CRESCENT PEAK WIND PROJECT PLAN OF DEVELOPMENT …

Crescent Peak Renewables Plan of Development – Second Draft

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CRESCENT PEAK WIND PROJECT PLAN OF DEVELOPMENT

SECOND DRAFT

Prepared by:

Crescent Peak Renewables, LLC A wholly-owned subsidiary of Eolus North America, Inc,. 7486 La Jolla Boulevard, Suite 276 La Jolla, California 92037

November 27, 2017


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CONTENTS

1 PROJECT DESCRIPTION .......................................................................................................... 1

1.1 INTRODUCTION ........................................................................................................................ 1

1.2 PURPOSE AND NEED ............................................................................................................. 10 1.2.1 Air Quality ............................................................................................................................ 10 1.2.2 Greenhouse Gas Emissions .................................................................................................. 11 1.2.3 Wind Energy and Water Conservation ................................................................................. 14 1.2.4 Regional Electricity Demand ................................................................................................ 15 1.2.5 Wind Energy Provides Hedge Against Fossil Fuel Price Volatility ..................................... 16 1.2.6 Cost of Energy ...................................................................................................................... 17 1.2.7 Business Supports Renewable Energy .................................................................................. 19 1.2.8 Wind Power Provides Economic Benefits ............................................................................ 21 1.2.9 Legislation in Support of Renewable Energy ....................................................................... 21 1.2.10 Local Area Economic Benefits ........................................................................................... 22

1.3 GENERAL FACILITY DESCRIPTION, DESIGN, AND OPERATION ................................. 23 1.3.1 Project Location, Land Ownership, and Jurisdiction ........................................................ 23 1.3.2 Legal Land Description of Facility ................................................................................... 23 1.3.3 Total Acreage and General Dimensions of All Facilities and Components ..................... 24 1.3.4 Number and Size of Wind Turbine Generators ................................................................ 25 1.3.5 Access Roads .................................................................................................................... 26 1.3.6 Overhead Transmission Lines, Collection, and Communications Systems ...................... 28 1.3.7 Ancillary Facilities ............................................................................................................ 30 1.3.8 Temporary Construction Workspace, Yards, Staging/Laydown Areas ............................ 30 1.3.9 Water Usage, Amounts, and Sources ................................................................................ 30 1.3.10 Erosion Control and Storm Water Drainage ..................................................................... 31 1.3.11 Vegetation Treatment, Weed Management, and Any Proposed Use of Herbicides ......... 32 1.3.12 Waste and Hazardous Materials Management .................................................................. 32 1.3.13 Fire Protection ................................................................................................................... 33 1.3.14 Proposed Site Security and Fencing ................................................................................. 34 1.3.15 Helicopter Use and Refueling ........................................................................................... 34 1.3.16 Health and Safety Program ............................................................................................... 34

1.4 OTHER FEDERAL, STATE, AND LOCAL AGENCY PERMIT REQUIREMENTS ........... 35

1.5 FINANCIAL AND TECHNICAL CAPABILITY OF APPLICANT ........................................ 37 1.5.1 Profile and Experience ...................................................................................................... 37 1.5.2 Financing .......................................................................................................................... 38

2 CONSTRUCTION OF FACILITIES ........................................................................................ 39

2.1 WIND TURBINE DESIGN, LAYOUT, INSTALLATION, AND CONSTRUCTION PROCESSES .............................................................................................................................. 39

2.2 POTENTIAL GEOTECHNICAL STUDIES ............................................................................. 40

2.3 PROJECT CONSTRUCTION SCHEDULE .............................................................................. 40

2.4 ACCESS AND TRANSPORTATION SYSTEM, COMPONENT DELIVERY, AND WORKER ACCESS ................................................................................................................... 41

2.4.1 Primary Access to the Site ................................................................................................ 41 2.4.2 On-Site Access System ..................................................................................................... 41 2.4.3 Component Delivery and Construction Circulation .......................................................... 42


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2.5 CONSTRUCTION WORK FORCE NUMBERS, VEHICLES, EQUIPMENT, AND TIMEFRAMES .......................................................................................................................... 44

2.6 SITE PREPARATION, SURVEYING, AND STAKING ......................................................... 44

2.7 GRAVEL, AGGREGATE, CONCRETE NEEDS AND SOURCES ........................................ 45

2.8 WIND TURBINE ASSEMBLY AND CONSTRUCTION ....................................................... 45

2.9 ELECTRICAL CONSTRUCTION ACTIVITIES ..................................................................... 48 2.9.1 Trenching and Installation of Underground Electrical and Communication Cables ........ 48 2.9.2 Bus Work and Electrical Line Connections ...................................................................... 48 2.9.3 Communication of the Project Substations ....................................................................... 49 2.9.4 Construction of the Project Substation ............................................................................. 49 2.9.5 Construction of the Overhead Transmission Line and Switching/Interconnection

Structure ............................................................................................................................ 49 2.9.6 Grounding ......................................................................................................................... 49

2.10 AVIATION LIGHTING ........................................................................................................... 50

2.11 SITE STABILIZATION, PROTECTION, AND RECLAMATION PRACTICES ................... 51

3 RELATED FACILITIES AND SYSTEMS ............................................................................... 52

3.1 TRANSMISSION SYSTEM INTERCONNECT ...................................................................... 52 3.1.1 Existing and Proposed Transmission System ................................................................... 52 3.1.2 Substations ........................................................................................................................ 52 3.1.3 Status of Power Purchase Agreements ............................................................................. 53 3.1.4 Status of Interconnect Agreement ..................................................................................... 53

3.2 METEOROLOGICAL TOWERS .............................................................................................. 53

3.3 OTHER RELATED SYSTEMS ................................................................................................. 54

4 OPERATIONS AND MAINTENANCE .................................................................................... 55

4.1 OPERATIONS AND FACILITY MAINTENANCE NEEDS .................................................. 55

4.2 MAINTENANCE ACTIVITIES ................................................................................................ 55

4.3 OPERATIONS WORKFORCE, EQUIPMENT, AND GROUND TRANSPORTATION ....... 56

5 ENVIRONMENTAL CONSIDERATIONS .............................................................................. 58

5.1 GENERAL DESCRIPTION OF SITE CHARACTERISTICS AND POTENTIAL ENVIRONMENTAL ISSUES ................................................................................................... 58

5.1.1 Site NV-1 .......................................................................................................................... 60 5.1.2 Site NV-2 .......................................................................................................................... 60 5.1.3 Site NV-3 .......................................................................................................................... 61 5.1.4 Site NV-4 .......................................................................................................................... 61

5.2 RESOURCES OF CONCERN ................................................................................................... 61 5.2.1 Biological Resources ........................................................................................................ 61 5.2.2 Cultural Resources ............................................................................................................ 66 5.2.3 Visual Resources ............................................................................................................... 66

5.3 DESIGN CRITERIA PROPOSED BY APPLICANT AND INCLUDED IN POD .................. 67 5.3.1 Facility Commitments ....................................................................................................... 68 5.3.2 Construction, Operation, and Decommissioning Commitments....................................... 68 5.3.3 Resource Conservation Measures ..................................................................................... 69

6 LITERATURE CITED ................................................................................................................. 1


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Appendix A. Legal Description


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Figures Figure 2-4. Cross sections and plans for typical road sections representative of BLM resource

roads. (Source: USDI and USDA 2007: Figure 3) ........................................................................... 43

Figure 2-2. Typical WTG pad, crane pad/rotor assembly area. ................................................................. 46

Figure 2-3. Typical WTG obstruction lighting. ......................................................................................... 50

Tables Table 1–1–4 Legal Description Acreages by Project Component ............................................................ 24

Table 1-5. Project Area’s Temporary and Permanent Length and Width by Project Component on BLM Managed Public Lands ............................................................................................................ 24

Table 1-6. Project Area’s Temporary and Permanent Disturbance Acreages by Project Component on BLM Managed Public Lands ....................................................................................................... 25

Table 1-7. Authorizations Table ................................................................................................................. 36

Table 2-1. Project Construction Schedule .................................................................................................. 41

Table 2-2. Construction Manpower and Equipment .................................................................................. 44

Table 5-1. Resources Analyzed .................................................................................................................. 58

Table 5-1. Resources Analyzed (Continued) ............................................................................................. 59

Table 5-1. Resources Analyzed (Continued) ............................................................................................. 59

Table 5-2. Sensitive Species with potential to occur in the Project Area. .................................................. 62


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LIST OF ACRONYMS

APLIC Avian Power Line Interaction Committee BBCS Bird and Bat Conservation Strategy BGEPA Bald and Golden Eagle Protection Act BLM Bureau of Land Management BMP best management practice CAISO California Independent Systems Operator CCRFCD Clark County Regional Flood Control District CFR Code of Federal Regulations CPR Crescent Peak Renewables, LLC CWA Clean Water Act DOE U.S. Department of Energy ECP Eagle Conservation Plan EIA Energy Information Administration EIS environmental impact statement EPA U.S. Environmental Protection Agency ESA Endangered Species Act FAA Federal Aviation Administration FEMA Federal Emergency Management Agency FLPMA Federal Land Policy and Management Act FR Federal Register GIS geographic information system HMMP Hazardous Materials Management Plan HSEP Health, Safety and Environmental Plan kV kilovolt(s) km kilometer(s)

m meter(s)

MBTA Migratory Bird Treaty Act MET meteorological (tower) MW megawatt(s) N/A not applicable NAC Nevada Administrative Code NDEP Nevada Division of Environmental Protection NDOW Nevada Department of Wildlife NEPA National Environmental Policy Act NHPA National Historic Preservation Act NNHP Nevada Natural Heritage Program NPDES National Pollutant Discharge Elimination System NRHP National Register of Historic Places


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NRS Nevada Revised Statutes O&M operations and maintenance P&H Patrick and Henderson Inc. PEIS Programmatic Environmental Impact Statement PL Public Law POD Plan of Development PPA Power Purchase Agreement Project Crescent Peak Wind Project RMP Resource Management Plan ROD Record of Decision ROW right-of-way RPS Renewable Portfolio Standard SCADA supervisory control and data acquisition SCE Southern California Edison SHPO State Historic Preservation Office SPCC Spill Prevention Control and Countermeasures SWCA SWCA Environmental Consultants SWPPP Storm Water Pollution Prevention Plan USC United States Code USDA U.S. Department of Agriculture USDI U.S. Department of the Interior USFWS U.S. Fish and Wildlife Service VRM Visual Resource Management WTG wind turbine generator


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1 PROJECT DESCRIPTION

1.1 Introduction

Crescent Peak Renewables, LLC (CPR), a wholly owned subsidiary of Eolus North America, Inc., proposes to construct, operate, and maintain a 175- to 500-megawatt (MW) wind generation facility on a portion of approximately 28,785 acres in the Crescent Peak Wind project area (Figure 1-1). The Crescent Peak wind energy facility consists of the construction, operation, and decommissioning of wind turbine generators (WTGs) and associated facilities necessary to successfully generate up to 500 MW on four sites west of the town of Searchlight in Clark County, Nevada (herein called the Crescent Peak Wind Project or the Project).

