An Analysis of the Alta East Wind Project in the Tehachapi Valley of Kern County, California

Austin Williams ENVS 196: Renewable Energy Tim Duane June 6, 2013

Introduction The Alta East Wind Project is a proposed wind farm in Tehachapi Pass, a part of Kern County, California. The project has yet to begin construction, but was approved by the BLM on May 24, 2013. (3) The project is being built by Alta Windpower Development LLC, which is owned by Terra-Gen Power. The project is a part of the Alta Wind Energy Center (AWEC), a 9,000-acre plot that has a combined installed capacity of 1020MW, making it the largest wind farm in the world. (1) The AWEC is expected to increase jobs in the California wind industry by 20% and reduce carbon dioxide emissions by about 52 metric tons. The project has some big name investors including: Google, GE and Citi. (1) In 2006 Southern California Edison agreed to a 1,550MW Power Purchase Agreement with the Alta Wind Energy Center for projects in the Tehachapi area from 2010 to 2015. (1) To help meet this goal Southern California Edison built the Tehachapi Renewable Transmission Project, the first major transmission project in California to be built specifically to connect with renewable energy sources. (1) Alta Wind was the first to connect to these transmission lines. (1)

Alta East Wind Project The Alta East Wind project is the newest addition to the Alta Wind Energy Center, and will be the focus of this paper. The project covers a total of 2592 acres, with 1,999 acres being public, BLM regulated land, and the remaining 593 acres being private land held by various stakeholders. (2) Once completed, the farm is expected to have an electricity production capacity of 153MW, which is enough to displace 126,358 metric tons of carbon dioxide. (2) Originally the project was proposed to have 106 wind turbines, but

Terra-Gen worked with the BLM to minimize the projects footprint, with only 51 turbines eventually being authorized. (3) The project has stated several of its objectives: to help the federal government to meet its renewable energy goals, supply clean energy to California in support of its RPS, aid the economy of Kern County, provide revenue to the BLM to lease the public land, create local jobs, provide revenue to the local landowners, and to locate themselves near existing facilities, mines and other projects to reduce the aesthetic impact. (3)

Tehachapi Renewable Transmission Project The major force that is bringing projects like the Alta East Wind Farm to Kern County is the Tehachapi Renewable Transmission Project (TRTP) being built by Southern California Edison (SCE). Once it is completed it will be capable of producing 4,500MW of wind-generated energy. (6) This is another part of SCEs plan to meet Californias Renewable Portfolio Standard of 33% of power generation from renewables by 2020. In 2011 about 21% of the power SCE produced was from wind, solar, biomass, geothermal and small hydro systems. (6) California was the first state to develop large wind farms in the 1980s due to tax incentives and favorable legislation following the 1970s energy crisis. The Tehachapi area has a rich history of generating wind energy because of strong northwesterly winds that blow through passes in the Tehachapi Mountains. (6) The reason why SCE is so interested in increasing its clean energy production is because of Californias Renewables Portfolio Standard (RPS). The program began in 2002, with an initial goal of increasing the percentage of renewable energy produced in the state to 20% by 2017. (7) In 2003 the Integrated Energy Policy Report recommended an

increase to 20% by 2010, and the 2004 Energy Report Update recommended an increase to 33% by 2020. (7) In 2006 Senate Bill 107 made the 20% by 2010 goal law. On November 17,2008 Governor Arnold Schwarzenegger signed Executive Order S-14-08 which boosted the goal to 33% by 2020. (7) With such strict legislation in place it is clear why SCE, and many energy producers and retailers, are so intent on doing what they can to grow the renewable energy sector. In response to these new standards, the California Public Utilities Commission (CPUC) created the Tehachapi Collaborative Study Group to develop a comprehensive transmission development plan for the phased expansion of transmission capability in the Tehachapi area. (6) Following reports made by this group in 2005 and 2006, the CPUC arranged an agreement between SCE and the California Independent System Operator to create the Tehachapi Renewable Transmission Project. In January 2007 the project plan was approved by the California Independent System Operator Board of Governors to begin construction. (6) Once completed, 250 miles of new transmission facilities will stretch from Eastern Kern County to San Bernardino County, passing through Angeles National Forest and the San Gabriel Valley. (6) In order to minimize cost and increase speed, the project will be constructed primarily on existing facilities, which will be either upgraded or replaced. (6) A new transmission line will cross 5.5 miles of BLM land to connect the project to Southern California Edisons Windhub Substation, a part of the TRTP. (10) Without this robust renewable energy transmission system in place, projects such as AEW would not be economical to build.

