Place of Eagles

December 15, 2023 - Spring Valley, Nevada - This cold basin in eastern Nevada next to Great Basin National Park was well known by park rangers and others as having abundant golden and bald eagles, many overwintering here. Golden eagle nests are also found in the surrounding mountains.

Locals had described eagles in winter "as common as chickens." While that might be somewhat of an exaggeration, it was known that the area was a major wintering range for eagles. And therefore the last place to build a huge remote wind energy project far from load centers, and in an area with wind resources that are poor compared to windy coastal gaps in California.

We wrote comments on the project opposing it, visitied the site to document the basin before the wind project, and predicted that eagle and other bird kills would happen all too often.

We were right. Unfortunately. Fast forward to 2023 and after revieweing several Freedom and Information Act requests (FOIAs) and talking with agency staff, and the golden eagle kills from wind rotor strikes are growing, surpassing federal permits. See out investigative journalism, and archive of stories following the environmental review, opposition, approval, and construction of this remote utility-scale wind project.

Bird and Bat Mortality Surveys are now being cut back at the Spring Valley Wind Project, Nevada

April 2, 2016 - While this project has one of the better monitoring programs we have seen, they still only surveyed a third of the project every two weeks. According to the Bureau of Land Management: Currently, there are no mortality surveys occurring at the Spring Valley Wind Project. Bat mortality surveys will resume again this fall and then bird and bat fatality monitoring will occur at year 5, 7, 10 and every fifth year following as outlined in the Avian and Bat Protection Plan.

The project is known to have killed two golden eagles since it was built, and those eagles were found incidentally (not found on surveys). Other birds killed include prairie falcons, eared grebes and saw-whet owls. In 2014, the project killed triple the number of bats than the BLM agreed to allow. They claimed to have solved this problem by enabling a cut-in speed for the turbines, but we have seen no official documentation on their numbers. The project was approved and built three miles from the Rose Guano Cave - a roosting colony of millions of Mexican free-tailed bats. We believe this project is killing more wildlife than we are hearing about and now the monitoring will be cut back even more. 

Reports also show this project is producing a lower capacity than promised by the company, Pattern Energy.

Bats need all the help they can get, as white-nose syndrome fungal infection has now been reported from the West Coast: http://www.latimes.com/science/sciencenow/la-sci-sn-white-nose-bats-washington-20160331-story.html

Second Golden Eagle Killed at Spring Valley Wind Project

February 18, 2015 - Spring Valley NV - A second golden eagle was found dead on January 9, 2015, next to a wind turbine generator. The first golden eagle was found two years ago in February 2013. We found the second mortality record while examining the Year two cumulative impacts list October 2014 to Feb 14, 2015.

The following is from WEST, Inc. (Bureau of Land Management personal communication):

The GOEA [golden eagle] was at a scheduled search turbine, but was found incidentall y, not during a scheduled search (reported on incidental tab of report). In response to the GOEA fatality and per the Avian and Bat Protection Plan, we also completed searches of the 44 non-scheduled turbines. Only one fatality was documented during those extra searches (a horned lark). It is reported on third tab as an incidental since it was at one of the non-scheduled turbines (D7).

US Fish and Wildlife Service told us in a personal communication that this is under investigation.

Spring Valley Wind Project with More Bat Deaths than Predicted

August 18, 2014 - The eastern Nevada wind project that was built too close to a major roosting colony of Mexican free-tailed bats has been forced to change operations after its turbines killed triple the number of bats allowed under an agreement with federal regulators. Read more at the Las Vegas Review Journal: 

http://www.reviewjournal.com/news/water-environment/bat-deaths-prompt-change-wind-farm

Study Plan for Spring Valley Wind Project

June 12, 2014 - The post-contruction wildlife surveying and monitoring plans are contained in this February 2014 Study Plan report (1.07 MB PDF). The report details how bird and bat mortality studies will be carried out: surveys for dead birds and bats would only be done every other week for the first year, and then only every few years for the lifetime of the project. We feel this will miss much data, many dead bird and bat carcasses that will be scavenged and missed.

A Curtailment Study was done in 2012, a Fall-Only Bat Survey will be done in2016, Bat Acoustic Surveys will be undertaken, Avian Use Surveys, Raptor Nest Survey, and Annual Reports.

February 27, 2014 - The bird mortality monitoring compliance for the Spring Valley Wind Project, located next to Great Basin National Park, Nevada on public lands reports a Northern saw-whet owl (Aegolius acadicus) mortality this winter. The find is “incidental” meaning it was not found during an official search. It makes one wonder what else is being missed and killed by the turbines. The nearby Swamp Cedars Area of Critical Environmental Concern is located right next to the wind farm and could be a breeding habitat for these owls. 

The Northern saw-whet owl breeds in conifer forests, including pinyon-juniper woodlands. Some owls move seasonally, and saw-whet owls may have been nesting in the swamp cedars or traveling through the area. They usually nest in old woodpecker holes. 

In Nevada they may be uncommon, although probably are more widespread because of the difficulty of detecting the bird. Nesting has been confirmed in the White Pine Range, the Toiyabe Range, and in Great Basin National Park.

They are named for their loud persistent night-time song during the breeding season. Mice and other small mammals make up most of their diet.

