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HomeMy WebLinkAboutREPORT - ENV & PERMITTING - little_mt.susitna_wind_stantec_12.15.21Memo To: Matthew Perkins From: Sara Lindberg Alaska Renewables, LLC Stantec Date: December 15, 2021 Reference: Environmental Screening and Permitting Plan Alaska Renewables Little Mt. Susitna Win d Project Site Stantec Consulting Services Inc. (Stantec) conducted a preliminary desktop assessment of natural and cultural resources in the vicinity of the proposed Little Mt. Susitna wind project site in southcentral Alaska (Figure 1). The purpose of this assessment is to identify environmental issues that could present risks in the development or permitting of the project. An issue is considered a high-risk level if project development could affect a resource in a manner that state or federal regulators may not permit the project or may result in significant project delays . No high-risk level issues have been identified for the project. We identified, reviewed, and analyzed issues presenting potential risk s for the project site and provide recommendations on next steps. This assessment considers regulated natural and cultural resources located in the vicinity of the project site and identifies those resources that could be affected by the project. This review was based on the .kmz files for the project provided by Alaska Renewables on November 30, 2021. The assessment for the site included a review of publicly available GIS and background data from various state and federal agencies, as well as other readily available sources. We rev iewed the following resources: 1) Wetlands, waterbodies, and natural communities within the preliminary site area; 2) Wildlife and fisheries resources within the preliminary site area, as well as known wildlife resources within 10 miles; 3) Parcel data within 2 miles; 4) Resource Protection Areas and Conservation lands within 10 miles; 5) Cultural and scenic resources within 10 miles; 6) Airspace and communications constraints within 10 miles. Results of the assessment are presented below and summarized in the attached table. The table is not a complete list of potential considerations or issues that may affect the project, but rather a list of issues that coincide with the requested environmental considerations listed above. Each table contains the low- and medium-ris k level issues outlined in this memo. Medium-risk items are those that may be cause for agency or public concern and will require further study to identify potential impacts and options for avoidance and/or mitigation. Low-risk level issues are for those resources that do not occur or can be avoided and are likely to be non -issues during project development. Some low-risk issues will need to be evaluated during the permitting process but are not likely to cause obstacles for project development. Recommen dations for each issue category are also provided in the tables. December 15, 2021 Matthew Perkins Page 2 of 7 Reference: Environmental Screening and Permitting Plan Alaska Renewables Little Mt. Susitna Wind Project Site Additionally, a permitting schedule is provided that forecasts each study and approval anticipated to support construction and operation of the project. We assume construction of the project will take two years and a target Commercial Operation Date (COD) in January 2025. Depending on the extent of field studies required by agencies in spring/summer 2022 and length of the consultation/permitting process, it may not be possible to complete all required studies and obtain permits/clearances by December 2022. To allow for the best chance in achieving the COD of January 2025, we have developed the schedule to begin agency coordination and alternativ e route development (for the access road and transmission line) in earnest in spring 2022 and have assumed an expedited field effort and use of desktop survey methods for resources where possible. To minimize and mitigate for impacts to air quality during project construction, as well as minimize the carbon footprint associated with the production and transportation of materials and equipment to the site, we suggest limiting the construction of the project to two seasons . The work will also take place during the summer months when construction vehicle traffic will be greatest. If feasible, we also suggest sourcing local construction material to reduce travel distance for construction vehicles. Placement of turbine pads, transmission, access roads, and other facilities will utilize existing infrastructure wherever possible to minimize the disturbance footprint. Following construction, vehicle traffic will be minimal and include a small number of operations and maintenance staff driving to the project site each day. The turbine site is located on state lands; however, a portion of the new access road and transmission line are located on protected State game refuge lands. While a permit would be allowed to construct a new road