## DOE/EA-1516



# FINAL Environmental Assessment
for the Proposed Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project, Carbon County, Wyoming January 2005

U.S. Dep a rtment of En ergy/National Renewabl e Energy Laboratory 1617 Cole Boulevard Golden, Col o rad oFINAL ENVIRONMENTAL ASSES S MENT FOR THE

PROPOSED CLIPP E R WINDPOWER, INC. LOW WIND SPE E D TURBI N E DEMONSTRATION PROJECT, CARBON COUNTY, WYOMING

Prepared for U.S. Department of Energy National Renew a ble Energy Laboratory Golden, Colorado

By TRC Mariah Associates Inc. Laramie, Wyoming MAI Project 44136
January 2005Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project i

EXECUTI V E SUMMARY Clipper W i ndpower, Inc. (Clipper), in partnershi p with the U.S. Departm e nt of Ene r gy (DOE) and the National Renewable Research Laborato ry (NREL), has devel oped a proprietary low wind speed turbine design that is capable of producing more electricity in low wind speed conditions than comp arable wind turbines. Th e Clipper turbine would have a m a ximum output of 2.5 me gawatts of electrical power and has undergone num e rous tests, including dynam o meter testing at the National W i nd Technology Center (N WT C) for at least 6 m onths. At this point, Clipper needs to test the prototype wind turbin e under field conditions before the design can be put into full production. In or der to test the low wind speed turbine, Clipper proposes to construct/install and operate the low wind speedturbine demonstration project on privately owned land near Medicine Bow, Wyoming.
The proposed project would be located approximately 5 mi s outhwest of the community of Medicine B o w, Wy om i ng, in eastern Carbon County. Acc e ss to the site is south from Medicine Bow, Wyoming, via the Elk Mountain to Medicine Bow Road (an unpaved public road). The proposed project would be located in Section 1, T21N, R79W. In additi on, the proposed project would be located approximately 850 ft south of a s m all existing wind far m that consists of 10 existing wind turbines (i.e., the Medicine Bow W i nd Project). This small wind farm is owne d and operated by the Platte River Power Authority (PRPA). However, the proposed project would not be part of PRPA’s Medicine Bow W i nd Farm but would be locatednear that facility so that it could utilize as mu ch of the existin g infrastructure (i.e., roads and powerlines) as possible. By co-locating the pro j ect area the Medicine Bow W i nd Far m , Clipper would mi nim i ze addition a l disturbance and associa t ed impacts.
The Proposed Action would include the construction/installation of a single wind turbine, a single m e teorological tower, a small service building, and buried powe rlines and cables and would result in less than 10 acres of new short- and long-term disturbance. Clipper anticipates that the equipment would last approximately 20 years, after which time the wind tur b ine would be decommi ssioned and all the equipment rem o ved. The Proposed Action would com p ly with all relev a nt f e deral, stat e, and local laws and regulations.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project ii

To mi ni mi ze potential environmental impacts associated with the Proposed Action, Clipper would undertake vario u s applicant-committed m easures including seasonal restrictions o n operations in crucial winter range for pronghorn and restrictions in the spri ng for operations near greater sage-grouse leks. C lipper would also imple m ent st orm water pollution prevention

m easures to mi ni mi ze impacts to ve getation, soils , and surface water resources. C lipper would also monitor potential impacts to avian and bat species by conducting mortality surveys near the wind turbine and m e teorological tower during the first 12 months of operation of the Proposed Action and would paint the small service building a dese rt tan to blend in to its surroundings. Once construction operations have been com p leted and after the site have been decommissioned, Clipper would imple m ent prompt revegetation operations and return the area to disturbance conditions. Detailed infor m ati on concerning all applicant-committed practices is p r esented in Chapter 2 of this Environmental Ass e ssment (EA).
This EA analyzes the potential environmental impacts of the DOEdecision to fund the Proposed Action. In accordance with applicable regulations and policies, the DOE conducted internal and external scoping of the Proposed Action. This process determined the scope and the specific critical elements of the h uma n environment to be addressed in this EA. Fe deral, state, and local governm e nt agencies were also contacted to identify potential issues and concerns.
In addition to the Proposed Action , the EA a lso analyzes the No Action Alternative in d e tail. Other alternative s were evaluated p rior to s c opi ng by Clipp e r; they eith er would not meet the needs of Clipper or would obviously result in mo re disturbance and environmental impacts than the Proposed Action. Th ese alternatives are discusse d in the EA but were not analyzed in detail.
Based on public scoping, internal DOE review of the Proposed Action, and additional existing information concerning the proposed project ar ea, DOE has determined that this EA would analyze the potential impacts of the Proposed Action and No Action Alternative on surface water resources (including wetlands); wi ldlife; veg e tation; soils; thr eatened, endangered, proposed, and candidate s p ecies; cultural resou r ces; noise; and visual resources. Num e rous otherFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project iii

environmental resources were determined not t o be affected by the project or were not present within the general project area and are not discussed in detail in this EA.
The project site is located immediately adjace nt to the exiting Medicine Bow Wind Far m , and this area has been utilized for wind development since the 1980s. With C lipper’s commitm e nt to imple m ent storm water pollution prevention meas ures and to promptly conduct reclamation operations, it was determined that the Proposed Action would have neglig ible short- and longterm impacts on soils, v e getation, and surface wate r resources (in c luding wetlands). The project area was also surveyed for cultural resources and none were identified; the Proposed Action would have no impacts on historic or prehisto ric sites. D O E/NREL has also notified Native American tribes in accordance with federal polic y. To date, no sites or areas of tradition al cultural importanc e hav e been identif i ed withinor near the project ar ea. The Proposed Action would also have negligible impacts on noise an d visual resources. The Proposed Action would not adversely affect any threatened, endangered, proposed, or candidate species that m a y occur or traverse through the project area. The Pro posed Action (specifically the presence of the

me teorological tower and operation of the wind turb ine) would like l y result in the mortality of 6.7 bats per year, 0.15 raptors per year and, 15.4 passerine birds per year. However, these mortalities would not have an adverse impact on bat, raptor, or passerine bird populations. Clipper would monitor mortalities around the me teorological tower and wind turbine for a 12- month period and would report the results to U. S. Fish and Wildlife Service, DOE/NREL, and Wyoming Gam e and Fish Departm e nt. The Propos ed Action would have negligible impacts on other species that m a y o ccur in the p r oject area.
The Proposed Action would result in less than 10 acres of disturbance (8.45 acres of temporary disturbance and 1.25 acres of life -of-project disturbanc e) but would likely cause negligible

cumu lative impacts because of the limited amount of area that would be affected and the location of the project near the ex isting Medicine Bow W i nd Farm

.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project iv

TABLE OF CONTENTS Page 1.0 INTRODUCTION .................................................................................................................. 1 1.1 BACKGROUND ........................................................................................................ 1 1.2 PURPOSE AND NEED.............................................................................................. 5 1.3 ENVIRONMENTAL REVIEW PROCESS............................................................... 6 1.3.1 National Environ m ental Polic y Act and this NEPA Docum e nt................... 6 1.3.2 Scoping and Public Involvem e nt ................................................................. 7 2.0 PROPOSED ACTION AND ALTERNATIVES ................................................................... 9 2.1 PROPOSED ACTION................................................................................................ 9 2.1.1 Overview...................................................................................................... 9 2.1.2 Construction and Installation P h ase.............................................................12 2.1.3 Operations Phase..........................................................................................17 2.1.4 Decommissioning Phase ..............................................................................18 2.1.5 Applicant-committed Practices....................................................................19 2.1.5.1 Air Quality ....................................................................................19 2.1.5.2 Soils and Vegetation .....................................................................19 2.1.5.3 W ildlife (Including Sp ecial Status Species) .................................20 2.1.5.4 Noise .............................................................................................22 2.1.5.5 Cultural Resources........................................................................22 2.1.5.6 Health and Safety..........................................................................23 2.1.5.7 Aesthetics......................................................................................23 2.2 NO ACTION ALTERNATIVE..................................................................................23 2.3 ALTERNATIVES CONSI D ERED BU T ELIMINATED FROM DETAILED STUDY ..................................................................................................................24 2.3.1 Locate the Proposed Project at a Site in Southern California......................24 2.3.2 Locate the Proposed Project at a Site in Jackson County, Minnesota .........25 2.3.3 Locate the P r oposed Project at a S ite 0.5 mi South of the Proposed Project Location.........................................................................................25 3.0 AFFECTED ENVIRONMENT..............................................................................................27 3.1 LOCATION, SETTING, AND HISTORICAL USE .................................................27 3.2 AFFECTED RESOURCES ........................................................................................29 3.2.1 Cultural Resources (Including Native Am er ican Concerns) .......................29 3.2.2 Noise ............................................................................................................30 3.2.3 Soil Resources..............................................................................................32 3.2.4 Threatened, Endangered, Candidate, and Proposed (TEP&C) Species.......32 3.2.4.1 Introduction...................................................................................32 3.2.4.2 TEP&C Ani m al and Plant Species ...............................................33Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project v
TABLE OF CONTENTS (Continued) Page 3.2.5 Vegetation Resources...................................................................................37 3.2.6 Visual Resources..........................................................................................37 3.2.7 Wa ter Resources (Surface W ate r Including Wetlands) ...............................38 3.2.8 Wildlife ........................................................................................................40 3.2.8.1 Big Game ......................................................................................40 3.2.8.2 Other Mammals ............................................................................43 3.2.8.3 Raptors ..........................................................................................43 3.2.8.4 Upland Game Birds.......................................................................43 3.2.8.5 Other Birds (Including Migratory Birds)......................................45 3.2.8.6 Amphibians, Reptiles, and F i sh ....................................................47 4.0 ENVIRONMENTAL CONSEQUENCES .............................................................................48 4.1 CULTURAL RESOURCES .......................................................................................48 4.1.1 Proposed Action...........................................................................................48 4.1.2 No Action Alternative..................................................................................49 4.1.3 Mitigation and Monitoring...........................................................................50 4.1.4 Residual Impacts..........................................................................................50 4.2 NOISE.........................................................................................................................50 4.2.1 Proposed Action...........................................................................................50 4.2.2 No Action Alternative..................................................................................51 4.2.3 Mitigation and Monitoring...........................................................................51 4.2.4 Residual Impacts..........................................................................................51 4.3 SOIL RESOURCES....................................................................................................52 4.3.1 Proposed Action...........................................................................................52 4.3.2 No Action Alternative..................................................................................52 4.3.3 Mitigation and Monitoring...........................................................................53 4.3.4 Residual Impacts..........................................................................................53 4.4 THREATENED, ENDANGERED, PROPOSED, AND CANDIDAT E (TEP&C) SPECIES ...............................................................................................53 4.4.1 Proposed Action...........................................................................................53 4.4.1.1 Black-footed Ferrets......................................................................53 4.4.1.2 Bald Eagle.....................................................................................53 4.4.1.3 Summary.......................................................................................54 4.4.2 No Action Alternative..................................................................................54 4.4.3 Mitigation and Monitoring...........................................................................54 4.4.4 Residual Impacts..........................................................................................54 4.5 VEGETATION RESOURCES...................................................................................55 4.5.1 Proposed Action...........................................................................................55 4.5.2 No Action Alternative..................................................................................55 4.5.3 Mitigation and Monitoring...........................................................................55 4.5.4 Residual Impacts..........................................................................................56Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project vi

TABLE OF CONTENTS (Continued) Page
4.6 VISUAL RESOURCES..............................................................................................56 4.6.1 Proposed Action...........................................................................................56 4.6.2 No Action Alternative..................................................................................57 4.6.3 Mitigation and Monitoring...........................................................................57 4.6.4 Residual Impacts..........................................................................................57 4.7 WA TER RESOURCES (SURFACE WATER INCLUDING WETLANDS) ...........58 4.7.1 Proposed Action...........................................................................................58 4.7.2 No Action Alternative..................................................................................59 4.7.3 Mitigation and Monitoring...........................................................................59 4.7.4 Residual Impacts..........................................................................................59 4.8 WILDLIFE.................................................................................................................. 59 4.8.1 Proposed Action...........................................................................................59 4.8.1.1 Big Game ......................................................................................60 4.8.1.2 Other Mammals ............................................................................63 4.8.1.3 Raptors ..........................................................................................65 4.8.1.4 Upland Game Birds.......................................................................68 4.8.1.5 Other Birds (Including Migratory Birds)......................................70 4.8.1.6 Amphibians, Reptiles, and F i sh ....................................................73 4.8.1.7 Summary.......................................................................................73 4.8.2 No Action Alternative..................................................................................74 4.8.3 Mitigation and Monitoring...........................................................................74 4.8.4 Residual Impacts..........................................................................................74 4.9 CUM U LATIVE I M PACTS......................................................................................75 4.10 IRREVERSIBLE AND I RRETRIEVABLE COMMITMENT OF RESOURCES ...........................................................................................................77 4.11 SHORT-TERM USE OF THE E NVIRONMENT VERSUS LONG-TERM PRODUCTIVITY.....................................................................................................78 5.0 RECORD OF PERSONS, GROUPS, AND GOVERNM E NTAL AGENCIES CONTACTED ...................................................................................................................79 6.0 REFERENCES ................................................................................................................ .......80

APPENDIX A : COPIES OF P UBL IC SCOPING LETTERSFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project vii

LIST OF F I GURES Page Figure 1.1 Location of Project Area........................................................................................ 3 Figure 2.1 Layout of Medicine Bow Low Wind Speed Turbine Facilities.............................10 Figure 2.2 Location of Existing Deve lopment near the Project Area .....................................11 Figure 2.3 Low Wind Speed Turbine......................................................................................14 Figure 2.4 Location of Underground Powerline .....................................................................16 Figure 3.1 Location of Projec t and PRPA Wind Turbines......................................................28 Figure 3.2 Surface W ate r Featu r es near the Project Area .......................................................39 Figure 3.3 Pronghorn Antelope Ra nges near the Project Area ...............................................42 Figure 3.4 Raptor Nest Locati ons near the Project Area........................................................44 Figure 3.5 Greater Sage-grouse L e ks near the Proposed Project Area ...................................46 Figure 4.1 Existing and Authorized Projects in th e General Project Area..............................76

LIST OF TABLES Page Table 2.1 Proposed Proj ect New Disturbance .......................................................................12 Table 3.1 Comp arison of Measured Nois e Levels with Commonly Heard Sounds ..............31 Table 3.2 Federal Threatened, Endangere d, Proposed, and Candidate S p ecies and Their Potential Occurrence Withinthe Proposed Project Area, 2002 ...................34 Table 5.1 Record of Persons, Groups, a nd Governm e ntal Agencies Contacted....................79 Table 5.2 List of Preparers.....................................................................................................79Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project viii

LIST OF ABBREVIATIONS AND ACRONYMS

BLM Bureau of Land Management CEQ Council on Environmental Quality C.F.R. Code of Federal Regulations Clipper Clipper W i ndpower, Inc. dBA A-weighted decibels DOE Department of Energy EA Environmental assessment MW Meg awa tt(s) NEPA National Environmenta l Policy Act of 1969 NREL National Renewable Energy Laboratory NRHP National Registerof Historic Places PRPA Platte River Power Authority RCRA Resource Conservation and Recovery Act TEP&C Threatened, Endangered, Proposed, and Candidate Species U.S.C. United States Code USFW S United Sta tes Fish and Wildlife Service WAP A Western Area Power Administration WDEQ/W QD Wyoming Departm e nt of Envir onm en tal Quality/Water Quality Division WGFD Wyoming Gam e and Fish Departm e nt WNDD Wyoming Natural Diversity Database WSHPO Wyoming State His t oric Preservation OfficeFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project

1.0 INTRODUCTION

1.1 BACKGROUND

Wi nd resources in the U.S. are vast. However, less than 1% of the nation's energy needs are currently being provided by renewabl e wind power. As the U.S. looks to find ways to generate more electricity from wind resources, wind develope rs are challenged to improve the efficiency of future wind turbines so that m o re electric ity can be produced economically in low wind speed areas--areas where the average ann u al wind speed is at least 13-14 mph at a height of 33 ft. Currently, most large wind turbines are des ign ed for optimal perfor ma nce in areas where the average wind speed is at least 15 mph at a he ight of 33 ft. However, m a ny large population centers and power grids in the U. S. are located in low-wind s p eed-a reas. If low wind speed areas could be used effectively for large-scale power generation, electric transmission losses and costs would be greatly reduced and the total ar ea available f o r wind project d e velopment in the U.S. would be increased twenty-fol d (National Renewable Energy Laboratory [NREL] 2002). As a result, governm e nt and private re searchers are working to devel op wind turbines that operate

more economi cally at lower wind speeds that can be integrated into m a ny U.S. powe r grids.
The NREL is a national laboratory for the U.S. Departm e nt of Energy (DOE) and is the nation' s premier laboratory for renewable energy research and development. NREL works with the wind energy industry and provides funding for researchand development for state-of-the-art wind turbine designs to advance wi nd power technologies that lowe r the cost of wind energy.
Clipper W i ndpower, Inc. (Clipper) has developed a proprietary low-speed wind turbine design that is capable of producing mo re electricity in low-wind conditions than comp arable wind turbines. The Clipper turbin e would have a m a ximu m outputof 2.5 me gawatts (MW ) of electrical power. Clipp e r has des ign ed and co nstructed a fu ll-sca l e v e rsion of the low-speed wind turbine and has begun the process of obtaini ng international certification for the low-speed wind turbine model. The National W i nd T echnology Center (operated by the NREL) admi nisters the wind turbine certification progr am
. Certification is provided by severalFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 2

international organizations incl uding Underwriters' Laboratories in the U.S. and Germanishe r Lloyd in Europe. Although the wind turbine certification program is not a warranty, the certification provides purch asers of wind turbines assurance th at a particu l ar wind turbine model has been through the following:

• tested and evaluated by an accreditedcertification test o r ganization,

• examined by a regis t ered certificati on ag en t to ensure com p liance with internationally approved standards fo r identif i cation and labeling, power perform a nce, structural integrity, acoustic emissions, loads, power quality, safety, and other characte ristics, and

• demonstrated to have safe operating charac teristics, including control system s that reflect sound engineering practice.

Wi nd turbine model certification is a m a jor step in providing electric service organizations, governm e nt agencies, businesses, and private individuals that plan to purchase a wind installation with assurances that win dturbine m odels have been tested and meet certain design,

ma nufacturing, performance, and safety standard s. The Clipper low wind speed turbine design has undergone num e rous tests, including drive tr ain testing in the National W i nd Test Center dynam o meter. At this point, Clipper needs to test the demonstration wind turbine under natural wind conditions before the design can obtain international certification and can be put into full production. In order to test the low-speed wind tu rbine, Clipper proposes to install/construct and operate the low-speed wind turbine de m onstr ation project on privately owned land near Medicine Bow, Wyomi ng (refer to Figure 1.1). The DOE/NREL, through a cost-shared research and development subcontract, proposes to provid e partial funding for this project throughout the 3-year perform a nce test period.

This environmental assessm e nt (EA) is being prepared under the National Environmental Policy Act of 1969(NEPA), as amended (42 United States Code [U.S.C.] 4321 et seq.), and its imple m enting regulations found in 40 Code of Federal Regulations (C.F.R.) Part 1500–1508, and DOE’s implem e nting regulations contained in 10 C.F.R. 1021.330 et seq. This EA assessesFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 3

This figure is a separ ate file Fig 1-1.pdf.

Figure 1.1 Location of Project Area.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 4

the environmental impacts of the Proposed Action and the No Action Altern ative, and serves to guide the decision-making process.
Seven critical elements (clearing o rexcavatio n [i.e., vegetation and soils ], new or modified fe deral/state permits, th r eatenedand endangered species, arc h aeol ogical/cultural resources, other protected species, noise, and aesthetics) are presen t in the proposed projec t area, m a y be affected by the Proposed Action, and are discussed in detail in this EA. DOE has determined that 29 of the 36 critical elements of the hu ma n environment are not present in the area or are n o t affected by the Proposed Action and are not di scussed further in this E A.
Based on an internal DOE review of the Proposed Action and additional existing infor m ation concerning the proposed project area, DOE has de termined that this EA would also analyz e potential impacts of the Proposed Action and alternatives on surfa ce water resources and wildlife. Air quality, water qua lity (groundwater), livestock gr azing, and wastes (hazardous or solid) were determined to be pres ent in the proposed pro j ect area, but they would no tbe affected by the P r oposed Action and would not be discusse d further in this EA. Other resources (e.g., geology, health and safety, socioeconomics, noxious weeds, water rights, wild horses, landownership, timber, m i neral resources, environm ental justice, wilder ness areas, etc.) have been determined not to be aff ected by the proposed project and are therefore not analyzed in detail in this EA.

Based on the discussio npresented above and in accordance with DOE NEPA regulations an d policies, the fo llowing r e source issues/top i cs will be addressed in this EA: cultural resources , noise, soil resources, threaten, endangered, proposed, and candidate species, vegetation, aesthetic/visual resources, water resources (s urface water including wetlands), and wildlife

resources.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 5

1.2 PURPOSE AND NEED
DOE/NREL’s purpose is to fund the installation/construction and ope ration of a single low-speed wind turbine and associated facilities. The p r oject would collect elec trical production and reliability d a ta from the wind turbine and wind da ta that would be necessary to evaluate the economic and technical feasibility of the demonstr ation wind turbine and it s design. In addition, Clipper would also utilize a ne w design for the concrete pad fo r the wind turb ine and would monitor perform a nce of t h e pad.
This pro j ect is important to DOE/NREL becaus e previous wind turbine des i gn s tud ies indicate that several new design confi gurations offer significant opportunities for reducing costs over current wind turbine configurations. Three m a jo r elements factor into opportunities for reducing the cost of wind energy. First, reduction in th e cost of and improvements in the efficiency of wind turbine components including the drive train; second, increases in energy capture by taking advantage of higher wind speeds due to wind sh ear by placing turbines on innovative tall towers; third, incr ea ses in ene r gy capture by incre asi ng rotor diameter and taking advantage of innovative rotor configurations. These studies haveindicated that several techniques can be used to achieve these results. Many of these techn i ques are interrelated, such as decreasin g drive train weight that m akes use of taller towers m o re cost effective, or introduction of novel rotor designs that decre ase loads and allow larg er rotor d i ameters. Application of emerging controls strategies, coupled with increased instrum e ntation, promises to aid in the cost-effective integration of these

ma jor elements.
Clipper has proposed a new turbine design that attem p ts to take into account all three of these elements. This new turbine design will use a novel gearbox with mu ltiple gener a tors. This ne w design is expected to be significan tly lighte r and less costly and allow use of taller towers to tak e advantage o f wind shear at h i gher altitudes. The proposed Clipper turb ine, if successful, is expected to be a m a jor step toward realizi ng the advantages of lo w wind speed technology.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 6
Many barriers impede the rapid advancement of wind turbine technologies, warranting cooperative development efforts between the fede ral governm e nt and the private sector. As a result, DOE/NREL has imple m ented financial pr ograms that encou r age partnerships with

me mbers of the U.S. wind industry , with the ultimate goal of developing large wind turbin e systems capable of producing el ectricity for 3.0 ¢/kilo watt hour in Class 4 wind areas by 2007. A portion of the cost of Clipper’s current low wi nd speed turbine demonstration project is being provided through one of DOE/NRE L’s partnership programs. In October 2002, Clipper won (through competitive b i dding pro c ess) app r oxim a te ly $13 million for the partial funding of the development of new low wind sp eed turbine technologies being tested and evaluated under the Proposed Action.

1.3 ENVIRONMENTAL REVIEW PROCESS

1.3.1 National Environmental Policy Act and this NEPA Document
The DOE is the federal lead agency for eval uating the project under NEPA, and the DOE must determine whether to provide funding for the pr oposed project. As required by NEP A , this EA examines the expected individual and cumu lative impacts of the proposed project. The DOE is the only federal agency with responsibility fo r approving or denying the partial funding for the project and therefore is the lead agency in preparing this EA.

The DOE/N REL prepared this EA to provide the public and responsible agencies with information about the project and its potential effects on the local and regiona l environment. This EA was prepared in compliance with NEPA requirem e nts.
NEPA, as amended (42 U.S.C. 4321 et seq.), th e President’s Council on Environmental Quality (CEQ) regulations for implem e nting the procedural provision of NEPA (40 C.F.R. 1500-1508), and DOE’s imple m enting procedures for comp lian ce with NEPA (10 C.F.R. 1021) require that DOE, as a federal agency :
• assess the environmental imp acts of any Proposed Action,Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 7

• identify any adverse environmental eff ects that cannot be avoided, should the Proposed Action be implemented,

• evaluate alternatives to the Proposed Action, including a No Action Alternative,

• describ e th e relation s hip between the local sho r t-term use of the env i ron m ent and the m a intenance and enhancement of long-term productivity, and

• characterize any irreversible and irretr ievable commit me nts of resources that would be involved should the Proposed Action be imple m ented. These provisions mu st be addressed before the final decision is m a de to proceed with any proposed federal action that has the potential to cause impacts to the human environment, including providing federal funding to a project. This EA evalua ted the potential individual and

cumu lative effects of the Proposed Action and th e No Action Alternative on the physical, human, and natural environment. The EA is intended to (1) meet DOE’s regulatory requirements under NEPA and (2) provid e DOE with the inf o rmati on needed to m ake an informed decision i n connection with the proposed project.
Existing NEPA docum en ts that m a y be related to the proposed project include the following:

• EA, wind energy, W y oming (Bur eau of Reclamation 1979),

• environmental survey report, wind en ergy project, Medicine Bow, Wyoming (Platte River Power Authority 2000),

• environmental impact statement for the Carbon Basin coal project (Bureau of Land Managem e nt [BLM] 1999), and

• environmental impact statement for th e Kenetech/PacifiCorp windpower project (BLM 1995).
1.3.2 Scoping and Public Involvement
A public scoping notice was m a iled to approximat ely 52 federal, state, and local governm e nt agencies, companies, individuals, and organi zations, giving them until Nove mb er 10, 2004 (14 days), to submit comments. Five comment lett ers were received by th e DOE. All five lettersFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 8

were from governm e nt agencies--none were fr om private corporations or non-governm e nt organizations. Copies of the public scoping letters are presented in Appendix A.
Issues raised by government organizations and the public include the following:

• potential impacts to threatened, enda ngered, proposed, and candidate (TEP&C) species (e.g., black-footed ferret, ba ld eagle, Ute ladie s ’-tre sse s);

• potential impacts to raptors, m i gratory bi rds, greater sage-grouse, crucial winter range for pronghorn antelope, white-tailed prairie dogs, other m a mmals, and wetlands ;
• alternatives to the Proposed Action and cumu lative impacts;

• livestock grazing on state and federal leases;

• construction procedures; and

• reclamation and stabilization procedu r es.
This EA presents DOE/NREL’s analysis of th e Proposed Action and N o Action Alternative and findings of the potential environmental effect s of the Proposed Action. The EA is being distributed for public review to interested m e mbers of the publ ic, Tribal organizations, and federal, s t ate, and local agencies, and for review and comment prior to any final decision by DOE on the proposed project.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 9

2.0 PROPOSED ACT I ON AND ALT E RNATIVES

2.1 PROPOSED ACTION

2.1.1 Overview
The Proposed Action would be located on privatel y owned lands in portions of Section 1, T21N, R79W, and Section 36, T22N, R79W(refer to Figure 1.1) and woul d involve the construction of a single 262-ft tall tubular tower and wind turbine, a 240-ft tall m e teorological tower, a 400-ft 2 service building, and approxim a tely 4,300 ft of underground powerline (refer to Figure 2.1). Associated cables and powerlines would be burie d between the proposed m e teorological tower, the wind turbine, and the servic e building. In addition, approxi ma tely 1,000 ft of 10-ft wide service road would be constructe d to provide access to the facilit ies (refer to Figure 2.1).
The proposed project would be located approxim a tely 850 ft south of seven existing wind turbines (i.e., the Medicine Bow W i nd Project) owned and operated by th e Platte River Power Authority (PRPA). The proposed project would not be part of PRPA’ s Medicine Bow W i nd Project but would be located near that facility so that it could utilize as mu ch of t h e existing infrastructure (i.e., roads and powerlines) as possible. This would mi nimi ze additional disturb a nce and associated impacts. The Propos ed Action would likely result in less tha n 10 acres of new disturbance (refer to Table 2.1).

Access to the site would be south from Medi cine Bow, Wyoming, vi a the Elk Mountain to Medicine B o w road (an unpaved cou n ty road) to a series of unpaved private access roads located near the existing Medicine Bow Wi nd Project (refer to Figure 2.2).
Clipper anticipates that the equ i pm en t would last approxim a tely 20 years, after which tim e the wind turbine would be decommissioned and all the equipment removed. The Proposed Action would comp ly with all relevant federal, state, and local laws and regulations.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 10

This figure is a separ ate file Fig 2-1.pdf.

Figure 2.1 Layout of Medicine Bow Low W i nd Speed Turbine Facilities.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 11

This figure is a separ ate file Fig 2-2.pdf.

Figure 2.2 Location of Existing Deve lopment near the Project Area.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 12

Table 2.1 Proposed Project New Disturbance 1

. Temporary Life-of-Project Total Component Disturbance Disturbance Disturbance Access road 1.00 0.50 1.50 Wi nd turbine 3.75 0.25 4.00 Meteorological tower and service building 3.50 0.50 4.00 Underground powerline 0.20 0.00 0.20 Total 8.45 1.25 9.70

In acres.
2.1.2 Construction and Installation Phase

The construction and installati on phase of the Proposed Action would begin as soon as all required authorizations are obtaine d from DOE and any related state or local regulatory agencies

. Locations of the various components (e.g., roads, wind turbine, m e teorological tower, service building, buried cables) would be surveyed an d staked. The existin g access road from the southern portion of Section 36, T22N, R79W, would be extended approxim a tely 200 ft to the proposed wind turbine site and woul d provide access to the wind turbin e. An additional 800 ft of access road would be constructed between the m e teorological tower and the service building (refer to Fig u re 2.1). Th e proposed access road would be approxim a tely 10 ft wide and woul d likely result in 0.5 acre of life-of -project disturbance. There w ould also be an additional 1.0 acre of temporary disturb a nce created by the construc tion of the access rou t e. The road would be surfaced with locally available gravel or crushed stone to provide year-round access to the project site.

The wind turbine would be anchor-bolted to a concrete foundation consisting of an octagonshaped pad that would have a diameter of 53 ft and approxim a tely 4 f tthick. The turbin e erection site would likely require approximately 0.25 acre of life-of- project disturbance. The pad would be excavated with a backhoe, and the excess m a terial would be transported off-site for disposal. Th e concrete for m s would be placed into the excavation, and concrete poured. The 1Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 13

262-ft tall turbine tower would be transported in pieces and assem b le d on-site. The turbine tower, turbine nacelle, and 148-ft long blades w ould be painted white and would m a tch the colo r of the existing wind turbines. A large crane would be transported to th e site and use dto erect th e tower and to lift the turbine, hub, and rotor blad es into place. The self-supporting tower would not require any guy wires or othe r support system (refer to Figur e 2.3). There would be an additional 3.75 acres of temporary disturbance created by construction/installation of the wind turbine.