Bat and Bird Mortality at Wind Turbines

September 9, 2013 - A yearlong fatality monitoring at the Spring Valley Wind Project has revealed how numerous bats and birds have already died from turbine impacts. Biweekly reports are sent to Bureau of Land management biologists from contractors surveying the ground around the turbines. Environmental groups and concerned citizens had warned the agency that buildinga wind project a mere mile from an important roosting colony of Mexican free-tailed bats would result in mortality. Now Mexican free-tailed bats and other bats are being killed. 

These daily numbers will be used to develop a curtailment plan. Fall daily searches began August 1. 40 turbines are searched.

Here is a tally of individial bat and bird carcasses recovered in plots around the turbines for approximately a year (corrected from a month):

• Mexican free-tailed bat - 105 

• Hoary bat - 4

• unidentified bat - 1

• American kestrel - 1

• Cliff swallow - 1

• Horned lark - 2

• Blue-gray gnatcatcher - 1

• MacGillivray's warbler - 1

Since October 2012, a Golden eagle and Rough-lgeed hawk were also found dead at the wind project.

First Golden Eagle Killed at Spring Valley Wind Project

March 8, 2013 - Already a dead Golden eagle was found on February 25 at a wind turbine generator in the Spring Valley, a place with a dense population of eagles. Those who knew thae area had predicted eagle mortality was likely, but no one thought it would be so soon after the project was completed.

According to the Bureau of Land Management (BLM), Pattern Energy contacted US Fish and Wildlife Service (FWS) as required and preserved the carcass for them. FWS has confirmed it was a strike that killed the eagle.

The golden eagle death triggered a requirement that the company survey all 66 turbines in the next survey period.

Because the death was at the start of the nesting season the company may need to move up their surveys for nests and do some analysis to determine if the eagle killed was resident and part of a nesting pair, or a transient.

BLM says that the project has now “reached but not exceeded” the take threshold for golden eagle of one take. If they get another take this may trigger curtailment and other measures.

Photos of Spring Valley Wind Project Under Cosntruction - 2012

Notes on Spring Valley Wind Project Site Visit (Resource Advisory Committee for BLM) on July 20, 2012, provided by Judy Bundorf:

General comments:  The roads are currently about 30 feet wide (estimated); they are in the process of “mitigating” and will replant the outer edges of the roads, and end up with 18-foot wide roads.

As we arrived at the site, the last two of the construction trailers were being hauled out.  The area where all the trailers were is being “reclaimed” and “mitigated”; it presently looks like a plowed field.

1. When we arrived about 9:00 a.m., the turbines were turning very, very slowly or not at all.  We were informed that the power line which takes the power generated onto the grid had been damaged in a fire in early July.  It was anticipated the power lines would be repaired and electricity flowing from the turbines by some time the week of July 23rd.  Thus there was no power going online for about three weeks.  With only one line to deliver the power from the site, seems like this may be a common occurrence due to ice storms, wind storms, and forest fires.  

I asked the Pattern Energy representative if there was another line to export the power on, and the answer was “No.”  I also asked ft NV Energy couldn’t take the power, if it could be sold on the open market.  Again, the answer was “No.”  

Rumor has it that the power purchase agreement between Pattern and NV Energy is between 10 and 12 cents per kwh wholesale.  (My NV Energy bills charge between 12 and 13.5 cents per kwh retail.)  

2. While we were standing outside the maintenance building, the Pattern Energy representative said the 66 2.3 MW Siemens turbines would power for 200,000 homes.  However, when we got inside and saw some poster boards with project specifictions, it indicated the project would power 45,000 homes. 

3. The representative pointed out their “bat radar” machine, and talked about how much they were spending to keep the environmentalists happy by tracking bat activity.  He said they had a second radar machine they would be using as well.  Apparently one radar will be set up near the bat cave, and another closer to the turbines.  For two months each year (during the bat migration) Pattern will slow the cut-in speed, and perhaps not operate the turbines for several hours, starting at dusk.  However, there is no way to have the radar shut down the turbines if they detect bats or avian activity.

Pattern also will have several college students go to the site each morning to count any dead bats or birds.  I asked why they didn’t consider hiring someone with a dog trained to find the birds and animals that had been killed.  The Pattern Rep. said they would not do that.  (Side note:  I’ve read that a dog is much more efficient than humans in finding anything killed by turbines.  Also, the coyotes will be picking the site clean during the night!)

4. At no time did the representative actually state they would shut down the wind farm because of the bats or avian migration…perhaps I missed it, but my friend did not hear that said either.  Also, the representative indicated the monitoring would go on for five years, but no mention of what would happen after that. 

So, for now, just count the fatalities!

5. I asked if there would be strobe lights 24/7, and was told that there would be to comply with FAA requirements.  I don’t know if lights will be on all or just some of the turbines and MET towers.  He mentioned that someone is working on a system that would sense aircraft and turn the lights on only when aircraft were near, but that hadn’t been perfected.  So for now, the “dark night skies” in Spring Valley are no more.

6. Someone asked if the turbines were made in America.  Short answer is “No.”  The blades are manufactured in Utah; the components that go in the nacelle, and the nacelle are manufactured elsewhere, but assembled in the U.S.  The turbine “tower” (i.e., where the nacelle and blades are mounted) is manufactured in China. 

