Wildlife and Wind Energy

Story and photo by Brian Kelly, Restoration Coordinator

I strongly believe in renewable energy but also that we need to protect wildlife and their habitats during the development all energy projects. HCPC has been reviewing the Antelope Ridge wind energy project proposed for construction in the foothills of the Grande Ronde Valley of northeast Oregon. Significant wildlife issues have come to light as the project has been reviewed. There is cause for concern.

Since May, 2009, four golden eagles have found dead at the adjacent Elkhorn wind energy site. Golden eagle nests have been found in the vicinity of the proposed Antelope Ridge project area and so the need for strong protections is obvious. Antelope Ridge also contains critical winter range for elk and deer, a potential sage-grouse lek, forested areas, habitat for bats, and it is located adjacent to northeast Oregon's largest remaining wetland, Ladd Marsh.

Below, you can read HCPC's letter that was sent to Oregon Department of Energy addressing these wildlife concerns. Three other conservation organizations signed-on to HCPC's letter. In this letter, we encourage the Department of Energy to adopt the wildlife recommendations that have been provided by Oregon Department of Fish & Wildlife and the US Fish & Wildlife Service to date as conditions for approval for Antelope Ridge.

Over the past year, I've heard a wide variety of opinions about wind energy. Whatever your views may be, if you care about protecting the wildlife of this area please make your voice heard.

You may submit comments about Antelope Ridge to Oregon Department of Energy at Sue.Oliver@state.or.us until 5 PM on February 14. A public meeting will also be held in Union, Oregon on January 25 at the elementary school in Union, OR at 6 to 8:30 PM. Visit the ODE website at http://www.oregon.gov/ENERGY/SITING/review.shtml for more information about Antelope Ridge.

Here is HCPC's letter:

Hells Canyon Preservation Council

Oregon Natural Desert Association

Audubon Society of Portland

Defenders of Wildlife

December 21, 2010

Ms. Sue Oliver

Oregon Department of Energy

245 Main Street, Suite C

Hermiston, OR 97838

Please accept these comments on behalf of the Hells Canyon Preservation Council , Oregon Natural Desert Association, Audubon Society of Portland, and Defenders of Wildlife regarding the proposed Antelope Ridge Project located in Union County, Oregon. We submit these comments during the preliminary application phase of the review process, and intend to submit additional comments during the public hearing phase.

We recognize the need for domestic energy independence and viable solutions to global climate change. We support responsible permitting and development of renewable energy projects and strongly believe that long-term success of the State’s efforts to develop renewable energy depends on thoroughly evaluating projects and finding ways to minimize environmental impacts. Impacts to wildlife and key habitats, along with methods to reduce and mitigate these impacts, must be fully considered in the decision making processes. In order to create a truly sustainable energy system for Oregon, we support of the recommendations provided by Oregon Department of Fish & Wildlife (ODFW) and US Fish & Wildlife Service (USFWS) issued to date during the preliminary application process. We ask that the Oregon Department of Energy fully adopt these recommendations as necessary requirements for approval of Antelope Ridge.

ODFW and USFWS have raised numerous concerns about wildlife including the proximity of active golden eagles nests to the project area, Greater sage-grouse habitat and the location of a potential lek site, big game critical wildlife habitat and winter range within the site area, as well as concerns related to other avian species and bats. These impacts will likely be compounded by the cumulative effects from the adjacent Elkhorn Valley project which has already impacted species such as the Golden Eagle. Adequate mitigation and protection plans are needed to reduce the severity of impacts on avian species and other wildlife, as well as sensitive vegetation such as the Doulas clover and Oregon semaphore grass.

Golden eagles are among our chief concerns. USFWS indicated there have been mortalities at the nearby Elkhorn Valley Wind Farm over the last year and we feel the likelihood of additional mortalities at both the Elkhorn site as well as the proposed Antelope Ridge project site is extremely high. This could pose a significant risk to golden eagle populations in the area. Several active and historic golden eagle nests have been identified within the proposed Antelope Ridge project area as well as in adjacent habitat. USFWS predicts additional eagles will be killed by wind turbines at Antelope Ridge unless a strong golden eagle protection plan is adopted. It is essential that USFWS recommendations for eagle protection are implemented to protect the eagles as well as Swainson’s hawk and burrowing owls identified within the project area.

