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. Department of Energy/National Renewable Energy Laboratory 

1617 Cole Boulevard 

Golden, Colorado
FINAL 

ENVIRONMENTAL ASSESSMENT FOR THE 

PROPOSED CLIPPER WINDPOWER, INC. 

LOW WIND SPEED TURBINE DEMONSTRATION PROJECT, 

CARBON COUNTY, WYOMING

Prepared for 

U.S. Department of Energy 

National Renewable Energy Laboratory 

Golden, Colorado

By 

TRC Mariah Associates Inc. 

Laramie, Wyoming 

MAI Project 44136

January 2005
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project i 

EXECUTIVE SUMMARY 

Clipper Windpower, Inc. (Clipper), in partnership with the U.S. Department of Energy (DOE) 

and the National Renewable Research Laboratory (NREL), has developed a proprietary low 

wind speed turbine design that is capable of producing more electricity in low wind speed 

conditions than comparable wind turbines. The Clipper turbine would have a maximum output 

of 2.5 megawatts of electrical power and has undergone numerous tests, including dynamometer 

testing at the National Wind Technology Center (NWTC) for at least 6 months. At this point, 

Clipper needs to test the prototype wind turbine under field conditions before the design can be 

put into full production. In order to test the low wind speed turbine, Clipper proposes to 

construct/install and operate the low wind speed turbine demonstration project on privately 

owned land near Medicine Bow, Wyoming. 

The proposed project would be located approximately 5 mi southwest of the community of 

Medicine Bow, Wyoming, in eastern Carbon County. Access 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 addition, the proposed project 

would be located approximately 850 ft south of a small existing wind farm that consists of 10 

existing wind turbines (i.e., the Medicine Bow Wind Project). This small wind farm is owned 

and operated by the Platte River Power Authority (PRPA). However, the proposed project 

would not be part of PRPA’s Medicine Bow Wind Farm but would be located near that facility 

so that it could utilize as much of the existing infrastructure (i.e., roads and powerlines) as 

possible. By co-locating the project area the Medicine Bow Wind Farm, Clipper would 

minimize additional disturbance and associated impacts. 

The Proposed Action would include the construction/installation of a single wind turbine, a 

single meteorological tower, a small service building, and buried powerlines 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 turbine would 

be decommissioned and all the equipment removed. The Proposed Action would comply with 

all relevant federal, state, and local laws and regulations. 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project ii 

To minimize potential environmental impacts associated with the Proposed Action, Clipper 

would undertake various applicant-committed measures including seasonal restrictions on 

operations in crucial winter range for pronghorn and restrictions in the spring for operations near 

greater sage-grouse leks. Clipper would also implement storm water pollution prevention 

measures to minimize impacts to vegetation, soils, and surface water resources. Clipper would 

also monitor potential impacts to avian and bat species by conducting mortality surveys near the 

wind turbine and meteorological tower during the first 12 months of operation of the Proposed 

Action and would paint the small service building a desert tan to blend into its surroundings. 

Once construction operations have been completed and after the site have been decommissioned, 

Clipper would implement prompt revegetation operations and return the area to disturbance 

conditions. Detailed information concerning all applicant-committed practices is presented in 

Chapter 2 of this Environmental Assessment (EA). 

This EA analyzes the potential environmental impacts of the DOE decision 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 human environment to be addressed in this EA. Federal, state, and local 

government agencies were also contacted to identify potential issues and concerns. 

In addition to the Proposed Action, the EA also analyzes the No Action Alternative in detail. 

Other alternatives were evaluated prior to scoping by Clipper; they either would not meet the 

needs of Clipper or would obviously result in more disturbance and environmental impacts than 

the Proposed Action. These alternatives are discussed 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 area, 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); wildlife; vegetation; soils; threatened, endangered, proposed, and 

candidate species; cultural resources; noise; and visual resources. Numerous other 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project iii 

environmental resources were determined not to 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 adjacent to the exiting Medicine Bow Wind Farm, and 

this area has been utilized for wind development since the 1980s. With Clipper’s commitment to 

implement storm water pollution prevention measures and to promptly conduct reclamation 

operations, it was determined that the Proposed Action would have negligible short- and longterm impacts on soils, vegetation, and surface water resources (including wetlands). The project 

area was also surveyed for cultural resources and none were identified; the Proposed Action 

would have no impacts on historic or prehistoric sites. DOE/NREL has also notified Native 

American tribes in accordance with federal policy. To date, no sites or areas of traditional 

cultural importance have been identified within or near the project area. The Proposed Action 

would also have negligible impacts on noise and visual resources. The Proposed Action would 

not adversely affect any threatened, endangered, proposed, or candidate species that may occur 

or traverse through the project area. The Proposed Action (specifically the presence of the 

meteorological tower and operation of the wind turbine) would likely 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 meteorological 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 Game and Fish Department. The Proposed Action would have negligible impacts on 

other species that may occur in the project 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 disturbance) but would likely cause negligible 

cumulative impacts because of the limited amount of area that would be affected and the location 

of the project near the existing Medicine Bow Wind 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 Environmental Policy Act and this NEPA Document................... 6 

1.3.2 Scoping and Public Involvement ................................................................. 7 

2.0 PROPOSED ACTION AND ALTERNATIVES ................................................................... 9 

2.1 PROPOSED ACTION................................................................................................ 9 

2.1.1 Overview...................................................................................................... 9 

2.1.2 Construction and Installation Phase.............................................................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 Wildlife (Including Special 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 CONSIDERED BUT 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 Proposed Project at a Site 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 American 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 Animal and Plant Species ...............................................33 
Final 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 Water Resources (Surface Water 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 Fish ....................................................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 CANDIDATE

(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..........................................................................................56 
Final 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 WATER 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 Fish ....................................................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 CUMULATIVE IMPACTS......................................................................................75 

4.10 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF 

RESOURCES ...........................................................................................................77 

4.11 SHORT-TERM USE OF THE ENVIRONMENT VERSUS LONG-TERM

PRODUCTIVITY.....................................................................................................78 

5.0 RECORD OF PERSONS, GROUPS, AND GOVERNMENTAL AGENCIES 

CONTACTED ...................................................................................................................79 

6.0 REFERENCES .......................................................................................................................80 

APPENDIX A: COPIES OF PUBLIC SCOPING LETTERS 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project vii 

LIST OF FIGURES 

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 Development 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 Project and PRPA Wind Turbines......................................................28 

Figure 3.2 Surface Water Features near the Project Area .......................................................39 

Figure 3.3 Pronghorn Antelope Ranges near the Project Area ...............................................42 

Figure 3.4 Raptor Nest Locations near the Project Area........................................................44 

Figure 3.5 Greater Sage-grouse Leks near the Proposed Project Area ...................................46 

Figure 4.1 Existing and Authorized Projects in the General Project Area..............................76 

LIST OF TABLES 

Page 

Table 2.1 Proposed Project New Disturbance .......................................................................12 

Table 3.1 Comparison of Measured Noise Levels with Commonly Heard Sounds ..............31 

Table 3.2 Federal Threatened, Endangered, Proposed, and Candidate Species and 

Their Potential Occurrence Within the Proposed Project Area, 2002 ...................34 

Table 5.1 Record of Persons, Groups, and Governmental Agencies Contacted....................79 

Table 5.2 List of Preparers.....................................................................................................79 
Final 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 Windpower, Inc. 

dBA A-weighted decibels 

DOE Department of Energy 

EA Environmental assessment 

MW Megawatt(s)

NEPA National Environmental Policy Act of 1969

NREL National Renewable Energy Laboratory 

NRHP National Register of 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

USFWS United States Fish and Wildlife Service 

WAPA Western Area Power Administration 

WDEQ/WQD Wyoming Department of Environmental Quality/Water Quality Division 

WGFD Wyoming Game and Fish Department 

WNDD Wyoming Natural Diversity Database 

WSHPO Wyoming State Historic Preservation Office 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 

1.0 INTRODUCTION 

1.1 BACKGROUND 

Wind resources in the U.S. are vast. However, less than 1% of the nation's energy needs are 

currently being provided by renewable wind power. As the U.S. looks to find ways to generate 

more electricity from wind resources, wind developers are challenged to improve the efficiency 

of future wind turbines so that more electricity can be produced economically in low wind speed 

areas--areas where the average annual wind speed is at least 13-14 mph at a height of 33 ft. 

Currently, most large wind turbines are designed for optimal performance in areas where the 

average wind speed is at least 15 mph at a height of 33 ft. However, many large population 

centers and power grids in the U.S. are located in low-wind speed-areas. 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 area available for wind project development in the U.S. 

would be increased twenty-fold (National Renewable Energy Laboratory [NREL] 2002). As a 

result, government and private researchers are working to develop wind turbines that operate 

more economically at lower wind speeds that can be integrated into many U.S. power grids. 

The NREL is a national laboratory for the U.S. Department 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 research and development for state-of-the-art wind 

turbine designs to advance wind power technologies that lower the cost of wind energy. 

Clipper Windpower, Inc. (Clipper) has developed a proprietary low-speed wind turbine design 

that is capable of producing more electricity in low-wind conditions than comparable wind 

turbines. The Clipper turbine would have a maximum output of 2.5 megawatts (MW) of 

electrical power. Clipper has designed and constructed a full-scale version of the low-speed 

wind turbine and has begun the process of obtaining international certification for the low-speed 

wind turbine model. The National Wind Technology Center (operated by the NREL) 

administers the wind turbine certification program. Certification is provided by several 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 2 

international organizations including Underwriters' Laboratories in the U.S. and Germanisher 

Lloyd in Europe. Although the wind turbine certification program is not a warranty, the 

certification provides purchasers of wind turbines assurance that a particular wind turbine model 

has been through the following: 

• tested and evaluated by an accredited certification test organization, 

• examined by a registered certification agent to ensure compliance with 

internationally approved standards for identification and labeling, power 

performance, structural integrity, acoustic emissions, loads, power quality, safety, 

and other characteristics, and 

• demonstrated to have safe operating characteristics, including control systems that 

reflect sound engineering practice. 

Wind turbine model certification is a major step in providing electric service organizations, 

government agencies, businesses, and private individuals that plan to purchase a wind 

installation with assurances that wind turbine models have been tested and meet certain design, 

manufacturing, performance, and safety standards. The Clipper low wind speed turbine design 

has undergone numerous tests, including drive train testing in the National Wind Test Center 

dynamometer. 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 turbine, Clipper proposes to install/construct and 

operate the low-speed wind turbine demonstration project on privately owned land near 

Medicine Bow, Wyoming (refer to Figure 1.1). The DOE/NREL, through a cost-shared research 

and development subcontract, proposes to provide partial funding for this project throughout the 

3-year performance test period. 

This environmental assessment (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 

implementing regulations found in 40 Code of Federal Regulations (C.F.R.) Part 1500–1508, 

and DOE’s implementing regulations contained in 10 C.F.R. 1021.330 et seq. This EA assesses 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 3 

This figure is a separate 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 Alternative, and serves to 

guide the decision-making process. 

Seven critical elements (clearing or excavation [i.e., vegetation and soils], new or modified 

federal/state permits, threatened and endangered species, archaeological/cultural resources, other 

protected species, noise, and aesthetics) are present in the proposed project area, may 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 human environment are not present in the area or are not affected 

by the Proposed Action and are not discussed further in this EA. 

Based on an internal DOE review of the Proposed Action and additional existing information 

concerning the proposed project area, DOE has determined that this EA would also analyze 

potential impacts of the Proposed Action and alternatives on surface water resources and 

wildlife. Air quality, water quality (groundwater), livestock grazing, and wastes (hazardous or 

solid) were determined to be present in the proposed project area, but they would not be affected 

by the Proposed Action and would not be discussed further in this EA. Other resources (e.g., 

geology, health and safety, socioeconomics, noxious weeds, water rights, wild horses, 

landownership, timber, mineral resources, environmental justice, wilderness areas, etc.) have 

been determined not to be affected by the proposed project and are therefore not analyzed in 

detail in this EA. 

Based on the discussion presented above and in accordance with DOE NEPA regulations and 

policies, the following resource issues/topics will be addressed in this EA: cultural resources, 

noise, soil resources, threaten, endangered, proposed, and candidate species, vegetation, 

aesthetic/visual resources, water resources (surface 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 operation of a single low-speed 

wind turbine and associated facilities. The project would collect electrical production and 

reliability data from the wind turbine and wind data that would be necessary to evaluate the 

economic and technical feasibility of the demonstration wind turbine and its design. In addition, 

Clipper would also utilize a new design for the concrete pad for the wind turbine and would 

monitor performance of the pad. 

This project is important to DOE/NREL because previous wind turbine design studies indicate 

that several new design configurations offer significant opportunities for reducing costs over 

current wind turbine configurations. Three major elements factor into opportunities for reducing 

the cost of wind energy. First, reduction in the 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 shear by placing turbines on innovative tall towers; 

third, increases in energy capture by increasing rotor diameter and taking advantage of 

innovative rotor configurations. These studies have indicated that several techniques can be used 

to achieve these results. Many of these techniques are interrelated, such as decreasing drive train 

weight that makes use of taller towers more cost effective, or introduction of novel rotor designs 

that decrease loads and allow larger rotor diameters. Application of emerging controls strategies, 

coupled with increased instrumentation, promises to aid in the cost-effective integration of these 

major elements. 