The Project would be located mainly on Bureau of Land Management (BLM) lands, and would be administered from the BLM’s Las Vegas Field Office. CPR has a queue position in CAISO Cluster 9 and is working with the California Independent Systems Operator (CAISO) on plans for interconnection and delivery of energy into the CAISO system and with NV-Energy on plans for interconnection and delivery of energy into the Nevada market. The proposed Crescent Peak Wind Project includes:

up to 248 WTGs that would be erected on tubular monopole towers supported on concrete foundations. Each WTG would have a maximum generating capacity between 1.5 and 4.5 MW (expected range being 2.1 to 4.2 MW);

for each WTG, there would be an adjacent, or nacelle-mounted, step-up transformer that would increase the voltage of the electricity from 570–1,000 volts to approximately 34.5 kilovolts (kV);

an approximately 34.5-kV electric collection system, primarily located underground;

access roads;

operations and maintenance (O&M) facility;

up to five on-site electrical collection substations owned and operated by CPR and associated control facilities to increase the voltage of the electricity to a level between 66 kV and 500 kV for transmission and one Project interconnection substation (Project Substation) owned and operated by CPR or a local utility for interconnection with the area transmission grid;

an overhead transmission line to transmit the 66 kV to 500 kV (most likely 230 kV) electricity from the collection substations to a Project Substation at an interconnection point named Bob near the existing Eldorado substation for connection with the Gridliance West TransCo 230-kV transmission system approximately 22 miles north northeast of the project area ;

staging areas, laydown yards, and batch plant areas; and

up to 20 permanent meteorological (MET) towers.

This Plan of Development (POD) is a required component of the BLM’s Type III right-of-way (ROW) grant application form SF-299 and describes how the Project would be built, operated, and decommissioned in a manner consistent with the requirements of the BLM. The POD will continue to be refined during the BLM evaluation of the application, including the National Environmental Policy Act (NEPA) review process, and would be finalized for inclusion as part of the grant.

The proposed schedule for the Project (including anticipated timelines for permitting, construction and operation is:

Finished Draft Environmental Impact Statement (EIS) – December 2018


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Final EIS – April 2019

Record of Decision (ROD) and Type III ROW Grant issued by BLM – May 2019

Notice to Proceed issued by BLM – June 2019

Site NV-1 start of construction – Q3 2019


Site NV-3 start of construction – 20Q4 2019



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Figure 1-1 Crescent Peak project areas.


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Figure 1-2 Crescent Peak proposed transmission path.


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Figure 1-3 CPR turbine layout.


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Figure 1-4 CPR site NV-1 detail.


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Figure 1-5. CPR site NV-2 detail.


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1.2 Purpose and Need

1.2.1 Air Quality Air quality is important to everyone. The American Lung Association studies air quality in the US, and their most recent study, the State of the Air 2017, collected data on air pollution from the years 2013, 2014 and 2015. Clark county, Nevada received an “F” grade for totaling 64 Orange Days and one Red Day over the three-year study period. Washoe county also received an” F” grade, with 18 Orange Days reported during the study period. There are two major types of air pollution: particulate and ozone. Particulates are very small bits of matter, solid particles and liquid droplets that float around in the earth’s atmosphere. They are the main cause of reduced visibility (haze). Particulates sometimes drift for long distances, can be inhaled or settle on the ground or water. Breathing in either type of pollution, particulate matter and ozone, can have damaging effects on your heart and lungs. This is especially true for children whose lungs are still developing, people with lung diseases, and older adults. (www.airnow.gov, accessed August 7th, 2017.) Ozone is a molecule that consists of three oxygen atoms. In general, the upper atmosphere ozone layer (10 to 30 miles above the earth’s surface) is created naturally, and is beneficial to the environment by filtering out ultraviolet radiation. This is sometimes called “Good Ozone.” Ozone at ground level, however, is a major pollutant. PowerScorecard.org is a group dedicated to help consumers assess the environmental impact of different types of electrical generation. According to PowerScorecard, “Ozone is not emitted directly into the environment. It is produced by a complex chemical reaction when nitrogen oxides (NOx) and volatile organic compounds (VOCs) react in the presence of sunlight. NOx is produced when cars and trucks, electric power plants and industrial processes burn fossil fuels. VOC's are unstable and easily-evaporated organic compounds present in vehicle exhaust, paint fumes, and industrial process waste. The interaction between these two chemicals create ozone pollution, the primary harmful ingredient in urban smog.” “Weather conditions are critical to ozone formation, which is greatest during the summer, when long hours of sunlight and high temperatures speed the photochemical reactions that produce ozone. These chemical reactions take place while the pollutants are being blown through the air by wind. What this means is that ozone pollution can be far more severe many miles away from the original power plant site that generates the NOx precursors. As a result, tall smokestacks that emit NOx can contribute to air pollution build-up in downwind states located hundreds of miles away.” Figure 1 shows the average ozone concentrations for the summer season in the US. Much of the state of Nevada has elevated levels of ozone pollution, especially Las Vegas.


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Figure 1-8. Ozone concentration map. Las Vegas has a high level of summertime average ozone concentrations. Clark County received and “F” grade from the American Lung Association for ozone pollution and a “D” grade for particulates. Reno/Carson City area gets a ‘B” grade for ozone pollution, but suffers from higher particulate pollution, getting an “F” grade for the study period of 2013, 2014 and 2015. (American lung association, State of the Air 2017, www.lung.org, accessed August 8, 2017.) Nevada’s population will assuredly gain significant health benefits from adopting more wind power production in the region. This is also true for its air polluting neighbor, California. It is evident that ozone and particulate pollution are real health threats in the southwest. It is in everyone’s best interest to reduce air pollution, and wind power is a proven clean energy source. Wind power is also one of the lowest-cost forms of generation to add to the electrical grid.

1.2.2 Greenhouse Gas Emissions Carbon dioxide is a major greenhouse gas and is the main driver of climate change according to research by the Union of Concerned Scientists. The chemistry of greenhouse gases and their effect on the atmosphere is a complex area of study, but there is very reputable scientific evidence that the amount of carbon dioxide in our earth’s atmosphere has increased dramatically over the last 100 years. “Antarctic ice core records vividly illustrate that atmospheric CO2 levels today are higher than levels recorded over the past 800,000 years (see Figure 2).”


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Atmospheric CO2 levels rose 40 percent between 1750 and 2011. (In 2013, atmospheric CO2 levels surpassed 400 million parts per million for the first time in human history.) Half of human-related CO2 emissions occurred only in the last 40 years. CO2 (and other gases emitted from industrial and agricultural sources) trap heat in the atmosphere, so it is no surprise that we are now witnessing an increase in global average temperature.” (www.ucsusa.org, “Why does CO2 get most of the attention when there are so many other heat-trapping gases?” last revised date: August 3, 2017.) Historically, the electrical power sector was the largest contributor to greenhouse gas emissions, since a large portion of electrical generation was from coal-fired power plants. The energy generation mix has changed significantly over the last decade, as natural gas, wind and solar plants are brought on-line and more expensive coal plants are retired.

Figure 1-10. The Electrical Power industry is the sector leader in reduction of carbon dioxide emissions.


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The majority of new power plants constructed over the last decade have been wind and natural gas plants. This trend, driven by the low cost of energy, ample natural gas supply, and energy policy has resulted in a very positive impact on carbon emissions from the power industry, as shown in figure 3.

Utility-scale wind power has become an important technology for new generation capacity added to the generation mix. Wind is the second largest producer in the renewable generation mix in comparison to hydro power, and is forecast to out-produce hydro power for the first time in history in the next year or so, as new wind power plants are brought online. Wind generators produce no greenhouse gases like carbon dioxide, nitrous oxide or other emissions which help create ground level ozone pollution.

Figure 1-11 Coal-fired emissions are on the decline and natural gas emissions are on the rise as natural gas and renewables replace costlier and polluting coal plants. Petroleum emissions bottomed in 2012 but are on the rise.


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1.2.3 Wind Energy and Water Conservation Water consumption for natural gas fired and other thermoelectric power plants (including geothermal) is significantly reduced when displaced by wind energy. “The electricity sector is second only to agriculture in water use within the United States.” (‘‘USGS: Thermoelectric Power Water Use in the United States’’ 2014) Thermal power plants include natural gas plants, nuclear plants, coal and geothermal plants. Water use in power plants is divided into two categories, water withdrawn, and water consumed. Water withdrawn is the volume of water pumped from surface water and wells for cooling. Water consumption is water lost to steam in the cooling process and is not returned to the source. Common measures of water use are gallons-per-megawatt-hour, or gallons-per-day. Water withdrawn is recycled in the system and immediately returned to the source after use. Plant cooling systems often return the water to the source, such as a rivers and lakes, at an elevated temperature, which can have a negative effect on fish populations. According to a study released in 2015 by the Desert Research Institute, in Nevada, thermoelectric power plants, “withdraw an average of 33 billion gallons of operational water per year and consume approximately 6.3 billion gallons of operational water per year. Thermoelectric generating units use approximately 115 gallons of water per MWh per year on average.” Even hydropower consumes a vast amount of water for energy production. “According to the United States Geological Survey, hydroelectric power plants consume 18 gallons of water for every kilowatt-hour that they produce – more than 30 times their thermoelectric power counterparts.” This equates to 18,000 gallons of water per megawatt hour.

Figure 1-12 The initial period of utility scale wind energy began in the 1980’s, but the real growth of wind power began around 2002. Wind energy production continues grow because of a competitive cost of energy, technology efficiency gains, and supportive energy.


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The following is an example of the water savings when comparing a 100MW combined-cycle gas plant versus a 100MW wind plant. If both plants ran at a 30% capacity factor for one year, both plants would produce a nominal 262,800 Megawatt-hours of electricity (100MW x 8760 hours per year x .3 capacity factor). In the production of this electricity, the natural gas plant will consume an estimated 30,222,000 gallons of water, mostly lost through evaporation in the cooling process (262,800 MWh x 115 gallons per MWh). The wind plant will consume an estimated 50,000 gallons in that same year for use in watering the roads and supporting the operations and maintenance of the facility. The wind plant will consume approximately one tenth of one percent (0.1%) of the water consumed by the gas combined cycle plant. Other than water used for construction of roads and concrete foundations, the only water consumption by wind power is that which is used in support of operations and maintenance activities, such and washing equipment and watering roads, and of course site personnel at the operations and maintenance facility.

