American robins 

(0.0054) had the third highest risk value, followed 

by sage thrashers (0.0027) (TRC 2009b). Based 

on avian surveys at the WMWE Project in 2008, 

horned lark was the most abundant of the species 

documented in the WMWE project area during 

both spring and fall surveys (TRC 2009b). Given 

its abundance in the project area and the high 

mortality rates documented for this species 

compared to other species in several wind farm 

avian mortality studies (Young et al. 2003; 

Erickson et al. 2002; Erickson et al. 2004), it is 

likely that wind farm-related mortality would be 

highest for horned lark relative to other bird 

species occurring in the WMWE project area. 

This species may be especially vulnerable to 

collision with turbines during the breeding 

season because of their distinct aerial courtship 

displays. Male horned larks may deliver flight 

songs lasting 0.5 to 8 minutes during the breeding 

season (Beason 1995). After ascending to heights 

of approximately 541 ft (range 262-820 ft), the 

birds glide toward the ground with wings and tail 

spread (Beason 1995). The birds repeatedly regain 

altitude and repeat their song. At the end of the 

song flights, the males dive to the ground. 

However, despite their potential vulnerability to 

collide with turbines, it is unlikely that turbinerelated mortality in the WMWE project area 

would have a significant negative impact on 

horned lark populations. Many of the other 

passerine birds were not observed flying within 

the rotor-swept area, so risk value is assumed to be 

low. 

Raptor use in the WMWE project area is 

dominated by northern harriers and golden eagles, 

whereas nonraptor large bird species most 

common in the area are common raven and black­
EA, White Mountain Wind Energy Project 4-65 

billed magpie. Similarly, the risk index among 

raptors and other large birds reflects the 

dominance of these species: common raven, 

golden eagle, and northern harrier, which rank in 

the top three in risk for turbine-related collision. 

Risk for black-billed magpies is assumed to be 

low, as no individuals were observed flying within 

the rotor-swept area. 

Although the number of PSBs observed during the 

WMWE avian studies far exceeded the number of 

RLBs observed, RLBs had a notably higher risk 

level associated with turbine-related injury or 

mortality (0.8919 vs. 0.1499) because they were 

over six times as likely to fly within the rotorswept area of a typical 1.5-MW turbine. Despite 

the apparent higher risk level, raptor mortality has 

been absent to very low at all newer-generation 

wind energy facilities in the U.S. (Erickson et al. 

2002; Young et al. 2003). Other studies report 

that passerines appeared to be at greatest risk 

given their higher fatality rates compared to 

raptors (McCrary et al. 1986; Young et al. 2003). 

In the WMWE project area, some raptors appeared 

to use the area along the eastern edge of White 

Mountain preferentially. Raptors also used areas 

near drainages and hills. Based on these findings 

and the increased tendency for raptors to fly within 

the rotor-swept area along rim edges (Johnson 

et al. 2000), turbines located along the eastern 

edge of the mountain would pose the greatest risk 

to RLBs. Turbines along the edges of incised 

drainages also might pose higher than average risk 

to RLBs. 

Although it has been widely used in wind energy 

studies (e.g., Johnson et al. 2000; Erickson et al. 

2002; Young et al. 2003) to date, the exposure risk 

model has been validated by few post-construction 

fatality studies (for an exception see Johnson et al. 

2000). The exposure risk does not take into 

account factors such as bird behavior, flight styles, 

and varying abilities of birds to detect turbines, all 

of which may be important factors in determining 

risk of collision with turbines. Therefore, the 

index is useful primarily as an indicator of those 

species in the project area that had the highest 

exposure to the wind turbine rotor-swept area. It 

also facilitates comparisons of risk among selected 

species in the project area. Because of the 

similarities of the WMWE project area to that of 

the Foote Creek Rim wind farm, it is estimated 

that the WMWE Project would result in 

approximately 1.5 avian fatalities per turbine per 

year, and most (possibly 90%) of the fatalities 

would be passerines and the remaining 10% would 

be RLBs. Under the Proposed Action, 

approximately 360 total avian mortalities per year 

could occur. Of these mortalities, approximately 

324 mortalities could be PSBs and 36 could be 

RLBs. Based on other post-construction avian 

mortality studies, the mortalities are expected to 

include migratory and resident birds (Young et al. 

2003). The potential avian mortalities expected at 

the WMWE Project are within the range of avian 

mortalities documented and acknowledged in the 

Wind Energy PEIS (BLM 2005), which 

acknowledges that an average of 1.83 avian 

fatalities per turbine per year has been documented 

and a range of 0.0 to 4.45 bird fatalities per turbine 

per year (excluding wind energy projects in 

California, which historically had higher fatality 

rates). With proper design and siting of wind 

projects, avian mortalities can be reduced (BLM 

2005). 

