HomeMy WebLinkAboutUtility-Scale Railbelt Wind Final Design and Permitting Project - Environmental Permitting Assistance Report for Little Mount Susitna & Shovel Creek 2022 - REF Grant 7015021Environmental Permitting Assistance for Two Proposed
Wind Energy Projects, Interior and Southcentral, Alaska
Prepared by:
ABR, Inc. —Environmental
P.O. Box 80410
Fairbanks, AK 99708
907-455-6777
Attm
Terry Schick
tschick@abrinc.com
907-344-6777 ext. 202
2 August 2022
Research & Services
Prepared for:
Alaska Renewables, LLC
Attm
Matt Perkins
matt@alaskarenewables.com
Andrew McDonnell
andrew@alaskarenewables.com
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Table of Contents
Introduction........................................................................................................................03
PermittingProcess................................................................................................................06
Estimated Timeline of Deliverables............................................................................................14
EstimatedCosts...................................................................................................................15
TeamQualifications..............................................................................................................16
PastPerformance..................................................................................................................18
KeyPersonnel.....................................................................................................................21
LiteratureCited...................................................................................................................24
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Introduction
ABR Inc. —Environmental Research & Services (ABR) has assembled a team of experienced Alaska -based
professional consulting companies that, as a group, will ensure that Alaska Renewables, LLC (AKR) receives the
environmental permits needed to construct the proposed Shovel Creek wind farm project in interior Alaska and
the Little Mount Susitna wind farm project in southcentral Alaska starting in 2024. The team is composed of
ABR who will act as prime contractor, cover all potential biological impact concerns, and coordinate permitting
with AKR and the subcontractors. Solstice Alaska Consulting, Inc. (Solstice) will assist with permitting and
project scoping. Cultural Resources Consultants LLC (CRC) will address cultural and archaeological resources
concerns and permitting. R&M Consultants, Inc. (R&M) will cover the required Phase 1 environmental site
assessments and land survey work. Boreal Environmental Services (Boreal) will address any noise, air quality,
and climate change concerns, and Resolution 3D LLC (Res3D) will provide viewshed analyses to support the
assessment of visual impacts of the projects, as needed.
Each of these companies has demonstrated experience with the challenges posed by environmental permitting
of industrial projects in Alaska, and specifically, wind power development. The key staff at these companies also
have a long track record of successful interactions with state and federal management agency personnel in the
process of supporting the permitting for numerous industrial and energy projects throughout Alaska. The
exception is Res3D, which is a new, innovative company that provides high -quality 3D simulations for viewshed
analyses.
The ABR team will start small and plan to address only those resources that are nearly certain to be of
concern to the public and the management agencies. We will work with AKR to minimize potential impacts as
much as possible in advance of the formal submission of permit applications. Similarly, we will work with AKR
to minimize the potential for triggering the National Environmental Policy Act (NEPA) process. The federal
nexuses that could trigger NEPA are:
1. federal lands in the project areas (current understanding is that all lands in both project areas are under
state ownership)
2. a federal funding source (currently no federal funding sources have been identified), and/or
3. the requirement for a federal permit.
A Section 404 Clean Water Act (CWA) permit application to the U.S. Army Corps of Engineers (USACE) could
trigger NEPA if substantial acreages of wetlands are found in the project areas. For these reasons, we have
prepared a separate proposal for AKR to develop a desktop planning -level wetland map, which will provide more
fine -scale information on the occurrence of wetlands in the project areas than is depicted on the publicly available
coarse -scale National Wetland Inventory (NWI) mapping. By minimizing the acreage of wetlands to be filled,
Solstice's extensive permitting experience with small projects in Alaska (see Team Qualifications, below)
indicates that the USACE may elect to prepare the required NEPA document in-house rather than asking AKR to
develop a formal Environmental Assessment (EA), for example, to be submitted along with the Section 404
permit application. This scenario seems likely because of high -elevation and well -drained terrain in the wind
farm project areas. The primary challenge will be developing access road alignments to minimize fill in wetlands.
For the two proposed AKR wind farm projects, our goal is to work closely with AKR and the engineering
design contractor for the project to minimize the impacts and maximize the electrical generation of the projects.
Overall, the ABR team is very excited to support these important renewable energy projects and to help make
some real progress in reducing the heavy carbon footprint of our state.
Why ABR?
Founded in 1976, ABR has studied biological resources and supported the permitting of industrial projects in
every ecosystem in Alaska, from marine waters, coastal mudflats and saltmarshes, to arctic tundra and alpine
rocky barrens. We have been directly involved in the successful permitting, construction, and operation of the
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biggest wind farms in Alaska. With the set of contractors assembled for this proposal, the ABR team brings
decades of experience in the permitting of energy and other industrial projects in Alaska and the lower 48 states,
and it does so with a group of 100% Alaska -based companies that are dedicated to improving the quality of life in
our great state.
Individually, with the exception of Res3D, each of the companies on the ABR team has between 20 and 55
years of experience with the environmental permitting of industrial projects in Alaska, including gathering
baseline data and studying potential impacts to support the permitting and NEPA processes. Res3D is a relatively
new company that contributes cutting -edge technology for viewshed analyses that can address stakeholder and
community concerns. ABR and Solstice will conduct the visual impact assessments for the AKR projects using
the materials provided by Res3D.
One of the key features of the ABR team is the strong experience with wind farm projects in both Alaska and
the lower 48 states. Solstice in particular has over 13 years of experience obtaining environmental approvals for
wind projects in Alaska and clearly understands the concerns that are likely to be brought up regarding the two
proposed AKR wind farms. ABR has been studying the wildlife impacts of wind farm projects in Alaska and the
lower 48 states since the mid-1990s and has developed ornithological radar techniques to track migrating birds
during low light and inclement weather conditions, when most collisions with wind turbines will occur. Using
local -scale information on the movements of birds derived from visual and radar sampling, ABR staff can make
recommendations on turbine siting and transmission line locations to minimize potential collision hazard. ABR
has also used acoustic sampling to study the potential for collisions with foraging bats. The field experience
studying wind projects that ABR brings to the table is unparalleled in Alaska and will be important when
discussing the potential biological impacts of the projects with management agencies, regardless of whether or not
migration studies are conducted specifically for these projects.
ABR staff also have long-standing working relationships with Solstice and R&M in particular and have
collaborated with both companies for over 15 years. For the AKR wind farm projects, Solstice brings a wealth of
experience in environmental permitting to the table, and R&M can provide a full suite of engineering design
services for the project. If selected for that role, the ABR team can work directly with AKR and R&M engineers
to design project infrastructure (roads, transmission lines, turbine and substation pads) to minimize or avoid
potential impacts to biological and cultural resources.
CRC has been studying cultural resources for development projects in Alaska and conducting permitting for
cultural resources under Section 106 of the National Historic Preservation Act (NHPA) and related state
permitting procedures for 45 years. CRC maintains positive relationships with staff at the Alaska Department of
Natural Resources (ADNR) Office of History and Archeology/State Historic Preservation Office (OHA/SHPO),
and will provide key services in securing cultural resources authorization for the proposed wind farms. The ABR
team also includes the well -respected firm, Boreal, to address noise, air quality (if needed), and climate change.
The key staff at Boreal have 20 to 30 years of experience addressing noise and air quality concerns and
successfully assisting industrial clients with state and federal permitting for those resources.
Overall, the ABR team has the expertise to address all the permitting needs that are expected to be important
for the two wind farm projects. If additional resources are brought up as concerns during agency and public
scoping meetings, we have relationships with other specialist groups in Alaska that can address any specific,
additional environmental issues, such as recreation and subsistence, surface water and groundwater,
socioeconomic impacts, and environmental justice.