7. Roads into the site all have gates on them now…at some future time, some of the pre-existing roads may be reopened to the public. 

8. At the end of the “useful life” of the project, the turbines will be demolished and all resulting materials hauled away.  According to the representative, nothing can be recycled!  The concrete foundations will be removed to 4 feet below present grade.  (I believe he stated the foundations were 56 feet in diameter, by 30 feet deep…hope I’ve got that right!).  

9. Part of the mitigation will include replanting native flora right up to the base of the turbines.  I asked if that wouldn’t present a fire hazard (based on the Searchlight DEIS that talked about how a large area would need to remain plant-free to prevent the spread of fire).  I was told that wasn’t an issue in Spring Valley.

10. Someone inquired as to why the turbines, while mostly in neatly aligned rows, had some randomly placed.  We were told there were areas with heavy sage brush cover that might be home to pygmy rabbits, so those areas were avoided.

11. Someone had told me that the plan was to build many more turbines (up to 1000 total) in Spring Valley.  When I asked about this, I was told this project was built-out at 66 turbines, and there would be no more turbines built by Pattern.  (Some folks commented that other companies may pursue more turbines in the valley.) 

Some of the folks from Lincoln County found it interesting that Pattern Energy said they had to build this project in the valley to get the best wind, while Wilson Creek Wind told the people there the project had to be on the mountain tops for the best wind!  Flexible, aren’t they!

Construction Begins on Spring Valley Wind Project

September 17, 2011 - Construction has begun on the 150-megawatt, $250-million wind farm with 66 2.3-megawatt turbines. The project is on 8,500 acres of public land managed by the Bureau of Land Management. Now, the developer says, with financing in place, construction will ramp up with completion of the project next summer.

Pattern Energy announced on August 26 that it has secured a construction loan that converts into an 18-year term loan for Spring Valley Wind through Siemens Financial Services, Inc., Credit Agricole Corporate and Investment Bank, and Union Bank, N.A.

"The official completion date is June 30 (2012). We hope to beat that," said Head Developer George Hardie during a groundbreaking ceremony on August 26 at Ely's County Park. He said completion a month ahead of schedule is possible. 

"We've got to go through the winter months," he said, and acknowledged that there could be construction difficulties during the wintertime.

The contractor, Mortenson Construction of Minneapolis, Minnesota, will hire about 225 workers for the construction phase of the project and jobs will be available to local residents.

"We've already had job fairs here," Hardie said.

Hardie said the Spring Valley Wind would employ 13 permanent employees after the project is completed.

The BLM land where the turbines will be located is not taxable by the county but the turbine structures would be.

"It (wind generation) is possible because the OnLine is going to connect the northern and southern service areas in Nevada," Hardie said.

Construction of the One Nevada Transmission Line is currently progressing through White Pine and Nye counties. When completed in late 2012, the estimated $510 million, 235-mile long, 500-kilovolt transmission line will run from the Harry Allen Substation north of Las Vegas to the soon to be constructed Robinson Summit Substation, about 20 miles northwest of Ely. The project was formerly known as the Southwest Intertie Project (SWIP).

www.patternenergy.com

http://www.elynews.com/articles/2011/09/02/news/news11.txt

Bureau of Land Management Hastily Approves Project

October 19, 2010 - Despite outcries from environmental groups and Native Tribes, the Ely Bureau of Land Management office decided against doing a more thorough environmental review and went ahead and approved this project with only an Environmental Assessment. 

Huge problems remain with large numbers of Golden and Bald eagles, as well as other raptors using Spring Valley, Greater sage grouse leks close, archaeological sites, and groundwater concerns over the nearby unique juniper-dotted wetland. Visual concerns of the giant turbines so close to Great Basin National Park were dismissed. 

A Finding of No Significant Impact was issued, and in the Decision Record, BLM states, "Geotechnical investigations will be done for each turbine to ensure not to puncture and dewater the aquifer. Specific measures will be developed as needed to address geotechnical issues. If the perching ground water layer, as identified by the onsite geologist or geotechnical engineer or engineer’s representative is breached, the hole or breach point will be seal grouted to preserve the subsurface hydrology that feeds the local system."

An Avian and Bat Protection Plan describes initial mitigation requirements, post-construction monitoring requirements, and an adaptive mitigation strategy. The plan uses a tiered approach that would result in different levels of mitigation being implemented based on the findings of postconstruction monitoring. But we argue that the plan puts too much emphasis on "adaptive management" -- study later and then decide what to do after birds and bats are killed, after the public review period is over. 

"Nest surveys will be conducted prior to the nesting season (approximately March 15 to July 30) and once each month during the nesting season during the first three years and every fifth year after that. Aerial or ground based raptor nest surveys will be conducted within the entire project area and a 1-mile buffer for raptors, except for golden eagles. Golden eagle search distances will be 10 miles from the project area based on current USFWS guidance. The complete 10-mile search area will be limited to once at the beginning of the golden eagle nesting season with monthly follow-up surveys only being completed for identified golden eagle or potential golden eagle nests." Golden eagle nest surveys should have been done already, this is unacceptable. If a nest is found within the area, the project would be shut down, following the strict Bald and Golden Eagle Protection Act of the US Fish and Wildlife Service. No eagle may be killed or harassed, including harassment on foraging grounds.