Figure 1.13 American Wind Energy Association data for 2016 estimates wind power saves 86.8 billion gallons per year of water in the US.

1.2.4 Regional Electricity Demand Both Nevada and California are net energy importers. Both states rely on power produced in other states. According to the US Energy Information Administration, in 2016, “About 90% of the energy Nevada consumes comes from outside the state. California now imports 33% of its electricity supply from fast growing neighbors, with about 65% of that coming from the Southwest and 35% coming from the Northwest. In 2010, California “only” imported 25% of its power.” Clemete, Jude. California's Growing Imported Electricity Problem, www.forbes.com, April 3,2016. Nevada generated 73% of its electricity from natural gas plants. Only one wind plant is currently operational in Nevada, and produces 0.8% of Nevada’s generation. There is exciting potential to add more wind power plants to Nevada’s power generation mix.


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1.2.5 Wind Energy Provides Hedge Against Fossil Fuel Price Volatility Over the past 20 years, fossil fuel market prices have experienced very high volatility. The cause of the volatility is generally attributed to supply and demand, low price elasticity, and to some degree, speculation in the energy futures markets. These rapid swings in fuel costs have

a serious effect on our economy. “Sharp, rapid swings in the price of oil have outsize effects on companies, economies, and global geopolitics. Oil price spikes can stunt economic growth, for example, and a sudden price plunge can wreak havoc on cash-strapped oil companies. For countries, an oil price roller coaster can blow a hole in government budgets, prompt wholesale economic reform, or alter geopolitical priorities seemingly overnight.” (Greenberg Center for Geoeconomic Studies, “Oil Price Volatility: Causes, Effects and Policy Implications,” June 13, 2016.)

Figure 1.14 Natural gas and oil prices since 1995. (US Energy Information Administration, 2016.


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According to one economist, there is evidence that the suggests the oil price run-up to the great recession of 2009 was quite possibly the trigger event to the collapse of the housing market bubble, which lead to the recession. “…the evidence to me is persuasive that, if there had there been no oil shock, we would have described the U.S. economy in 2007:Q4-2008:Q3 as growing slowly, but not in a recession.” (Hamilton, Dr. James D., Causes and consequences of the Oil Shock of 2007-8*, Department of Economics, UC San Diego, February 3, 2009, revised April 27, 2009. 70 pp.) Since wind power has no fuel costs, the presence of wind energy in the production mix is a natural hedge against fuel price variability, because it often directly offsets natural gas fired generation. It also reduces water use as described in the previous section.

1.2.6 Cost of Energy Lazard did an analysis of the levelized cost of energy from conventional and renewable generation sources. According to their research, in the period from 2009 to 2016, the unsubsidized levelized cost of energy for wind power decreased 66%. The primary reasons for the declining cost of energy are from decreased cost of components, and efficiency gains in the technology. In the Lazard high end analysis, thin film solar is the cheapest form of new energy, at $56/MWh, followed by crystalline utility scale solar at $61/MWh. Utility scale wind energy came in third at $62/MWh. In both the high end and low-end analyses, utility scale wind and solar were less expensive than natural gas combined cycle plants. (Lazard Levelized Cost of Energy Analysis, Version 10.0, December 2016, 21 pages.)

Figure 1-15 United States Natural gas prices and recessions over the last 15 years. (US Energy Information Administration, 2016.)


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The Energy Information Administration also performed cost of energy analysis for new power plants, which considers the avoided cost of energy (levelized avoided cost of energy, or LACE). Avoided costs are those costs associated with more expensive forms of energy, such a nuclear and coal. In this analysis, higher numbers are better. Wind energy was again the least-cost *new energy source and benefits the energy market the most by avoiding and displacing more expensive forms of energy production. (US Department of Energy, Energy Information Administration, Levelized Cost and Levelized Avoided cost of New Generation Resources in the US accessed August 2017.)

Table 1–1 According to the EIA, wind power is the lowest cost alternative for new power plants installed in 2019.


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Table 1–2 In the LCOE - LACE analysis, larger numbers are better. Inexpensive renewable energy sources Solar power and Wind power are nearly even, and Geothermal shows the most “avoided cost” for power plants entering service in 2022.

1.2.7 Business Supports Renewable Energy “It’s imperative that businesses take an active role in meeting the goals set out by the Paris Climate Agreement,” said Anna Walker, Senior Director of Global Policy and Advocacy at Levi Strauss & Co. “It will be critical that we work together to ensure the U.S. maintains its climate leadership, ultimately ensuring our nation’s long-term economic prosperity.” “Clean technology is a major engine of job growth in the United States, and is key to overcoming the challenge of climate change,” said Dave Hudson, CEO of Vigilent. “Vigilent strongly supports continued U.S. participation in the Paris Agreement as the best means to address the climate challenge with global cooperation.” In a recent interview on Bloomberg Studio Television, Tim Cook, CEO of Apple, expressed his disappointment with the United States exit from the Paris Climate Accord. Cook said in the


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interview that he personally called President Trump and told him how important it was for the United States to stay in the agreement. After President Trump officially pulled out of the agreement, Cook said, “I think he decided wrong. I think it’s not good, not in the best interest of the United States, what he decided.” Lowcarbonusa.org is an organization of businesses supporting a low carbon economy. “One thousand companies and investors have signed the Business Backs Low-Carbon USA statement since November 2016.” (www.lowcarbonusa.org) Some of the larger companies who signed the pledge include: Acer America Corporation adidas Group Adobe, Inc. Akamai Technologies, Inc. AMD Autodesk, Inc. Ben & Jerry’s Homemade, Inc. Biogen, Inc Campbell Soup Company Dannon Company, Inc. Ebay Genentech, Inc. General Mills, Inc. Hewlett Packard Enterprise Hilton IKEA North America Services, LLC Intel Corporation Kellogg Company Lyft M.A. Mortenson Mammoth Mountain and June Mountain Mars Incorporated Mercy Health Monsanto Corporation National Ski Association New Belgium Brewing Nike NRG Energy, Inc. Outdoor Industry Association Pacific Gas and Electric Salesforce.com Schneider Electric Sierra Nevada Brewing Co. Solar City Staples Starbucks Symantec Corporation Tesla The Dow Chemical Company The Hartford The North Face

Tiffany & Co. Timberland Trinity Health Uniliver Vail Resorts Vans Virgin VMwar


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1.2.8 Wind Power Provides Economic Benefits Development and operation of wind plants create good paying jobs for the local economy. Jobs are created in many disciplines, and typically include biologists, archeologists, geologists, engineers, technicians, electricians, construction workers, truckers, and retail workers. Jobs are also created in other states, especially for wind turbine manufacturing. “American wind power supported a record 88,000 jobs at the start of 2016—an increase of 20 percent in a year—according to the American Wind Energy Association. (AWEA, U.S. Wind Industry Annual Market Report, Year Ending 2015.) A tool was developed by the National Renewable Energy Laboratory to estimate the jobs created in the development, construction, operation and decommissioning of wind plants. The tool is called the Jobs and Economic Development Impact Model, specifically designed for on-shore wind projects developed in the United States. This tool was used to estimate the economic impact of a 400-Megawatt capacity wind project at Crescent Peak, and the estimates are listed in table 1-1. (National Renewable Energy Lab, 01D JEDI Land based Wind Model, release W12.23.16)

1.2.9 Legislation in Support of Renewable Energy

FEDERAL President George W. Bush recognized the need to expedite the development of new energy projects in the US for the benefit of the American people. Below is selected text from the executive order: “Executive Order 13212 of May 18, 2001 By the authority vested in me as President by the Constitution and the laws of the United States of America, and in order to take additional steps to expedite the increased supply and availability of energy to our Nation, it is hereby ordered as follows: Section 1. Policy. The increased production and transmission of energy in a safe and environmentally sound manner is essential to the well-being of the American people. In general, it is the policy of this Administration that executive departments and agencies (agencies) shall take appropriate actions, to the extent consistent with applicable law, to expedite projects that will increase the production, transmission, or conservation of energy. Sec. 2. Actions to Expedite Energy-Related Projects. For energy-related projects, agencies shall expedite their review of permits or take other actions as necessary to accelerate the completion of such projects, while maintaining safety, public health, and environmental protections. The agencies shall take such actions to the extent permitted by law and regulation, and where appropriate.” Another federal incentive for renewable energy development is tax credits for plant capital investments (investment tax credit), and a separate credit for energy production (production tax credit). Congress has extended the tax credits for wind and solar power, but will phase out the credits over the next several years.

STATE Recently, the Nevada state legislature drafted and approved bill AB-206, which would have increased the mandated renewable portfolio standard from 25% renewables by 2025, to 40% by 2030. Governor Sandoval, who is generally a supporter of renewables, vetoed the bill due to


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concerns over the implementation of Nevada’s Energy Choice Initiative, which would cause a significant disruption of the Nevada energy market. Nevada’s neighbor, California, recently passed a law requiring the state to produce 50% of its power from renewables by 2030. This is one of the most aggressive renewable energy policies in the nation and will spur development of renewables over the next decade. This policy will reduce air pollution in the state of California and help neighboring Nevada’s air quality as well.

LOCAL Though there are no local (city or county) incentives for renewable energy development in Nevada, other municipalities around the country have committed to provide clean renewable power to their cities. “The City Council of Austin, Texas, first adopted a renewable portfolio standard (RPS) in 1999 (Resolution No. 990211-36). The RPS was subsequently amended several times, with the current RPS goal—65% renewables by 2025—among the most ambitious in the nation.

GOALS AND REQUIREMENTS The RPS for Austin Energy (the City of Austin’s municipal utility) and the city as a whole include the following renewable energy and greenhouse gas emission goals, targets, and standards:

2020: meet 50 percent of all energy needs through the use of renewable resources 2025: meet 65 percent of all energy needs through the use of renewable resources 2030: reduce carbon dioxide emissions from all city-controlled generation resources to

zero by 2030 2050: achieve a goal of reaching net zero community-wide greenhouse gas emissions”

(www.dsireusa.org, City of Austin – Renewables Portfolio Standard, last updated Last Updated April 27, 2015.) “In November 2004, voters in Columbia, Missouri, approved* a proposal to adopt a local renewable portfolio standard (RPS). (The state renewable electricity standard adopted by ballot initiative in November 2008 does not apply to municipal utilities such as Columbia Water & Light.) The city's municipal utility Columbia Water & Light is required to generate or purchase 30% of its electricity from eligible renewable energy resources by the end of 2028. Nearly 7% of all energy sources for 2013 were renewable according to the most recent renewable energy report. The goal was revised in 2014 to increase the 2017 goal to 15% from 10%, the 2022 goal from 15% to 25%, and to set a goal of 30% by December 31, 2028. * The RPS was approved by 78% of voters, with no organized opposition.” (energy.gov/savings/city-columbia-renewable-portfolio-standard accessed August 18, 2017)

1.2.10 Local Area Economic Benefits Whenever a project of this nature is constructed and operated, the local area economy stands to benefit in a combination of job revenues, property taxes, sales taxes, and other tangible and intangible benefits. Table 1-1: Local Benefits of the Comstock Wind Energy Facility, shows the estimate of economic benefits based on ongoing projects of comparable size.