Overview of Permitting Process and Timeline
Given the goal of starting operations at the end of 2024 at Shovel Creek and in 2025 at Little Mount Susitna,
the pre -permitting process for the AKR wind farm sites will begin in August 2022 with the preparation of a
desktop, planning -level wetland map for each project site. This will allow AKR, ABR, and the engineering design
contractor to plan access roads, turbine and substation pads, and transmission lines to avoid and minimize fill in
wetlands as much as possible. Similarly, an assessment of known locations of cultural resources and a landscape
model of the probability of cultural resources occurrence can be prepared now to help streamline the process of
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selecting which portions of the project areas should be surveyed for cultural/archaeological resources. With the
engineering contractor on board, advanced planning and siting of project infrastructure and coordination with the
environmental contractor team will avoid wetland areas and expected "hot spots" for cultural resources. It will be
critical for the project timeline to have near -final locations of project infrastructure by early spring 2023 so that
any necessary field surveys can be planned in advance of the subsequent snow -free season. This is especially
important for wetland and cultural resources field surveys, allowing us to limit the work to areas where project
development is expected to occur and realize significant cost savings. Similarly, for cost efficiency, the Phase 1
site assessment and land survey work should not be conducted until the infrastructure plans are near final. Prior to
setting plans for field surveys in 2023, it will also be necessary to secure any required land access permits. We do
not expect major hurdles in this regard for access to state lands, but a land -access assessment should also be made
in early spring 2023.
In fall 2022, before near -final engineering design plans are in place, it will be beneficial to start and/or
continue early -phase, pre -permitting discussions with the resource agencies to get important feedback on the
proposed wind projects. This should include discussions with the USACE regarding potential wetland impacts
(Section 404 of the CWA), the OIWSHPO regarding cultural resources (Section 106 of the NHPA), and the U.S.
Fish and Wildlife Service (USFWS) regarding potential impacts to migrating and breeding birds, protected under
the Migratory Bird Treaty Act (MBTA) and/or Bald and Golden Eagle Protection Act (BGEPA). These early
discussions will allow time to determine whether or not additional field surveys (e.g., bird migration studies)
should be conducted in 2023, that is, if the USFWS contends that existing data are insufficient to assess local
movements of birds in the project areas (see Permitting Process, below). It may also be prudent to initiate
discussions with the National Oceanic and Atmospheric Administration's National Marine Fisheries Service
(NMFS or NOAA Fisheries) regarding the increased vessel traffic expected in upper Cook Inlet for construction
of the Little Mount Susitna project and potential concerns over endangered Cook Inlet beluga whales.
Following compilation of the 2023 field survey data in late summer/fall 2023, the preparation of project
permit applications can be finalized with the goal of submitting applications by 31 December 2023. This leaves 6
months (to the end of June 2024) for permit consultations and the preparation of any requested mitigation plans
prior to the authorization of permits and the anticipated start of construction (at Shovel Creek) in mid -summer
2024.
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Permitting Process
Project Management
From 2012-2017, ABR served as one of several prime contractors for what was then the state's flagship
renewable energy project, the Susitna-Watana Hydroelectric Project. For the AKR wind farm projects, we would
take a similar project management approach as a prime contractor, coordinating permitting activities and
maintaining clear communication with AKR on technical progress and financial status. ABR's work on the
Susitna project was well received by Federal Energy Regulatory Commission (FERC) licensing participants,
many of whom were strongly opposed to the project, and we received praise from the Alaska Energy Authority
(AEA) for our technical and contracting administration work.
For the AKR projects, Terry Schick at ABR will serve as the permitting team Project Manager. Clear
communications between AKR and the project team will be key. After NTP, a project kick-off meeting with AKR
and the full ABR team will be conducted to ensure all team members are aware of task expectations and the
overall schedule. We will leverage remote collaboration tools and schedule check -in meetings with all team
members (frequency to be determined in consultation with AKR) to inform the team of updates in the project
plans or schedule and to allow all team members to raise questions and concerns. Monthly summaries of project
activities and cost accruals will be requested of all team members to track progress and costs, and this information
will be summarized and submitted to AKR monthly to aid their management of the projects.
Project Scoping
Prior to initiating formal scoping meetings, the permitting team, led by Solstice and ABR, would complete an
initial analysis to determine expected permit needs and data gaps. The effort would include querying and
compiling available information and informal discussions with agency personnel and other knowledgeable
persons. The results of this work would be a memorandum identifying data sources and limitations and expected
permitting requirements. Once the memo is completed, it will be distributed to agencies, including the Alaska
Departments of Fish and Game (ADFG) and Environmental Conservation (ADEC); ADNR;U.S. Fish and
Wildlife Service (USFWS; U.S. Army Corps of Engineers (USACE; National Marine Fisheries Service (NMFS;
the OHA/SHPO; and local boroughs and nearby community governments.
An agency scoping meeting would then be held to introduce the two projects, discuss data and permitting
needs identified in the above -mentioned memo, and gather additional information and comments. Agencies would
be given time to respond and provide input on project permitting needs following the meeting. Once agency input
is provided, a detailed task list and schedule would be developed to guide the subsequent data collection and
permitting effort. If needed, pending discussion with AKR, a public scoping meeting also could be scheduled to
acquire additional information on concerns regarding the project from interested parties.
Land Use and Zoning
Little Mount Susitna
Based on an initial search of the online ADNR Land Mapper database, it appears that AKR acquired a number
of leases from the ADNR to install temporary meteorological towers on state land for the Little Mount Susitna
Project. As AKR is well aware, for the wind farm to be constructed on state land, long-term leases would need to
be obtained from ADNR. Access roads sighted across state land and/or materials and equipment brought to the
site through state-owned tidelands (beach landings or temporary docks), would also require leases and easements
from the state through ADNR. Furthermore, if material (borrow) sites are needed, material site development
permits would be needed from ADNR, regardless of land ownership.
The proposed wind farm site is in the Matanuska-Susitna Borough (MSB) but not within a special -use or
residential land -use district. Borough land -use regulations require land -use variances if any project structures
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(wind turbines or buildings) are placed within 75 feet of a waterbody or watercourse. The application for a
variance includes a description of unusual conditions or circumstances for which the variance is sought and
information on how the deviation from requirements of the watercourse/water setback would be no more than is
necessary to enable a reasonable use of the property. Solstice staff would work with the MSB Planning and
Zoning Department to obtain variances, if any project components are planned within 75 feet of waterbodies.
Shovel Creek
Based on an initial query of the ADNR Land Mapper database, there are multiple land owners in the Shovel
Creek project area including University of Alaska Land Trust, Alaska Mental Health Land Trust, Fairbanks North
Star Borough (FNSB), and State of Alaska Lands. Long-term leases or easement (for roads or intertie) would be
needed from the applicable land owners. Project features sighted on state land would require leases and easements
from the state through ADNR. Material site development permits would be needed from ADNR, regardless of
land ownership.
The proposed Shovel Creek project is located in the FNSB. It is expected that the FNSB will support the
project because one of the actions listed in their Regional Comprehensive Plan (FNSB 2005) is to, "Encourage the
development and use of alternative energy sources including solar and wind energy."
Based on a review of FNSB zoning mapping, the proposed Shovel Creek wind farm would be located within a
General Use Zoning District. Solstice staff would work with the FNSB Community Planning Department to
identify intertie and access road routes that meet the needs of AKR and avoid any incompatible land uses. If
project components must be sited in a location that does not have a compatible land use, Solstice would work with
AKR to apply for a conditional -use permit, which would include a site plan and other requirements as stated in
FNSB Code 18.04.
Wetlands
Based on our preliminary aerial photo site review, the terrain in the two project areas, the complete avoidance
of wetland impacts or expected fill of < 0.5 acre (which could be covered under a nationwide wetland permit) is
unlikely. This is because access roads in particular will need to cross lower and more poorly drained areas which
are likely to be jurisdictional wetlands. As with the vast majority of industrial projects in Alaska, it is probable
that an individual Section 404 CWA wetland permit will be needed for each wind farm project, in this case for
access roads and possibly also for wind turbine pads and transmission line towers. If the project design limits
wetland fill to small amounts, however, the USACE may elect to prepare the federally required NEPA document
for each project in-house, which would help save project resources.