through the area, additional diligence will be needed to evaluate alternatives and minimize impacts to habitat through the refuge. In addition, the nearby community of Tyonek, an Alaska Native Athabascan community located south of the barge landing merits consideration for outreach and relationship building to gain support for the project. Cook Inlet is designated Critical habitat for the Endangered Cook Inlet population of beluga whales. Should the barge landing need improvement below the high tide line, consultation with the National Marine Fisheries Services (NMFS) will be required and would be an extensive and lengthy process. Therefore, we assume any improvements to the barge landing would occur above the beach in uplands. Bird surveys conducted at the turbine site and within areas proposed for new ground disturbance will help account for state and federal species of concern, federally protected migratory birds and eagles, but also species that may be of interest, such as swans and owls, but are not formally protected in Alaska. There are no known records of threatened or endangered plants within the project area. However, the Alaska Center for Conservation Science maintains a list of rare plants for the state. Precise locations of collection records are not available but lists for the region around a project area can be produced. These lists are not specific to habitat, therefore a characterization of potential rare plants for the project site may also be required depending on the potential for occurrence of state protected status plants and can occur coincident with wetland surveys. December 15, 2021 Matthew Perkins Page 3 of 7 Reference: Environmental Screening and Permitting Plan Alaska Renewables Little Mt. Susitna Wind Project Site Site Constraints Summary We identified six medium-risk level issues that require further evaluation to determine effects to project development/design and/or present risk during permitting (Table 1). These issues are discussed below. 1) Proximity to Conservati on Lands is a medium-risk level issue that could affect road and transmission line route development and design. The turbine area is approximately 3.5 miles north of the Susitna Flats State Game Refuge which is conserved/protected by the State of Alaska. The proposed new access road and transmission line cross the Refuge for a portion of their alignments. Outreach to the Alaska Department of Fish and Game (ADF&G) should occur during project planning to identify any potential concerns with wildlife corridors that may be associated with the refuge. Development of the road and transmission line within the refuge will require a Special Area Permit. The permit process will evaluate whether the project will damage refuge resources, disturb wildlife, or disrupt existing public uses. New roads within the refuge may be allowed if the use is in the overall public interest and for which there is no feasible alternative. As such, a robust alternatives analysis will be required during project planning. 2) Proximity to Cultural, Scenic, and Recreation Resources is a medium -risk level issue that could affect project design. Scenic and Recreation Resources: Hunting, berry picking, travel to private cabins takes place in the greater area and within the Susitna Flats State Game Refuge. There is also land owned by the Cook Inlet Region, Inc. (an Alaska Native regional corporation) within 10 miles of the turbine area which may see some use for subsistence activities (Figure 2). No other designated recreation a reas existing within the project area. A preliminary viewshed analysis should be completed for scenic resources within 10 miles of the site. Impacts to recreation resources are likely minimal/temporary but will be evaluated during the Special Area Permit process for development within the State game refuge. Cultural and Historic Resources: Various cultural sites are identified near the project area. Within the barge landing and transportation area along the coast, several sites occur associated with th e Chuitna Archaeological District near the unincorporated community of B eluga. Along the corridor for the new access road and transmission line, there are a few buried archaeological sites discovered during previous surveys associated with oil and gas exploration. The last survey in the area was conducted as recently as 2016. The turbine area itself does not have any recorded sites, however no surveys have been conducted in the vicinity. No other scenic resources within 10 miles of the site are noted. A cultural survey will be required within the area of potential effect along the new access road and transmission line corridor as well as the turbine area. As several alternative routes for the access road and transmission line will likely require evaluation, some level of cultural review will be needed along December 15, 2021 Matthew Perkins Page 4 of 7 Reference: Environmental Screening and Permitting Plan Alaska Renewables Little Mt. Susitna Wind Project Site all routes to evaluate impacts to cultural and historic resources. Agency consultation should be conducted prior to implementing surveys. 