All mitigation measures listed in Chapter 2.0 to 

avoid avian collisions with wind turbines would be 

incorporated into the design of the wind turbine 

and the tower. These measures include solid 

tubular towers to eliminate perch locations, slowrotating blades for increased visibility, and setback 

of wind turbines at least 50 m (164 ft) from the 

east edge of White Mountain and at least 50 m 

(164 ft) from the edge of large drainages within 

the project area. Lighting of the wind turbines 

would also be in accordance with USFWS and 

FAA recommendations to aid in the reduction of 

avian and bat mortalities (Gehring et al. 2009). 

Teton would conduct a 3-year post-construction 

avian and bat mortality study for the project unless 

sufficient evidence determines that continued 

monitoring is unneccesary. 

In addition, all electrical equipment (including the 

substation) would be designed and constructed in 

accordance with Suggested Practices for Raptor 

Protection on Power Lines: the State of the Art in 

2006 (Avian Power Line Interaction Committee 

2006). In addition, all permanent met towers 
4-66 EA, White Mountain Wind Energy Project 

would be self supported (i.e., nonguyed) to 

minimize avian collisions and mortalities and 

potential big game entanglement. 

4.12.1.3 Decommissioning Phase 

Wildlife (Including Big Game) 

Impacts to wildlife from decommissioning of the 

WMWE Project would be similar to impacts 

associated with their construction, but of reduced 

magnitude. Noise and visual disturbance to 

wildlife may temporarily increase during 

decommissioning and site restoration relative to 

conditions during project operation. New habitat 

loss would be negligible, and wildlife injury and 

mortality would be much lower than during 

construction. Removal of facilities components 

would eliminate the impacts associated with 

wildlife collisions with WMWE structures. 

Wildlife habitat in the area is expected to return to 

preproject conditions following decommissioning 

and site restoration (BLM 2005). 

Disturbance to wildlife habitats and wildlife 

during decommissioning of the WMWE project 

facilities is expected to be localized, short-term, 

and minor. Impacts to wildlife would be 

minimized, where practicable, and the 

implementation of environmental protection 

measures during decommissioning, including 

seasonal wildlife stipulations, dust suppression, 

contaminant control, control of nonnative invasive 

species, and revegetation of impact areas with 

native seed mixtures, would minimize potential 

disturbance or impacts to wildlife habitats and 

species. Protection measures for the project can 

be found in Chapter 2.0 of this EA. 

Bats 

No additional impacts to bats beyond those 

discussed under construction impacts are expected 

to occur during the decommissioning phase of this 

project, and these impacts are expected to be 

minimal. 

Raptors and Other Birds 

No additional impacts to raptors and other birds 

beyond those discussed under construction 

impacts are expected to occur during the 

decommissioning phase of this project. The 

removal of a limited amount of natural vegetation 

(grassland and shrub communities) would be 

minimized to the extent possible during 

decommissioning of the project. In addition, the 

movement of personnel and equipment on-site 

would be limited to the extent possible to 

construction areas to avoid inadvertent compaction 

of vegetation. 

Raptors could be impacted as a result of 

decommissioning-related disturbance during the 

nesting season. To avoid impacts on the nesting 

raptors during the decommissioning phase of the 

project, Teton will implement the same seasonal 

restriction areas in accordance with BLM policy 

(BLM 1997) as provided in Table 2.9 of this EA. 

4.12.2 Alternative A - Development Only on 

Privately Owned Lands 

4.12.2.1 Construction Phase 

Potential direct and indirect impacts to wildlife, 

including big game, bats, and birds, under 

Alternative A would be the same as discussed 

under the Proposed Action. Implementation of 

this alternative would involve the construction of 

170 wind turbines on privately owned land; 

therefore, direct impacts to wildlife habitat would 

include the disturbance of 619 acres of habitat 

from road construction, the excavation of the 

turbine pads, the substation and batch plant, and 

the collector lines. Most of the disturbed area 

would be reclaimed and revegetated, with 

115 acres (less than 1.0% of the project area) 

remaining occupied by roads, turbine foundations, 

and facilities for the life of the project. The 

potential impact to wildlife habitat would be 

reduced by 30% compared to those described 

under the Proposed Action; however, if the 

construction of the 170 turbines occurs wholly on 

one vegetation type, impacts to that single 

vegetation community would be similar to that 

described under the Proposed Action. Noise and 
EA, White Mountain Wind Energy Project 4-67 

human disturbance during construction activities 

under Alternative A are anticipated to be the same 

as under the Proposed Action. 

The reduction in both short-term and life-ofproject loss of wildlife habitat under Alternative A 

when compared to the Proposed Action would be 

negligible. 

4.12.2.2 O&M Phase 

Under Alternative A, no additional impacts 

beyond those discussed under the Proposed Action 

are expected to occur during the O&M phase of 

this project. Implementation of Alternative A may 

slightly decrease the total number of bird and bat 

turbine-related fatalities by 30% as a result of the 

construction of 30% fewer turbines. Under 

Alternative A, approximately 255 total avian 

mortalities per year and approximately 218 to 

370 total bat mortalities could occur. Assuming 

all design features are implemented, potential 

avian and bat mortalities would be within the 

range of mortalities documented and 

acknowledged in the Wind Energy PEIS (BLM 

2005). 