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Table 1–2 Estimated economic impacts of the CPR wind project. Development Construction Operations Schedule 2017-2020 2020 2020-2050 Jobs Created1 4 1,104 54 Property Tax Revenue1

- - $7,901,348 / year

Sales Tax1 - $38,313,558 $414,434 / year Notes 1. Source: National Renewable Energy Laboratory (NREL) Jobs and Economic Development Impact (JEDI) wind model. Jobs based on CPR experience at a 400MW project capacity. Construction jobs include jobs created for turbine suppliers and induced impact jobs. Operations jobs also include 22 induced impact jobs.

1.3 General Facility Description, Design, and Operation

1.3.1 Project Location, Land Ownership, and Jurisdiction

The project area extends 22 miles (35.4 kilometers [km]) north to south, and 15 miles (24.1 km) east to west, adjacent to the California/Nevada border. CPR proposes placing up to 248 WTGs on four sites, constructed back to back.

The transmission interconnect will likely be made at the BOB switchyard about two to three miles north of the Eldorado substation. CPR will construct a 230kV transmission line on the northwest side of the existing Eldorado-Mojave 500-kV transmission line corridor from where that corridor passes through the CPR project area to a junction point with the Gridliance West TransCo system near the Eldorado substation.

1.3.2 Legal Land Description of Facility

Table 1-2 provides the legal description acreage of each project component.. A legal description of the Crescent Peak Wind Project ROW is provided in Appendix A. Figure 1-3 shows the legal description of the project area that is covered under the ROW.


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Table 1–3 Legal Description Acreages by Project Component

Project Component BLM

(acres)

Ancillary Features* 244

NV-1 7,901.22

NV-2 6,242.43

NV-3 7,035.18

NV-4 7,607.05

Project, including Gen-tie 29,030.51

* Includes facilities located outside of primary project sites (transmission lines).

1.3.3 Total Acreage and General Dimensions of All Facilities and Components

Facilities for the Project would consist of WTGs, an underground electrical collection system for collecting the power generated by each WTG, electrical substations, staging/laydown areas, access roads, and an O&M building. The overall project study area (Sites NV-1, NV-2, NV-3 and NV-4) totals approximately 28,786 acres, land that is covered by the requested ROW (Figures 1-3 through 1-7). The Project footprint itself would be confined to a much smaller area with an overall temporary ground disturbance of about 1200 acres. The permanently disturbed areas after construction will likely be under 700 acres..

Table 1-5 shows the total acreages of BLM land for each Project component and the gen-tie alternative. Tables 1-5 and 1-6 summarize the short-term and long-term surface disturbance associated with each Project component.

Table 1-5. Project Area’s Temporary and Permanent Length and Width by Project Component on BLM Managed Public Lands

Project Component Temporary

Disturbance Length (feet)

Temporary Disturbance Width (feet)

Permanent Disturbance Length (feet)

Permanent Disturbance Width (feet)

Wind Turbines (248 WTG’s) 240* 0.00 150* 0.00

New Roads 414,427 32 414,427 16

Gen-tie 230 kV (Project to Eldorado Substation) 106,286 100 106,286 100

Project Substation (1) 300 300 300 300

Internal 230 kV Lines 84,638 100 84,638 100

Internal Substations (each) 300 300 300 300

Staging Areas Various Various Various Various

Project O & M Facility (1) 400 400 400 400

Met Towers (each) 50* 0.00 50* 0.00

* This measurement represents the diameter of the disturbance area.


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Table 1-6. Project Area’s Temporary and Permanent Disturbance Acreages by Project Component on BLM Managed Public Lands

Project Component Existing

Disturbance (acres) Temporary

Disturbance (acres)

Permanent Disturbance

(acres)

Wind Turbines (248 WTG’s) 0.00 258.00 102.00

New Roads 0.00 305.00 152.00

Existing Roads 94.00 0.00 0.00

Gen-tie 230 kV (Project to Eldorado Substation) 0.00 244.00 244.00

Project Substation (1) 0.00 2.00 2.00

Internal 230 kV Lines 0.00 194.00 194.00

Internal Substations (5) 0.00 10.00 10.00

Staging Areas 0.00 162.00 15.00

Project O & M Facility (1) 0.00 4.00 4.00

Met Towers (20) 0.00 4.00 4.00

Total 94.00 1,183.00 727.00

1.3.4 Number and Size of Wind Turbine Generators

The Project includes 248 planned possible turbine locations and we plan on building turbines at 72 to 165 of those locations depending on the final selected turbine model and size as well as the final selected project MW rating. (see Figure 1-2). CPR is considering several potential WTG models with a capacity between 2.0 and 4.5 MW per WTG. Final WTG size and design will be based on several factors including but not limited to terrain, wind resource studies, and required mitigation factors. Depending upon the WTG manufacturer(s) and the model(s) chosen, the WTGs will be approximately 445 to 599 feet (135–182 meters [m]) in total height (measured from the top of the foundation to blade tip with a blade in the vertical position). Each WTG will have a three-bladed upwind configuration.

The installed WTGs will be utility multi-megawatt-class machines, and would be arranged in rows in accordance with applicable industry siting recommendations for optimum energy production and minimum land disturbance. Each WTG would operate as an independent generator with its own step-up transformer. Figure 1-16 shows a typical WTG structure.


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1.3.5 Access Roads

The Project would use existing federal, state, county, and local public roads, as well as new roads constructed specifically for the Project. Primary site access would be from Nevada Highway 164 (Nipton Road), which is a paved, two-lane highway connecting Interstate 15 and Interstate 95. In addition to these primary access routes, turbines and other Project facilities would be accessed via upgraded existing roads and new access roads. The overall proposed road network, including the primary access points, is shown in Figures 1-3 through 1-7. These figures also identify existing roads proposed for upgrading to support the transport of project facility components, as well as new roads proposed for turbine access and long-term O&M.

The access roads would be located and designed to minimize disturbance, manage water runoff, avoid sensitive resources, and to maximize transportation efficiency during construction and maintenance activities. The access roads would provide permanent vehicular access (construction and maintenance) to each WTG, the MET towers, the substations, and the other buildings. In order for equipment and personnel to reach the WTG locations, roads would need to be constructed to each WTG site. Roads would need to be constructed and maintained to allow for the ingress and egress of vehicles that range in size from passenger vehicles to semi-tractor trailer trucks, earth-moving equipment, cement trucks, tower and blade delivery trucks, and large cranes. During the construction of the facility, 16 to 32-foot-wide road access would be required for the construction equipment and the delivery and erection of the WTGs. This may require roads to be either improved or constructed to facilitate site development, operation, and maintenance.

Whenever possible, existing roads would be used and improved to avoid additional disturbance. In addition to the crane travel paths, the underground collection system and fiber-optic lines would also be constructed within the access road paths. Existing roads needed for turbine construction would be upgraded to up to 32 feet wide, and new roads would be constructed to up to 32 feet wide, where necessary, so that the turbine erection crane can crawl to each turbine location, should a crawler crane be used. It is likely that multiple cranes would be used to expedite facility construction.

Roads would be rough-graded and consist of approximately 6 inches of aggregate road base over compacted native material. At-grade crossings and, where necessary, culverts would be installed in drainages to manage water runoff and prevent washouts. During operations, roads would be regularly inspected, and maintenance would be done at least twice annually. Periodic grading and placement of aggregate base may be required to maintain road quality. Road maintenance would be scheduled during times of low wind to minimize airborne dust. Speed limits of 20 miles per hour would be posted and enforced on all Project roads. To minimize airborne dust and erosion, road surface treatment options would be considered and all vehicles traveling on site roads would be required to obey the established speed limit.

All roads would remain for the life of the Project; however, where possible, road widths would be reduced to a width between 16 and 24 feet through restoration activities following construction.


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Conceptual design of a wind turbine generator.

Public access roads would incorporate existing BLM standards regarding road design, construction, and maintenance, such as those described in the 2005 PEIS/ROD (BLM 2005), BLM Manual 9113–Roads .(BLM 1985), and Surface Operating Standards for Oil and Gas Exploration and Development (i.e., the Gold Book) (U.S. Department of the Interior and U.S. Department of Agriculture [USDI and USDA]

Rotor Diameter


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2007). All roads would be built at ground level. Additionally, any public access roads would conform to all applicable County road regulations, as well as the Nevada State Fire Marshal’s fire safety regulations. Roads would not be closed to the public except during construction, when road travel would be limited for safety purposes. Off-road vehicle travel is prohibited in the area and would not be allowed during any portion of the Project, with exception of pre-existing, pre-designated off-road routes.

1.3.6 Overhead Transmission Lines, Collection, and Communications Systems

TRANSMISSION

An aboveground, 230-kV overhead transmission line is proposed between the Project collection substations and the Project interconnection substation/switchyard facility in the southeast area of parcel NV-2. From this substation, the 230kV transmission line will be constructed to run parallel with the existing SCE Eldorado-Mojave 500-kV transmission system corridor that intersects the ROW near site NV-2.

The Project’s overhead transmission system would be a total of 36.16 miles long and would be routed across BLM lands. The transmission lines running from NV-4 to the switchyard at NV-2 will be approximately 16.03 miles in length. The transmission lines running from the switchyard in NV-2 to the Eldorado substation will be approximately 20.13 miles in overall length. The transmission lines would follow the route shown in Figure 1-2. The overhead transmission line would consist of electric cable strung from wooden H-frame, guyed or free-standing monopoles, or lattice towers.

The transmission line and poles would include devices to prevent raptor perching and nesting. The overhead transmission line would be accessed and installed by truck. Where possible, CPR will use the existing Mojave-Eldorado transmission line access road for construction of the new line. A temporary at-grade road may be required to be constructed parallel to the existing 500kV transmission line, and the site would be restored upon completion. The transmission ROW would have a 100-foot width (50 feet on either side of the planned center line). During the construction phase, the disturbed ROW width would be anywhere from 50 to 100 feet wide where towers are constructed depending on terrain, and would likely be fewer than 25 feet wide. An 8-foot-wide service road would be located within the ROW where needed. Wooden “H” or steel monopole transmission towers would be used to support the conductors.

COLLECTION SYSTEM

A step-up transformer would be co-located with each WTG. The transformer size and specific location will depend on the model of WTG selected for the Project. The step-up transformer would increase the voltage of the electricity up to 34.5 kV, for feeding into the Project collection substations. Depending on the WTG model selected for the Project, the step-up transformer may be housed in the nacelle or mounted outside the base of the tower approximately 5 feet away from the WTG foundation on a reinforced concrete pad. The reinforced concrete pad would be approximately 9 × 9 feet square and 1 foot thick.