3) Proximity to potential raptor habitat and Bald Eagle nests within the new road and transmission line corridor is a medium-risk level issue that could require careful siting of the project to avoid/minimize risk of impacts to protected species. Raptor habitat occurs throughout the lower portions of the project area, and Bald Eagles are known to nest in large cottonwood trees above the Susitna flats area. Exposed rocky habitat appears to occur at the top of the project within the turbine area which may also be suitable habitat for nesting raptors. Aerial eagle nest surveys will be required during the planning process. If nests are found during surveys, agency-app roved buffer zones (e.g., 500-feet) will be implemented to avoid/minimize impacts to eagles during construction and operation of the project. Depending on results of aerial eagle nests surveys, the USFWS could recommend site specific eagle use surveys for a minimum of one year and possibly up to two years to meet the USFWS Final Eagle Rule. Agency consultation should be conducted prior to implementing surveys. 4) Proximity to high value fish and wildlife habitat within the new road and transmission line corridor is a medium-risk level issue that will likely affect project design. Anadromous Fish: The project is located within or near the Lewis River and tributaries to the Theodore R iver, both rivers are designated a s anadromous waterbodies by ADF&G, important for the spawning, rearing and migration of Coho, Chinook, and Pink salmon (Figure 3). If bridge modifications are required on the existing Beluga Highway near the barge landing, several other anadromous streams may also be impacted, some of which support sockeye salmon in addition to the species already listed. Construction of the proposed access road across the Lewis River will need to evaluate alternatives and the design should allow for maintenance of flow and fish passage. Construction of the access road or disturbance associated with the transmission line within the tributaries of the Theodore River may also have impacts, and ADF&G may require fish habitat surveys be conducted to determine fish presence. An ADF&G Fish Habitat Permit will be required prior to development and may include mitigation for impacts. Threatened and Endangered Species: Endangered Species and Critical Habitat occur within the bar ge landing area, although no impacts are anticipated. Cook Inlet and the lower Susitna River are within the range of the Endangered Short-tailed Albatross (Phoebastria albatross). H owever , these species are largely pelagic (occurring in the open sea), and no opportunistic sightings have occurred in the project area . Consultation with the USFWS during project planning will address any concerns related to this species and identify considerations (if any) needed during materials shipping or other project activities. The Cook Inlet beluga whale (Delphinapterus leucas ) population is listed as Endangered, and Cook Inlet has been designated as Critical Habitat for the survival and recovery of the population. Consultation with the National Marine Fisheries Service (NMFS) will be required December 15, 2021 Matthew Perkins Page 5 of 7 Reference: Environmental Screening and Permitting Plan Alaska Renewables Little Mt. Susitna Wind Project Site during project planning to address any concerns with shipping associated with construction of the project. Should the barge landing or the transportation corridors/bridges along the beach be modified, impacts to protected species may be of concern and would trigger additional consultation requirements. We r ecommend any improvements to the barge landing occur within uplands above the high tide line. 5) Proximity to bird habitat for state Birds of Conservation Concern (BCC) and travel corridors for other species of interest within the site area is a medium-risk level issue that could require careful siting of turbines or operational controls to avoid/minimize risk. As with any land-based wind energy project, it is recommended that the project consult with state and federal wildlife agencies at the point of conception to determine potential wildlife resource concerns, conduct field surveys if necessary, and site and operate the project to avoid and minimize impacts. The USFWS Land Based Wind Energy Guidelines (WEG’s), 1 and Eagle Conservation Plan Guidance (ECP)2 details the standard approach to evaluating potential impacts from a project. The analysis below is consistent with Tier 1, Preliminary Site Evaluation of the WEG’s. The elevation of the turbine area ran ges from 2,000-3,000 feet; the Susitna Flats to the south is approximately 0-100 feet in elevation at the bottom and the highest point and closet to the project area is at about 670 feet in elevation. Based on a desktop review, the project area is