The 240-ft tall m e teorological tower (withthree sets of guy wires) and 400-ft 2 service building would be transported to the site and ere c ted and would comply with m a nufacture rins ta llatio n recommendations. The m e teorological tower is a stand ard lattice-de s ign and would be placed on a small concrete pad and supported with guy wires. The 400-ft 2 service building would be a 10-ft tall metal building that would be placed on a concrete slab (refer to Figure 2.1). The service building would be painte d desert tan color to blend in to the surrounding environment. Electrical p o wer and communicati on service would be available in the service building. Construction of both the meteorological tower and service building woul d likely result in approxim a tely 0.5 acre of life-of-project d i stu r ba nce and an addition a l 3.5 acres of temporary disturbance.

Portable self-contained chemical toilet(s) would be provided for hum a n wa ste disposal during the construction , operations, and decommissioning pha ses of the Proposed Action. Bottled drinkin g water would be provided during the construction and operations phase of the Proposed Action. All solid waste (i.e., trash) and waste m a terial s generated during the construction, operations, and decommissioning phases of the Proposed Action w ould be collected in portable dump sters or trash containers and would be tran sported off-site to an authorizedsolid waste disposal facility. Clipper does not anticipate that any flamm able waste m a terial s or hazardous waste would be generated as a result of the Pr oposed Action; however, Clipper an d its contractors would com p ly with all applicable federal and state laws and regulations governing the handling and disposal of any flammable or hazardous waste. No solid orliquid wastes would be disposed within the project area.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 14

This figure is a separ ate file Fig 2-3.pdf.

Figure 2.3 Low Wind Speed Turbine.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 15

Approxim a tely 4,300 ft of 34.5-kV underground power line would be installe d from the proposed wind turbine to a terminal riser pole owned by the W e stern Area Power Ad mi nistration ( W APA) (refer to F i gure 2.4). Th e termin al riser pole is the connection point to th e power grid and is located approxim a tely 300 ft northeast of th e existing Medicine Bow Wind Project. Approximately 400 ft of buried powerline would be installed between the terminal riser pole and PRPA’s electric substation. This would resu lt in approxim a tely 0.1 acre of temporary disturbance. Approximately 3,700 ft of undergr ound powerline would be buried in the center of the existing access road using conventional trenchi ng techniq u es. This actually would result in no new disturbance. Th e rem a ining 200-ft of underground powerline w ould be buried across undisturbed ground (using the sam e installation technique) and woul d result in a mi nim a l amount of te mporary disturb a nce (less than 0.1 acre)

. Additionally, 1,300 ft of communication and power cables would be buried am ong the m e teorological tower, turbine, and service building along the side of the new access road and would not result in any additional distu rba nce. Under the Proposed Action, no aboveground powerlines or cables would be constructed or installed.
The construction/installation phase of the Proposed Action would require approximately 10-15 people, and typical construction equipmen t (e.g., backhoe, crane, pickup, dum p truck, cable plow, etc.) and would require approxim a tely 2 months to com p lete starting in Dece mb er 2004. Off-road travel w ithin the project area would be li mited to area between the proposed wind turbine, m e teorolo g ical towe r, and service building. To tal di stu rbance associated with the Proposed Action (including off-road travel) would result in less than 10 acres of ne w disturbance.
Clipper would apply to the W y oming Departm e nt of Environmental Quality, W a ter Quality Division (WDEQ/WQD) for per mit coverage for potential storm water pollution (i.e., erosion from construction activities). In addition, Clipper would prep are and implem e nt a storm water pollution prevention plan to prevent distur bed runoff fro m l eavi ng the project site.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 16

This figure is a separ ate file Fig 2-4.pdf.

Figure 2.4 Location of Underground Powerline.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 17

2.1.3 Operations Phase

Once the construction and insta llation phase is comp lete, Cli pper would begin the operations phase of the Proposed Action. During this phase, wind energy would be converted into rotational energy and then into electricity thro ugh the use of generators located in the wind turbine nacelle. The wind turbine would be computer-controlled for m a ximu m perform a nce and for safety when wind speeds exceed design param e ters. Typically, the wind turbine would start spinning at approxim a tely 9 mph (i.e., the “cut- in speed”), and the typical shu t -down speed would be between 55 and 63 mp h (i.e., “cut-out speed”). The wind turbine would have a blade sweep area of 73,093 ft 2 , a nominal rotor speed of 9.6 to 15.5 revolutions per m i nute, and a blade tip speed of 167 mph at optimal operating speed. The wind t u rbine system would be designed to stand hurricane-force winds.
During the first 9-12 m o nths of operations, the site would be m a nned by a technician on 24-hr per day/7-day per week basis. After the initial start-up period, a technician would typically visit the site once per week. Other than regularly scheduled m a intenance (e.g., gearbox inspection, oil and oil filter rep l ac em ent, etc.), the wind tu rbine would require little routine m a intenance. Utility comp any techn i cal staf f would integ r ate e l ectri city gen e rated by the wind turbine into the power grid.
One of the primary purposes of the Proposed Action would be the collection and analysis of various power gener a tion and reliability data f rom the dem o nstration wind turbine and wind data. Data collection would be autom a ted and would utilize a lo ca l ar ea n e twork-based web caching data collection system

. The data would be co llec t ed and transmitted in real-time to Clipper personnel at their corporate offices in Carpinteria, California, where the data would be analyzed.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 18

2.1.4 Decommissionin g Phase
Clipper expects the operating lif e of the wind turbine and associa t ed equ i pment to be approxim a tely 20 years. At the end of the usef ul operating life, the turbine, tubular tower,

me teorological tower, and service building woul d be removed and recycled as appropriate. Those m a terials that are not recycl able would be disposed of at anauthorized solid waste landfil l facility. All used lubricating fl uids would be non-hazardous and would be recycled or disposed in accordance with state regula tions. The concrete pads and bu ried cables and powerlines would be recyc l ed or disposed at an author ized solid waste landfill facility.
Once the equipment has been rem o ved from the s ite, all disturbed and/or comp acted areas (i.e., areas with roads, pads, and buried cables) not need ed for on-going operations or desired to be left in-place by the private landowner would be reclai me d and r e vegetated. Disturbed areas would be recontoured and disced to prepare a suitable s eedbed and, at the seaso n ally app r opriate time, the area would be seeded and mu lched as direct ed by the private landowner. The specific seed mi xture would be determined by the private lan downer and would likely contain grasses, forbs, and shrubs, and the reclaim e d areas would be mulched.
It is possible that, at the end of the 20-year li fe of the project, the pr oposed wind turbine site mi ght not be decommissioned. Rather than be d ecommissioned, the site m a y be equipped with a new or different wind turbine (i.e ., repowered). If the site is repowered, it would continue to operate and generate electricity. However, at this time Clipper does not anticipate r e powering the site, and the Proposed Action is limited to a 20 -year life. Repowering of the project site m ay require further environmental review and analys is, and f o r the purpose of this project the repowering situation is outside the scope of this EA and is not a ddressed in this EA. Additional environmental review and analysis may be conducted if a decision was made to repower the site.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 19

2.1.5 Applicant-committed Practices
Clipper proposes to implement the fo llowing applicant-committed measures and procedures to mi nimi ze or avoid pote n tial env i ronmental impact s. These measures w ould be applied on all lands affected by the project.
2.1.5.1 Air Quality

• Clipper would not burn garbage or refuse at the site o r other facilities.
2.1.5.2 Soils and Vegetation

• To m i ni mi ze impacts to soil and vegetation resources, Clipper would reduce the area of distu rbance to the absolute mini mum nec e ssary for construction operations while providing for safe operating conditions. Clipper would also restrict off-road vehicle traffic where it is not necessary for construction of the Proposed Action.

• Where feasible, buried powerlines and cables would be located in common corridors to avoid creating separate areas of disturbance.

• Upon comp letion of construction/instal lation phase and decommissioning phase of the Proposed Action, Clipper would re store topography to near pre-existing contours on the project site, including acce ss roads and oth e r f acilities. Clipp er would also revegetate all disturbed ar eas not required for on-going operations. Clipper would apply fertilizer as required , would s eed , and w ould apply mulch to all disturbed areas. The landowner would de termine the species to be seeded and the quantity of fe rtilizer and mu lch to be used during vegetation operations.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 20

• Any m a terials used during reclamation activities (e.g., seed, mu lch) would be certified free of noxious weed seed and re productive plant parts as determined by appropriate county or state officials.

• Clipper would imple m ent noxious weed control measures within the area disturbed by construction activities. Noxious weed control measures would include chemical or m e chanical treatmen t to contain or eradicate any new noxious weed populations that develop in disturba nces created by cons truction activities. Prompt reclamation of disturbed sites would also mi ni mi ze potential for weed inf e stations.

• Clipper would obtain permit coverage for storm water pollution from construction sites f r om the W y oming Departm e nt of Environmental Quality/W a ter Quality Division. Clipper would also develop a storm water pollution prevention plan that would include measures (such as inte rception ditches, sedim e nt traps , water bars, and silt fences) to mi ni mi ze storm water pollution.

2.1.5.3 W ildlife (Including Sp ecial Status Species)

• To mi ni mi ze potential impacts to all wild life species, Clipper would prohibit all unnecessary off-site activities by project personnel. Clippe r would infor m all project personnel of applicab le wildlife laws and penalties associated with unlawful taking or hara ss me nt of wildlife.

• To mi ni mi ze potential impacts to raptors a nd avian species, C lipper would ensure that all project-related p o werline structures would be construct e d i n accor d ance with Suggested Practices for Raptor Protection on Powerline: The State of the Art in 1994 (Avian Power Line Interaction Committee 1996).Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 21

• To mi nimi ze potential impacts to activ e gre a ter sage-grous e leks during the construction of the Proposed Action, C lipper would not conduct any surfacedisturbing activities within 0.25 mi of any active lek during the greater sagegrouse m a ting season between February 1 and May 15. In addi tion, in order to mi ni mi ze potential impacts to nes t ing gr eater s a ge-grouse, no surface-d i sturb i ng activities would be conducte d within 2 m i of any activ e lek between April 1 and July 1 without permission from th e W y oming Ga me and Fish Departm e nt (WGFD). Reclamation activ ities would be conducted prior to April 1, unless prior permission is ob tai n ed f r om WGFD.

• To mi nimize potential im pacts to pronghorn, construc tion activities would be limited during severe winter conditions. Specifically, Clipper would m a intain contact with local WGFD personnel, and if it is determined by WGFD that severe winter conditions exist, Clipper would notify DOE/NREL of any restrictions required by W G FD and would limit the number of construction vehicles that would be allowed to access the site

. In addition, Clipper would mi nimi ze the amount of t ime personnel would be at th e construction site. Reclamation and revegetation procedures would be follo wed to m i ni mi ze the long-term loss of habitat.

• To docum en t potential impacts to avian and bat species, Clipper would conduct mortality surveys near the wind turbine and m e teorological tower during the first 12 months of operation of the Proposed Ac tion. Clipper would utilize mortality survey m e thods similar to those developed for the nearby Foote Creek R im Wi nd Plant (Young et al. 2003). Personnel w ould conduct one survey every 2 weeks, and each survey would involve walking tran sects established within 250 ft of each tower. Search transects would be se t approximately 25-30 ft apart and the searcher would walk at a rate of approxim a tely 2 mi/hr along the transect searching both sides out approxi ma tely 12-15 ft fo r casualties . Itis estimated th at it should require 0.75 hour to survey both towers. For each casualty identified,Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 22

data recorded would include species, se x, and age when possible, date, and tim e collected, location, condition, and any comment s that m a y indicate the tim e and cause of death. All carcasses locate d would be photographed as found and

mapped. If the species information cannot be determined, the carcass would be bagged and transported to local biologists for proper identification. At the end of the 12-month survey period, the data would be com p iled, summarized, and submitted to the DOE, USFWS, and W G FD. The U.S. Fish and Wildlife Service (USFW S ) would be notified imm e diately by telephone if carcasses of raptors or other species of concern were located at any ti me during turbine operation.

2.1.5.4 Noise

• Clipper would ensure that mu ffles and m o torized equ ipm ent are maintained according to ma nufacturers' specifications.

2.1.5.5 Cultural Resources

• Clipper would inform all construction pe rsonnel that they are working on private property and not to search for or rem ove any cultural resource m a terials.

• If any cultural resources are discove red during construction operations, all construction activities w ithin the immediate area being conducted by Clipper would be suspended and DOE and Wyoming State Histo r ic Preservatio n Office (WSHPO) personnel and appropriate tribal representatives would be imm e diately notified. Th e m a terials would be evaluated b y the arch ae ol ogist or historian

m eeting the Secretary o f Interior’s Prof essional Qualification Standards (48 FR 22716, September 1983). Wo rk in the area would not resu me until the status of the find is determined and any appropriate mitigation pla n s (if necessary) are developed and imple men ted.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 23

• If a cultural resourc e site, considered eligible f o r the National Register of Historic Places (NRHP) is identified, Clipp e r w ould utilize avo i dance as the preferred

me thod of minimizing potential ad verse effects to the property.

• Clipper would m i nimi ze adver s e ef f

ects to c u ltur a l/historical prope rties that cannot be avoided by the preparation and implementation of a cultural resources

mitigation p l an approv edby the W S HPO and DOE /NREL.
2.1.5.6 Health and Safety

• Clipper would provide potable drinking wa ter and portable self -contained toilets for hum a n waste disposal. All sewage a nd refuge (i.e., trash) generated on-site would be collected and r outinely transported off-site to a Departm e nt of Environmental Quality-approved waste disposal facility.

• Clipper plans to avoid the creation of hazardous wastes as defined by Resource Conservation and Recovery Act (RCRA) wherever possible. Clipper would ensure that any hazardous waste, as defined by RCRA, that is generated by Clipper would be transported and/or disposed of in acco rdance with all applicable federal, state, and local regulations.

2.1.5.7 Aesthetics

• The service building would be painted a desert tan color to b l end into the surrounding.

2.2 NO ACTION ALTERNATIVE
The No Action Alternative is required under Section 1502.14(d) of NEPA and DOE implementing regulation s. A No Action Alternativ e is con s idered in this EA and provides aFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 24

benchmark, enabling decision-makers to comp are th e m a gnitude of environmental effects of the alternatives (including the Propos ed Action). Under the No Acti on Alternative, the DOE would not fund the proposed project. To create the basis for a m e aningful analysis, it is assum e d that the low wind speed turbine dem o nstration projectwould not be constructed at the proposed location. However, it is possible that Clippe r could construct the pr oject using other funds independent of DOE.

2.3 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM DETAI L ED STUDY
In accordance with CEQ and DOE NEPA regulati ons, several alternatives to the proposed project were identified and considered but eliminat ed by Clipper from detailed study in this EA. One of the alternative sites was eliminated (i.e ., screened out) becaus e of scheduling conflicts

. In addition, som e of the potential sites were el iminated from detailed study because they would clearly result in m o re environmental impact s than the Proposed Action. Th e following alternatives were identified and consider ed but eliminated from detailed study.
2.3.1 Locate the Proposed Project at a Site in Southern California

Under this alternative, Cli pper would construct and operat e the low-speed wind turbin e demonstration project at a site located near Bi rds Landing in southern Solano County in northern California. This site would be part of the repow ering effort in a portion of an existing wind far m. Recent information submitted to the Solano Count y Board of Supervisors for this location indicates that inciden ts of bird strikes on wi nd turbines were mu ch higher than originally expected. As a result, the Solano County Board of Supervisors is reviewing current information and has delayed its decision to permit and allow th e repowering of this site (including a possible site f o r the Clipper ’ s low wind speed turbine). As a result, this site would not be a v ailab l e f or use for the immediate future (personal comm unication, October 18, 2004, with Mr. To m Feiler, Clipper, Boulder, Colo ra do). The permitting d e lay would not meet the scheduling needs of Clipper or DOE and could poten tially have more impac t s to avian species than under theFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 25

Proposed Action. Therefore, this alternative w a s determined not to meet the schedule required for this project, was eliminated from further consid eration, and is not studiedin detail in this EA.
2.3.2 Locate the Proposed Project at a Site in Jackson County, Minnesota

Under this alternative, Cli pper would construct and operat e the low wind speed turbine demonstration project at a site located in Jack son County in southwestern Minnesota. At this site, the proposed low-speed wind turbine dem o ns tration project would be the only wind turbin e in the immediate area (i.e., it would not be part of an existing wind far m ). At t h e Jackson County alternative site, the low-speed wind turbine demonstration project w ould be located in an area that does not currently have any wind farms. As a result, the proposed wind turbine would be noticeable to the casual observer when comp ar ed to the Proposed Action. In addition, this alternative would likely result in more disturbance thanunder the P r oposed Action (personal communication, October 18, 2004, with Mr. Tom Fe iler, Clipper, Boulder, Colorado).
This alternative would result in increased aesthetic impacts and visual intrusion s into the viewshed of the project area and would result inincreased disturbance compared to the Proposed Action. Therefore, this alternative was dete rmined not to be environmentally sound when

comp ared to the Proposed Action, w a s eliminated from further consideration, and is not studied in detail in this EA.
2.3.3 Locate the Proposed Project at a Site 0.5 mi South of the Proposed Project Location
Under this alternative, Clippe r would construct and operate the lo w-speed wind tu rbi n e at a site located approxim a tely 0.5 mi south of the proposedconstruction site. The alternative site would be located in an area that would be similar inall environmental aspects to the site of the Proposed Action. The primary disadvantage of the alternative site is that it would be located farther away from the existing infrastructure (i .e., roads and powerlines) and would cost m o re and would require m o re disturbance for the acc ess road and underground powerline comp ared to the Proposed Action.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 26

The Proposed Action, however, would be located approximately 850 ft south of an existing Medicine Bow W i nd Project. Under the Pro posed Action, the additional wind turbine and associated facilities would be similar in appearance to the existing wind turbines and would hardly be n o tice able to the casual o b server. Un der this alternative, th e low-speed wind turbin e would be located 0.5 mi south of the existing Medi cine Bow W i nd Project, and it would be m o re noticeable to the casu a l observer when comp ared to the Proposed Action.

This alternative would result in inc rea sed costs and disturbance and would cause increased visual intrusion into the viewshed of the general project area compar ed to the Proposed Action. In addition, the USFWS recommends siting wind turbines in g r oups or s trings to mi nimi ze i mpacts to avian species (USFWS 2003). Therefore, th is alternative was determined not to be economically feasible or environmentally s ound when compared to the Proposed Action, was eliminated from further consideration, and is not studied in d e tail in this EA.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 27

3.0 AFFECTED ENVIRONMENT
3.1 LOCATION, SETTING, AND HISTORICAL USE
The proposed project would be located approximately 5 mi s outhwest of the community of Medicine B o w, W y omi ng, in eastern Carbon County (r efer to Figure 1.1). Access to th e site is south from Medicine Bow, W y om i ng, via the E l k Mountain to Medicine Bow Road (an unpaved public road) to unpaved private access roads lo cated near the existi ng Medicine Bow Wi nd Project (refer to Figure 2.2). The proposed proj ect would be located in Section 1, T21N, R79W, and the property is privately owned.
The proposed project would be located on the ea stern flanks of the Hanna Basin (Lageson and Spearing 1998). The proposed project area is also located within th e Upper Platte River drainage basin (Knight 1994), and the Medici ne Bow River is located appr oxim a tely 1.5 mi southeast of the project area. Elevation of the project area is approximately 6,750 ft above mean sea level and is relatively flat except for the western portion of the project area that gently slo p es toward the west-southwest. The general pr oject ar ea is also relative l y f l at with som e areas of rollin g hills (refer to Figure 3.1).
Based upon 1:100,000-scale m apping, the mi xed-gras s prairie is the only ecological region within 1 mi of the proposed pr oject area (U.S. Geological Survey 1996). Mixed-grass prairie is composed of grasses, forbs, and shrubs (such a needle-and-thread grass, western wheatgrass , Sandberg bluegrass, Junegrass, Indian ricegrass, scarlet globemallow, fringed sagewort, Hood’s phlox, black sagebrush, and cush ionplants) (Knight 1994).
Climatic conditions within the g e neral p r oje c t ar ea are characteristic of the Foothills and Basin area of south-central Wyoming. According to weather data collected at Medicine Bow, Wyoming (approxim a tely 5 mi northeast of the proj ect ar ea), record hig h and low temp eratures are approximately 97oF and –46oF, respectively, w ith an average annual air temperature ofFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 28

This figure is a separ ate file Fig 3-1.pdf.

Figure 3.1 Location of Projec t and PRPA Wind Turbines.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 29

41.6oF. Summer temp eratures range widely, typical ly with warm sunny days and cool nights. On average, there are approxim a tely 90 frost-free da ys a year in the general project area (Martner 1986). The proposed project areareceives approximately 10.25 inch es of precipitation per year, and the prevailing winds are from the s outhwest (Soil Conservation Service 1988).
The general project area historically has b een utilized for lives tock grazing, wind energy development, oil andga s develop m ent, utility co rridors, and wildlif e habitat. Currently, the PRPA owns and operates the Medi ci ne B ow Wi nd F arm located imme diately north of the project area. This wind farm c onsists of 10 large (> 600-kilowatt) wind turbin es, two 400-ft tall guyed

me teorological towers, an 800-ft 2 se rvice building, and ass o ciated outb u ildings and facilities. The seven of the existing wind turbines are locate d south of t h e service building and configured in a single row of turbines, and the three rem a ining turbines are located nearof the servic e building. WAPA operates and m a intains a 115-kilovolt p o werline and electric substation that connects the PRPA wind f arm to the power grid. The existing e l ectric substation is located approxim a tely 500 ft east of the PRPA service building, and the powerlin e runs northeast from the PRPA wind f arm toward the community of Medicine Bow. A 69-kV transmission powerline (owned and operated by Carbon Power and Light Inc ., a rural electric cooper ative) runs from the northeast to the southwest through the general project area. This line provide s electric service to the community of Elk Mountain but is not associat ed with or connected to the PRPA wind far m or WAPA powerline (refer to Figure 2.2).

3.2 AFFECTED RESOURCES
3.2.1 Cultural Resources (Includin g Native American Concerns)

Cultural resources are the nonren ewable physical rem a ins of past human activity and are protected under Section 106 of the National Historic Preservation Act of 1966 , as amended (1 6 U.S.C. § 4 70 et seq), the Archaeological R e sources Protection A c t of 1979, as amended (16 U.S.C. §470aa et seq), and other law s. Archaeol ogical investigations in south-central W y oming indicate that hum a n activity has occurred across the landscape over the past 10,000 years, beginning during the Paleoindian period and c ontinuing up to the pr esent (Frison 1991).Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 30

Results of a BLM Class I survey (i .e., file search) did no t ind i cate tha tany previously identif i ed historic o rprehistori c sites were located withinthe pro j ect area. A Cl ass III inventory (i.e., pedestrian survey) of the proj ect area that included 34.4 acres did not identify any cultural resource sites (TRC Mariah Associates Inc. 2004). Several historic trails including the Overland Trail, Chero k ee Trail, and the Fort Halleck to Fort Fetterm an W a gon Road occur within the vicinity of the project area, but none of these trails are lo cated within 10 mi of the project area.

Num e rous Native Am er ican groups including butnot limited to Crow, Shoshone, Com a nche, Arapaho, Cheyenne, and Sioux have utilized the general project area and numerous sites of tradition a l c u ltur a l inte re st hav e previously been identified within 10 mi of the project ar ea
. Som e of the s e sites are located near the Foote Creek W i nd Farm project, the Carbon Basin Coal project, and a fiber optic pro j ect (pers onal communication, December 21, 2004, with Mark Soldier W olf, Northern Arapaho Tr ibal Archaeo l ogical Con s ultan t ). Tribes and/or individuals

were sen tletters requesting thei r comme nts concerning any religious or significant cultural areas within or near the pro j ect area. To date, no historic o rprehistori c sites of Native America n origin, or s i tes or areas o f tradition a l cultural sign ificance hav e been identif i ed within the proje ct
area.

3.2.2 Noise
The A-weighted sound pressure leve l, or A-scale, is used extens ively in the U.S. to measure community and transportation noise and is a meas ure of noise in A-wei ghted decibels (dBA), which is directly correlated with som e comm only heard sounds. Table 3.1 presents a list of commonly heard sounds with the corresponding noise level (Rau and Wooten 1980).Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 31

Table 3.1 Comp arison of Measured Nois e Levels with Commonly Heard Sounds. 1

Source dB A Descript i on Normal breathing 10 Barel y audibl e Ru st li ng l eav es 20 Soft wh ispe r (at 16 ft) 30 Very qu iet Library 40 Quiet o f fice 50 Quiet Normal conve rs at i on (at 3 ft ) 60 Busy traffic 70 Noisy Noisy office with m achines; factory 80 Heavy truck traffic (at 4 9 ft) 90 C onst ant ex posu re endangers hearing

Source: Rau andWooten ( 1980).

No site-specific noise level data are available for th e project ar ea. However, m a jor sources of noise include the wind and the PRPA wind turbin es that generate noise only when they are operating. Rural areas like the pr oject area have an average noise level of 30-45 dBA (Rau and Wooten 1980). Median noise levels for rural areas likely range from 20 to 40 dBA in the morning and evening and from 50 to 60 dBA in the afternoon when wind speeds are typically greatest. These no ise levels correspond to a soft whisper (30 dBA), a library (40 dBA), a quiet office (50 dBA), a small town (40-50 dBA), and norm a l conversation (60 dBA). Traffic along an interstate highway typically averages noise levels greaterthan 70 dBA ( W yle Laboratories 1971). Wh en operating at the optim a l wind speed(33 mp h), the existi ng PRPA wind turbines likely produce approximately 40- 50 dBA of nois e 800 ft downwind of the turbines (Madison Gas and Electric 2004). In high wi nds, the background noise produ ced by the wind w ould generally

ma sk most of the noise from the operating wind turbines.

Noise-sensitive ar eas in the general project ar ea in clude private resid e nces (the closest residence is approximately 1.5 mi north of th e project area), occupied raptor ne sts (the closest raptor nest is approxim a tely 1.4 m i s outhwest of the project area), and greater sage-g rouse leks during the breeding and nesting season (the closest greater sage-grouse lek is 0.4 mi south of the project area). 1Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 32

3.2.3 Soil Resources

The Natural Resources Conservatio n Service has not published a detailed soil survey report for the eastern portion of Carbon County. However, the College of Agriculture at the U n iversity of Wyoming has prepared 1:100,000 scale digital so il m aps including the pr oposed project area (Munn and Arneson 1998). The pr oject area includes so ils from the High Plai ns Southeast zone, which is typ i cally com p rised of mo untains and foot hills. In the general project area, the surface 12 inches of soil is typic a lly gravelly loam, a nd the subsoil is highly calcareous, very gravelly, and cobbly loam to sandy loam . Wa ter erosion is slight, and wind erosion potential is moderate. These soils support a vegetative cover that typica lly serves as rangeland a nd wildlife habitat (Soil Conservation Service 1988).
3.2.4 Threatened, Endangered, Proposed, and Candidate (TEP&C) Species

3.2.4.1 Introduction

The federal Endangered Species Act (16 U.S.C. 1531-1543) protects federally listed threatened and endangered p l ant and animal species and their critical habitats. A lis t of federally listed TEP&C species that potentially oc cur in the vicinity of the pr oposed project was compiled from the W y oming State Supervisor Office of the USFWS (2004) and the Wyoming Natural Diversity Database (WNDD) (2004).
TEP&C species are those that h a ve been specifically de signated as such by the USFWS. Endangered species are those thatare in danger of extinction throughout all or a significant portion of their range. Th reatened species are th os e that are likely to beco me endangered in th e foreseeable future throughout all or a significan t portion of their range. Candidate species are those f o r which the USFWS has suf f icien tdata to list as thr e atened o r endangered but f o r which proposed rules have not yet been issued. Propos ed 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.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 33

3.2.4.2 TEP&C Ani m al and Plant Species

The black-footed ferret (Mustela nigripes ), a fed e ral endangered species; bald eagle ( Haliaeetu s leucocephalus ), a federal threatened species; Ute ladies’-tresses ( Spiranthes diluvalis ), a federal threatened species; and Platte Ri ver system species--whooping crane ( Gr us americana ), interio r leas t tern( Sterna antillarum ), piping plover ( Charadrius melodus ), pall idsturgeon ( Scaphirhynchus albus ), bald eagle ( Haliaeetus leucocephalus ), Eskimo curlew (Numenius borealis ), and western prairie fringed orchid ( Platanthera praeclara )--may potentially occu r within the project area or m a y be affected by the Proposed A c tion (refer to Table 3.2). No other TEP&C species as desig n ated by the USFWS have been identified to poten tially o ccu r within the project area (USFW S 2004).

Black-foote dFerret

. The black-footed ferret, a federally listed endan g ered species, was once distributed throughout the high plains of the Ro cky Mountain and western Great P l ains regions (Clark and Strom b erg 1987; Forrest et al. 1985). Prairie dogs are the main food of black-footed ferrets (Sheets et al. 1972), and his t orically a few black-footed ferrets ha ve been collected away from prairie dog towns (Forrest et al. 1985). Th e last known wild popul ation 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 popu lation, the rem a ining black-footedferrets were captured from the Pitchfork area and p l aced into a captive br eeding project in 1985 (W yom i ng Gam e and Fish Departm e nt [WGFD] 1997).Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 34

Table 3.2 Federal Threatened, Endangered, Proposed and Candidate Species and Their Potential Occurrence W i thin the Project Area, 2004. 1

Potential Occurrence Comm on Name Scientific Nam e Fed e ral Statu s 2 With in t he Proposed Project Area 3 MA MM AL S Black-f oo ted f e rret Mustela nigripes E X BIRDS Bald eagle 4 Haliaeet us leucocephalu s T R PLANTS Ute ladies’-tresses Spi ra nthes di lu vial is T X PLATTE RIVER Various 5 n/ a n/ a SYSTE M SPECIES

1 Ad apted fr om US FWS (2004)

. 2 Fed era l statu s (USFW S 2004): E = listed as fed e rally en da ngered. T = listed as fed e rally threatened. n/ a = not ap pl i cabl e. 3 Species occ u rrence: R = Rar e ; species may b e in the project area for just a f ew da ys or hou rs (e .g., st oppi ng over du ring mi grat i on)

. Encou nte rs during pr oj ect const ruct io n i s very unl ik el y. X = Unlikely; there has been no r ecent historical record of the species 's occurrence in t h e project are a; pr obability o f encountering th e species du ri ng powerline co nstruc tion is ve ry unlikely. n/ a = not ap pl i cabl e. 4 Pro po sed f or rem oval fr om fe deral listin g. 5 Includes whooping cra n e ( Grus americana ), interio rleast tern ( Stern a antillaru m ), piping pl ov er ( Ch ara d rius melodu s ), p a llid sturg e on ( Sc aphi rhync h us al bus ), bal d eagle ( Haliaeetus leu coc ephalu s ), Eskim o curlew (Nu menius b ore al is ), a nd wes t ern prairie f rin gedorchid ( Plat anth era praeclara ).

As a result of the captive bree ding and reintroduction program , black-footed ferrets have been successfully released into several areas in the west including the Shirley Basin Ferret Managem e nt Area located approxim a tely 30 mi north of the project area. Eighty-eight blackfooted ferrets were counted during surveys conduc ted in August 2004. This is an increase of 36 black-footed ferrets (69%) m o re than the 52 individuals counted dur ing August 2003 (CasperStar Tribune 2004).

