Long Beach, Washington 98631

P O Box 724

October 21, 2011

To whom it may concern with interest in the Radar Ridge Wind Project:

As you may know, the Discovery Coast Audubon Society Chapter (Pacific County Washington) is the local Audubon Chapter with great interest regardingthe Radar Ridge Wind Project.

We have been thoroughly briefed, have continued to follow this project and have scrutinized their development and habitat conservation plans over the past several years of activity. As a result, this chapter remains in support of this development from the perspective of environmental stewardship as well as from the local Pacific County resident’sperspective.

We believe the developer hasbalanced the overall potential wildlife impact; continually responded toenhancements suggested;andtheir results have been successfullypeerreviewed. In our zeal to protect this planet’s wildlife, we must not lose sight of our primary mission to accommodate societal growth through wise and selective use of emissionless renewable energy resources. Namely “WIND”.

We are at a loss to understand how such a project, most likely providing a net-positive benefit to the species of concern could be so burdened with costlymitigation that it becomes no longer viable. To have this recalcitrance continue to happen, especially at this late stage, is appalling.

We have concluded that there is no credible scientific controversy and are quite shocked with the permitting delays and cost increases at our expense. This development is consumer ownedand the development costs are being paid by the ratepayer’s in the local communitiesparticipating in the project.

We have visited their proposed mitigation land-bank area and found it to be exceptional potential habitat within the wildlife population area affected by the wind project. It is remarkable the developer is willing to contribute an old-growth areaand we applaud their ingenuity and the private landowner for making this possible.

One of the main concerns seems to be: Is the potential take low with ample compliance checks and balances?

We understand there is uncertainty, but we believe there is sound and successfully peer reviewed conservative analyses resulting in the potential species of concern take of “less than one bird per year.” These analyses were prepared by nationally recognized experts and meet or exceed all industry standards and guidelines, clearly the best available science. Their conclusions were validated by data collected at high species of concern use areas nearby. (Copies available for the asking)

Should the take rate increase, which we think is highly unlikely,we see a clear adaptive management plan that will immediately mitigate to lower the take rate.

We see ample compliance checks and balances to assure agency and stakeholder involvement in the successfully peer reviewed monitoring program.

We see a post-construction wildlife fatality monitoring program, whichfor the life of the project offers substantial monitoring coverage. Initially by sampling all wind turbines, followed by monthly and incidental take monitoring.

We also see a plan to address any changed circumstances to assure take remains within authorized limits. In other words, the resource agencies have provided for compliance monitoring on every level.

In addition, we are aware that the only operating wind project in a similar species of concern conservation zone nearthe Radar Ridge site has nearly completed their first-year post-construction monitoring surveys and has not discovered a single wildlife collision fatality.

A natural resource being overlooked: Wind projects offsetfossil plant emissions and their water usage, with a short manufacturing emissions “pay-back” period.

We note that the wind industry trade group, American Wind Energy Association (AWEA), has published a Wind Turbines andHealthFact-Sheet that strongly suggests wind projects contribute to the lowering of fossil plant emissions and water use, as well as mitigating climate change. It notes that climate, energy and clean air are inexorably linked. Solutions that lead to cleaner air must be included in any approach to cleaner, more efficient energy use and reductions in global warming. Wind energy is one such solution - a clean energy source that can provide communities with decreased greenhouse gas emissions, along with air qualityimprovements and corresponding human health benefits. Clearly the same could be said for the wildlife at the Radar Ridge site.

Also, AWEA has published a ClimateChangeFact-Sheet that strongly suggeststhat even emissions from the manufacture and installation of wind turbines are negligible. The “energy payback time” (a measure of how long a power plant must operate to generate – “pay back” – the amount of electricity required for its manufacture and construction) of a wind project is three to eight months, depending on the wind speed at the site – one of the shortest of any generation technology.

This Fact-Sheet also relates that wind opponents sometimes argue that wind energy doesn’t actually reduce the fuel use or harmful emissions of other power plants. It goes on to say that on its face, this claim does not make sense: utility system operators must precisely balance the total supply of electricity with the total demand for electricity at all times, so the electricity produced by a wind plant must be matched by an equivalent decrease in electricity production at another plant. When it is available, system operators use wind energy to reduce the output of the powerplants that are the most expensive to operate, which are almost always natural gas or coal power plants because of their high fuel costs. Wind energy is also occasionally used to reduce the output of hydroelectric dams, which can store water to be used later to replace more expensive fossil fuel generation.

In addition, AWEA has published a Wind Reliability Fact-Sheetrelatesthe fact that changes in wind output are slower and predictable has important implications for the cost and emissions associated with integrating wind. Slower changes can be dealt with through the use of non-spinning reserves--power plants that are not operating but are standing by ready to provide power within 30 minutes or so. Since non-spinning reserves are not operating, there is no fuel use associated with them standing by, ready to operate. As a result, there is little to no emissions impact from having these reserves, and the cost of these non-spinning reserves is typically a few percent of the cost of the fast-response and higher-emitting spinning reserves that are needed to accommodate sudden changes like the loss of a large fossil or nuclear power plants.