Once planning -level wetland maps and revised engineering design plans for the two project areas are
available and a preliminary estimate is made as to how much wetland acreage, if any, will need to be filled during
project construction, we recommend conducting pre -application meetings with the USACE, one in Fairbanks for
Shovel Creek and one in Anchorage for Little Mount Susitna. These meetings would be arranged to discuss with
USACE project managers the goals of the projects and the measures already taken during the design phase to
reduce wetland impacts. An important objective of the meetings will be to highlight the substantial benefits to the
state of implementing the proposed renewable energy projects. An advocate for each project at the USACE will
help substantially because that person will be making key decisions regarding whether or not an individual
wetland permit is needed, the level of NEPA documentation required, if any, and whether or not a mitigation plan
will be needed to offset wetland impacts.
Once the 30% engineering design plans are completed and the field -supported wetland delineations and
revised wetland maps for each site are finalized (targeting late summer/fall 2023), Solstice staff, with assistance
from AKR and ABR, will develop a wetland permit application for each proposed wind farm. These applications
will include required backup materials, including detailed design drawings prepared in accordance with USACE
guidance and material site plans, if appropriate. Documentation of other authorizations needed to be completed to
obtain the 404 permits will also be drafted, including findings under the Magnuson -Stevens Fishery Conservation
and Management Act (MSA; see Fish Habitat, below), the ESA, MBTA, and NHPA.
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If mitigation for unavoidable wetland impacts is required by the USACE, a detailed compensatory mitigation
plan will be prepared. Following USACE's guidance, the mitigation plan will document the type and amount of
mitigation planned through a wetland functional assessment and project debit/credit analysis. Compensatory
wetland mitigation in Alaska involves either paying an in -lieu fee to purchase wetland credits from an existing
wetland mitigation bank(s) or developing a permittee-responsible mitigation plan that can include restoration or
enhancement of degraded wetlands in the vicinity of a project. If a restoration or enhancement project is proposed,
a work plan will be prepared that provides site and construction information and plan drawings. All mitigation
will be planned in association with AKR and the USACE.
A Section 401 CWA Water Quality Certification (in Alaska acquired from the ADEC) will also be required
for the placement of fill in wetlands. Using ADEC's newly developed web -based portal, Solstice staff will prepare
and submit a Water Quality Certification Pre -Meeting Application with preliminary details on proposed fill in
waters of the U.S.
Wildlife
The statutes that will apply to wildlife for the AKR wind projects are the Migratory Bird Treaty Act (MBTA),
the Bald and Golden Eagle Protection Act (BGEPA), the Marine Mammal Protection Act (MMPA), and the
Endangered Species Act (ESA). The MMPA and ESA will only apply to possible disturbances to marine
mammals, especially Cook Inlet beluga whales, from possible increases in vessel traffic in Cook Inlet during
construction of the wind farms. In terrestrial habitats at the two project sites, no federally listed endangered,
threatened, or candidate wildlife species occur, and authorization under the ESA for work in terrestrial habitats
can be quickly accomplished with informal consultation under Section 7 of the ESA.
The important first step in obtaining authorization under these statutes is to initiate early informal discussions
of the project plans with the USFWS and NOAA Fisheries to gather information on their concerns regarding
wildlife. These discussions, some of which have already been started, can be conducted in 2022 in advance of
near -final engineering design plans. Our experience is that agency personnel truly appreciate these early -phase
discussions because they provide opportunities to work with the project proponent to minimize wildlife impacts.
These meetings can also facilitate the development of relationships with key agency staff and will allow AKR to
describe the importance of the projects for the state's energy portfolio as interest in fossil fuel exploration and
development continues to decline.
The next step will be to conduct a data -gap analysis to assess the amount and quality of existing information
on wildlife resources in the two wind farm project areas. This would be done as part of preparing the memo to be
delivered to the management agencies to initiate project scoping (see Project Scoping, above). In this analysis,
ABR would evaluate the available data for relevancy to the project in terms of both spatial and temporal
parameters. Key questions will be: (1) were the data collected in or near the project areas in similar habitats and
(2) how long ago were they collected? This information will help drive the process for authorizations from
USFWS under the MBTA and BGEPA, and from NMFS under the MMPA and ESA.
Avian Studies
If requested, ABR can develop studies to collect site -specific information on bird movements during
migration and breeding periods at the two project sites and conduct an assessment of collision hazard for birds
with the proposed wind turbines and transmission lines. ABR has nearly 30 years of experience modeling bird
collision hazards in Alaska, Hawaii, and the Lower 48. Importantly, we have conducted bird migration studies for
the Eva Creek wind farm in Interior Alaska and proposed developments near Beluga, Alaska. We have also
studied bird collisions with transmission lines for the Golden Valley Electric Association (GVEA) in interior
Alaska as part of their permitting requirements. With information on estimated collision hazard, we can work with
AKR and the USFWS to develop plans (e.g., turbine spacing and transmission line locations) to minimize these
potential impacts.
In the event that an eagle nest(s) may be affected by one or both projects, ABR can work with the USFWS to
obtain approvals for project activities under the BGEPA, which can include the removal of nest structures that can
be shown to be inactive. Given the higher elevation ridge crest and plateau topography and the expected low and
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dwarf vegetation in the two project areas, it is likely that neither tree -nesting Bald Eagles nor cliff -nesting Golden
Eagles breed in the vicinity of the proposed wind turbines. It will also be important to conduct all clearing of
vegetation in early spring or late summer/fall to avoid the destruction of bird nests during the breeding season and
stay in compliance with the MBTA.
Marine Mammals
Authorization from NOAA Fisheries for possible increases in vessel traffic in Cook Inlet or upgrades to the
barge landing at Beluga is likely to require only informal consultation, but the requirement of obtaining an
Incidental Harassment Authorization (IHA) for expected "takes" (disturbances) of marine mammals under the
MMPA and consultation under Section 7 of the ESA may be requested for possible takes of Cook Inlet beluga
whales. An early determination of the level of concern from NOAA Fisheries will be key to understanding how
much effort may be involved in obtaining authorization for shipping wind turbine components to the barge
landing site in upper Cook Inlet (for Little Mount Susitna). If needed, Solstice has 10 years of experience in
preparing applications for and successfully obtaining IHAs from NOAA Fisheries for Alaska projects. Both ABR
and Solstice are also well -versed in consultation under Section 7 of the ESA (with a combined 25 years of
experience; see Team Qualifications, below). If required, ABR and Solstice can collaborate on the preparation of a
Biological Assessment (BA) to describe the potential impacts to Cook Inlet beluga whales and work with NOAA
Fisheries through the consultation process to obtain the final Biological Opinion (BO) in which NOAA Fisheries
will determine whether or not increased vessel traffic will jeopardize the continued existence of Cook Inlet beluga
whales. If planned appropriately to avoid important seasonal events for beluga whales (e.g., calving and key
periods for foraging on adult salmon), it is unlikely that increased vessel traffic will result in a jeopardy opinion.
Fish Habitat
If it is determined that anadromous streams will need to be crossed by project access roads, the ABR
permitting team will work with AKR and the engineering design team to minimize any impacts to Essential Fish
Habitat (EFH). Similarly, for the Little Mount Susitna project, we will assess any proposed upgrades to the barge
landing site in upper Cook Inlet with respect to EFH in nearshore marine waters. In freshwater, EFH under the
MSA is effectively defined as those areas in which salmon of any life history stage are known to occur, whereas
EFH is more broadly defined for marine waters and in Alaska often includes areas in which commercially
harvested fish and crustaceans of various species occur. Data on the distribution of anadromous streams in Alaska
is available online in the ADFG Anadromous Waters Catalog and data on marine EFH in Alaska is available
online in the NOAA Fisheries EFH Mapper. The goal of the EFH work will be to avoid a determination of likely
adverse effects on EFH from the proposed construction and operation plans. As with possible concerns for marine
mammals noted above, we recommend early consultation with NMFS staff to discuss the project plans and likely
construction methods and to seek an opinion on whether an EFH Assessment will be necessary. If no adverse
effects on EFH are identified, an EFH Assessment is not required, but in our experience, most clients want the
assurance of NMFS concurrence on a no -adverse -effects determination. If an EFH Assessment is required, which
is likely only for Little Mount Susitna, ABR fish and aquatics staff will prepare the document and pursue
concurrence on the effects determination from the NMFS. This is a relatively simple process, but advance
planning will be needed to ensure enough time is available to roll the EFH information into the package of
materials that should accompany the Section 404 wetland permit application (see Wetlands, above).