The Black-footed Ferret Survey Guidelines fo r Compliance with the Endangered Species Act (USFW S 1989) defines potential black-footed ferret habitat as any white-tailed prairie dogFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 35

towns or complexes greater than 200 acres in si ze. Based on the results of a reconnaissance survey conducted by TRC Mari ah Associates Inc. on Octobe r 28, 2004, no prairie dogs wer e identified within the project area. In additi on, while pote n tial black-f ooted ferret may travel through the general project area, th e project area is located outside of any area requiring blackfooted ferret surveys (USFW S 20 04). In addition, no recent bl ack-footed ferret observations have been recorded in the vicinity of the project area (USFWS 2004; WN DD 2004). Therefore, it is unlikely that any black-footed ferre ts would occur in the project area.
Bald Eagle

. The bald eagle is a federa lly listed threatened species (downlisted from endangered and now proposed for removal from fe deral listing). This species requires cliffs, large trees, or sheltered canyons associated w ith concentrated food sources (e.g., fisheries or waterfowl concentration areas) for nesting an d/or roosting areas. Bald eagles forage over wide areas during the non-nesting season (i.e., fall and winter) and scavenge on an imal carcasses such as pronghorn antelope, deer, and elk (Edwards 1969; Snow 1973; Call 1978; Stee nhof 1978; Peterson 1986).
No bald eagle nests or winter roosts are known to occur in the project ar ea or within the general project area, due to the lack of suitable nesting or winter ro osting habitats. There are no known bald eagle nests with 15 mi of the proposed project area (BLM 2003) and there have been no documented m o rtalities of bald eagles associatedwith the Phase I portion of the Foote Creek Ri m Wi ndpower project located approxim a tely 10 mi southeast of the proposed project area (Young et al. 2003). Although searches of the WNDD revealed no records of bald eagles in the vicinity of the proposed project area (WNDD 2004), it is possible that individuals m ay occasion a lly forage in or fly through the general project area.

Ute Ladies'

- tresses

. Ute ladies'

- tresses, a federally listed threatened species, is a perennial

me mber of the orchid family that inhabits mo ist streambanks, wet meadows, and abandoned stream channels at elevations of 4,500-6,800 ft(Fertig 1994; Spackm a n et al. 1997). Although the species will tole rate mildly alkaline conditio ns, it is unlikely to be found in association with Gardner's saltbush, greasewood, or other alkaline vegetation. Wh ere it occurs in ephem e ral drainages, groundwater is typically shallow (i.e., within approxi ma tely 18 inches of the groundFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 36

surface) (personal communication, March 16, 2000, wit h Pat Deibert, USFWS; personal communication, March 22, 2000, with W a lt Fertig, W N DD).
The species has been docum e nted in Goshe n, Converse, and Niobrara Counties in W y oming (Fertig 1994) and along the Front Range in northern and central C o lorado (Sp a ckm a n et al. 1997). Although mu ch time has been devoted inr ecent years to determin ing areas in W y oming where the s p ecies occurs, it has n o t been docum ented within the proposed proje c t area, th e general project area, or Carbon or Albany Coun ties (WNDD 2004). Based on visual observation of the project area and descriptio ns for vegetation communities in the project area, there is no suitab l e habitat f o r Ute ladie s'- tress e s within th e project area or imm e diat e p r oject area. There would be no affect from the project, and the sp ecies is not discussed further in this EA.
Platte River System Species

. The USFWS has determined that water depletion to the Platte River system may advers ely affect the federally listed whooping crane ( Grus americana) , interior least tern ( Sterna antillarum ), piping plover ( Charadrius melodus ), pallid sturgeon ( Scaphirhynchus albus ), bald eagle ( Haliaeetus leucocephalus ), Eskimo curlew (Numenius borealis ), and western p r airie fringed orchid ( Platanthera praeclara ). Wa ter d e pletions includ e evaporative losses or consumptive use including, but not limited to, ponds , lakes, reservoirs, created or enhanced wetlands, hydro static testing of pipelines, wells, diversion structures, dust abatement, etc. The Proposed Action would not re sult in any water depl etions from the Platte River system and would not result in any adv e rse ind i rect impacts to these species ; therefore they are not discussed further in this EA.

Boreal Toad

. The boreal toad is not a listed speci es (threatened, endangered, proposed, or candidate) under the federal Endangered Specie Act

. Howev e r, the USFWS has determined that suf fi cient in fo rmation exists to list the species as a candidate species, b u t the USFWS has not proposed the species for listing because of high er priority listing actions (USFW S 2004). The boreal toad ( Bufo boreas boreas ) is one of two subspecies of the western toad that is found throughout much of the western U.S. The range of the boreal toad cu rrently extends from western British Colum biato southern Nevada a nd east to parts of W y omi ng. Wy omi ng is on theFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 37

southeastern periphery of the bor eal toad distribution, and it has been found in the south-central and northwestern portion of the state. In W y oming, boreal toads generally occur between 7,500 to 12,000 ft above mean sea level and are usually found in wetlands near ponds, lakes, reservoirs, rivers, and s treams. There are no recorded occurrences of boreal toads in the general project area (WNDD 2004; W G FD 1999), and there is no suitable habitat within th e project area. Therefore, there would be no affect from the project and the species is not di scussed further in this EA.
3.2.5 Vegetation Resources
Based upon 1:100,000-scale m apping, the m i xed-grass prai rie is also the only ecological region within 1 mi of the proposed pr oject area (U.S. Geological Survey 1996). Mixed-grass prairie is composed of grasses, shrubs, and forbs such a needle-and-thread grass, western wheatgrass, Sandberg bluegrass, Junegrass, Indian ricegrass, scarlet globemallow, fringed sagewort, Hood’s phlox, black sagebrush, and cush ion plants (Knight 1994).

3.2.6 Visual Resources
The Proposed Action would be located on Spade Flats, which generally provides a 360-degree perspective of portions of the surrounding plains, foothills, a nd mountains. PRPA’s Medicine Bow W i nd Farm domi nates the view to the north of the project area.
Approxim a tely 800 ft north of the proposed wind turbine is the southern m o st PRPA wind turbine, f o llowed in a line by the rem a ining six wi nd turbines. The other three wind turbines, not located in the row of wind turbines, as well as the two m e teorological towers, the servic e building, the electric substa tion, the WAPA and Carbon Po wer and Light powerlines and associated facilities, are also vis i ble north of the project area.
To the east, there is little evidence of hum an encroachm e nt e x cept for the top of num e rous wind turbines ass o ciated with the Foote C r eek W i nd Farm that are located along the horizo n southeas t of the project area. These wind turbines are lo cated approximately 10 mi away from the project

area.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 38

To the south, there is a lso limited evidence of hu ma n encroachm e nt except for tops of additional wind turbines associated with the Foote Creek Wi nd Farm that are located along the horizon south of the project area. These wind turbines are located approxim a tely 12 m i south of the project area. Portions of Carbon Power and Light’s electric transmission powerline and the Medicine Bow to Elk Mountain roadare both visible southwest of the project area and continue beyond out of view of t h e project area.
To the west, another portion of Carbon Power a nd Light' s small electric transmissio n powerlin e and the Medicine Bow to Elk M ountain road are both visible.
Because of topographic diversity in the area (i.e. , rolling hills), the proposed project would not be visib l e from the communities of Medicine B o w, Rock River, McFad d en, Arling t on, Hanna, or Elk Mountain. However, the existing Medicine Bow W i nd Farm and the proposed Clipper wind turbine would be visible from portions of U.S. Highway 30.

3.2.7 Water Resources (Surface W a ter Including Wetlands)
The project area lies within the Upper Platte River drainage basi n; however, there are no defined ephem e ral, intermittent, or perennial drainage cha nnels in the project area (refer to Figure 3.2).Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 39

This figure is a separ ate file Fig 3-2.pdf.

Figure 3.2 Surface W ate r Featu r es near the Project Area.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 40

The project area is on the northwestern side of Spad e Flats and is extremely flat, and the fact that little surface water runoff is produced is evidence d by the lack of any defined drainage channels and the presence of sev e ral small p l ayas in the general pro j ect area. A ny surface water runoff that is produced would eventually flow into the Medicine Bow Rive r located approxim a tely 1.5 m i southeast of th e project area.
No surface water quality data are a v ailab l e from the project area. However, water quality is expected to be highly variable depending upon the nature and intensity of the runoff event and the nature of the affected soils. A comp aris on of water quality from the general area to WDEQ/W QD Chapter 8 water class standard s (WDEQ/WQD 2000) ind i cates that surface water quality would typic a lly meet Class III (live s toc k class of use) criteria (U.S. Geological Survey 2004). The Medicine Bow River inthe general project area is de signated as having Class 2AB surface water quality as defined by the W D EQ/WQD. The Class 2AB designation means that these waters can support gam e and non-gam e fish species (WDEQ/WQD 2001). There are no drainage channels or reservoirs within the ge neral proje c t area that are included in the WDEQ/W QD (2002) 2000 303(d) list of water bodies with water quality impairments.
No formal jurisdictional wetland delineations ha ve been conducted within the project area. However, according to National Wetland Inv ent ory m aps produced by the USFWS, there are no potential wetlands in the projec t area or within 0. 5 mi of the project area (USFWS 1997).

3.2.8 Wildlife
3.2.8.1 Big Ga me
According to the WGFD, three big gam e species--p ronghorn, mu le deer, and elk--occur within or immediately adjacent to the proposed project area (WGFD 2003b). The population estimates for big game herds provided below are base d upon WGFD m o del estim ates (WGFD 2004).Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 41

Pronghorn . Pronghorn in the project area belong to the Medicine Bow pronghorn herd (herd uni t 525), and the project area is located in crucia l winter/yearlong antelo pe range (WGFD 2004) (refer to Figure 3.3). Pronghorn were observ e d inand adjacent to the project area during a reconnaissance survey conduc ted by TRC Mariah Associates Inc. in October 2004. Atthe end of 2003, the Medicine Bow herd unit had an estim a ted population of 56,804 pronghorn, which is approxim a tely 5% below the WG FD population objective of 60,000 an imals for t h is herd unit. Drought continues to be one of the biggest fact ors affecting populations in herd units with populations below WGFD obj ectives (WGFD 2004).

Mule Deer

. Mule deer in the projec t area belong to the Sheep Mount ain mule deer herd (herd unit 539) and the p r oject area lies within winter/y earlong ran g e. The nearest mu le deer crucial winter range is located approxim a tely 1 m i southeast of th e p r oject area (WGF D 2004). No mule deer were o b served in and adjacent to the pro j ect area during a reconnaissance survey conducted by TRC Mariah Associates Inc. in O c tober 2004. At the end of 2003, the Sheep Mountain herd unit had an estimated populati on of 10,885 mu le deer, which is approximately 27% below the WGFD population objective of 15,000 animals for this herd unit. Drought c ontinues to be one of the b i ggest factors affecting mu le deer in herd u n its with populations be low WGFD objectives

. In addition, chronic wasting dis ease has been docum e nted in porti ons of this herd unit and m ay be having som e e ffect on animal survival (WGFD 2004).

Elk . Elk in the project area belong to the Snowy Range Elk Herd (herd unit 533), and the project area lies within winter/yearlong range. The n earest elk crucial wint er range is located approxim a tely 13 mi south of the project area(WGFD 2004). No elk were observed in and adjacent to the project area during a recon n aissance s u rvey conducted by TRC Mariah Associates Inc. in October 2004. At the end of 2003, the Snowy Range herd unit had an estimated population of 5,473 elk-- approxim a tely 9% below the W G FD population objective of 6,000 animals. Drought and habitat i ssues continue to be important factors affecting elk in herd units with populations below WGFD objectives (WGFD 2004).Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 42

This figure is a separ ate file Fig 3-3.pdf.

Figure 3.3 Pronghorn Ranges near the Project Area.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 43

3.2.8.2 Other Mammals
Typical predators known to occur or to potentially occur in the project area are coyote, red fox, raccoon, long-tailed weasel, badg er, mi nk, striped skunk, m o untain lion, and bobcat. Lagomorph species include desert cottontail, mountain (Nuttall' s ) cottontail, and white-tailed jackrabbit. Squirrels known to occur or to potentially o ccur include least chipmunk, Richardson/Wyom i ng ground squirrel, and thirteen-lin ed ground squirrel, and other r odents include one species of pocket gopher (northern), two species of pocke t mouse (olive-backed and northern), Ord's kangaroo rat, beaver, deer mouse, northern grasshopper mouse, bushy-tailed woodrat, five species of vole (southern red-backed, western, m eadow, long-tailed, and sagebrush), and western jum p ing m o use. Porcupine and four species ofbats (little brown, hoary, big brown, silverhaired) also likely occur in the general pr oject area (WGFD 1999; Cl ark and Strom b erg 1987). 3.2.8.3 Raptors
Raptor species known to occur or to potentially occur within the project area incl ude peregrine falcon, golden eagle, prairie falcon, American kestrel, m e rlin, Swainson's hawk, ferruginous hawk, red-tailed hawk, northern harrier, rough-legged hawk, and great horned owl, burrowing owl, long-eared owl, and shor t-eared owl (WGFD 1999; Clark and S tromberg 1987). A review of BLM historic raptor nest in formation reveals that there ar e no known raptor nests within 1.0 mi of the project area. However, there are fi ve raptor nests/eyries within 2.0 m i of the proposed project area--two golden eagle, two prai rie falcon, and one ferruginous hawk (refer to Figure 3.4). No monitoring has occurred at these site s; therefore, the historic activity status of these nests is unknown.
3.2.8.4 Upland Ga me Birds
The project area is lo ca ted within W G FD Upla nd Ga me Bird Managem e nt Area Num b er 24. Several upland gam e bird species occur on and ad jacent to the pro j ect ar ea, including greater sage-grouse and mourning dove (WGFD 2002).Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 44

This figure is a separ ate file Fig 3-4.pdf.

Figure 3.4 Raptor Nest Locati ons near the Project Area.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 45

Two greater sage-grouse leks are known to occur within 2 mi of the project area (WGFD 2003a). The leks are approximately 0.5 mi and 0.7 mi south of the project area (r efer to Figure 3.5). According to WGFD records, 1980 was the last time any greater sage-grouse were observed at either of these leks; however, no m o nitoring wa s conducted at either lek between 1980 and 1998. Over the past 6 years, both leks w e re mon itored several tim e s each breeding season, except during 2001 when no monitoring was conducted. No greater sage-grouse ha ve been observed at either of these leks during th e 1999 to 2004 m o nitoring period. WG FD and BLM policy states that greater sage-grou s e leks are considered active unless there is no grouse attendance at the leks for 10 consecutive years. Despite the lack of m onitoring data at the two leks located nearest the project area, it is th e W G FD biologists' opinion that thes e two leks are abandoned (personal communication, October 29, 2004, with Bob Lanka, WG FD biologist, Laram i e, Wyoming). However, the W G FD are waiting fo r additional m onitoring data be fo re they m ake a f i nal determination on the status of these leks.
3.2.8.5 Other Birds (Including Migratory Birds)
Bird species (including mi grator y birds) potentially o ccurring within the pr oject area, based upon range and habitat preference, include but ar e not limited to common nighthawk, Say's phoebe, western kingbird, horned lark, sw allows (e.g., violet-green, bar n, cliff), black-billed m a gpie , common raven, American crow, rock wren, mount ain bluebird, loggerhead shrike, Brewer' s sparrow, vesper sparrow, savannah sparrow, sage sparrow, lark bunting, McCown' s longspur, red-winged blackbird, western m eadowlark, B r ewer' s blackbir d, com m on grackle, green-tailed towhee, and brown-headed cowbird (WGFD 1999).
Since there are no permanent su rface water bodies (i.e ., lakes, ponds, etc.) within the project area, it is unlikely that waterfowl and shorebir ds would nest in the project area. However, several species of wading/shore birds--such as great blue heron, bl ack-crowned night-heron, American avocet, willets, killdeer, and spotted sa ndpiper--an dwaterfowl m a y occasionally occu r around East Allen Lake (located approxim a tely 3 mi north of the project area), the Medicine Bow River (located approxim a tely 1.5 mi southeas t of the project area), and seasonal ponds (i.e.,Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 46

This figure is a separ ate file Fig 3-5.pdf.

Figure 3.5 Greater Sage-grouse L e ks near the Proposed Project Area.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 47

playas) (lo c ated within 3 mi of the project area). Wa terfowl species likely to occu r in the general project area include pied -billed grebe, American coot, Cana da goose, m a llard, green-winged teal northern pintail, blue-winged teal, cinnam o n t eal, northern shoveler, redhead, ring-necked duck, American wigeon, and common m erg anser (WGFD 1999).
3.2.8.6 Amphibians, Reptiles, and F i sh
Based on range and habitat preferen ce, it is likely that three amphi bians and three reptile species

ma y possibly occur within the project area or within 3 mi of the p r oject area. Amphibians include tiger salam a nder, chorus frog, and north ern leopard frog that occur primarily in and adjacent to aquatic h abitats. Reptile species include northern sagebrush lizard, prairie rattlesnake, and western garter snake (BLM 1998; WGFD 1999).

There are n o perennial waters; therefore, no fishoccur within the project area. However, the Medicine Bow River (located approxim a tely 1.5 mi southeast of the project area) is designated by the W G FD as a Clas s 4 stream

. WGFD Class 4 streams are con s ideredlow-production trout water tha t ma y provide f i sheries o f local import ance but are generally incapable of sustaining substantial fishing pressure. The section of the Medicine Bow River located near the project area likely supports a variety of fish species including brown tout, brook trout, rainbow trout, walleye, longnose dace, longnose sucker, white sucker, common carp, creek chub, silver shiner, and johnny darter (BLM 1998).Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 48

4.0 ENVIRONMENTAL CONSEQUENCES
In accordance with 40 C.F.R. 1502.16, this chapte r of the EA includes a discu s sion of the potential environmental consequences of the Proposed Action and the No Action Alternative on each of the affected resources. An environmental im pact is defined as a change in the quality or quantity of a given resource due to a modificat ion in the existing envi ronment resulting from project-related activities. Impacts may be benefi cial or adverse, m a y be a primary result (direct) or secondary result (indirect) of an action, and m a y be permanent and long-term or temporary and of a short duration. Impacts m a y vary in degr ee from a slightly discernible change to a total change in the environ m ent. This impact ass e ssment ass ume s that all applicant-committed

m easures described in the Proposed Action w ould be successfully im ple m ented. If such

m easures are not implemented, addition a l adve rs e impacts m a y occur.

Cumu lative impacts are discussed in Section 4.9, irreversible a nd irretrievable commitments are discussed in Sections 4.10, and short-term use of the environment versus long-term productivity is discussed in Section 4.11.

4.1 CULTURAL RESOURCES ( I NCLUDI NG NATIVE AMERICAN CONCERNS)
4.1.1 Proposed Action
Class I and III surveys (i.e., file sear ch and pedestrian inven t ory) have b e en comp leted for the project area, and no historic or pr ehistoric sites were identified. Therefore, the Proposed Actio n would not have any direct impacts on identified cultural resources within the p r oject area. In addition, the project area would not be visible from any of the historic tr ails (Overland Trail, Cherokee Trail, and the Fort Halleck to Fort Fetterman W a gon Road); th erefore, the Proposed Action would not have any visual impacts on hi storic trails in the general ar ea.
As discussed in the Proposed Ac tion (Section 2.0), Cli pper and its contractor would stop work if any cultural resources are discovered during construction operations. Work in the area of theFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 49

discovery would not resum e until the appropriate regulatory agency would be notified and appropriate treatm e nt plans imple men ted. Construc tion employees would be instructed that they would be working on private land and are not to search for, scavenge, or remove any cultural resources found while working on the project (refe r to applicant-committe d practices presented in Chapter 2 ).
Consultation with Native American groups has been in itiated (i.e., letters were sent to the tribes), and no sites of religious or traditional cultural importance have been identified within the proje ct area. Formal consultation is ongo ing between DOE and one of the tribal organizations that was previously contacted; however, the consulting tribe has not identified to DOE any tradition al cultural properties or specific Native American issues concer ning the Proposed Action. There are no known historic, archaeologi cal, or trib al resou r ces within the p r oject site, therefore no impacts are anticipated as a resultof the proposed acti on. If pr eviou s ly unidentified sites of religious or cultural importance are identified wi thin the project area through tribal consultation or during construction of the project, DOE woul d review the potential impacts consisten twith the applicant-committed practices c i ted in Chapter 2 to verif y they ar e suf f icien tto m i nimi ze any impacts.

Therefore, documented and undocumented cultu ral resources would be protected during construction , operations, and m a intenance operations and no unmitigated cultura l res ources that are eligible for listing o n the NRHP would be impacted by the Proposed Action. No addition al

mitigation b e yond those already included in th e Proposed Action would be req u ired. The Proposed Action would not have any si gnificant impacts on cultural resources.

4.1.2 No Action Alternative
Under the No Action Alternative, the DOE would not fund of the Proposed Action, construction of the dem o nstration wind turbine and associated facili ties would not occur, and no impacts to cultural resources would occur.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 50

4.1.3 Mitigation and Monitoring
No additional mitigation or m o nitoring is recommended beyond the applicant-committed practices ide n tified in Chapter 2.
4.1.4 Residual Impacts
The Proposed Action would not re sult in any unavoidable adve rse impacts to identified unmitigated cultural resources. However, some loss of unidentified c u ltur a l resources sites or artifacts m a y occur, but, if previously unide ntified cultural resou r ces are loc a ted during construction operations, activity in the are awoul d be halted, the proper regulatory authority would be contacted, and appropria te treatm e nt plans imple men ted to avo i d significant impacts.

4.2 NOISE
4.2.1 Proposed Action
There are no applicable federal, state, or county regulations governing environmental noise levels in the project area. Under the Proposed Action, the noi se would be generated during construction/installationand operation of a single 2.5-MW wi nd turbine that is expected to generate 105 dBA at 415 ft in an 18 mph wind. As a result of the Proposed Action, there would be an increase in noise due to the operation of the addition a l wind turbine (40-60 dBA f o r the background and the Medicine Bow Wind Farm compared to 105 dBA from the proposed Clipper wind turbine). As a result, the noise would only occur when the wind turbine is operating and would likely be m a sked by the background noise le vel (including wind and existing PRPA wind turbines) that could be as high as 40-60 dBA. The increased leve l of noise would not likely be highly noticeable m o re than 1,000 ft away from the wind turbine.

The increase in noise due to th e Proposed Action would not be no ticeable to the casual observer located on the nearest public road (the Medi cine Bow to Elk Mountain Road), which isFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 51

approxim a tely 1 mi north and west of the project area, or to the nearest residence approxim a tely 1.5 mi north of the project area. The increased noi se would not be expected to adversely impact the nearest raptor nest 1.4 m i s outhwest (upwind) of the project area. The potential impacts of noise on greater sage-grouse leks is addressed in Section 4.8 of the EA.
The impacts of the increased level of noise woul d only occur when the tu rbine is operating an d would be eliminated after the win dturbine h a s been decommissioned and the equipment removed. No additional mitigation beyond those already included in the Proposed Action would be required. Therefore, the Proposed Action woul d not result in any signif i cant impacts to noisesensitive receptors.

4.2.2 No Action Alternative
Under the No Action Alternative, the DOE would not fund of the Proposed Action, construction of the dem o nstration wind turbin e and associated fac ilities would not occur, and noise levels would continue to be primarily influenced by wind and the existing PRP A wind far m.
4.2.3 Mitigation and Monitoring
No additional mitigation or m o nitoring is recommended beyond the applicant-committed practices ide n tified in Chapter 2.
4.2.4 Residual Impacts
As a result of the Proposed Action , there would be an increase (40-60 dBA comp ared to 106 dBA) in noise due to the operation of the additional wind turbine. However, the noise would only occur when the wind turbine is operating and would generally be m ask ed by the background noise level (including wi nd and PRPA wind turbines) thatcould be as high as 40-60 dBA.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 52

4.3 SOIL RESOURCES
4.3.1 Proposed Action
Under the Proposed Action, less than 10 acres would be newly disturbed by construction/installation operations. Because of the small a m ount of area (less than 1.25 acres) that would be disturbed for the life-of-the-pr oject for the construction of the wind turbine, service building, and m e teorological tower, a nd cables and powerline no topsoil would be removed or salvaged. Instead, wheeled vehicles that o p erate off-road would disturb th e
rem a ining 8.45 acres. Direct im pacts to soils would be limited to compaction of soils when construction equipment operates off of existing road s. These impacts may result in an increase in runoff, erosion, and sedim e ntation into any local receiv ing waters.

Short-term control of surface runoff would be accom p lished by imple m entation of storm water pollution control measures requ ired by the W D EQ/W QD and desc ribed in the Proposed Action. In addition, long-term control of surface runoff would be accomplished by successful imple m entation of the stabilization and reclamat ion operations described in the Proposed Action. Stabilization and reclamation procedures would be designed to reduce the susceptibility of disturbed areas to soil erosion inboth the short-term and for the li fe of the project. No additional

mitigation b e yond those already included in th e Proposed Action would be req u ired. The Proposed Action would not have sign ificant impacts on soil resources.

4.3.2 No Action Alternative

Under the No Action Alternative, the DOE woul d not fund the Proposed Action, construction of the demonstration wind turbine and associated f acilities would not occur, and existing impact s (e.g., erosion, etc) to soil resources in the project area would conti nue to occur at current rates.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 53

4.3.3 Mitigation and Monitoring
No additional mitigation or m o nitoring is recommended beyond the applicant-committed practices ide n tified in Chapter 2.
4.3.4 Residual Impacts
The Proposed Action would result in som e incr eased and unavoidable soil loss through wind and water erosion. Soils on approx imately 8.45 acres (i.e., temporary disturbance ar eas) would be

comp acted as a result of off-road vehicle traffic. Productivity of som e disturbed soils would be slightly reduced due to the comp action of soils; how ever, these impacts would be short-term (i.e., 3-5 years) and would be mitigate dby implemen tation of the recla m ation and stabilizatio n procedures.

4.4 THREATENED, ENDANGERED, PR OPOSED, AND CANDIDATE (TEP&C) SPECIES 4.4.1 Proposed Action

4.4.1.1 Black-footed Ferrets
No prairie dogs are known to occur with the pr oject area, and there have been no black-footed fe rrets sightings or signs have been documented within the project area. In addition , the projec t area is located outside of a ny areas requiring black-footed ferret surveys (USFWS 2004). Therefore, the Proposed Action would have no a dverse affects to black-footed ferrets.
4.4.1.2 Bald Eagle
Migrating b a ld eagles may occasion a lly forage o r fly through the project area; however, such use of the proje c t area is lik e ly intermittent and f or relatively short periods. There is a chance that bald eagles m i ght collide with the o p erating wi nd turbine o rthe m e teorological tow e r and guyFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 54

wires. However, given this inte rmittent use, the lack of nesting and roosting habitat in the imm e diate project area, and the lack of any ne w aboveground powerlines, it is anticipated that the Proposed Action m a y affect, but woul d not adversely aff ect, bald eagles.
4.4.1.3 Summary
Based on the discussion presented above and as sumi ng all appropriate mitigation measures are imple m ented, the Proposed Action would not have any significant impacts on any TEC&P species.

4.4.2 No Action Alternative

Under the No Action Alternative, the DOE woul d not fund the Proposed Action, construction of the demonstration wind turbine and associated faci lities would not occur, and impacts to TEC&P species would continue at present levels, with fluc tuations d u e primarily to weather, disease, and other natural causes.
4.4.3 Mitigation and Monitoring
No additional mitigation or m o nitoring is recommended beyond the applicant-committed practices ide n tified in Chapter 2.
4.4.4 Residual Impacts

Under the P r oposed Action, there would be a negligible increase in the risk of collisions of bald eagles with the proposed wind turbine and/or m e teorological tower. There would also be negligible addition a l impacts to any other TEC&P species that m a y occur in the project ar ea.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 55

4.5 VEGETATION RESOURCES
4.5.1 Proposed Action
Under the Proposed Action, less than 10 acres w ould be disturbed by c onstruction operations. Because less than 1.25 acres would be disturbed for the life-of-the-p roject for the construction of the wind turbine, service build ing, m e teorological tower, and cables and powerline, no topsoil would be removed or salvaged. Instead, wheeled vehicles that drive cros s-country would disturb the rem a ining 8.45 acres. Direct impacts woul d be limited to comp action/destruction of vegetation when construction equipment operates o ff any roads. These impacts m a y result in a limited increase in runoff, erosion, and sedim e ntation into any receiving waters. All disturbed vegetation would be of a kind that is common and widespread in the p roj ect area and vicinity.

Short-term control of surface runoff would be accom p lished by imple m entation of storm water pollution control measures requ ired by the W D EQ/W QD and desc ribed in the Proposed Action. In addition, long-term control of surface runoff would be accomplished by successful imple m entation of the stabilization and reclamat ion operations described in the Proposed Action. No addition a l mitigation beyond those already in cluded in the Proposed Action would b e required. Th e Proposed Action would not ha ve any significant impacts on vegetation.

4.5.2 No Action Alternative

Under the No Action Alternative, the DOE woul d not fund the Proposed Action, construction of the demonstration win dturbin e and associated facilities woul d not occur, and impacts to vegetation resources would continue to occur at curren trates

. 4.5.3 Mitigation and Monitoring
No additional mitigation or m o nitoring is recommended beyond the applicant-committed practices ide n tified in Chapter 2.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 56

4.5.4 Residual Impacts
The Proposed Action would result in long-term disturbance of 1.25 acres of vegetation and approxim a tely 8.45 acres of short-term vegetation disturbance. Once construction operations are updated, stabilization and reclamation operations would be conducted, and vegetation would be re-established on all but 1.25 acres

. Once the project has been decommi ssioned, all disturbed areas would be reclaim e d. These impacts assu me that the s i te w ould not be repowered.

4.6 VISUAL RESOURCES
4.6.1 Proposed Action
The Proposed Action would result in limited changes and impacts to existing visual resources and aesthetics of the general pro j ect area. The ge neral project area has already been altered by hum a n encroachm e nt including the PRPA M e di cine Bow W i nd Farm, the Elk Mountain to Medicine Bow unpaved road, and the W A PA a nd Carbon Power and Light powerlines. The existing PRPA Medicine Bow W i nd Farm domi nates the view of a nd from the project area. The 10 wind turbines, two m e teorological towers, se rvice building, and access roads are the m o st visible components. Th e turbine towers for th e seven existing wind turb ines (Vestas [brand] 660-kW units), located south of the service build ing, are 164-ft tall, and the m a xi mu m height at the top of each turbine blade is 241 ft. The turbine tower for the proposed demonstration wind turbine would be 262 ft high (approxim a tely 100 ft higher than the existing towers) and the

ma xi mu m height at the top of the blade woul d be approximately 410 ft(approximately 169 ft higher than the m a xi mu m height of the existing turbines). Th e proposedwind turbine would be taller than the existing turbines but would likely be only slightly m o re visible (because of the height) from a distance than the existing wind turbine s. The existing wind turbine towers an d blades are painted white, and the proposed wi nd turbine (tower and blades) would also be painted white. Wh ile approxim a tely 60% taller than the existing wind turbines, the proposed wind turbine would not dom i nate the local viewsh ed and would likely blend into the existing PRPA wind far m.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 57

The proposed wind turbine as viewed from th e unpaved Elk Mountain to Medicine Bow road would likely appear to be an additional and larger wind turbine tha t from a distance would blend in with the existing wind turbines. The proposed service building would be painted a desert tan color to blend into the existing env i ronment. Th e m e teorological tower would be a lattice design and would not be noticeable from more than 1 mi from the project area. Therefore, the Proposed Action would blend into the existing wind far m a nd would not domi nate the local viewshed. Nor would the Proposed Action dominate the viewshedbeyond 3 mi as the size difference between the proposed wind turbine and the existing wind tu rbines would appear less as the distance from the viewer increases. Inaddition, the Proposed Ac tion would not be visible from Medicine Bow, Rock River, McFadden, Arlington, Hanna, or El k Mountain

. No additional mitigation beyond those already included in the Proposed Action would be required. The Proposed A c tion would be a continuation of existing wi nd energy development in the ge neral area, would not attract additional or new attention, and would have nonsignificant impacts on visual resources and aesthetics.