Location of the Connection of AEWP to TRTP

(12)

Environment and Climate The Alta East Wind Project is located in the western Mojave Desert, in a rural part of the Antelope Valley, located in the foothills of the Tehachapi Mountains. The climate consists of fairly hot summers, mild winters, large diurnal ranges in temperature, irregular rainfall, low relative humidity, and lots of sunshine. (3) The basin the site is in is separated from the coastal regions by two mountain ranges, which gives it a unique climate and strong wind flow, this area is known as the Tehachapi Wind Resource Area because it has some of the best wind in California. (3) Temperatures range from 70-98 degrees in July to 33-57 degrees in December, with rainfall averaging 5.9 inches per year. (3) The closest residential properties to the site are about 100 feet east of the northern boundary. (3)

History of the Project The Alta East Wind project submitted their Plan of Development (POD) on February 15, 2011. (13) The Notice of Intent to Prepare a Joint Environmental Impact Statement and Environmental Impact Report for the Proposed Alta East Wind Project, and Possible Land Use Plan Amendment by the BLM was posted on July 15, 2011. (13) After it was published, the project reduced the total acreage from 3,200 to 2,592 acres, by eliminating portions of the project on the north and south sides, reducing the number of wind turbine generators (WTGs) from 120 to 106 with a capacity of 318MW. (3) The BLM worked in conjunction with Kern County to create the draft Environmental Impact Statement/Environmental Impact Report, which was published on July 31, 2012. (13) There was then a 90 day period during which the public could make comments that would be considered for the final draft. (13)

There were many comments made about the document during this time from people from many different agencies. Many had issues with the visual impact, with some pointing out that in conjunction with other projects, some properties would be surrounded on all four sides by wind turbines. Others were worried that it would lower the scenic value of the area by lowering the amount of nearby wildlife, a reason why some people choose to live there. (14) Many were worried about the negative effect the project could have on their property values and did not believe the claims that the project would have positive effects on the local economy. (14) There were many who were concerned about endangered species, and some who were afraid that the loss of Joshua trees could cause bees, who use the trees to build their hives, to move closer to populated areas. (14) The final draft of the EIS/EIR was also supposed to be a joint document, but Kern County decided to move forward with its EIR, which was approved on January 22, 2013. (4) The BLM waited until February 15, 2013 to publish the final EIS in order to allow for a public protest period. (4) On April 10, 2013 Alta East submitted a revised Plan of Development (POD), which further reduced the projects footprint based on engineering information gathered by the Fish and Wildlife Service, lowering the number of WTGs from 106 to 51 with a capacity of 153MW. (4) The BLM decided that the new submission was not a substantial change to the project and that the impact was within the range that was analyzed in the EIS. (4) On May 17, 2013 the BLM granted a California Desert Conservation Area (CDCA) Amendment. The Record of Decision by the BLM was published on May 24, 2013 and granted the AEWP a right-of-way (ROW). (4) Construction is expected to take about 9 to 12 months. (4)

Reasons Why the BLM Approved the Project The BLM has very strict standards for what a project must have and do in order to be approved; following are some of the reasons why the BLM chose to approve the AEWP. The energy produced could displace up to 126,358 metric tons of CO2 that would otherwise be generated. (4) There are already many wind energy and transmission projects nearby. The AEWP agreed to an Eagle Conservation Plan and Avian Protection Plan, which will avoid and monitor impacts to eagles and migratory birds. (4) The project avoids direct impacts to known archeological and cultural resources. (4) The Fish and Wildlife Service concluded that the AEWP is not located in critical habitat of the California condor or desert tortoise. (4) Also, the AEWP agreed to a condor avoidance and minimization plan, which states Project activities are reasonably likely to result in the death of no more than one condor as a result of being struck by a turbine blade. (4) This marks the first time that the BLM has approved a wind project to take a California condor, an interesting occurrence that many people are concerned about, further information on this topic below.