A Fish Habitat Permit from ADFG will also be required for any road crossings of anadromous and/or resident
fish streams to ensure that fish passage (via culverts, for example) is maintained to meet the requirements of
Alaska Statute 16.05.841-871 (aka Title 16). As above, the ABR permitting team will first work with AKR and
the project design team to minimize any stream crossings. If needed, we will work with ADFG to develop Fish
Habitat Permit applications that detail stream crossings and culvert designs to accommodate fish species known to
occur in the waterbodies in question. If it is necessary to divert water around a stream crossing site during
construction, we will describe pumping or trenching methods and how fish will be captured and released back into
the stream after construction.
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Cultural Resources
Even though the AKR wind projects may not involve a federal undertaking subject to Section 106 of the
NHPA, the methodology of the cultural resources study will generally follow the Secretary of Interior's Standards
and Guidelines for Archaeology and Historic Preservation, which establishes a comprehensive approach to the
identification, evaluation, and management of historic properties. This includes:
• Conducting literature reviews to identify known cultural resources within project study areas
• Assisting in determining areas of potential effect (APE)
• Consulting with tribal groups, local entities, and state and federal agencies
• Conducting cultural resource field surveys
• Evaluating cultural resources to determine eligibility for inclusion in the National Register of Historic
Places
• Evaluating the effects of proposed projects on historic properties and making recommendations to avoid,
minimize, or mitigate adverse effects
• Implementing selected project effect measures
• Preparing reports and agreement documents
Cultural resources in the two project areas will be studied using a combination of literature review,
consultation, and field surveys. An archaeological and historical assessment of an agreed -upon APE will consist
of an initial desktop component followed by field surveys. The desktop effort will result in a summary of existing
information related to cultural resources present and their respective locations. This summary will be based both
upon existing documentation and consultation with state and federal agencies, tribal groups, and other interested
parties with cultural resource information. The desktop review will also include analysis of aerial imagery,
spherical videography, and LiDAR data, if available.
Section 106 of the NHPA requires federal agencies to consider the effects on historic properties of projects
they carry out, assist, fund, permit, license, or approve. If a federal or federally assisted project has the potential to
affect historic properties, a Section 106 review must take place. The lead federal agency (LFA) identifies who will
participate in the review. Consulting parties may include the Alaska SHPO, local governments, and interested
federally recognized tribes. Historic preservation organizations and others with an interest in the preservation
outcomes of the project or those with a legal or economic interest may also be invited to join consultation. The
LFA also plans how it will involve the public.
The LFA ensures that historic properties that could be affected by a project are identified and that there is
sufficient information to determine if any properties in the area that may be affected by the project are eligible for
listing in the National Register of Historic Places. The LFA determines how historic properties might be affected
by the project and whether any of those effects would be considered adverse; it does so in consultation with other
participants in the review. In the final step of the process, the LFA explores measures to avoid, minimize, or
mitigate adverse effects to historic properties and reach agreement with the SHPO on measures to resolve them.
The LFA's statutory obligations under NEPA and NHPA are independent, although the Section 106 review
must be completed prior to issuance of a federal decision (see Wetlands, above). Because the information
gathering and consultation done in the Section 106 review should inform the NEPA review, and vice versa, the
timing of both reviews should be coordinated.
The Alaska SHPO reviews projects under both Section 106 and the Alaska Historic Preservation Act (A.S.
41.35.070). The Alaska Historic Preservation Act requires a review of state public construction projects to
determine if historic, prehistoric, or archaeological sites may be adversely affected. A state Cultural Resource
Investigation Permit is required of any person or agency proposing to conduct cultural resource surveys on state
lands. Artifacts collected from state lands are primarily curated at the University of Alaska Museum of the North.
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Noise, Air Quality, and Climate Change
Noise
Noise analyses for NEPA compliance will include preparing noise assessments for project construction and
operations. The need for baseline noise monitoring, noise impact studies, and evaluating abatement technologies
would be identified case -by -case based on ongoing review of construction and operation plans. Additionally,
noise -sensitive locations would be identified for mitigation, as needed. Boreal has budgeted for collecting
representative pre -construction noise data at each project site.
Air Quality and Meteorology
If needed, air quality analyses for environmental permitting and NEPA compliance will include air quality
permit applicability analyses for construction or operations activities such as construction camps, rock crushers
(for access road materials), or possible permanent maintenance facilities. Required air quality permits would be
identified case -by -case based on ongoing review of construction and operation plans. Meteorological analyses for
NEPA compliance will include an assessment of existing meteorological conditions at the project sites based on
the available, representative meteorological data sets.
Climate Change
Climate change analyses for NEPA compliance will follow Council on Environmental Quality (CEQ)
guidance and include an evaluation of project effects on climate change (expected to be positive because of the
reductions in fossil fuel consumption!) and the potential effects that climate change would have on the project.
Recent agency findings on climate change in NEPA determinations will be reviewed for the latest policy trends.
An evaluation of design elements that would make the project resilient to climate change effects will be identified
case -by -case based on ongoing review of construction and operation plans.
FAA Obstruction Evaluation
Although the wind farms are proposed away from airports, if the proposed turbines are over 200 feet tall, an
obstruction Evaluation/Airport Airspace Analysis will be required to determine whether or not the wind farms will
have an impact to air navigation. In accordance with 14 CFR Part 77.9, Solstice staff will file Notices of Proposed
Construction or Alteration (FAA Form 7460-1) for each turbine electronically with the FAA. The applications
would detail the exact location, height above ground surface, ground surface elevation, and other design details.
Visual Impacts
Res3D will provide 3D digital viewshed image support for the two AKR wind farm projects so that
management agencies and the public can get a sense of how visible the projects will be from various vantage
points on the ground, including roadways and waterways. The graphic support will be in the form of
geographically referenced simulations of final constructed conditions based on the project data provided by AKR
and 3D renderings of topographic and vegetation conditions at each site using GIS data and high -resolution digital
elevation models (DEMs). Facilities models of each wind farm site will be developed from the AKR data and will
form the basis of each viewshed image. ABR and Solstice use the viewshed images and associated data (e.g.,
viewshed area calculations) to develop the visual impact sections in any required project NEPA documents for
each project.
Phase I Environmental Site Assessments
A Phase I Environmental Site Assessment will be prepared for both the Shovel Creek and Little Mount
Susitna wind farm project areas (herein referred to as the Subject Properties). R&M's Earth Sciences Department
consists of geologists, geotechnical engineers, and environmental specialists with a high level of technical
expertise and extensive experience evaluating environmental site conditions, as well as the regulations and
standards that drive a Phase I assessment. Phase I assessments for the Subject Properties will be prepared
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according to ASTM E 1527-21 or ASTM E 2247-16 to satisfy the all appropriate inquiries (AAI) rule of the
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA).
The Phase I assessment process is designed to support maintaining Landowner Liability Protection (LLP)
provisions of CERCLA by evaluating the Subject Property for recognized environmental conditions (REC)
resulting from past or current land use. R&M's assessment would begin with desktop research along with an aerial
overflight site visit of the Subject Properties, in accordance with ASTM procedures, followed by preparation of a
report of our findings. Desktop research includes review of regulatory databases and records, environmental liens,
activity and use limitations, physical setting sources (mapping and aerial photography), state and local agency
records (e.g., fire department, health department, city planning or development agencies, utilities), historical use
records, and conducting interviews. A User Questionnaire must be completed by the Phase I assessment "User"
(AKR) to the best of their knowledge for a Phase I assessment to be AAI compliant and to maintain LLP
provisions of CERCLA. To meet ASTM guidelines, records that are readily ascertainable within a reasonable time
or cost will be reviewed.