at the subalpine zone; ericaceous low shrubs, alder , dwarf birch, and willow are the dominant vegetation on higher slopes near the turbine area . A mix of birch/white spruce and cottonwood trees dominate the lower slopes and flats near the coast. Scattered through out the slopes and lower elevations of the project are open shrub and emergent wetlands. The Lewis and Theodore Rivers and their tributaries cross the project area, and provide riparian habitat for various species. Birds of Conservation Concern: U.S. Fish and Wildlife Service (USFWS) Information for Planning and Conservation (IPaC) tool was reviewed for records of species of concer n within 10 miles of the site area. This review identified 2 USFWS BCCs potentially occurring within 10 miles, and include the Aleutian tern (Sterna aleutica ) and the American Golden -plover (Pluvialis dominica). These two species are of concern th roughout their range in the US. Both of these species are strongly associated with water and nest in nearby areas. Wetlands and waters found at lower elevations may provide habitat for these species and these birds could pass through the project during migration. Breeding seasons for these birds occur between May and August, and considerations for constructing timing to avoid periods when these species are actively nesting will likely be a component of project development. Bats: There are no state or federally listed bat species known to occur in the project area. The little brown bat (Myotis lucifugus ) is the only known bat species found north of 59°N latitude. ADF&G considers the bat widespread, but in low numbers. There is an absence of baseline data on population sizes and trends. They are managed by the state as ‘unclassified game’; 1 WEG_final.pdf (fws.gov) 2 Microsoft Word - ECPG Wind 4 -18-13_final -rap -4-25-13-2 (fws.gov) December 15, 2021 Matthew Perkins Page 6 of 7 Reference: Environmental Screening and Permitting Plan Alaska Renewables Little Mt. Susitna Wind Project Site there are no hunting seasons or bag limits. They can only be killed or harassed under the terms of a wildlife nuisance permit. While listed bats are not known to occur based on the IPaC database bats are known to be susceptible to collision with wind turbines during migration. Impacts to bats, while not regulated, may require additional survey to confirm species presence/probable absence, we recommend a Site Characterization consistent with Tier 2 of the WEG’s to assess habitat and potential for occurrence of bird and bat species of concern which will guide potential need and type of field surveys that may be required. Depending on the results of agency consultation , nocturnal radar migration or acoustic bat surveys may also be recommended to document potential nocturnal movement patterns in areas proposed for turbines. If rare bats are present, the project may be required by the agencies to curtail turbines at low wind speeds (e.g., 5.0 meters per second) to minimize collision risk for bats. 6) Proximity to wetlands and waterbodies is a medium-risk level issue that could require careful siting of new road and transmission line routes to avoid/minimize risk. National Wetland Inventory (NWI) data depicts several wetlands and streams within the site area (Figure 3). Wetlands occur within the lower portions of the project area where barge landing and transportation activities will occur on existing infrastructure. A portion of the new access road and transmission line crosses wetlands and streams before reaching the turbine area. Route planning will be important to minimize wetland and stream impacts. The turbine area does not contain mapped wetlands , but likely has small headwater streams. A wetlands survey will be required during project planning and the survey area will need to accommodate all road route alternatives. Please let us know if you have any questions about the information presented in this memo. Sincerely, STANTEC CONSULTING SERVICES INC. Sara Lindberg, Principal Phone: (907) 328-9622 Attachments: Table 1 – Summary of Issues for Little Mt. Susitna Site Table 2 –Potential Natural Resource Studies, Permits, and Anticipated Timeframes December 15, 2021 Matthew Perkins Page 7 of 7 Reference: Critical Issues Analysis and Permitting Plan Alaska Renewables Wind Project Sites Figure 1 – Little Mt. Susitna Overview Figure 2 – Little Mt. Susitna Land Ownership Figure 3 – Little Mt. Susitna Wetlands and Waters Reference: Environmental Screening and Permitting Plan, Alaska Renewables Little Mt. Susitna Wind Project Site Table 1. Summary of Potential Issues for Little Mt. Susitna Site Issue Risk Level Comments Recommendations High Medium Low Conservation Lands X The turbine area is approximately 3.5 miles north of the Susitna Flats State Game Refuge which is conserved/protected by the State of Alaska. The proposed new access road and transmission line cross the Refuge for a portion of their alignment. Outreach to ADF&G should occur during project planning