From each step-up transformer, power would be transmitted via up to 34.5-kV electric conductor cable to allow the generated energy to be transported to the on-site Project collection substations. This system would include primarily underground cable and a limited amount of overhead cables. There would be junction boxes, sectionalizing cabinets, cross bonding cabinets, and disconnect switches and fuses. The cables would be armor-clad and when practical would be buried directly into the soil or placed in conduit using cable specifically designed for this application. The cables would be buried in trenches with at least 3 feet of cover material. The trench area would be typically 20 to 40 inches (1.7–3.3 feet) wide for each set of cables. From each set of cables laid in a trench, the trench must be widened by a minimum


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width required for one set of cables in a trench. If native materials are found to provide insufficient thermal conductivity (i.e., allow heat to dissipate from the cables), CPR may need to bring in engineered backfill. This backfill would be a soil type sufficient to radiate the heat from the cables and may be mixed with native material if appropriate thermal conductivity can be achieved from a mixture. The engineered backfill would only be used in the trenches with the cables, and only to an amount sufficient to radiate the necessary heat from the cables. The remaining depths of the trenches would be filled with native material from the site. In certain situations, concrete encasing may be utilized.

In all areas, the cable would be run along the side of the access roads, in an area already disturbed by the road construction. For areas near the Project substations where several runs of cable would all be in the same area, CPR might use both sides of the road for the cable trenches. After cable installation, the surrounding surface would be re-contoured and re-vegetated. Overhead lines would be used in limited situations for the collection system when good engineering practices require the lines for crossing extreme topography (i.e., crossing major gullies), archaeological sites, or if avoiding underground hazards (such as an aqueduct). Also, in areas with dense rock, it may be necessary to run the cables on overhead lines if the minimum trench depth of 4 feet cannot be economically achieved.

SUBSTATIONS

The five on-site Project substations would receive power generated from the WTGs at up to 34.5 kV and then step up the power to 230 kV for transmission. The two substations in NV-1 will collect power from the turbines in site NV-1 and step up the voltage to 230kV for transmission to the substation/switchyard in southeastern NV-2, near the Mojave-Eldorado transmission corridor. A 34kV to 230kV substation will be constructed in site NV-3 for collecting the power from turbines located in NV-3 and transmitting the power north to NV-2. The single substation in NV-4 will step up the collector network voltage to 230kV for transmission to the substation located in NV-3.

Each substation would be approximately 400 × 400 feet in size. The substation would contain the equipment required for switching, transforming, and transmitting the power, protection equipment, and a supervisory control and data acquisition (SCADA) system. In addition, if necessary, the substation would contain capacitor banks and other equipment that may be required to provide the voltage regulation necessary to meet the interconnection requirements for the Project. Such requirements are typically determined by federal, International Organization for Standardization, and local utility standards.

Each substation would include a small control building for electrical metering equipment, and the SCADA system which measures substation power levels and power delivery into the electrical grid. Riser poles at the substation connection point would have a pole-top, three-phase switch (operable from the ground), surge protection, insulated cable terminations and jumper wires, wildlife boots (a protective covering over cable terminators), and lightning arresters. Each substation site would be a graveled, fenced area with transformer and switching equipment and an area to park utility vehicles. Transformers and capacitors would be non-polychlorinated biphenyl (non-PCB) oil-filled types with spill containment capability.

UNDERGROUND COMMUNICATION LINES

The WTGs would be operated by a SCADA system in the control panel inside the tower of each WTG. Each WTG and substation would be connected via fiber-optic cable to a central computer in the Project O&M building. The WTGs can be controlled on-site or remotely, and data may also be accessed remotely. The fiber-optic communications cable would be collocated with the electrical collection system to reduce environmental impacts. Where feasible, collection cabling and communication lines would be collocated with roads to further reduce environmental impacts.


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1.3.7 Ancillary Facilities

The O&M building would preliminarily be constructed in the northern portion of Site NV-1 (see Figures 1-2 and 1-3). The O&M building would be constructed of composite panels, and would be approximately 140 × 60 feet. It would contain offices and house the control system for the WTGs, parts, consumables, and tools. Maintenance trucks would park adjacent to the O&M building. Portable water supplies would be used in the building, and sewage disposal would be by means of an on-site septic tank. Telecommunications lines and the SCADA system would also be installed inside the O&M building.

1.3.8 Temporary Construction Workspace, Yards, Staging/Laydown Areas

Proposed preliminary locations of laydown yards and staging areas for each construction phase are shown as yellow areas in Figures 1-3 through 1-7. The temporary laydown yards would be utilized for staging of the WTG components, cabling and ancillary facilities and components prior to transport to the site for installation. At these areas, the WTG components would be received and inspected for shipping and handling damage, cleaned of dirt, mud, and other debris picked up during transportation, and off-loaded from the delivery vehicles and prepared for installation. Preparation for installation includes removal of shipping fixtures and covers, installation of handling equipment, and assembly to the maximum amount possible prior to movement to the WTG pad sites for installation. Each laydown yard would be approximately 575 × 240 feet in size (approximately 3.16 acres total). Following completion of construction, the laydown yards would be reclaimed and revegetated.

The primary staging area would be established adjacent to the proposed O&M facility location (see Figure 1-3). This area would be permanent and initially be for construction purposes and then used for operational storage of maintenance materials and equipment. The area would be partially or fully fenced, and would cover a total area of approximately 46 acres (included in the overall area of the BLM ROW). After construction is completed, the primary staging area will be reduced in size to between 5 and 15 acres, depending on future operational and maintenance requirements.

During construction, construction equipment, cable, foundation parts, components, towers, blades, nacelles, etc., may be temporarily stored one of the laydown yards, or at the base of each WTG location. The equipment would be supported on wooden frames, pallets, or straw bales, which would be placed on the ground while turbine components are loaded, pre-assembled, and await installation. Areas of sensitive habitat would be fenced off with caution tape to prevent damage. Unless a local concrete batch plant is available during construction, concrete for foundations would be mixed at mobile batch plants located in the laydown yards. If concrete is mixed at mobile batch plants, cement, water, and aggregate would also be staged in the laydown yards.

1.3.9 Water Usage, Amounts, and Sources

It would be necessary to provide water to the O&M building(s) and fire suppression system. Though a water source has yet to be determined, CPR would like to investigate the opportunity to drill an on-site well, or convert a nearby well to commercial use. If drilling a new well is not feasible or cost effective, CPR would then truck potable and non-potable water in from sources outside of the Project site. Water storage tanks would be installed at the Project site as may be required. Water would be used for dust control during road construction and for concrete mixing in the batch plant(s) during foundation construction. Minimal amounts of water would be required during the maintenance and operation of the Project since the WTGs do not use water to generate power. CPR would attempt to find alternative cost-effective means for dust suppression on Project roads during operation.


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Once the WTGs are operational, limited blade cleaning maintenance would be required. High-pressure washing would be periodically conducted as part of a regularly scheduled maintenance program. This keeps the efficiency and productivity of the WTGs higher by eliminating dirt and other airborne debris that accumulates on the blades over time. On average, the blades on each WTG need to be washed about twice a year due to build up on the blades from dirt, insects, etc. However, because the Project would be located in a higher elevation and a drier climate, the WTG blades may only need to be cleaned once a year to once every couple of years. With sophisticated software monitoring of WTG performance, diminished performance can be detected, and blade cleaning can be determined based on need rather than as a part of a routine, scheduled maintenance plan. The amount of water used per WTG for blade washing varies, but typically, only clean water is used. Depending on the cleaning needs of the WTGs utilized for the Project, some blades may require a biodegradable solvent/cleaner to be added to the water during the cleaning process. Any solvents utilized during the blade cleaning process would be environmentally safe and biodegradable. The estimated amount of water required for blade washing and the potential types of cleaners to be used would be determined and analyzed during the NEPA process.

The rock/soil conditions and weather conditions during road construction will determine how much water would be required for dust control. After the roads are constructed, dust control would be maintained throughout periods of construction, which includes WTG component deliveries, crane moves, and final grading. The amount of water required for foundation construction would depend upon the final design selected for the foundations, which determines the amount of concrete required. Another factor affecting this would be weather conditions during construction, since the amount of water needed must be adequate to provide both workability and strength for the concrete.

Reclaimed water could be used for dust control during road construction. Other substances such as Envirotec may also be used to control dust to reduce the amount of water required. Water would be trucked from the closest available, approved source and stored on-site in water storage tanks established at key strategic locations to assure a steady supply of water during construction.

1.3.10 Erosion Control and Storm Water Drainage

Practices and experience in successful erosion control that CPR has gained at other wind farms shall be utilized when applicable. Erosion control methods may include construction of water diversion structures and site-specific applications of mulch or other water-flow dissipation materials as needed to control surface water runoff across disturbed areas. Water bars would be constructed to the size, spacing, and cross sections specified by the BLM to divert water from all erosion-prone areas and to direct drainage away from disturbed areas to established vegetation in sloped areas. Spacing intervals for water bars would be determined on a site-specific basis. Slope protection would be designed for the particular application required. Mulch would be applied on highly erodible soils and in areas with slopes greater than 15 percent. On steep slopes, hydromulching may be appropriate. Only mulch that has been certified to be weed free would be used. Erosion and sediment control best management practices (BMPs) would be employed during construction, in compliance with National Pollutant Discharge Elimination System (NPDES) General Storm Water Construction Permit requirements. An Erosion Control Plan would be developed for the Project in accordance with federal, state, and local laws.

A Storm water Pollution Prevention Plan (SWPPP) would be prepared and submitted to the BLM and other appropriate agencies for review and implementation during construction to control erosion and storm water runoff. The SWPPP would also provide post-construction monitoring of potential erosion issues with specific attention paid to areas that were disturbed during construction and potential problems caused by natural drainage. The SWPPP would be provided as an appendix to the final POD. A Site Grading Plan would be submitted after the exact Project footprint has been determined and would be provided as an Appendix to the final POD.


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1.3.11 Vegetation Treatment, Weed Management, and Any Proposed Use of Herbicides

Areas that have been temporarily disturbed by grading or other earth-moving activities would be restored to the original contours of the land to the extent possible and consistent with future operating needs. Reclamation work may consist of recontouring areas, extending water bars, creating berms, installing rock barriers, establishing vegetation, and applying mulch to provide additional erosion control. Ungraded areas disturbed only by overland travel would be assessed in coordination with BLM to determine if reclamation is needed for recovery of the area. Temporary disturbance areas on BLM-administered lands would be revegetated using seed mixtures and techniques developed in consultation with the BLM. Reclamation on private lands would take place according to landowner specifications. CPR would develop a comprehensive Construction Reclamation Plan (CRP) for areas disturbed by the construction process. The Construction Reclamation Plan would be an appendix to the final POD. The Construction Reclamation Plan would include success criteria and monitoring protocols to assess how successful revegetation efforts have been and to determine whether additional reclamation efforts are needed. The full plan would be developed during the environmental process and planning of the Project, and would be carried forward into the final phase of construction and identified within the final POD filed at that time.