4.6.2 No Action Alternative

Under the No Action Alternative, the DOE woul d not fund the Proposed Action, construction of the demonstration wind turbine and associa t edf acilities would not occur, and no addition al impacts to visual resources would occur.
4.6.3 Mitigation and Monitoring
No additional mitigation or m o nitoring is recommended beyond the applicant-committed practices ide n tified in Chapter 2.
4.6.4 Residual Impacts
The construction and operation of the Proposed Action w ould result in som e additional impacts to visual resources. Th e wind turbine would be the m o st visible component of the ProposedFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 58

Action. Vegetation would be compacted when ve hicles operate off-road, and these impacts would be visible for 2-4 years. Visual impacts would be mi nim i zed to the casual observer with the Proposed Actionbe ing located imm e diately adjacent to the existing PRPA wind farm. Impacts would continue for approximately 20 years until the wind turbine and associa t ed facilities are decommissioned, rem o ved, and the disturbed areas reclaim e d and revegetated.

4.7 WATER RESOURCES (SURFACE WATER INCLUDING WETLANDS)
4.7.1 Proposed Action
The Proposed Action would result in limited short- term impacts to surface water resources. Direct impacts would result from approxim a tely 10 acres of soil disturbance and excavation associated with construction of the pads f o r the wind turbine, m e teorolo g ical tower, and service building, from the construction of the access ro ad, and from compaction of vegetation and soil due to equipment operating off of e x isting acce ss roads. These actions would cause a limited increase in sedim e ntation and off-site channe l erosion. However, these impacts would be

mitigated by implementation of the storm water pollution prevention plan (TRC Mariah Associates Inc. 2004) and by pollution prevention m easures such as intercep tor ditches, sedim e nt traps / silt f e nces, water bars, and silt f e nces. Implementation of prompt reclamation and stabilization procedu r es presented in the Propose d Action would also mi ni mi ze potential impacts to surface w a ter resources. Ther e are no jurisdictional wetlands in the project ar ea; therefore, th e Proposed Action would not have any impacts on wetlands

. No additional mitigation beyond those already included in the Proposed Action would be required. The Proposed A c tion would have negligible short-term and no long-term im p acts on water quality and no short-term or longterm impacts on water q u antity to receivi ng waters or any surface water resources.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 59

4.7.2 No Action Alternative

Under the No Action Alternative, the DOE woul d not fund the Proposed Action, construction of the demonstration wind turbine and associated faci lities would not occur, and impacts to surface water resources would con tinue at current rates.
4.7.3 Mitigation and Monitoring
No additional mitigation or m o nitoring is recommended beyond the applicant-committed practices ide n tified in Chapter 2.
4.7.4 Residual Impacts
Even with the implementation of the Storm Wa te r Pollution Prevention Pl an, there would be a negligible short-term increase in s e dim e ntation during the construction/installation phase of the Proposed Action. However, there would no reduction in surface water flow due to the Proposed Action. Impacts that occur during the construc tion/installation phase of the Proposed Action would be pro-actively mitigated as discussed above. Compared to the construction phase, the annual rate of sedi me ntation w ould decrease during the operatio ns phase of the project. Following decommissioning and rem oval of the project and successf ul comp letion of permanent reclamation and stabilization operations, surface water quality would eventually return to preconstruction levels.

4.8 WILDLIFE
4.8.1 Proposed Action
Direct impacts to wildlife would result f r om the direct loss o f habitat d u e to th e construction/installation of project -related facilities and vegetati on com p action; displacem e nt of wildlife du e to d i stu rbance by p r oje ct -related a c tivities; direct m o rtality du e to construction

- andFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 60

operational-related activities; inc rea sed m o rtality due to poaching and harassment; and an increased likelihood of vehicle/animal collisions due to increased traffic. Becaus e the Proposed Action would be located imm e diately adjacent to the existing PRPA wind far m , the addition of the Proposed Action would not be likely to have any significant short- or long-term impacts on wildlife populations.

Constructio n/installatio n activitie s would like ly cause som e wildlif e spe c ies that curr ently utilize the p r oject area to temp orarily v acate the area (up to 0.5 mi or m o re) around the active area while construction operations are occurring. The temporary loss of big gam e habitat due to the construction related f aci lities a nd vegetation compaction would be mitigated by the fa ct tha tth e project area would be limited to less than 10 acr es, construction operations would likely require only 2 months to comple te, and applicant-comm itted measures included in the Proposed Action would m i ni mi ze surface distu rbance. Once construction o p erations have been completed, m ost affected species would like ly re-utilize the impacted portion of the project area.
4.8.1.1 Big Ga me
The project area is located incrucial winter/yea rlong range for pronghorn and winter/yearlong range for mule deer and elk. However, the Pro posed Action would directly impact less than 10 acres of native vegetation. During s e vere wint ers, crucial winter ranges are important because these areas can provide animals with exposedvegetation and topogr aphic protection from extremely harsh weather conditions. In additi on, crucial winter ranges are important in

ma intaining a self-sustaining population at or above W G FD population obj ectives over the long term

. During the 2-month construction period, there could be an indirect impact of the temporary displacement of pronghorn that would nor ma lly occupy the immediate project area. In addition to the project area, the temporary displacement coul d also include a 0.5-mi area around the project area or a to tal of 503 acres (0.79 mi 2 ).
The project area is located in a crucial winter/yearlong rangefor pronghorn that contains 361,000 acres (564 mi 2 ). There f ore, the construction/installa tion phase of the Proposed Action (that m ayFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 61

occur durin g a severe winter) could potentially displace p r onghorn from approximately 0.2% of the crucial winter big gam e range located in the general vicinity of the project area. It is expected that any displaced pronghorn would re locate to u n affected portions of the 564-mi 2 crucial winter/yearlong habitat that exists near the project area. Wh ile som e pronghorn m a y be temporarily displaced from the project area, the displacement would be temporary, would impact only 0.2% of the crucial winter/y earlong habitat within the general project area. To minimize potential impacts to pronghorn, construction acti vities would be limited during severe winter conditions. Specifically, Clipper would m a intain c ontact with local W G FD personnel, and if it is determined by W G FD t h at severe winter cond itions exist, Clipper would limit the number of construction vehic l es that would be allowed to access the site. In addition, Clipper would mi ni mi ze the amount of ti me personnel would be at the construction site. Reclamation and revegetation procedures would be followed to m i ni mi ze the long- term loss of habitat. The Proposed Action would not have a significant impact on the local pronghorn population.
If the project area does not experience a seve re winter during the construction phase, the Proposed A c tion could likely still result in th e temporary displacement of pronghorn from the project area and the 0.5-mi 2 buffer area (a total of 503 acres). However, the impacts would be less important becaus e the area contains yearlon g habitat, the animals would be under less stress than during a severe w i nter, a nd could easily move and find alte rnative areas for forage and cover. Therefore, the Proposed Action (if the construction phase does no t occur during a severe winter) would have negligible impacts to the pronghorn populati on in the herd unit. Once construction operations have been comp leted, pronghorn would likely acclimate to human disturbance and utilize habitat at near pr e- di sturbanc e le ve ls.

Mule deer and elk that ma y occur within the pr oject area and the 0.5-mi 2 buffer area m a y be temporarily displaced to other su itable habitats due to the c onstruction phase of the Proposed Action. If construction occurs during a severe winter, m a ny of the mu le deer and elk in the area will likely move to crucial winter r a nge that is located approxim a tely 1 m i southeast and 13 mi south of the project area, respectively. The Pro posed Action would not have direct or indirect impacts on any crucial winter ra nge for mu le deer or elk. On ce the 2-month construction phaseFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 62

is comp leted, mu le deer and elk would likely re-u tilize the unaffected portion of the project area. Therefore, the construction phase of the ProposedAction would have neg ligible impacts on mu le deer and elk populations.
Surveys of pronghorn, mule deer, and elk at SeaWest’s Foote Creek R im Wi nd Farm (located approxim a tely 9 mi south of the project area) conducted from 1995 th rough 1998 during the operational phase of this project ind i cate that abundance and distri bution of these species did not appear to be significan tly affected by the presence of the 183 turbine wind farm (Johnson et al. 2000). Therefore, the addition of the Proposed Action next to the existing PRPA wind far m would have only negligible impacts on pronghor n antelope, mu le deer, and elk during the operational phase of the project.
It is also possible the indivi dual pronghorn, mu le deer, and/or elk m a y be killed (an indirect impact) as a result of vehicular/ animal collisions on the 5-mi se gment of the Medicine Bow to Elk Mountain Road that would be associatedwith the Proposed Action. However, the anticipated level of traf fi c would be limited to less than 20 trips per day between the c o mmunity of Medicine Bow and the project area during the construction phase and less than four trips pe r day during the operational phase of the project. Maintenance personnel w ould also occasionally visit the project facilities during the operational phase of the Proposed Action. The level of traffic during the operational phase of the project would be similar to thatcurrently observed at the adjacent PRPA wind farm and would result in negligible impacts to pronghorn, mule deer, and elk.
Once the project has been terminated, the equipment decommissioned and removed, and reclamation and revegetation oper ations comp leted, pronghorn, mu le deer, and elk would be able to re-utilize all areas aff ected by the Proposed Action.
Based upon the small amount of disturbance, the limited amount of vehicu lar traffic during the project, and the appropriate im plementation o f reclamation a nd revegetation procedures, theFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 63

Proposed Action would result in nonsignificant short- and long-term impact s to local pronghorn, mule deer, and elk populations.

4.8.1.2 Other Mammals
Impacts to other m a mmals due to the Proposed Action would inclu d e direct mortality during construction activities, especially to those tha tma y take refuge in burrows that would be destroyed b y project-related activities, and a potenti al inc rea se in m o rtality f r om vehicle/ animal collisions. The relatively small a m ount of wil d life habitat i mpacted by the Proposed Action would result in limited impacts to all wildlife species. Most sm a ll m a mmal species are relatively tolerant of hum a n activity and likely would expe rience reduced populations in direct proportion to the amount of habitat destruction. This woul d be m o st likely true for species with relatively small hom e ranges (rodents, lagomorphs, etc.) a nd would be less appli cable to mo re wideranging species such as coyote. Project impacts to small m a mmals would likely be m a sked by natural variations in populations due to weather, disease, and othe r natural factors.
According to Young et al. (2003), at least four bat species w e re found dead near wind turbines at SeaWest’s Foote Creek W i nd Far m located approxim ately 9 mi south of the project area. The

ma jority--ap p roxim a tely 80%--were hoary bats, 9% were little brown bats, 8% were silverhaired bats, and 1% were big brown bats and 2% c ould not be identified. Most of the identified bat species likely nest and/or roost in aspe n trees, cottonwood trees, and abandoned buildings located near the wind farm

. The dead bats we re found primarily between June and September, with m o st of the bats found during August. No bat carcasses were f ound associated with the lattice m e teorological towers. Young et al. (2003) estim a ted annual mortality at 1.34 bats per wind turbine.

Bat m o rtality data collected by Young et al. (2003) at the Foote Creek W i nd Farm (located approxim a tely 10 m i south of the project area ) were based on 69 600-kilowatt Mitsubishi wind turbines that are smaller that the proposed Clipper dem o nstration wind turbine. The Clipper demonstration wind turbine would also have othe r design and operational differences comp aredFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 64

to the Mitsu b ishi wind turbines. The Mitsubishi wind turbines have a rotor and blade diameter of 138 ft, while the Clipper demonstration wind turbine would have a rotor and blade diameter of 305 ft. The Mitsubishi wind turbines have a blade sweep area of 14,950 ft 2 comp ared to th e sweep area of the Clipper dem onstration wind turbine of 73,024 ft 2 , an increase of alm o st fivefold.
Various factors likely influence the rate of bat a nd avian m o rtalities as a result of the operation of wind turbines such as blade sweep area, rotor s p eed, blade tip speed, height of the wind turbine, distance to topographic ridge s, position of the indi vidual turbine inthe turbine st ring, weather, distance to suitable habitat, fl ying height of the specific speci es, etc. (Young et al. 2003). It should be noted that no bat or avian m o rtality studies have been conducted at the PRPA Medicine Bow W i nd Farm (personal communi cation, October 20, 2004, with Paul W arila, PRPA, Fort Collins, C o lorado). In order to com p are potential bat moralities b e tween the Mitsubishi wind turbine to the Clipper wind turbin e, it is assum e d that all f act ors are constan t except for blade sweep area and th at the rate of bat m o rtalitie s would be based solely upon a

com p arison of the blade sweep area for each wind turbine model. This approach would likely result in a worst-case scenario since there is limited suitab l e nesting o rroosting habitat in the imm e diate project area comp ared to the Foote Creek Wi nd Farm

. It should also be noted that bat mortalities were only recorded a t approxim a tely 70% of the monitored w i nd tu rbines at the Foo te Creek W i nd Farm (Young et al. 2003). Therefor e, based on these assumptions, the proposed Clipper demonstration w i nd turbin e would result in approxim a tely 6.7 bat m o rtalities per year

comp ared to 1.34 bat mortalities per year for the small Mitsubishi wind turbines. As a result, the Proposed Action is not expectedto adversely impact any of the bat population in the area.
To document potential impacts to bat species, Clipper would conduc t mortality surveys near the wind turbines and m e teorological tower during the first sum mer season (June through September 2005) of operation of the Proposed Action. Th is period coincides with when bats typically utilize the g e neral project area and when bat mortalities were documented at the Foote Creek Wi nd Far m (Young et al. 2003). Cli pper would utilize m o rtality surv ey me thods similar to those developed for the nearby Foote Creek Ri m Wi nd Far m (Young et al. 2003). Personnel wouldFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 65

conduct one survey every 2 weeks, and each survey would involve walking transects established within 250 ft of each tower. S earch transects would be s e t appr oxim a tely 25-30 ft apart, and th e searcher would walk at a rate of approxim a te ly 2 mph along the transe ct searching both sides approxim a tely 12-15 ft for casualties out approxim a te ly 12-1 5 ft. Itis e s timated thatit should require 0.75 hour to survey both towers. For each casualty identified, data recorded would include species, sex, and age (when possible), date and time collected, location collected, condition, and any comments that m a y indicate the time and cause of death. All carcasses located would be photographed as found and m apped. If the species infor m ation cannot be determined, the carcass would be bagged and tr ansported to a qualified biologist for proper identification. At the end of the survey peri od, the data would be compiled, summarized, and submitted to the DOE, USFWS, and W G FD.
Rare habitats (e.g., springs, wetlands, and riparian areas) would not be impacted (because none occur in the project area), and applicant-committed practice s to m i nim i ze impacts to wildlif e would mitigate and reduce impacts to other animals. There f ore, the P ro posed Action would not have any significant impact s on other m a mmal species.
4.8.1.3 Raptors
Direct impacts to raptors include mo rtality due to collisions with the wind turbine and

me teorological tower. Other potential impacts to nesting raptors incl ude decreased raptor reproductive success due to the physi cal d i stu rbance of the n e st o rto increased hum an activities near the nest; destruction of nest, egg, and/or young; increased predation of the eggs or young; and impacts to hunting, foraging, and roosting habitat (National Wildlife Federation 1987) and all these would be illegal under the Migratory B i rd Treaty A ct (U.S.C. 703 [1918]). No raptor nests were documented within 1.0 mi of the project area; how ever, there are five rapto r nests/eyries within 2.0 mi of the proposed project area (ref e r to Figure 3.6). There is no historic nest occupancy or productivity data from any of this nests/eyries. Given the distance from the project area to the nests, it is un likely that individual nesting raptors or raptor populations wouldFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 66
be impacted by the Proposed Action; however, indi vidual birds could be ki lled as a result of flying into the rotating wind turbine blades.
No site-specific raptor mortality s tudies have been conducted at the PR PA wind farm. A single dead golden eagle was found in 2003 near the one of the PRPA wind t u rbines and the incident was reported to the USFWS. No other raptor m o rtalities have been d o cum e nted at the PRPA wind farm since the facility was constructed in 1998 (pers onal communication, October 28, 2004, with Bill Young, PRPA WindSite Support Engineer, Medicine Bow, W y om i ng).
According to Young et al. (2003), there were only five reported raptor mo rtalities (which accounted for 8% of the avian m o rtalities) betw een Novem ber 1998 and June 2002 (3.5 years) at the monitored portion of Sea W est’s Foote Creek W i nd Far m located approxim a tely 9 m i south of the pro j ect area. The rem a ining 92% of the avia n m o rtalities were passerine birds. Raptor mortalities were low during the s tudy despite high raptor use estim a tes at the site. For example, no golden eagle m o rtalities were recorded during th e study despite the fact tha t go lden eag l es accounted f o r approximately 40% of all raptor use of the area. On the other hand, use of the study area by American kestrels acc ounted for only 5% of the total raptor use, but accounted for 60% of the raptor carcasses found in the area. Five raptor carcasses we re found--three American kestrels, one northern harrier, and one short-ea red owl--during the 3.5-year study period. There were no recorded raptor m o rtalities associated with any of the m e teorological towers. Young e t al. (2003) estimated there was an average of 0.03 raptor m o rtalities per wind turbine per year.
Raptor m o rtality data collectedby Young et al. (2003) at the F oot Creek Wind Farm (located approxim a tely 10 m i south of the project area ) were based on 69 600-kilowatt Mitsubishi wind turbines that are smaller that the proposed Clipper dem o nstration wind turbine. The Clipper demonstration wind turbine would also have othe r design and operational differences comp ared to the Mitsu b ishi wind turbines. The Mitsubishi wind turbines have a rotor and blade diameter of 138 ft, while the Clipper demonstration wind turbine would have a rotor and blade diameter of 305 ft. The Mitsubishi wind turbines have a blade sweep area of 14,950 ft 2 comp ared to th eFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 67

sweep area of the Clipper demonstr ation wind turbine would be 73,024 ft 2 an increase of al mo st five-fold.
Various factors likely influence the rate of raptor mo rtalities as a result of the operation of wind turbines such as blade sweep area, rotor speed , blade tip speed, height of the wind turbine, distance to topographic ridge s, position of the indi vidual turbine inthe turbine st ring, weather, distance to suitable habitat, fl ying height of the specific speci es, etc. (Young et al. 2003). It should be noted that no bat or avian m o rtality studies have been conducted at the PRPA Medicine Bow W i nd Farm (personal communi cation, October 20, 2004, with Paul W arila, PRPA, Fort Collins, Colorado). In order to co mpare pote n tial rap t or mortalities between th e Mitsubishi wind turbine to the Clipper wind turbin e, it is assum e d that all f act ors are constan t except for blade sweep area and that the rate of raptor m o rtalities would be based solely upon a

com p arison of the blade sweep area for each wind turbine model. This approach would likely result in a worst-case scenario since there is limited suitab l e nesting o r roosting habitat in the imm e diate project area com p ared to the Foote C r eek W i nd Farm

. It should also be noted that avian m o rtalities were o n ly recorded at approxim ately 67% of the monitored wind tur b ines at th e Foote Creek W i nd Farm (Young et al. 2003). Therefore, base d on these assumptions, the proposed Clipper demonstrati on wind turbine would result in approxim a tely 0.15 raptor mortalities per year compared to 0.03 raptor mo rtalities per year f o r the s m aller Mitsubishi wind turbines. As a result, the Proposed Action is not expected to adversely impact any of the raptor populations in the area.
To document potential impacts to raptor species , Clipper would conduct mortality surveys near the wind turbine and m e teorologi cal tower during the f i rst 1 2 -m onth period of operation of the Proposed Action. Clipper would utilize m o rtality survey m e thods similar to those developed for the nearby Foote Creek Ri m Wind Far m (You ng et al. 2003). Personnel would conduct one survey every 2 weeks, and each survey would invol ve walking transects established within 250 ft of each tower. Search transect s would be set approxim a tely 25- 30 ft apart, and the searcher would walk at a rate of approxim a tely 2 mph along the transect sear ching both sides out approxim a tely 12-15 ft for casualties. It is estimated that it should require 0.75 hour to surveyFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 68

each tower. For each casualty identified, data recorded would include species, s e x, and age (when possible), date and time collected, loca tion collected, condition, and any comments that

ma y indicate the tim e and cause of death. All carcasses located would be photographed as found and m apped. If the species information cannot be determined, the carc a ss would be bagged and transported to a qualified biologis t for proper identification. At th e end of the survey period, the data would be comp iled, summarized, and sub mitted to the DOE, USFWS, and W G FD. The USFWS would be notified immediately by telephone if carcasses of raptors or other species of concern were located at any time during turbine operation.
As described in Chapter 2.0 of the EA, electri cal components of the Proposed Action would be designed, constructed, operated, and m a in taine din conform a nce with the National Electrical Safety Code and other applicable codes and standards. In additi on, all aboveground electrical facilities would also be design ed, constructed , operated, and m a intained in accordance with Suggested P r actices for Raptor Protection on Po werlines: The State of the Art in 1996 (Avian Power Line Interaction Committ ee 1996). Implementation of thes e standards would reduce the risk of raptor electro cutions with powerline structures. The USFWS guideline recommend grouping wind turbines (i.e., avoid si ting individual wind turbines) to reduce potential impacts to raptors and placing wind turbines away from ri dges and away from prairie dog colonies (USFWS 2003). The Proposed Action comp li es with these guidelines.

Construction activities would di stu rb less than 10 acres; therefor e, reductions in prey species abundance would be mi ni ma l and are not anticipat ed to adversely affect raptor populations. Foraging habitat for raptors within the proj ect area would be redu ced until revegetation successfully attra c ts small m a mmals and birds that serve as the pre y base f o r the rapto r s. Therefore, the Proposed Action would not ha ve any significant impacts on raptors.
4.8.1.4 Upland Ga me Birds
The Proposed Action would result inthe disturbance of less than 10 acres of native vegetation; however, this a m ount of disturbance is unlikely to have an adverse affect on greater sage-grouse,Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 69

although it is possib l e the ind ivi dual greater sage-grou s e m a y be killed as a result of vehicular/bird collisions on the 5-m i segment of the Medicine Bow to Elk Mountain Road. However, the anticip a ted lev e l of traffic w ould be less than 20 trip s per day between the community of Medicine Bow, and the project ar ea during the constructi on phase and less than four trips per day during the operational phase of the project. In addition, m a intenance personnel would also occasion a lly visit th e project facilities during the ope rational phase of the Proposed Action. The level of traffic duri ng the operational phase of the pr oject would be si milar to that currently observed at the adjacent P R PA wind farm , and potential vehicle/b i rd collisions would result in negligible impacts to g r eater sage-grouse.
According to Young et al. (2003), no greater sage-grouse mortalitie s were recorded at either the wind turbines or m e teorological towers during the 3.5-ye ar m onitoring period at SeaWest’s Foote Creek Rim wind farm

. Therefore, great er sage-grouse would not be impacted (by collisions with the m e teorologi cal tower or wind turbine).

Noise levels associated with the P r oposed Action would likely increase from a maximum of 60 dBA (under windy natural conditions with th e existing Medicine Bow W i nd Farm) to 105 dBA with the addition of the proposed Clipper wind turbine. However, these noise levels would occur only during periods when th e wind is blowing at least 18 mph and the wind turbine is operating. Male greater sage-grouse perform a courtship display in the early m o rning hours (typically before 8 a.m

. ) from March through May. Male greater sage -grouse strut, fan their tail feathers, and produce a popping sound by inflating and deflating air sacs in the neck to attract fe ma les. Yeo et al. (1984) determined that th ere was no decrease in greater sage-grouse lek attendance due to the construction or operation of a large wind tu rbine generators located ne ar the Foote C r eek W i nd Farm

. In addition, variati ons in lek attendance could not be directly attributed to the presence of the wind turbine generators (Yeo et al. 1984). Therefore, noise from the Proposed Action would likely have negligib le impacts on greater sage-grouse.
The construction of the Clipper wi ndturbine could also adv e rsely affect nesting of greater sagegrouse near the pro j ect area. After the courtship period, approxim a tely two-thirds of the fem a leFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 70

greater sage-grouse nest within 3 m i of where they were bred(WGFD 2003a). Therefore, the project area and the existing Me dicine Bow W i nd Farm would be located within greater sage

grouse nesting habitat, and this area could have already been impacted by the construction and operation of the existing wind far m. Connelly et al . (2000) noted that nest success is better in areas where the greater sage-grouse nest in sage brush that is between 16 and 32 inches tall; sagebrush that tall is not found within the project area. As a result, the Proposed Action would like l y have negligible addition a l impacts on nesting greate rsage-grou s e.

To mi nimi ze potential impacts to a c tive greater sa ge-grouse leks during the construction of the Proposed Action, Clipp e r would not conduct any su rface-d i sturbing activities within 0.25 m i of any active lek during the greater sage-grouse ma ting season between February 1 and May 15. In addition, in order to minimize potential impacts to nesting greater sage -grouse, no surfacedisturbing activities would be conducted within 2 mi of any active lek between April 1 and July 1 witho u t permissio n fr om the W G FD. Recl amation a c tivities would be conducted prior to April 1, unless prior permissi on is obtained from WGFD.
Mourning doves would likely be impacted in dir ect proportion to the amount of suitable habitat that is disturbed by the P r oposed Action. There would be negligible im pacts on m o urning dove population because only 10 acres would be d i sturb e d by the Proposed Action. In addition , Young et al. (2003) documented only one mourning dove mo rtality at either the wind turbines o r
me teorological towers during the 3.5-year m on itoring period at SeaWest’s Foote Creek Rim wind far m. This represents les s than 0.5% of the total recorded m o rtalities.
4.8.1.5 Other Birds (Including Migratory Birds)
According to Young et al. (2003) passerine birds and other non-raptor species ac counted for 92% of the avian m o rtalitie s recorded at wind turbines and 100% of the avian m o rtalities at

me trological towers at the monitored portion of SeaWest’s Foote Creek W i nd Farm located approximately 9 mi south of the project area. A total of 37 s p ecies was killed and approxim a tely half of the species were nocturnal m i grants. Fo r example, approxim a tely 29% of the fatalitiesFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 71

were horned lark, 7% w e re vesper sparrow, 5% were chipping sparrow, and 5% were Brewer’s sparrow. Species such as rock wren, hous e wren, Wilson’s warbler, American robin, Townsend’s warbler, green-trailed towhee, wh ite-crowned sparrow, mountain bluebird, Lincoln’s sparrow, cliff swallow, and brown creeper were documented between 2% and 4% of the total m o rtalities. The rem a ining 22 species e ach repre s ented less than 2% of the total species mortalities d o cum e nted at the Foote Creek wind far m.
Young et al. (2003) estim a ted that there was an average of 1.46 passerine m o rtalities per wind turbine per year and an average of 8.1 passerine mortalities per me teorological tower per year.

Passerin e bird m o rtality data collected by Young et al. (2003) at the Foote Creek W i nd Far m (located approxim a tely 10 m i south of th e project area) were based on 69 600-kilowatt Mitsubishi wind turb ines that are smaller that the proposedClipper demonstrat ion wind turbine. The Clipper demonstration wind turbine w ould also have other design and operational differences comp ared to the Mits ubishi wind tur b ines. The Mitsub ishi wind turbines have a roto r and blade diameter of 138 ft, while the Clipper demonstration wind turbine would have a rotor and blade diameter of 305 ft. The Mitsubishi wind turbines have a blade sweep area of 14,950 ft 2

comp ared to the sweep area of the Clipper demonstrati on wind turbine would be 73,024 ft 2 , an increase of alm o st five-fold.
Various factors likely infl uence the rate of avian mortalities as a result of the operation of wind turbines, such as b l ade sweep area, rotor spee d, blade tip speed, heightof the w i nd turbine , distance to topographic ridge s, position of the indi vidual turbine inthe turbine st ring, weather, distance to suitable habitat, fl ying height of the specific speci es, etc. (Young et al. 2003). It should be noted that no bat or avian m o rtality studies have been conducted at the PRPA Medicine Bow W i nd Farm (personal communi cation, October 20, 2004, with Paul W arila, PRPA, Fort Collins, Colorado). In order to comp are potential passerine bird m o rtalities between the Mitsubishi wind turbine to the Clipper wind turb ine, it is assum e d that all facto r s are constan t except for blade sweep area and that the rate of bird m o rtalities would be based solely upon a

com p arison of the blade sweep area for each wind turbine model. This approach would likelyFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 72

result in a worst-case scenario since there is limited suitab l e nesting o r roosting habitat in the imm e diate project area com p ared to the Foote C r eek W i nd Farm

. It should also be noted that avian m o rtalities were o n ly recorded at approxim ately 67% of the monitored wind tur b ines at th e Foote Creek W i nd Farm (Young et al. 2003).

Therefore, based on these assump tions, the prop osed Clipper demonstration wind turbine would result in approxim a tely 7.3 passerine bird m ort al ities per year comp ared to 1.46 passerine bird mortalities p e r year f o r the smaller Mitsubishi wi nd turbines. The estim a ted num b er of passerine bird m o rtalities assoc i ated with th e me teorol ogical tower would be e xpected to be similar (8.1 passerine birds per year) to that documente d by Young et al. (2003) at the Foote Creek W i nd Farm

. Therefore, the P r oposed Action would like ly result in approxim a tely 15.4 passerine bird mortalities p e r year as a result of the m e teorological tower and wind turbine.