Clipper has proposed a new turbine design that attempts to take into account all three of these 

elements. This new turbine design will use a novel gearbox with multiple generators. This new 

design is expected to be significantly lighter and less costly and allow use of taller towers to take 

advantage of wind shear at higher altitudes. The proposed Clipper turbine, if successful, is 

expected to be a major step toward realizing the advantages of low 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 federal government and the private sector. As a 

result, DOE/NREL has implemented financial programs that encourage partnerships with 

members of the U.S. wind industry, with the ultimate goal of developing large wind turbine 

systems capable of producing electricity for 3.0 ¢/kilowatt hour in Class 4 wind areas by 2007. 

A portion of the cost of Clipper’s current low wind speed turbine demonstration project is being 

provided through one of DOE/NREL’s partnership programs. In October 2002, Clipper won 

(through competitive bidding process) approximately $13 million for the partial funding of the 

development of new low wind speed 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 evaluating the project under NEPA, and the DOE must 

determine whether to provide funding for the proposed project. As required by NEPA, this EA 

examines the expected individual and cumulative impacts of the proposed project. The DOE is 

the only federal agency with responsibility for approving or denying the partial funding for the 

project and therefore is the lead agency in preparing this EA. 

The DOE/NREL prepared this EA to provide the public and responsible agencies with 

information about the project and its potential effects on the local and regional environment. This 

EA was prepared in compliance with NEPA requirements. 

NEPA, as amended (42 U.S.C. 4321 et seq.), the President’s Council on Environmental Quality 

(CEQ) regulations for implementing the procedural provision of NEPA (40 C.F.R. 1500-1508), 

and DOE’s implementing procedures for compliance with NEPA (10 C.F.R. 1021) require that 

DOE, as a federal agency: 

• assess the environmental impacts of any Proposed Action, 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 7 

• identify any adverse environmental effects that cannot be avoided, should the 

Proposed Action be implemented, 

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

• describe the relationship between the local short-term use of the environment and 

the maintenance and enhancement of long-term productivity, and 

• characterize any irreversible and irretrievable commitments of resources that 

would be involved should the Proposed Action be implemented. 

These provisions must be addressed before the final decision is made 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 evaluated the potential individual and 

cumulative effects of the Proposed Action and the 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) provide DOE with the information needed to make an informed decision in 

connection with the proposed project. 

Existing NEPA documents that may be related to the proposed project include the following: 

• EA, wind energy, Wyoming (Bureau of Reclamation 1979), 

• environmental survey report, wind energy project, Medicine Bow, Wyoming 

(Platte River Power Authority 2000), 

• environmental impact statement for the Carbon Basin coal project (Bureau of 

Land Management [BLM] 1999), and 

• environmental impact statement for the Kenetech/PacifiCorp windpower project 

(BLM 1995). 

1.3.2 Scoping and Public Involvement 

A public scoping notice was mailed to approximately 52 federal, state, and local government 

agencies, companies, individuals, and organizations, giving them until November 10, 2004 (14 

days), to submit comments. Five comment letters were received by the DOE. All five letters 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 8 

were from government agencies--none were from private corporations or non-government 

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, endangered, proposed, and candidate (TEP&C) 

species (e.g., black-footed ferret, bald eagle, Ute ladies’-tresses); 

• potential impacts to raptors, migratory birds, greater sage-grouse, crucial winter 

range for pronghorn antelope, white-tailed prairie dogs, other mammals, and 

wetlands; 

• alternatives to the Proposed Action and cumulative impacts; 

• livestock grazing on state and federal leases; 

• construction procedures; and 

• reclamation and stabilization procedures. 

This EA presents DOE/NREL’s analysis of the Proposed Action and No Action Alternative and 

findings of the potential environmental effects of the Proposed Action. The EA is being 

distributed for public review to interested members of the public, Tribal organizations, and 

federal, state, 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 ACTION AND ALTERNATIVES 

2.1 PROPOSED ACTION 

2.1.1 Overview 

The Proposed Action would be located on privately owned lands in portions of Section 1, T21N, 

R79W, and Section 36, T22N, R79W (refer to Figure 1.1) and would involve the construction of 

a single 262-ft tall tubular tower and wind turbine, a 240-ft tall meteorological tower, a 400-ft2 

service building, and approximately 4,300 ft of underground powerline (refer to Figure 2.1). 

Associated cables and powerlines would be buried between the proposed meteorological tower, 

the wind turbine, and the service building. In addition, approximately 1,000 ft of 10-ft wide 

service road would be constructed to provide access to the facilities (refer to Figure 2.1). 

The proposed project would be located approximately 850 ft south of seven existing wind 

turbines (i.e., the Medicine Bow Wind Project) owned and operated by the Platte River Power 

Authority (PRPA). The proposed project would not be part of PRPA’s Medicine Bow Wind 

Project but would be located near that facility so that it could utilize as much of the existing 

infrastructure (i.e., roads and powerlines) as possible. This would minimize additional 

disturbance and associated impacts. The Proposed Action would likely result in less than 

10 acres of new disturbance (refer to Table 2.1). 

Access to the site would be south from Medicine Bow, Wyoming, via the Elk Mountain to 

Medicine Bow road (an unpaved county road) to a series of unpaved private access roads located 

near the existing Medicine Bow Wind Project (refer to Figure 2.2). 

Clipper anticipates that the equipment would last approximately 20 years, after which time the 

wind turbine would be decommissioned and all the equipment removed. The Proposed Action 

would comply 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 separate file Fig 2-1.pdf. 

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

This figure is a separate file Fig 2-2.pdf. 

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

Table 2.1 Proposed Project New Disturbance1

. 

Temporary Life-of-Project Total 

Component Disturbance Disturbance Disturbance 

Access road 1.00 0.50 1.50 

Wind 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 installation phase of the Proposed Action would begin as soon as all 

required authorizations are obtained from DOE and any related state or local regulatory agencies. 

Locations of the various components (e.g., roads, wind turbine, meteorological tower, service 

building, buried cables) would be surveyed and staked. The existing access road from the 

southern portion of Section 36, T22N, R79W, would be extended approximately 200 ft to the 

proposed wind turbine site and would provide access to the wind turbine. An additional 800 ft of 

access road would be constructed between the meteorological tower and the service building 

(refer to Figure 2.1). The proposed access road would be approximately 10 ft wide and would 

likely result in 0.5 acre of life-of-project disturbance. There would also be an additional 1.0 acre 

of temporary disturbance created by the construction of the access route. 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 approximately 4 ft thick. The turbine 

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 material would be transported off-site for 

disposal. The concrete forms would be placed into the excavation, and concrete poured. The 

1 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 13 

262-ft tall turbine tower would be transported in pieces and assembled on-site. The turbine 

tower, turbine nacelle, and 148-ft long blades would be painted white and would match the color 

of the existing wind turbines. A large crane would be transported to the site and used to erect the 

tower and to lift the turbine, hub, and rotor blades into place. The self-supporting tower would 

not require any guy wires or other support system (refer to Figure 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 meteorological tower (with three sets of guy wires) and 400-ft2 service building 

would be transported to the site and erected and would comply with manufacturer installation 

recommendations. The meteorological tower is a standard lattice-design and would be placed on 

a small concrete pad and supported with guy wires. The 400-ft2 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 painted desert tan color to blend into the surrounding environment. 

Electrical power and communication service would be available in the service building. 

Construction of both the meteorological tower and service building would likely result in 

approximately 0.5 acre of life-of-project disturbance and an additional 3.5 acres of temporary 

disturbance. 

Portable self-contained chemical toilet(s) would be provided for human waste disposal during the 

construction, operations, and decommissioning phases of the Proposed Action. Bottled drinking 

water would be provided during the construction and operations phase of the Proposed Action. 

All solid waste (i.e., trash) and waste materials generated during the construction, operations, and 

decommissioning phases of the Proposed Action would be collected in portable dumpsters or 

trash containers and would be transported off-site to an authorized solid waste disposal facility. 

Clipper does not anticipate that any flammable waste materials or hazardous waste would be 

generated as a result of the Proposed Action; however, Clipper and its contractors would comply 

with all applicable federal and state laws and regulations governing the handling and disposal of 

any flammable or hazardous waste. No solid or liquid wastes would be disposed within the 

project area. 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 14 

This figure is a separate file Fig 2-3.pdf. 

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

Approximately 4,300 ft of 34.5-kV underground powerline would be installed from the proposed 

wind turbine to a terminal riser pole owned by the Western Area Power Administration (WAPA) 

(refer to Figure 2.4). The terminal riser pole is the connection point to the power grid and is 

located approximately 300 ft northeast of the 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 result in approximately 0.1 acre of temporary 

disturbance. Approximately 3,700 ft of underground powerline would be buried in the center of 

the existing access road using conventional trenching techniques. This actually would result in 

no new disturbance. The remaining 200-ft of underground powerline would be buried across 

undisturbed ground (using the same installation technique) and would result in a minimal amount 

of temporary disturbance (less than 0.1 acre). Additionally, 1,300 ft of communication and 

power cables would be buried among the meteorological tower, turbine, and service building 

along the side of the new access road and would not result in any additional disturbance. 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 equipment (e.g., backhoe, crane, pickup, dump truck, 

cable plow, etc.) and would require approximately 2 months to complete starting in December 

2004. Off-road travel within the project area would be limited to area between the proposed 

wind turbine, meteorological tower, and service building. Total disturbance associated with the 

Proposed Action (including off-road travel) would result in less than 10 acres of new 

disturbance. 

Clipper would apply to the Wyoming Department of Environmental Quality, Water Quality 

Division (WDEQ/WQD) for permit coverage for potential storm water pollution (i.e., erosion 

from construction activities). In addition, Clipper would prepare and implement a storm water 

pollution prevention plan to prevent disturbed runoff from leaving the project site. 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 16 

This figure is a separate 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 installation phase is complete, Clipper would begin the operations 

phase of the Proposed Action. During this phase, wind energy would be converted into 

rotational energy and then into electricity through the use of generators located in the wind 

turbine nacelle. The wind turbine would be computer-controlled for maximum performance and 

for safety when wind speeds exceed design parameters. Typically, the wind turbine would start 

spinning at approximately 9 mph (i.e., the “cut-in speed”), and the typical shut-down speed 

would be between 55 and 63 mph (i.e., “cut-out speed”). The wind turbine would have a blade 

sweep area of 73,093 ft2, a nominal rotor speed of 9.6 to 15.5 revolutions per minute, and a blade 

tip speed of 167 mph at optimal operating speed. The wind turbine system would be designed to 

stand hurricane-force winds. 

During the first 9-12 months of operations, the site would be manned 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 maintenance (e.g., gearbox inspection, 

oil and oil filter replacement, etc.), the wind turbine would require little routine maintenance. 

Utility company technical staff would integrate electricity generated 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 generation and reliability data from the demonstration wind turbine and wind data. 

Data collection would be automated and would utilize a local area network-based web caching 

data collection system. The data would be collected 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 Decommissioning Phase 

Clipper expects the operating life of the wind turbine and associated equipment to be 

approximately 20 years. At the end of the useful operating life, the turbine, tubular tower, 

meteorological tower, and service building would be removed and recycled as appropriate. 

Those materials that are not recyclable would be disposed of at an authorized solid waste landfill 

facility. All used lubricating fluids would be non-hazardous and would be recycled or disposed 

in accordance with state regulations. The concrete pads and buried cables and powerlines would 

be recycled or disposed at an authorized solid waste landfill facility. 

Once the equipment has been removed from the site, all disturbed and/or compacted areas (i.e., 

areas with roads, pads, and buried cables) not needed for on-going operations or desired to be left 

in-place by the private landowner would be reclaimed and revegetated. Disturbed areas would 

be recontoured and disced to prepare a suitable seedbed and, at the seasonally appropriate time, 

the area would be seeded and mulched as directed by the private landowner. The specific seed 

mixture would be determined by the private landowner and would likely contain grasses, forbs, 

and shrubs, and the reclaimed areas would be mulched. 

It is possible that, at the end of the 20-year life of the project, the proposed wind turbine site 

might not be decommissioned. Rather than be decommissioned, the site may 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 repowering 

the site, and the Proposed Action is limited to a 20-year life. Repowering of the project site may 

require further environmental review and analysis, and for the purpose of this project the 

repowering situation is outside the scope of this EA and is not addressed 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 following applicant-committed measures and procedures to 

minimize or avoid potential environmental impacts. These measures would 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 or other facilities. 

2.1.5.2 Soils and Vegetation 

• To minimize impacts to soil and vegetation resources, Clipper would reduce the 

area of disturbance to the absolute minimum necessary 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 completion of construction/installation phase and decommissioning phase 

of the Proposed Action, Clipper would restore topography to near pre-existing 

contours on the project site, including access roads and other facilities. Clipper 

would also revegetate all disturbed areas not required for on-going operations. 

Clipper would apply fertilizer as required, would seed, and would apply mulch to 

all disturbed areas. The landowner would determine the species to be seeded and 

the quantity of fertilizer and mulch to be used during vegetation operations. 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 20 

• Any materials used during reclamation activities (e.g., seed, mulch) would be 

certified free of noxious weed seed and reproductive plant parts as determined by 

appropriate county or state officials. 

• Clipper would implement noxious weed control measures within the area 

disturbed by construction activities. Noxious weed control measures would 

include chemical or mechanical treatment to contain or eradicate any new noxious 

weed populations that develop in disturbances created by construction activities. 

Prompt reclamation of disturbed sites would also minimize potential for weed 

infestations. 

• Clipper would obtain permit coverage for storm water pollution from construction 

sites from the Wyoming Department of Environmental Quality/Water Quality 

Division. Clipper would also develop a storm water pollution prevention plan 

that would include measures (such as interception ditches, sediment traps, water 

bars, and silt fences) to minimize storm water pollution. 