4.12.2.3 Decommissioning Phase 

Under Alternative A, no additional impacts 

beyond those discussed under the Proposed Action 

are expected to occur during the decommissioning 

phase of this project. 

4.12.3 No Action Alternatives 

Under the No Action Alternative, the proposed 

wind energy facility would not be authorized nor 

approved. No ground would be disturbed, and no 

impacts to the existing biological environment 

would take place beyond those that already exist. 

4.12.4 Residual Impacts 

The Proposed Action would result in the direct 

life-of-project loss of approximately 189 acres of 

wildlife habitat due to vegetation removal. Some 

wildlife species could be temporarily displaced 

from project-related construction activities and 

some species, especially small mammals, birds, 

amphibians, and reptiles, may be killed by 

construction, O&M, and decommissioning 

operations. Habitat effectiveness, especially for 

big game species, would likely be reduced, due to 

the change in the compaction of vegetation 

communities as revegetated areas become reestablished and evolve toward a sagebrush 

dominated plant community. There would also be 

an unavoidable loss of wildlife due to 

wildlife/vehicle collisions. 

4.12.5 Cumulative Impacts 

In order to assess potential cumulative impacts to 

wildlife species, various IAAs have been 

established to evaluate the Proposed Action, and 

quantitative data for the various IAAs are 

summarized in Table 4.14. 

4.12.5.1 Wildlife (Including Big Game) 

For general wildlife (i.e., nongame and small 

mammals), habitat disturbance associated with the 

existing Proposed Action and RFFAs is expected 

to result in 8.15% disturbance of the IAA, and 

cumulative impact would be similar to those 

discussed under the Proposed Action. 

Implementation of the various mitigation measures 

to limit disturbance and encourage prompt 

reclamation of disturbance and other appropriate 

mitigation measures presented in the Proposed 

Action would minimize impacts to wildlife 

species, and cumulative impacts to nongame and 

small mammal populations within the cumulative 

IAA are expected to be limited. 

For pronghorn antelope, current disturbance 

accounts for a total of 17,409 acres (2.84%) of the 

IAA, and physical disturbance associated with the 

Proposed Action and RFFAs would represent an 

additional 973 acres (0.16%) of the IAA for a total 

current and projected physical disturbance of 

18,382 acres (3.00%) of the IAA for pronghorn 

antelope (refer to Table 4.13). Impacts to 

pronghorn antelope during the life of these 

projects would be similar to those discussed under 

the Proposed Action and could include disturbance 

and/or displacement due to human presence, 

fugitive dust or noise, direct mortality due to 
4-68 EA, White Mountain Wind Energy Project 

Table 4.14 IAAs for Wildlife Resources. 

Resource Description 

Total Area 

(acres) 

Amount of 

Current 

Disturbance 

(acre and %) 

Amount of 

Disturbance Related 

to RFFA (Including 

Proposed Action) 

(acre and %) 

Total Amount 

of Current and 

RFFA 

Disturbance 

(acre and %) 

Wildlife, 

bats, and 

migratory 

birds 

Level 12 HUC 

boundary 

268,613 19,954 (7.43%) 1,080 (0.40%) 21,034 (7.83%) 

Pronghorn 

antelope 

WGFD - Sublette 

Herd Unit 

612,496 17,409 (2.84%) 973 (0.16%) 18,382 (3.00%) 

 Crucial 

Pronghorn 

antelope 

winter/yearlong 

range 

279,452 9,944 (3.56%) 71 (0.02%) 10,015 (3.58%) 

Mule deer WGFD - Mule 

Deer Steamboat 

Herd Unit 

2,554,688 27,191 (1.06%) 1,268 (0.05%) 28,459 (1.11%) 

Elk WGFD - Elk 

Steamboat Herd 

Unit 

2,529,715 23,452 (0.93%) 1,207 (0.05%) 24,659 (0.98%) 

 Crucial elk 

winter/yearlong 

range 

280,448 1,896 (0.68%) 29 (<0.01) 1,925 (0.69%) 

Raptors and 

other birds 

Project area plus 

14.45-mi buffer 

693,604 29,676 (4.28%) 1,455 (0.21%) 31,131 (4.49%) 
EA, White Mountain Wind Energy Project 4-69 

collisions with vehicles, and loss of habitat by 

alteration and/or fragmentation. Appropriate 

design features as discussed in Chapter 2.0 

(including prompt revegetation efforts) would be 

implemented for each federally authorized project 

and would mitigate potential impacts. The 

Proposed Action and RFFAs would add 973 acres 

of disturbance (0.16% of the total IAA), and this 

represents a small percentage of direct 

disturbances. However, indirect disturbance (due 

to human presence, noise, dust, etc.) and habitat 

fragmentation would likely increase and would 

result in some reduction in use and/or 

displacement. 