We are also concerned about impacts to Greater sage-grouse. There is a potential Greater sage-grouse lek near the southern edge of the project. Greater sage-grouse are a species recently identified by the USFWS as warranting an endangered species listing under the Endangered Species Act (“ESA”) because of widespread declines in sage-grouse populations throughout the West. They have been precluded from a formal listing and the State has a responsibility to protect the integrity of the species.

In addition to our concerns about avian species, we are concerned about impacts to big game habitat such as critical winter range within the project area. This habitat that is vital for mule deer and elk to survive during harsh winter months. In a letter to Horizon from ODFW (see attached letter dated 5-28-10), ODFW cited that mule deer decreased by nearly 400 individuals at the Elkhorn Project site from 2005 to 2009. They felt this strongly indicated the population had decreased in the area after the project was built (indicating avoidance issues by mule deer to the wind turbines). ODFW also said that this information should inform future projects such as the Antelope Ridge Project.

This is an area rich with wildlife and natural heritage we all enjoy as Oregonians. In addition to the species and places we have already discussed, the Antelope Ridge project area is located immediately south of Ladd Marsh Wildlife Area, northeast Oregon’s largest remaining wetland and is home to abundant wildlife. Due to the proximity of forest land, shrub steppe and wetlands, the project area supports movements of wildlife and should be seen as important to wildlife connectivity in the area.

Despite the positive benefits of renewable energy, we feel the Antelope Ridge Project can only be truly “green” if it is sited and permitted with the utmost concern for wildlife. We hope that the Oregon Department of Energy will continue its ethic of responsible permitting and follow the counsel of ODFW and USFWS. We feel these agencies have adequately articulated concerns and potential solutions—now, it is the responsibility of the Oregon Department of Energy to comply with fellow agencies.

Thank you for your time and consideration. We hope to continue to be a partner in creating a sustainable energy economy all Oregonians can support.

Sincerely,

Brian Kelly, Restoration Coordinator

Hells Canyon Preservation Council

Liz Nysson, Climate Change Coordinator

Oregon Natural Desert Association

Bob Sallinger, Conservation Director

Audubon Society of Portland

Bruce Taylor, Director of Oregon Biodiversity Program

Defenders of Wildlife

New Critically Important Comprehensive Science Review on Moist Forest Logging

A recent review paper published in Conservation Letters entitled: Effects of logging on fire regimes in moist forests (Lindenmayer et al. 2010) focuses primarily on logging in moist forests where fires naturally occur at a lower frequency and higher intensity relative to dry forests. The manuscript represents a thorough review of over 650 research articles on fire, fire management, forest management, and conservation biology. The Lindenmayer et al. (2010) review is very relevant to management of our local moist, mixed conifer forests on the Umatilla and Wallowa-Whitman National Forests.

Lindenmayer et al. (2010) states: “Our focus is on relationships between industrial logging practices in native forests (i.e., not plantations) and alterations to natural fire regimes (sensu Gill 1975) that might include (among others) changed susceptibility to ignition, altered fire severity, altered fuel loads and fuel condition, and changed fire frequency. Altered fire regimes can have significant negative effects on biodiversity in moist forests (Holdsworth & Uhl 1997; Brown et al. 2004; Noss et al. 2006b; Lindenmayer et al. 2008), especially those forest types where wildfires are extremely rare or even a novel kind of major natural disturbance (e.g., some kinds of tropical rainforest, Uhl & Kauffman 1990; Cochrane & Barber 2009).”

In the Introduction, Lindenmayer et al. (2010) reminds us that logging cannot replace natural disturbance regimes: “However, we note that natural fire regimes cannot simply be replaced with regulated disturbance by logging (Hunter 2007). This is because, in part, many elements of forest flora and fauna depend on particular fire return intervals and associated habitat features (Saint-Germain et al. 2004). Logging operations also do not provide the diversity of habitats and micro site conditions found after wildfires (Haeussler & Kneeshaw 2003; Lindenmayer et al. 2008).”