To docum en t potential impacts to passerine species, Clipp e r would conduct m o rtality surveys near the win dturbine and m e teorolo g ical tower during the first 12-month period of operation of the Proposed Action. Clipper would utilize m o rtal ity survey m e thods similar to those developed for the nearby Foote Creek Rim Wind Plant (Young et al. 2003). Perso nnel would conduct one survey every 2 weeks, and each survey would invol ve walking transects established within 250 ft of each tower. Search transect s would be set approxim a tely 25- 30 ft apart, and the searcher would walk at a rate of approxim a tely 2 mph along the transect sear ching both sides out approxim a tely 12-15 ft for casualties. It is es timated that is should re quire 0.75 hour to survey each tower. For each casualty identified, data recorded would include species, s e x, and age (when possible), date and tim e collected, location co llection, condition, a nd any comments that

ma y indicate the tim e and cause of death. All carcasses located would be photographed as found and m apped. If the species information cannot be determined, the carc a ss would be bagged and transported to a qualified biologis t for proper identification. At th e end of the survey period, the data would be comp iled, summarized, and subm itted to the DOE, US FWS, and WGFD.
Additional impacts would probably occur in direct proportion to the amount of a species' habitat that would be disturbed. Som e in creased mo rtality would also be li kely f r om bird collision s as aFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 73

result of increased vehicle traffic. Di sturb a nc e would be approxim a tely 10 acres, and measure s already des c ribed above to mitigate surface disturbances and project-related activities would mi ni mi ze impacts to other bird sp ec ies as well. Impacts to wate rfowl and shoreb irds would be mi ni ma l because few areas of suitable habitat would be affected and because these birds would temporarily move to adjacent h abitats undistu rbe d by constru c tion. Oth e r birds would also move to suitab l e adjacent h abitats. Therefore, the P r oposed Action would n o t have any significant impacts on the populations of other birds (including mi gratory birds).
4.8.1.6 Amphibians, Reptiles, and F i sh
Impacts to amphibians and reptiles due to th e Proposed Action likely would occur in direct proportion to the amount of their habitat dis turb e d. Applicant-committed practices describ e d in the Proposed Action to mi ni mi ze surface d i sturbance and to ensure tim e ly reclamation and stabilization would m i nimi ze project-related impact s to amphibians and reptiles. Som e reptiles and amphibians could be killed in vehicle/an imal collisions, but s u ch impacts would be negligible. The applicant-committed practices describ e d in the Proposed Action to mi ni mi ze surface dis turbance and ensure timely reclam ation and stabilization would m i ni mi ze projectrelated impacts to fish that o ccur in Medicine Bow River. Th erefore, the Proposed Action would not have any significant impacts on amphibians, reptiles, and fish.
4.8.1.7 Summary
Direct impacts to wildlife would result f r om the direct loss o f habitat d u e to th e construction/installation of project-related facilities and vegetation com p action, displacem e nt of wildlife due to disturbance by proj ect -related activities, direct m o rt ality due to construction- and operational-related activities, increased m o rtal ity due to poaching a nd harassment, and an increased likelihood of vehi cle/animal collisions du e to increased traffic. In addition, som e avian individuals would be killed as a result of collisions with the r o tating wind turbine bla d es or with the m e teorological tow e r. No addition a l mitigation beyond those already included in the Proposed Action would be required. Despite the potential temporary displacement of big gam eFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 74

individuals during construction/installation of the Proposed Ac tion and the m o rt alities of individual avian species during operation of th e Proposed Action, the Proposed Action would not result in any significant impacts to wildlife populations.

4.8.2 No Action Alternative

Under the No Action Alternative, the DOE woul d not fund the Proposed Action, construction of the demonstration wind turbine and associated faci lities would not occur, and wildlife (i.e., big gam e , other m a mmals, raptors, upland gam e bird s, other birds, and amphibians, reptiles, and fish) populations would continue atpresent levels, with fluctuati ons due primarily to weather, disease, hum a n i m pacts (e.g., the P R PA wind farm), and other natural causes.
4.8.3 Mitigation and Monitoring
No additional mitigation or m o nitoring is recommended beyond the applicant-committed practices ide n tified in Chapter 2.
4.8.4 Residual Impacts
The Proposed Action would result in direct impacts such as disturbance of less than 10 acres of wildlife habitat, including cruc ial winter/yearlong range for pr onghorn and the mortality of a limited number of individual raptors, bats, and passe rine and other birds. Constructio n activities would occur over a 2-month period of time and reclamation and revegetation operations would be conducted upon the decommiss i oning and remova l of the various project facilities and equipment. Som e individual bird or animal species would be destroyed as a result of vehicle/animal collisions. In light of the fa ctthat the Proposed Action would result in the addition of a single wind turb ine and meteorological tower immedi ately adjacent to the existing PRPA wind far m , the Proposed Action would result in nonsignificant residua l impacts to wildlife

resources.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 75

4.9 CUMULATIVE I M PACTS

Cumu lative impacts result f r om the incremental impact s of an action that is added to other past, present, and reasonably foreseeable future acti ons, regardless of who is responsible for such action s. Cumulative impacts m a y result f r om i ndividually mi nor, but co llectively significant, actions occurring over a period of tim e (40 C.F.R. 1508.7). All environmental resources have been evalu a ted for cumula tive impacts in accordance with DOE and CEQ policy (CEQ 1997).
The general project area has been utilized co ntinuously for agricultura l purposes (livestock grazing) and oil and g a s develop m ent since the early 1900s. In addition, coal mi ning (the Carbon Basin surface and underground coal m i ne [approved but not operating]) and wind energy development projects (the exis ting Foote Creek and PRPA wind farms and the approved but not constructed Sim p son Ridge wind farm) are present within the general p r oject area. The Foote Creek W i nd Farm currently ha s 183 wind turbines, and an a dditional 857 wind tu rbines have been autho r ized for construction but have not been constructed at the Simpson Ridge site (BLM 1995). There are also num e rous paved and unpaved roads located within the general project area (including Interstate 80, U.S. Highway 30/ 287, State Highway 487, County Road 72, and the Medicine B o w to Elk Mountain Road). In additi on, utility corridors (s uch as transmission and distribution powerlines and various na tural gas p i peline s ) and the communities of Medicine Bow and Elk Mountain are also located within the gene ral project area (refer to Figure 4.1). Despite these f aci lities, the natural environ m ent withina m a jor p o rtion of the gener a l p r oject ar ea
rem a ins largely unaffected by hum a n-related acti vities, and the existing developm en t does not appear to having any significant imp acts on the existing environment.

There are n o other large-scale industrial or commercial devel opments such as quarrying or mi ning oper a tions, logging activities, oil and ga s development activities, wind developmentsFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 76

This figure is a separ ate file Fig 4-1.pdf.

Figure 4.1 Existing and Authorized Projects in th e General Project Area.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 77

(except for the PRPA Medicine Bow wind far), or other industrial developments within 3 mi of the project area. In addition, the DOE is unaware of any planned or reasonab ly foreseeable future actions within the general project area that would contribute a ny cumulative impacts.
The Proposed Action would involve the construc tion/installation, operation, and after 20 years the removal of a single 2.5-MW wi nd turbine, a 240-ft tall meteor ological tower, a small service building, and associated undergr ound powerlines and cables. The Proposed Action would be located imm e diately adjacent (within 800 ft) of PRPA’s existing Medicine Bow Wi nd Farm. W ithin this facility, the r e are 10 larg e commerc ial wind turbines, two m e teorological towers, a service building and out-buildings, powerlines, and a substation. There are no other existing, proposed, or planned commercial or industrial projects within the general project area. In addition, there are no plans for expansion of the M e dicine Bow W i nd Farm (personal communication, October 20, 2004, with Paul W arila, PR PA, Fort Collins, Colorado). It has been determined that cumu lative impacts would not be significant because there are no past, present, or reasonable foreseeable future actions that, when com b ined with the P r oposed Action, would result in impacts beyond those that already exist or have already been identified and discussed in Chapter 4.0 of this EA. Ther efore, non-significant cumulative impacts to all environmental resources would be anticipated from the implementation of the Proposed Action.

4.10 IRREVERSIBLE AND I R RETRIEVA BLE COMMITMENT OF RESOURCES

An irrever s ible and irretrievab l e commitment of resources is defined as a permanent reduction or loss of a resource that, on ce lost, cannot be regained. The primary irrev e rsible and irretrievab le commit me nt of resources due to the Proposed Action would be labor, m a terials, and energy expended utilized to construc t the Proposed Action. Other irreversible and irretrievable commit me nts of resources would include soil lo st through wind and wate r erosion; loss of productivity (i.e., forage and wildlife habitat) from lands involved in project; inadvertent or acciden t al d e struction of unident ified cultural resources; and loss of animals due to mortality by collisions with vehicles, the m e teorol ogical tower, and the wind turbine.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 78

4.11 SHORT-TERM USE OF THE ENVI RONMENT VERSUS LONG-TERM PRODUCT I VITY For purposes of this E A , short-term use of the environment is tha t us e during the life of the project (i.e., approxim a tely 20 year s), whereas long-term productivity refers to the period of ti me after the pro j ect has b e en decommissioned and th e equipment has been removed and the area is reclaim e d and stabilized. Short-term use of environment would not affect the long-term productivity of the proposed project area. Afte r project has been comple ted, the equipment and facilities decommissioned and removed, and all disturbed areas reclaim e d and stabilized, the

sam e resources that were present p r ior to the pro j ect would b e available. It m a y take 5-7 years after the p r oject has been comp leted for som e of the impacted and reclaim e d areas to have vegetation cover and biodiversity com p arable to predisturbance conditions. However, reclamation would eventually provide conditions to support wildlife and livestock. Use of the proposed project area during the lif e of the project would not precl ude the subsequent short- or long-term use of the area for any purpose for which it was suitable prior to the project.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 79

5.0 RECORD OF PERSONS, GROUPS, AND GOVERNME NTA L AGE N CIES CONTACTED Table 5.1 Record of Persons, Groups, a nd Governm e ntal Agencies Contacted.

Co mp any/Agency Ind ividual Discipline/Positio n Project Proponen t – Clip per Tom Feiler Project Manager Wi ndpower, Inc. Eli Bosco Project Manager Lea d er U.S. Fis h and Wild life Service, Brian Kel ly Field Supe rvis or , Wy omi ng F i eld Office Wy omi ng Office Kathl een Erwi n Staff B i ol ogis t State of Wy om i ng Wy omi ng De part me nt of Park s and Ju dy Wolf Deputy State Histo r ic Preserv a tio n Officer Cultural Resources Wy omi ng De part me nt of Barb Sahl NPDES Storm Water Permit Specialist Env i ron m ental Quality Wyomin g Game an d Fish Dep artm ent Bill W i chers Deputy Directo r Wy omi ng Nat u ral Diversi ty Dat abase Terra Du tche r Datab a se Specialist

Table 5.2 List of Preparers.

Firm /Company Nam e EA Respo nsib ility TRC Mariah Associates Inc.

Depart me nt of Energy Scott Kam b er
Jam e s Lowe Ro ge r Scho um acher Gen i al DeCastro Tam ara Lin se Beth Ri nt z Suzanne Lu hr

Mau r een Jordan Steve Blazek Ro sel le Dr ahushas-C row Joh n Kerst en Kristin Kerwi n Alan Laxs on Project Man a ge ment , EA Preparation , and Quality C ontrol EA Preparation -Cu ltural Resources EA Preparation

- Quality Assurance Docu ment Prod uc tion and Quality Co ntro l Techn i cal Editing, Docu ment Production Doc ume nt Pr o duct ion CADD Specialist

DOE/ N REL Sen i or En vi ronmental Scientist DOE/ N REL NEPA Manager DOENEPA Do cum e nt Ma nager DOE Ma nage r DOENEPA Coor dinato r DOE/ NR EL Project ManagerFinal EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 80

6.0 REFERENCES

Avian Power Line Interaction Committee. 1996. S uggested practices for raptor protection on power lines: The state of the art in 1996. Edison Electric Institu te/Raptor Research Foundation. Wa shington, D.C. 125 pp. Baxter, G.T. and Stone M.D. 1995. Fishes of Wyoming. Wyoming Gam e and Fish Departm e nt, Cheyenne, Wyoming. 290 pp. Blackstone, Jr., D.L. 1988. Traveler's guide to the geology of W y oming. Geological Survey of Wyoming, Bulletin 67. Larami e, Wyoming. 130 pp. Bureau of Land Managem e nt, 1995. Final environmental impact statem en t for the Kenetech/PacifiCorp windpower project. U.S. Departm e nt of the Interior, Bureau of Land Managem e nt, Rawlins, W y omi ng. 64 pp.

. 1998. Draft Carbon Basin co al project environmental impact statement, U.S. Departm e nt of the Interior, Bureau of Land Managem e nt, Rawlins District. 276 pp. + append.

. 1999. Final environmental impact statemen t for the Carbon Basin coal project. U.S. Departm e nt of the Interior, Bureau of Land Managem e nt, Rawlins, W y oming. 58 pp.

. 2003. Unpublished data, geographic info rm ation system

. Bureau of Land Managem e nt, Rock Springs Field Office.

. 2004. Draft programmatic environmental impact statement on wind energy development on BLM-admi nistered lands in th e western United Stat es, U.S. Departm e nt of the Interior, Bureau of Land Mana gem e nt, Washington, D

. C. 382 pp. + append. Bureau of Reclamation. 1979. Negative determin ation of significant environmental impacts; system verification units, wind energy proj ect, Wyoming (NDN79-4). U.S. Departm e nt of the Interior, Bureau of Reclamation, Denver, Colorado. Call, M.W

. 1978. Nesting habitats and surveyin g techniques for common we stern raptors. U.S. Departm e nt of the Interior, Bureau of Land Managem e nt, Technical Note No. 316. 115 pp. Casper-Star Tribune. 2004. Shirley Basin ferret nu mb ers grow. Story by the Associated Press, dated October 13, 2004. <http://www.caspers tartribune.net/articles/2004/10/13/news/ wyoming/4ef59f481725433287256f2b005cdb81.txt>. Accessed on October 27, 2004. Clark, T.W

. , and M.R. Strom b erg. 1987. Mamma ls in Wyoming. University of Kansas, Museum of Natural History, Public Education Series No. 10. 314 pp.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 81

Connelly, J.W., M.A. Schroeder, A.R. Sands, and C. Braun. 2000. Guidelines to m a nage sage grouse populations and their habitats. W ildlife Society Bulletin 28:968-985. Council on Environmental Quality. 1997. Consid ering cumulative effects under the National Environmental Policy Act. Executive Office of the President, Council on Environmental Quality, W a shington, D.C. 64 pp. + append. Departm e nt of Energy. 1993. Recomm e ndations for the preparation of environmental assessments and environmental impact statements. U.S. Departm e nt of Energy, Environment, Safety and Health, Of fice of NEPA Policy and Assistance. <http://ww w .eh.doe.gov/nepa/gu ida nce.htm l #other>. Accessed on October 26, 2004.

. 1994. Environmental assessment checklist. U.S. Departm e nt of Energy, Environm en t, Safety and Health, Office of NEPA Po licy and Assistance. <http://www.eh.doe.gov/ nepa/guid an ce.htm l #other>. Accessed on October 26, 2004.

. 1998. E ffective public participation under the National E nvironmental Policy Act. U.S. Departm e nt of Energy, Environment, Sa fety and Health, Office of NEPA Policy and Assistance, Washington, D.C. 38 pp. Dorn, J.L., and R.D. Dorn. 1990. Wy oming bi rds. Mountain West Publishing, Cheyenne, Wyoming. 139 pp. Edwards, C.C. 1969. Wi nter behavior and popul ation dynami cs of Amer ican eagles in Utah. Ph.D. dissertation, Brigham Young University, Provo, Utah. 156 pp. Federal Emergency Managem e nt Agency. 2002. Flood hazard map, map center point: - 109.09020, 41.61870. <http://mapserver2.esri.co m>. Access October 27, 2004. Fertig, W

. 1994. Wyoming rare plant guide. The W y om i ng Rare Plant Technical Committee. 157 pp. Forrest, S.C., T.W

. Clark, L. Richardson, and T. M. Ca mpbell III. 1985. Black-footed ferret habitat: Som e ma nagem e nt and r e introducti on considerations. Wy oming Bureau of Land Managem e nt Wildlife Technical Bulletin No. 2. 49 pp. Frison, G.C. 1991. Prehistoric hunters of the hi gh plains. Academic Press, Inc. New York, New York. 532 pp. Johnson, G.D., D.P. Young Jr., W. P. Erickson, C.E. Derby, M.D. Strickland, R.E. Good. 2000. Final report, wildlife monitoring studies, SeaWest windpower project, Carbon County, Wyoming, 1995-1999. We stern EcoSystem s T echnology, Inc., Cheyenne, W y oming. 35 pp. + append.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 82

Knight, D.H. 1994. Mountains and plains: The ecology of Wyoming landscapes. Yale University Press, New Haven, Connecticut. 338 pp. Lageson, D.R., and D.R. Spearing. 1998. Ro adside geology of Wyoming. 2nd Edition. Mountain Press Publishing Com p an y, Missoula, Montana. 271 pp.
Madison Gas and Electric. 2004. Wi nd Far m F acts. <http://www.m g e.com / environment/wind/ windfar m_ facts.htm >. Accessed on Nove mb er 11, 2004. Martner, B.E. 1986. Wyoming clim atic atlas. University of Nebraska Press, Lincoln, Nebraska. 432 pp. Munn, L.C., and C.S. Arneson. 1998. Soils of Wyoming: A digital statewide m ap at 1:500,000. Report B-1069. University of W y oming College of Agriculture, Agricultural Experim e nt Station, Laram i e, W y oming. 34 pp. National Renewable Energy Labor atory. 2002. Wi nd power toda y; taking advantage of low wind speeds – the advancing technology. U.S. Departm e nt of Energy, National Renewal Energy Laboratory. <http://ww w .nrel .gov/d o cs/fy02osti/31583.pdf>. Access e d on Nove mb er 5, 2004. National Wildlife Federation. 1987. Raptor m a nagem e nt techniques m a nual. National Wildlife Federation Scientific and Technical Series N o. 10. Port City Press, Inc., Baltimore, Maryland. 420 pp. Peterson, A. 1986. Habitat suitabi lity index models: Bald eagle (breeding season). U.S. Fish and Wildlife Service Biologi cal Report 82(10.126). 25 pp. Platte River Power Authority. 2000. Environm ental survey report, wind energy project, Medicine B o w, W y om i ng. Platte River Power Authority, Fort Collins, Colorado. 9 pp. + append. Rau, J.G., and D.C. Wooten. 1980. Environmen tal impact analysis handbook. McGraw Hill, Inc., New York, New York. 656 pp. Sheets, R.G., R.L. Linder, and R.B. Dahlgren. 1972. Food habits of tw o litters of black-footed ferrets in South Dakota. Ameri can Midland Naturalist 87:249-251. Snow, C. 1973. Habitat m a nagem e nt series for endangered species. Re port No. 5: Southern bald eagle ( Haliaeetus leucocephalus leucocephalus ) and northern bald eagle ( H.l. alascanus ). U.S. Departm e nt of the Interior , Bureau of Land Managem e nt, Technical Note No. 171. 58 pp.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 83

Soil Conservation Service. 1988. High plains southeast, Wyoming r a nge descriptions, field office technical guide. U.S. Departm e nt of Agriculture, Natural Resource and Conservation Service, Wa shington, D.C. 76 pp. Spackm a n, S., B. Jennings, J. Cole, C. Dawson, M. Monton, A. Kratz, and C. Spurrier. 1997. Colorado rare plant field guide. Pr epared for the Bureau of Land Managem e nt, U.S. Forest Service, and U.S. Fish and Wildlif e Service by the Colorado Natural Heritag e Program, Fort Collins, C o lorado. Steenhof, K. 1978. Management of wintering bald eagles. U.S. Fish and Wildlife Service FWS/OBS-78/79. 59 pp.
TRC Mariah Associates Inc. 2004. A Class III Cultural Res ource Inventory for the Proposed Clipper W i ndpower Wind Turbine and relate d Facilities, Carbon County, W y oming. Prepared for Clipper W i ndpower, Inc. and th e U.S. Departm e nt of Energy. Larami e, Wyoming. 6 pp.
U.S. Fish and Wildlife Service. 1989. Black-foot ed ferret survey guidelines for compliance with the Endangered Species Act

. U.S. Fish and Wildlife Service, Denver, Colorado, and Albuquerque, New Mexico. 10 pp. + append.

. 1991. National W e tland Inventory m aps. Cheyenne, Wyoming.

. 1997. National W e tlands Inventory data fo r portions of Wyoming: Spatial Data and Visualization Center, Laram i e, W yoming. <http://www.n w i.fws.gov/Maps/maps.htm >. Accessed on October 28, 2004.

. 2003. Interim guidance on avoiding and mi ni mi zing wildlife impacts from wind turbines. U.S. Fish and Wildlife Service, W a shington, D.C. 55 pp.

. 2004. Le tter from Brian Kelly (Field Su pervisor, Wyoming Field Office) to John Kersten (Department of Energy, Golden Colorado) in response to a scoping of the proposed Medicine Bow De m onstration W i nd Turbine Project. USFWS letter num b er ES-61411/W.02/ WY8800. U.S. Geological Survey. 1996. Final report, W y oming gap analysis: A geographic analysis of biodiversity prepared in cooperation with the Wyoming Cooperative Fish and Wildlife Research U n it and University of W yoming, Larami e, Wyom i ng. 109 pp.

. 2000. W yoming surface-water quality data for water year 2000. <http://wy-water.usgs. gov.projects/QW /htm s /qwpage00.htm >
. Accessed Nove mb er 2004.

. 2004. Wyoming surface-water quality data for water year 2002. <http://wy-water.usgs. gov.projects/QW /htm s /qwpage00.htm >
. Accessed on October 28, 2004.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 84

Wyle Laboratories. 1971. Community noise. Pr epared for the U.S. Environmental Protection Agency, Report No. NTID300.3. Washington, D.C. 203 pp. Wyoming Departm e nt o f Environm en tal Quality, Wa ter Quality Div i sion. 1990. Wa ter quality rules and regulations, Chapter 1: Quality standards for W y oming surface waters. Cheyenne, Wyoming. 24 pp. + append.

. 2000. Wyoming’s 2000 305(b) state water quality assessment report. Cheyenne, Wyoming. 8 pp. + append.

. 2001. Wyoming's 2000 305(b) State water quality assessment report. Cheyenne, Wyoming. 8 pp. + append.

. 2004. Wyoming’s 2002 303(d) waters requiring TMDs. Cheyenne, Wyoming. 8 pp. + append. Wyoming Ga me and Fish Departm e nt. 1991. Wy omi ng trout stream classification m ap. Wyoming Gam e and Fish Departm e nt, Cheyenne, W y oming.

. 1997. Black-footed ferret. Wyoming Ga me and Fish Departm e nt Conservation Publication, Volum e 13, Num b er 8. 3 pp.

. 1999. Atlas of birds, m a mmals, reptil es, and a mphibians in W y oming. Wyoming Ga me and Fish Departm e nt, Wildlife Division.

. 2002. Annual report of upland ga me a nd furbearing harvest 2000. Che y enne, Wyoming. 100 pp.

. 2003a. Wyoming greater sage-grouse cons ervation plan. Wy oming Ga me and Fish Departm e nt, Cheyenne, Wyoming. 97 pp.

. 2003b. Big gam e herd unit and range, sage grouse lek GIS shapefile Information. Wyoming Gam e and Fish Departm e nt, Geograp hic Information Sciences and Services, Cheyenne, Wyoming. Unpublished data.

. 2004. Annual big gam e herd unit reports, 2003. Lara mi e region. W yoming Game and Fish Departm e nt, Cheyenne, W y om i ng. Wyoming Geological Survey. 1996. Final report, W y oming gap analysis: A geographic analysis of biodiversity prep ared in cooperation with the W yoming Cooperative Fish and W ildlife Research Unit and the Universi ty of Wyoming, Laram i e, Wyomi ng. 109 pp. Wyoming Natural Diversity Database. 2004. Data com p ilation for TRC Mariah Associates Inc. comp leted 10/28/04. Unpublished Report. Wyoming Natural Diversity Database, University of W y oming, La ram i e, Wyoming. 24 pp.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 85

Yeo, J., A.F. Reeve, P. MacLar en, and A.L. Travsky. 1984. Me dicine Bow wind energy project, wildlife stu d ies, f i nal report. Wy om i ng Ga me and Fish Department, Cheyenne, Wyoming, and University of W y omi ng, Larami e, W y oming. 151 pp. Young, D.P., W

. P. Erickson, R.E. Good, M.D. Strickland, and G.D. Johnson. 2003. Final report; avian and bat mortality associated w ith the initial phase of the Foote Creek Rim windpower project, Carbon County, W y om i ng. Western Ecosystems Technology, Inc., Cheyenne, Wyoming. 35 pp. + append.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project

APPENDIX A: COPIES OF PUBLIC SCOPING LETTERS

### Department of Energy Golden Field Office 1617 Cole Boulevard Golden, Colorado 80401-3305 ERRATA

for the ENVIRONMENTAL ASSESSMENTFOR THE

PROPOSEDCLIPPER WINDPOWER, INC. LOW WIND SPEEDTURBINE DEMONSTRATION PROJECT1 CARBON COUNTY, WYOMING

Page 15 Paragraph2, the first sentenceis removedandreplacedwith thefollowing: "Construction equipmentand personnelwould accessthe project site south from Medicine Bow, via the Elk Mountain to Medicine Bow road to a seriesof existing unpavedprivate access/serviceroads located immediately adjacentto and within the Medicine Bow Wind Project (refer to Figure 2.2). Once equipmentreachesthe existing Medicine Bow Wind Project, traffic would travel on a service road located next to the existing wind turbines. To minimize vehicle traffic at the actual project site, construction employeeswould park at the PRPA control building parking lot and would be shuttled by other pickup trucks to the actual work site. No other accessroads are available, would be constructed, or utilized to accessthe project area. Since the project requires only the construction/installation of one wind turbine, one meteorological tower, and associatedfacilities, the construction/installation phaseof the ProposedAction would involve a limited amount of equipment and personnel. Typical construction equipmentwould include a road grader, trackhoe, front-end loader, concretetrucks, two cranes,a flatbed truck, rough-terrain forklift, trailer mounted electric generator,and two or three pickup trucks. Becauseof the remote location of the project area, not all equipment would be on-site at the sametime and would only be brought to the site when required for specific tasks. Construction and installation operationswould begin with survey work that would be completed in approximately 2 days by surveyors with one pickup truck. The service building for the ProposedAction (i.e., trailer) would then be delivered and installed on site in approximately 1 day. Site preparation and excavationwould then be conducted. Concretewould be delivered to the site from a small portable concrete batch plant that would be setupfor 7 days in a previously disturbed areanear the existing Medicine Bow Wind Project. The concrete supplier would immediately remove the batch plant upon completion of the concrete deliveries. The site preparation and excavation activities would be completed within 20 days. The wind turbine, meteorological tower, and associatedequipment



# ~ FederalRecyclingProgram* PrintedonRecycledPaper

# . would then be installed over a period of approximately 14days. Nine round-trips would likely be required to transport the major components (e.g., tower, blades,nacelle, hub, etc) to the site. Final site grading and cleanupwould then be conductedusing available equipment. Clipper anticipates that construction and installation operations would require a total of 2 to 3 round trips per day by pickup trucks used by supervisors from Medicine Bow to the project site. Construction/installation of the ProposedAction would require approximately 2 months to complete starting in January2005, with activity levels fluctuating basedon the tasks describedabove."
Page21 After the lastparagraph,insertthefollowing newbulletedparagraphs: "To document raptor use of the immediate project area, Clipper would conduct surveys for raptors and other large birds utilizing methods and protocols presentedin Thomas etat. (1997) and utilized at the nearby Foote Creek Rim Windpower Project (Johnsonet al. 2000). The surveyswould utilize observationcircles (eachwith a 0.5-mi radius) that would be monitored during the first 12-monthperiod of operation of the ProposedAction. All surveyswould be conducted by qualified and trained biologists and detailed surveymethods would be included in a surveyprotocol document that would be prepared for the project and submitted to DOE, USFWS, and WGFD for review and comment." "To documentpasserinebird useof the immediate project area, Clipper would conduct surveys for passerineand other small birds during the spring of 2005 utilizing methods and protocols utilized at the nearbyFoote Creek Rim Windpower Project (Johnson et al. 2000). The surveys would utilize transectline(s) with point count stations established on the transect(s). Thesesurveyswould be conducted three times during the breeding season(May 15 though July 31) during the first 12-monthperiod of operationof the ProposedAction. All surveyswould be conducted by qualified and trained biologists and detailed surveymethodswould be included in a survey protocol document that would be prepared for the project and submitted to DOE, USFWS, and WGFD for review and comment." Page61 Secondparagraph, after secondsentence,insert "The phasedconstruction plan described under "page 15" above on this Errata would likely further minimize construction-related impacts to pronghorn by minimizing the level of construction activity on the site at any given time."



# .Page64 Secondparagraph,secondto last sentenceending with "wind turbine" insert the following "(refer to Table 4.1 for detailed infomlation)" after the word "turbine."

After the secondparagraph,insertthefollowing newtable. Page 64

Table4.1 MeasuredandEstimatedWildlife Mortalities.

Basedonaveragemortalitiespresentedin Young etal. (2003)for a FooteCreekRim projectarea thatis locatedwithin 10mi of the site of theProposedAction.

2 Estimatesarebasedonthe specificationsof the Clipperdemonstrationwind turbinethathasa blade sweepareafive times largerthanbladesweepareafor thewind turbineslocatedatthe Foote CreekRim WindpowerProject. Therefore,for thepurposeof this analysismortalitiesfor the ProposedAction areassumedto be 5 timesgreaterthanthosedocumentedatthe FooteCreekRim WindpowerProject. Theproposedmeteorologicaltowerwould be similar in designto meteorologicaltowerslocatedattheFooteCreekRim WindpowerProject. TheProposedAction would includeonewind turbineandonemeteorologicaltower. Page 64 After Table4.1 insertthefollowing: "Results of raptor use surveyspresentedin the BLM (1995) and Johnson et al (2000) for the Foote Creek Rim project area,indicate that raptor use was lowest for areasthat were located on top of the rim (i.e., away from the rim) on flat and open terrain (i.e., areasthat are similar to the proposed project area)." last paragraph, last sentencestarting with "Personnel would. removed and replaced with the following: tower" is Page 64"The frequency of the mortality surveys would be basedon the results of seasonalcarcassremoval surveyconducted at the beginning of spring, summer, fall, and winter. The protocol for the carcassremoval surveys would follow proceduresdescribed in Young et al. (2003). Each mortality survey would involve walking transectsestablishedwithin 325 ft of each tower. All surveyswould be conducted by qualified and trained biologists and detailed survey methodswould be included in a survey protocol document that would be prepared for the project and submitted to DOE, USFWS, and WGFD for review and comment." Page67 Secondparagraph,secondto last sentenceending with "wind turbines" insert the following "(refer to Table 4.1 for detailed information)" after the word "turbines." Page67 After the secondparagraph,insertthefollowing newparagraph. "To document raptor use of the immediate project area, Clipper would conduct surveys for raptors and other large birds utilizing methods and protocols presentedin Thomas et al. (1997) and utilized at the nearby Foote Creek Rim Windpower Project (Johnsonet al. 2000). The surveys would utilize observationcircles (each with a 0.5-mi radius) that would be monitored during the first 12-monthperiod of operation of the Proposed Action. All surveyswould be conducted by qualified and trained biologists and detailed surveymethods would be included in a survey protocol document that would be prepared for the project and submitted to DOE, USFWS, and WGFD for review and comment." After the first paragraph,insertthefollowing: Page67 "Given the flat topography, lack of topographic features,and the lack of suitable nesting habitats and breeding areasfor most raptors in the immediate project area, raptor use of the project areais expectedto be less than that found at the Foote Creek Rim Windpower Project area. However, it is reasonable(and even conservative)to usethe results of the Foote Creek Rim mortality surveys asthe basis for estimating impacts to raptors from the ProposedAction."
last paragraph,third sentencestarting with "Personnel would. tower" is removed and replaced with the following: Page67
"The frequency of the mortality surveys would be basedon the results of seasonalcarcassremoval survey conducted at the beginning of spring, summer, fall, and winter. The protocol for the carcassremoval surveys would follow proceduresdescribed in Young et al. (2003). Each mortality survey would involve walking transectsestablishedwithin 325 ft of eachtower. All surveyswould be conducted by qualified and trained biologists and detailed survey methodswould be included in a surveyprotocol document that would be prepared for the project and submitted to DOE, USFWS, and WGFD for review and comment."
Page68 After the first paragraph,insertthefollowing: "Migration routes are determined more by the availability of and changes in local food suppliesthan by any other environmental factor (Welty and Baptista 1988). Therefore, since food supplies for avian specieswithin the project areaare limited compared with other areasin the vicinity, the project areaavian specieswould not likely be located within any local migratory corridors for raptors or passerinebirds. While specific migratory movementpatternshave not beendetermined for the project area,previous studies in the generalareaindicate that migratory routes appearto be strongly correlatedto year-round avian use (BLM 1995; Johnsonet al. 2003; Young et a12003, Thomas et al. 1997). While some avian speciesmay forage in the project area it is unlikely that they would spend much time in an area that produceslimited opportunities for securing food sources(Welty and Baptista 1988). Therefore, impacts to migratory specieswould be lessthan significant and are unlikely to result in detrimental impacts to populations of any migratory bird."
Page71 After the third paragraph, insert the following: "Given the flat topography, lack of topographic features, and the lack of suitable nesting habitats and breeding areasfor most passerinebirds in the immediate project area,passerinebird use of the project areais expected to be lessthan that found at the Foote Creek Rim Windpower Project area. However, it is reasonable(and even conservative)to usethe results of the Foote Creek Rim mortality surveys asthe basis for estimating impacts to passerinebirds from the ProposedAction."