"As part of the project, the project proponent has volunteered to donate $500,000 to enhance sagebrush habitat that supports species such as the greater sage-grouse. Funds would be deposited into NDOW’s Non-Executive Account and marked specifically for purposes of sagebrush restoration efforts, which could include permitting, equipment and seed purchase, labor, and other necessities for restoration. An effort must first be made to apply the funds to sagebrush restoration within Spring Valley and then outside of the valley if necessary. Donations into this account are eligible for matching federal funding. All decisions of how to utilize the money will require both NDOW and the BLM approval." But this does not mitigate the loss of pristine sagebrush habitat that is currently unfragmented in Spring Valley.

"Any swamp cedar that must be removed would be made available for education, scientific, and research purposes as determined by the BLM." This too is unacceptable, as this species of juniper, Rocky Mountain junipers (Juniperus scopulorum), is unusual growing on this flat valley floor. Will the trees be placed in pots?

"If pesticides are used on the site, an integrated pest management plan shall be developed to ensure that applications would be conducted within the framework of BLM and U.S. Department of the Interior policies and entail only the use of U.S. Environmental Protection Agency (EPA)-registered pesticides. Pesticide use shall be limited to non- persistent, immobile pesticides and shall only be applied in accordance with label and application permit directions and stipulations for terrestrial and aquatic applications." No pesticides should be used in this sensitive habitat, and any plan should be made available for public review.

No Decommissioning Plan was made.

"Per SHPO [State Historic Preservation Offices] requirements, complete detailed recordation and specific photo documentation (prior to construction), of any eligible sites that would be visually impacted by the project, this will be completed to SHPO (2010) standards." In other words, valuable cultural sites would only be photographed before destruction? The Goshute Tribe is concerned about burial sites here.

BLM said, "...a determination was made that the Selected Alternative will not significantly affect the quality of the human environment and that preparation of an Environmental Impact Statement is not required." 

This valley is one of the most pristine in the Great Basin, and should not be industrialized.

Lawsuit Filed Against Spring Valley Wind Project

January 25, 2011 - Western Watersheds Project, Center for Biological Diversity, Confederated Tribes of the Goshute Reservation, the Duckwater Shoshone Tribe, and the Ely Shoshone Tribe filed suit today to protect a pristine mountain valley adjacent to Great Basin National Park in Nevada from a poorly-sited 8000 acre industrial wind energy project, approved by the Department of the Interior with only a short Environmental Assessment instead of a longer and more throrough Environmental Impact Statement. 

“We hope this litigation will lead the federal government to choose less damaging locations for wind power developments,” said Jon Marvel, executive director of Western Watersheds Project.

“Renewable energy is nationally and globally important for addressing the growing threats from climate change,” said Rob Mrowka, an ecologist with the Center for Biological Diversity, one of the parties in the suit. “But, renewable projects must be properly located with careful consideration of the values of not only the site but also of the surrounding area...The best ways to avoid negative impacts of renewable energy projects are to carry out a thorough environmental review and site them carefully. Unfortunately, in this case BLM did neither.”

One of the more critical negative biological impact of the project will be on the 1 million Mexican free-tailed bats that roost in the Rose Guano Cave near the project area. This cave is one of the most important known roosts in the Great Basin. A growing body of science demonstrates that wind turbines can kill bats by the thousands through the phenomenon known as “barotrauma,” in which the pressure difference created by wind turbine blades causes bats’ lungs to explode.

“Biologists believe that the populations of bats that roost in Rose Guano Cave may migrate from Texas, Mexico and beyond,“ said Katie Fite of Western Watersheds Project, “the impact of this wind farm to these bats will negatively affect these bats’ important role in ecosystems all over the southwest.”

The Spring Valley Wind Energy Facility would include 75 turbines and 25 miles of new roads on public lands - just 4 miles from the Rose Guano Bat Cave in eastern Nevada.

Golden eagles and other bird species that inhabit or migrate through Spring Valley are also put at risk by the project, as wind turbines are known to kill or dismember birds through collisions with turbine blades.

The area is historically and culturally significant as the site of a massacre and a US Calvary and Native American war. 

Plaintiffs Western Watersheds Project and Center for Biological Diversity will be represented by Advocates for the West, a Boise-based environmental law firm.

http://www.westernwatersheds.org/news-media/news-release/2011/01/25/suit-filed-protect-one-nevadas-largest-bat-roosts-national-park

http://www.biologicaldiversity.org/news/press_releases/2011/spring-valley-01-25-2011.html

http://www.lasvegassun.com/news/2011/jan/25/groups-sue-feds-over-plans-nevada-wind-energy-farm/

Spring Valley Wind Project Background

Spring Valley Wind, LLC, a subsidiary of Pattern Energy of San Francisco, is proposing to build Spring Valley Wind Project, a 149.1 megawatt wind generation farm that would be constructed on 8,565 acres of the public lands in north Spring Valley, about 30 miles east of Ely. The project would consist of from 66 to 85 wind turbines and a new electrical substation. It would utilize an existing 230 kilovolt (kV) transmission line for distribution. On our site visit in November 2009, we noticed that, like all renewable energy projects we have seen, the first choice by the developer is proximity to existing powerlines. Last on the list are biological and cultural resources. Vegetation would be cleared, bulldozed, and grading would be done for buildings and switchyards.

