EPA comments on Shu’luuk Wind Project 

March 4, 2013

Subject: Draft Environmental Impact Statement (DEIS), Shu’luuk Wind Project, Campo Indian Reservation, San Diego County, California (CEQ # 20130001)

To: Robert Eben, Superintendent, Southern California Agency, Bureau of Indian Affairs

From: Kathleen Martyn Goforth, Manager, Environmental Review Office, Region IX, United States Environmental Protection Agency

… The Draft Environmental Impact Statement (DEIS) assesses the impacts of three project alternatives and a No-Action alternative. A preferred alternative is not identified. According to the DEIS, Alternative 1 would generate approximately 250 megawatts (MW) and consist of 85 3-megawatt turbines; Alternative 2 would generate approximately 200 MW and consist of 80 2-MW turbines plus 40 MW solar photovoltaic panels; and Alternative 3 would generate approximately 160 MW and consist of 71 2.3-MW turbines. All alternatives would include 25 miles of new road, 52 miles of underground cable, an on-Reservation substation, up to 5 miles of transmission line, an operations and maintenance facility, meteorological towers, and groundwater wells. …

Based on our review, we have rated the DEIS’s project alternatives as Environmental Concerns – Insufficient Information …. The DEIS acknowledges significant impacts regarding biological resources (birds and bats), noise, and visual resources, but does not clearly differentiate the levels of these impacts among the alternatives. For biological resources, the DEIS does indicate that Alternative 3 would result in lower golden eagle collision risk, and implies that it would present lower risk to raptors in general; however, insufficient information is provided to determine whether that alternative would also result in significantly reduced noise or other impacts. A clearer depiction of the severity of impacts of each alternative, especially with regard to those impacts that the DEIS predicts are significant, would offer valuable information to the decision-maker and the public.

A more robust alternatives analysis would help to illuminate the extent to which the scope and severity of impacts is driven by the size, number and location of turbines, thereby informing identification of the environmentally preferable alternative and selection of the preferred alternative.

Because the Campo Reservation has existing turbines, there is an opportunity to incorporate actual monitoring data into the impact assessment, yet no such information was provided in the DEIS. We encourage BIA to incorporate this information in the FEIS, to the extent it is available, to inform the impact assessment conclusions. …

Potential health impacts from noise were not discussed. The World Health Organization recommends that, where noise is continuous, the equivalent sound pressure level should not exceed 30 dBA indoors if negative effects on sleep are to be avoided. When the noise is composed of a large proportion of low-frequency sounds, a still lower guideline value is recommended, because low frequency noise can disturb rest and sleep even at low sound pressure levels. [See http://www.who.int/docstore/peh/noise/Comnoise-4.pdf p. 58.] …

We are concerned with the significant impacts to migratory birds, especially red-tailed hawks. The DEIS predicts high mortality rates to individuals and significant adverse effects to the population on the Reservation. …

We are concerned with the significant impacts to bats identified in the DEIS (p. 4.4-38). … The DEIS does include a recommendation for a Bird and Bat Conservation Strategy in MM BIO-3(d) to include minimization and compensation for adverse impacts, but no further information is provided on whether or how this could be accomplished for bats. …

Download original document: “EPA comments on Shu’luuk Wind Project”