Page 72 Secondparagraph, last sentenceending with "wind turbine" insert the following "(refer to Table 4.1 for detailed information)" after the word "turbine." Page72 After the secondparagraph,insertthefollowing newparagraph. "To documentpasserinebird use of the immediate project area, Clipper would conduct surveys for passerineand other small birds during the spring of2005 utilizing methods and protocols utilized at the nearby Foote Creek Rim Windpower Project (Johnsonet al. 2000). The surveys wouldutilize transectline(s) with point count stations establishedon the transect(s). Thesesurveys would be conductedthree times during the breeding season(May 15 though July 31) during the first 12-monthperiod of operation of the ProposedAction. All surveyswould be conducted by qualified and trained biologists and detailed survey methods would be included in a surveyprotocol documentthat would be prepared for the project and submitted to DOE, USFWS, and WGFD for review and comment." Page72 last paragraph,third sentencestarting with "Personnelwould removed and is replaced with the following: is
"The frequency of the mortality surveyswould be basedon the results of seasonalcarcassremoval surveys conducted at the beginning of spring, summer, fall, and winter. The protocol for the carcassremoval surveys would follow proceduresdescribed in Young et al. (2003). Each mortality survey would involve walking transectsestablishedwithin 325 ft of each tower. All surveyswould be conducted by qualified and trained biologists and detailed surveymethods would be included in a survey protocol document that would be prepared for the project and submitted to DOE, USFWS, and WGFD for review and comment." Page72 After thethird paragraph,insertthefollowing: "Migration routes are determined more by the availability of and changes in local food suppliesthan by any other environmental factor (Welty and Baptista 1988). Therefore, since food supplies for avian specieswithin the project areaare limited compared with other areasin the vicinity, the project areaavian specieswould not likely be located within any local migratory corridors for raptors or passerinebirds. While specific migratory movementpatternshave not beendetermined for the project area,previous studies in the generalareaindicate that migratory routes appearto be strongly correlatedto year-round avian use (BLM 1995; Johnsonet al. 2003; Young et a12003, Thomas et al. 1997). While some avian speciesmay forage in the project area it is unlikely that they would spend much time in an area that produceslimited opportunities for securing food sources(Welty and Baptista 1988). Therefore, impacts to migratory specieswould be lessthan significant and are unlikely to result in detrimental impacts to populations of any migratory bird."
Page83 After the Steenhofreference,insertthefollowing newreference: "Thomas, D.M., J.M. Ward, and R. Pickering. 1997. Baseline Avian Studies for the ProposedSeaWest Energy Corporation Wyoming Wind Plant, TRC Mariah Associates,Laramie, Wyoming."

.tower"Page84 Beforethe Wyle laboratoriesreference,insertthefollowing new reference: "Welty, l.C., andL. Baptista. 1988. TheLife of Birds, fourthedition. SaundersCollegePublishing,New York, New York. 581 pp+ append."Final EA, Clipper Windpower, Inc. Low Speed Turbine Demonstration Project 3

Figure 1.1 Location of Project Area.Final EA, Clipper Windpower, Inc. Low Speed Turbine Demonstration Project 10

Figure 2.1 Layout of Medicine Bow Low W i nd Speed Turbine Facilities.Final EA, Clipper Windpower, Inc. Low Speed Turbine Demonstration Project 11

Figure 2.2 Location of Existing Development near the Project Area.Final EA, Clipper Windpower, Inc. Low Speed Turbine Demonstration Project 14

Figure 2.3 Low W i nd Speed Turbine.Final EA, Clipper Windpower, Inc. Low Speed Turbine Demonstration Project 16

Figure 2.4 Location of Underground Powerline.Final EA, Clipper Windpower, Inc. Low Speed Turbine Demonstration Project 28

Figure 3.1 Location of Project and PRPA W i nd Turbines.Final EA, Clipper Windpower, Inc. Low Speed Turbine Demonstration Project 39

Figure 3.2 Surface W a ter Features near the Project Area.Final EA, Clipper Windpower, Inc. Low Speed Turbine Demonstration Project 42

Figure 3.3 Pronghorn Ranges near the Project Area.Final EA, Clipper Windpower, Inc. Low Speed Turbine Demonstration Project 44

Figure 3.4 Raptor Nest Locations near the Project Area.Final EA, Clipper Windpower, Inc. Low Speed Turbine Demonstration Project 46

Figure 3.5 Greater Sage-grouse Leks near the Proposed Project Area.Final EA, Clipper Windpower, Inc. Low Speed Turbine Demonstration Project 76

Figure 4.1 Existing and Authorized Proj ects in the General Project Area.Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project

APPENDIX A: COPIES OF PUBLIC SCOPING LETTERS,

United

In ReplyReferTo: ES-61411/W.O2/WY8800
John Kersten Department of Energy Golden Field Office 1617 Cole Boulevard Golden, Colorado 80401-3305
Dear Mr. Kersten: States Department of the
FISH AND WILDLIFE SERVICE Ecological Services 4000 Airport Parkway Cheyenne, Wyoming 82001 Interior
~5 ~

~--- --. ;'It $- -

NOV 102004

This is regarding your October 21, 2004, notice of the proposed low-speed wind turbine demonstration project located in section 1, T21N, R79W in Carbon County, Wyoming. The project includes one 262-foot tall wind turbine and associatedfacilities such as a 240-foot tall meteorological tower, 400 square foot building, and underground electric lines. You have requested comments regarding this project to be used in the preparation of your environmental assessment. Federal Agency Responsibilities In responseto the notice, the U.S. Fish and Wildlife Service (Service) is providing you with comments on (1) threatened,endangeredand candidate species,(2) migratory birds, (3) wetlands and riparian areas,and (4) sensitive species,including petitioned species. The Service provides recommendations for protective measuresfor threatenedand endangeredspeciesin accordance with the EndangeredSpeciesAct (Act) of 1973, as amended, 16 U.S.C. 1531 et seq. Protective measuresfor migratory birds are provided in accordancewith the Migratory Bird Treaty Act (MBTA), 16 U.S.C. 703 and the Bald and Golden Eagle Protection Act (BGEPA), 16 U.S.C. 668. Wetlands are afforded protection under Executive Orders 11990 (wetland protection) and 11988 (floodplain management), as well as section 404 of the Clean Water Act. Other fish and wildlife resourcesare considered under the Fish and Wildlife Coordination Act, 48 Stat. 401, as amended, 16 U.S.C. 661 et seq., and the Fish and Wildlife Act of 1956, as amended,70 Stat. :' 1119,16 U.S.C. 742a-742j. ~~ ,..-J

~ The Department of Energy (DOE) and their non-federal representativesshould work with the (, Service in developing surveys, impact minimization measures,and conservation measuresfor all

, Ii fede~allylisted species..If any proposed project.may affec.ta listed ~pecies,consultation wit~ the ",?' Service pursuant to section 7(a)(2) of the Act wtll be required. SectIon 7 (a)(l) of the Act directs federal agenciesto utilize their authorities in furtherance of the purposesof the Act by carrying out programs for the conservation and recovery of listed species. Therefore we encouragethe ( DOE to incorporate measuresinto project design for the conservation of listed species.In accordancewith section 7 of the Act, my staff has determined that the following threatenedor endangeredspecies,or speciesproposed for listing under the Act, may be present in or near the project area. We would appreciatereceiving information as to the current status of each of these specieswithin the project area.
SPECIES Bald eagle (Ha/iaeetus /eucocepha/us) Black-footed ferret (Muste/a nigripes)
Ute ladies'-tresses (Spiranthes di/uvia/is) STATUS Threatened

Experimental /Nonessential
Threatened HABITAT Found throughout state

Shirley Basin/Medicine Bow Reintroduction site Seasonally moist soils and wet meadows of drainages below 7000 feet elevation. If the proposed action may lead to consumptive use of water in the Colorado River System or the Platte River System, impacts to threatened and endangeredspecies inhabiting the downstream reachesof these systemsshould be included in the evaluation. Colorado River fish Endangered Downstream riverine habitat of the Yampa, Green and Colorado river systems Platte River species Endangered Downstream riverine habitat of the Platte River in Nebraska Bald eagle: While habitat loss still remains a threat to the bald eagle'sfull recovery, most experts agreethat its recovery to date is encouraging. Adult eaglesestablish life-long pair bonds and build huge nests in the tops of large trees near rivers, lakes, marshes,or other wetland areas. Although bald eaglesmay range over great distances,they usually return to nest within 100 miles of where they were fledged. During winter, bald eaglesgather at night to roost in large mature trees, usually in secludedlocations that offer protection from harsh weather. Bald eaglesoften return to use the samenest and winter roost year after year. In order to reduce potential adverseeffects to the bald eagle, a disturbance-free buffer zone of 1 mile should be maintained around eagle nests and winter roost sites. Activity within 1 mile of an eagle nest or roost may disturb the eaglesand result in take. The notice indicates that the wind turbine may be in existence for up to 20 years. The Service recommendsthat extensive site specific information be collected regarding the potential for bald eaglesto "Usethe project areaor areasadjacent to it. We recommend that the wind turbine and associatedfacilities be sited to ensureimplementation of an appropriate protective buffer for bald eagle nests and roost sites. Black-footed ferret: Reintroduction ofblack-footed ferrets has occurred in the Shirley Basin/Medicine Bow ManagementArea (SBMB) in southeasternWyoming (USFWS, 1991). The SBMB population is designatedas experimentaVnon-essentialaccording to provisions under section 100) of the Act and is treated as a proposed species. However, this designation indicates that the loss of the SBMB population will not jeopardize the continued existence of the

2~
black-footed ferret. The proposed project site is not located within the primary management zone for the SBMB population. However, the geographic boundaries of this population extend beyond the primary managementzone to include areasof Wyoming that are south and east of the North Platte River in Natrona, Carbon and Albany Counties. Ifwhite-tailed prairie dog towns or complexes (primary prey species for ferrets) will be affected by this project we recommend that you contact this office for guidance on project analysis methodologies and/or ferret surveys. We encourageyou to consider the extensive time and energy that has been expendedto reintroduce ferrets to a small part of their historical range and that you exercise due care to ensure that black-footed ferrets are not negatively affected by this project. According to the Federal Register notice (USFWS, 1991) ferret injuries or mortalities are required to be reported immediately to the Service. There will be no penalties if it is determined that the injury or death was unavoidable, unintentional and did not result from negligent conduct. Ute ladies'-tresses: Ute ladies'-tresses(Spiranthes diluvialis) is a perennial, terrestrial orchid, 8 to 20 inches tall, with white or ivory flowers clustered into a spike arrangementat the top of the stem. Spiranthes typically blooms from late July through August; however, depending on location and climatic conditions, it may bloom in early July or still be in flower as late as early October. Spiranthes is endemic to moist soils near wetland meadows, springs, lakes, and perennial streamswhere it colonizes early successionalpoint bars or sandy edges. The elevation range ofknown occurrences is 4,200 to 7,000 feet in alluvial substratesalong riparian edges, gravel bars, old oxbows, and moist to wet meadows. Soils where Spiranthes have been found typically range from fine siltlsand, to gravels and cobbles, aswell as to highly organic and peaty soil types. Spiranthes is not found in heavy or tight clay soils or in extremely saline or alkaline soils. Spiranthes seemsintolerant of shadeand small scatteredgroups are found primarily in areaswhere vegetation is relatively open. Surveys should be conducted by knowledgeable botanists trained in conducting rare plant surveys. Spiranthes is difficult to survey for primarily due to its unpredictability of emergenceof flowering parts and subsequentrapid desiccation of specimens. The Service does not maintain a list of "qualified" surveyors but can refer those wishing to become familiar with the orchid to experts who can provide training or services. Colorado River water depletions: Formal consultation is required for projects that may lead to depletions of water to the Colorado River system. Federal agencyactions resulting in water depletions to the Colorado River system may affect the endangeredBonytail (Gila elegans), Colorado pikeminnow (Ptychocheilus lucius), Humpback chub (Gila cypha), and Razorback sucker (Xyrauchen texanus) downstream in the Green and Colorado river systems. In addition, depletions may contribute to the destruction or adversemodification of designatedcritical habitat for these four species. In general, depletions include evaporative lossesand/or consumptive use of surface or groundwater within the affected basin, often characterizedas diversions less return flows. Project elementsthat could be associatedwith depletions include, but are not limited to, ponds (detention/recreation/irrigation storage/stock watering), lakes (recreation/irrigation storage/municipal storage/power generation), reservoirs (recreation/irrigation storage/municipal storage/power generation), hydrostatic testing of pipelines, wells, dust abatement,diversion structures, and water treatment facilities. Any actions that may result in a water depletion should

3be identified. The document should include: an estimate of the amount and timing of average annual water use (both historic and new uses)and methods of arriving at such estimates; location of where water use or diversion occurs as specifically as possible; if and when the water will be returned to the system; and what the water is being used for. Note that if the project has peculiarities or oddities, the Service may have more specific questions regarding the potential consumptive use of water. Platte River water depletions: Water depletions to the Platte River system may affect the federally listed whooping crane (Crus americana), interior least tern (Sterna antillarum), piping plover (Charadrius melodus), pallid sturgeon (Scaphirhynchus albus), bald eagle (Haliaeetus leucocephalus), Eskimo curlew (Numenius borealis), and western prairie fringed orchid (Platanthera praeclara). In addition, depletions may contribute to the destruction or adverse modification of desi~ated critical habitat for the whooping crane and the northern Great Plains breeding population of the piping plover. Depletions include evaporative lossesand/or consumptive use, often characterizedas diversions from the Platte River or its tributaries less return flows. Project elementsthat could be associatedwith depletions to the Platte River system include, but are not limited to, ponds (detention/recreation/irrigation storage/stock watering), lakes (recreation/irrigation storage/municipal storage/power generation), reservoirs (recreation/irrigation storage/municipal storage/power generation), created or enhancedwetlands, hydrostatic testing of pipelines, wells, diversion structures,dust abatement,and water treatment facilities. Any actions that may result in a water depletion to the Platte River system should be identified. The document should include: an estimate of the amount and timing of average annual water use (both historic and new uses)and methods of arriving at such estimates; location 'ofwhere water use or diversion occurs as specifically as possible; if and when the water will be returned to the system; and what the water is being used for. Note that if the project has peculiarities or oddities, the Service may have more specific questions regarding the potential consumptive use ofwater. Candidate Species The Service has determined that sufficient information exists to propose the western boreal toad (Bufo boreas boreas) as a candidatespeciesfor listing under the Act. However, the proposal to list is currently precluded by higher priority listing actions. The boreal toad occurs in the mountains of southeastWyoming. Many federal agencieshave policies to protect candidate species from further population declines. We would appreciatereceiving information on the status of this speciesin or near the project area. In addition, if the boreal toad is listed prior to completion of the project, unnecessarydelays may be avoided by considering project impacts to candidatesnow. Sensitive Species - Federal agenciesare also encouragedto consider sensitive speciesor speciesat risk in project review. Your consideration of thesespeciesis important in preventing their inclusion on the EndangeredSpeciesList. The Wyoming Natural Diversity Databasemaintains the most current information on sensitive plants in Wyoming. The databasemust charge for data retrieval to financially support the databaseand staff. The staff can be contacted at (307) 766-5026.

4Migratory Birds Under the MBT A and the BGEPA, the DOE has a mandatory obligation to protect the many speciesof migratory birds, including eaglesand other raptors that may be affected by projects under their authority. The MBT A, enacted in 1918, prohibits the taking of any migratory birds, their parts, nests, or eggs except as permitted by regulations and does not require intent to be proven. Section 703 of the Act states,"Unless and except as permitted by regulations ...it shall be unlawful at any time, by any means or in any manner, to ...take, capture, kill, attempt to take, capture, or kill, or possess...any migratory bird, any part, nest, or eggs of any such bird..." The BGEPA, prohibits knowingly taking, or taking with wanton disregard for the consequencesof an activity, any bald or golden eaglesor their body parts, nests,or eggs,which includes collection, molestation, disturbance, or killing. The Service recommends that the DOE use the best available technologies to determine if migratory birds will be negatively affected by the proposed project. This may entail surveys, review of data from the adjacent wind farm, breeding bird survey data, and contacting other agenciesor birding groups before the project moves forward. In addition to surveys for avian specieswe suggestyour surveys include bats as well. In order to promote the conservation of migratory bird populations and their habitats, the Service recommends the DOE implement those strategiesoutlined within the Memorandum of Understanding directed by the President of the U .S. under the Executive Order 13186, where possible. Sage Grouse The Service has received severalpetitions to list the greater sage-grouse(Centrocercus urophasianus) under the Act. The causesfor the greater sage-grouserangewide decline are not completely understood and may be influenced by local conditions. However, habitat loss and degradation, as well as loss of population connectivity are important factors (Braun 1998, Wisdom et a1.2002). Greater sage-grouseare dependenton sagebrushhabitats year-round. Therefore, any activities that result in loss or degradation of sagebrushhabitats that are important to this speciesshould be closely evaluated for their impacts to sagegrouse. If important breeding habitat (leks, nesting or brood rearing habitat) is present in the project area,the Service recommendsno project-related disturbance between March 1 and June 30, annually. Minimization of disturbance during lek activity, nesting, and brood rearing is critical to sage grouse survival. We recommend you contact the Wyoming Game and Fish Department to identify important greater sage-grousehabitats within the project area,and appropriate mitigative measuresto minimize potential impacts from the proposed project. The Service recommends surveys and mapping of important greater sage-grousehabitats where local information is not available. The results of these surveys should be used in project planning, to minimize potential impacts to this species. No project activities that may exacerbatehabitat loss or degradation should be permitted in important habitats. Wetlands and Riparian Areas The Service recommendsmeasuresbe taken to avoid wetland lossesin accordancewith Section 404 of the Clean Water Act, Executive Order 11990 (wetland protection) and Executive Order 11988 (floodplain management)as well as the goal of "no net loss ofwetlands." If wetlands may

5be destroyed or degradedby the proposed action, those (wetlands) in the project area should be inventoried and fully described in tenus of functions and values. Acreage ofwetlands, by type, should be disclosed and specific actions outlined to minimize impacts and compensatefor all unavoidable wetland impacts. Project components of seismic actions that may have potential negative impacts to wetlands and riparian areasmay occur from vehicular traffic through these sensitive areasresulting in erosion and degradation of vegetation. We appreciateyour efforts to ensurethe conservation of endangered,threatened,and candidate speciesand migratory birds. If the scopeof the project is changed, or the project is modified, in a manner that you detenuine may affect a listed species,this office should be contacted to discuss consultation requirements pursuant to section 7(a)(2) of the Act. If you have further questions regarding our comments or your responsibilities under the Act, please contact Kathleen Erwin at 307-772-2374 extension 28 for wind power projects proposed within Wyoming.

Sincerely,
~bg (¥D-, Brian T. Kelly ~ Field Supervisor Wyoming Field Office

References Braun, C.E. 1998. Sagegrouse declines in western North America: What are the problems? Proceedingsof the Western Association ofFish and Wildlife Agencies 78:139-156 U.S. Fish and Wildlife Service. 1989. Black-footed ferret survey guidelines for compliance with the EndangeredSpeciesAct, Apri11989. U. S. Fish and Wildlife Service, Denver, , Colorado and Albuquerque, New Mexico. 15pp. U.S. Fish and Wildlife Service. 1991. Endangeredand threatenedwildlife and plants: establishment of a nonessentialexperimental population ofblack-footed ferrets in southeasternWyoming. Federal Register/ Vol. 56, No. 162/ Wednesday,August 21, 1991 (41473). Wisdom, M.j., B.C. Wales, M.M. Rowland, M.G. Raphael, R.S. Holthausen, T.D. Rich, and V .A. Saab.2002. Perfonuance of Greater Sage-Grousemodels for conservation assessmentin the Interior Columbia Basin, USA. Conservation Biologyl6: 1232-1242. Enclosure (1)

cc: TRC, Environmental Consultant, Laramie (S. Kamber) ( WGFD, Lander, Non-Game Coordinator (B. Oakleaf) :: WGFD, Cheyenne,Statewide Habitat Protection Coordinator (V. Stelter)

6United States Department of the Interior
FISH AND Wll...DLIFE SERVICE Ecological Services 4000 Airport Parkway Cheyenne, Wyoming 82001

In ReplyRefer To: February 2, 2004 ES-61411/BfF/WY7746

Dear Interested Party: This letter is to infonn you that black-footed feITet (Mustela nigripes) surveys are no longer necessary in black-tailed prairie dog colonies statewide or in white-tailed prairie dog towns except those noted in the attachment. In response to requests from numerous entities and our own review of the situation regarding ferret surveys, the U.S. Fish and Wildlife Service (Service) and others have been evaluating the potential for a previously unidentified black-footed feITet population to occur in Wyoming and the need for conducting black-footed ferret surveys across the entire state. This issue has been especially pertinent when evaluating various activities for compliance with the Endangered Species Act of 1973 (Act), as ~nded (16 USC 1531 etseq). ", The black-footed ferret was listed as an endangered species in 1967, prior to the Act (under the Endangered Species Preservation Act of 1966). The Act prohibits the take of listed specjes without proper pennits and places an additional requirement on activities funded, authorized or carried out by Federal agencies to ensure that such actions will not jeopardize the continued existence of any listed species. The latter process is known as interagency consultation and is outlined in section 7(a)(2) of the Act (50 C.F.R. § 402.13) . The Service developed the 1989 Black-footed Ferret Survey Guidelinesfor Compliance \~'ith the Endangered Species Act (Survey Guidelines) to assist with section 7 consultations for felTe(s. The Survey Guidelines provide a mechanism to evaluate the possibility of locating existing ferrets in prairie dog colonies by examination of the size, density, and juxtaposition of existing prairie dog colonies. The key points of the strategy are to determine the existence of ferrets or an area's potential for feiTet recovery and either may be used in section 7 consultations when detennining whether an action may affect the black-footed felTet. The Survey Guidelines can be followed by interested parties (federal agencies and their partners) during the section 7 consultation process to make detem1inations on whether an activity may adversely affect feITets. However, an unintended drawback to the Survey Guidelines is that repetitive surveys may be undertaken to evaluate possible impacts to feITets on prairie dog colonies that have already been searched or that didn't present any realistic opportunities for feITet reintroduction.~. ~ , .r "

~

The Service has been coordinating with the Wyoming Game and Fish Department in reviewing information about the current and historic status of prairie dog towns throughout Wyoming. In addition to the status review, we have also been reviewing the history of black-footed ferret surveys to determine whether the survey guidelines should continue to be applied across the entire state. Through this process, the Service has developed an initial list of blocks of habitat that are not likely to be inhabited by black-footed ferrets. In these areas, take of individual ferrets and effects to a wild population are not an issue and surveys for ferrets are no longer recommended. The term "block clearance" has often been used to describe this type of approach. This initial list is based largely on the quality of the habitat today, as well as information regarding past population bottlenecks that may have resulted from plague and poisoning events in particular areas and may have led to the loss of ferrets in the area. Additional information regarding the survey effort on the specific areas not yet block-cleared is currently being reviewed by the Service. Based on this review, the Service will likely add several blocks of habitat to the list in the future. The Service will continue to collect and review information on any remaining areas to determine if they should be added to the list of areas cleared from the survey recommendation. Therefore, prior to conducting surveys, you s~ culd coordinate with the Service to determine which specific areas are recommended for survc.ys. We have attached our initial list of areas cleared from the ferret survey recommendation. We believe this approach is not only biologically defensible, but also allows all parties involved to focus survey effort and resources on those areas where the likelihood of discovering wild ferrets is greatest. Please note that "block clearance" must not be interpreted to mean that the area is free of all value to bla�k-footed ferrets. These areas, or blocks, are merely being cleared from the need for ferret surveys. Therefore, this clearance from the survey recommendations reflects only the negligible likelihood of a wild population of ferrets occuning in an area. It does not provide insight into an area's value for survi val and recovery of the species through future rein~:.:ction efforts. Nor does this clearance relieve a Federal agency of its responsibility to evaluate me effects of its actions on the survival and recovery of the species. For example, while an action proposed in a cleared area needs no survey and is not likely to result in take of indi viduals, the action could have an adverse effect upon the value of a prairie dog town as a future reintroduction site and should be evaluated to determine the significance of that effecL Consultation with the Service is appropriate for any agency action resulting in an effect significant enough to diminish a site's value as a future reintroduction site. Additionally, block clearance of an area does not imply that other values of maintaining the integrity of the prairie dog ecosystem are unimportant. We appreciate your efforts to conserve listed species. Without the valuable information co!1ected to date in association with black-footed ferret surveys, we would not be able to undertake chis effort to focus ferret surveys on the most promising habitaL If you have any questions regarding

2this letter or your responsibilities under the Act, please contact Mary Jennings of my staff at the letterhead address or phone (307) 772-2374, extension 32.

Sincerely,

1!:: ::: ~ Field Supervisor Wyoming Field Office

Enclosure (I) cc: 	 WGFD, Non-Game Coordinator, Lander, WY (B. Oakleaf) FWS, BFF Recovery Coordinator, Laramie, WY (M. Lockhart)

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. From: Mike-Robinson@blm.gov [mailto:Mike Robinson@blm. ov} Sent: Tuesday, November 09, 20049:09 AM To: Drahushak-Crow, Roselle Subject: DOl BLM Rawlins Field Office Comments

Hello; The staff at the Rawlins Field Office have reviewed your proposal and the following issues were identified in the area: -The project is within Antelope Critical Winter Range -Greater Sage Grouse: Also within 600 meters of one lek and
meters of satellite lek -both active. From a Realty standpoint, the pro,ject is on private land and therefore will not affect public lands. Wildlife are a State governed right therefore needs to be addressed and these concerns are reflect in the above issues, but the BLM has no rights to govern/interpret private land. Thank you for you request, and feel free to contact myself for any further information or requests concerning this project.

Mike Robinson Realty Specialist BLM Rawlins Field Office Phone: (307) 328-4389 Fax: (307) 328-4224

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J' 9002004 .1 WiOMING GAME AND FISH DEPARTMENT
-;;:~~-;;;~

~. WildliJe-Serving "Conserving People" ~L!i ~

--~ November 10, WER 10988 ;-;;-;-=

Department of Energy National Renewable Energy Laboratory Scoping Clipper WindPower Low-Speed Wind Turbine Demonstration Project Carbon County

Roselle Drahushak-Crow NEPA Document Manager U.S. Department of Energy, Golden Field Office 1617 Cole Blvd. Golden, CO 80401-3393
Dear Ms. Drahushak-Crow: The staff of the Wyoming Game and Fish Department has reviewed the Clipper Windpower Inc. Low-Speed Wind Turbine Demonstration Project near Medicine Bow, Wyoming. We offer the following comments. Wildlife habitat diversity in the general areais high, with primary components including big sagebrush,black greasewood,Nut tall saltbush,willow/cottonwood riparian, shortgrasses, rock outcrops, Ponderosapine/juniper, playas, and wet meadows. Wildlife using thesehabitats frequently moves through the proposed project area. The nearby Medicine Bow River and East Allen Lake attract several speciesofwaterfowl, shorebirds, and other species. The project occurs within or near the following crucial and important wildlife habitats: .Crucial winter/yearlong range for pronghorn. .Winter/yearlong range for mule deer (about 1 mile from crucial winter/yearlong range). .The project occurs within a lek complex for sagegrouse, a speciespetitioned for listing under the EndangeredSpeciesAct. .Bald eagle,golden eagle,red-tailed hawk, ferruginous hawk, rough-legged hawk, Swainson's hawk, northern harrier, prairie falcon, kestrel, great horned owl, and
Headquarters:Bishop Cheyenne, 5400 Boulevard, WY82006-0001 (307) Web Fax: 777-4610 Site:http://gf.state.wy.usMs. Roselle Drahushak-Crow November 10, 2004 Page2 -WER 10988

burrowing owl potentially occur in the project vicinity. Specifically, bald eagle, golden eagle,red-tailed hawk, ferruginous hawk, Swainson's prairie falcon, kestrel, and great horned owl are known to nest in the surrounding area. We have not conducted any recent nesting surveys in the immediate project area­ .Several other migratory birds occur in the vicinity, including mountain plover, sandhill crane, Canadageese,and a variety of other waterfowl, shorebirds, and wading birds. .Bobcat, red fox, swift fox, coyote, skunk, weasel, and badger are someof the carnivores in the area­ .White-tailed prairie dogs, Wyoming ground squirrels, least chipmunk, desertcottontail, white-tailedjackrabbit, and a variety ofbats are some of the common smaller mammals in the area­ .Historically, black-footed ferrets were sighted in the general vicinity. We offer the following comments regarding this proposed project and the EA: I. 	 Considerations include siting, wildlife impacts, baseline inventories, monitoring, and mitigation. 2. 	 The EA should addresscumulative impacts, including nearby existing and proposedwind plants, proposed and past coal mining, oil and gas (including CBM) development, and habitat alterations such as sagebrushcontrol efforts. Determination of the effects of a potential commerciallow-speed wind farm should be addressed,in the event the demonstration project is expanded. 3. 	 The EA should addressconsideration of alternate sites, particularly if there are suitable locations with fewer potential environmental conflicts (e.g., outside of crucial winter range or sagegrousehabitat, lower potential for avian and bat mortalities). If the objective is to demonstrateelectrical generation at lower wind speeds,other less windy locations may serve that purpose with less potential impacts. 4. 	 A considerable amount of information concerning wildlife impacts hasbeen gatheredfor the adjacent existing wind farm. We recommend thesebe reviewed and referencedin the EA. 5. 	 This proposedproject is located in the samesection as a sagegrouse lek complex. There aretwo leks associatedwith this complex. Although we have not documentedactivity on theseleks in recent years,our monitoring has been inconsistent. Becausesagegrouse have beenpetitioned for federal listing, we recommend monitoring be initiated by the project proponentsprior to development of the site, in order to determine site use. If sage ~Ms. Roselle Drahushak-Crow November 10,2004 Page 3 -WER 10988

grouse leks remain active, appropriate mitigation should be developed for any foreseeable disturbances to the birds. 6. 	 In the EA, the design and characteristicsof the proposed low-speed wind turbine should be contrasted with other existing designs,including height of rotor-swept area,blade tip speeds,and potential for wildlife mortalities. These featuresshould be described in terms of their effect on wildlife mortalities. 7. 	 We recommend that construction activities ceasefrom November 15 to April 30 to minimize disturbance to crucial pronghorn winter range during the winter period. 8. 	 Appropriate timing limitations and buffers should be applied for any raptor nests identified on or near the project area. 9. 	 The project should monitor wildlife mortalities using acceptedprotocols in place at the adjacent wind farm, and use the samereporting format. These comments are also being provided to TRC Mariah, who are gathering information on behalf of Clipper Windpower Inc., and to the Carbon County Planning Commission for their use in considering a land use zoning change. We thank all parties for the opportunity to provide comments, and encourageyou to include us in future actions involving this project.