We discussed the matter of bats and wind turbines with Ely BLM personnel on a site visit on November 17, 2009. Wells McGiffert, Renewable Energy Coordinator for the Ely BLM office, and Mary D'Aversa, Field manager of the Schell Field Office met us, along with Katie Fite now at Wildlands Defense.

The Ely district has 17 renewable applications, but McGiffert said many of them may be speculators.

More wind projects are proposed for north of this site in Spring Valley, two "on top of each other."

We all asked BLM why this large wind project will just have a small Environmental Assessment, rather than a lengthier Environmental Impact Statement. They told us they are still getting information, and could decide to make it an EIS.

The issues are many here: the 400-foot-tall turbines would be in the viewshed of Great Basin National Park (Wheeler Peak is clearly visible from the site), impacts to bats, three Greater sage grouse leks within a few miles of the project, Pygmy rabbit foraging and burrow habitat in the project site, antelope, deer, and elk habitat impacts, groundwater pumping, affects to the unique wetlands adjacent to the site, and others. The EA states: "there is a potential effect on Native American burial sites" (page 5).

McGiffert told us the applicant contracted a Visual Resources report, sending people even up to the top of Mt. Wheeler. The visual impacts were "a lot less significant than you would think," he said. Great Basin National Park is about 5 miles from the project site.

The exact model of turbine has not yet been chosen, but would be a Siemens 2.3 MW or 1.8 MW Vestas or 2.0 MW RePOWER type, about 425 feet tall in total. Height would be around 400 feet. Rotor diameter is about 300 feet.

Lighting on the turbine tops might be a kind activated by airplane fly-bys. Most turbines would have red flashing lights. How will this affect views from the park?

D'Aversa said the wind company gets a three-year study period, then must drop out or go ahead with the project.

We asked why Nevada does not have a brownfields program, like Arizona BLM has, where the public can participate in siting cases for renewable, and suggest sites that are disturbed. This Spring Valley area was definitely not disturbed.

McGiffert said they were looking at such a program, and looking at such areas as past fire disturbances where restoration efforts do not seem to be working (we would disagree that a wildfire could not restore over time -- this is not a good idea for renewable industrialization). BLM was also looking at mines in the state. Wind companies found that mine tailings had a poor substrate for turbine foundations, however.

Katie Fite asked whether this company has any plans to build water storage batteries, which are being proposed in Oregon: water would be pumped out of lakes by the wind or solar plant and into a reservoir -- at night this "stored capacity" could be released, turning turbines to generate electricity. Needless to say this would have drastic impacts on local water resources. BLM said there are no plans like this for Spring Valley.

Fite persisted -- this is just the tip of the iceberg, she pointed out. NV Energy has the whole Spring Valley mapped out as a vast wind energy zone.

We asked what "Fast-Tracking" really involves for a renewable project. Is public involvement curtailed? Both BLM employees assured us that Fast-Tracking involves putting staff onto priority projects, not sidestepping NEPA.

We pointed out that the public would like to be more involved, including the chance to say that such a large wind project shouldnot be placed right next to an Area of Critical Environmental Concern.

D'Aversa said the BLM has the latitude to go back and reconsider amending the EA, and having a second scoping period.

The wind project would need 30 acre-feet of water for construction, mostly for dirt road maintenance and for making the cement for the large foundations for each turbine. Southern Nevada Water Authority holds most of the allotments, but Pattern Energy would probably lease water rights from the Church of Latter Day Saints, which owns grazing allotments on the site. And cattle would have to be moved until after the project was built.

Bat Caves

We drove out to the site on a cold November morning to look at an amazing view and unique bat roosting cave in the Snake Range next to the proposed wind farm. Rose Guano Cave lay high on a limestone cliff, only a few miles from the proposed field of giant wind turbines with their moving rotors. 

The Nevada Division of Wildlife became interested in impacts to the bats by the wind project, and in cooperation with BLM and the applicant, a study was contracted with Dr. Richard Sherwin of Christopher Newport University in Virginia in 2008.

Using thermal imaging cameras, Sherwin found an impressive southward migration in mid and late August as Brazilian free-tailed bats (Tadarida brasiliensis) crowded into the cave. Later into September as cave air cool, the bats roost in smaller numbers on overhanging crevices on nearby cliffs. He estimated that over 1 million bats used the cave in migration annually.

Hundreds of thousand of bats could be seen in a plume exiting the cave above 800 feet, many dropping to the valley floor to forage on insects. The plume looses cohesion at 12 miles out, as individual bats spread out: the entire Spring Valley is occupied each night in August and September during nightly forays.

Primarily adult bats use the roost, and the females caught were post-lactating, having given birth elsewhere. The cave is a migratory stop-over, bats staying for a few days, then moving on and replaced by more migrants. Bats begin leaving the cave slightly before sundown, the outflight continuing for tow hours. Small groups of bats were seen flying west and north over Spring Valley (apparently over the proposed wind project area), while others flew south towards agricultural fields to forage. Migratory flight was typically at 800 to 2,500 feet above sea level, while foraging flight was lower. The majority of bats foraged at night in the valley or along the margins of the mountains before returning to the cave, as early as 3:00 AM. Other bats roosted elsewhere nearby, or continued their southward migration.

