Public Scoping Comments,
North Steens Transmission Line Project EIS
Submitted by the Oregon Chapter Sierra Club
High Desert Committee
We would like to thank you on behalf of the Sierra Club for the opportunity to comment on the development of North Steens Transmission Line Project EIS.
First and foremost we have a concern regarding the isolated evaluation of the environmental impact this proposed transmission line will have on Steens Mountain in the absence of considering the cumulative impact of both the Echanis wind farm and future proposals for energy development which would access this transmission line. We believe that if evaluated and considered without regard for the whole, the true impact of the development will not be realized. It would be as if someone considered the construction of a single wind turbine alone, finding minimal impact and then considering a second turbine and its stand alone impact, also minimal, and multiplying this process a hundredfold to determine that 100 turbines have no impact because individually the impact of each one is insignificant. As silly as that sounds, this appears to be the process being used. Given that the proposed transmission lines will have far more capacity than the Echanis project will need (at its current level) it is reasonable to predict that other wind projects (perhaps including ones previously identified within the SMCMPA) will be proposed piece meal as separate developments, to be evaluated individually without the oversight of any concern for a cumulative effect. The fact that the proposed line will operate at half capacity (115kV of 230 kV circuit) and that a second circuit is proposed for the future more than implies that addition development is intended. We believe the BLM and USFW should consider the environmental impact of not only the transmission lines and associated infrastructure, but also the combined impact with the Echanis project as well as future development of wind farms on the mountain up to the capacity of the transmission lines proposed.
Given that Steens Mountain is a major staging and migration point for raptors and Malhuer Refuge is likewise for waterfowl, there needs to be serious concern given to the impacts these lines (and wind farms, proposed and potential) will have on the flight of these varied species and others. Given that the line will bisect Steens Mountain, migrating birds will be forced to navigate over, under, or through the lines. Although the proposed line only crosses a narrow portion of the formal refuge, any waterfowl or other bird species will also be forced over, under, or through the lines as they move between the north and south parts of the refuge. There will undoubtedly be casualties from strikes in a landscape supposedly protected first and foremost for wildlife and ecosystem integrity, not to mention the additional effects of the wind turbines.
Given that sage grouse remain a struggling species perpetually on the cusp of receiving protected status as threatened through much of its range, it would seem that additional caution should be given to the effect these lines will have on breeding leks and the migration patterns of these species as well. Sage grouse are notorious for avoiding areas with tall structures (power poles and wind turbines) that might appear to provide perches for predators. Given that the Steens ecosystem might appear to have a marginally stable population of sage grouse, a long barrier such as the transmission line would no doubt diminish such stability in an otherwise lightly developed ecosystem.
Undoubtedly there will be impacts to wildlife and these should be documented explicitly with mitigation efforts such as habitat improvements and land acquisitions and protection which would take place to reduce these impacts. It would seem fair and prudent that such mitigation would be funded with income from the power production.
While no new roads seem proposed within the actual CMPA, the staging areas and the construction and maintenance of the lines will no doubt disturb the vegetation and provide a potential foothold for invasive species across the breadth of the mountain. Given the number of roads currently on the mountain already providing vectors for dispersal of invasive plants, this may seem insignificant, but this development is a new disturbance of significant length and much greater width than a single track road. We also have concerns regarding the temporary but perhaps ongoing use by ORVs along the transmission line and would like to know what measures will be taken to rehabilitate disturbed lands and prevent ongoing unauthorized use.
Many people come to Steens Mountain for the spectacular views. While this project may be marginally visible from the famous viewpoints, we are concerned that future projects intended to fill the capacity of the power line will likely be far more prominent and visible and this potential or inevitability should be considered in evaluating the transmission lines. In addition to passing through the CMPA, the lines appear that they may be visible from nearby wilderess study areas along with the wind turbines. Because of the special nature of Steens as a special place, protecting its views from development (again, lines and turbines – proposed and future combined) should be considered.
We wonder whether anyone has looked at the physical viability and analyzed the impacts of burying the power lines either in their entirety or at least in sensitive areas. We also wonder whether anyone has considered having the lines follow or replace current access roads or routes, and what other potential routes have been explored, including directing the transmission line toward the Fields FollyFarm road to the east. We would hope that financial cost of alternatives would not be the foremost consideration in this incredible and nationally protected landscape.
The Sierra Club supports wind development in general as a means to reduce our dependence on foreign oil and to reduce our carbon footprint as well as to bring jobs and income to rural economies, but we also support such development only in appropriate locations and with thorough review and evaluation of the effects such development will have on the surrounding environment. It would seem absurd to propose wind turbines say on the rim of the Grand Canyon. There are undoubtedly many other appropriate sites for wind development in Harney County and we hope that the various communities (local, state, and federal) will consider a more comprehensive evaluation and approach to siting wind farms, transmission lines, and the associated infrastructure with the goal that such developments be pursued efficiently and with sensitive consideration of their environmental impact. Strong wind cannot become the sole criteria for selecting wind power generation sites as the environmental costs and sacrifices are just as real as the benefits of clean energy.
The Oregon Chapter of the Sierra Club has been actively engaged in advocating for and protecting Oregon’s desert wildlands for nearly 20 years. The Sierra Club is the nation’s oldest and largest environmental organization. Its mission is to: (1) explore, enjoy and protect the wild places of the earth; (2) practice and promote the responsible use of the earth’s ecosystems and resources; (3) educate and enlist humanity to protect and restore the quality of the natural and human environment; and (4) use all lawful means to carry out these objectives. The Sierra Club is primarily a volunteer run organization with over 1.4 million members and supporters nationwide including nearly 25,000 members in Oregon.
Over the course of this time, volunteers with the Chapter’s High Desert Committee (“HDC”) have explored and inventoried BLM Wilderness Study Areas, commented on numerous proposals and plans regarding wildlands management decisions, lead countless trips and outreach activities to expose Oregonians to the High Desert, and participated in consensus based advisory councils. The mission of the HDC is to protect the ecological integrity of Oregon’s desert wildlands and to advocate for the eventual designation of some of these lands as wilderness. The Club was a core partner with other environmental groups involved with the process to protect Steens Mountain, eventually resulting in the Steens Mountain Cooperative Management and Protection Act, and members have continued such involvement by serving on the Steens Mountain Advisory Council, writing comments on various land use decisions, and participating in service projects on Steens.
Thank you for considering these comments toward the further planning of how to manage potential wind development on Steens. We look forward to participating further in this matter.
Borden Beck – chair, High Desert Committee
Oregon Chapter Sierra Club
1821 SE Ankeny St.
Portland, OR 97214