All federally and State-listed noxious weeds within the areas identified for disturbance (including access roads) would be identified and mapped. A Noxious Weed Management Plan would be developed to control the spread of weeds during the construction, reclamation, and operational periods of the Project. A list would be provided that may have several species that are currently not applicable to the area, but which could be brought into the area from construction equipment that is not cleaned in accordance with the strict guidelines and standards that would be identified in the Noxious Weed Management Plan. The Noxious Weed Management Plan would be an appendix to the final POD. Noxious weed control would continue on-site during the revegetation process according to the specifications stipulated in the Noxious Weed Management Plan. Upon completion of construction and reclamation, fences and other previously existing structures would be reestablished to as good a condition or better than the original condition.

1.3.12 Waste and Hazardous Materials Management

Several types of non-hazardous and non-petroleum construction wastes would be generated during construction of the Project and the transmission line. “Waste” means all discarded matter, including but not limited to trash, garbage, refuse, filters, welding rods, equipment, or human waste. Approved enclosed refuse containers would be used throughout the Project. CPR would develop a Hazardous Materials Management Plan (HMMP) to address transportation storage, use, and disposal of hazardous materials expected to be used on-site during construction and operation. The HMMP would be provided as an appendix to the final POD. The HMMP would also identify requirements for notices to federal and local emergency response authorities and include emergency preparedness and response plans, including spill response. Hazardous material means:

1) any substance or material defined as hazardous, a pollutant, or a contaminant under Comprehensive Environmental Response Compensation and Liability Act at 42 USC 9601(14) and (33);

2) any regulated substance contained in or released from underground storage tanks, as defined by the Resource Conservation and Recovery Act at 42 USC 6991;

3) oil, as defined by the Clean Water Act at 33 USC 1321(a) and the Oil Pollution Act at 33 USC 2701(23); or


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4) other substances applicable federal, state, tribal, or local law define and regulate as ‘‘hazardous’’ (43 Code of Federal Regulations [CFR] 2801.5[b]).

CPR would develop a Spill Prevention Control and Countermeasures (SPCC) Plan for the Project in accordance with EPA requirements at 40 CFR 112, Oil Pollution and Prevention. The SPCC Plan, along with secondary containment design, would be developed in accordance with good engineering practices, obtaining the full approval of management at a level of authority to commit the necessary resources to fully implement the plan, and would meet the regulatory requirements. The SPCC Plan would be provided as an appendix to the final POD. The SPCC would ensure that adequate containment will be provided to control accidental spills, that adequate spill response equipment and absorbents will be readily available, and that personnel will be properly trained in how to control and clean up any spills.

Materials required for construction of this Project that are classified as hazardous materials would be primarily fuels and lubricants. Hazardous and non-hazardous materials used or stored at the site would be managed properly, and precautions would be taken to prevent them from entering soils and water. If any hazardous wastes are generated during construction, these wastes would be removed and disposed of in an appropriately permitted disposal facility. Construction waste materials including refuse and trash would be removed from the Project area and disposed of at a permitted landfill. Portable toilets would be provided for the construction crew, and sanitary waste would be periodically removed by a licensed hauler to an existing municipal sewage treatment facility. CPR would develop a Waste Management Plan. The Waste Management Plan would be provided as an appendix to the final POD.

Petroleum products such as gasoline, diesel fuel, crankcase oil, lubricants, and cleaning solvents would be present within the project area and the transmission line corridor during construction. These products would be used to fuel, lubricate, and clean vehicles and equipment and would be transported in containerized trucks or in other approved containers. Petroleum materials would be properly stored to prevent drainage or accidents. Preventive measures such as the use of vehicle drip pans for overnight parking areas would be used. The construction or maintenance crew foreman would ensure compliance with Nevada SWPPP guidelines for spill prevention and response. Additionally, if storage of petroleum products during construction, operation, and maintenance is required by CPR, the standards developed within the HMMP and SPCC Plan would be followed. Enclosed containment would be provided for petroleum wastes, and petroleum-related construction waste would be removed to a disposal facility authorized to accept such materials. The contractor would furnish fuel tanks for refueling of contractor vehicles and equipment. The storage containers typically range in size from 500 to 1,000 gallons each and would be located within secondary containment at the storage/staging/laydown areas to provide fuel for light-duty vehicles, construction equipment, and portable 100-gallon fuel containers. The fuel supply would be trucked in by trailer/tanker from local fuel suppliers. No light-duty vehicles would be refueled on the transmission line ROW, though it would be necessary and practical for heavy equipment left on the ROW during construction to be refueled within the ROW. This equipment includes cranes, blades, bulldozers, drill rigs, backhoes, and conductor stringing equipment. Light-duty vehicles would transport fuel in 100-gallon containers to the heavy equipment. The contractor would implement standard refueling procedures, including spill prevention practices. These procedures would be included in the SPCC Plan.

1.3.13 Fire Protection

CPR’s general contractor would develop a full Fire Management and Safety Plan consistent to the BLM fire management standards within the BLM Las Vegas District. This would be designed in a manner to minimize the potential for a human-caused fire. Associated with the Fire Management and Safety Plan, there would be safety considerations designed to address the potential fire sources and appropriate safety and fire prevention measures. Project-specific potential fire sources include vehicle exhaust systems, fueling operations, smoking, welding, and on-site flammable liquid storage. Fire suppression, emergency


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preparedness, and emergency notification and follow-up procedures would also be developed addressing BLM fire guidelines for equipment use, and other measures (such as carrying fire extinguishers and shovels) would be incorporated. The Fire Management and Safety Plan would be an appendix to the final POD.

1.3.14 Proposed Site Security and Fencing

Temporary construction yards, staging yards, and parking areas, where appropriate, would be fenced with 6 feet of temporary fencing and monitored/patrolled 24 hours a day by a security contractor. Access to the site and all facilities would be monitored and controlled during construction to protect public safety and provide for security. During operations, site facilities would be monitored 24 hours a day by project staff and/or a security contractor. Permanent buildings would likely not be fenced unless security issues dictate fencing. Permanent yards would be fenced with 6 to 8 feet of chain-link fencing. All structures and yards would be monitored with video cameras equipped with motion sensor–activated lights.

1.3.15 Helicopter Use and Refueling

The use of helicopters is not common in wind projects due to the heavy weights to be lifted. The largest helicopter available in this area, a Sikorsky Sky crane, is able to hover with around 25,000 pounds on the hook at sea level on a cool day. Considering the WTG components weigh on the order of 60,000 pounds and up to over 150,000 pounds, the lifting capacity is just not available. However, helicopters are used quite a bit to install meteorological towers, transmission towers, and power lines in remote areas, since that methodology can be faster and more economical. Helicopters may be used in construction of the transmission line for pulling lines and installing hardware during conductor installation and, in some cases, to move personnel and equipment. Helicopters may also be used for heavy lifting and setting transmission line tower structures in place. Helicopters would set down, and/or workers would be lowered onto pulling and tensioning sites or other work areas. Landing zones would be located on disturbed land such as roads, parking areas, or turbine pad clearings. All Federal Aviation Administration (FAA) regulations would be followed. Use of the air space would be coordinated with other helicopters in the area being used for seeding, fire support, or other use. Water trucks would be used, as needed, to spray the helicopter landing sites to reduce dust. If fueling would be performed on-site, fuel for the helicopter would be trucked to specific locations.

1.3.16 Health and Safety Program

CPR will develop a Project Health, Safety and Environmental Plan (HSEP) to address health, safety, and environmental risks and requirements during the construction phase of the Project. This Project HSEP would be combined with the Fire Management and Safety Plan and would be an appendix to the final POD. Components of the management system that would be addressed in the HSEP include, but are not limited to, risk management analysis; emergency response; HSEP planning and procedures; HSEP implementation; monitoring and reporting results; setting performance targets; incident classification; investigation and reporting results; audits and inspections; and management review. Minimum contractor HSEP requirements would be established in the HSEP. These requirements would include personal climb procedures, protective equipment, housekeeping, maintaining a safe workplace, fire prevention, safe work practices, etc. Contractors would be required to comply with these minimum requirements. Contractor safety plans would be reviewed to assure compliance. As the Project moves into the operational phase, the components of the HSEP would be modified to adapt to that phase.


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1.4 Other Federal, State, and Local Agency Permit Requirements

Consultation will be made with the FAA and DOD to mitigate effects on local airports and nearby DOD facilities. Development of this project will require a curtailment agreement between CPR and the DOD to allow for turbines to be shut down during testing periods, as required by the DOD. These curtailments are typically capped at a certain number of hours per year, or a specified number of hours over a 10-year period, pending details of the final agreement.

Additional permits and authorizations that may be required will be obtained prior to the start of construction, and are listed in Table 1-7.


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Table 1-7. Authorizations Table Authorization Agency Authority Statutory Reference

Federal

ROW for land under federal management BLM FLPMA of 1976 (Public Law [PL] 94-579); 43 USC 1761–1771; 43 CFR 2800

NEPA compliance to grant ROW (tiered to wind energy EIS)

BLM NEPA (PL 91-190, 42 USC 4321−4347, January 1, 1970, as amended by PL 94-52, July 3, 1975, PL 94-83, August 9, 1975, and PL 97-258, §4(b), Sept. 13, 1982)

Endangered Species Act compliance U.S. Fish and Wildlife Service (USFWS) Endangered Species Act (PL 93-205, as amended by PL 100-478 [16 USC 1531, et seq.])

Migratory Bird Treaty Act USFWS 16 USC 703–711; 50 CFR Subchapter B

Bald and Golden Eagle Protection Act USFWS 16 USC 668−668(d)

National Historic Preservation Act (NHPA) compliance

Nevada State Historic Preservation Office (SHPO)

NHPA 106 (PL 89-665; 16 USC 470 et seq.)