The project site visits will allow direct evaluation of potential RECs identified in the initial desktop research
by directly observing current environmental conditions of the Subject Properties. ASTM E 2247-16 provides
modifications to the site visit requirements of ASTM E1527-21 that significantly reduce the cost of site
reconnaissance by allowing assessment by aerial flyover, aerial imagery (if recent enough), or other systematic
means. This alternate method is authorized for rural or forestland sites with little to no development. A traditional
site reconnaissance on these large, remote properties would require 3 to 7 days of field time and daily helicopter
support for the Little Mount Susitna site. Instead, R&M plans to assess the sites using either an aerial flyover
using fixed wing/rotary aircraft or ordering custom -tasked aerial imagery, which has become affordable in the past
few years. A site reconnaissance includes visual assessment of existing structures and current land use to evaluate
evidence of the potential release of petroleum or other hazardous substances to soil or groundwater.
A Phase I assessment does not include invasive testing such as, but not limited to, drilling, test pitting, or
building material testing (asbestos or lead). Each Phase I assessment will include a discussion of the following:
• Research and site visit methodology
• Data gaps and failures (if applicable)
• Records review
• Interview with current users
• ERIS report for each Subject Property (includes Chain of Title and/or Lien Search, historical topographic
maps, and aerial photos)
• Site visit observations including photographs (if conducted)
• Assessment of potential environmental conditions
• Recommendations/findings.
A Phase I assessment typically takes approximately 30 days to meet ASTM specifications. However, the
schedule for these Phase I assessments will be largely driven by the approach to the site reconnaissance effort
(physical site visit versus utilizing aerial imagery or aerial flyover). Site reconnaissance should be conducted
during snow/ice-free conditions when the ground surface can best be observed. R&M has staff available to
conduct these Phase I assessments in Fall 2022, if notice to proceed is received promptly so that site
reconnaissance efforts can be arranged.
Land Surveying
R&M's Geomatics Department which includes Land Surveying, ROW Services, and GIS Services is widely
recognized as one of the deepest, most diversely talented surveying and mapping teams in Alaska. Over R&M's
53-year history of providing professional surveying and mapping services in Alaska, we have conducted every
conceivable type of surveying and mapping project, ranging from federal, state, and municipal surveys to
individual lot surveys in urban and rural areas. R&M has provided property surveys, geodetic and
photogrammetric control surveys, boundary surveys, topographic/planimetric surveys, as -built surveys, route
surveys, hydrographic surveys, and detailed conventional surface and subsurface surveys for thousands of acres.
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R&M understands that the project areas are located on state-owned lands and survey requirements are dictated
by the Alaska Department of Natural Resources (ADNR). Typically, if the state is involved, the ADNR's survey
group will issue very specific survey instructions which will define the scope, and the estimate of survey costs is
dependent on that scope document. For example, an ALTA/NSPS survey may not be required if a
post -construction survey is the only requirement. R&M proposes that our surveyors provide initial support to
AKR to identify (in coordination with ADNR) the appropriate survey requirements for the Shovel Creek and
Little Mount Susitna sites. After the initial coordination efforts with ADNR and AKR, R&M is currently available
to support design or as -built survey efforts starting in 2023. Actual timing of field work and submission of the
deliverable is dependent on the established scope of work and logistical constraints, if any.
N EPA Review
Given the accelerated timeline for permitting and constructing the proposed wind projects, a formal NEPA
review is not practicable. Hence, the ABR team has not assessed costs for a possible NEPA review. As noted
above, we will work with AKR to avoid NEPA triggers altogether, and if wetlands cannot be avoided, we will try
to ensure that the expected wetland fill amounts are quite small, thus rendering any federal Section 404 permits
insubstantial compared to other, more typical industrial development projects in Alaska. If a permittee-responsible
NEPA review is required by the USAGE, it will be important, for any cost estimate for that work, to know the
type of NEPA document required. NEPA review work clearly has the potential to extend the project schedule
substantially, but if it is required, that work can be added by amendment.
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Estimated Timeline of Deliverables
Task
Contractor(s)
Timeline
Public and Agency Scoping
Solstice, with input
from team
July 2022—February 2023
Land Use Permit Applications
Solstice
October 2023—March 2024
Wetland Desktop Mapping
ABR
August 2022
Required
Wetland Field Delineations and Reports
ABR
July 2023—September 2023
Permitting
Activities
Section 404 Wetland Permit
ABR and Solstice
October 2023—May 2024
Section 401 Water Quality Certificate
Solstice
October 2023—May 2024
FAA Obstruction Evaluation
Solstice
October 2023—January 2024
Phase I Environmental Report
R&M
12/31/2023
Land Survey
R&M
July 2023
EFH Consultation and Fish Habitat Permit
ABR and Solstice
September 2023—May 2024
NEPA Review
Full ABR team
if needed, TBD
State Historic Preservation Office
Consultation
CRC
August 2022—February 2024
Likely
Additional
Permitting
Historic/Archeological/Cultural Surveys and
Reports
CRC
August 2022—February 2024
US Fish and Wildlife Avian Consultation
ABR
August 2022—September 2023
Activities
NOAA Fisheries Marine Mammal
Consultation
ABR and Solstice
August 2022—September 2023
Marine Mammal Incidental Harassment
Authorization
Solstice
if needed, December
2022—May 2024
Raptor Surveys and Report
ABR
July 2023—September 2023
Possible
Bird Migration Surveys
ABR
April/May and
August/September 2023
Permitting
Support
Studies
Breeding Bird Surveys
ABR
May/June 2023
Acoustic Surveys for Bats
ABR
July 2023
Noise, Air Quality, and Climate Change
Boreal
January —December 2023
Visual Impacts Assessed with Simulation
Res3D
September —December 2022
PosRev N PA
Activities
Post -construction Mortality Monitoring (birds
and bats)
ABR
May —September 2025 and
2026
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Team Qualifications
Founded in 1976, ABR has been providing biological and ecological consulting services in Alaska for over 45
years. ABR provides expertise in wetlands and soil science, landscape ecology, ecological restoration, wildlife
science, fisheries and aquatics, marine biology, statistics, GIS mapping and remote sensing analysis, permitting
support, and environmental impact analysis (e.g., NEPA documentation). ABR has supported most of the major
mining and energy development initiatives in Alaska in recent years, including the Pebble and Chuitna Coal
projects on the west side of Cook Inlet, the Manh Choh mine in interior Alaska, the Susitna-Watana Hydroelectric
project, the Willow project on the North Slope, and numerous onshore and offshore projects for the oil and gas
industry. We have also provided support, primarily with wildlife and wetland concerns, for a number of wind farm
and transmission line projects in Alaska and the lower 48 states (e.g., Day et al. 2007, Mabee et al. 2016,
Schirmacher et al. 2016), including the Eva Creek and Fire Island wind projects in interior and southcentral
Alaska (Day et al. 2005, Shook et al. 2015). We understand the cost concerns for early phase industrial projects
and design our studies accordingly, with a focus on just those studies and data elements that will be needed most
during the subsequent permitting and NEPA processes.
Boreal Environmental Services
Boreal is an Alaskan -owned firm founded on the premise that sustainable operations in the Alaska utilities,
mining, oil & gas, and government service sectors benefit from a high quality, efficiently priced, and responsive
local service provider. Based in Anchorage, our founders are all long-time Alaskans with decades of experience
specializing in one of the most complex regulatory and political environments anywhere. Boreal was established
in December 2020; however, our staff's experience providing environmental permitting and regulatory
compliance support for Alaska projects extends for decades. Selected project experience includes the Chugach
Electric Association, Inc. Southcentral Power Project, the Oil Search (Alaska), LLC Pikka Project, the Kinross
Fort Knox Mine, the AGDC Alaska LNG Project, and various Hilcorp Alaska, LLC (and predecessors) Kenai,
Cook Inlet, and North Slope Assets. We develop custom teams specifically designed to meet project needs by
balancing expertise with cost efficiency while providing our broader network of staff engineers and scientists who
are on call to assist on projects as needed.
