Dear Altamont Pass Wind Resource Area, Scientific Review Committee Member,
This proposal request has been dropped. The Alameda County Planners have been instructed by the County Board of Supervisors to create a Solar Energy Facility zoning policy for eastern Alameda County.
The last meeting in November 2012 was productive and a final public hearing maybe held in January 2013 before county planner submit their plan to the Alameda County Transportation subcommittee for a hearing. Stay tuned.
Allow me to introduce a potentially critical situation to you regarding the proposed changes to the Altamont Pass Wind Resource Area which will affect repowering collision and monitoring requirements as agreed to within the California Attorney Generals MOU for repowering.
Alameda County has been petitioned to consider approving a mega-sized, 2,700-acre industrial solar installation along Mountain House Road by Pegasus Energy Partners, (as shown on the Pegasus Energy Partners web site). The area in question is currently farmed in irrigated alfalfa. The conservation community many of whom had been stakeholders in the APWRA committee, feels that the Mountain House Road area is in the sphere of influence of the APWRA.
Recently, the Alameda County Board of Supervisors has directed County Planning to see if the Mountain House area can accommodate an industrial solar facility. This is when I (as Audubon Conservation Chair of the Ohlone Audubon Society, eastern Alameda County), The Alameda Creek Alliance, The Sierra Club, California Native Plants Society and Tri-Valley Conservancy began to speak up, offering input to discourage any change in land-use practices in the Mountain House area.
Alfalfa is grown and harvested several times a year in eastern Alameda County – Mountain House road area. When the crop is heavily irrigated, it forces rodent populations to surface. This produces an abundant food source for Kites, Eagles, Hawks, Falcons, Cranes, Owls, Herons, Vultures, and Shrikes. I have been birding this area for 30 years plus and have witnessed this foraging cycle annually. The volume of species can be astounding.
The spring crop harvest cycle coincides with (1) the back end of the Golden Eagle nesting cycle, when they forage these fields to feed their mates on the nest and, later, to feed both the mate and new hatchlings; (2) the arrival and nesting activity of migrating Swainson’s Hawks; and (3) the northward migration of winter resident hawk species. This is a critical time for all species to build their stamina for the cycle of life. These and the species already mentioned continue to use this source of protein during the summer, fall, and early winter months, but spring remains the crucial window for the species’ survival. Removing the food source in the Mountain House area would force birds to forage closer to the repowered turbines potentially increasing collisions in the repowering zone. Development will displace irrigated agriculture lands will forcing an expansion of avian species to seek new feeding grounds within the APWRA repowering area.
There are studies by Shawn Smallwood showing that Swainson’s hawks forage over alfalfa while the alfalfa was being flood irrigated or mowed 858 times other than expected. Species of Accipitridae (raptors) as a group visited alfalfa stands during summer 7 times other than expected. Ferruginous hawks visited alfalfa 7 times other than expected, and golden eagles hunt cottontails in alfalfa stands. Displaced birds will likely come into greater conflict as they attempt to forage over smaller spaces with many fewer resources than was found in the alfalfa, and these conflicts are likely to put them at greater risk of collision. Raptors chasing each other around wind turbines is likely to increase collisions.
There is deep concern within the conservation community that taking the Mountain House Road area out of irrigated agriculture production will destroy a significant foraging area and vital source of protein for the resident and migrating avian species—forcing them to forage farther into the APWRA repowering area and thus creating an (1) expanded source of avian collisions during peak seasonal energy demand and (2) the possibility of missing the 50 percent reduction in raptor collision goals of repowering and (3) skewing public and government opinion that repowering was ineffective.
An unfortunate precedent of this type of effect was seen when the golf course was constructed near Altamont Pass in 2005, displacing numerous burrowing owls. The next year there was a huge spike in burrowing owl fatalities in the APWRA, including at the just-repowered Diablo Winds project. Fatalities of other raptors also spiked in 2006.
The conservation community has asked for a five-year moratorium before Alameda County commits to a land-use plan that is almost certain to allow displacement into industrial use. The requested five-year moratorium is to gather avian use and impacts data and is modeled after that mandated in the California Attorney General’s MOU of December 3, 2010:
“Each phase of repowered turbines will be subject to three years of post-construction monitoring . . . [which] shall include collecting field data on behavior, utilization and distribution patterns of affected avian and bat species in addition to fatalities. In addition, each phase of repowering shall be subject to two years of further monitoring commencing on the tenth anniversary of its COD. (“Agreement,” 2010, Section 5.1, p. 6)”
During the last public meeting on February 28, 2012, Alameda County Planning Department had a map suggesting a buffer zone for APWRA banning solar development, but it failed to cover the irrigated agriculture areas. At the meeting conclusion I suggested that the SRC have a chance to weigh in with a study on the potential effects of increased avian population forced into the repowering study zone caused by a displacement of lowland foraging areas within the APWRA sphere of influence. It is the conservation community’s opinion that the APWRA should be managed for what science can control—in this case, protecting current foraging range from displacement.
Our community groups are not against government. We favor solar energy production. We support common sense, appropriately sited energy facilities and wise – land use within the APWRA sphere of influence. In fact, we are strong advocates for a huge reduction in the use of fossil fuels by the introduction of sustainable energy like solar and wind—but not to the detriment of eastern Alameda County’s unique, abundant avian populations.
In a 2011 interview, Nancy Rader (Executive Director of CalWEA) stated, “Our understanding of its [APWRA’s] environmental impacts has evolved just as much as the [wind] technology has”(Hull, 2011).
We agree with Nancy Rader. But industrial solar impacts are unknown and must be studied with specific focus on the impact of displacing 2,700 acres of significant raptor foraging habitat within APWRA’s sphere of influence. We know so much more about the avian use of the APWRA that we feel justified to question the judgment of developing and displacing so much foraging land within the APWRA sphere of influence is practical in light of the scientific data that is now available to support denying a zoning change.
Displacing 2,700 acres of vital avian foraging lands by zoning for industrialized solar within the sphere of influence of the APWRA without further study would interfere with and potentially violate the California Attorney Generals MOU monitoring requirements and may raise public trust issues. Without a five year moratorium to allow comprehensive study of repowering, the SRC may not achieve the scientific evidence that turbine repowering is a solution for reduced avian collisions.
Ohlone Audubon Conservation Chair Eastern Alameda County