2.1.5.3 Wildlife (Including Special Status Species) 

• To minimize potential impacts to all wildlife species, Clipper would prohibit all 

unnecessary off-site activities by project personnel. Clipper would inform all 

project personnel of applicable wildlife laws and penalties associated with 

unlawful taking or harassment of wildlife. 

• To minimize potential impacts to raptors and avian species, Clipper would ensure 

that all project-related powerline structures would be constructed in accordance 

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 minimize potential impacts to active greater sage-grouse leks during the 

construction of the Proposed Action, Clipper would not conduct any surfacedisturbing activities within 0.25 mi of any active lek during the greater sagegrouse mating season between February 1 and May 15. In addition, in order to 

minimize potential impacts to nesting greater sage-grouse, no surface-disturbing 

activities would be conducted within 2 mi of any active lek between April 1 and 

July 1 without permission from the Wyoming Game and Fish Department 

(WGFD). Reclamation activities would be conducted prior to April 1, unless 

prior permission is obtained from WGFD. 

• To minimize potential impacts to pronghorn, construction activities would be 

limited during severe winter conditions. Specifically, Clipper would maintain 

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 WGFD and would limit the number of construction vehicles that 

would be allowed to access the site. In addition, Clipper would minimize the 

amount of time personnel would be at the construction site. Reclamation and 

revegetation procedures would be followed to minimize the long-term loss of 

habitat. 

• To document potential impacts to avian and bat species, Clipper would conduct 

mortality surveys near the wind turbine and meteorological tower during the first 

12 months of operation of the Proposed Action. Clipper would utilize mortality 

survey methods similar to those developed for the nearby Foote Creek Rim Wind 

Plant (Young et al. 2003). Personnel would conduct one survey every 2 weeks, 

and each survey would involve walking transects established within 250 ft of each 

tower. Search transects would be set approximately 25-30 ft apart and the 

searcher would walk at a rate of approximately 2 mi/hr along the transect 

searching both sides out approximately 12-15 ft for casualties. It is estimated that 

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, sex, and age when possible, date, and time 

collected, location, condition, and any comments that may indicate the time and 

cause of death. All carcasses located 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 compiled, summarized, and 

submitted to the DOE, USFWS, and WGFD. The U.S. Fish and Wildlife Service 

(USFWS) would be notified immediately by telephone if carcasses of raptors or 

other species of concern were located at any time during turbine operation. 

2.1.5.4 Noise 

• Clipper would ensure that muffles and motorized equipment are maintained 

according to manufacturers' specifications. 

2.1.5.5 Cultural Resources 

• Clipper would inform all construction personnel that they are working on private 

property and not to search for or remove any cultural resource materials. 

• If any cultural resources are discovered during construction operations, all 

construction activities within the immediate area being conducted by Clipper 

would be suspended and DOE and Wyoming State Historic Preservation Office 

(WSHPO) personnel and appropriate tribal representatives would be immediately 

notified. The materials would be evaluated by the archaeologist or historian 

meeting the Secretary of Interior’s Professional Qualification Standards (48 FR 

22716, September 1983). Work in the area would not resume until the status of 

the find is determined and any appropriate mitigation plans (if necessary) are 

developed and implemented. 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 23 

• If a cultural resource site, considered eligible for the National Register of Historic 

Places (NRHP) is identified, Clipper would utilize avoidance as the preferred 

method of minimizing potential adverse effects to the property. 

• Clipper would minimize adverse effects to cultural/historical properties that 

cannot be avoided by the preparation and implementation of a cultural resources 

mitigation plan approved by the WSHPO and DOE /NREL. 

2.1.5.6 Health and Safety 

• Clipper would provide potable drinking water and portable self-contained toilets 

for human waste disposal. All sewage and refuge (i.e., trash) generated on-site 

would be collected and routinely transported off-site to a Department 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 accordance with all applicable 

federal, state, and local regulations. 

2.1.5.7 Aesthetics 

• The service building would be painted a desert tan color to blend into the 

surrounding. 

2.2 NO ACTION ALTERNATIVE 

The No Action Alternative is required under Section 1502.14(d) of NEPA and DOE 

implementing regulations. A No Action Alternative is considered in this EA and provides a 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 24 

benchmark, enabling decision-makers to compare the magnitude of environmental effects of the 

alternatives (including the Proposed Action). Under the No Action Alternative, the DOE would 

not fund the proposed project. To create the basis for a meaningful analysis, it is assumed that 

the low wind speed turbine demonstration project would not be constructed at the proposed 

location. However, it is possible that Clipper could construct the project using other funds 

independent of DOE. 

2.3 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM DETAILED STUDY 

In accordance with CEQ and DOE NEPA regulations, several alternatives to the proposed 

project were identified and considered but eliminated by Clipper from detailed study in this EA. 

One of the alternative sites was eliminated (i.e., screened out) because of scheduling conflicts. 

In addition, some of the potential sites were eliminated from detailed study because they would 

clearly result in more environmental impacts than the Proposed Action. The following 

alternatives were identified and considered but eliminated from detailed study. 

2.3.1 Locate the Proposed Project at a Site in Southern California 

Under this alternative, Clipper would construct and operate the low-speed wind turbine 

demonstration project at a site located near Birds Landing in southern Solano County in northern 

California. This site would be part of the repowering effort in a portion of an existing wind farm. 

Recent information submitted to the Solano County Board of Supervisors for this location 

indicates that incidents of bird strikes on wind turbines were much 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 the repowering of this site (including a possible 

site for the Clipper’s low wind speed turbine). As a result, this site would not be available for 

use for the immediate future (personal communication, October 18, 2004, with Mr. Tom Feiler, 

Clipper, Boulder, Colorado). The permitting delay would not meet the scheduling needs of 

Clipper or DOE and could potentially have more impacts to avian species than under the 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 25 

Proposed Action. Therefore, this alternative was determined not to meet the schedule required 

for this project, was eliminated from further consideration, and is not studied in detail in this EA. 

2.3.2 Locate the Proposed Project at a Site in Jackson County, Minnesota 

Under this alternative, Clipper would construct and operate the low wind speed turbine 

demonstration project at a site located in Jackson County in southwestern Minnesota. At this 

site, the proposed low-speed wind turbine demonstration project would be the only wind turbine 

in the immediate area (i.e., it would not be part of an existing wind farm). At the Jackson 

County alternative site, the low-speed wind turbine demonstration project would 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 compared to the Proposed Action. In addition, this 

alternative would likely result in more disturbance than under the Proposed Action (personal 

communication, October 18, 2004, with Mr. Tom Feiler, Clipper, Boulder, Colorado). 

This alternative would result in increased aesthetic impacts and visual intrusions into the 

viewshed of the project area and would result in increased disturbance compared to the Proposed 

Action. Therefore, this alternative was determined not to be environmentally sound when 

compared to the Proposed Action, was 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, Clipper would construct and operate the low-speed wind turbine at a site 

located approximately 0.5 mi south of the proposed construction site. The alternative site would 

be located in an area that would be similar in all 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 more 

and would require more disturbance for the access road and underground powerline compared 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 Wind Project. Under the Proposed Action, the additional wind turbine and 

associated facilities would be similar in appearance to the existing wind turbines and would 

hardly be noticeable to the casual observer. Under this alternative, the low-speed wind turbine 

would be located 0.5 mi south of the existing Medicine Bow Wind Project, and it would be more 

noticeable to the casual observer when compared to the Proposed Action. 

This alternative would result in increased costs and disturbance and would cause increased visual 

intrusion into the viewshed of the general project area compared to the Proposed Action. In 

addition, the USFWS recommends siting wind turbines in groups or strings to minimize impacts 

to avian species (USFWS 2003). Therefore, this alternative was determined not to be 

economically feasible or environmentally sound when compared to the Proposed Action, was 

eliminated from further consideration, and is not studied in detail 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 southwest of the community of 

Medicine Bow, Wyoming, in eastern Carbon County (refer to Figure 1.1). Access to the site is 

south from Medicine Bow, Wyoming, via the Elk Mountain to Medicine Bow Road (an unpaved 

public road) to unpaved private access roads located near the existing Medicine Bow Wind 

Project (refer to Figure 2.2). The proposed project would be located in Section 1, T21N, R79W, 

and the property is privately owned. 

The proposed project would be located on the eastern flanks of the Hanna Basin (Lageson and 

Spearing 1998). The proposed project area is also located within the Upper Platte River drainage 

basin (Knight 1994), and the Medicine Bow River is located approximately 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 slopes toward 

the west-southwest. The general project area is also relatively flat with some areas of rolling 

hills (refer to Figure 3.1). 

Based upon 1:100,000-scale mapping, the mixed-grass prairie is the only ecological region 

within 1 mi of the proposed project 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 cushionplants) (Knight 1994). 

Climatic conditions within the general project area are characteristic of the Foothills and Basin 

area of south-central Wyoming. According to weather data collected at Medicine Bow, 

Wyoming (approximately 5 mi northeast of the project area), record high and low temperatures 

are approximately 97oF and –46oF, respectively, with an average annual air temperature of 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 28 

This figure is a separate file Fig 3-1.pdf. 

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

41.6oF. Summer temperatures range widely, typically with warm sunny days and cool nights. 

On average, there are approximately 90 frost-free days a year in the general project area (Martner 

1986). The proposed project area receives approximately 10.25 inches of precipitation per year, 

and the prevailing winds are from the southwest (Soil Conservation Service 1988). 

The general project area historically has been utilized for livestock grazing, wind energy 

development, oil and gas development, utility corridors, and wildlife habitat. Currently, the 

PRPA owns and operates the Medicine Bow Wind Farm located immediately north of the project 

area. This wind farm consists of 10 large (>600-kilowatt) wind turbines, two 400-ft tall guyed 

meteorological towers, an 800-ft2

 service building, and associated outbuildings and facilities. 

The seven of the existing wind turbines are located south of the service building and configured 

in a single row of turbines, and the three remaining turbines are located near of the service 

building. WAPA operates and maintains a 115-kilovolt powerline and electric substation that 

connects the PRPA wind farm to the power grid. The existing electric substation is located 

approximately 500 ft east of the PRPA service building, and the powerline runs northeast from 

the PRPA wind farm toward the community of Medicine Bow. A 69-kV transmission powerline 

(owned and operated by Carbon Power and Light Inc., a rural electric cooperative) runs from the 

northeast to the southwest through the general project area. This line provides electric service to 

the community of Elk Mountain but is not associated with or connected to the PRPA wind farm 

or WAPA powerline (refer to Figure 2.2). 

3.2 AFFECTED RESOURCES 

3.2.1 Cultural Resources (Including Native American Concerns) 

Cultural resources are the nonrenewable physical remains of past human activity and are 

protected under Section 106 of the National Historic Preservation Act of 1966, as amended (16 

U.S.C. §470 et seq), the Archaeological Resources Protection Act of 1979, as amended (16 

U.S.C. §470aa et seq), and other laws. Archaeological investigations in south-central Wyoming 

indicate that human activity has occurred across the landscape over the past 10,000 years, 

beginning during the Paleoindian period and continuing up to the present (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 not indicate that any previously identified 

historic or prehistoric sites were located within the project area. A Class III inventory (i.e., 

pedestrian survey) of the project 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, Cherokee Trail, and the Fort Halleck to Fort Fetterman Wagon Road occur within the 

vicinity of the project area, but none of these trails are located within 10 mi of the project area. 

Numerous Native American groups including but not limited to Crow, Shoshone, Comanche, 

Arapaho, Cheyenne, and Sioux have utilized the general project area and numerous sites of 

traditional cultural interest have previously been identified within 10 mi of the project area. 

Some of these sites are located near the Foote Creek Wind Farm project, the Carbon Basin Coal 

project, and a fiber optic project (personal communication, December 21, 2004, with Mark 

Soldier Wolf, Northern Arapaho Tribal Archaeological Consultant). Tribes and/or individuals 

were sent letters requesting their comments concerning any religious or significant cultural areas 

within or near the project area. To date, no historic or prehistoric sites of Native American 

origin, or sites or areas of traditional cultural significance have been identified within the project 

area. 

3.2.2 Noise 

The A-weighted sound pressure level, or A-scale, is used extensively in the U.S. to measure 

community and transportation noise and is a measure of noise in A-weighted decibels (dBA), 

which is directly correlated with some commonly 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 Comparison of Measured Noise Levels with Commonly Heard Sounds.1 

Source dBA Description 

Normal breathing 10 Barely audible 

Rustling leaves 20 

Soft whisper (at 16 ft) 30 Very quiet 

Library 40 

Quiet office 50 Quiet 

Normal conversation (at 3 ft) 60 

Busy traffic 70 Noisy 

Noisy office with machines; factory 80 

Heavy truck traffic (at 49 ft) 90 Constant exposure endangers hearing 

Source: Rau and Wooten (1980). 

No site-specific noise level data are available for the project area. However, major sources of 

noise include the wind and the PRPA wind turbines that generate noise only when they are 

operating. Rural areas like the project 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 noise levels correspond to a soft whisper (30 dBA), a library (40 dBA), a quiet 

office (50 dBA), a small town (40-50 dBA), and normal conversation (60 dBA). Traffic along 

an interstate highway typically averages noise levels greater than 70 dBA (Wyle Laboratories 

1971). When operating at the optimal wind speed (33 mph), the existing PRPA wind turbines 

likely produce approximately 40-50 dBA of noise 800 ft downwind of the turbines (Madison Gas 

and Electric 2004). In high winds, the background noise produced by the wind would generally 

mask most of the noise from the operating wind turbines. 