In addition, the largest amount of current 

disturbance is in pronghorn crucial winter/ 

yearlong range and these disturbances account for 

a total of 9,944 acres or 3.56% of the crucial 

winter/yearlong range within the IAA. Physical 

disturbance associated with the Proposed Action 

and RFFAs would represent an additional 71 acres 

or 0.02% of the crucial winter/yearlong range 

within the IAA for a total physical disturbance for 

current and projected disturbance of 10,015 acres 

or 3.58% of the crucial winter/yearlong range 

within the IAA (refer to Table 4.14). Impacts to 

pronghorn antelope crucial winter/yearlong ranges 

during the life of these projects would be similar 

to those discussed above and could include 

disturbance and/or displacement due to human 

presence, fugitive dust or noise, direct 

mortality due to collisions with vehicles, and loss 

of habitat by alteration and/or fragmentation. 

Implementation of all appropriate seasonal 

restriction for all federally authorized projects 

would minimize potential impacts to pronghorn 

antelope in crucial winter ranges, Teton and other 

companies would comply with seasonal 

restrictions and would not conduct any projectrelated activities within antelope crucial 

winter/yearlong range from November 15 to April 

30. However, Teton and the other companies may 

request an exception from the seasonal restriction 

stipulation from the BLM or the landowner, who 

would evaluate the request on a case-by-case 

basis. This seasonal mitigation measure would 

minimize impacts to antelope on the 

crucial/yearlong ranges located within the various 

projects during the construction periods. The 

Proposed Action and RFFAs would add 71 acres 

of disturbance (0.02% of the crucial 

winter/yearlong range in the IAA), and this 

represents a small percentage of direct 

disturbances. However, indirect disturbance (due 

to human presence, noise, dust, etc.) and habitat 

fragmentation would likely increase and could 

result in some reduction in use and/or 

displacement. 

For mule deer, current disturbance accounts for a 

total of 27,191 acres (1.06%) of the IAA, and 

physical disturbance associated with the Proposed 

Action and RFFAs represents approximately 

1,268 acres (0.05%) of the IAA for a total current 

and projected physical disturbance of 28,459 acres 

(1.11%) of the IAA for mule deer (refer to 

Table 4.14). Impacts to mule deer during the life 

of these projects would be similar to those 

discussed under the Proposed Action and could 

include disturbance and/or displacement due to 

human presence, fugitive dust or noise, direct 

mortality due to collisions with vehicles, and loss 

of habitat by alteration and/or fragmentation. 

Appropriate design features as discussed in 

Chapter 2.0 (including prompt revegetation 

efforts) would be implemented for each federally 

authorized project and would mitigate potential 

impacts. The Proposed Action and RFFAs would 

add 1,268 acres of disturbance (0.05% of the 

total IAA), and this represents a small percentage 

of direct disturbances. However, indirect 

disturbance (due to human presence, noise, dust, 

etc.) and habitat fragmentation would likely 

increase and would result in some reduction in use 

and/or displacement. 

There are no crucial winter, severe winter relief, or 

mule deer parturition areas within or immediately 

adjacent to the WMWE project area. Therefore, 

the Proposed Action would not result in any 

cumulative impacts to these important mule deer 

habitats. 

For elk, current disturbance accounts for a total of 

23,452 acres (0.93%) of the IAA, and physical 

disturbance associated with the Proposed Action 

and RFFAs would represent an additional 

1,207 acres (0.05%) of the IAA for a total current 

and projected physical disturbance of 24,659 acres 
4-70 EA, White Mountain Wind Energy Project 

(0.98%) of the IAA for elk (refer to Table 4.14). 

Impacts to elk during the life of these projects 

would be similar to those discussed under the 

Proposed Action and could include disturbance 

and/or displacement due to human presence, 

fugitive dust or noise, direct mortality due to 

collisions with vehicles, and loss of habitat by 

alteration and/or fragmentation. Appropriate 

design features as discussed in Chapter 2.0 

(including prompt revegetation efforts) would be 

implemented for each federally authorized project 

and would mitigate potential impacts. The 

Proposed Action and RFFAs would add 

1,207 acres of disturbance (0.05% of the total 

IAA), and this represents a small percentage of 

direct disturbances. However, indirect disturbance 

(due to human presence, noise, dust, etc.) and 

habitat fragmentation would likely increase and 

would result in some reduction in use and/or 

displacement. 