Notice of Proposed Construction or Alteration (Form 7460.1)

FAA 49 USC, 44718 and, if applicable, 14 CFR 77 (2005) to determine whether the structure exceeds obstruction standards or be a hazard to air navigation

Notice of Actual Construction (Form 7460-2)

FAA 14 CFR 77 (2005)

Clean Water Act (CWA) Section 404 Dredge and Fill Permit

U.S. Army Corps of Engineers 33 USC 1344

Consultation Regarding Military Radar Department of Homeland Security N/A

CWA, Section 402 NPDES during operation Nevada Division of Environmental Protection (NDEP)

33 USC 1251 et seq.

State

NHPA Section 106 Determination of Effect Concurrence

Nevada SHPO 16 USC 470 et seq., NRS 383

Utility Environmental Protection Act – Permit to Construct

Nevada Public Utility Commission NRS 704.820-704.900, Nevada Administrative Code (NAC) 704.9063, NAC 704.9359–704.9361

Rare and Endangered Plant Permit Nevada Division of Forestry NRS 527.260–527.300

Native Cacti and Yucca Commercial Salvaging and Transportation Permit

Nevada Division of Forestry NRS 527.050–527.110

Incidental Take Permit Nevada Department of Wildlife NRS 503.584–503.589

Construction Permit NDEP, Bureau of Air Pollution Control NAC 445B, 42 USC 7401

Operating Permit (Clean Air Act, Title V) NDEP, Bureau of Air Pollution Control NAC 445B, 42 USC 7401

CWA, Section 401 Permit NDEP, Bureau of Water Quality Planning 33 USC 1251 et seq.

Groundwater Discharge Permit NDEP, Bureau of Water Pollution NRS 445A.300−730, NAC 445A.070−348, NAC 445A.810−925

CWA, Section 402 NPDES Notification for Stormwater Management during Construction

NDEP 33 USC 1251 et seq.

Surface Area Disturbance Permit NDEP NRS 519A.180 (for small sites), NAC 445B

ROW Occupancy Permit Nevada Department of Transportation NRS 408.423, 408.210, NAC 408

Over Legal Size/Load Permit Nevada Department of Transportation NRS 484.437−775, NAC 484.300−580


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Table 1-7. Authorizations Table (Continued) Authorization Agency Authority Statutory Reference

State (continued)

Uniform Permit (for transportation of hazardous materials)

Nevada Department of Public Safety NAC 459.979

Assignment of Water Rights Nevada Division of Water Resources (State Engineer)

NRS 533−534

Dust Control Permit Nevada Department of Environmental Quality

NAC 445B

Industrial Artificial Pond Permit Nevada Department of Wildlife NRS 502.390

Well Permit Nevada Division of Water Resources N/A

Phase I Environmental Site Assessment NDEP Comprehensive Environmental Response, Compensation, and Liability Act, as amended, 42 USC 9601 et seq.

Clark County / Local

Special Use Permit Clark County Planning Commission Clark County Zoning Ordinance Title 30

Dust Control Permit Clark County Department of Air Quality and Environmental Management

Clark County Air Quality Regulations. Clean Air Act of 1977 and amendments, NRS 321.001, 40 CFR Subpart C, 42 USC 7408–7409.

Grading Permit Clark County Civil Engineering and Clark County Building Department

Clark County Title 30.32.040

Commercial Septic Holding Tank Permit Southern Nevada Health District NRS 439, 444.650

Building Permit Clark County Comprehensive Planning Department

Clark County Title 30.32.030

Height Variance Permit Clark County Comprehensive Planning Department

Clark County Title 30

Conditional Use Permit Clark County Comprehensive Planning Department

Clark County Title 30

Federal Emergency Management Agency (FEMA) Map Review and Clark County Regional Flood Control District (CCRFCD) Plan Compliance

CCRFCD CCRFCD Uniform Regulations for Control of Drainage

1.5 Financial and Technical Capability of Applicant

The following description provides the profile and experience of the parent and affiliated companies of CPR, as well as the financial plan for the Project.

1.5.1 Profile and Experience

Crescent Peak Renewables, LLC is a wholly owned company by Eolus North America, Inc. Eolus North America, Inc in turn is owned by a public traded company Eolus Vind AB (publ.) traded on Nasdaq Stockholm stock exchange (www.eolusvind.com). Eolus has been in business since 1990 and is a leader of wind development in the Nordic countries and successfully expanded its business to North America during 2015. The team responsible for developing Eolus wind projects in the United States has a broad spectrum of wind energy development experience, on private and public lands, in both the United States and Europe culminating in well over 50 years of development experience and over 2,500 megawatts of sustainable wind energy development. Capital financing to develop the project has been secured through balance sheet financing and various banking and investment venues with substantial amounts of capital available.


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1.5.2 Financing

The Project would be developed, constructed, and operated to satisfy the due diligence and risk management requirements required by project financing. The Project has not yet obtained a commitment for construction and term debt since the Project is not yet at the appropriate stage of development. However, CPR personnel are in communication with several utilities and financial institutions on a regular basis to confirm availability of funds and its financial terms and conditions and has factored this into the analysis of the Project’s financial model and viability. CPR is in an advantageous position with respect to relations with financial institutions as its owners have financed wind projects well over $1 billion in recent years using both all-equity and a combination of equity and debt financing from sources like Allianz Global Investors, Skanska, City of Zürich, Aquila Capital, Munich Re, and Google.


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2 CONSTRUCTION OF FACILITIES

2.1 Wind Turbine Design, Layout, Installation, and Construction Processes

This POD discusses the general activities and design approaches as currently understood. CPR will remain in contact with the BLM and other agencies as the Project designs are finalized and specifics on construction are available, at which time this POD would be updated. In general, the design approach for the Project has two objectives:

1. The first is the concept of minimizing the overall environmental impact of the Project, while maintaining cost effectiveness and safety standards. This would include minimizing the amount of cut and fill required for the roads and foundations, and the use of as much excavated soil and rock as possible on Project roads.

2. The second is the concept of “voluntary environmental design management,” in which the Project design would be adjusted to complement the natural characteristics of the site. Voluntary environmental design management would also be employed during construction if the modification of particular Project components would allow for better adaptation to actual site conditions.

Prior to the start of construction, CPR would review and document the general condition of the site, including the existing vegetation and areas of disturbance. When construction is completed CPR would revegetate and reclaim areas not needed for ongoing operations to return the site to a near pre-construction condition. This may include reseeding areas exposed during construction, weed control measures, and returning land contours and drainage to a condition as near as possible to those that existed prior to construction.

Public access to the project site would be restricted during construction as necessary because of public safety concerns. Construction activities which raise safety issues include, but are not limited to, blasting, WTG erection, foundation excavation, electrical collection system trenching, transmission line construction, and the substation construction. CPR understands and respects that the BLM land within the project area is held in public trust; therefore, CPR would only restrict site access as necessary during construction, as required by law or as required for public safety.


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2.2 Potential Geotechnical Studies

Wind projects are subject to energy loads from wind, seismic events, or high dead loads transmitted to the earth through a foundation. Project designs must incorporate data on existing soil conditions and any load restrictions of the soil to determine thresholds of settlement or failure. One or more bore samples must be taken at each WTG and substation location and the associated soil sample analyzed and tested to determine the allowable loads. In addition, any subsurface anomalies, such as underground springs or voids, should be identified. The analytical results would enable the design of foundations adequate to withstand the high-energy loads produced by WTGs. Without complete geotechnical information, it is impossible to accurately develop a suitable foundation design and develop firm foundation costs.

In addition to geotechnical samples that would be collected at each WTG location, additional samples would be required along the road ROW(s) to determine the soil suitability for compaction and ability to carry the high construction loads and traffic. The primary objective of the geotechnical investigation is to characterize the strength characteristics of the bedrock and to determine the dynamic properties for the WTG foundation design. The investigation would consist of drilling and/or coring specific locations along the WTG alignments, WTG pads, roads, or other locations destined to be disturbed during construction. Drilling/coring would be completed using moderate-sized geotechnical drilling equipment mounted to either a truck or tracked vehicle. The drilling/coring process would obtain samples of earth/rock to be logged. Samples of the cores would be sent to a geotechnical laboratory for strength testing. The drilling/coring process leaves small holes at the test site approximately 3 to 6 inches in diameter and up to 60 feet deep. Upon completion, each hole would be backfilled in accordance with federal and state requirements. Test pits dug with a backhoe or similar equipment may also be utilized to evaluate whether the bedrock can be excavated.

Additional geotechnical investigations may include several seismic refraction survey lines. The seismic refraction lines would be used to determine dynamic soil properties of the underlying bedrock and would also be used to confirm bedrock strength. The seismic refraction lines would be completed using an extremely low energy source (a sledgehammer and plate). The seismic analysis would also include a multichannel surface-wave analysis, which utilizes background vibrations such as vehicles to generate seismic noise.

2.3 Project Construction Schedule

CPR expects to complete the construction of the proposed Project in phases. Due to federal tax law and the eligibility to receive Production Tax Credits the entire Project must be in commercial operation before end of 2020. The construction is estimated to take around one and a half year. Construction is scheduled to commence mid-2019 and is expected to be done by December 2020. Table 2-1 summarizes the construction schedule for the Project.


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Table 2-1. Project Construction Schedule

Task/Milestone Start Finish

Obtain Approvals August 2006 June 2019

Road Construction July 2019 March 2020

Wind Turbine Foundation Construction September 2019 April 2020

Electrical Collection System Construction August 2019 April 2020

Substation and Transmission Line Construction September 2019 September 2020

Operations and Maintenance Facility Construction January 2020 March 2020

Wind Turbine Receive, Assembly and Erection February 2020 September 2020

Plant Energization and Commissioning October 2020 November 2020

Plant Substantial Completion November 2020 December 2020

Plant Construction Punch List Cleanup December 2020 February 2021

2.4 Access and Transportation System, Component Delivery, and Worker Access

This POD discusses the transportation system as currently understood. CPR would remain in contact with the BLM and other agencies as the Project access and transportation system plans are finalized and specific information is available, at which time this POD would be updated.

2.4.1 Primary Access to the Site

Primary site access is from Nevada Highway 164 (Nipton Road in California) which is a paved, two-lane highway connecting with Interstate 15 approximately 18 miles west of the Project, and U.S. Route 95 approximately 10 miles east of the Project in Searchlight, Nevada. There is also potential access that would be investigated for delivery of large components via railroad at a Union Pacific railroad siding in the settlement of Nipton, California, about 7 miles west of the Project.

Existing access roads that would provide access to the Project area may need to be upgraded or improved to some degree. Existing roads would be improved using existing dirt and aggregate materials on-site to the maximum extent possible. It may be necessary to import additional materials to supplement the on-site materials; however, this would be held to a minimum. The main access roads would be improved as necessary to provide access for the delivery of the large WTG delivery trailers. Delivery trailers typically require a road width of 16 to 24 feet. Occasionally, wider widths may be required at sharp turning points to allow the longer delivery trailers to safely negotiate the turns.

2.4.2 On-Site Access System

WTG access roads within the project area would be designed and constructed to provide a path suitable for moving the large erection cranes from pad to pad during installation of the WTGs. Typically, these cranes require a road width of 16 to 32 feet, depending on the particular crane model chosen for use on the site. A wide enough path can be provided by constructing the road with a narrow strip sufficiently spaced from the road edge to allow the crane tracks to simultaneously ride on both the narrow strip and the road, depending on the terrain features.