Sincerely, J

-Oc/i! d/~ BILL WICHERS DEPUTY DIRECTOR
BW:VS:as cc: 	 Mary Flanderka-Governor's Planning Office USFWS TRC Mariah Carbon County Planning CommissionNovember 8, 2004
TO: Roselle Drahushak-Crow, NEPA Document Manager U.S. Department of Energy, Golden Field Office 1617 Cole Blvd. Golden, Colorado 80401-3393
Dear: Roselle: The Medicine Bow Conservation District appreciatesthe opportunity to provide input for the scoping processconcerning the Environmental Assessment(EA) for the Clipper Windpower Inc. Low SpeedTurbine Demonstration Project. The Medicine Bow Conservation District operatesunder and is guided by legislative declarations and policy of the Wyoming StateLegislature W.S. 11-16-103 et al. The Board of Supervisors, a group of locally elected individuals, held discussion concerning the proposed actions outlined in the EA. The Board finds no reasonfor concern with the proposedproject as outlined. The Board doeshowever wish to convey the following policies concerning activities within the districts legal boundaries: A. The Medicine Bow Conservation District supports the "Multiple Use" concept of managementof federal lands within the boundaries of the district. Multiple usesshall include but are not limited to the following: a. Timber harvesting b. Grazing c. Recreation d. Oil and Gas Development e. Mineral Development f. Wind Power Development g. Hydro-Electric Development B. 	The Medicine Bow Conservation District reservesthe right to review and make recommendationson all sub division plans within the boundariesof the district to the Carbon County Commissioners and the Carbon County Planning and Zoning Board. C. 	The Medicine Bow Conservation District requires only certified hay or straw to be usedas mulch on reclamation projects on any county road, stateor federal highway project, or any reclamation project on lands owned or managedby the stateof Wyoming or the Federal Government.D. 	The Medicine Bow Conservation District requires that all owners of Easementsand or rights-of-way for power lines, above or below ground transmission lines, road ways, oil and gasexploration, pipeline and development sites, wind farms and mineral exploration and extraction sites shall be solely responsible for all control of noxious weeds until full establishment of perennial grasscover is establishedmeeting the satisfaction of the private landowner, lesseeor federal manager. E. 	The Medicine Bow Conservation District supports local, state and federal agenciesin requiring proper construction, maintenanceand reclamation of transportation corridors such as, but not limited to, accessroads, pipelines, and transmission lines to prevent resourcedegradation. F. The Medicine Bow Conservation District will not support any action that results in a net loss of Animal Unit Months (AUM's) on any allotment, permit or leaseon lands owned or managedby the stateof Wyoming or the Federal Government. G. 	The Medicine Bow Conservation District of Supervisorsreservesthe right to appeal local, state,and federal decisions that adversely affect the Medicine Bow Conservation District Natural Resourceand Land Use Plan. Thank you again for the opportunity to provide our input to the NEPA process. If there are any questions pleasecontact the district directly. Sincerely,
Brad Holliday District Manager, Medicine Bow Conservation District PO Box 6 510 Utah Medicine Bow, WY 82329 Email: mbcd@trib.com Phone: (307) 379-2221 Fax: (307) 379-2224FISH AND WILDLIFE SERVICE
Ecological Services 4000 Airport Parkway Cheyenne, Wyoming 82001 In ReplyReferTo: ES-61411/W.35/WY9079 

### JAN 0 6 2004 JAN 1 0 REC'D SteveBlazek,NEPA ComplianceOfficer Departmentof Energy GoldenField Office 1617ColeBoulevard Golden,Colorado80401-3393

Dear Mr. Blazek: This letter is in responseto your December22, 2004, Draft Environmental Assessment,received in our office on December27, for the proposed low-speed Clipper wind turbine demonstration project located in section 1, T21N, R79W in Carbon County, Wyoming. The project includes one 262-foottall wind turbine and associatedfacilities including a 240-foot tall meteorological tower (latticeguyed type), 400 square foot building, and underground electric lines. Our office previously provided scoping comments for this project in our letter of November 10,2004 (WY8927). We appreciatethe opportunity to provide you with the following comments based on our review of the Draft Environmental Assessment(DEA). General Comments TheU.S. FishandWildlife Service(Service)understands theneedto detenninethe economicand technicalfeasibilityof the Clipperwind turbinedesignin orderto explorepossibleopportunitiesfor reducingcostsovercurrentwind turbineconfigurations.However,we stronglyencouragethe Departmentof Energy(DOE)to incorporatemeasuresto avoid and/orminimize effectsto wildlife andtheirhabitats.Theseeffortsshouldbe anintegralpart ofproject planning. To assistin project planningthe ServicehasissuedInterim Guidanceon AvoidingandMinimizingImpactsto Wildlife from WindTurbines(Guidance).TheGuidancedocumentcanfound atthefollowing website htm://www.fws.gov/r9dhcbfa/wind.Rdf. Although the Guidance is strictly voluntary, it can assistindustry in avoiding and/or minimizing impacts to wildlife and their habitats through (1) evaluation of potential Wind ResourceAreas (WRAs), (2) determining proper location and design of turbines and associatedstructures within WRAs selectedfor development, and (3) conducting pre and post-construction researchstudies and monitoring to identify and/or assessimpacts to wildlife. For your information, the Guidance is based on current scienceand will be updated as new information becomesavailable.We encouragethe DOE and its non-federal representativesto follow the Guidance and, in cooperation with the Service, to conduct science-basedresearchto provide the necessary infoffilation on the impacts of wind energy development on wildlife and their habitats. We further encouragethe DOE to look for opportunities to promote wildlife conservation through compliance with the Fish and Wildlife Service Mitigation Policy (Federal Register 46 (15), January 1981). The mitigation policy follows the stepsrecommended in the Council on Environmental Quality's Regulations for Implementing the Procedural Provisions of the National Environmental Policy Act to avoid, minimize or compensatefor negative impacts. Mitigation may involve (1) taking no action, (2) limiting the degreeof the activity, (3) repairing, rehabilitating, or restoring an affected environment, and (4) acquiring replacementhabitat and/or conservation easements. It is importantto notethatmitigationdoesnot applyto "take" of speciesprotectedunderthe EndangeredSpeciesAct (Act) of 1973,asamended,16V.S.C.1531et seq.,MigratoryBird Treaty Act (MBTA), 16V.S.C. 703,and/ortheBald and GoldenEagleProtectionAct (BGEPA), 16V.S.C. 668. Specific Comments Pageii. Executive Summ~: The DEA statesthat the wind energy companywill monitor impacts to bats and avian speciesby conducting mortality surveysduring the first 12 months of operation of the Clipper wind turbine. Determining post-construction surveyand monitoring needsshould be basedon the results of thepre-construction baseline surveys. Monitoring effort maybe cursory in areas where recorded pre-construction use by bats and/or avian speciesis low. However, it maybe necessaryto conduct intensive monitoring in areas ofdocumentedhigh use. For this reason the Service recommendsthat the companycollect pre-construction baseline wildlife information to evaluate the sitefor its importance to bats and avian species. Surveysshould be conducted by a qualified biologist during the appropriate time ofyear to observe activities related to courtship, nesting, rearing ofyoung, foraging, and migrating. Pageiii. Executive Summ~: The DEA statesthat the proposed Clipper wind turbine site is immediately adjacentto the existing Platte River Power Authority-Medicine Bow Wind Farm (pRPA). It also statesthat the proposed Clipper wind turbine would likely result in the mortality of 6.7 bats per year, 0.15 raptors per year, and 15.4passerinebirds per year. The Service recommends that the DEA include detailed information regarding the methodsin which thesenumbers were obtained. Additionally, we recommendan in-depth discussion of the mortality that maybe expected from a fully developedwind farm with this specific type ofturbine. Page 12.2.1.2 Construction and Installation Phase.Raragraph4: The DEA statesthat the proposed lattice-type meteorological tower will be 240 feet tall and will be supported by three sets of guy wires. The Service strongly recommendsthat towers, including communication and meteorological towers not exceed199feet and use construction techniquesthat do not require guy wires. Please refer to the Guidance documentas indicated above and seeattachment: Interim Guidelinesfor Recommendationson Communications Tower Siting, Construction, Operation, and Decommissioning.

2Page15.Raragraph phasewould startin 2: The DEA statesthatthe construction/installation December2004. Pleaseseeour commentaboveregardingtheimportanceofpre-construction baselinesurveys. Page 21.12aragra!>h 3: The DEA statesthat post-construction surveyswould consist of methods similar to those used by the SeaWest Foot Creek Rim Wind Plant. Thesemethods include walking transects every two weeks within 250-feet of the tower looking for casualties. The Service is concerned that mortality surveys, conductedat two week intervals, maynot capture the extent of the actual mortalities due to carcassesbeing scavengedor desiccation of carcassesoccurring so that observation becomesdifficult or impossible. Additionally, the description oftheproposed Clipperwind turbine states that the rotor and blade diameter is 305 feet and has almostfive times the windswept area as the smaller wind turbines at the comparative wind farm. Therefore, we are also concerned that surveys within 25O-feet ofthe tower maynot encompassall areas ofpotential strikes. Page43. 3.2.8.3Ra!>tors:The DEA statesthattherearefive raptornests/eyrieswithin 2.0miles of the projectarea.However,no monitoringhasoccurredatthesesitesto determinehistoric activity or currentstatus. TheServicerecommends that a currentraptor surveybe conductedwith 1.a-mile of theproject areato determineraptor usesuchasnesting,foraging andmigrationcorridors. This baselineinformationshouldbeusedin projectplanning. Page43. UnlandGameBirds. naragra!,h2: The DEA statesthattwo greatersage-grouse leks occurwithin 2-milesof the projectarea. Howevermonitoringof theselekshasbeensporadic since1980. ThereforetheWyomingGameandFishDepartment(WGFD)is collecting additionaldatabeforedeclaringtheseleksasno longeractive. TheServicerecommendsthat; until suchtimeasthe WGFDdeclarestheselek not active,theselek andadjacentnesting habitatbe managedfollowing theguidelinesby Connellyetal. 2000(alsoknownastheWAFWA guidelines). Page45.3.2.8.5:The DEA statesthatseveralspeciesof migratorybirds maypotentiallyusethe projectarea. However,the DEA doesnot mentionwhetherconstructionwill occuroutsideof the nestingseason.TheServiceis concernedthat constructionactivities,occurringduring the nesting season,mayresultin direct take ofactivenestsand/oryoung. To avoidsuchtakewe recommend that constructionandrelatedactivitiesbe conductedoutside ofthe nestingseason. Page63. 4.8.1.2.OtherMammals:The DEA indicatesthat approximately1.34batsperwind turbine werekilled atSeaWest'sFooteCreekWind Farmlocatedapproximately9-milessouthof the proposedprojectarea. It alsostatesthatwind turbinesatthe SeaWestfarm aremuchsmallerthan theproposedClipper wind turbine. The Clipperhasa wind-sweptareathatis almostfive times largerthanthe SeaWestturbines. The DEA goesonto statethatno bat or avianmortality studies havebeenconductedatthePlatteRiver PowerAuthority-MedicineBow Wind Farmlocated immediatelyadjacento theproposedClipperwind turbinesite. In orderto determinepotentialbat mortalitiesthe DEA makesa comparisonbetweenthe SeaWestwind turbinesandtheproposed Clipperwind turbine(10 miles apart). The DEA assumedthatall factorswereconstantbetweenthe two projectareasexceptthewind sweptareabetweenthetwo typesof turbines. This resultedin a potentialof 6.7batmortalitiesperyearfor the Clipperwind turbineascomparedto the 1.34batsper turbine/peryearfor the SeaWestturbines. The DEA statesthatthis is a worstcasescenariobased

3on the limited nesting or roosting habitat located within the project areaas compared to the Foote Creek Rim area. Finally, the DEA statesthat mortality surveys (post-construction) would document impacts to bat species. Please refer to our previous commentsregarding the importance ofbaseline surveys to determine use oftheproject area by bats and avian species. Use of theproject area may also include migration corridors. TheServicefeels strongly that you include migration surveys in your baseline studies. Additionally, data on wildlife use and mortality collected at one wind energy facility maynot necessarilybe applicable to other sites; as eachsite possessesdiscrete site specific information and as a result mayhave different effectson wildlife. Since wind energy is rapidly expandinginto habitats and regions that have not beenwell studied we strongly encourage a precautionary approach to site selection that includes an in-depth study ofthe specific area as well as review of existingpertinent information. Pa2e65.4.8.1.3.Raptors: 1. 	 The DBA statesthatno raptornestsarelocatedwithin I-mile of the projectarea. However,it alsostatesthatthereare5 nests/eyrieswithin 2.0miles of the site for whichno historic occupancydatais available. Pleaserefer to our abovecomment regardingtheimportanceofa currentraptor survey. 

### 2. The DEA statesit is unlikely that nesting raptors or raptor populations would be impacted by the proposed action, but that individual birds could be killed as a result of flying into the rotating turbine blades. Raptors and other migratory birds can also be killed when they.flyinto guywires. Therefore,we encourageyou to consider erecting a meteorological tower that is not guy wired. Wealso remind you that under the MBTA, take isprohibited. 

### 3. The DEA statesthat the SeaWestwind farm located 9 miles away had few raptor mortalities despite the high use of the areaby raptors. Please refer to our previous comment regarding the use ofwildlife datafrom existing wind farms to predict wildlife impactsfor the Clipper wind turbine especiallysince the SeaWestturbines have a muchsmaller blade swept area than the Clipper turbine. Information from other sourcesshould supplementthe baseline information collectedfor the Clipper turbine, not replace that information. Page68. 4.8.1.4. Upland GameBirds: The DEA statesthat the action would result in the loss ofless than 10-acresof native vegetation and is unlikely to have an adverse effect on greatersagegrouse, although somebirds may be killed by vehicles and the presenceof the turbine may adversely affect nesting activities within and near the site. The DEA goes on to discus measures to minimize effects to sage-grouse. TheService reminds you that, despiteour recommendation to find thegreater sage-grouseunwarrantedfor listing at this time, we continue to have concerns regarding sage-grousepopulation status, trends and threats, as well as concernsfor other sagebrushobligates. We strongly recommend that habitats be managedfollowing the guidelines by Connelly et al. 2000 (also known as the WAFWAguidelines). Page70. 4.8.1.5.OtherBirds: The DEA citesdatafrom theSeaWestwind farmregardingmigratory bird mortalitiesandusesthis datato predictmigratorybird mortality attheproposedClipperwind turbine. TheServiceis concernedthat datafrom a site 9 or 10 miles awayis usedexclusivelyto predict avianmortalitiesat theproposedClipperwind turbine. Webelievethat informationfrom

4other wind farms mayserve to supplementdata collectedfrom theproposed site, but not replace it, as migratory bird use maydiffer greatlyfrom site to site. Werecommend that you determine seasonaluse in the area by migratory birds, including raptors. This mayinclude nesting, roosting, foraging and migrating. Page77.4.10.IrreversibleandIrretrievableCommitmentof Resources:The DEA statesan irreversibleandirretrievablecommitmentof resourceswould includethe lossof productivity(i.e., forageandwildlife habitat)from landsinvolved in theproject...andlossof animalsdueto mortality. The Service believes that, through the use and implementation of the Guidance document as discussedabove and the collection ofscience-baseddatafor this proposed project, the Clipper wind turbine project can moveforward with little or no adverseeffectsto wildlife and their habitats. We appreciateyoureffortsto ensurethe conservationof endangered, threatened,andcandidate speciesandmigratorybirds. If youhavefurtherquestionsregardingourcommentsor your responsibilitiesundertheAct, pleasecontactKathleenErwin at 307-772-2374extension28.
Sincerely,

Brian T. Kelly Field Supervisor WyomingField Office 

# ~

References Connelly J.W., M.A. Schroeder,A.R. Sands,and C.E. Braun. 2000. Guidelines to managesage grousepopulations and their habitats. Wildlife Society Bulletin 28(4): 967 -985.

cc: BLM, Field Manager,Rawlins(M. Storzer) FWS,FederalActivities Coordinator,Lakewood(R. Dach) WGFD,Non-GameCoordinator,Lander(B. Oakleaf) WGFD, StatewideHabitatProtectionCoordinator,Cheyenne(V. Stelter)

5 

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### Department of Energy Golden Field Office 1617 Cole Boulevard Golden, Colorado 80401-3305 January19,2005

Mr. Brian Kelly Field Supervisor Wyoming Field Office U.S. Fish and Wildlife Service Ecological Services 4000 Airport parkway Cheyenne,WY 82001 DearMr. Kelly Responseto U.S. Fish and Wildlife Service(Service)Commentson Draft Environmental Assessmentfor the ProposedClipper Windpower, Inc. Low Wind SpeedTurbine DemonstrationProject, Carbon County, Wyoming. DOE/EA-1516 Pursuanto your commentletterto Mr. SteveBlazekdatedJanuary6, 2005,pleaseaccept this letterasthe Departmentof Energy's(DOE's)responseto yourcommentsconcerning theabovereferencedDraft EnvironmentalAssessment (DEA). Ourresponsesare presentedin the sameorderasyourcomments. USFWS Comment1. GeneralComment: The U.S. Fish and Wildlife Service (Service) understandsthe needto detennine the economic and technical feasibility of the Clipper wind turbine design in order to explore possible opportunities for reducing costs over the current wind turbine configurations. However, we strongly encouragethe Department of Energy (DOE) to incorporate measuresto avoid and/or minimize effects to wildlife and their habitats. Theseefforts should be an integral part of project planning. To assist in project planning the Service has issued Interim Guidance on Avoiding and Minimizing Impacts to Wildlife from Wind Turbines (Guidance). The Guidance document can be found at the following website http://www .fws.~ov/r9dhcbfa/wind/pdf. DOE ResDonseto Comment1. DOEis veryconcernedaboutminimizingpotentialenvironmentalimpactsof the proposedClipperLow Wind SpeedDemonstrationprojectandtakesits regulatory responsibilitiesseriously. ClipperWindpowerlnc. (Clipper)hasusedthe Service Guidancedocumentin theplanningphaseof this projectandthe preparationof theDEA.

FederalRecyclingProgram* PrintedonRecycled Paper 

### RE:As a result, severalpotential sites for the proposed project were evaluated by Clipper and eliminated from detailed analysis in the DEA becausethey ran contrary to many of the siting recommendationspresentedin the Service Guidanceand would have resulted in more potential environmental impacts than the proposedproject. Clipper determined the bestavailable site by identifying potential project areasthat conform to as many of the siting recommendationspresentedin the Service Guidance documentaspossible, while still meeting other technical, economic, and administrative restrictions. In particular, DOE wants to draw special attention to Site Development Recommendations 1-10 presentedin the Service Guidancedocument. Specifically, Clipper has avoided placementof the wind turbine in documentedlocations of any speciesprotected under the federal EndangeredSpeciesAct as outlined in Recommendation#1 (see Sections 3.2.4 and4.4.1 of the DEA). In addition, there are no known raptor nests within 1.0 mi of the proposed project site and only 5 nests/eyries within 2 mi of the proposed project site. Clipper has also avoided placement of the wind turbine in known local migratory pathways, known daily movement flyways (e.g. betweenroosting and feeding areas),or in areaswhere birds typically concentrate, such as wetlands (Recommendation#2). Clipper has also avoided placementof the wind turbine in known bat hibernation, breeding, maternity/nursery colonies, migration corridors, flight paths betweencolonies, or feeding areas(Recommendation#3). In addition, as stated in the DEA, the proposedwind turbine site avoids areasor features known to attract raptors suchas cliff/rim edges,buttes, mountains, or prairie dog colonies (Recommendation#4). To further delineatewildlife useof the proposed site and any impacts associatedwith the proposedturbine, the applicant-committed measuresinclude surveying of avian (raptor and passerine)use of the site along with mortality surveys associatedwith the turbine and meteorological tower. Pleasenote that Clipper would be contractually bound to all committed to measuresas a condition of Federal funding. The Service Guidance documentalso recommendsthat wind turbines: be grouped together rather than spreadingthem widely (Recommendation#5); avoid fragmenting large contiguous tracts of land (Recommendation#6); and minimize roads, fences,and other infrastructures (Recommendation#8). As noted in the DEA, the proposed wind turbine site meets all of thesecriteria. The proposedwind turbine site would be grouped with the immediately adjacent (within 800 it) existing Medicine Bow WindFarm and as a result, Clipper would be able to utilize the existing infrastructure (e.g., roads, powerlines, etc) from the Medicine Bow Wind Farm. In addition, the project would result in less than 10 acresof total new disturbance(including 8.45 acresof temporary disturbance and 1.25 acresof life-of -project disturbance). As recommendedin the Service Guidance document (Recommendation#5), the proposedproject would also implement appropriate storm water pollution prevention measuresthat do not createattractions for birds and maintain contiguous habitat for area-sensitivespecies. The Service Guidance document also recommendsthe developmentof a habitat restoration plan that avoids or minimizes negative impacts on vulnerable wildlife while maintaining and enhancing wildlife habitat values for other species(Recommendation#9). The proposed restoration plan included in the DEA would reclaim and revegetatethe site to pre-disturbanceconditions thereby meeting this objective.Clipper has met the majority of the site developmentrecommendationsdiscussedin the Service Guidance documentand hasminimized potential impacts wherever practical. Unfortunately, Clipper was unableto site the proposedwind turbine more than 5 mi from known greatersage-grouseleks (Recommendation#7). As illustrated in the DEA, there are four known greatersage-grouseleks within 5 mi of the proposedwind turbine site. The two closestleks are located 0.5 and 0.7 mi southof the proposedwind turbine site. Based on Wyoming Game and Fish Departmentmonitoring, theseleks have had no attendancefrom 1999 through 2004. It is possible that theseleks may have been impacted by natural degradationof the local sagebrushhabitat or the existing Medicine Bow Wind Project and may have beenabandoned. Construction of the proposedwind turbine would also be completed prior the breeding seasonand construction activities should not interfere or disturb any greatersage-grousethat may utilize the leks during the breeding season. The Wyoming Game and Fish Department (WGFD) will continue to monitor these leks for attendanceto determine their future status. This information is presentedin the DEA. Clipper has attemptedto locate the proposedwind turbine as far away as possible from greatersage-grouseleks, and as stated in the DEA, the proposed wind turbine is expectedto have minimal additional impacts on greatersage-grouse. In Summary,DOEhasreviewedClipper'suseof the SiteDevelopment Recommendationspresentedin the ServiceGuidancedocument.DOEhasdetermined that Clipperhasmadea good-faitheffortto meetthevoluntaryrecommendationsandhas proposeda site for the demonstrationwind turbinethatminimizesdisturbanceand potentialimpactsto all wildlife species. USFWS Comment2. Pageii. Executive Summary: The DEA statesthat the wind energy company will monitor impacts to bats and avian speciesby conducting mortality surveys during thefirst 12 months of operation of the Clipper wind turbine. Determining postconstruction surveyand monitoring needsshould be basedon the results ofpreconstruction baselinesurveys. Monitoring efforts maybe cursory in areas where recorded pre-construction use by batsand/or avian speciesis low. However, it may be necessaryto conduct intensive monitoring in areas ofdocumentedhigh use. For this reason the Service recommendsthat the companycollect pre-disturbance baseline wildlife information to evaluate the sitefor its importance to bats and avian species.Surveysshould be conducted by a qualified biologist during the appropriate time ofyear to observeactivities related to courtship, nesting, rearing ofyoung, foraging, and migrating. DOE ResDonseto Comment2. DOE agreeswith the Service that pre-construction monitoring may be warranted in areas that receive high use by bats and/or avian species. In the samelight, DOE also agrees that pre-construction monitoring is likely not warranted in areasthat receive low use by bats and/or avian species. Based on analysis conducted by TRC-Mariah, it is DOE'sopinion that the bat and/or avian speciesuseof the project areais low. This position is basedon the fact that the project areahas beenutilized for wind energyprojects for more than 20 years, relevant bat and avian information has beencollected from other projects conducted in the general areaincluding the Foote Creekand SimpsonRidge Wind Farm projects, and the Carbon Basin Coal Mine project, and the lack of known important habitats suchas nesting and breeding areas,migration routes, sensitive habitats (wetlands) for bats and/or avian specieswithin or near the project area. Mr. David Young, Jr. with WesternEcoSystemsTechnology, Inc. (WEST) (of Cheyenne, Wyoming) and project biologist for bat and avian studies that were conducted at the Foote Creek Rim Windpower Project, agreesthat pre-construction monitoring would not be very useful given the very small project area,the specific habitats near the project area,and the existenceof the Medicine Bow Wind Farm Project (personal communication between Scott Kamber, TRC-Mariah and David Young, WEST, January 7, 2005). Mr. Young also noted that the result of pre-construction monitoring conducted at theFoote Creek Rim Windpower Project did not correlate with the results from postconstruction bat and avian speciesmortality surveys conducted for the samearea (personal communication, Kamber/Young January7, 2005). For example, as noted in Young et al. (2003) golden eagleuseof the Foote Creek Rim wind farm represented40% of all documented raptor use of the study area. Utilizing the pre-construction use survey method to predict impacts and mortalities, it would have beenlogical to predict that golden eagleswould representapproximately 40% of the mortalities. However, no golden eagle mortalities were recordedduring the 3.5-year study period. Like wise, American kestrels accounted for only 5% of the total raptor use of the study area, but they accounted for 60% of the raptor mortalities. It may be useful for the Service to review this researchthat was conducted within 10 mi of the proposed project area.Copies of Young et al. (2003) can be obtained at http://www.westinc.com/wind_reQorts.QhQ. As result of this apparentlow useof the project areaby bats and/or avian species,it is DOE's professional opinion that pre-construction bat and avian use surveys of the project areaare not necessaryor warranted for this project. However, despitethe low use of theproject area by bats and/or avian species,DOE would require, Clipper to conduct postconstruction mortality surveys for bats and avian speciesduring the first 12 months of operation. DOE contends that the post-constructionmonitoring is justified and important to document actual impacts to bat and/or avian speciesdue to the operation of the larger Clipper wind turbine. DOE would also require Clipper to conduct raptor and passerine bird use surveys at the project site during the first 12-monthperiod of operation using methods and protocols presentgo in Thorias et al. (1997) and used at the nearby Foote Creek Rim Windpower Project. All surveyswould be conducted by qualified Biologists. Detailed survey methods would be included in a surveyprotocol documentto be prepared for the project and submitted to DOE, USFWS for review and comment.USFWS Comment3. Pageiii. Executive SummMY: The DEA statesthat the proposed Clipper wind turbine site is irnrnediately adjacentto the existing Platte River Power Authority-Medicine Bow Wind Farm (PRPA). It also statethat the proposed Clipper wind turbine would likely result in the mortality of 6.7 bats per year, 0.15 raptors per year, and 15.4 passerinebirds per year. TheService recommendsthat the DEA include detailed information regarding the methodsin which thesenumberswere obtained. Additionally, we recommendan in-depth discussion ofthe mortality that may be expectedfrom a fully developedwind farm with this specific type ofturbine. DOE Responseto Comment3. Detailedinfomlationregardingthe methodsusedto estimatebatandavianmortalityis currentlyincludedin Section4.8.1of theDEA. Additionaldetailis providedin the Erratadocument,whichis a componentof theFinal EA. In addition, the ProposedAction is only for the construction and operation of the single Clipper demonstrationwind turbine and as statedin the DEA, there are no reasonably foreseeableplans to place more wind turbines at this site. If additional federally-funded turbines were to be located at this site, additional environmental analysis would likely be conducted. Therefore, this portion of the Service comment is outside the scopeof this NEPA analysis. USFWS Comment 4 Page 12.2.1.2 Construction and Installation Phase.paragraph4. The DEA statesthat the proposed lattice-type meteorological tower will be 240 feet tall and will be supported by three setsof guy wires. The Service strongly recommendsthat tower, including communication and meteorological towers not exceed199feet and use construction techniquesthat do not require guy wires. Pleaserefer to the Guidance document as indicated above and seeattachment: Interim Guidelinesfor Recommendationson Communications Tower siting, Construction, Operation, and Decommissioning. DOE Response to Comment 4 As statedabove, Clipper has utilized and incorporated the recommendationsstated in the Service Guidance document into the planning phaseof this project, wherever possible. DOE and Clipper recognize that tall, guy-wired meteorological towers can result in numerous bat and avian mortalities. However, as stated in the DEA, one of the primary purposesof the proposed researchproject is international certification of the demonstrationwind turbine. These certification standardsspecify the location and height requirements of meteorological towers relative to turbines being certified. Meteorological data is neededto correlate wind velocities seenby the turbine with the power output generated. This correlation is required to predict the rated power output ofthe turbine. According to the international standards,meteorological tower height must be within 2% of hub height of the turbine (the hub height will be 75 meters, or 246 feet), and a maximum of 2 to 4 rotor diameters from the turbine, with the acceptedpractice being 2.5 rotor diameters away from the turbine (about 760 feet in this case). DOE has discussedwith Clipper the potential use of the existing meteorological towers associated with the Medicine Bow Wind Project and it has determined that thesetowers are too far away from the proposedturbine site and not taIl enoughto be utilized for the proposed researchproject. While utilization of an existing meteorological tower would result in significant cost savings, it would not meetthe technical datastandardsthat are required for this project. In addition, the tower must be 240 ft taIl, and a guyed-lattice tower is the only practical and reasonablemethod that can be usedto erecta tower of that height. USFWS Comment5 Page15.Daragraph phasewould 2: The DEA statesthatthe construction/installation startin December2004. Pleaseseeour commentaboveregardingtheimportanceof pre-constructionbaselinesurveys. DOE Responseto Comment5.