Noise-sensitive areas in the general project area include private residences (the closest residence 

is approximately 1.5 mi north of the project area), occupied raptor nests (the closest raptor nest is 

approximately 1.4 mi southwest of the project area), and greater sage-grouse leks during the 

breeding and nesting season (the closest greater sage-grouse lek is 0.4 mi south of the project 

area). 

1 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 32 

3.2.3 Soil Resources 

The Natural Resources Conservation Service has not published a detailed soil survey report for 

the eastern portion of Carbon County. However, the College of Agriculture at the University of 

Wyoming has prepared 1:100,000 scale digital soil maps including the proposed project area 

(Munn and Arneson 1998). The project area includes soils from the High Plains Southeast zone, 

which is typically comprised of mountains and foothills. In the general project area, the surface 

12 inches of soil is typically gravelly loam, and the subsoil is highly calcareous, very gravelly, 

and cobbly loam to sandy loam. Water erosion is slight, and wind erosion potential is moderate. 

These soils support a vegetative cover that typically serves as rangeland and 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 plant and animal species and their critical habitats. A list of federally listed 

TEP&C species that potentially occur in the vicinity of the proposed project was compiled from 

the Wyoming State Supervisor Office of the USFWS (2004) and the Wyoming Natural Diversity 

Database (WNDD) (2004). 

TEP&C species are those that have been specifically designated as such by the USFWS. 

Endangered species are those that are in danger of extinction throughout all or a significant 

portion of their range. Threatened species are those that are likely to become endangered in the 

foreseeable future throughout all or a significant portion of their range. Candidate species are 

those for which the USFWS has sufficient data to list as threatened or endangered but for which 

proposed rules have not yet been issued. Proposed species are those for which the USFWS has 

published proposed rules in the Federal Register for listing of the species but for which a final 

rule has not been adopted. 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 33 

3.2.4.2 TEP&C Animal and Plant Species 

The black-footed ferret (Mustela nigripes), a federal endangered species; bald eagle (Haliaeetus 

leucocephalus), a federal threatened species; Ute ladies’-tresses (Spiranthes diluvalis), a federal 

threatened species; and Platte River system species--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 prairie fringed orchid (Platanthera praeclara)--may potentially occur 

within the project area or may be affected by the Proposed Action (refer to Table 3.2). No other 

TEP&C species as designated by the USFWS have been identified to potentially occur within the 

project area (USFWS 2004). 

Black-footed Ferret. The black-footed ferret, a federally listed endangered species, was once 

distributed throughout the high plains of the Rocky Mountain and western Great Plains regions 

(Clark and Stromberg 1987; Forrest et al. 1985). Prairie dogs are the main food of black-footed 

ferrets (Sheets et al. 1972), and historically a few black-footed ferrets have been collected away 

from prairie dog towns (Forrest et al. 1985). The last known wild population of black-footed 

ferrets was discovered in the Pitchfork area near Meeteetse in 1981. Due to the fear that canine 

distemper would wipe out this population, the remaining black-footed ferrets were captured from 

the Pitchfork area and placed into a captive breeding project in 1985 (Wyoming Game and Fish 

Department [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 Within the Project Area, 2004.1 

Potential Occurrence 

Common Name Scientific Name Federal Status

2 Within the Proposed Project Area3 

MAMMALS

Black-footed ferret Mustela nigripes E X 

BIRDS

Bald eagle4 Haliaeetus leucocephalus T R 

PLANTS

Ute ladies’-tresses Spiranthes diluvialis T X 

PLATTE RIVER Various5

 n/a n/a 

SYSTEM SPECIES 

1 Adapted from USFWS (2004). 2 Federal status (USFWS 2004):

E = listed as federally endangered. 

T = listed as federally threatened. 

n/a = not applicable. 3

 Species occurrence: 

R = Rare; species may be in the project area for just a few days or hours (e.g., stopping over during 

migration). Encounters during project construction is very unlikely. 

X = Unlikely; there has been no recent historical record of the species's occurrence in the project area; 

probability of encountering the species during powerline construction is very unlikely.

n/a = not applicable. 4 Proposed for removal from federal listing. 5 Includes 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 prairie fringed orchid (Platanthera praeclara). 

As a result of the captive breeding and reintroduction program, black-footed ferrets have been 

successfully released into several areas in the west including the Shirley Basin Ferret 

Management Area located approximately 30 mi north of the project area. Eighty-eight blackfooted ferrets were counted during surveys conducted in August 2004. This is an increase of 36 

black-footed ferrets (69%) more than the 52 individuals counted during August 2003 (CasperStar Tribune 2004). 

The Black-footed Ferret Survey Guidelines for Compliance with the Endangered Species Act 

(USFWS 1989) defines potential black-footed ferret habitat as any white-tailed prairie dog 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 35 

towns or complexes greater than 200 acres in size. Based on the results of a reconnaissance 

survey conducted by TRC Mariah Associates Inc. on October 28, 2004, no prairie dogs were 

identified within the project area. In addition, while potential black-footed ferret may travel 

through the general project area, the project area is located outside of any area requiring blackfooted ferret surveys (USFWS 2004). In addition, no recent black-footed ferret observations 

have been recorded in the vicinity of the project area (USFWS 2004; WNDD 2004). Therefore, 

it is unlikely that any black-footed ferrets would occur in the project area. 

Bald Eagle. The bald eagle is a federally listed threatened species (downlisted from endangered 

and now proposed for removal from federal listing). This species requires cliffs, large trees, or 

sheltered canyons associated with concentrated food sources (e.g., fisheries or waterfowl 

concentration areas) for nesting and/or roosting areas. Bald eagles forage over wide areas during 

the non-nesting season (i.e., fall and winter) and scavenge on animal carcasses such as pronghorn 

antelope, deer, and elk (Edwards 1969; Snow 1973; Call 1978; Steenhof 1978; Peterson 1986). 

No bald eagle nests or winter roosts are known to occur in the project area or within the general 

project area, due to the lack of suitable nesting or winter roosting habitats. There are no known 

bald eagle nests with 15 mi of the proposed project area (BLM 2003) and there have been no 

documented mortalities of bald eagles associated with the Phase I portion of the Foote Creek 

Rim Windpower project located approximately 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 may 

occasionally forage in or fly through the general project area. 

Ute Ladies'-tresses. Ute ladies'-tresses, a federally listed threatened species, is a perennial 

member of the orchid family that inhabits moist streambanks, wet meadows, and abandoned 

stream channels at elevations of 4,500-6,800 ft (Fertig 1994; Spackman et al. 1997). Although 

the species will tolerate mildly alkaline conditions, it is unlikely to be found in association with 

Gardner's saltbush, greasewood, or other alkaline vegetation. Where it occurs in ephemeral 

drainages, groundwater is typically shallow (i.e., within approximately 18 inches of the ground 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 36 

surface) (personal communication, March 16, 2000, with Pat Deibert, USFWS; personal 

communication, March 22, 2000, with Walt Fertig, WNDD). 

The species has been documented in Goshen, Converse, and Niobrara Counties in Wyoming 

(Fertig 1994) and along the Front Range in northern and central Colorado (Spackman et al. 

1997). Although much time has been devoted in recent years to determining areas in Wyoming 

where the species occurs, it has not been documented within the proposed project area, the 

general project area, or Carbon or Albany Counties (WNDD 2004). Based on visual observation 

of the project area and descriptions for vegetation communities in the project area, there is no 

suitable habitat for Ute ladies'-tresses within the project area or immediate project area. There 

would be no affect from the project, and the species is not discussed further in this EA. 

Platte River System Species. The USFWS has determined that water depletion to the Platte 

River system may adversely 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 prairie fringed orchid (Platanthera praeclara). Water depletions include 

evaporative losses or consumptive use including, but not limited to, ponds, lakes, reservoirs, 

created or enhanced wetlands, hydrostatic testing of pipelines, wells, diversion structures, dust 

abatement, etc. The Proposed Action would not result in any water depletions from the Platte 

River system and would not result in any adverse indirect impacts to these species; therefore they 

are not discussed further in this EA. 

Boreal Toad. The boreal toad is not a listed species (threatened, endangered, proposed, or 

candidate) under the federal Endangered Specie Act. However, the USFWS has determined that 

sufficient information exists to list the species as a candidate species, but the USFWS has not 

proposed the species for listing because of higher priority listing actions (USFWS 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 currently extends from 

western British Columbia to southern Nevada and east to parts of Wyoming. Wyoming is on the 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 37 

southeastern periphery of the boreal toad distribution, and it has been found in the south-central 

and northwestern portion of the state. In Wyoming, 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 streams. There are no recorded occurrences of boreal toads in the general project area 

(WNDD 2004; WGFD 1999), and there is no suitable habitat within the project area. Therefore, 

there would be no affect from the project and the species is not discussed further in this EA. 

3.2.5 Vegetation Resources 

Based upon 1:100,000-scale mapping, the mixed-grass prairie is also the only ecological region 

within 1 mi of the proposed project 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 cushion 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, and mountains. PRPA’s Medicine 

Bow Wind Farm dominates the view to the north of the project area. 

Approximately 800 ft north of the proposed wind turbine is the southern most PRPA wind 

turbine, followed in a line by the remaining six wind turbines. The other three wind turbines, not 

located in the row of wind turbines, as well as the two meteorological towers, the service 

building, the electric substation, the WAPA and Carbon Power and Light powerlines and 

associated facilities, are also visible north of the project area. 

To the east, there is little evidence of human encroachment except for the top of numerous wind 

turbines associated with the Foote Creek Wind Farm that are located along the horizon southeast 

of the project area. These wind turbines are located 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 also limited evidence of human encroachment except for tops of additional 

wind turbines associated with the Foote Creek Wind Farm that are located along the horizon 

south of the project area. These wind turbines are located approximately 12 mi south of the 

project area. Portions of Carbon Power and Light’s electric transmission powerline and the 

Medicine Bow to Elk Mountain road are both visible southwest of the project area and continue 

beyond out of view of the project area. 

To the west, another portion of Carbon Power and Light's small electric transmission powerline 

and the Medicine Bow to Elk Mountain road are both visible. 

Because of topographic diversity in the area (i.e., rolling hills), the proposed project would not 

be visible from the communities of Medicine Bow, Rock River, McFadden, Arlington, Hanna, or 

Elk Mountain. However, the existing Medicine Bow Wind Farm and the proposed Clipper wind 

turbine would be visible from portions of U.S. Highway 30. 

3.2.7 Water Resources (Surface Water Including Wetlands) 

The project area lies within the Upper Platte River drainage basin; however, there are no defined 

ephemeral, intermittent, or perennial drainage channels 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 separate file Fig 3-2.pdf. 

Figure 3.2 Surface Water Features 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 Spade Flats and is extremely flat, and the fact that 

little surface water runoff is produced is evidenced by the lack of any defined drainage channels 

and the presence of several small playas in the general project area. Any surface water runoff 

that is produced would eventually flow into the Medicine Bow River located approximately 

1.5 mi southeast of the project area. 

No surface water quality data are available 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 comparison of water quality from the general area to 

WDEQ/WQD Chapter 8 water class standards (WDEQ/WQD 2000) indicates that surface water 

quality would typically meet Class III (livestock class of use) criteria (U.S. Geological Survey 

2004). The Medicine Bow River in the general project area is designated as having Class 2AB 

surface water quality as defined by the WDEQ/WQD. The Class 2AB designation means that 

these waters can support game and non-game fish species (WDEQ/WQD 2001). There are no 

drainage channels or reservoirs within the general project area that are included in the 

WDEQ/WQD (2002) 2000 303(d) list of water bodies with water quality impairments. 

No formal jurisdictional wetland delineations have been conducted within the project area. 

However, according to National Wetland Inventory maps produced by the USFWS, there are no 

potential wetlands in the project area or within 0.5 mi of the project area (USFWS 1997). 

3.2.8 Wildlife 

3.2.8.1 Big Game 

According to the WGFD, three big game species--pronghorn, mule 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 based upon WGFD model estimates (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 unit 

525), and the project area is located in crucial winter/yearlong antelope range (WGFD 2004) 

(refer to Figure 3.3). Pronghorn were observed in and adjacent to the project area during a 

reconnaissance survey conducted by TRC Mariah Associates Inc. in October 2004. At the end of 

2003, the Medicine Bow herd unit had an estimated population of 56,804 pronghorn, which is 

approximately 5% below the WGFD population objective of 60,000 animals for this herd unit. 

Drought continues to be one of the biggest factors affecting populations in herd units with 

populations below WGFD objectives (WGFD 2004). 

Mule Deer. Mule deer in the project area belong to the Sheep Mountain mule deer herd (herd 

unit 539) and the project area lies within winter/yearlong range. The nearest mule deer crucial 

winter range is located approximately 1 mi southeast of the project area (WGFD 2004). No mule 

deer were observed in and adjacent to the project area during a reconnaissance survey conducted 

by TRC Mariah Associates Inc. in October 2004. At the end of 2003, the Sheep Mountain herd 

unit had an estimated population of 10,885 mule deer, which is approximately 27% below the 

WGFD population objective of 15,000 animals for this herd unit. Drought continues to be one of 

the biggest factors affecting mule deer in herd units with populations below WGFD objectives. 

In addition, chronic wasting disease has been documented in portions of this herd unit and may 

be having some effect 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 nearest elk crucial winter range is located 

approximately 13 mi south of the project area (WGFD 2004). No elk were observed in and 

adjacent to the project area during a reconnaissance survey 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-- approximately 9% below the WGFD population objective of 

6,000 animals. Drought and habitat issues 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 separate 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, badger, mink, striped skunk, mountain lion, and bobcat. Lagomorph 

species include desert cottontail, mountain (Nuttall's) cottontail, and white-tailed jackrabbit. 

