Dear Commissioners:

I serve on the Board for North State Climate Action (NSCA), a group of volunteers in California’s far North State region. Our mission is to promote solutions addressing the climate crisis through education, collaboration, and action in our communities. To avoid increasingly dire effects of climate change, including drought, deadly heat waves and worsening fires, we must cease reliance on fossil fuels as quickly as possible, and replace it with carbon free energy, such as wind power. Wind power has the advantages of limiting climate change, improving air quality, and significantly reducing water demands that fossil fuel power creates. Additionally, wind power technology is still evolving, and future projects may be able to provide environmental mitigations not available today. Please consider the following comments as you evaluate Zone Amendment 22-0001. Ordinance changes proposed in the amendment prohibit all “large” wind power projects in the unincorporated county regardless of specific project details. Don’t propose enactment of a blanket prohibition on a viable, clean, and renewable power source in Shasta County.

Wildfire potential may be the most contentious issue for siting wind farms. We have arranged our comments to address fire concerns first. Then we discuss each of the impacts that were determined to be significant but unavoidable in the Fountain Wind project, as those issues will be similar in any future wind power proposal. We then discuss the general plan objectives addressed by staff in their report.

Wildfire

The Fountain Wind Environmental Impact Report (EIR) deemed fire risk less than significant with proposed mitigations. Similar or additional mitigation would be implemented for any new proposed project. Enhanced fire suppression techniques during construction, operation, and decommissioning could be considered for future proposals, such as:

· Greater fuel free buffer zones surrounding roads and towers.

· Enhanced maintenance for wind tower mechanical, electrical and fire suppression equipment.

· Enhanced maintenance of transmission lines including those off site.

· Burying transmission lines.

· Curtailment of turbines during extreme fire conditions.

· Additional removal of flammable debris along off-site roadsides. This was proposed in the Fountain Wind project, but the scope was apparently not considered adequate by the Supervisors.

· Changes in construction materials. In the Hatchet Mountain project, turbine nacelles were constructed of steel, instead of fiber glass, providing enhanced fire protection.

Also note that the access roads and site work in any wind farm project will provide fire breaks, aiding fire suppression, as noted in the Fountain Wind EIR and by Cal Fire.

The wind turbines at Hatchet Mountain have never experienced a fire, and they have been in operation for 12 years. It’s estimated by a wind trade organization that a wind tower has only a 1/2000 to 1/15,000 chance of a fire per year. This review estimated chances of fire to be even lower. These estimates include data from many older towers without cutting edge technology, such as automatic nacelle fire suppression.

A major concern expressed by the public, commissioners, and supervisors regarding the Fountain Wind project was the difficulty of aerial firefighting near the turbines, and that’s a valid issue. As indicated by Bret Gouvea with CAL FIRE at the October 26 Board of Supervisors meeting, although the difficulty of fire suppression adjacent to a wind tower is an important consideration, these types of decisions are part of the hazards considered in any firefighting plan. Mr. Gouvea also noted that all firefighting situations are unique. CAL FIRE could have spoken against the Fountain Wind project as proposed but did not do so. Additionally, the specific layout of wind towers in a project is important in any analysis of aerial firefighting potential. For example, a linear layout of towers like the Hatchet Mountain project would likely simplify aerial firefighting.

With all the mitigation discussed above, the risk of destructive fires is substantially reduced. The risk is not eliminated, which is impossible, but substantially reduced. In accordance with the EIR for Fountain Wind, fire impacts were reduced to less than significant with mitigation (as noted, mitigation could be enhanced in future projects), and planning staff concurred with that analysis.

Evaluation of wind project benefits should consider that the potential loss of life from wind power during its construction and operational life is significantly less than from fossil fuel power. One source indicates that the number of deaths from fossil fuel power generation (due to fuel extraction, transport, refining, construction, distribution, and operation) is almost 150 times that of wind power. In accordance with that information, for a project like Fountain Wind, there is a 50% chance of one death over a 40-year operation period, versus the potential of 69 deaths from fossil fuel power (primarily due to air pollution). Potential deaths from wildfires sparked by wind power would increase the chance of wind farm deaths to a degree, but it’s very unlikely to be comparable to fossil fuel power mortality. It’s clear that fossil fuel power kills.

Most of the County is in a high or very high potential fire area according to Figure FS-1 of the General Plan (currently outdated according to staff). All construction activities, as well as human occupation in those areas, have the potential to ignite fires. That, however, has not led to considering a prohibition of construction of homes and other buildings anywhere in Shasta County. That risk is accepted. If that type of building can continue, why not wind farms with appropriate mitigations? Additionally, since figure FS-1 of the general plan is not current, and the county is working on updating it, these ordinance changes are premature. Also note that Figure FS-1, although outdated, contains limited areas not considered either high or very high fire risk.

Biological Resources

There is no doubt that wind towers cause bird and bat mortality. Wind projects should be sited properly and be required to minimize bird and other wildlife losses. Impacts to biological resources were thoroughly discussed in the Fountain Wind EIR, and any proposed wind farm project would require the same process. Note that climate change presents a much greater potential for individual and species loss than wind farms. According to the United Nations, climate change may contribute to the extinction of 20–30 percent of all species. According to the Audubon Society, “If climate change continues apace, hundreds of North American bird species' ranges will shrink by at least half by 2100.”