Lindenmayer et al. (2010) identifies at least five interrelated ways that logging could influence wildfire frequency, extent and/or severity.

1. Changes in Microclimate: The removal of trees by logging creates canopy openings and this in turn alters microclimatic conditions, especially increased drying of understorey vegetation and the forest floor (Ray et al. 2005; Miller et al. 2007). As with the influence of forest edges (Harper et al. 2005), microclimate effects (including fuel drying) associated with forest harvesting can be expected to be greatest where the unmodified forest is moist.

2. Changes in stand structure and plant species composition: [Logging] changes not only alter microclimatic conditions as described above, but also can change stocking densities and patterns of trees, inter crown spacing, and other forest attributes such as plant species composition. Research in western North America indicates that logging related alterations in stand structure can increase both the risk of occurrence and severity of subsequent wildfires through changes in fuel types and conditions (Thompson et al. 2007).

3. Changes in fuel characteristics: Logging can alter fire regimes by changing the amount, type, and moisture content of fuels (Perry 1994; Weatherspoon & Skinner 1995; Thompson et al. 2007; Krawchuk & Cumming 2009). Large quantities of logging slash created by harvesting operations can sustain fires for longer than fuels in unlogged forest and also harbor fires when conditions are not suitable to facilitate flaming combustion or the spread of fire (Cochrane & Schulze 1999).

4. Change in ignition points: The road networks required for logging operations create an increased number of ignition points for wildfires. A substantial increase in ignitions and fire frequency in Russian boreal forests (Achard et al. 2006) has been attributed, in part, to roads built for logging and mining (Dienes 2004; Bradshaw et al. 2009). In Canadian mixedwood boreal forests, fire initiation following lightning strikes is more likely to occur in harvested areas because of increased fine fuels resulting from logging slash and this effect can remain for 10–30 years following logging (Krawchuk & Cumming 2009).

5. Change in the spatial pattern of stands: Logging operations change natural patterns of spatial juxtaposition of different kinds of forests stands (i.e., patterns of landscape heterogeneity) (Franklin & Forman 1987). This, in turn, can change spatial contagion in the spread of wildfire through landscapes (Whelan 1995; Bradshaw et al. 2009) with some areas traditionally characterized by an absence of fire becoming more susceptible to being burned by fires that spread from adjacent, more flammable, logged areas (Holdsworth & Uhl 1997; Perry 1998; Nepstad et al. 1999; Malhi et al. 2009). Similarly, forest edges created by logging and by logging roads can become sites for fire incursions into adjacent forests (Cochrane & Laurance 2002).

Lindenmayer et al. (2010) offers the following conclusions: “Contrary to claims by some commentators (e.g., National Association of Forest Industries 2009a,b,c), industrial logging is likely to make some kinds of forests more, not less, prone to an increased probability of ignition (Krawchuk & Cumming 2009) and increased fire severity and/or fire frequency (Uhl & Kauffman 1990; Thompson et al. 2007; Bradshaw et al. 2009; Malhi et al. 2009). Such places include tropical rainforests where fire was previously extremely rare or absent (Uhl & Kauffman 1990; Barlow & Peres 2004; Malhi et al. 2009), and other moist forests where natural fire regimes tend toward low frequency, stand replacing events (Whelan 1995; Odion et al. 2004; Bradshaw et al. 2009). These altered fire regimes can, in turn, have significant negative effects on a range of elements of forest biodiversity (Uhl & Kauffman 1990; Lindenmayer & Franklin 2002; Barlow & Peres 2004; Cochrane & Barber 2009).

“If industrial logging changes fire proneness, then interactions between logging and climate change could lead to cumulative negative impacts, including those on biodiversity. Conversely, recent work in Amazonia suggests that some kinds of forest may have some inherent resilience to climate change through maintaining mesic microclimate conditions if other agents such as logging are left undisturbed (Malhi et al. 2009). Third, a better understanding of relationships between logging and wildfire will improve policy making and forest management. For example, in moist forests there may be a case to create buffer areas adjacent to human settlements. In addition, there may be a strong case to exclude logging from those areas where past human disturbances (like timber harvesting) have been limited (Cochrane & Barber 2009). This is because logging induced alterations in landscape cover patterns can take prolonged periods to reverse and hence associated changes in fire susceptibility also may be long lived (Perry 1998).”