Squirrels known to occur or to potentially occur include least chipmunk, Richardson/Wyoming 

ground squirrel, and thirteen-lined ground squirrel, and other rodents include one species of 

pocket gopher (northern), two species of pocket 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, meadow, long-tailed, and sagebrush), and western 

jumping mouse. Porcupine and four species of bats (little brown, hoary, big brown, silverhaired) also likely occur in the general project area (WGFD 1999; Clark and Stromberg 1987). 

3.2.8.3 Raptors 

Raptor species known to occur or to potentially occur within the project area include peregrine 

falcon, golden eagle, prairie falcon, American kestrel, merlin, Swainson's hawk, ferruginous 

hawk, red-tailed hawk, northern harrier, rough-legged hawk, and great horned owl, burrowing 

owl, long-eared owl, and short-eared owl (WGFD 1999; Clark and Stromberg 1987). A review 

of BLM historic raptor nest information reveals that there are no known raptor nests within 

1.0 mi of the project area. However, there are five raptor nests/eyries within 2.0 mi of the 

proposed project area--two golden eagle, two prairie falcon, and one ferruginous hawk (refer to 

Figure 3.4). No monitoring has occurred at these sites; therefore, the historic activity status of 

these nests is unknown. 

3.2.8.4 Upland Game Birds 

The project area is located within WGFD Upland Game Bird Management Area Number 24. 

Several upland game bird species occur on and adjacent to the project area, 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 separate file Fig 3-4.pdf. 

Figure 3.4 Raptor Nest Locations 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 (refer 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 monitoring was conducted at either lek between 1980 and 1998. 

Over the past 6 years, both leks were monitored several times each breeding season, except 

during 2001 when no monitoring was conducted. No greater sage-grouse have been observed at 

either of these leks during the 1999 to 2004 monitoring period. WGFD and BLM policy states 

that greater sage-grouse leks are considered active unless there is no grouse attendance at the 

leks for 10 consecutive years. Despite the lack of monitoring data at the two leks located nearest 

the project area, it is the WGFD biologists' opinion that these two leks are abandoned (personal 

communication, October 29, 2004, with Bob Lanka, WGFD biologist, Laramie, Wyoming). 

However, the WGFD are waiting for additional monitoring data before they make a final 

determination on the status of these leks. 

3.2.8.5 Other Birds (Including Migratory Birds) 

Bird species (including migratory birds) potentially occurring within the project area, based upon 

range and habitat preference, include but are not limited to common nighthawk, Say's phoebe, 

western kingbird, horned lark, swallows (e.g., violet-green, barn, cliff), black-billed magpie, 

common raven, American crow, rock wren, mountain bluebird, loggerhead shrike, Brewer's 

sparrow, vesper sparrow, savannah sparrow, sage sparrow, lark bunting, McCown's longspur, 

red-winged blackbird, western meadowlark, Brewer's blackbird, common grackle, green-tailed 

towhee, and brown-headed cowbird (WGFD 1999). 

Since there are no permanent surface water bodies (i.e., lakes, ponds, etc.) within the project 

area, it is unlikely that waterfowl and shorebirds would nest in the project area. However, 

several species of wading/shore birds--such as great blue heron, black-crowned night-heron, 

American avocet, willets, killdeer, and spotted sandpiper--and waterfowl may occasionally occur 

around East Allen Lake (located approximately 3 mi north of the project area), the Medicine 

Bow River (located approximately 1.5 mi southeast 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 separate file Fig 3-5.pdf. 

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

playas) (located within 3 mi of the project area). Waterfowl species likely to occur in the general 

project area include pied-billed grebe, American coot, Canada goose, mallard, green-winged teal 

northern pintail, blue-winged teal, cinnamon teal, northern shoveler, redhead, ring-necked duck, 

American wigeon, and common merganser (WGFD 1999). 

3.2.8.6 Amphibians, Reptiles, and Fish 

Based on range and habitat preference, it is likely that three amphibians and three reptile species 

may possibly occur within the project area or within 3 mi of the project area. Amphibians 

include tiger salamander, chorus frog, and northern leopard frog that occur primarily in and 

adjacent to aquatic habitats. Reptile species include northern sagebrush lizard, prairie 

rattlesnake, and western garter snake (BLM 1998; WGFD 1999). 

There are no perennial waters; therefore, no fish occur within the project area. However, the 

Medicine Bow River (located approximately 1.5 mi southeast of the project area) is designated 

by the WGFD as a Class 4 stream. WGFD Class 4 streams are considered low-production trout 

water that may provide fisheries of local importance 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 chapter of the EA includes a discussion of the 

potential environmental consequences of the Proposed Action and the No Action Alternative on 

each of the affected resources. An environmental impact is defined as a change in the quality or 

quantity of a given resource due to a modification in the existing environment resulting from 

project-related activities. Impacts may be beneficial or adverse, may be a primary result (direct) 

or secondary result (indirect) of an action, and may be permanent and long-term or temporary 

and of a short duration. Impacts may vary in degree from a slightly discernible change to a total 

change in the environment. This impact assessment assumes that all applicant-committed 

measures described in the Proposed Action would be successfully implemented. If such 

measures are not implemented, additional adverse impacts may occur. 

Cumulative impacts are discussed in Section 4.9, irreversible and 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 (INCLUDING NATIVE AMERICAN CONCERNS) 

4.1.1 Proposed Action 

Class I and III surveys (i.e., file search and pedestrian inventory) have been completed for the 

project area, and no historic or prehistoric sites were identified. Therefore, the Proposed Action 

would not have any direct impacts on identified cultural resources within the project area. In 

addition, the project area would not be visible from any of the historic trails (Overland Trail, 

Cherokee Trail, and the Fort Halleck to Fort Fetterman Wagon Road); therefore, the Proposed 

Action would not have any visual impacts on historic trails in the general area. 

As discussed in the Proposed Action (Section 2.0), Clipper and its contractor would stop work if 

any cultural resources are discovered during construction operations. Work in the area of the 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 49 

discovery would not resume until the appropriate regulatory agency would be notified and 

appropriate treatment plans implemented. Construction 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 (refer to applicant-committed practices presented 

in Chapter 2). 

Consultation with Native American groups has been initiated (i.e., letters were sent to the tribes), 

and no sites of religious or traditional cultural importance have been identified within the project 

area. Formal consultation is ongoing between DOE and one of the tribal organizations that was 

previously contacted; however, the consulting tribe has not identified to DOE any traditional 

cultural properties or specific Native American issues concerning the Proposed Action. There 

are no known historic, archaeological, or tribal resources within the project site, therefore no 

impacts are anticipated as a result of the proposed action. If previously unidentified sites of 

religious or cultural importance are identified within the project area through tribal consultation 

or during construction of the project, DOE would review the potential impacts consistent with 

the applicant-committed practices cited in Chapter 2 to verify they are sufficient to minimize any 

impacts. 

Therefore, documented and undocumented cultural resources would be protected during 

construction, operations, and maintenance operations and no unmitigated cultural resources that 

are eligible for listing on the NRHP would be impacted by the Proposed Action. No additional 

mitigation beyond those already included in the Proposed Action would be required. The 

Proposed Action would not have any significant 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 demonstration wind turbine and associated facilities 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 monitoring is recommended beyond the applicant-committed 

practices identified in Chapter 2. 

4.1.4 Residual Impacts 

The Proposed Action would not result in any unavoidable adverse impacts to identified 

unmitigated cultural resources. However, some loss of unidentified cultural resources sites or 

artifacts may occur, but, if previously unidentified cultural resources are located during 

construction operations, activity in the area would be halted, the proper regulatory authority 

would be contacted, and appropriate treatment plans implemented to avoid 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 noise would be generated during 

construction/installation and operation of a single 2.5-MW wind 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 additional wind turbine (40-60 dBA for 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 masked by the background noise level (including wind and existing PRPA wind 

turbines) that could be as high as 40-60 dBA. The increased level of noise would not likely be 

highly noticeable more than 1,000 ft away from the wind turbine. 

The increase in noise due to the Proposed Action would not be noticeable to the casual observer 

located on the nearest public road (the Medicine Bow to Elk Mountain Road), which is 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 51 

approximately 1 mi north and west of the project area, or to the nearest residence approximately 

1.5 mi north of the project area. The increased noise would not be expected to adversely impact 

the nearest raptor nest 1.4 mi southwest (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 would only occur when the turbine is operating and 

would be eliminated after the wind turbine has been decommissioned and the equipment 

removed. No additional mitigation beyond those already included in the Proposed Action would 

be required. Therefore, the Proposed Action would not result in any significant 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 demonstration wind turbine and associated facilities would not occur, and noise levels 

would continue to be primarily influenced by wind and the existing PRPA wind farm. 

4.2.3 Mitigation and Monitoring 

No additional mitigation or monitoring is recommended beyond the applicant-committed 

practices identified in Chapter 2. 

4.2.4 Residual Impacts 

As a result of the Proposed Action, there would be an increase (40-60 dBA compared 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 masked by the 

background noise level (including wind and PRPA wind turbines) that could 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 amount of area (less than 1.25 acres) 

that would be disturbed for the life-of-the-project for the construction of the wind turbine, 

service building, and meteorological tower, and cables and powerline no topsoil would be 

removed or salvaged. Instead, wheeled vehicles that operate off-road would disturb the 

remaining 8.45 acres. Direct impacts to soils would be limited to compaction of soils when 

construction equipment operates off of existing roads. These impacts may result in an increase 

in runoff, erosion, and sedimentation into any local receiving waters. 

Short-term control of surface runoff would be accomplished by implementation of storm water 

pollution control measures required by the WDEQ/WQD and described in the Proposed Action. 

In addition, long-term control of surface runoff would be accomplished by successful 

implementation of the stabilization and reclamation operations described in the Proposed Action. 

Stabilization and reclamation procedures would be designed to reduce the susceptibility of 

disturbed areas to soil erosion in both the short-term and for the life of the project. No additional 

mitigation beyond those already included in the Proposed Action would be required. The 

Proposed Action would not have significant impacts on soil resources. 

4.3.2 No Action Alternative 

Under the No Action Alternative, the DOE would not fund the Proposed Action, construction of 

the demonstration wind turbine and associated facilities would not occur, and existing impacts 

(e.g., erosion, etc) to soil resources in the project area would continue 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 monitoring is recommended beyond the applicant-committed 

practices identified in Chapter 2. 

4.3.4 Residual Impacts 

The Proposed Action would result in some increased and unavoidable soil loss through wind and 

water erosion. Soils on approximately 8.45 acres (i.e., temporary disturbance areas) would be 

compacted as a result of off-road vehicle traffic. Productivity of some disturbed soils would be 

slightly reduced due to the compaction of soils; however, these impacts would be short-term (i.e., 

3-5 years) and would be mitigated by implementation of the reclamation and stabilization 

procedures. 

4.4 THREATENED, ENDANGERED, PROPOSED, 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 project area, and there have been no black-footed 

ferrets sightings or signs have been documented within the project area. In addition, the project 

area is located outside of any areas requiring black-footed ferret surveys (USFWS 2004). 

Therefore, the Proposed Action would have no adverse affects to black-footed ferrets. 

4.4.1.2 Bald Eagle 

Migrating bald eagles may occasionally forage or fly through the project area; however, such use 

of the project area is likely intermittent and for relatively short periods. There is a chance that 

bald eagles might collide with the operating wind turbine or the meteorological tower and guy 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 54 

wires. However, given this intermittent use, the lack of nesting and roosting habitat in the 

immediate project area, and the lack of any new aboveground powerlines, it is anticipated that 

the Proposed Action may affect, but would not adversely affect, bald eagles. 

4.4.1.3 Summary 

Based on the discussion presented above and assuming all appropriate mitigation measures are 

implemented, 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 would not fund the Proposed Action, construction of 

the demonstration wind turbine and associated facilities would not occur, and impacts to TEC&P 

species would continue at present levels, with fluctuations due primarily to weather, disease, and 

other natural causes. 

4.4.3 Mitigation and Monitoring 

No additional mitigation or monitoring is recommended beyond the applicant-committed 

practices identified in Chapter 2. 

4.4.4 Residual Impacts 

Under the Proposed Action, there would be a negligible increase in the risk of collisions of bald 

eagles with the proposed wind turbine and/or meteorological tower. There would also be 

negligible additional impacts to any other TEC&P species that may occur in the project area. 
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 would be disturbed by construction operations. 

Because less than 1.25 acres would be disturbed for the life-of-the-project for the construction of 

the wind turbine, service building, meteorological tower, and cables and powerline, no topsoil 

would be removed or salvaged. Instead, wheeled vehicles that drive cross-country would disturb 

the remaining 8.45 acres. Direct impacts would be limited to compaction/destruction of 

vegetation when construction equipment operates off any roads. These impacts may result in a 

limited increase in runoff, erosion, and sedimentation into any receiving waters. All disturbed 

vegetation would be of a kind that is common and widespread in the project area and vicinity. 

Short-term control of surface runoff would be accomplished by implementation of storm water 

pollution control measures required by the WDEQ/WQD and described in the Proposed Action. 

In addition, long-term control of surface runoff would be accomplished by successful 

implementation of the stabilization and reclamation operations described in the Proposed Action. 

No additional mitigation beyond those already included in the Proposed Action would be 

required. The Proposed Action would not have any significant impacts on vegetation. 

4.5.2 No Action Alternative 

Under the No Action Alternative, the DOE would not fund the Proposed Action, construction of 

the demonstration wind turbine and associated facilities would not occur, and impacts to 

vegetation resources would continue to occur at current rates. 