List of Required Permits In order to enter into full operation there is an enormous list of permits and authorizations that the AEWP must obtain. At the federal level, from the BLM they must receive a ROW Grant in accordance with the Federal Land Policy and Management Act (FLPMA), as well as a CDCA Plan Amendment because the land is in the California Desert Conservation Area. (8) From the Tribal Historic Preservation Office they must get a Programmatic Agreement, Memorandum of Agreement or Determination of No Adverse

Effect under the National Historic Preservation Act. (8) From the USFWS a Biological Opinion or Determination of No Adverse Effect under the ESA and a Programmatic Take Permit under the Eagle Act. (8) From the Federal Aviation Administration they must receive a Notice of Proposed Construction of Alteration Application and a Determination of No Hazard. (8) At the state level, from the California Department of Fish and Game a Streambed Alteration Agreement under the California Fish & Game Code, and a CESA Incidental take permit. (8) From the Lahontan Regional Water Quality Control Board they must follow Waste Discharge Requirements, obtain a National Pollutant Discharge Elimination System General Permit for discharges from construction, as well as a Stormwater Pollution Prevention Plan. (8) Finally, from the county level they must get an Authority to Construct/Permit to Operate as well as over five discretionary permits and amendments. (8) This list really shines some light onto the amount of effort Alta East Wind and other wind farms in the area require to get up and running.

Project Equipment and Facility Details The 51 turbines used by Alta East Wind are capable of generating up to 3MW of electricity each, and are typically spaced 1.2 to 2.0 rotor diameters (350-590 feet) apart, with the rows spaced 8 to 10 rotor diameters apart. (3) They have a horizontal-axis design, and a light gray color with a non-reflective finish, following FAA guidelines. (3) A WTG is composed of a tower, nacelle, hub, blades/rotor, controller, central Supervisory Control and Data Acquisition (SCADA) system for communication, transformer, braking system, safety lighting, and a lightning protection system. (3) The towers at the highest point of a blade are 465 feet tall, and the lowest point of a blade reaches 98 feet off the ground. (3)

The towers can withstand wind speeds of up to 120mph, which is higher than any recorded or projected wind speeds near the site. (3) The main facility on site is the Permanent Operations and Maintenance Facility, which is two to three acres in size. The facility would contain a main building with offices, SCADA system (used to monitor and diagnose operations), control room, spare parts storage, restroom, shop area, outdoor parking, lay-down area, turn-around area for large vehicles, outdoor lighting, all with gated access with partial of full fencing, along with an information center for visitors. (3) There would also be a 230/34.5 kV substation on site to minimize power losses in the collection of power from the individual WTGs. (3) This substation will connect via an overhead transmission line to the main transmission line and Substation 6D, which are both part of the nearby Alta Infill II Project and from there to the SCE Windhub Substation. (3) There will also be meteorological towers to measure and collect data to allow for optimum turbine layout. (3) There will be one primary and one secondary road constructed to the facility, with no temporary roads required, although the roads will be temporarily widened during construction. (3) There will also be a five-acre large staging area during construction, which will be re-vegetated once construction is complete. (3) Once the project is completed up to 15 people will be hired, including wind turbine technicians, and operations/administrative/managerial personnel, to operate and maintain it. (3) Operation and maintenance personnel will need to conduct maintenance for each wind turbine for a set amount of time depending on the turbine supplier, with the average being 40 to 50 hours a year. (3) This maintenance will involve things like replacing fluids, checking for wear and tear, and recording data from chips in the turbines. (3) Outside of

this routine check-up, the SCADA system will alert operators if anything deviates outside set limits, even activating an automatic braking system if there is danger.

California Condor Conflict On May 24, 2013, as part of the Record of Decision, the BLM, and thus the Obama Administration, gave permission to the AEWP to take a California condor. (5) The California condor is protected under the Endangered Species Act of 1973. Normally a $200,000 fine is given to an organization that kills a condor, so the consent of the President to allow this is certainly worth noting. If a condor is killed then the project will be required to operate only at night, and BLM and FWS will need to reassess the situation. (5) One way in which the project hopes to avoid this is by the installation of very high frequency equipment that can pick up signals from devices that are attached to about half the 106 wild condors, from as far as 16 miles away. (5) Field trials were performed of the system, which was found to not only have a 100% success rate, but also detected the condor before the human observer, who many times never saw the condor at all. (11) If a condor is seen to be within 2 miles of the wind farm then the turbines will be reduced from 150 to 15 miles per hour in less than two minutes, reaching a speed of 3mph a few minutes later. (5) Terra-Gen will also contribute $100,000 a year to the Condor Recovery Program, which focuses mainly on reducing deaths caused by lead shot. (5) Many concerned citizens dislike the precedent that this announcement sets, and believe that the impact of wind turbines on condors should be considered as a whole rather than on a project-by-project basis, and do not believe that the federal government would punish the project too severely were they to

kill a condor early on in the projects lifetime. (5) This is an important event in the history of wind energy development, and how it affects future legislation will interesting to watch.