The cave is occupied as early as June. On July 15, 1994, 600 bats per minute were seen for over two hours exiting the cave.

Sherwin concludes, "it is clear based on radar and radio telemetry data that many individuals are active at low elevations throughout Spring Valley, including the landscape immediately surrounding Rose Guano Cave. Similarly, the single night movement of some radio tagged bats to the Wilson Creek Mountains (roughly 40 miles south of the cave) reveal that these animals are functioning at a larger spatial scale than we had previously supposed and that the fate of this colony could be profoundly impacted by habitat perturbations that occur at larger distances from the cave itself" (page 25-26). Sherwin summarized: "...the entire Spring Valley area receives high levels of bat activity each night, with individuals foraging and accessing water at low altitudes, and commuting at higher altitudes" (page 27). 

Sherwin also notes, "This prolonged association with a site that is at the periphery of the species range, and whose use therefore invokes some degree of energetic costs, certainly indicates that this location is of biological significance and warrants managerial attention" (page 3).

According to Paul Cryan of the USGS Fort Collins Science Center, "Bat fatalities have now been documented at nearly every wind facility in North America where adequate surveys for bats have been conducted, and several of these sites are estimated to cause the deaths of thousands of bats per year." 

Bats especially affected are those with large seasonal movements, that concentrate in certain areas during migration periods -- such as caves. Brazilian free-tailed bats (also called Mexican free-tailed bats) have been found to be disproportionately affected by wind turbines (Arnett et al. 2008).

What would BLM to reduce these impacts or mitigate for bats deaths? we asked. D'Aversa said mitigation would be a "design feature," meaning nothing will be done now, but only later (after bats have started dying). Two years after construction of the wind farm, "intensive mortality studies" will be undertaken. Katie Fite pointed out this was not mitigation, but only adaptive management. We laughed. Would NV Energy really agree to cut turbine operation because of bat mortality? McGiffert responded that BLM is curious, and Nevada Division of Wildlife wants the data.

Bat "carcasses will be removed from the site," says the EA (page A-2).

The EA states that the company would avoid lighting that attracts bats and birds, but no details are given.

Other bats found in the area include: Townsend's big-eared bat (Plecotus townsendii), Big brown bat (Eptesicus fuscus), Western red bat (Lasiurus blossevillii), Hoary bat (L. cinereus), Silver-haired bat (Lasionycteris noctivagans), Western small-footed myotis (Myotis ciliolabrum), Long-eared myotis (M. evotis), Long-legged myotis (M. volans), Yuma myotis (M. yumanensis), and Little brown bat (M. lucifugus).

The project is approximately 4 miles from Rose Guano Bat Cave. The Programmatic EIS for wind states that caves used by bats should be avoided. In place of this measure, a project- specific Mitigation Measure has been provided in Section 6.4.2 and in the ABPP. The mitigation measure, to avoid known bat caves and migration corridors, is completely being ignored. There appears to be no mitigation.

The Programmatic Wind EIS states:

“Turbines should not be located near known bat hibernation, breeding, and maternity/nursery colonies, in migration corridors, or in flight paths between colonies and feeding areas.”

The Avian and Bat Mitigation and Adaptive Management Plan is only in Draft Form. Where is the final document? The several unresolved issues in the document indicate that BLM is negligent in completing these studies.

The Draft Avian and Bat Mitigation and Adaptive Management Plan fails to document four species that would occur in the region.

These species are: 

California myotis (Myotis californicus)

Fringed myotis (Myotis thysanodes) 

Western Pipistrell (Pipistrellus hesperus) 

Hoary Bat (Lasiurus cinereus) 

The hoary bat is mentioned in the in the EA, but the EA neglects to mention that the Hoary bat is a BLM Species of Special Concern. 

An EIS will need to provide a complete list of bat species that would occur in the area.

In April, 2010, BLM employees informed us that this new mitigation and adaptive management plan “would resolve issues associated with bats.” We believe that this was a premature statement.

From the US Geological Survey web site:

http://www.fort.usgs.gov/BatsWindmills/

“In the push to develop new forms of sustainable energy, the wind power industry is at the forefront....However, recent evidence shows that certain species of bats are particularly susceptible to mortality from wind turbines. Bats are beneficial consumers of harmful insect pests, and migratory species of bats cross international and interstate boundaries. Dead bats are turning up beneath wind turbines all over the world. Bat fatalities have now been documented at nearly every wind facility in North America where adequate surveys for bats have been conducted, and several of these sites are estimated to cause the deaths of thousands of bats per year. This unanticipated and unprecedented problem for bats has moved to the forefront of conservation and management efforts directed toward this poorly understood group of mammals. The mystery of why bats die at turbine sites remains unsolved. Is it a simple case of flying in the wrong place at the wrong time? Are bats attracted to the spinning turbine blades? Why are so many bats colliding with turbines compared to their infrequent crashes with other tall, human-made structures?”