4.5.3 Mitigation and Monitoring 

No additional mitigation or monitoring is recommended beyond the applicant-committed 

practices identified 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 

approximately 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 decommissioned, all disturbed 

areas would be reclaimed. These impacts assume that the site would 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 project area. The general project area has already been altered by 

human encroachment including the PRPA Medicine Bow Wind Farm, the Elk Mountain to 

Medicine Bow unpaved road, and the WAPA and Carbon Power and Light powerlines. The 

existing PRPA Medicine Bow Wind Farm dominates the view of and from the project area. The 

10 wind turbines, two meteorological towers, service building, and access roads are the most 

visible components. The turbine towers for the seven existing wind turbines (Vestas [brand] 

660-kW units), located south of the service building, are 164-ft tall, and the maximum 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 (approximately 100 ft higher than the existing towers) and the 

maximum height at the top of the blade would be approximately 410 ft (approximately 169 ft 

higher than the maximum height of the existing turbines). The proposed wind turbine would be 

taller than the existing turbines but would likely be only slightly more visible (because of the 

height) from a distance than the existing wind turbines. The existing wind turbine towers and 

blades are painted white, and the proposed wind turbine (tower and blades) would also be 

painted white. While approximately 60% taller than the existing wind turbines, the proposed 

wind turbine would not dominate the local viewshed and would likely blend into the existing 

PRPA wind farm. 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 57 

The proposed wind turbine as viewed from the unpaved Elk Mountain to Medicine Bow road 

would likely appear to be an additional and larger wind turbine that 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 environment. The meteorological 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 farm and would not dominate the local viewshed. Nor 

would the Proposed Action dominate the viewshed beyond 3 mi as the size difference between 

the proposed wind turbine and the existing wind turbines would appear less as the distance from 

the viewer increases. In addition, the Proposed Action would not be visible from Medicine Bow, 

Rock River, McFadden, Arlington, Hanna, or Elk Mountain. No additional mitigation beyond 

those already included in the Proposed Action would be required. The Proposed Action would 

be a continuation of existing wind energy development in the general 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 would not fund the Proposed Action, construction of 

the demonstration wind turbine and associated facilities would not occur, and no additional 

impacts to visual resources would occur. 

4.6.3 Mitigation and Monitoring 

No additional mitigation or monitoring is recommended beyond the applicant-committed 

practices identified in Chapter 2. 

4.6.4 Residual Impacts 

The construction and operation of the Proposed Action would result in some additional impacts 

to visual resources. The wind turbine would be the most visible component of the Proposed 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 58 

Action. Vegetation would be compacted when vehicles operate off-road, and these impacts 

would be visible for 2-4 years. Visual impacts would be minimized to the casual observer with 

the Proposed Action being located immediately adjacent to the existing PRPA wind farm. 

Impacts would continue for approximately 20 years until the wind turbine and associated 

facilities are decommissioned, removed, and the disturbed areas reclaimed 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 approximately 10 acres of soil disturbance and excavation 

associated with construction of the pads for the wind turbine, meteorological tower, and service 

building, from the construction of the access road, and from compaction of vegetation and soil 

due to equipment operating off of existing access roads. These actions would cause a limited 

increase in sedimentation and off-site channel 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 measures such as interceptor ditches, sediment 

traps/silt fences, water bars, and silt fences. Implementation of prompt reclamation and 

stabilization procedures presented in the Proposed Action would also minimize potential impacts 

to surface water resources. There are no jurisdictional wetlands in the project area; therefore, the 

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 Action would 

have negligible short-term and no long-term impacts on water quality and no short-term or longterm impacts on water quantity to receiving 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 would not fund the Proposed Action, construction of 

the demonstration wind turbine and associated facilities would not occur, and impacts to surface 

water resources would continue at current rates. 

4.7.3 Mitigation and Monitoring 

No additional mitigation or monitoring is recommended beyond the applicant-committed 

practices identified in Chapter 2. 

4.7.4 Residual Impacts 

Even with the implementation of the Storm Water Pollution Prevention Plan, there would be a 

negligible short-term increase in sedimentation 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 construction/installation phase of the Proposed Action 

would be pro-actively mitigated as discussed above. Compared to the construction phase, the 

annual rate of sedimentation would decrease during the operations phase of the project. 

Following decommissioning and removal of the project and successful completion 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 from the direct loss of habitat due to the 

construction/installation of project-related facilities and vegetation compaction; displacement of 

wildlife due to disturbance by project-related activities; direct mortality due to construction- and 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 60 

operational-related activities; increased mortality due to poaching and harassment; and an 

increased likelihood of vehicle/animal collisions due to increased traffic. Because the Proposed 

Action would be located immediately adjacent to the existing PRPA wind farm, the addition of 

the Proposed Action would not be likely to have any significant short- or long-term impacts on 

wildlife populations. 

Construction/installation activities would likely cause some wildlife species that currently utilize 

the project area to temporarily vacate the area (up to 0.5 mi or more) around the active area while 

construction operations are occurring. The temporary loss of big game habitat due to the 

construction related facilities and vegetation compaction would be mitigated by the fact that the 

project area would be limited to less than 10 acres, construction operations would likely require 

only 2 months to complete, and applicant-committed measures included in the Proposed Action 

would minimize surface disturbance. Once construction operations have been completed, most 

affected species would likely re-utilize the impacted portion of the project area. 

4.8.1.1 Big Game 

The project area is located in crucial winter/yearlong range for pronghorn and winter/yearlong 

range for mule deer and elk. However, the Proposed Action would directly impact less than 10 

acres of native vegetation. During severe winters, crucial winter ranges are important because 

these areas can provide animals with exposed vegetation and topographic protection from 

extremely harsh weather conditions. In addition, crucial winter ranges are important in 

maintaining a self-sustaining population at or above WGFD population objectives over the long 

term. During the 2-month construction period, there could be an indirect impact of the 

temporary displacement of pronghorn that would normally occupy the immediate project area. 

In addition to the project area, the temporary displacement could also include a 0.5-mi area 

around the project area or a total of 503 acres (0.79 mi

2

). 

The project area is located in a crucial winter/yearlong range for pronghorn that contains 361,000 

acres (564 mi

2

). Therefore, the construction/installation phase of the Proposed Action (that may 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 61 

occur during a severe winter) could potentially displace pronghorn from approximately 0.2% of 

the crucial winter big game range located in the general vicinity of the project area. It is 

expected that any displaced pronghorn would relocate to unaffected portions of the 564-mi

2 

crucial winter/yearlong habitat that exists near the project area. While some pronghorn may be 

temporarily displaced from the project area, the displacement would be temporary, would impact 

only 0.2% of the crucial winter/yearlong habitat within the general project area. To minimize 

potential impacts to pronghorn, construction activities would be limited during severe winter 

conditions. Specifically, Clipper would maintain contact with local WGFD personnel, and if it is 

determined by WGFD that severe winter conditions exist, Clipper would limit the number of 

construction vehicles that would be allowed to access the site. In addition, Clipper would 

minimize the amount of time personnel would be at the construction site. Reclamation and 

revegetation procedures would be followed to minimize 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 severe winter during the construction phase, the 

Proposed Action could likely still result in the 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 because the area contains yearlong habitat, the animals would be under less stress 

than during a severe winter, and could easily move and find alternative areas for forage and 

cover. Therefore, the Proposed Action (if the construction phase does not occur during a severe 

winter) would have negligible impacts to the pronghorn population in the herd unit. Once 

construction operations have been completed, pronghorn would likely acclimate to human 

disturbance and utilize habitat at near pre-disturbance levels. 

Mule deer and elk that may occur within the project area and the 0.5-mi

2

 buffer area may be 

temporarily displaced to other suitable habitats due to the construction phase of the Proposed 

Action. If construction occurs during a severe winter, many of the mule deer and elk in the area 

will likely move to crucial winter range that is located approximately 1 mi southeast and 13 mi 

south of the project area, respectively. The Proposed Action would not have direct or indirect 

impacts on any crucial winter range for mule deer or elk. Once the 2-month construction phase 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 62 

is completed, mule deer and elk would likely re-utilize the unaffected portion of the project area. 

Therefore, the construction phase of the Proposed Action would have negligible impacts on mule 

deer and elk populations. 

Surveys of pronghorn, mule deer, and elk at SeaWest’s Foote Creek Rim Wind Farm (located 

approximately 9 mi south of the project area) conducted from 1995 through 1998 during the 

operational phase of this project indicate that abundance and distribution of these species did not 

appear to be significantly 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 farm 

would have only negligible impacts on pronghorn antelope, mule deer, and elk during the 

operational phase of the project. 

It is also possible the individual pronghorn, mule deer, and/or elk may be killed (an indirect 

impact) as a result of vehicular/animal collisions on the 5-mi segment of the Medicine Bow to 

Elk Mountain Road that would be associated with the Proposed Action. However, the 

anticipated level of traffic would be limited to less than 20 trips per day between the community 

of Medicine Bow and the project area during the construction phase and less than four trips per 

day during the operational phase of the project. Maintenance personnel would 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 that currently 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 operations completed, pronghorn, mule deer, and elk would be able 

to re-utilize all areas affected by the Proposed Action. 

Based upon the small amount of disturbance, the limited amount of vehicular traffic during the 

project, and the appropriate implementation of reclamation and revegetation procedures, the 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 63 

Proposed Action would result in nonsignificant short- and long-term impacts to local pronghorn, 

mule deer, and elk populations. 

4.8.1.2 Other Mammals 

Impacts to other mammals due to the Proposed Action would include direct mortality during 

construction activities, especially to those that may take refuge in burrows that would be 

destroyed by project-related activities, and a potential increase in mortality from vehicle/animal 

collisions. The relatively small amount of wildlife habitat impacted by the Proposed Action 

would result in limited impacts to all wildlife species. Most small mammal species are relatively 

tolerant of human activity and likely would experience reduced populations in direct proportion 

to the amount of habitat destruction. This would be most likely true for species with relatively 

small home ranges (rodents, lagomorphs, etc.) and would be less applicable to more wideranging species such as coyote. Project impacts to small mammals would likely be masked by 

natural variations in populations due to weather, disease, and other natural factors. 

According to Young et al. (2003), at least four bat species were found dead near wind turbines at 

SeaWest’s Foote Creek Wind Farm located approximately 9 mi south of the project area. The 

majority--approximately 80%--were hoary bats, 9% were little brown bats, 8% were silverhaired bats, and 1% were big brown bats and 2% could not be identified. Most of the identified 

bat species likely nest and/or roost in aspen trees, cottonwood trees, and abandoned buildings 

located near the wind farm. The dead bats were found primarily between June and September, 

with most of the bats found during August. No bat carcasses were found associated with the 

lattice meteorological towers. Young et al. (2003) estimated annual mortality at 1.34 bats per 

wind turbine. 

Bat mortality data collected by Young et al. (2003) at the Foote Creek Wind Farm (located 

approximately 10 mi south of the project area) were based on 69 600-kilowatt Mitsubishi wind 

turbines that are smaller that the proposed Clipper demonstration wind turbine. The Clipper 

demonstration wind turbine would also have other design and operational differences compared 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 64 

to the Mitsubishi 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 ft2

 compared to the 

sweep area of the Clipper demonstration wind turbine of 73,024 ft2

, an increase of almost fivefold. 

Various factors likely influence the rate of bat and avian mortalities 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 ridges, position of the individual turbine in the turbine string, weather, 

distance to suitable habitat, flying height of the specific species, etc. (Young et al. 2003). It 

should be noted that no bat or avian mortality studies have been conducted at the PRPA 

Medicine Bow Wind Farm (personal communication, October 20, 2004, with Paul Warila, 

PRPA, Fort Collins, Colorado). In order to compare potential bat moralities between the 

Mitsubishi wind turbine to the Clipper wind turbine, it is assumed that all factors are constant 

except for blade sweep area and that the rate of bat mortalities would be based solely upon a 

comparison of the blade sweep area for each wind turbine model. This approach would likely 

result in a worst-case scenario since there is limited suitable nesting or roosting habitat in the 

immediate project area compared to the Foote Creek Wind Farm. It should also be noted that bat 

mortalities were only recorded at approximately 70% of the monitored wind turbines at the Foote 

Creek Wind Farm (Young et al. 2003). Therefore, based on these assumptions, the proposed 

Clipper demonstration wind turbine would result in approximately 6.7 bat mortalities per year 

compared to 1.34 bat mortalities per year for the small Mitsubishi wind turbines. As a result, 

the Proposed Action is not expected to adversely impact any of the bat population in the area. 

To document potential impacts to bat species, Clipper would conduct mortality surveys near the 

wind turbines and meteorological tower during the first summer season (June through September 

2005) of operation of the Proposed Action. This period coincides with when bats typically 

utilize the general project area and when bat mortalities were documented at the Foote Creek 

Wind Farm (Young et al. 2003). Clipper would utilize mortality survey methods similar to those 

developed for the nearby Foote Creek Rim Wind Farm (Young et al. 2003). Personnel would 
Final 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. Search transects would be set approximately 25-30 ft apart, and the 

searcher would walk at a rate of approximately 2 mph along the transect searching both sides 

approximately 12-15 ft for casualties out approximately 12-15 ft. It is estimated that it 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 may indicate the time and cause of death. All carcasses 

located would be photographed as found and mapped. If the species information cannot be 

determined, the carcass would be bagged and transported to a qualified biologist for proper 

identification. At the end of the survey period, the data would be compiled, summarized, and 

submitted to the DOE, USFWS, and WGFD. 