In addition, current disturbance in elk crucial 

winter/yearlong range accounts for a total of 

1,896 acres or 0.68% of the crucial winter/ 

yearlong range within the IAA. Physical 

disturbance associated with the Proposed Action 

and RFFAs would represent an additional 29 acres 

or less than 0.01% of the crucial winter/yearlong 

range within the IAA for a total physical 

disturbance for current and projected disturbance 

of 1,925 acres or less than 0.69% of the crucial 

winter/yearlong range within the IAA (refer to 

Table 4.14). Impacts to elk crucial 

winter/yearlong ranges during the life of these 

projects would be similar to those discussed above 

and could include disturbance and/or displacement 

due to human presence, fugitive dust or noise, 

direct mortality due to collisions with vehicles, 

and loss of habitat by alteration and/or 

fragmentation. Implementation of all appropriate 

seasonal restriction for all federally authorized 

projects would minimize potential impacts to elk 

in crucial winter ranges. Teton and other 

companies would comply with seasonal 

restrictions and would not conduct any projectrelated activities within elk crucial winter/yearlong 

range from November 15 to April 30. However, 

Teton and the other companies may request an 

exception from the seasonal restriction stipulation 

from the BLM or the landowner, who would 

evaluate the request on a case-by-case basis. This 

seasonal mitigation measure would minimize 

impacts to elk on the crucial/yearlong ranges 

located within the various projects during the 

construction periods. The Proposed Action and 

RFFAs would add 29 acres of disturbance (less 

than 0.01% of the crucial winter/yearlong range in 

the IAA), and this represents a small percentage of 

direct disturbances. However, indirect disturbance 

(due to human presence, noise, dust, etc.) and 

habitat fragmentation would likely increase and 

could result in some reduction in use and/or 

displacement. The Proposed Action would not 

result in any disturbance to elk parturition areas. 

Therefore, the Proposed Action would not result in 

any cumulative impacts to elk parturition areas. 

4.12.5.2 Bats 

For bats, habitat disturbance associated with the 

existing Proposed Action and RFFAs is expected 

to result in 7.83% disturbance of the IAA. The 

Proposed Action would be expected to primarily 

affect migratory bats during the fall; however, 

studies indicate that the population of migratory 

bats is generally limited. In addition, the WMWE 

project area does not contain topographic features 

likely to funnel migrating bats, and the project 

area lacks large tracts of forest cover, unlike highmortality sites in the eastern U.S. Assuming all 

design features are implemented for the Proposed 

Action and all BLM-authorized RFFAs, potential 

cumulative impacts to bats would likely be within 

the range of mortalities and impacts documented 

and acknowledged in the Wind Energy PEIS 

(BLM 2005). 

4.12.5.3 Raptors and Other Birds 

For raptors and other birds, current disturbance 

accounts for a total of 29,676 acres (4.28%) of the 

IAA, and disturbance associated with the Proposed 

Action and RFFAs would represent an additional 

1,455 acres (0.21%) of the IAA for a total current 

and projected disturbance of 31,131 acres (4.49%) 

of the IAA for raptors and other birds (refer to 

Table 4.14). Impacts to raptors and other birds 

during the life of these projects would be similar 

to those discussed under the Proposed Action and 

could include habitat loss and fragmentation due 
EA, White Mountain Wind Energy Project 4-71 

to vegetation disturbance, human presence, and 

noise. Additional impacts during the construction 

and decommissioning phases to raptors and other 

birds may be collisions with construction vehicles, 

turbines, meteorological towers, substations, and 

other structures. The primary impact during the 

O&M phase of the Proposed Action and other 

wind energy projects would be avian collisions 

with the operating wind turbines. In addition to 

the Proposed Action, one other wind energy 

project is located within the IAA and it would be 

located north of the WMWE project area. It is 

estimated that there would be approximately 1.5 

avian fatalities per turbine per year for the 

Proposed Action and for the proposed Lonesome 

Bronco wind energy project. Most (possibly 90%) 

of the fatalities would likely be PSBs, and the 

remaining 10% would likely be RLBs. 

Raptors could be impacted as a result of 

construction-related disturbance during the nesting 

season. The BLM has established seasonal and no 

surface occupancy restriction areas that Teton 

would comply with according to BLM policy 

(BLM 1997). Additionally, Teton has committed 

to adopting a 50-m (164-ft) minimum setback 

from the ridgeline of White Mountain and the edge 

of large drainages to further reduce impacts to 

avian species. Table 2.9 lists the seasonal 

restriction areas, as well as the no surface 

occupancy buffers, and Teton and all other BLMauthorized RFFAs would not place any wind 

turbines or other disturbances within these no 

surface occupancy buffer areas. In addition, to 

reduce the risk of electrocution, all electrical 

systems and components would be designed, 

constructed, operated, and maintained in 

conformance with the National Electrical Safety 

Code and other applicable codes and standards, as 

well as Suggested Practices for Raptor Protection 

on Power Lines: The State of the Art in 2006 

(Avian Power Line Interaction Committee 2006). 

In addition, the removal of natural vegetation 

(grassland and shrub communities) would be 

minimized to the extent possible during 

construction. The movement of construction 

personnel and equipment on-site would be limited 

to the extent possible to the construction areas to 

avoid inadvertent impacts to all wildlife species. 

Therefore, potential cumulative impacts to avian 

species would be within the range of mortalities 

and impacts acknowledged and documented in the 

Wind Energy PEIS (BLM 2005). 