Lastly, Lindenmayer et al. (2010) states: “Calls to log forests to save them (Tuckey 2001) are overly simplistic. In this case, fire and forest management recipes suitable in one situation (e.g., for restoring the natural fire regime of a dry forest) might be inappropriate (and even counter productive) in another (e.g., a relatively moist forest) (Brown et al. 2004).”

If management actions in the Blue Mountains continue to target the remaining old growth moist forests, then these forests will become more rare and less able to support dependent native species. As we see today in the Ponderosa Pine/Douglas fir type, when old-growth forests are significantly reduced through logging, old growth associated species are greatly reduced as well. It is time we protect all remaining old growth forests from industrial logging.

If you are interested in receiving the pdf of this paper, please contact David at david@hellscanyon.org.

David Mildrexler

Ecosystem Conservation Coordinator

Hells Canyon Preservation Council

Lawsuit Seeks to Protect Thousands of Acres of Public Lands and Waters from Forest Service's Inadequate Environmental Review of Livestock Grazing

The Hells Canyon Preservation Council and the Oregon Natural Desert Association recently filed a lawsuit in federal court challenging several Forest Service livestock grazing permit renewals on three National Forests in eastern Oregon. The Wallowa-Whitman, Umatilla and Malheur National Forests have together reauthorized livestock grazing on well over a quarter million acres of our public lands without thoroughly assessing or disclosing to the public the impacts of these actions on the region's natural resources.

Instead, the Forest Service has elected to forego any thorough environmental assessments or meaningful public participation, issuing numerous "categorical exclusions" across eastern Oregon and throughout the entire American West. An appropriations “rider” passed by Congress in 2005 and extended in 2008, allowed the Forest Service to categorically exclude grazing reauthorizations in fiscal years 2005 through 2008 from documentation under the National Environmental Policy Act (NEPA), if the agency was able to demonstrate with monitoring data that current grazing management is meeting resource standards (standards designed to ensure ecosystem health, protect native species, and prevent overgrazing). Categorical exclusions are also disallowed if grazing might negatively affect certain special resources like threatened and endangered species; flood plains, wetlands, or municipal watersheds; congressionally designated areas, such as wilderness or national recreation areas; and cultural or archeological sites.

The Forest Service has repeatedly misapplied this grazing rider across these three forests. Although grazing has occurred on these public lands allotments for decades, in most cases the Forest Service has never prepared any environmental analyses under NEPA, despite the presence of imperiled plants, threatened salmon and steelhead, degraded streams, sensitive and unique habitats, cultural and archeological sites, and areas designated by Congress for special resource protection, such as the Hells Canyon National Recreation Area and the Imnaha and John Day Wild & Scenic Rivers. Because the agency has failed to adequately monitor these areas and the resources they contain, it cannot show that protective standards are being met and that grazing does not pose any serious threats.

When inappropriately managed, livestock grazing adversely impacts ecological communities, particularly sensitive streamside areas, meadows, sagebrush ecosystems, aspen stands, and native grasses and forbs, all of which are critically important habitat for fish and wildlife. Livestock can trample and eat vegetation, spread noxious weeds, compact soils, erode streambanks and impair water quality. When livestock are allowed to degrade this habitat, it threatens the ecological functioning or survival of many fish, wildlife and plant species.

This action aims to ensure the Forest Service takes a hard look at the impacts of grazing on thousands of acres of public lands and waters, imperiled species, and countless other natural resources of eastern Oregon and gives the public a meaningful opportunity to participate in the decisions affecting our natural heritage.

Jennifer Schwartz, Staff Attorney

Photo: Juniper Flat pasture, Alder Springs allotment on the Whitman Ranger District, Wallowa-Whitman National Forest (this allotment was among those categorically excluded from thorough environmental review and challenged in this lawsuit).