A relatively straightforward metric used to understand the carbon benefits of wind energy is that a single 1.5 MW wind turbine displaces 2,700 metric tons of CO2 per year compared with the current U.S. average utility fuel mix, or the equivalent of planting 4 square kilometers of forest every year (AWEA 2007). Therefore, 27 such wind turbines at Radar Ridge would displace CO2equivalent to 988-acres each or 26,676 acres in total. Coupling this with the tree-loss at Radar Ridge being offset by the mitigation land-bank, the CO2 reduction would be tremendous.

We are greatly disappointed with the NEPA process:

We are very disappointed andwere surprised at this stage of the NEPA process, after the developer invested over $4-million in development costs, to be informed that the USFWS Pacific Region would endorse conservation and mitigation measures that we believe are not rationally related to the reasonably foreseeable potential impact of the project, are unreasonable, not scientifically justifiable and are not economically feasible, and therefore are not in the public interest.

We believe this developer has done all of the right things exceptionally well to attempt to permit a project in southwestern Washington at the highest level of environmental review and public process. They were very fortunate to potentially bring $147-million of federal stimulus incentives allocated to the project into our County. Further delays jeopardize the availability of this low interest financing incentive.

They have worked hard with all parties and made appropriate concessions which have resulted in:

Fewer wind turbines,
Limited wind turbine blade length and tower height,
Buffer zones to sensitive areas,
Some curtailment during peak fly times,
Peer reviewed monitoring program,
Aggressive adaptive management strategy that takes prompt and immediate action in the event of more take than anticipated,and
A mitigation commitment that provides excellent maturing murrelet habitat in the area impacted.

They have provided at great expense a comprehensive environmental information document to be used as the basis for the preliminary draft environmental impact statement, yet delays have extended delivery of the completed product by 9-months to date, without firm commitment for future delivery.

The recovery of this species of concern will not be achieved by burdening a single wind project when no evidence exists to suggest their science is anything but valid.

It is remarkable that this permitting standard is being pursued when just recently a private wind project nearby, with similar uncertainty and perceived impact on this same threatened species of concern, only received a recommendation for more, albeit limited, curtailment to avoid collision.

DNR Trust mandate: Balancing economic, environmental and social benefits

Please truly investigate what happened to common law and the ‘trust mandate’relative to Radar Ridge. We understand DNR policy states that Trustees and trust managers such as DNR must operate prudently and with undivided loyalty on behalf of the trusts. Sustainability is a key to managing the state trust lands to achieve the many benefits they provide to Washingtonians. A major component of sustainability is keeping natural resource landscapes and ecosystems healthy so they can provide the steady stream of revenue for beneficiaries, healthy habitat and a wide array of other benefits into the future. In our view, this wind project will do more to enhance the sustainability of Radar Ridge and southwest Washington than any other credible opportunity we can conceive of.

Increase the geographic diversity of wind projects:

In the “Northwest Power and Conservation Council publication 2011-09” a recommendation addresses electric grid reliability. It relates that over 70 percent of committed Northwest wind generation is located in areas strongly influenced by Columbia Gorge winds. This concentration leads to peaks in wind output approaching full installed wind nameplate capacity, which contributes to the frequency and magnitude of excess energy events. Good quality wind resources are found elsewhere in the Northwest and in adjacent regions; however it would be necessary to strengthen or extend the transmission grid to tap large amounts of new resources in outlying areas. New long-distance high voltage transmission is expensive, requires many years to develop, and encounters public resistance.

The project developer has indicated that higher capacity factor wind resources in remote locations with minimal overhead power-line interconnections and utilizing available transmission capacity can meet this need. Radar Ridge is a prime candidatewith a generation profile in-sync with the load demand for the area and contributing geographic diversity to counter concentrated wind generation and contribute to lowering east-west power flow congestion.

A truly missed opportunity:

In summary, the project developer has assured us that this project could have come on-line at the right time to stimulate the local and regional economy during a period of record low interest rates, provide increased School Trust revenue, enhance the electric grid reliability, provide domestic renewable energy resources, contribute to greenhouse gas reduction, benefit the recovery of a threatened species and provide a locally-controlled competitive power supply resource at the cost of production.

Instead, unless the resource agenciesperspectives change, we fear it could result in a significant financial loss for the very communities it sought to benefit. This is not a faceless corporation; it is our local utility and our money. Without this project, the opportunity to contribute to the conservation and recovery of the species of concern will be lost. A missed opportunity indeed!

Respectfully,

Patricia Cruse, President/Conservation Chair

Discovery Coast Audubon Society

Pacific County Washington

360-642-1310

Copied to:

Governor Christine Gregoire

Lt. Governor Brad Owen:

Comm of Public Lands/Peter

Senator Patty Murray:

Senator Maria Cantwell:

Congresswoman Jaime H. Beutler:

Via: Shari Hildreth:

Senator Brian Hatfield:

Rep. Dean Takko:

Doug Miller:

Dave Kobus, Project

Ken Berg:

Shawn Cantrell:

The Daily News:

North Pacific County:

Editor/Chinook Observer: