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KLICKITAT COUNTY PLANNING DEPARTMENT 228 W. Main Street; MS:CH-17 Goldendale, WA 98620 [PHONE REDACTED] [PHONE REDACTED] FAX [PHONE REDACTED] Memorandum DATE: December 14, 2006 RE: Request for Comments and Notice of Complete Application Linden Ranch Wind Farm (Linden Portion of Kenetech Project) To: Interested Parties The Linden Ranch Wind Farm, a 28 turbine/56 MW wind project, has been proposed for location east of U.S. Highway 97, west of Rock Creek, and southeast of Goldendale.1 The project was originally permitted by conditional use permit (CUP) in 1995, but litigation was not dismissed until this year. The 28 turbine Linden project is a smaller proposal than the 345 turbines authorized through the Kenetech CUP. The applicant is seeking to amend the existing permit to reflect the current proposal, and/or obtain an Energy Overlay Zone (EOZ) permit. The EOZ Permit application was deemed conditionally completed on May 11, 2006, but at the applicant’s request, was not included in the final EOZ Permit issued for the Hoctor Ridge project. Since that time, the applicant has revised the application and submitted additional, site- specific environmental review materials. Both this application and the CUP amendment application are now complete, although the Planning Department will need additional information to complete permit processing. This determination does not preclude the County from requesting such additional information, or studies, if needed. In the May 11 letter, the County also granted a deferral request for submitting site specific cultural resource studies and grading/stormwater management plans. The County re-affirms this decision, but notes extensive site specific cultural analysis has already been completed as part of the Kenetech EIS for this project. The applicant has held two community meetings (March 13 and December 11, 2006), consistent with Energy Overlay Zone requirements. A public hearing on the conditional use permit amendment has not been set. Additional information is in the attached Draft SEPA2 Addendum to the Kenetech EIS. The application materials, including the SEPA Checklist, are on file with the Planning Department. Please provide comment by no later than December 28, 2006. If you have concerns, or would like additional information, please contact Curt Dreyer, at the Klickitat County Planning Department, (509) 773-5703. 1 Tax parcel numbers include 03-16-10-00000-200; 03-16-14-00000-100; 03-16-15-00000-000; 03-16-22-00000- 100; 03-16-09-00000-100. 50749745.2 ---PAGE BREAK--- DRAFT ADDENDUM TO KENETCH FINAL ENVIRONMENTAL IMPACT STATEMENT1 KENETECH WIND FARM (FOR LINDEN PORTION OF KENETECH PROJECT) Northwest Wind Partners, LLC (Northwest) is developing a portion of the previously permitted Kenetech wind project site, located southeast of Goldendale, in Klickitat County (Linden Project). The Linden Project would include no more than 28, 2 MW wind turbines, spread throughout 1,760 acres. This Addendum adds information regarding the Linden Project to the Kenetech FEIS. Permitting History The Kenetech Project was authorized by conditional use permit (CUP) in 1995, and evaluated in conjunction with an FEIS issued that same year. The CUP authorized a 345 turbine project over 3,910 acres, but was appealed. The litigation was dismissed in August, 2006. Northwest has acquired the Kenetech permit rights, and wishes to proceed with the western portion of the original Kenetech project. The reduced project area is located on the west end of the Kenetech site, to the east of U.S. Highway 97, and west of Rock Creek. Northwest has applied to amend the existing CUP to account for project modifications made to reflect current industry standards and practices, and a better understanding of wind conditions. Because Northwest applied for an EOZ Permit for the Linden Project before the litigation was dismissed, it has continued to proceed on both permitting tracks, although both permits are not required. Linden and Kenetech Proposals The Linden Project will generally result in fewer environmental impacts than the Kenetech FEIS projected for wind development on the site. The FEIS evaluated impacts from Kenetech’s 345 turbines, and also impacts from the nearby CARES2 proposal, a 91 turbine wind project, which was never developed. Both the original Kenetech proposal, and the Linden Project, involve construction and operation of wind turbine generators, access roads, underground and overhead conduit, operation and maintenance facilities, and electrical substations. The differences that do exist turbine technology, precise turbine placement and compliance with today’s more stringent regulatory standards generally indicate a reduction of environmental impacts for the Linden Project. The Linden turbines are larger and more efficient, resulting in less turbines. The Linden turbines also turn slower (at 20 RPM), further reducing risk and impacts to the environment. Greater turbine height does affect the Linden Project’s appearance relative to the aesthetic impacts the Kenetech FEIS projects, although this is compensated for by the reduced number of turbines. 1 The FEIS includes the Draft EIS and appendices, including Appendix B (Botanical Resources Field Survey) and Appendix C (Avian Use of Proposed Kenetech and CARES Wind Farm Sites). 2 Acronym for Conservation and Renewable Energy Systems. This was an energy demonstration project sponsored by the Bonneville Power Administration. ---PAGE BREAK--- Linden Project consultants performed supplemental field investigations to assess any changes in the existing environment, and to assess environmental information developed since the Kenetech FEIS was issued. The Linden Project area contains steep, rolling hills, characterized primarily by grassland. The natural and built environment in the area has experienced little change, although ongoing grazing has further degraded wildlife habitat. The Linden Project incorporates the relevant mitigation measures from the Kenetech FEIS, and in some cases, regulatory requirements imposed since 1995 have addressed those measures. Examples of regulatory programs and guidance that were not in place or were less stringent in 1995 include the Washington Department of Fish and Wildlife’s Wind Development Guidelines (2003) (which the project is consistent with), the Klickitat County Critical Areas Ordinance (2004), and the Klickitat County Energy Overlay Ordinance (2005). In addition, Northwest has proposed avoiding riparian areas, and oak woodlands, and will provide mitigation for impacted shrub-steppe habitat consistent with the Washington Wind Power Guidelines. County Energy Overlay Zone FEIS The 2004 EOZ FEIS addresses energy facility siting within Klickitat County. It evaluates impacts, alternatives and mitigation to be considered in the County’s determination of where wind energy projects could be sited, what regulatory process to use in making permit decisions, and the cumulative environmental impacts that could result from development of multiple wind energy projects. Based on the EOZ FEIS, Klickitat County enacted the EOZ. The EOZ designates an area of the County within which wind energy development is a land use allowed outright, subject to other applicable laws and permit conditions tailored to address site-specific issues. The EOZ requires preparation of specified site-specific studies in addition to an expanded SEPA checklist, and it imposes standards applicable to development and operation of wind facilities. The Linden Project is within the designated overlay zone where such wind energy facilities are allowed outright. The application includes the EOZ’s required studies. The Project’s cumulative impacts are disclosed in the EOZ FEIS, Kenetech EIS, and other environmental review documents. Incorporation by Reference This FEIS Addendum adds information to the original FEIS, and also incorporates by reference the following environmental review documents: • Conservation and Renewable Energy System Draft and Final EIS, and Appendices (1995) (CARES EIS). The CARES EIS is a project-level EIS which analyzes wind energy generation facilities proposed for development in the same vicinity as the Linden Project, but which was ultimately not developed. • Klickitat County Energy Overlay Zone Draft and Final EIS, and Appendices (2004) (EOZ EIS). Klickitat County issued the EOZ FEIS in 2004. It is a programmatic EIS that was prepared to examine environmental impacts, alternatives, and mitigation ---PAGE BREAK--- measures for energy development within the County, under various permitting procedures, and at alternative locations. • Windy Point Expanded Checklist, including the Environmental Report, attaching Appendix A (Habitat Assessment Report) and Appendix B (Analysis of Potential Wildlife Impacts) (February 2006). The Windy Point Expanded Checklist evaluates a 95 turbine wind project with a total generation capacity of 237.5 MW, located proximate to the Project. The County has also relied on the Linden Project SEPA Checklist (December, 2006), and supplemental environmental review information submitted by the applicant, all of which is incorporated by reference, and is located in the County’s project file. All documents referenced in this Addendum are on file with the Klickitat County Planning Department, at 228 West Main, Room 150, Goldendale, Washington, 98620. If you have questions, please contact Curt Dreyer, at (509) 773-5703. Curt Dreyer Klickitat County Planning Director, SEPA Responsible Official Date