4.13 ENVIRONMENTAL PROTECTION 

MEASURES 

The environmental protection measures for the 

Proposed Action are presented in Section 2.5 of 

this EA as design features. 
EA, White Mountain Wind Energy Project 5-1 

5.0 CONSULTATION AND COORDINATION
 

5.1 INTRODUCTION 

A Notice of Scoping for the EA for the WMWE 

Project, Sweetwater County, Wyoming, was 

issued on November 20, 2008, to more than 200 

government offices and government officials, 

public land users and user groups, newspapers, 

radio stations, and television stations for a 30-day 

public comment period (Appendix A). Forty 

comment letters were received, including letters 

from the WDEQ, WGFD, USFWS, National 

Wildlife Federation, Biodiversity Conservation 

Alliance, Wyoming Outdoor Council, Department 

of Agriculture, PacifiCorp, Wyoming Department 

of Transportation, the RSGA, the Sierra Club, 

Sweetwater County Board of County 

Commissioners, Sweetwater County Land Use 

Department, Historic Trail Corps, the Rock 

Springs Airport, and local broadcasting station and 

communication companies. 

5.2 LIST OF AGENCIES, 

ORGANIZATIONS, AND INDIVIDUALS 

CONTACTED 

Table 5.1 lists the agencies, organizations, and 

individuals contacted during preparation of this 

EA. 

5.3 LIST OF PREPARERS 

Table 5.2 lists the names of people who prepared 

this EA. 

Table 5.1 Record of Persons, Groups, and Governmental Agencies Contacted or Provided 

Comments.1 

Company/Agency Individual Discipline/Position

 Richard Beckwith Citizen 

 John Bookless Citizen 

 H. Caller Citizen

 Daniel Calvey Citizen 

 Dennis Carlson Citizen

 Mike Cheney Citizen 

 Lynn Clark Citizen 

 Carl Demshar Citizen 

 Joe Drnas Citizen 

 Albert Ellis Citizen

 Michael Fletcher Citizen 

 Ray Gordon Citizen

 James Graham Citizen 

 Ted Hainworth Citizen

 Dorothy Harton Citizen 

 Michael J. Herzing Citizen 

 Richard H. Honaker Citizen 

 Debra Izatt Citizen 

 Nelle Johnson Citizen 
5-2 EA, White Mountain Wind Energy Project 

Table 5.1 (Continued) 

Company/Agency Individual Discipline/Position

 Lynn Kinter Citizen 

Fred & Fern Linton Citizen 

 Joe Lustik Citizen

 Drew Mather Citizen

 Craig Nelson Citizen

 Ken Nosich Citizen

 Doug Obrocto Citizen

 Chris Plant Citizen 

Natalie & Dylan Powell Citizen

 Angelina Pryich Citizen 

Leslie M. Ranta Citizen

 Susan Ruff Citizen

 Bill Taliaferro Citizen 

Russel L. Tanner Citizen

 Craig Thompson Citizen 

 Glennise Wendorf Citizen 

 Haman Wise Citizen

 Hollis Wold Citizen 

Alliance for Historic Wyoming Barbara Dobos 

American Lands Alliance Mark Salvo 

American Wind Energy Association Jaime Steve 

Anadarko E&P LP Patrick Navratil 

Anadarko E&P LP Steve Ruhl 

Anadarko Petroleum Corporation Tom Clayson 

Anadarko Petroleum Corporation Cathy Flansburg 

Anadarko Petroleum Corporation Richard T. Robitaille 

Animal Protection Institute of America 

Arapaho Wind River Traditional Elders Mr. Bobby Joe Goggles 

Barlow & Haun, Inc. 

Biodiversity Conservation Alliance Jeff Kessler 

Bjork Lindley Little P.C. Laura Lindley 

Buys & Associates Inc. Lindsey S. Hockert 

BWAB 

Casper Star-Tribune Jeff Gearino 

City of Rock Springs Tim Kaumo Mayor 

Richard Beckwith City Attorney 

Defenders of Wildlife 
EA, White Mountain Wind Energy Project 5-3 

Table 5.1 (Continued) 

Company/Agency Individual Discipline/Position 

District 1 Schools Superintendent 

District 2 Schools Superintendent 

Earth Justice Legal Defense Fund Research Associate 

Eastern Shoshone Tribe Richard Ferris Tribal Cultural Consultant 

Edge Environmental 

Environmental Defense Fund 

Exxon Company U.S.A. Fernando Blackgoat 

Fed Energy Regulatory Commission 

Fed Energy Regulatory Commission Mike Boyle 

Fed Energy Regulatory Commission L. J. Sauter, Jr. 

Friends of the Red Desert 

General Chemical Co 

Grassroots Advocate 

Greater Yellowstone Coalition Melissa Frost 

Greater Yellowstone Coalition Scott Groene 

Heitzmann Drill Site Services Bob Anderson 

Indep Petroleum Assn of Mtn States Marc Smith 

Infinity Oil and Gas Of Wyoming John Long 

J.A. Rohn Consulting Jennifer Head 

Jackson Hole Conservation Alliance Pam Lichtman 

JFC Joe Manatos 

Julian Land & Livestock Truman Julian 

Land and Water Fund for the Rockies Melinda Harm Benson 

Land Management Services Earl Layser 

Library-Colorado State University Judy Smith 

Library-Rock Springs E. Gamble 

Library-Sweetwater County 

Library-University of Wyoming Tamsen Hert 

Library-White Mountain 

Library-Western Wyoming Community Hay Library 

College 

Mayor of Green River 

Mayor of Rock Springs 

Medicine Butte Wildlife Assn. 

Mormon Trails Association President 

MPEC Inc. Jon Kennedy 

MPEC Inc. Justin Strub 

National Pony Express Association 
5-4 EA, White Mountain Wind Energy Project 

Table 5.1 (Continued) 

Company/Agency 

National Wildlife Federation 

Individual Discipline/Position 

Natural Resources Defense Council Johanna H. Wald 

Natural Resources Defense Council Andrew Willis 

Northern Arapaho Tribe 

Northern Ute Tribes 

Northwestern University 

OCI Wyoming L.P. 

OCTA - Oregon-California Trails 

Association 

James Chase 

Betsy Chapoose 

H Paul Friesema 

Preservation Officer 

Tribal Archaeologist 

Tribal Cultural Specialist 

OCTA - Oregon-California Trails 

Association Wyoming Chapter 

OCTA - Oregon-California Trails 

Association Wyoming Chapter 

People for the USA 

People for Wyoming 

Petroleum Association of Wyoming 

Petroleum Information Corporation 

Powder River Basin Resource 

Frank “Pinky” Ellis 

Don Hartley 

c/o Randy Shipman 

Executive Director 

Bruce Hinchey, President 

Bob Knowles 

Council 

Predator Project 

Public Lands Advocacy 

Public Lands Advocacy 

Questar Gas Management Corporation 

Questar Gas Management Corporation 

Rock Springs Grazing Association 

Rocky Mountain Elk Foundation 

Rocky Mountain Power 

Roscoe Culvert 

Safari Club International 

Claire M. Moseley 

George Lea 

Dennis Hughes 

Rights-of-way Services 

Andy Seiller 

Executive Director 

SAIC 

Sierra Club Patricia Dowd 

Sierra Club Northern Plains 

Sierra Club Wyoming Chapter 

Sinclair Oil Corporation 

Shoshone-Bannock Tribe 

Page McNeill 

Southwest Wyoming Mule Deer 

Foundation 

Les Greene 

Southwest Wyoming 

State of Wyoming 

Industrial Association (SWIA) 

Oil and Gas Conservation 

Commission 
EA, White Mountain Wind Energy Project 5-5 

Table 5.1 (Continued) 

Company/Agency Individual Discipline/Position 

State of Wyoming WGFD, Environmental 

Coordinator 

State of Wyoming DEQ 

State of Wyoming DEQ – Air Quality 

Division 

Darla Potter 

State of Wyoming DEQ – Industrial Siting 

Division 

Tom Schroeder 

State of Wyoming DEQ – Land Quality 

Division 

State of Wyoming DEQ – Water Quality 

Division 

State Representative (District 17) Bernadine Craft 

State Representative (District 18) Allen Jaggi 

State Representative (District 20) Kathy Davison 

State Representative (District 23) Keith Gingery 

State Representative (District 33) Patrick Goggles 

State Representative (District 34) Frank Philip 

State Representative (District 39) Stan Blake 

State Representative (District 48) Joe Barbuto 

State Representative (District 60) Bill Thompson 

State Senator (District 12) Marty Martin 

State Senator (District 13) John Hastert 

State Senator (District 14) Stan Cooper 

SWEDA 

Sweetwater County Historical Society 

Sweetwater County Land Use Department 

Sweetwater County Museum Ruth Lauritsen 

Sweetwater Conservation District Mary Thoman 

Sweetwater County Commission Debby Dellai-Boise 

Sweetwater Commissioner Paula Wonacott 

Sweetwater County Planning and Zoning Mark Kot Planner 

John Radosevich Engineering and Planning 

 Steve Horton Planner 

Sweetwater County Weed and Pest Control Gale Lamb Supervisor 

U.S. Fish and Wildlife Service, 

Wyoming Office 

Brian Kelly 

Kathleen Erwin 

Pat Deibert 

Field Officer Supervisor 

Staff Biologist 

Staff Biologist 

Wyoming Department of Agriculture Chris Wichman 
5-6 

1 

EA, White Mountain Wind Energy Project 

Table 5.1 (Continued) 

Company/Agency Individual Discipline/Position 

Wyoming Department of Parks and Mary Hopkins State Historic Preservation 

Cultural Resources Office 

Wyoming Department of Environmental Mark Conrad Water Quality Division 

Quality Todd Parfitt Industrial Siting Council 

Wyoming Game and Fish Department Mary Flanderka Habitat Protection Supervisor 

State Office, Cheyenne 

Wyoming Governor’s Office Steve Furtney 

Wind Energy Temple Stevenson 

Wyoming Natural Diversity Database Staff 

Additional individuals, groups, and agencies were contacted during scoping. 

Table 5.2 List of EA Preparers. 

Agency/Company Discipline/Position 

BLM Interdisciplinary Team, RSFO 

Teri Deakins Project Lead 

Lance Porter Field Manager 

John MacDonald Assistant Field Manager, Lands and Minerals 

Bernie Weynand Assistant Field Manager, Resources 

Jim Glennon Vegetation 

Nicholas Kaczor Wildlife Resources, TEPC species, and BLM-sensitive species 

Jo Foster Visual Resources, Recreation 

Dennis Doncaster Water Resources 

Patricia Hamilton Realty Specialist 

Penny Daniels Cultural Resources 

Colleen Sievers Cultural Resources 

Cherette Mastny Range 

Jay D’Ewart Wild Horses 

Dale Hanson Geology and Paleontology 

Angelina Pryich Editor 

John Henderson Fisheries - water depletions 

BLM Wyoming State Reviewers 

Teresa Ingles Project Manager - Renewable Energy Coordination Office 

Melissa Hovey Air Quality Specialist 

Ken Peacock Planning Environmental Coordinator 

Janet Kurman Environmental Protection Specialist 
EA, White Mountain Wind Energy Project 5-7 

Table 5.2 (Continued) 

Agency/Company Discipline/Position 

Other Contributors 

Teton Wind, LLC Gary Tassainer

 Jesse Tassainer 

 Rick Frandsen 

Lloyd Levy Consulting, LLC Lloyd Levy 

Uinta Paleontological Associates, Inc. Kellie Trujillo 

 Peter Robinson 

TRC Environmental Corporation 

Scott Kamber Project Manager, EA Preparation 

Jan Hart EA Preparation--Vegetation, Soils, Species, and 

BLM-sensitive Species, Rangeland, and Wild Horses 

Diane Thomas EA Preparation--Wildlife, Socioeconomic, Avian Surveys, and 

Raptor Surveys 

James Lowe EA Preparation--Cultural and Historic Resources 

Nathan Fleming EA Preparation--Cultural Resources 

Chase Hahn EA Preparation--Air Quality 

Ryan Johnson Diurnal and Nocturnal Avian Surveys 

Waylon Hiler Diurnal and Nocturnal Avian Surveys 

Judy Bartos GIS, Photosimulation 

Randall Blake GIS, Photosimulation, Greater Sage-grouse Surveys 

Mindy Uitterdyk GIS 

Betty Wills AutoCad and GIS 

Genial DeCastro Document Production 

Rena Merritt Document Production 

Jessica Robinson Technical Editor and Document Production 

Tamara Linse Technical Editor 
EA, White Mountain Wind Energy Project 6-1 

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persistence of greater sage-grouse 

(Centrocercus urophasianus) in Alberta, 

Canada. Doctoral dissertation, University of 

Alberta, Edmonton, Alberta, Canada. 

Aldridge C.L. and M.S. Boyce. 2007. Linking 

occurrence and fitness to persistence; habitatbased approach for endangered greater sagegrouse. Ecological Applications 17(2):508­

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American Wind Energy Association. 1995. 

Avian interactions with wind facilities: A 

summary. Prepared by Colson & Associates 

for American Wind Energy Association, 

Washington, D.C. 

Arnett, E., M. Schirmacher, M. Huso, and J. 

Hayes. 2009. Effectiveness of changing wind 

turbine cut-in speed to reduce bat fatalities at 

wind facilities: 2008 annual report. 

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fatalities at wind energy facilities in North 

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72(1):61-78. 

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Larkin, S. Manes, A.M. Manville, J.R. 

Thresher. 2007. Impacts of wind energy 

facilities on wildlife and wildlife habitat. 

Wildlife Society Technical Review 07-2. The 

Wildlife Society, Bethesda, Maryland. 

Avian Power Line Interaction Committee. 2006. 

Suggested practices for raptor protection on 

power lines: The state of the art in 1996. 

Edison Electric Institute and the Raptor 

Research Foundation, Washington, D.C. 

Baerwald, E. 2006. Bat fatalities in Southern 

Alberta. Presented at the Wildlife Research 

Meeting VI, San Antonio, Texas. National 

Wind Coordinating Collaborative. November 

2006. 

Baldwin, P.H. 1971. Diet of the mountain plover 

at the Pawnee National Grassland, 1970­

1971. U.S. IBP Grassland Biome Program 

Report 134. Colorado State University, Fort 

Collins, Colorado. 34 pp. 

Bat Conservation International, Inc. 2002. Bat 

species: U.S. bats. Bat Conservation 

International, Inc., Austin, Texas. 

<www.batcon.org>. Accessed November 18, 

2008. 

Beason, R.C. 1995. Horned lark (Eremophila 

alpestris). In The birds of North America, 

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Academy of Natural Sciences, Philadelphia, 

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