Pleaserefer to DOE Responseto Comment 2. USFWS Comment6 Page21. Paragraph3. The DEA statesthatpost-construction surveyswould consist of methodssimilarto thoseusedby the SeaWestFooteCreekRim Wind Plant. These methodsincludewalkingtransectseverytwo weekswith 250-ft of the towerlooking for casualties.TheServiceis concernedthat mortalitysurveys,conductedat two weekintervals,maynot capturetheextentoftheactualmortalitiesdueto carcasses beingscavengedor desiccationofcarcassesoccurringso that observationbecome difficult or impossible.Additionally,thedescriptionoftheproposedClipper wind turbinestatesthat therotor andbladediameteris 305feet andhasalmostfive times thewind-sweptareaasthesmallwind turbinesat thecomparativewindfarm. Therefore,we arealso concernedthatsurveyswithin 250it ofthetower maynot encompass all areas ofpotentialstrikes. DOE ResDonseto Comment6. Based on the review of the Clipper wind turbine and recommendationby Mr. David Young, Jr. (with WEST of Cheyenne,Wyoming), DOE has increasedthe mortality searchdistance from 250 ft to 325 ft. This changeis expectedto be adequateto capture the mortalities associatedwith the larger wind turbine design. Based on the recommendationof Mr. Young, the frequency of surveys will be changed from once every two weeks to a time period basedon the results of on-site seasonal carcassremoval trials that will be conducted at the project site (personal communication between Scott Kamber, TRC-Mariah, and David Young, West, January7, 2005). Theobjective of the carcassremoval trials is to estimatethe length of time avian and bat carcassesremain in the searchareasprior to being removed. Carcassremoval eliminates the possibility of detection during mortality surveys and includes removal by predators, scavengers,or other means; it is directly related to level of use of the project area by local scavengers. The carcassremoval trials would be conductedutilizing protocol presented in the Final Report: Avian and Bat Mortality Associated with the Initial Phase of the Foote Creek Rim Windpower Project, Carbon County, Wyoming(Young et al. 2003). This document can be found at http://www.west-inc.com/wind_re}2orts.}2h}2.The trials would be conducted at the beginning of eachof the following seasons:spring migration (February 15 -April 15), summerbreeding season(April 16 -August 31), fall migration (September1 -October 31), and winter (November 1 -February 14) and would be used to statistically determine the amount of time betweeneachsurvey. The carcassremoval trials will document scavengeruse of the immediate project areaand will be usedto determine the frequency of mortality surveys. Therefore, the 325-ft survey distance for the mortality surveys are included in the Errata Document for the DEA. In addition, a commitment to conduct carcassremoval trials will replacethe two-week survey period and is reflected in the Errata Document for the DEA. USFWS Comment7 Page43. 3.2.8.3 Raptors: The DEA statesthat there are five raptor nests with 2.0 miles of the Project area. However, no monitoring has occurred at these sites to determine historic activity or current status. TheService recommendsthat a current raptor surveybe conductedwithin 1.0 mile oftheproject area to determine raptor usesuch as nesting,foraging, and migration corridors. This baseline information should be used in project planning. DOE ResDonseto Comment7. Clipper Windpower has agreedto conduct surveys of current use of the immediate project area by raptors and passerinebirds along with the mortality surveys mentioned in the DEA. The current site use surveyswill be basedon surveymethods and protocols used at the nearby Foote Creek Rim Windpower Project. The Errata to the DEA includes a commitment to these current site use surveys. USFWS Comment8Page43. UnlandGameBirds. oaraflIaoh2: the DEA statesthattwo greatersagegrouseleks occurwithin 2 milesof the projectarea. However,monitoringof these lekshasbeensporadicsince1980. Therefore,the WGFDis collectingadditionaldata beforedeclaringtheseleksareno longeractive. TheServicerecommendsthat until suchtimesasthe WGHFDdeclaretheseleksnot active,theseleksandadjacent nestinghabitat bemanagedfollowing theguidelinesby Connellyetal. 2000(also knownastheWAFWAguidelines).--- DOE ResDonseto Comment8 DOEhasincorporatedthe greatersage-grouseguidelinespresentedin Connellyetal.2000,asmuchaspractical,in the DEA. Pleasereferto the discussionon greatersagegrousepresentedin the DOEResponseto Comment1.

USFWS Comment9 Page45.3.2.8.5: The DEA statesthat several speciesof migratory birds may potentially usethe project area. However, the DEA does not mention whether construction will occur outside of the nesting season. TheService is concerned that construction activities, occurring during the nestingseason, mayresult in direct take ofactive nestsand/or young. To avoid such take we recommendthat construction and related activities be conductedoutside ofthe nestingseason. DOE Responseto Comment9 In Section 2.1.2 of the DEA, it statesthat construction would require approximately 2 months to complete and would start in December2004. Construction is now scheduled to begin in January, and is anticipated to be complete by the end of March 2005. It is therefore clear (as stated in the DEA) that construction activities would not occur during the nesting seasonfor migratory birds in the project area. USFWS Comment 10 Page63. 4.8.1.2. OtherMammals: The DEA indicates that approximately 1.34bats per wind turbine were killed at SeaWest'sFoote Creek Wind Farm located approximately 9 miles southof the proposed project area. It also statesthat wind turbines at the SeaWest farm are much smallerthan the proposed Clipper wind turbine. The Clipper has a wind-swept area that is almost five times larger than the SeaWest turbines. The DEA goes on to state that no bat or avian mortality studies have beenconducted at the Platte River Power Authority-Medicine Bow Wind Farm located immediately adjacentto the proposed Clipper wind turbine site. In order to determine potential bat mortalities the DEA makesa comparison betweenthe SeaWestwind turbine and the proposed Clipper wind turbine (10 miles apart). The DEA assumesthat all factors were constantbetweenthe two project areasexceptthe wind swept area betweenthe two types of turbines. This resulted in a potential of 6.7 bat mortalities per year for the Clipper wind turbine as comparedto the 1.34bats per turbine for the SeaWestturbines. The DEA statesthat this is a worst casescenario based on limited nesting or roosting habitat located with the project areacompared tothe Foote Creek Rim area. Finally, the DEA statesthat mortality surveys (postconstruction) would documentimpacts to bat species. Pleaserefer to our previous commentsregarding the importance ofbaseline surveysto determine use of the project area by bats and avian species. Use oftheproject area may also includemigration corridors. TheServicefeels strongly that you include migration surveys in your baselinestudies. Additionally, data on wildlife useand mortality collected at one wind energyfacility maynot necessarilybe applicable to other sites, as each site possessesdiscrete site specific information and as a result mayhave different effects on wildlife. Since wind energyis rapidly expandinginto habitats and regions that have not beenwell studied we strongly encouragea precautionary approach to site selection that includes an in-depth study ofthe specific area as well as review of existingpertinent information. DOE Responseto Comment10 PleaseseeDOE Responseto Comment 2 presentedabove for a discussionof the relevanceof data from the Foote Creek Rim project, and DOE Responseto Comment 7 for infonnation regarding the current site use surveyplanned by Clipper. USFWS Comment11-1 The DEA statesthat no raptor nestsare located within I-mile of the project area. However, it also statesthat there are 5 nests/eyrieswithin 2.0 miles of the sites for which no historic occupancy datais available. Please review to our above comment regarding the importance ofa current raptor survey. DOE ResDonseto Comment11-1. Pleasereferto DOEResponseto Comment7. USFWS Comment 11-2 The DEA statesit is unlikely that nesting raptors or raptor populations would be impacted by the proposed action, that individual birds could be killed as a result of flying into the rotating turbine blades. Raptors and other migratory birds can also be killed when theyfly into guy wires. Therefore, we encourageyou to consider the erecting a meteorological tower that is not guywired. Wealso remind you that under the MBTA, take isprohibited. DOE Responseto Comment11-2. Pleasereferto DOEResponseto Comment4. USFWS Comment 11-3 The DEA statesthat the SeaWestwind farm located 9 miles away had few raptor mortalities despitethe high use of the area by raptors. Pleaserefer to our previous comment regarding the use ofwildlife datafrom existingwind farms to predict wildlife impactsfor the Clipper wind turbine especiallysince the SeaWestturbines have a muchsmaller blade swept area than the Clipper turbine. Information fromother sourcesshouldsupplementthebaselineinformationcollectedfor theClipper turbine,not replacethatinformation. DOE Response to Comment 11-3 Pleaserefer to DOE Responsesto Comments2 and 7.
USFWS Comment 12 Page68. 4.8.1.4.URlandGameBirds: The DEA statesthatthe actionwould resultin the lossof lessthan 1Q-acresof nativevegetationandis unlikelyto haveanadverse effecton greatersage-grouse,althoughsomebirds maybekilled by vehiclesandthe presenceof the turbinemayadverselyaffectnestingactivitieswithin andnearthe site. The DEA goesonto discussmeasuresto minimizeeffectsto sage-grouse.The Serviceremindsyou that,despiteour recommendationtofind thegreatersage-grouseunwarrantedfor listingat this time,wecontinueto haveconcernsregardingsagegrousepopulationstatus,trendsandthreats,aswall asconcernsfor other sagebrush obligates. Westronglyrecommendthat habitatsbe managedfollowing theguidelines by Connellyetal. 200(alsoknownastheWAFWA guidelines).
DOE R~SDonseto Comment 12 DOE encouragesresponsible development,and Clipper's plan for construction and operation of the demonstrationturbine includes measuresto minimize surface disturbance, minimize and avoid impacts to wildlife species,and adhereto applicable managementguidelines suchasthose presentedin Connelly et al. (2000). Pleaserefer to DOE Responseto Comment 1 for a discussionof the sagegrouseissue. USFWS Comment13 Page70. 4.8.1.5 OtherBirds: The DEA cites datafrom the SeaWest wind farm regarding migratory bird mortalities and usesthis datato predict bird mortality at the proposed clipper wind turbine. The Service is concernedthat data from a site 9 or 10 miles away is used exclusively to predict avian mortalities at the proposed Clipper wind turbine. Webelieve that information from other wind farms may serve to supplementdata collectedfrom theproposed site, but not replace it, as migratory bird use maydiffer ~eatly from site to site. Werecommendthat you determine seasonal use in the area by migratory birds, including raptors. This may include nesting, roosting, foraging, and mi~ating. DOE ResDonseto Comment13 Pleaserefer to DOE Responsesto Comments 2 and 7 for a discussionof this issue.USFWS Comment 14 Page77. 4.10. Irreversible and Irretrievable Commitment of Resources. The DEA statesan irreversible and irretrievable commitment of resourceswould include the loss of productivity (i.e., forage and wildlife habitat) from lands involved in the project. ..and loss of animals due to mortality. TheService believesthat, through the useand implementation ofthe Guidance documentas discussedabove and the collection ofscience-baseddatafor this proposed project, that Clipper wind turbine project can moveforward with little or no adverseeffectsto wildlife and their habitats. DOE Responseto Comment 14 DOE appreciatesUSFWS's review of the proposal Clipper Windpower, Inc., Low Wind SpeedTurbine Demonstration Project Environmental A~sessment. If you have further questionsregarding DOE's responseto your comments,pleasecontact Steve Blazek at 303-275-4723. Mr. Blazek will contact you in the near future to coordinate review and comment of the Survey Protocol documents. Sincerely,

JohnH. Kersten Manager

Enclosure

### WYOMING GAME AND FISH DEPARTMENT

"ConservingWildlife -Serving People" JAN 1 .( R£'C'O

January7, 2005

WER 10988 Departmentof Energy Golden Field Office Draft Environmental Assessment Proposed Clipper Windpower, Inc. Low Wind SpeedTurbine Demonstration Project Carbon County

SteveBlazek NEPA ComplianceOfficer DOE GoldenField Office

. 1617ColeBoulevard Golden,CO 80401-3393 DearMr. Blazek: The staff of the Wyoming Game and Fish Departmenthas reviewed the Draft Environmental Assessmentfor the Proposed Clipper Windpower, Inc. Low Wind SpeedTurbine Demonstration Project in Carbon County. We offer the following comments. Terrestrial Considerations: We provided comments on the scopingof this project in a letter dated November 10, 2004, and those concernsstill exist. The project occurs crucial winter/yearlong range for antelope,winter/yearlong range for mule deer, and a sage-grouselek complex. Bald eagle, golden eagle,red-tailed hawk, ferruginous hawk, Swainsonhawk, prairie falcon, kestrel and great-homedowl are known to nest in the surrounding areaand northern harrier and burrowing owl occur in the project vicinity. Several migratory birds that can be found in this areainclude mountain plover, sandhill crane, Canadageese,and a variety of other waterfowl, shorebirdsand wading birds. Historically, black-footed ferrets were sighted in the generalvicinity. A variety of bats occur in the area. Major unresolved issuesraised during scoping include the justification for siting the demonstration project at this site, the lack of detail in comparing how the Clipper low speed turbine differs from existing turbines that have beenevaluated for environmental consequences,

Headquarters:5400BJShOpBOUlevara-;--Cheyenne;WY 82006-0001 Fax: (307) 777-4610 Web Site: http://gf.state.wy.usSteveBlazek January 7, 2005 Page-2 -WER 10988
the lackof adequatebaseline,constructionandpost-constructionmonitoring,andtheminimal commitmento avoidimpactsor implementmitigation. The EA does not fully addressthe cumulative impacts (Section 4.9, pp 75ft), particularly the existing and proposedwind plants in the vicinity, and fails to disclose the potential for windpower expansion at the proposed site. Figure 4.1 and the related discussionare incomplete and do not show many of the projects. A considerable amount of wildlife infonnation has beengathered in the vicinity and at nearbywindplants over the years. We suggestedthat thesebe specifically reviewed and referenced in the EA. If the EA is going to baseassumptionson other studies (e.g., SeaWest),then it needsto presentthe similarities and differences betweensites and projects. A single, nonquantified reconnaissancesurveyis inadequateas a baseline for the project (e.g., p. 41). Measuresto reduce impacts incorporated into the project are vague and appearto be solely at the discretion of the operator, despite federal funding and involvement. For example, we recommendedduring scoping that construction not occur from November 15- April 30, to prevent disturbance on crucial big gamerange. However, construction would start in December of 2004 and continue for about2 months during this sensitive period (pp. 15,21,60-62). Measuresto mitigate sage-grouseconcernsare inadequate(p. 21). The immediate construction of the project does not allow for anybaseline data gathering and may discourage sage-grousefrom eveninitiating strutting in the eventthesebirds decide to reoccupy close lek sites. NREL or Clipper WindPower should commit to this monitoring. If leks are active, additional mitigation would be required. The provisionfor onlymonitoringmortality for only 1 year(p. 21)is grosslyinadequate anddoesnotnegatethe projectfromobligationsunderthe MigratoryBird TreatyAct andother laws. Oneyear'smonitoringmaymaskactualimpactsdueto seasonalandannualvariation. DOE shouldrequiremonitoring for at least3 years.Resultsshouldbecomparedto othernearby projects. Mortality monitoringdoesnotaddressscavenginganddecomposition(pp.64-65). We suggestthat the design and characteristicsof the proposed low-speed wind turbine be contrasted with other existing designs,including height of rotor-swept area,blade tip speeds,and potential for wildlife mortalities. Implications of the differing height of the rotor-swept area from the Clipper design to conventional turbines should be discussedin detail (p. 64). Individual met towers can causeas much wildlife mortality asworking turbines, especially if theseare lattice towers with guy wires. We recommendusing current met towers by the Platte River Power Authority and others since they are alreadymonitoring wind speedsin the area. The assumptionsabout impacts to Bald Eagles(p. 35, p. 54) are understated. An active Bald Eagle nest is within 8 miles of the preferred site and is directly in the flight line to East Allen Lake, where waterfowl, fish and other preferred prey occur.SteveBlazek January7, 2005 Page-3 -WER 10988

In summary, we are disappointed that the Draft EA did not take our scoping comments more seriously. The document fails to recognize the potential implications of this different type of wind turbine.
Aquatic Consideration: We continue to have no aquatic concernspertaining to this project.
We thank DOE for the opportunity to provide comments. We ask that DOE provide a more comprehensivefinal EA and assureadequatemonitoring and mitigation.

BW:VS:as cc: Mary Flanderka-Govemor'sPlanningOffice USFWS-- 

### Department of Energy Golden Field Office 1617 Cole Boulevard Golden, Colorado 80401-3305 January 19, 2005

Mr. Bill Wichers DeputyDirector WyomingGameandFishDepartment 5400BishopBlvd Cheyenne,WY 82002 Responseto Wyoming Gameand Fish Department (WGFD) Commentson Draft Environmental Assessmentfor the ProposedClipper Windpower, Inc. Low Wind SpeedTurbine DemonstrationProject, Carbon County, Wyoming. DOE/EA-1516 DearMr. Wichers: Pursuanto your commentletterto Mr. SteveBlazekdatedJanuary7,2005, pleaseaccept this letterasthe Departmentof Energy's (DOE's)responseto yourcommentsconcerning the abovereferencedDraft EnvironmentalAssessment (DEA). Ourresponsesare presentedin the sameorderasyourcomments.
WGFD Comment 1 We providedcommentsonthe scopingof this projectin a letterdatedNovember10, 2004,andthoseconcernsstill exist. DOE ResDonseto Comment1 Pleaseseeresponsesbelow. WGFD Comment 2 Major unresolved issuesraised during scoping include the justification for siting the demonstration project at this site, the lack of detail in comparing how the Clipper low speedturbine differs from existing turbines that have beenevaluated forenvironmental consequences,the lack of adequatebaseline, construction and postconstruction monitoring, and minimal commitment to avoid impacts or implement mitigation.

FederalRecyclingProgram* PrintedonRecycled Paper 

### RE:DOE ResDonseto Comment 2 DOE is very concerned aboutminimizing potential environmental impacts of the proposed Clipper Low Wind SpeedDemonstration project and takes its regulatory responsibilities seriously. Clipper Windpower Inc. (Clipper) has usedthe u.S. Fish & Wildlife Service Guidance document, Interim Guidance on Avoiding and Minimizing Impacts to Wildlife from Wind Turbines (Service Guidance), in the planning phaseof this project and the preparation of the DEA. As a result, severalpotential sites for the proposed project were evaluated by Clipper and eliminated from detailed analysis in the DEA becausethey ran contrary to many of the siting recommendationspresentedin the Service Guidance and would have resulted in more potential environmental impacts than the proposedproject. Clipper determinedthe bestavailable site by identifying potential project areasthat conform to as many of the siting recommendationspresented in the Service Guidance documentaspossible, while still meeting other technical, economic, and administrative restrictions. DOE agreeswith WGFD that pre-construction monitoring may be warranted in areasthat receive high use by bats and/or avian species. In the samelight, DOE also agreesthat pre-construction monitoring is likely not warranted in areasthat receive low use by bats and/or avian species. Based on TRC-Mariah's analysis, it is DOE's opinion that the bat and/or avian speciesuse of the project areais low. This position is based on the fact that the project areahas beenutilized for wind energyprojects for more than 20 years, relevant bat and avian information has beencollected from other projects conducted in the general area including the Foote Creek and SimpsonRidge Wind Farm projects, and the Carbon Basin Coal Mine project, and the lack of known important habitats suchas nesting and breeding areas,migration routes, sensitive habitats (wetlands) for bats and/or avian specieswithin or nearthe project area. Mr. David Young, Jr. with Western EcoSystemsTechnology, Inc. (WEST) (of Cheyenne,Wyoming) and project biologist for bat and avian studies that were conducted at the Foote Creek Rim Windpower Project, agreesthat pre-construction monitoring would not be very useful given the very small project area,the specific habitats nearthe project area,and the existenceof the Medicine Bow Wind Farm Project (personal communication between Scott Kamber, TRC-Mariah and David Young, WEST, January7, 2005). Mr. Young also noted that the result of pre-construction monitoring conducted at theFoote Creek Rim Windpower Project did not correlate with the results from postconstruction bat and avian speciesmortality surveysconducted for the samearea (personal communication, Kamber/Young, January7, 2005). For example, as noted in Young et al. (2003) golden eagleuse of the Foote Creek Rim wind farm represented40% of all documented raptor use of the study area. Utilizing the pre-construction use survey method to predict impacts and mortalities, it would have beenlogical to predict that golden eagleswould representapproximately 40% of the mortalities. However, no golden eagle mortalities were recordedduring the 3.5-year study period. Like wise, American kestrels accounted for only 5% of the total raptor use of the study area, buttheyaccountedfor 60%of the raptormortalities. It maybeusefulfor the Serviceto reviewthis researchthatwasconductedwithin 10mi of theproposedprojectarea.Copiesof Young etal. (2003)canbeobtainedathttu://www.westinc.com/wind_re~orts.~h~. As result of this apparentlow use of the project areaby bats and/or avian species,it is DOE's professional opinion that additional pre-construction bat and avian use surveys of the project areaare not necessaryor warranted for this project. However, despitethe low use of the project area by bats and/or avian species,DOE would require Clipper to conduct post-construction mortality surveys for bats and avian speciesduring the first 12 months of operation. DOE contendsthe post-construction monitoring is justified and important to document actual impacts to bat and/or avian speciesdue to the operation of the larger Clipper wind turbine. DOE would also require Clipper to conduct raptor and passerinebird use surveys at the project site during the first 12-monthperiod of operation using methods and protocols presentedin Thomas et al. (1997) and used at the nearby Foote Creek Rim Windpower Project. All surveyswould be conducted by qualified biologists. Detailed surveymethodswould be included in a surveyprotocol documentto be prepared for the project and submitted to DOE, USFWS, and WGFD for review and comment. Basedonthe reviewof the Clipperwind turbineandrecommendationby Mr. David Young,Jr. (with WESTof Cheyenne,Wyoming),DOEhasincreasedthe mortality searchdistancefrom 250ft to 325ft. This changeis expectedto beadequateto capture themortalitiesassociatedwith the largerwind turbinedesign.The 325-ft surveydistance for the mortality surveysis includedin theErrataDocumentfor theDEA. Based on the recommendationof Mr. Young, the frequency of surveyswill be changed from once every two weeks to a time period basedon the results of on-site seasonal carcassremoval trials that will be conducted at the project site (personal communication between Scott Kamber, TRC-Mariah, and David Young, West, January 7, 2005). The objective of the carcassremoval trials is to estimatethe length of time avian and bat carcassesremain in the searchareasprior to being removed. Carcassremoval eliminates the possibility of detection during mortality surveys and includes removal by predators, scavengers,or other means; it is directly related to level of use of the project area by local scavengers. The carcassremoval trials would be conductedutilizing protocol presented in the Final Report: Avian and Bat Mortality Associated with the Initial Phase of the Foote Creek Rim Windpower Project, Carbon County, Wyoming(Young et al. 2003). This document can be found at htm://www.west-inc.com/windreports.php. The trials would be conducted at the beginning of eachof the following seasons:spring migration (February 15 -April 15), summerbreeding season(April 16 -August 31), fall migration (September1 -October 31), and winter (November 1 -February 14) and would be used to statistically determine the amount of time betweeneachsurvey. The carcassremoval trials will document scavengeruse of the immediate project areaand will be usedto determine the frequency of mortality surveys. In addition, a commitment to conduct carcassremoval trials will replacethe two-week surveyperiod and is reflected in the Errata Document for the DEA.WGFD Comment 3 The EA does not fully address the cumulative impacts (Section 4.9, pp75ft), particularly the existing and proposed wind plants in the vicinity, and fails to disclose the potential for windpower expansion at the proposed site. Figure 4.1 and the related discussion are incomplete and do not show many of the projects. DOE ResDonseto Comment3 DOE has made every effort to fully addresscumulative impacts in the DEA, including the existing wind farm, and proposedwind farms and other industrial development in the general project area known to DOE, Clipper, and TRC-Mariah staff. In addition, the ProposedAction only calls for the construction and operation of the single Clipper demonstrationwind turbine and as stated in the DEA, there are no reasonablyforeseeableplans to place more wind turbines at this site. If additional turbines were to be located at this site aspart of a federally-funded project, additional environmental analysis would likely be conducted. Therefore, this portion of the WGFD comment is outside the scopeof this NEPA analysis. WGFD Comment 4 A considerable amount of wildlife information has beengathered in the vicinity and at nearby windplants over the years. We suggestthat thesebe specifically reviewed and referenced in the EA. If the EA is going to baseassumptionson other studies (e.g., SeaWest), then it needsto presentthe similarities and differences betweensites and projects. A single, nonquantified reconnaissancesurvey is inadequateas a baseline for the projects (e.g., p 41). DOE ResDonseto Comment4 The DEA currentlydiscussesandcitesnumerousbaselineenvironmentalstudiesthat havebeenconductedoverthe pastseveralyearsincludingtheEnvironmentalImpacts Statements(EISs)for theFooteCreekRim andSimpsonRidgewind farm project,the EIS for the CarbonBasinCoalMine, andpost-construction monitoringconductedatthe FooteCreekRim andSimpsonRidgeprojectareas.TheDEA statesthatthe environmentalanalysisincludestheexistingbaselinestudiessupplemented with a reconnaissance survey. Detailed infoffilation regarding the methods usedto estimate bat and avian mortality is currently included in Section4.8.1 of the DEA. Additional detail has beenadded,and is provided in the Errata document which is a componentof the Final EA. Clipperhascommittedto conductavianusesurveysandpost-constructionmortality surveysfor batsandavianspeciesduringthe first 12monthsof operation.DOEfeelsthesevarious surveys arejustified and important to documentactual impacts to bat and/or avian speciesdue to the operation of the larger Clipper wind turbine. Information concerning additional surveyshas beenincluded in the Errata document for the DEA. WGFD Comment5 Measuresto reduce impacts incorporated into the project are vague and appearto be solely at the discretion of the operator, despitefederal funding and involvement. For example, we recommendedduring scoping that construction not occur from November 15 -April 30, to prevent disturbance on crucial big gamerange. However, construction would start in Decemberof 2004 and continue for about 2 months during this sensitive period (pp. 15,21,60-62). DOE Responseto Comment5 In addition to the applicant-committed practices currently listed in Section2.1.5 of the DEA, pleasereferencethe additional applicant committed measuresregarding raptor and passerineavian use surveys,as described in the attachedErrata document. Clipper Windpower will be contractually bound to all of theseapplicant-committed practices. Section4.8.1.1includesa discussionof potentialenvironmentalimpactsto pronghorn antelopeandthe applicant-committed practiceincludedin the projectto minimize impacts. Additional informationconcerningthetiming andextentof construction operationshasbeenincludedin theErrataDocumentfor theDEA. WGFD Comment6 Measuresto mitigatesage-grouse concernsareinadequate(p. 21). Theimmediate constructionof the projectdoesnot allow of anybaselinedatagatheringandmay discouragesage-grouse from eveninitiating struttingin the eventthesedecideto reoccupycloselek sites. NREL or ClipperWindPowershouldcommitto monitoring. If leksareactive,additionalmitigationwouldberequired.



# . DOE ResDonseto Comment6 Construction will begin in mid- January2005, and is expectedto last for about 2 months. Construction activities are expectedto be completed by the middle of March 2005, which is before the prime breeding seasonfor greatersage-grouse. In addition, seasonal mitigation measmesfor greatersage-grouseare listed on page21 of the DEA. WGFD Comment7 The provision for only monitoring mortality for only 1 year (p. 21) is grossly inadequate and does not negate the project from obligations under the Migratory Bird Treaty Act and other laws. One year's monitoring may mask actual impacts due to seasonal and annual variation. DOE should require monitoring for at lease threeyears. Resultsshouldbecomparedto othernearbyprojects. Mortality monitoring doesnotaddressscavenginganddecomposition(pp. 64-65). DOE Response to Comment 7 Clipper Windpower has agreedto conduct surveys of avian useof the immediate project area by raptors and passerinebirds along with the mortality surveysdiscussedin the DEA. The avian use surveyswill be basedon surveymethods and protocols used at the nearby Foote Creek Rim Windpower Project. The Errata to the DEA includes a commitment to these site use surveys. One year of post-construction mortality surveyswill provide some information on the potential impacts of the ProposedAction on bat and/or avian speciesand further characterizethe impacts of this wind turbine. As discussedunder DOE Responseto Comment2, Mortality surveys would be conducted in accordancewith Final Report: Avian and Bat Mortality Associated with the Initial Phase of the Foote Creek Rim Windpower Project, Carbon County, Wyoming(Young et al. 2003); these survey proceduresdo addressissuesof scavengingand decomposition. This document can be found at http://www.west-inc.com/wind reports.php. WGFD Comment8 We suggesthatthe designandcharacteristics of theproposedlow-speedwind turbinebe contrastedwith otherexistingdesigns,includingheightof rotor-swept area,bladetip speeds,andpotentialwildlife mortalities. Implicationsof the differing heightof the rotor-sweptareafromthe Clipperdesignto conventionalturbinesshould be discussedin detail(p. 64). DOE ResDonseto Comment8 Design specifications for the Clipper wind turbine are discussedin the DEA on pages9 - 14. Relevant design specifications for the Clipper wind turbine are also compared to conventional wind turbines on pages63-64 of the DEA. The DEA also presentsan analysis that estimatesbird and bat mortalities for the Clipper wind turbine comparedto the existing wind turbines that are located at the Foote Creek Rim Windpower Project and the Medicine Bow Wind Project. Clipper has also committed to additional monitoring in an attemptto betterdefine relative impacts to wildlife of the larger turbine compared with smaller turbines. WGFD Comment 9 Individual met towers can cause as much wildlife mortality as working turbines, especially if these are lattice towers with guy wires. We recommend using current met tower by the Platte River Power Authority and other since they are already monitoring wind speeds in the area.DOE Response to Comment 9 As stated above, Clipper has utilized and incorporated the recommendations stated in the Service Guidance document into the planning phase of this project, wherever possible. DOE and Clipper recognize that tall, guy-wired meteorological towers can result in numerous bat and avian mortalities. However, as stated in the DEA, one of the primary purposes of the proposed research project is international certification of the demonstration wind turbine. These certification standards specify the location and height requirements of meteorological towers relative to turbines being certified. Meteorological data is needed to correlate wind velocities seen by the turbine with the power output generated. This correlation is required to predict the rated power output of the turbine. According to the international standards, meteorological tower height must be within 2% of hub height of the turbine (the hub height will be 75 meters, or 246 feet), and a maximum of 2 to 4 rotor diameters from the turbine, with the accepted practice being 2.5 rotor diameters away from the turbine (about 760 feet in this case). DOE has discussed with Clipper the potential use of the existing meteorological towers associated with the Medicine Bow Wind Project, and Clipper has determined that these towers are too far away from the proposed turbine site and not tall enough to be utilized for the proposed research project. While utilization of an existing meteorological tower would result in significant cost savings, it would not meet the technical data standards that are required for this project. In addition, the tower must be 240 ft tall, and a guyed-lattice tower is the only practical and reasonable method that can be used to erect a tower of that height. WGFD Comment 10 The assumptions aboutimpacts to Bald Eagles (p.35, p.54) are understated. An active Bald Eagle nestis within 8 miles of the preferred site and is directly in the flight line to East Allen Lake, where waterfowl, fish and other preferred prey occur. DOE ResDonseto Comment10 The analysis included in Section4.4.1.2 does not understatepotential impacts to bald eagles(a federally listed and protected species). The document clearly statesthat migrating bald eaglesmay occasionally forage or fly though the project area. The DEA also statesthat there is a chancethat bald eaglesmight collide with the operating wind turbine or meteorological tower and guy wires. When asked for their comments and concerns aboutwildlife speciesin the areaduring the scoping period prior to preparation of the DEA, neither the WGFD nor the USFWS identified the project areaas a migratory pathway for bald eagles. There are no datato indicate that the project areais located in a migratory flight path. The Wyoming Natural Diversity Database(coordinated by the University of Wyoming) also does not note any sightings of bald eagleswithin 6 miles of the project area including the areaaround East Allen Lake and no bald eagle mortalities have beendocumented at the Medicine Bow Wind Project. The DEA concludes that theProposedAction mayaffect, butwould not adverselyaffectbaldeaglesthatmight utilize the projectarea. DOEappreciatesWGFD's reviewof theProposedClipperWindpower,Inc. Low Wind SpeedTurbineDemonstrationProjectEnvironmentalAssessment.If youhavefurther questionsregardingDOE's responseto yourcomments,pleasecontactSteveBlazekat 303-275-4723.Mr. Blazekwill contactyou in thenearfutureto coordinatereviewand commentof the surveyprotocoldocuments. Sincerely,

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