Rare habitats (e.g., springs, wetlands, and riparian areas) would not be impacted (because none 

occur in the project area), and applicant-committed practices to minimize impacts to wildlife 

would mitigate and reduce impacts to other animals. Therefore, the Proposed Action would not 

have any significant impacts on other mammal species. 

4.8.1.3 Raptors 

Direct impacts to raptors include mortality due to collisions with the wind turbine and 

meteorological tower. Other potential impacts to nesting raptors include decreased raptor 

reproductive success due to the physical disturbance of the nest or to increased human 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 Bird Treaty Act (U.S.C. 703 [1918]). No raptor 

nests were documented within 1.0 mi of the project area; however, there are five raptor 

nests/eyries within 2.0 mi of the proposed project area (refer 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 unlikely that individual nesting raptors or raptor populations would 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 66 

be impacted by the Proposed Action; however, individual birds could be killed as a result of 

flying into the rotating wind turbine blades. 

No site-specific raptor mortality studies have been conducted at the PRPA wind farm. A single 

dead golden eagle was found in 2003 near the one of the PRPA wind turbines and the incident 

was reported to the USFWS. No other raptor mortalities have been documented at the PRPA 

wind farm since the facility was constructed in 1998 (personal communication, October 28, 

2004, with Bill Young, PRPA Wind Site Support Engineer, Medicine Bow, Wyoming). 

According to Young et al. (2003), there were only five reported raptor mortalities (which 

accounted for 8% of the avian mortalities) between November 1998 and June 2002 (3.5 years) at 

the monitored portion of SeaWest’s Foote Creek Wind Farm located approximately 9 mi south of 

the project area. The remaining 92% of the avian mortalities were passerine birds. Raptor 

mortalities were low during the study despite high raptor use estimates at the site. For example, 

no golden eagle mortalities were recorded during the study despite the fact that golden eagles 

accounted for approximately 40% of all raptor use of the area. On the other hand, use of the 

study area by American kestrels accounted for only 5% of the total raptor use, but accounted for 

60% of the raptor carcasses found in the area. Five raptor carcasses were found--three American 

kestrels, one northern harrier, and one short-eared owl--during the 3.5-year study period. There 

were no recorded raptor mortalities associated with any of the meteorological towers. Young et 

al. (2003) estimated there was an average of 0.03 raptor mortalities per wind turbine per year. 

Raptor mortality data collected by Young et al. (2003) at the Foot Creek Wind Farm (located 

approximately 10 mi south of the project area) were based on 69 600-kilowatt Mitsubishi wind 

turbines that are smaller that the proposed Clipper demonstration wind turbine. The Clipper 

demonstration wind turbine would also have other design and operational differences compared 

to the Mitsubishi 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 ft2

 compared to the 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 67 

sweep area of the Clipper demonstration wind turbine would be 73,024 ft2

 an increase of almost 

five-fold. 

Various factors likely influence the rate of raptor mortalities 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 ridges, position of the individual turbine in the turbine string, weather, 

distance to suitable habitat, flying height of the specific species, etc. (Young et al. 2003). It 

should be noted that no bat or avian mortality studies have been conducted at the PRPA 

Medicine Bow Wind Farm (personal communication, October 20, 2004, with Paul Warila, 

PRPA, Fort Collins, Colorado). In order to compare potential raptor mortalities between the 

Mitsubishi wind turbine to the Clipper wind turbine, it is assumed that all factors are constant 

except for blade sweep area and that the rate of raptor mortalities would be based solely upon a 

comparison of the blade sweep area for each wind turbine model. This approach would likely 

result in a worst-case scenario since there is limited suitable nesting or roosting habitat in the 

immediate project area compared to the Foote Creek Wind Farm. It should also be noted that 

avian mortalities were only recorded at approximately 67% of the monitored wind turbines at the 

Foote Creek Wind Farm (Young et al. 2003). Therefore, based on these assumptions, the 

proposed Clipper demonstration wind turbine would result in approximately 0.15 raptor 

mortalities per year compared to 0.03 raptor mortalities per year for the smaller 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 meteorological tower during the first 12-month period of operation of the 

Proposed Action. Clipper would utilize mortality survey methods similar to those developed for 

the nearby Foote Creek Rim Wind Farm (Young et al. 2003). Personnel would conduct one 

survey every 2 weeks, and each survey would involve walking transects established within 250 ft 

of each tower. Search transects would be set approximately 25-30 ft apart, and the searcher 

would walk at a rate of approximately 2 mph along the transect searching both sides out 

approximately 12-15 ft for casualties. It is estimated that it should require 0.75 hour to survey 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 68 

each tower. 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 

may indicate the time and cause of death. All carcasses located would be photographed as found 

and mapped. If the species information cannot be determined, the carcass would be bagged and 

transported to a qualified biologist for proper identification. At the end of the survey period, the 

data would be compiled, summarized, and submitted to the DOE, USFWS, and WGFD. 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, electrical components of the Proposed Action would be 

designed, constructed, operated, and maintained in conformance with the National Electrical 

Safety Code and other applicable codes and standards. In addition, all aboveground electrical 

facilities would also be designed, constructed, operated, and maintained in accordance with 

Suggested Practices for Raptor Protection on Powerlines: The State of the Art in 1996 (Avian 

Power Line Interaction Committee 1996). Implementation of these standards would reduce the 

risk of raptor electrocutions with powerline structures. The USFWS guideline recommend 

grouping wind turbines (i.e., avoid siting individual wind turbines) to reduce potential impacts to 

raptors and placing wind turbines away from ridges and away from prairie dog colonies (USFWS 

2003). The Proposed Action complies with these guidelines. 

Construction activities would disturb less than 10 acres; therefore, reductions in prey species 

abundance would be minimal and are not anticipated to adversely affect raptor populations. 

Foraging habitat for raptors within the project area would be reduced until revegetation 

successfully attracts small mammals and birds that serve as the prey base for the raptors. 

Therefore, the Proposed Action would not have any significant impacts on raptors. 

4.8.1.4 Upland Game Birds 

The Proposed Action would result in the disturbance of less than 10 acres of native vegetation; 

however, this amount 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 possible the individual greater sage-grouse may be killed as a result of 

vehicular/bird collisions on the 5-mi segment of the Medicine Bow to Elk Mountain Road. 

However, the anticipated level of traffic would be less than 20 trips per day between the 

community of Medicine Bow, and the project area during the construction phase and less than 

four trips per day during the operational phase of the project. In addition, maintenance personnel 

would 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 that 

currently observed at the adjacent PRPA wind farm, and potential vehicle/bird collisions would 

result in negligible impacts to greater sage-grouse. 

According to Young et al. (2003), no greater sage-grouse mortalities were recorded at either the 

wind turbines or meteorological towers during the 3.5-year monitoring period at SeaWest’s 

Foote Creek Rim wind farm. Therefore, greater sage-grouse would not be impacted (by 

collisions with the meteorological tower or wind turbine). 

Noise levels associated with the Proposed Action would likely increase from a maximum of 

60 dBA (under windy natural conditions with the existing Medicine Bow Wind Farm) to 105 

dBA with the addition of the proposed Clipper wind turbine. However, these noise levels would 

occur only during periods when the wind is blowing at least 18 mph and the wind turbine is 

operating. Male greater sage-grouse perform a courtship display in the early morning 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 

females. Yeo et al. (1984) determined that there was no decrease in greater sage-grouse lek 

attendance due to the construction or operation of a large wind turbine generators located near 

the Foote Creek Wind Farm. In addition, variations 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 negligible impacts on greater sage-grouse. 

The construction of the Clipper wind turbine could also adversely affect nesting of greater sagegrouse near the project area. After the courtship period, approximately two-thirds of the female 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 70 

greater sage-grouse nest within 3 mi of where they were bred (WGFD 2003a). Therefore, the 

project area and the existing Medicine Bow Wind Farm would be located within greater sagegrouse nesting habitat, and this area could have already been impacted by the construction and 

operation of the existing wind farm. Connelly et al. (2000) noted that nest success is better in 

areas where the greater sage-grouse nest in sagebrush 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 

likely have negligible additional impacts on nesting greater sage-grouse. 

To minimize potential impacts to active greater sage-grouse leks during the construction of the 

Proposed Action, Clipper would not conduct any surface-disturbing activities within 0.25 mi of 

any active lek during the greater sage-grouse mating 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 without permission from the WGFD. Reclamation activities would be conducted prior to 

April 1, unless prior permission is obtained from WGFD. 

Mourning doves would likely be impacted in direct proportion to the amount of suitable habitat 

that is disturbed by the Proposed Action. There would be negligible impacts on mourning dove 

population because only 10 acres would be disturbed by the Proposed Action. In addition, 

Young et al. (2003) documented only one mourning dove mortality at either the wind turbines or 

meteorological towers during the 3.5-year monitoring period at SeaWest’s Foote Creek Rim 

wind farm. This represents less than 0.5% of the total recorded mortalities. 

4.8.1.5 Other Birds (Including Migratory Birds) 

According to Young et al. (2003) passerine birds and other non-raptor species accounted for 92% 

of the avian mortalities recorded at wind turbines and 100% of the avian mortalities at 

metrological towers at the monitored portion of SeaWest’s Foote Creek Wind Farm located 

approximately 9 mi south of the project area. A total of 37 species was killed and approximately 

half of the species were nocturnal migrants. For example, approximately 29% of the fatalities 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 71 

were horned lark, 7% were vesper sparrow, 5% were chipping sparrow, and 5% were Brewer’s 

sparrow. Species such as rock wren, house wren, Wilson’s warbler, American robin, 

Townsend’s warbler, green-trailed towhee, white-crowned sparrow, mountain bluebird, 

Lincoln’s sparrow, cliff swallow, and brown creeper were documented between 2% and 4% of 

the total mortalities. The remaining 22 species each represented less than 2% of the total species 

mortalities documented at the Foote Creek wind farm. 

Young et al. (2003) estimated that there was an average of 1.46 passerine mortalities per wind 

turbine per year and an average of 8.1 passerine mortalities per meteorological tower per year. 

Passerine bird mortality data collected by Young et al. (2003) at the Foote Creek Wind Farm 

(located approximately 10 mi south of the project area) were based on 69 600-kilowatt 

Mitsubishi wind turbines that are smaller that the proposed Clipper demonstration wind turbine. 

The Clipper demonstration wind turbine would also have other design and operational 

differences compared to the Mitsubishi 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 ft2 

compared to the sweep area of the Clipper demonstration wind turbine would be 73,024 ft2

, an 

increase of almost five-fold. 

Various factors likely influence the rate of avian mortalities 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 ridges, position of the individual turbine in the turbine string, weather, 

distance to suitable habitat, flying height of the specific species, etc. (Young et al. 2003). It 

should be noted that no bat or avian mortality studies have been conducted at the PRPA 

Medicine Bow Wind Farm (personal communication, October 20, 2004, with Paul Warila, 

PRPA, Fort Collins, Colorado). In order to compare potential passerine bird mortalities between 

the Mitsubishi wind turbine to the Clipper wind turbine, it is assumed that all factors are constant 

except for blade sweep area and that the rate of bird mortalities would be based solely upon a 

comparison of the blade sweep area for each wind turbine model. This approach would likely 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 72 

result in a worst-case scenario since there is limited suitable nesting or roosting habitat in the 

immediate project area compared to the Foote Creek Wind Farm. It should also be noted that 

avian mortalities were only recorded at approximately 67% of the monitored wind turbines at the 

Foote Creek Wind Farm (Young et al. 2003). 

Therefore, based on these assumptions, the proposed Clipper demonstration wind turbine would 

result in approximately 7.3 passerine bird mortalities per year compared to 1.46 passerine bird 

mortalities per year for the smaller Mitsubishi wind turbines. The estimated number of passerine 

bird mortalities associated with the meteorological tower would be expected to be similar 

(8.1 passerine birds per year) to that documented by Young et al. (2003) at the Foote Creek Wind 

Farm. Therefore, the Proposed Action would likely result in approximately 15.4 passerine bird 

mortalities per year as a result of the meteorological tower and wind turbine. 

To document potential impacts to passerine species, Clipper would conduct mortality surveys 

near the wind turbine and meteorological tower during the first 12-month period of operation of 

the Proposed Action. Clipper would utilize mortality survey methods similar to those developed 

for the nearby Foote Creek Rim Wind Plant (Young et al. 2003). Personnel would conduct one 

survey every 2 weeks, and each survey would involve walking transects established within 250 ft 

of each tower. Search transects would be set approximately 25-30 ft apart, and the searcher 

would walk at a rate of approximately 2 mph along the transect searching both sides out 

approximately 12-15 ft for casualties. It is estimated that is should require 0.75 hour to survey 

each tower. For each casualty identified, data recorded would include species, sex, and age 

(when possible), date and time collected, location collection, condition, and any comments that 

may indicate the time and cause of death. All carcasses located would be photographed as found 

and mapped. If the species information cannot be determined, the carcass would be bagged and 

transported to a qualified biologist for proper identification. At the end of the survey period, the 

data would be compiled, summarized, and submitted to the DOE, USFWS, and WGFD. 

Additional impacts would probably occur in direct proportion to the amount of a species' habitat 

that would be disturbed. Some increased mortality would also be likely from bird collisions as a 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 73 

result of increased vehicle traffic. Disturbance would be approximately 10 acres, and measures 

already described above to mitigate surface disturbances and project-related activities would 

minimize impacts to other bird species as well. Impacts to waterfowl and shorebirds would be 

minimal because few areas of suitable habitat would be affected and because these birds would 

temporarily move to adjacent habitats undisturbed by construction. Other birds would also move 

to suitable adjacent habitats. Therefore, the Proposed Action would not have any significant 

impacts on the populations of other birds (including migratory birds). 