Adaptive Management Plan:

The Draft Avian and Bat Mitigation and Adaptive Management Plan in no way convinces us that bat mortality can be avoided. We are concerned that the BLM is considering approving a Right of Way for a project that is so close to the Rose Guano Cave and in a region that has such a robust population of different species of raptors.

The Draft Avian and Bat Mitigation and Adaptive Management Plan states:

“A curtailment study will be completed during the first year to determine the most effective cut-in speed following methods based on those developed by Arnett et al. (2009) in which they evaluated the effectiveness of increasing cut-in speeds from an initial 4.0 m per second (m/s) to experimental speeds of 5.0 and 6.5 m/s. These increased cut-in speeds were effective in reducing bat mortality by 53%–87%, with minimal loss of revenue for the WEF (Arnett et al. 2009). No Brazilian free-tailed bats were evaluated in this study; therefore, testing is needed to determine the effectiveness of increased cut-in speed.”

Because “No Brazilian free-tailed bats were evaluated in the study”, you have very little information as to what the future outcome will be. 

The report states:

“During this study, turbine cut-in speeds will be altered from sunset to 4 hours after sunset for a 62-day period (248 hours) during the highest use period of August 1 through September 31.”

There are 12 other species of bats that could potentially be impacted by this project from May to the beginning of August. An adaptive management plan should be created for the additional species at risk as well.

Mortality Surveys:

We have interviewed two biologists who have participated in mortality surveys for wind energy projects. It is extremely difficult to train people to find carcasses of dead bats due to the size of the animals and the camouflage color of the animals. Most biologists tend to feel that this kind of monitoring is not effective. 

Creating a Wind/Wildlife Research Fund:

The EA States:

“The project proponent will provide $10,000 per year for three years to fund wind/wildlife interaction studies. Research will be recommended by the TAC, approved by the BLM Authorized Officer, and funded by the proponent. Additionally, the BLM or other participating agency may elect to contribute funding. In that event, the proponent would provide funding to the BLM, and the BLM would issue a Request for Proposals for the study.” 

A $30,000 research fund will not bring back the Rose Guano Cave population of Mexican free-tailed bats if the wind farm causes a giant population crash. This is not an acceptable mitigation plan.

Carcass Removal Trials: 

The EA States:

“Carcass removal trials will be completed seasonally as described above in Section 6.2. Different seasonal rates for carcass removal are necessary to address changes in the scavenging throughout the season, as well as over time, as scavengers adapt to a novel food source. Carcasses will be placed as described for searcher efficiency trials. Carcasses will be checked at 1, 2, 3, 4, 5, 6, 7, 14, 21, and 28 days following placement, or until they are all removed. Separate carcass removal rates will be determined for bats, small birds (passerines), and large birds (raptors). Carcasses used for removal trials will be handled with disposable nitrile gloves or an inverted plastic bag to avoid leaving a scent on the carcasses and interfering with the scavenger removal trial (Arnett et al. 2009).”

This still is in the trial phase. More studies should be conducted before the project is constructed, not after. This data should be included in an EIS.

Mortality Threshold: 

The Mortality Threshold fails to explain the reasons that the numbers listed are acceptable thresholds for mortality of species. A final EIS will need to justify these numbers from an ecological perspective.

Mitigation Phases:

All of the mitigation phases are “after the fact”. You have not convinced us that any of these mitigation phases will be adequate enough to prevent the mortality. 

Science Recommendations on bats and Wind Farms:

Although Spring Valley is not within the California Desert, the DRECP Independent Science Advisors' recommendations for bats will apply to the Great Basin (Public Review Draft Recommendations of Independent Science Advisors for The California Desert Renewable Energy Conservation Plan (DRECP), Prepared For Renewable Energy Action Team: California Department of Fish & Game, U.S. Fish & Wildlife Service, U.S. Bureau of Land Management, andCalifornia Energy Commission, Prepared By The DRECP Independent Science Advisors, August 2010):

"Bats. Basic conservation needs of bats are met by ensuring that roosts, foraging areas, and free water are maintained within a few km of one another. However species of bats differ in the types of structures used as roosts, types of habitat favored for foraging, and nightly distances travelled to reach foraging and drinking areas. Therefore, conservation and mitigation efforts must take care to ensure that proposed actions are species-specific and maintain viable juxtaposition between important resources. For instance, loss of cave roost habitat in one area cannot be mitigated via protection of rock face or tree roost habitat elsewhere, as it would be unlikely to be used by the affected species. Similarly, loss of roost habitat cannot be offset through provision of foraging habitat. The success even of in-kind (e.g., protection of foraging habitat to offset loss elsewhere) habitat substitution should be verified through an adaptive management process before it is widely implemented as a mitigation tool."

and 

"Hoary bat (Lasiurus cinereus). Although this species is widely distributed and unlikely to be listed as threatened or endangered in the near future, hoary bats are the most frequently killed species at wind energy developments in North America (Arnett et al. 2008) and have been recorded as fatalities at wind energy facilities within the DRECP (Chatfield et al. 2009). Given the cumulative impacts of massive expansion of utility-scale wind energy development in the United States, combined with low reproductive rates of bats, there is some potential for hoary bats to be added to one or more special status lists within the next 30-50 years."