Cultural Resource Consultants
CRC has over 45 years of historic preservation experience in Alaska ranging from literature reviews and
quick field surveys of small project areas to multi -year projects involving complex Section 106 analyses. CRC
provides a wide range of cultural resource services. Much of our work involves assisting our clients in complying
with historic preservation laws, such as Section 106 of the National Historic Preservation Act and the National
Environmental Policy Act. CRC's senior staff includes Linda Finn Yarborough and Michael Yarborough, who
both meet the Secretary of the Interior's Professional Qualification Standards for anthropology.
R&M Consultants
R&M is a well -established professional services consulting firm with a 53-year history in Alaska and has been
involved in some of Alaska's most significant projects. Our firm is truly 100% committed to the state. We provide
professional services focused on improving quality of life and the infrastructure that makes a real difference in the
day-to-day lives of Alaskans. R&M provides innovative professional solutions —by Alaskans, for
Alaskans —through uncompromised quality and world class expertise. From offices in Anchorage, Fairbanks and
Juneau, R&M provides an array of services, including civil engineering, construction administration,
environmental services, geology, geotechnical engineering, GIS, hydrographic surveying, hydrologic and
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hydraulic engineering, land surveying, materials testing, planning, public involvement, remote sensing, right of
way services, special inspections, and structural engineering.
Resolution 3D
Res3D provides computer digital modeling, illustrations, animation, and interactive presentation support
services for heavy industries. We offer digital 3D immersive tools for meetings, for interdisciplinary discussion,
proposals, environmental impact statements, and community outreach. We assist with presentations to
stakeholders, board members, community groups, and all project disciplines to communicate the overall project
scope throughout the initial proposal stages and through the project's life -cycle. As part of our environmental
moldering services we provide full integration with GIS mapping, acquired point -cloud data, terrain modeling and
integration with proposed facilities in the 3D context. Res3D was founded in 2005 as a local Alaska resource for
high -end multimedia solutions for Alaska's A&E and resource development industries, and has since branched out
beyond the region and into adjacent industries needing to communicate project intent to stakeholders and
regulatory bodies. Res3D list of industry clients include, GE Measurement and Control, GE Oil & Gas, and GE
Power and Water, ABB Industrial Solutions, ConocoPhillips, Nabors Drilling, Donlin Gold, Pebble Limited
Partnership, and Torex Gold.
Solstice Alaska Consulting
Solstice is a is a 100% women -owned small business and DBE (#9900647) headquartered in midtown
Anchorage. Formed as Solstice Environmental Consulting in August 2008, Solstice incorporated in January 2010.
With eight environmental planners, biologists, and grant writers, Solstice provides services related to
environmental documents and permitting, public involvement, and grant assistance. Solstice has the expertise to
inform and gather public input in a cost-efficient manner and the experience to help secure project funding
through grants. They also have the knowledge, experience, and relationships with regulatory agencies to prepare
environmental documents and obtain environmental permits expeditiously.
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Past Performance
ABR: Susitna-Watana Hydroelectric Project (2012-2017)
From 2012-2017, ABR served as one of several prime contractors for what was then the state's flagship
renewable energy project, the Susitna-Watana Hydroelectric Project. This prime contracting work would be
similar to the environmental contractor role on the AKR wind farm projects. On the Susitna project, ABR and its
8 subcontractors worked for the Alaska Energy Authority (AEA) and were responsible for collecting baseline data
on wildlife, botanical resources (including wetlands), fish, instream flow, and groundwater hydrology, and we also
worked with AEA with the Federal Energy Regulatory Commission (FERC) licensing process. Terry Schick of
ABR was Project Manager for all 5 botanical studies and served as lead on 2 wildlife studies. Wendy Davis of
ABR led the wetland study for the project. Solstice, as one of the ABR subcontractors, managed all of the
complex land -access permitting for the project. ABR's work on the Susitna project was well received by FERC
licensing participants, many of whom were strongly opposed to the project, and we received praise from AEA for
our technical and prime contracting administration work (references available upon request).
ABR: Post -construction Avian and Bat Mortality Monitoring for the Eva Creek Wind
Project (2013)
As part of a USFWS programmatic eagle take permit, and due to concerns about avian and bat mortality
caused by collisions with wind turbines, ABR conducted post -construction mortality monitoring at the Eva Creek
Wind Energy Project for GVEA. Studies included surveys for birds and bats that had collided with turbines or the
meteorological tower and bias experiments that estimated the number of carcasses not found due to searcher
efficiency and removal of carcasses by scavengers. Additional studies and a comprehensive final report were
produced in 2014.
ABR: Environmental Support for Pre -Construction Studies of the Eva Creek Wind
Project (2011)
ABR conducted bird studies including raptor studies, as well as wetland mapping and analyses in preparation
for filing necessary permits and opening discussions with state and federal agencies on environmental concerns of
the proposed Eva Creek Wind Project. ABR also provided additional support for other wildlife questions and
concerns during the NEPA process (EA development).
ABR: Avian Studies near the proposed GVEA Wind Turbine Site at Eva Creek (2010)
ABR conducted field work at Eva Creek as part of Phase 2 avian studies in spring of 2010. Radar, night vision
equipment, and visual survey techniques were used to determine the species, abundance, flight characteristics, and
seasonal patterns of bird migration near proposed wind turbine strings. In addition, mortality searches were
conducted around existing meteorological stations.
ABR: Wetland Delineation for the Eva Creek Wind Project (2010-2011)
A wetland delineation and wetland map were prepared for two subalpine ridge sites and supporting access
road, man -camp, and substation for the Eva Creek Wind Project on the GVEA northern intertie. The wetlands
map and accompanying acreage calculations were used to support a pre -construction notice to the U.S. Army
Corps of Engineers for a Nationwide Permit 12.
ABR: Avian Studies near the proposed GVEA Wind Turbine Site at Eva Creek (2009)
ABR conducted work at Eva Creek as part of Phase 1 avian studies in fall/winter of 2009 in two parts. For
part 1, we conducted a reconnaissance -level site visit near the proposed wind farm and identified gaps in our
knowledge, aiding in the design of avian -assessment studies planned for 2010 (Phase 2, monitoring bird
migration). For part 2 of Phase 1, we synthesized existing information on avian migration and studies for the area
using information from the reconnaissance visit and existing information, to design Phase 2 studies.
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ABR: Avian support for Fire Island Wind Project (2008-2009)
ABR provided advice and technical support on avian issues as they related to permit requirements and
technical needs of the environmental assessment team. Technical support included review, interpretation, and
additional analyses of previous ABR work on Fire Island, including the development and implementation of field
projects, identification of mitigation strategies, and development of post -construction mortality monitoring
programs.
ABR: Monitoring Nesting Bald Eagles on Fire Island During Clearing (2004-2005, 2009)
ABR monitored Bald Eagle nests for potential disturbance during clearing activities that occured for the wind
farm on Fire Island, Alaska. Clearing activities were in compliance with the Migratory Bird Treaty Act (MBTA)
and the Bald and Golden Eagle Protection Act (BGEPA). ABR also provided advice and technical support on
raptor issues as they relate to permit requirements and technical needs of the environmental assessment team.
ABR: Aerial Surveys for Bald Eagles on Fire Island (2004-2005, 2009)
ABR conducted aerial surveys to identify and determine status of known and new Bald Eagle nests on Fire
Island. One survey was conducted in February to relocate known nests and get precise GPS coordinates for nests.
A second survey was conducted in May to establish current nest and territory status. ABR also provided advice
and technical support on raptor issues as they relate to permit requirements and technical needs of the
environmental assessment team.