4.8.1.6 Amphibians, Reptiles, and Fish 

Impacts to amphibians and reptiles due to the Proposed Action likely would occur in direct 

proportion to the amount of their habitat disturbed. Applicant-committed practices described in 

the Proposed Action to minimize surface disturbance and to ensure timely reclamation and 

stabilization would minimize project-related impacts to amphibians and reptiles. Some reptiles 

and amphibians could be killed in vehicle/animal collisions, but such impacts would be 

negligible. The applicant-committed practices described in the Proposed Action to minimize 

surface disturbance and ensure timely reclamation and stabilization would minimize projectrelated impacts to fish that occur in Medicine Bow River. Therefore, 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 from the direct loss of habitat due to the 

construction/installation of project-related facilities and vegetation compaction, displacement of 

wildlife due to disturbance by project-related activities, direct mortality due to construction- and 

operational-related activities, increased mortality due to poaching and harassment, and an 

increased likelihood of vehicle/animal collisions due to increased traffic. In addition, some avian 

individuals would be killed as a result of collisions with the rotating wind turbine blades or with 

the meteorological tower. No additional mitigation beyond those already included in the 

Proposed Action would be required. Despite the potential temporary displacement of big game 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 74 

individuals during construction/installation of the Proposed Action and the mortalities of 

individual avian species during operation of the 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 would not fund the Proposed Action, construction of 

the demonstration wind turbine and associated facilities would not occur, and wildlife (i.e., big 

game, other mammals, raptors, upland game birds, other birds, and amphibians, reptiles, and 

fish) populations would continue at present levels, with fluctuations due primarily to weather, 

disease, human impacts (e.g., the PRPA wind farm), and other natural causes. 

4.8.3 Mitigation and Monitoring 

No additional mitigation or monitoring is recommended beyond the applicant-committed 

practices identified 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 crucial winter/yearlong range for pronghorn and the mortality of a 

limited number of individual raptors, bats, and passerine and other birds. Construction activities 

would occur over a 2-month period of time and reclamation and revegetation operations would 

be conducted upon the decommissioning and removal of the various project facilities and 

equipment. Some individual bird or animal species would be destroyed as a result of 

vehicle/animal collisions. In light of the fact that the Proposed Action would result in the 

addition of a single wind turbine and meteorological tower immediately adjacent to the existing 

PRPA wind farm, the Proposed Action would result in nonsignificant residual impacts to wildlife 

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

4.9 CUMULATIVE IMPACTS 

Cumulative impacts result from the incremental impacts of an action that is added to other past, 

present, and reasonably foreseeable future actions, regardless of who is responsible for such 

actions. Cumulative impacts may result from individually minor, but collectively significant, 

actions occurring over a period of time (40 C.F.R. 1508.7). All environmental resources have 

been evaluated for cumulative impacts in accordance with DOE and CEQ policy (CEQ 1997). 

The general project area has been utilized continuously for agricultural purposes (livestock 

grazing) and oil and gas development since the early 1900s. In addition, coal mining (the 

Carbon Basin surface and underground coal mine [approved but not operating]) and wind energy 

development projects (the existing Foote Creek and PRPA wind farms and the approved but not 

constructed Simpson Ridge wind farm) are present within the general project area. The Foote 

Creek Wind Farm currently has 183 wind turbines, and an additional 857 wind turbines have 

been authorized for construction but have not been constructed at the Simpson Ridge site (BLM 

1995). There are also numerous 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 Bow to Elk Mountain Road). In addition, utility corridors (such as transmission and 

distribution powerlines and various natural gas pipelines) and the communities of Medicine Bow 

and Elk Mountain are also located within the general project area (refer to Figure 4.1). Despite 

these facilities, the natural environment within a major portion of the general project area 

remains largely unaffected by human-related activities, and the existing development does not 

appear to having any significant impacts on the existing environment. 

There are no other large-scale industrial or commercial developments such as quarrying or 

mining operations, logging activities, oil and gas development activities, wind developments 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 76 

This figure is a separate file Fig 4-1.pdf. 

Figure 4.1 Existing and Authorized Projects in the 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 reasonably foreseeable 

future actions within the general project area that would contribute any cumulative impacts. 

The Proposed Action would involve the construction/installation, operation, and after 20 years 

the removal of a single 2.5-MW wind turbine, a 240-ft tall meteorological tower, a small service 

building, and associated underground powerlines and cables. The Proposed Action would be 

located immediately adjacent (within 800 ft) of PRPA’s existing Medicine Bow Wind Farm. 

Within this facility, there are 10 large commercial wind turbines, two meteorological 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 Medicine Bow Wind Farm (personal 

communication, October 20, 2004, with Paul Warila, PRPA, Fort Collins, Colorado). It has been 

determined that cumulative impacts would not be significant because there are no past, present, 

or reasonable foreseeable future actions that, when combined with the Proposed Action, would 

result in impacts beyond those that already exist or have already been identified and discussed in 

Chapter 4.0 of this EA. Therefore, non-significant cumulative impacts to all environmental 

resources would be anticipated from the implementation of the Proposed Action. 

4.10 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES 

An irreversible and irretrievable commitment of resources is defined as a permanent reduction or 

loss of a resource that, once lost, cannot be regained. The primary irreversible and irretrievable 

commitment of resources due to the Proposed Action would be labor, materials, and energy 

expended utilized to construct the Proposed Action. Other irreversible and irretrievable 

commitments of resources would include soil lost through wind and water erosion; loss of 

productivity (i.e., forage and wildlife habitat) from lands involved in project; inadvertent or 

accidental destruction of unidentified cultural resources; and loss of animals due to mortality by 

collisions with vehicles, the meteorological tower, and the wind turbine. 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 78 

4.11 SHORT-TERM USE OF THE ENVIRONMENT VERSUS LONG-TERM 

PRODUCTIVITY 

For purposes of this EA, short-term use of the environment is that use during the life of the 

project (i.e., approximately 20 years), whereas long-term productivity refers to the period of time 

after the project has been decommissioned and the equipment has been removed and the area is 

reclaimed and stabilized. Short-term use of environment would not affect the long-term 

productivity of the proposed project area. After project has been completed, the equipment and 

facilities decommissioned and removed, and all disturbed areas reclaimed and stabilized, the 

same resources that were present prior to the project would be available. It may take 5-7 years 

after the project has been completed for some of the impacted and reclaimed areas to have 

vegetation cover and biodiversity comparable to predisturbance conditions. However, 

reclamation would eventually provide conditions to support wildlife and livestock. Use of the 

proposed project area during the life of the project would not preclude 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 GOVERNMENTAL AGENCIES CONTACTED 

Table 5.1 Record of Persons, Groups, and Governmental Agencies Contacted. 

Company/Agency Individual Discipline/Position 

Project Proponent – Clipper Tom Feiler Project Manager 

Windpower, Inc. 

Eli Bosco Project Manager Leader 

U.S. Fish and Wildlife Service, Brian Kelly Field Supervisor, Wyoming Field Office 

Wyoming Office Kathleen Erwin Staff Biologist 

State of Wyoming 

Wyoming Department of Parks and Judy Wolf Deputy State Historic Preservation Officer 

Cultural Resources 

Wyoming Department of Barb Sahl NPDES Storm Water Permit Specialist 

Environmental Quality 

Wyoming Game and Fish Department Bill Wichers Deputy Director 

Wyoming Natural Diversity Database Terra Dutcher Database Specialist 

Table 5.2 List of Preparers. 

Firm/Company Name EA Responsibility 

TRC Mariah Associates Inc. 

Department of Energy 

Scott Kamber 

James Lowe 

Roger Schoumacher 

Genial DeCastro

Tamara Linse 

Beth Rintz 

Suzanne Luhr 

Maureen Jordan

Steve Blazek 

Roselle Drahushas-Crow

John Kersten 

Kristin Kerwin

Alan Laxson

Project Management, EA Preparation, and Quality 

Control

EA Preparation-Cultural Resources 

EA Preparation-Quality Assurance 

Document Production and Quality Control 

Technical Editing, Document Production

Document Production 

CADD Specialist 

DOE/NREL Senior Environmental Scientist 

DOE/NREL NEPA Manager 

DOE NEPA Document Manager 

DOE Manager

DOE NEPA Coordinator 

DOE/NREL Project Manager
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 80 

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Wyoming Game and Fish Department. 1991. Wyoming trout stream classification map. 

Wyoming Game and Fish Department, Cheyenne, Wyoming. 

. 1997. Black-footed ferret. Wyoming Game and Fish Department Conservation 

Publication, Volume 13, Number 8. 3 pp. 

. 1999. Atlas of birds, mammals, reptiles, and amphibians in Wyoming. Wyoming 

Game and Fish Department, Wildlife Division. 

. 2002. Annual report of upland game and furbearing harvest 2000. Cheyenne, 

Wyoming. 100 pp. 

. 2003a. Wyoming greater sage-grouse conservation plan. Wyoming Game and Fish 

Department, Cheyenne, Wyoming. 97 pp. 

. 2003b. Big game herd unit and range, sage grouse lek GIS shapefile Information. 

Wyoming Game and Fish Department, Geographic Information Sciences and Services, 

Cheyenne, Wyoming. Unpublished data. 

. 2004. Annual big game herd unit reports, 2003. Laramie region. Wyoming Game and 

Fish Department, Cheyenne, Wyoming. 

Wyoming Geological Survey. 1996. Final report, Wyoming gap analysis: A geographic 

analysis of biodiversity prepared in cooperation with the Wyoming Cooperative Fish and 

Wildlife Research Unit and the University of Wyoming, Laramie, Wyoming. 109 pp. 

Wyoming Natural Diversity Database. 2004. Data compilation for TRC Mariah Associates Inc. 

completed 10/28/04. Unpublished Report. Wyoming Natural Diversity Database, 

University of Wyoming, Laramie, Wyoming. 24 pp. 
Final EA, Clipper Windpower, Inc. Low Wind Speed Turbine Demonstration Project 85 

Yeo, J., A.F. Reeve, P. MacLaren, and A.L. Travsky. 1984. Medicine Bow wind energy project, 

wildlife studies, final report. Wyoming Game and Fish Department, Cheyenne, 

Wyoming, and University of Wyoming, Laramie, Wyoming. 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 with the initial phase of the Foote Creek Rim 

windpower project, Carbon County, Wyoming. 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." 

Page 64 After the secondparagraph,insertthefollowing newtable.

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." 

Page67 After the first paragraph,insertthefollowing:

"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 each 
tower. 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 would 
utilize 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 Wind 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 Wind 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 Wind Turbines. 
Final EA, Clipper Windpower, Inc. Low Speed Turbine Demonstration Project 39 

Figure 3.2 Surface Water 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 Projects 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 

3

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


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.


4

Migratory 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


5 
be 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) 

6 
United States Department of the Interior 

FISH AND Wll...DLIFE SERVICE 

Ecological Services 

4000 Airport Parkway 

Cheyenne, Wyoming 82001 

In ReplyReferTo: 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 

2

this 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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Original Message . 

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


c~~­

J' 

900 
2004 

.1


WiOMING 

GAME AND FISH DEPARTMENT 

-;;:~~-;;;~ 

~. 

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

--~ 

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 Fax: 777-4610 Site:http://gf.state.wy.us (307) Web
Ms. 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 Commission 
November 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) 379-2224

FISH 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-foot 

tall 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)understandstheneedto 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. 

2 
Page15.Raragraph 2: The DEA statesthatthe construction/installation phasewould startin

December2004. Pleaseseeour commentaboveregardingtheimportanceofpre-construction 

baselinesurveys. 

Page 21.12aragra!>h3: 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 Clipper 

wind 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. TheServicerecommendsthat 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-grouseleks 

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 

theproposedClipperwind 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 

3 
on 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 of 

less 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 

4 
other 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 

0?~~9-

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* PrintedonRecycledPaper 

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 the 

first 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's 
opinion 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 the 

Foote 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 the 

project 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 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 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 2: The DEA statesthatthe construction/installation phasewould

startin December2004. Pleaseseeour commentaboveregardingtheimportanceof 

pre-constructionbaselinesurveys. 

DOE Responseto Comment5. 

Pleaserefer to DOE Responseto Comment 2. 

USFWS Comment6 

Page21. Paragraph3. The DEA statesthatpost-constructionsurveyswould 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 

encompassall 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). 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 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 Comment8 

Page43. 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 to 

the 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 include 
migration 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 from 
other 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-grouse 

unwarrantedfor 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.us 
SteveBlazek 

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 for 

environmental consequences,the lack of adequatebaseline, construction and postconstruction monitoring, and minimal commitment to avoid impacts or implement 

mitigation. 

FederalRecyclingProgram* PrintedonRecycledPaper 

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 the 

Foote 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, but 
theyaccountedfor 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-constructionmonitoringconductedatthe 

FooteCreekRim andSimpsonRidgeprojectareas.TheDEA statesthatthe 

environmentalanalysisincludestheexistingbaselinestudiessupplementedwith a 

reconnaissancesurvey. 

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.DOEfeels 
thesevarious 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-committedpracticeincludedin the projectto minimize 

impacts. Additional informationconcerningthetiming andextentof construction 

operationshasbeenincludedin theErrataDocumentfor theDEA. 

WGFD Comment6 

Measuresto mitigatesage-grouseconcernsareinadequate(p. 21). Theimmediate 

constructionof the projectdoesnot allow of anybaselinedatagatheringandmay 

discouragesage-grousefrom 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 three 
years. 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 designandcharacteristicsof 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 the 
ProposedAction 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, 

Enclosure