to identify any pot ential concerns with wildlife corridors that may be associated with the refuge. Development of the road and transmission line within the refuge will require a Special Area Permit. A robust alternatives analysis will be required during project planning. Cultural and Scenic/Recreation Resources X Hunting, berry picking, travel to private cabins takes place in the greater area and within the Susitna Flats State Game Refuge. No other designated recreation areas existing within the project area. Various cultural sites are identified near the project area. The turbine area itself does not have any recorded sites, however no surveys have been conducted in the vicinity. No other s cenic resources within 10 miles of the site are noted. A preliminary viewshed analysis should be completed for scenic resourc es within 10 miles of the site. Impacts to recreation resources are likely minimal/temporary but will be evaluated during the Special Area Permit process for development within the State game refuge. A cultural survey will be required within the area of potential effect along the new access road and transmission line corridor as well as at the turbine area. Potential Raptor Habitat X Raptor habitat occurs through the lower portions of the project area, and Bald Eagles are known to nest in the large cottonwood trees above the Susitna flats. Exposed rocky habitat occur s at the top of the project within the turbine area as well. Aerial eagle nest surveys should occur during the planning process and known nests will need to be avoided. Eagle Use Surveys according to the USFWS Final Eagle rule may also be required depending on nests within 2 miles of the project. Reference: Environmental Screening and Permitting Plan, Alaska Renewables Little Mt. Susitna Wind Project Site Table 1. Summary of Potential Issues for Little Mt. Susitna Site Issue Risk Level Comments Recommendations High Medium Low High Value Fish and Wildlife Habitat X The barge landing and a portion of the transportation corridor is located within the range of Endangered species and designated Critical Habitat. Cook Inlet and the lower Susitna River are within the range of the Endangered Short -tailed Albatross. Cook I nlet is designated as Critical Habitat for the Cook Inlet population of the beluga whale. The project is located within or near the Lewis River and tributaries to the Theodore R iver, both designated a s anadromous streams by ADF&G, important for the spa wning, rearing and migration of Coho, Chinook, and Pink salmon. Consultation with USFWS and NMFS will be required during permitting to evaluate impacts to protected species associated with barge activities but should not be a high risk to project development. Recommend any improvements to the barge landing occur within uplands above the high tide line to avoid triggering additional consultation requirements . Construction of the proposed access road across the Lewis River will require design for maintenance of fish passage. An ADF&G Fish Habitat Permit will be required. Birds and Bats X Several bird and bat species use and travel through the project area from adjacent habitats. USFWS IPac tool identified 2 Birds of Conservation Concern (BCC) species potentially occurring within 10 miles of the site area. Conduct breeding bird surveys. Nocturnal radar and acoustical bat surveys may also be recommended by agencies during project planning. Wetlands and Waterbodies X National Wetland Inventory (NWI) data depicts several wetlands and streams within the site area. Wetlands occur within the lower portions of the project area where barge landing and existing/proposed transportation activities will occur. The turbine site area itself does not contain mapped wetlands , but likely includes the headwaters of numerous small streams . Modifications to existing infrastructure components of the project may necessitate wetland impacts and should be determined as early in the process as possible to identify permit requirements . Modification to the barge landing should be limited to disturbance above the high tide line. A wetlands survey of all route alternatives will be required as part of wetland permitting , Reference: Environmental Screening and Permitting Plan, Alaska Renewables Little Mt. Susitna Wind Project Site Table 1. Summary of Potential Issues for Little Mt. Susitna Site Issue Risk Level Comments Recommendations High Medium Low but can be used in the avoidance and minimization of these impacts during design. Airports X Several airports occur in the greater project area: • Beluga (private airport)- 18 miles • Tyonek- 26 miles • Ted Steven Anchorage International- 36 miles • Elmendorf Air Force Base- 39 miles • Merrill Field- 40 miles Small planes for travel and recreation use the airspace in the project vicinity. Consultation with the Federal Aviation Administration (FAA) and Department of Defense (DOD) will be required after turbine locations are determined. Structures X A structure