Boreal: Alaska LNG Project — FERC Resource Report 9 (2014-2019)
Prepared RR9, the pre-NEPA document for Air Quality and Noise Impacts, for a $50+ billion project
including an 800-mile pipeline from Prudhoe Bay to the Kenai Peninsula and relocation of a section of the Kenai
Spur Highway. Collected ambient air and meteorological data in multiple locations, coordinated detailed
emissions evaluation, air modeling studies, dust mitigation plans, noise data collection and modeling, climate
change, extensive impact assessment negotiations with NPS and USFWS, comprehensive mitigation, and
post -construction monitoring plans for air quality and noise.
Boreal: Peak Gold, LLC — Manh Choh Air Quality and Climate Change NEPA Services
(2018-present)
Designed, installed, and now operating a meteorological monitoring station in support of the Peak Gold Manh
Choh project in support of air quality NEPA compliance and permitting. Prepared pre-NEPA meteorology, air
quality, and climate change impact analyses. Obtained complex regulatory siting and ADEC approval of
PSD-quality meteorological data. Continuing to collect data and providing air permitting and compliance support.
Solstice: Bethel Wind Project
Solstice Alaska Consulting, Inc. (Solstice) helped Alaska Village Electric Cooperative (AVEC) secure grant
funding from the U.S. Department of Energy (DOE) and the Alaska Energy Authority (AEA) to install a Emergya
Wind Technologies (EWT) Direct Wind 50-meter, 900 kW wind turbine in Bethel, Alaska. Solstice prepared the
National Environmental Policy Act (NEPA) document for the project which focused on impacts to wetlands,
noise -sensitive receivers, and the visual landscape. Solstice worked with other consultants to obtain a wetlands
delineation and prepare visual models. Solstice prepared the applications for and obtained the U.S. Army Corps of
Engineers (USACE) section 404 (wetlands) permit and the Federal Aviation Administration's (FAA) No Hazard
to Air Navigation finding. To comply with the City of Bethel's land use regulations, Solstice prepared the
application for a tall structure permit, which involved holding two public meetings and working directly with the
planning director and commission. The project was approved and the wind turbine was constructed.
Solstice: Stebbins/St. Michael Wind Farm and Intertie
Solstice prepared successful grant applications to USDA Rural Development (RD), Community Development
Block Grant (CDBG), DOE, and AEA to secure funding to purchase, install and energize an EWT DW 900 kW
turbine with a 75-meter tower and 52-meter rotor and an 8-mile-long intertie to serve the communities of Stebbins
and Saint Michael in northwest Alaska. Solstice prepared separate NEPA documents following DOE, RUS, and
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CDBG/HUD environmental guidelines. The documents focused on impacts to wetlands (an USACE permit was
required), air navigation (consultation with FAA resulted in a Hazard to Air Navigation with Conditions),
endangered species (for eider species and polar bears), floodplains, and cultural resources. Solstice also planned
and facilitated public meetings to meet the requirements of funding agencies. The intertie and wind turbine were
constructed.
Solstice: St. Mary's/Mountain Village Wind Farm and Intertie
Solstice secured funding through USDA RD, CDBG, DOE and AEA to secure funding to plan, design,
purchase, install and energize an EWT DW 900 kW turbine with a 75-meter tower and 52-meter rotor and a
26-mile-long intertie to serve the communities of Saint Mary's, Mountain Village, and Pitka's Point in western
Alaska. Solstice then prepared separate environmental documents to meet the requirements of NEPA and the
federal funding agencies. The environmental documents focused on wetlands and cultural resources. Solstice also
secured a Section 404 permit from the USACE for the placement of the turbine pads and intertie within wetlands.
Solstice organized and facilitated numerous meetings in the communities to build support and meeting funding
agencies' requirements. This project was constructed in 2018.
Solstice: Emmonak Wind Farm
Solstice obtained grant funding from AEA for AVEC to plan, design, and construct six Northwind 100 B
model wind turbines (600 kW capacity) and a 26-mile electric intertie between Emmonak and Alakanuk, Alaska.
Solstice applied for and obtained an USACE section 404 permit for construction of the intertie and turbine pads in
wetlands, which involved developing a statement of purpose and need and alternatives and assessing impacts to
wetlands and other resources. The project was constructed in 2010 and remains successful.
Solstice: Mekoryuk Wind Farm
Solstice wrote the successful AEA grant application to secure funding for AVEC to plan, design, and
construct two Northwind 100 B model wind turbines (200 kW capacity) to serve Mekoryuk, Alaska. Once
funding was received, Solstice consulted with the U.S. Fish and Wildlife Service to determine the best location for
the turbines and Endangered Species Act -listed and other migratory birds. Solstice prepared and obtained the
Section 404 permit from the USACE for the turbine access road and two turbine pads.
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Key Personnel
Terry Schick, Ph.D., Director of Business Development and Senior Scientist, ABR
Terry will serve as the Project Manager for ABR and will oversee all the environmental permitting, any
focused field studies, and any required NEPA work for the wind farm projects. He holds a B.S. in Zoology and a
Ph.D. in Plant Ecology, and he is equally versed in wildlife and botanical concerns for development projects in
Alaska. He has 31 years of field experience and has been managing multidisciplinary projects in Alaska for 24
years. He served as one of two ABR Project Managers for AEA on the highly controversial, multiyear
Susitna-Watana Hydroelectric Project. His background managing work on contentious industrial and
transportation projects, including Pebble, Chuitna Coal Project, King Cove —Cold Bay Road and others,
demonstrates how he will successfully coordinate work on the AKR wind projects. His focus is on the evaluation
of impacts to wildlife, habitats, wetlands, and vegetation from proposed industrial developments, and he brings
over 10 years of experience with formal biological impact assessments for NEPA projects in Alaska. Terry
maintains good working relationships with industry and management agency representatives and has a reputation
for bringing disparate parties to consensus.
Wendy Davis, M.Sc., PWS, Senior Scientist, ABR
Wendy will serve as ABR Project Manager for the wetland and vegetation mapping for the Shovel Creek and
Little Mount Susitna projects, will coordinate as well as participate in the mapping, and will provide senior -level
quality control of the final map products. She has worked in wetlands and landscape sciences at ABR for 18 years,
with experience all over Alaska. She is currently the lead scientist for the wetland program and oversees all
wetland work at ABR. Wendy is a Professional Wetland Scientist (PWS), trained in wetland delineation, wetland
permitting and policy, and current NEPA procedures. Wendy provided the wetland delineation to support the
wetland permitting for the Eva Creek wind farm in 2010 and managed the wetland field program, study plan and
reporting for a 500,000-acre mapping area for the Susitna-Watana Hydroelectric project. Each wetland project is
unique, and Wendy works with each client to optimize the data collection to provide useful products and timely
consultation during the permitting phase. She has extensive experience in advising clients on the level of effort
that may be required to obtain necessary wetland permits.
Adrian Gall, Ph.D., President and Senior Scientist, ABR
Adrian will serve as the lead for assessing agency concerns and possible study development for birds and
marine mammals for the wind farm projects.She is a Senior Scientist with over 20 years of experience conducting
avian and marine mammal studies in Alaska, Hawai'i, Washington, Oregon, California, and Mexico. She holds an
M.S. degree in Wildlife Science from Oregon State University and a Ph.D. in Biological Oceanography from the
University of Alaska Fairbanks. She has collaborated with the Alaska Village Electric Cooperative and the North
Slope Borough to assess and reduce wildlife hazards associated with wind power in rural Alaska communities.
She has extensive experience writing Biological Assessments to support Section 7 consultations with federal
agencies and conducting radar and audiovisual surveys of migratory bird populations for the purpose of
conducting collision analyses. In addition to fieldwork and data analysis, Adrian collaborates with federal, state,
and tribal agencies, and non -governmental organizations, to design protocols for monitoring population trends and
the breeding ecology of seabirds. She organizes and participates in community outreach and education activities
to promote local involvement in ecological monitoring programs.