Bald and Gold Eagle Protection Act In addition to obeying the Endangered Species Protection Act, AEW must of course comply with The Bald and Gold Eagle Protection Act of 1940. (3) Under this Act it is illegal to kill or take a Bald or Gold Eagle, however, the U.S. Fish and Wildlife Service can permit certain activities to take eagles. (3) The EIS found that even with the protective measures that AEW will be taking to avoid harming these eagles, it is not enough. (3) As such, AEW will need to obtain a permit from the USFWS if they want to be protected from punishment for killing an eagle. (3) The BLM chose to still go ahead and grant the ROW, but made it clear that AEW will not be protected should a turbine harm an eagle. (3) In addition to violating the Eagle Act, the BLM will require AEW to implement limitations on nearby turbines when eagles are active were an eagle to be taken. (3) Alta East Wind decided to apply for an eagle take permit following these recommendations. (4)

Noise and Other Health Concerns While certainly much safer than alternative forms of energy such as coal and fossil fuels, wind power still poses a few health threats. Perhaps the strangest issue is called Wind Turbine Syndrome (WTS), which is caused by the constant low level noise and vibration of rotating blades and can cause illness in certain people. (3) Symptoms of WTS include: sleep disturbance, headache, tinnitus, ear pressure, dizziness, vertigo, nausea, visual blurring, rapid heart beating, irritability, and even panic episodes. Many health

issues originate with organic waste from depressed areas, ponds, or drainage that attract disease vectors such as mosquitoes, flies, and rodents. Also, soil in the area can contain a fungus called Coccidioides immitis, which can become airborne when the soil is disturbed, leading to a disease of the lungs called Valley Fever. (3) In addition to these more mundane, everyday concerns, there is also the threat of a major disaster such as a tower falling or catching on fire, possibly leading to a local disaster. (3) A major complaint that many nearby residents have is the noise pollution created by a large wind farm. These are legitimate complaints, as noise can have a negative impact on ones quality of life. According to the World Health Organization (WHO), sleep disturbance can occur when continuous indoor noise levels exceed 30-decibals. (3). In addition to a lack of sleep, noise has been found to have a possible negative effect on completing complex cognitive tasks, including: reading, attention span, problem solving, and memorization. (3) It can also cause real, physiological effects such as hypertension and even heart disease after many years of exposure. (3) There are several policies that the BLM has when it comes to the regulation of noise levels. For one, they follow the criteria of the California Division of Occupational Safety and Health (DOSH). (3) They encourage vegetation and landscaping along roadways and adjacent to noise sources and utilize good land use planning principles. (3) They also enforce the State Noise Insulation Standards and Chapter 35 of the Uniform Building Code for construction of new hotels, apartments and condominiums. (3) As with most issues a new technology faces, the issue of noise pollution will fade as technology improves to muffle the noise.

Aesthetic Impacts

As it is wind farms obviously imply large wind turbines, Alta East Wind faces many concerns over the visual impact of the project. Firstly, during construction the project will cause temporary issues involving cranes, heavy construction equipment, temporary storage and office facilities, and staging areas. (11) Not only will the presence of this equipment be visually distracting, they will also generate dust clouds. Construction will also increase traffic along State Route 58 and 14. (11) Because at least some construction will be taking place at night, mitigation measures to reduce visual contrast, light and glare are recommended by the BLM. (11) Disturbance to vegetation caused by soil disruption during construction will be a longer lasting issue, but could be alleviated if the project helped to plant and grow new vegetation. (11) Project impacts to views from the Pacific Crest Trail will be minimized through compensatory mitigation requiring funds for acquisition of property along the trail corridor. (10) In order to follow FAA standards, aviation warnings must be placed on the nacelles (the box-like component on top of the tower) of the turbines on the end of a turbine string, as well as on every third of fourth turbine in a row. (11) These are visible from 10 miles away at night, and thus would be visible from nearby residences. WTGs also have the potential to create shadow flickers which is when the blades of a turbine cause a strobe effect on nearby areas, which could induce seizures in sensitive individuals; however, studies showed that any shadow flicker created in AEW would not be significant enough to cause serious problems.