Both the Audubon Society and the American Bird Conservancy support properly sited wind power. State and Federal departments of Fish and Wildlife made no comments on the final Fountain Wind EIR. Future wind projects could be further constrained to provide additional protection for birds and bats, as well as other wildlife. Some promising methods for additional bird fatality reduction include painting of towers, or even painting one blade of the turbine black, and use of radar to detect approaching flocks, so turbines can be temporarily shut down. One objection raised against Fountain Wind was the adequacy of the post-construction bird mortality monitoring. That objection could be overcome by expanding such monitoring beyond the 3 years proposed in that project, perhaps for the life of a project. Studies have also been performed using dogs to better spot birds killed in tower collisions. Compensatory mitigation is another option to preserve bird populations. This mitigation could consist of earmarking land not on the wind farm proper as increased habitat for species of concern, or a project to minimize bird mortality from other causes, such as power transmission that is not a part of the proposed project. Lastly, Fountain Wind proposed that individual turbines could be removed if they were shown to cause unacceptable bird mortality. Such a condition could, and should, be included in any future wind farm proposal.

The issue of wildlife protection in wind projects also must be compared to wildlife impacts from fossil fuel power generation that wind can replace. One study estimated that fossil fuel power resulted in the loss of 10-15 times as many birds as wind power, on a per kilowatt-hour basis. This mortality data included older wind farms, which are more likely to cause bird kill than newer towers.

Aesthetics

Aesthetics tends to be a bit subjective, so we are not going into this issue in detail. It should be noted, however, that wildfires exacerbated by climate change will continue to severely impact the beautiful view sheds of the county.

Cultural and Tribal Resources

Like other comments above, it’s not possible to discuss this issue in detail until there is a project to analyze. Any project in Shasta County could impinge on Native American concerns and cultural resources, but that is not a given. Any necessary mitigation must be site specific.

Additional mitigations regarding this issue were proposed for Fountain Wind after the Planning Commission hearing, including providing access to areas the tribes considered significant to their cultural and religious practices. That same approach, or others, could be investigated if relevant to a new project.

Air Pollution

The EIR found that impacts from PM10 emissions were significant and unavoidable but recommended that the Planning commission adopt a statement of overriding considerations to allow the project. Future proposed wind farms would likely have similar issues, but the scope of those issues would depend on the size, location, and other specifics of the project.

Compliance with General Plan Objectives as noted in the Staff Report

Following are the General Plan Objectives that were discussed in the staff report and thoughts on how those objectives do not necessarily preclude the construction of wind farms in the county.

Objective FS-1 Protect development from wild land and non-wild land fires by requiring new development projects to incorporate effective site and building design measures commensurate with level of potential risk presented by such a hazard and by discouraging and/or preventing development from locating in high-risk fire hazard areas.

The county can fulfill this objective by requiring appropriate mitigations specific to each wind project. It’s not possible to adequately analyze a project for fire danger, or even whether it is in a very high fire danger zone, until there is a project to consider and fire hazard zones have been updated by the county. Note the objective does not propose a blanket ban on all projects in high fire danger zones in the county, and the benefits of wind power should be considered in fulfilling this objective. And, as noted above, there is no current consideration of preventing development except for wind farms.

Objective SH-1 Protection of the natural scenery along the official scenic highways of Shasta County from new development which would diminish the aesthetic value of the scenic corridor.

The entire county is not a scenic highway. There are many potential wind project areas adequately distant from the County’s designated scenic highways to eliminate wind towers from their view shed. Prohibiting wind farms in the entire County due to aesthetic considerations of scenic highways is overkill. The commission may consider prohibiting wind farms within a prescribed distance of scenic highways, but that determination should again be evaluated taking into account the benefits of wind power. As also noted above, if the risk of wildfires due to relentless temperature increases from climate change continues, the scenic resources along these highways are likely to burn, eliminating a major portion of their scenic value.

Objective CO-3 To guide development in a pattern that will respect the natural resource values of County lands and their contributions to the County's economic base.

Harvesting of the wind resources of the county, which will contribute substantially to the county’s economy, while helping to reduce greenhouse gases and minimize climate change exacerbated wildfires (which degrade the aesthetic resources of the county with acrid smoke and burned timberland), seems to be a good fit for this objective. The Hatchet Mountain project has economically benefited the county, as noted by former Supervisor Moty at the 26 October 2021 Board of Supervisors meeting, and future wind projects could bring similar benefits.

Objective CO-4 To guide development in a pattern that will minimize land use conflicts between adjacent land users.

We can certainly see that placing wind towers at a location where they would dominate the landscape of adjacent property owners could create a conflict. But these potential conflicts must be weighed along with the potential benefits of a wind farm to everyone in the county.

In conclusion, power generated with wind energy benefits everyone in the county, including indigenous populations, due to its mitigation of climate change’s deleterious effects, reduction of air pollution and decreased water use. Even if a proposed wind project has significant impacts, impacts and benefits should be considered on a site-specific basis to assess whether its benefits override those impacts.

Please do not recommend a blanket prohibition on wind farms in the county.

Thank you for the work you do and the opportunity to comment on these proposed ordinance changes.

Ron Dykstra
Board Member
North State Climate Action