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Boreal Environmental Services
Brian Hoefler, P.E., (Anchorage)
Brian will serve as Boreal Project Manager and lead the climate change analysis. Mr. Hoefler has over 30
years of broad experience in NEPA documentation, environmental permitting, regulatory compliance, noise
studies, utility planning, and siting studies. His recent project experience includes senior advisor for climate
change analyses for the Oil Search (Alaska), LLC Pikka Project and Peak Gold, LLC Manh Choh Project and
noise and air quality studies prepared for the Kinross Fort Knox Mine and the AGDC Alaska LNG Project. He
had a key role in the NEPA process for the Alaska LNG Project supporting extensive dialogue and negotiations
with FLMs across Alaska, including the NPS at Denali National Park, regarding air quality and noise impacts.
Isaac Bertschi, Ph.D., (Anchorage)
Isaac will lead the noise, air quality, and meteorology analyses. Dr. Bertschi is the Air Quality Team Lead for
Boreal with over 20 years of experience in ambient air and meteorological monitoring, air permitting, noise
monitoring and modeling studies, and NEPA compliance. His project experience includes meteorological data
collection and air permitting for the Oil Search (Alaska), LLC Pikka Project and Peak Gold, LLC Manh Choh
Project, and AQ and noise studies for Parks Highway MP 44-52, Foothills West Transportation Access Study and
Kenai Spur Road relocation.
Cultural Resource Consultants
Linda Finn Yarborough, Ph.D., Cultural Resource Specialist
Linda received her Master of Arts degree in Anthropology from University of Toronto in 1973 and her Ph.D.
in Anthropology from the University of Wisconsin -Madison in 2000. She established CRC in 1975 and worked as
an archaeological and anthropological consultant throughout the state until 1991. In 1989, Dr. Yarborough began
working as an archaeologist for the Chugach National Forest on projects involving both historic and prehistoric
cultural resources. She accepted the Forest Archaeologist position in 2000 and continued to work for the Forest
through July 2008, when she returned to consulting with CRC. Dr. Yarborough has a thorough understanding of
cultural resource laws and regulations. She also has an excellent working knowledge of the historical and
archaeological literature available for Alaska and is experienced in working with state and federal agencies. Dr.
Yarborough has experience surveying for and monitoring historic properties, devising mitigation for historic
properties, and preparing Programmatic Agreements and Memoranda of Agreement.
Michael Yarborough, M.A., Senior Archeologist
Michael has a Master of Arts degree in Anthropology from the University of Toronto and 47 years of
prehistoric and historic archeological experience in Alaska. He has worked in all areas of the state and began
working in Alaska in 1974. Prior to joining CRC in 1981, he conducted archeological surveys and excavations
along the Alyeska Pipeline for the University of Alaska and worked as an archaeologist for the U.S. Fish and
Wildlife Service's Alaska Regional Office. During the time he has been a consultant, he has worked on over 150
cultural resource projects throughout the Cultural Resource Consultants LLC 2 June 2022 state.
R&M Consultants
Chris Fell, CPG, Environmental Geologist
Chris is an environmental and engineering geologist with more than 15 years of consulting experience and is
R&M's technical expert on contaminated site investigation and remediation. His skills include Phase I and II
Environmental Site Assessments, assessing the potential to encounter contamination, geotechnical investigations,
environmental construction oversight and monitoring, and coordinating with the Alaska Department of
Environmental Conservation and Environmental Protection Agency. He has conducted Phase I ESAs at remote
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locations throughout Alaska. Chris holds a B.S. in Geology from the University of Wisconsin -Eau Claire. He is a
Certified Professional Geologist in Alaska and through the American Institute of Professional Geologists.
AJ Griffin, PLS, Senior Land Surveyor
AJ has 22 years of diverse survey experience, including 18 years in Alaska. He is proficient in field and office
work and is experienced at taking a project from field -to -finish. AJ enjoys research, field work, computations and
producing final deliverables. He uses both conventional and GPS surveying methods, and is experienced with GIS
data and software, giving him the ability to work between CAD and GIS to meet client needs. AJ is experienced
in developing horizontal and vertical control networks, geodetic control and aerial photo control surveys;
boundary and cadastral surveys; topographic and bathymetric mapping; right of way surveys; ALTA surveys;
FEMA flood insurance surveys; FAA 150/5300 surveys; quantity surveys; and all aspects of construction layout
and computations. He has performed design surveys in remote locations throughout Alaska and is uniquely
qualified to execute the field survey and design mapping tasks associated with this project. AJ holds a B.A. in
Geography from the University of Montana. He is an FAA Part 107 Certified Pilot.
Solstice Alaska Consulting
Robin Reich, President and Senior Environmental Planner & Project Manager, Solstice
Robin, president and founder of Solstice Alaska Consulting, Inc., has 25 years of environmental permitting
experience in Alaska and over 13 years of experience obtaining environmental approvals for wind projects in the
state. Robin has a degree in biology from Humboldt State University. She started her professional career
completing wetlands delineations, fisheries surveys, Phase 1 contaminated site assessments, and other field -based
environmental studies. She then moved on to preparing National Environmental Policy Act (NEPA) documents,
Essential Fish Habitat assessments, and Biological Assessments, and obtaining environmental permits. She has
obtained numerous Clean Water Act Section 404 permits; Alaska Department of Fish and Game Fish Habitat
permits, Federal Aviation Administration No Hazard to Air Navigation approvals; borough and city land use and
zoning approvals; and other environmental and land use approvals for wind projects. Robin has also led grant
writing efforts to obtain over $50 million for the planning, design, and construction of wind projects. In addition,
Robin has led efforts to educate and involve the public, stakeholders, and agencies in wind farm development to
help gather input and build consensus. In short, Robin understands wind farm and electric intertie designs and
construction methods and how to secure funding, obtain authorizations, and build public and agency support for
them. Robin grew up in Bethel, Alaska and currently lives in Anchorage.
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Literature Cited
Day, R. H., R. J. Ritchie, J. R. Rose, and G. V. Frost. 2005. Bird migration near Fire Island, Cook Inlet, Alaska,
spring and fall 2004. Unpublished report for Chugach Electric Association, Inc., Anchorage, AK, by ABR,
Inc. —Environmental Research & Services, Fairbanks, AK. 128 pp.
Day, R.H., A.K. Prichard, L.B. Attanas, J.E. Shook, and B.A. Anderson. 2007. Mortality of birds at powerlines: a
guide for studies in northern Alaska. Unpublished report prepared for BP Exploration (Alaska), Inc.,
Anchorage, AK, by ABR Inc., Environmental Research and Services, Fairbanks, AK. 136 pp.
Fairbanks North Star Borough (FNSB). 2005. Regional Comprehensive Plan. Adopted in September 2005.
Available online at: https://fnsb.gov/DocumentCenter/View/900/Regional-Comprehensive-Plan-PDF.
Mabee, T.J., A.K. Prichard, and J.E. Shook. 2016. Post -construction monitoring at the Three-mile Canyon Wind
Project, 2015-2016. Report prepared for Exelon Generation —Wind and Solar, West Des Moines, IA, by ABR,
Inc. —Environmental Research & Services, Fairbanks, AK. 26 pp.
Schirmacher, M. R., A. Prichard, T. Mabee, and C. D. Hein. 2016. Evaluating a Novel Approach to Optimize
Operational Minimization to Reduce Bat Fatalities at the Pinnacle Wind Farm, Mineral County, West Virginia,
2015. An annual report submitted to NRG Energy and the Bats and Wind Energy Cooperative. Bat
Conservation International, Austin, Texas, USA.
Shook, J.E., J.P. Parrett, and A.K. Prichard. 2015. Post -construction mortality monitoring at the Eva Creek wind
energy project, 2013-2014. Final report prepared for Golden Valley Electric Associations, Fairbanks, AK, by
ABR, Inc., Fairbanks, AK. 30 pp.
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