Fire Being located in the dry conditions typical of inland California, the project faces the potential of starting a wildfire. If a fire were to escape the area and spread into the

Tehachapi Mountains, much serious damage could occur. (11) Construction using large machinery and vehicles, heated mufflers, explosives used during site preparation, and workers smoking on the location, all pose a fire hazard. (11) If the introduction of certain non-native plants is not controlled, the risk of a fire will further increase. (11) Some ways suggested to prevent the introduction of invasive plants include: monitoring, weed identification, controlled inspection of vehicles coming from areas containing invasive species, monitoring of access roads and new transmission line corridors, the use of certified weed-free mulch, reclaiming disturbed soil with native shrubs and grasses, and careful use of pesticides. The actual operation of the project also increases the risk of a wildfire. (11) This could occur if the rotor blades spin out of control and cause a fire in the nacelle of a turbine, or if lightning or a bird strikes a turbine. (11) In the case of a fire, each turbine is equipped with a fire detection system. Also, a lightning rod and lightning shielding on all blades and sensitive equipment is attached to the top of each. (11) The project must also install either an automatic fire extinguishing system or purchase an Industrial Mini Pumper. (11) The risk of a wildfire from the AEWP is a low-probability, high-damage scenario, which is something society tends to be risk-adverse to, which is why such stringent measures are taken.

Impact on Wildlife California sports an abundance of species richness; as such extra precaution must be taken to prevent harm to many local species. The species most impacted by the project include: desert tortoise, coast horned lizard, California condor, golden eagle, Swainsons

hawk, burrowing owls, bats, American badger, desert kit fox, Mohave ground squirrel and various invertebrates such as Kern shoulderbrand. (11) The AEWP is located within the Tehachapi Connection, an important connection between plants and animals of the Sierra Nevada, San Emigdio Mountains, San Joaquin Valley, and the Mojave Desert. (11) Many mitigation measures are required in order to reduce the impact of the project on local wildlife: biological monitoring during construction, worker environmental awareness training, minimization of construction night lighting, a vehicle speed limit of 15 miles per hour, and dust control. (11) The biggest threats to desert tortoise include: traffic causing direct mortality or injury, avoidance of the area because of noise vibrations, and an increase in predators, such as ravens, because of the food source of trash cans and perching areas created by fences and transmission poles. (11) As mentioned earlier, the project has the possibility of harming the endangered California condor, although there are no known specimens that currently use the site for foraging, roosting or nesting. Were they to enter the area they could be harmed by collision with WTGs or transmission lines, loss or disruption of foraging habitat, the introduction of trash that they may try to eat, and exposure to toxic glycol antifreeze. (11) However, an extremely high number of mitigation measures will be implemented to reduce the possible impact on the condors, including removing livestock carcasses from the area, especially because condors are group feeders, which could mean several fatalities could occur at once if a carcass is located in a danger zone. (11) Because of the nature of WTGs birds and other flying animals such as bats face the greatest risk during the operation of the project. (11) Interestingly, the greatest cause of WTG-related fatalities

of bats is not from direct impact, but from barotraumas because they cannot detect the low-pressure areas caused by the spinning blades, causing severe lung damage. (11)

Why Wind is the Best Option for the Site As part of the EIS, the BLM analyzed alternatives to the project, including, the construction of solar, geothermal, biomass, tidal, wave, natural gas, coal, or nuclear energy projects, as well as simply no construction at all. The first alternative mentioned is solar, including solar photovoltaic (PV) panels. A solar project in the area would create more land disturbance in the creation of solar panels and access roads, and a solar project of the size of AEW is simply not feasible in the local topography. (3) Distributed PV panels would cause less destruction, but under the Energy Policy Act of 2005, the Secretary of the Interior must approve at least 10,000MW of non-hydropower renewable electricity by 2015, so they need a non-distributed source of power. (3) Geothermal projects have a lower effect on air quality and cultural and biological resources because they use less land, but can cause visual impacts and produce waste such as hydrogen sulfide. (3) Biomass also requires less land, but needs multiple facilities and air quality, traffic and noise impacts would increase because of the long distance required to haul the fuel. (3) The reason why the BLM did not side with the no-construction option is because of the need to meet the California RPS. (3) Wind possesses many qualities that make it the perfect choice in situations where other sources of renewable energy would not be viable.

Conclusion The Alta East Wind Project and the Alta Wind Energy Center as a whole represent an exciting step forward for the wind-generated energy industry, as well as a reason to believe that California will actually meet its RPS goal of 33% renewables by 2020. Many see solar as the most practical option for renewable energy, and while this may in fact be the case, it cannot power the world on its own, especially at night. There is no one source of clean energy that will save us from our current woes over oil and climate change, the future will require us to find the right resource for the job on a site by site basis. The tremendous growth of wind projects in the Tehachapi area in only a few years time proves that wind can become a viable source of clean power as we enter the Climate Change Era.