analysis has not been performed. There are no known structures within 2 miles of the turbine area . Perform a desktop structure analysis for the area within 2 miles of proposed turbines . No impacts anticipated. Reference: Environmental Screening and Permitting Plan, Alaska Renewables Little Mt. Susitna Wind Project Site Table 2: Alaska Renewables Little Mt. Susitna Site - Potential Natural Resource Studies and Anticipated Permits and Timeframes PROJECT TASK 2022 Jan Feb Mar Apr May Jun Jul Aug Sept Oct Nov Dec Project Planning Workplan and Agency Meetings1 Wildlife Surveys Avian Migration Studies Aerial Eagle nest Surveys2 Nocturnal Radar Surveys Acoustic Bat Surveys 3 Breeding Bird Surveys 4 Terrestrial surveys Wetlands and waters Cultural surveys Historic and Pre-Historic Survey Sound and flicker Survey5 Visual Survey6 Permits/Consultation SHPO Consultation ADF&G Fish Habitat Permit ADF&G Special Area Permit USACE 404 Permit7 Reference: Environmental Screening and Permitting Plan, Alaska Renewables Little Mt. Susitna Wind Project Site NOTES: 1. Agency involvement will be ongoing throughout the planning and permitting process. Anticipated agencies/other stakeholders involved include but are not limited to: ADEC, ADF&G, ADOT, CIRI, DOD, FAA, Native Village of Tyonek, NMFS, SHPO, USACE, USFWS, FNSB , ADNR. 2. The final USFWS Eagle Rule outlines 2 years of surveys, however we are assuming 1 survey in 2022 breeding season will be sufficient to identify nests and plan avoidance activities. This assumption will be validated during agency meetings. 3. Acoustic bat surveys may not be needed to address potential USFWS and ADF&G concerns. 4. ADF&G may indicate concern for nesting birds in wetland areas , which may require a breeding season investigation for occurrence of BCCs. This will be decided from outc ome of agency meetings. 5. Sound and flicker survey not anticipated given the remote nature of the projects. However, the findings of a dwelling surve y would help determine if a survey would be needed. 6. Visual survey would occur during leaf off and leaf on periods. Leaf on may not be needed but will but will be determined during agency consultation. 7. USACE Section 404 permit is likely unavoidable, given the new access road crosses the Lewis River. A USACE application will trigger a NEPA process that could extend the project schedule beyond what is shown depending on the level of environmental document (EA vs EIS). Assumes no changes below ordinary high tide line, thus no Section 10 permit from USACE. 8. Assumes Jan 1, 2025 in service date and 2 years of construction. 9. Assumes the following permits will be pursued by Alaska Renewables: FAA Form 7460-1 (Notice of Proposed Construction); Utility Permits; ADOT Utility ROW and letter of non-objection. 10. Does not include permits that would typically be obtained by the construction contractor such as APDES CGP coverage, ADNR Material Sales Agreement and Reclamation Plan, and ADEC Temporary Water Use Permits. 11. Assumes a tiered approach to avoid impacts to migratory birds and no take permits will be required. Reference: Environmental Screening and Permitting Plan, Alaska Renewables Little Mt. Susitna Wind Project Site GF #V GF " """"""""" """"" """"""""""""""" """""""""""""" """"" """"" """ " "" " " o o o o o o o o o o o oo Willow Apt Big Lake Apt Goose Bay Apt Ted Stevens AnchorageInternational Airport TrailRidge Apt Merrill Field Tyonek Apt Lake HoodStrip Beluga Apt 10 Mile Turbine Centroid Buffer o Airport GF Barge Landing #V Beluga Power Plant GF North Foreland Barge Dock "Turbine Location Existing Beluga Transmission Line Existing Road New Access New Transmission Line Lease Area 0 4 82Miles ¯ Figure 1 - Little Mt. SusitnaOverview GF #V GF " """"""""" """"" """"""""""""""" """""""""""""" """"" """"" """ " "" " " Susitna Tyonek 10 Mile Turbine Centroid Buffer GF Barge Landing #V Beluga Power Plant GF North Foreland Barge Dock "Turbine Location Existing Beluga Transmission Line Existing Road New Access New Transmission Line Lease Area Sustina Flats State Game Refuge Land Ownership Native Private or Municipal State State and Native 0 4 82Miles ¯ Figure 2 - Little Mt. SusitnaLand Ownership Sustina Flats State Game Refuge #V GF " """"""""" """"" """"""""""""""" """""""""""""" """"" """"" """ " "" " "TheodoreRive r Pi e rceCreek Granite Creek S usitnaRiver O ls onCreek Tala chulitnaRiverC h uitnaRiver ChuitnaRiver Wol ve r i n eCreekPrettyCreek T hreemile C re ekCoffeeCreek SusitnaRiver FishCreekAlexande rCreekBeluga River Ivan R iverLewisRiver GF Barge Landing #V Beluga Power Plant "Turbine Location Access Row Existing Beluga Transmission Line Existing Road New Access Road New Transmission Line Lease Area Yard Anadromous Stream NHD Flowline NWI Wetland Type Estuarine and Marine Deepwater Estuarine and Marine Wetland Freshwater Emergent Wetland Freshwater Forested/Shrub Wetland Freshwater Pond Lake Riverine 0 2 41Miles ¯ Figure 3 - Little Mt. SusitnaWetlands and Waters