Birds, wildlife, rare plants

Horned larks rose from the valley floor, which had a mosaic Big sagebrush (Artemisia tridentata), Black sagebrush (A. nova), Greasewood (Sarcobatus vermiculatus), Winterfat (Krascheninnikovia lanata), Nevada ephedra (Ephedra nevadensis), Shadscale (Atriplex confertifolia), Four-wing saltbush (A. canescens), Yellow rabbitbrush (Chrysothamnus viscidiflorus), and Rubber rabbitbrush (C. nauseosus). Grasses were scattered among the shrubs: Indian ricegrass (Achnatherum hymenoides), Needle-and-thread (Hesperostipa comata), Alkali sacaton (Sporobolus airoides), Galleta grass (Pleuraphis jamesii), and Great Basin wildrye (Leymus cinereus).

A raptor nest sat on one of the powerline poles, in the middle of the project site. During turbine operation, any raptor nests within a half-miles would be removed.

Other birds found in the area include Prairie falcon, Ferruginous hawk, Golden eagle, Northern harrier, Swainson's hawk, Western burrowing owl, Long-eared owl, Long-billed curlew, Willet, Greater sandhill crane, Red-naped sapsucker, Pinyon jay, Juniper titmouse, Loggerhead shrike, Sage sparrow, Vesper sparrow, and Brewer's sparrow. Bald eagles commonly winter in the area.

No surveys for rare plants were undertaken on the site, only a few casual observations. Parish's phacelia (Phacelia parishii) has the potential to be found on the site, as records of it are found 250 feet from the project boundary. It is found on clay and alkaline soils by the playas and springs.

Cement foundations for each turbine will be made on site using a new 5-acre cement batch plant. Gravel would be trucked in from an existing mine tailings pile nearby and will also be taken from a new 10-acre gravel pit on the site. The turbine foundations would be 8 feet deep into the ground. The turbine base diameter is 15 feet. Each turbine would require a 400-foot diameter (2.9 acres) temporary construction pad for the crane to lift the steel tower. This area would be bulldozed, graded, and compacted to level. Each foundation would use 400 tons of gravel, 250 tons of sand and 120 tons of cement.

No new water rights are available in Spring Valley, so temporary leases will be obtained from LDS Church's rights north of the site (is this the spring we photographed? -- see below). Up to 200,000 gallons a day would be pumped to make cement for turbine foundations and buildings pads and road maintenance/dust suppression. Water use may be up to 30.7 acre-feet.

Access roads would be built, 28-feet wide (with temporary disturbance up to 68 feet wide total) for large trucks and cranes. A total of 27.5 miles of new roads would be constructed in this valley. Final roads would be surfaced with gravel. Electric cables and fiber-optic lines would be undergrounded between turbines in trenches, creating more disturbance.

The turbines will not be fenced. A 7-foot chain-link fence would surround the new operations and maintenance building and substation (20 acres) to keep out "unauthorized wildlife" and people.

A 100-foot tall microwave tower would be put up at the new Osceola substation next to the new switchyard. Connection would be to NV Energy's line.

Herbicides will be applied to the areas around the turbines bases to control weeds.

The only mitigation offered is that the company would not construct turbines closest to the lek on the northwest side during sage grouse breeding activities. Turbines would not "where possible" be located within two miles of active leks. This is unacceptable. Will operations of this facility and fragmentation of foraging habitat cause lek abandonment? Energy has priority over wildlife apparently.

See the Basin and Range Watch archive website on Spring Valley Wind Project: http://www.basinandrangewatch.org/SpringVal-Wind.html

Elk, Pronghorn and Wildlife Connectivity:

The wind farm we believe will result in impacts to resident elk, deer, and pronghorn antelope, by noise impacts, habitat fragmentation, and increased human presence.
The project will disrupt connectivity for wintering elk and pronghorn antelope. Turbines would be bisected by roads, concrete, electric cables and other disturbances. Wildlife in general would be blocked by the proposed project.

From our comments on the EA: Pygmy rabbit (Brachylagus idahoensis):

Biologists mapped two burrows of this small animal in the northern part (SWCA 2009). These small herbivores require tall dense sagebrush stands to hide from predatory hawks and eagles. At least 3 individuals were seen in 3 separate habitat patches in the project site. About 89 acres of good habitat for this rabbit, and 61 acres of occupied habitat with active burrows were found on the project area. The EA states that is it hoped that the Pygmy rabbits will move away, "to avoid mortality associated with daily operations such as crushing by vehicles"

Because pygmy rabbits are restricted to sagebrush habitats with deep soils, they have always been rare and patchily distributed across their range. Biologists agree that the main threats to pygmy rabbits across their range are habitat loss and fragmentation caused by:
• conversion of sagebrush rangeland to agriculture;
• development, including oil and gas production; and wildfire frequency in some areas

If the Proposed Action is selected, relocation of pygmy rabbits by live trapping prior to construction should be considered in consultation with the USFWS and NDOW to avoid direct mortality. This is unacceptable, as the public does not have a chance to review any Pygmy rabbit relocation plan after project approval. How does trapping impact the rabbit? Please reference past trapping studies and give mortality numbers. How will rabbits be prevented from returning to home ranges? Where will rabbits be relocated to? Will these areas have other disturbance, and how will Pygmy rabbits already present be affected?