Any public access roads would incorporate existing BLM standards regarding road design, construction, and maintenance, such as those described in the 2005 Wind Energy PEIS/ROD (BLM 2005), BLM


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Manual 9113 (BLM 1985), and the Surface Operating Standards for Oil and Gas Exploration and Development (USDI and USDA 2007) (i.e., the Gold Book). A typical road cross section is shown in Figure 2-1.

2.4.3 Component Delivery and Construction Circulation

Multiple laydown areas would be established within the project area to provide temporary storage space during construction. On-site parking would be kept to a minimum, utilizing construction yards where practical. All temporary construction areas would be graded to return the area to its original condition following construction. During construction, the large WTGs and the associated equipment needed to erect them require a good amount of space to move around for operational safety and standards. Access to some sites may require the crane to be either partially or fully disassembled, loaded onto transportation trucks by a secondary crane, and reassembled at or near the WTG assembly point, thereby reducing the amount of road construction. Although some very difficult sites might require additional construction access, roads would be between 16 and 32 feet wide, leveled from side to side, with a well-compacted base and gravel overlay.

Many of these heavy vehicles accessing the project site during construction would be specialized vehicles for WTG component delivery. Included in the normal heavy-duty truck traffic would be cement trucks used for delivering cement for the construction of the WTG bases, dump trucks to move aggregate from base excavations, and water tankers to wet down the site roads for dust control. Trucks would be confined within the site boundary for safety, fire control, and noxious weed control. Signs on the public roads utilized by these trucks would be erected warning the public of the increased heavy construction traffic on these roads. When possible, delivery times would be coordinated with the use patterns of the roads to avoid traffic congestion.

When practical, the routing of existing roads would be improved, rather than constructing new roads. Also, the cut and fill required for the access road would be balanced to the extent possible to minimize the amount of material movement to and from the site. An analysis would be conducted on all Project roads to determine cut and fill volumes. Where possible, crossings at low spots or drainage courses would be at-grade with no culverts or extensive fill. The on-site service roads would be regraded with low spots and ruts filled in with the extra gravel base materials. A qualified civil contractor would construct all required roads. The roads would be sprayed with water or other substances to control dust such as Envirotec.


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Figure 2-4. Cross sections and plans for typical road sections representative of BLM resource roads. (Source: USDI and USDA 2007: Figure 3)


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2.5 Construction Work Force Numbers, Vehicles, Equipment, and Timeframes

The construction work force would be spread throughout all phases of Project construction. The work force would be expected to arrive in personal or company vehicles and park at the designated laydown, work, and parking areas. Part of the workforce would be hired from the local market, primarily for activities such as road construction and maintenance, building construction, and site restoration. Specialized labor and construction expertise is needed for functions such as the WTG installation and would likely be brought in from outside the local area. Depending on the stage of development, the equipment on-site may include road construction equipment, general excavation equipment, rock drills, trenching machinery, heavy-haul trucks, and heavy-lift cranes. Portable construction trailers would be installed on-site to provide temporary office space for the construction management. Table 2-2 identifies the Project components, estimated number of workers, and types of equipment needed based on the specific component. The specific timelines for the manpower and equipment would be developed as the Project moves closer to start-up.

Table 2-2. Construction Manpower and Equipment

Project Component Number of People Equipment

Office staff and management 18 Pickup trucks and small vehicles

Foundations 50 (per phase) Bulldozer, grader, excavator or drill rig, crane, concrete trucks, concrete pump trucks, pickup trucks with trailers, all terrain forklifts, water trucks, dump trucks, pickup trucks, compactors, generators, welders

Roads 32 (per phase) Bulldozer, grader, front-end loaders, compactor, roller, pickup trucks, water trucks, dump trucks, compactors, scrapers

WTG component unloading crew (pad site)

24 (per phase) Cranes, all terrain forklifts, pickup trucks with trailers

WTG erecting 50 (per phase) Cranes, pickup trucks with trailers

Environmental 15 (per phase) Pickup and flat-bed trucks

Substations 30 (per substation) Cranes, forklifts, pickup trucks, water trucks, concrete trucks, concrete pump trucks, dump trucks, compactors, generators, welders, scrapers

Electrical collection system 30 (per phase) Trencher, grader, forklift, small cranes, pickup trucks, line trucks

Directional boring 15 (per phase) Boring machine, pickup trucks

Transmission line 35 (per phase) Cranes, excavator, drill rig, pickup trucks, line trucks

Laborers 40 (per phase) Pickup trucks

Owner representatives 10 (per phase) Pickup trucks

Turbine supplier 50 (per phase) Pickup trucks

2.6 Site Preparation, Surveying, and Staking

The first construction activities include mobilization of personnel and equipment, installation of temporary construction facilities such as trailers and parking for privately owned vehicles and construction equipment, and surveying and staking of the road alignments. Construction surveying and staking would be a continuous activity throughout the first several months of the Project and involve center line and toe staking for roads as well as staking for the WTG pads, substations, and all other Project facilities. All roads, laydown areas, WTG pads, and any surface that would be disturbed would be cleared and the existing vegetation would be grubbed in accordance with the procedure described in


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Section 1.3.11. The surficial soil would then be removed. The soil depth in the project area varies. On average, it is anticipated that 6 inches of soil/rock “topsoil” would be removed from all previously undisturbed areas and be stockpiled so that it can later be used for site restoration of roads, collections trenches, WTG pads, and other areas that can be restored once construction is complete. A Site Grading Plan would be submitted after the exact Project footprint has been determined and would be provided as an appendix to the final POD.

2.7 Gravel, Aggregate, Concrete Needs and Sources

When practical, aggregate materials may be made by crushing the rock excavated from the foundation holes at the project site. Any additional aggregate materials would be from private sources located off-site. As the access and initial Project roads would be built before any foundations are excavated, initial quantities of aggregate would be imported from a nearby source. The exact source of the aggregate would be determined once a civil construction contractor is selected. Concrete batch plants would be set up on or adjacent to the project sites to provide concrete necessary for base foundations of the WTGs and substation equipment. Attempting to bring large numbers of trucks onto the site with pre-mixed concrete is likely not feasible due to the distance to the nearest concrete plant and travel limitations of Project roads. The batch plants may be relocated to different strategic sites during construction to optimize service to the various sites requiring concrete. The gravel and cement would be trucked to the batch plants and temporarily stored on-site. The gravel and cement would be delivered from private sources located off-site. The water would be stored in a temporary aboveground storage tank. The gravel and cement would be trucked to the site as needed to minimize storage requirements.

2.8 Wind Turbine Assembly and Construction

The WTG installation requires specialized equipment and crews. The construction activities necessary for the assembly and installation of a WTG include: WTG component delivery and storage; crane movement or assembly; connection of internal wiring between the generator, transformer, and control systems; connection of the transformer to the electrical collection system; and connection of the control system to the central communications and control systems. Limited construction zones would be built around each WTG site. Directly adjacent to the WTG foundation would be a crane pad area. The crane pad would be approximately 90 × 150 feet and would require adequate structural support for the cranes during installation, WTG assembly area and limited storage during erection of the WTG. The crane pad area would be cleared and level enough (generally less than 2% slope) to allow for the WTG components to be staged for installation. Figure 2-2 illustrates a typical WTG assembly area.

Designers and engineers would work to minimize the amount of work required at each site, and where possible only a minimal amount of vegetation would be removed to allow for the WTG component delivery. When such is practical and economical, portions of these pads would then be revegetated once construction is complete. To the greatest extent possible, the areas of construction and operation would be consolidated for efficient land use in order to minimize disturbance (for example, crane pads would in some cases be constructed to coincide with road areas).

The WTG component consists of the tower sections, nacelle, drive train, rotor hub and blades, and step-up transformers. As the WTG components arrive at the project site, they would be routed to the WTG sites where they are to be installed. When trucks arrive at each site, one or more small cranes mounted on would remove the cargo. Each site would have a plan prepared in advance for the arrangement of major components before erection. If the WTG foundation has had sufficient time to cure before the lowest tower section arrives, that section may be off-loaded directly onto the foundation. The WTG deliveries may begin before the site opens and before the site roads are ready for truck traffic. In these instances,


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some major components may be off-loaded and temporarily stored at a laydown area off-site. These components would then be moved to their WTG site as soon as feasible.

Figure 2-2. Typical WTG pad, crane pad/rotor assembly area.

When a large crane first arrives onto the project site, it would be taken to the location for the first WTG installation. The crane would be assembled on that site, and then used to install the WTG. Once the WTG at that site is erected, the crane would be “walked” to the next WTG site using the crane’s tracked base (providing that type of crane is used).

The requirements for walking the cranes would set many of the design parameters for the WTG string road, including road width, pitch, and slope. At locations where the road cannot be built within the tolerances for walking the crane, the crane would be disassembled, moved to the next site, and reassembled. Whereas most of the major components would arrive in completed form, the rotor (consisting of the hub and blades) would need to be assembled after delivery. The rotor would be placed with the nose up, and a small crane would be used to lift blades so they can be attached to the rotor. Once these blades are attached, and any hydraulic or electrical connections are made between the hub and blades, the completed rotor package would be ready to be lifted. Depending on the size of the rotor blades, the supplier might however choose to lift the rotor first and then attach each individual blade


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separately. Similar assembly work may be required for the nacelle, depending on the WTG model selected for use.

WTGs are installed in large, pre-assembled components that are interconnected in the field. Crane crews erect the WTGs soon after all components arrive to minimize the amount of time the equipment is on the ground. The only exception may be if components begin to arrive before the site is available for construction (due to impassible roads on the site or some other similar reason). In such an instance, some components may be temporarily stored at off-site or on-site construction laydown areas until proper project site access is available. The tower, which usually consists of three or four sections, would be installed first. The lower tower section would be placed on the foundation, with the remaining components placed around the site in planned laydown arrangements. The tower sections are lifted one at a time, and bolted together in place. Once the last tower section is in place, the nacelle is secured to the top of the tower. Finally, the rotor (hub and blades) would be lifted into place and secured onto the nacelle. The rotor can usually be lifted into position as a complete unit, however, it may be more efficient to first fit the hub onto the nacelle, and then have the blades lifted into position one at a time and fixed to the hub. The rotor and blades lifts usually require the use of a small “helper” crane. Once the crane and all WTG components have arrived at a site, the assembly of the major components takes 1 to 2 days. The lifting of large WTG components can only be done during periods of high visibility and low winds. Weather delays could occur at some sites. To minimize the impact of weather delays, two or more large cranes may be simultaneously installing WTGs.

Each WTG is placed on a foundation. The WTG foundation anchors the WTG (consisting of the tower, hub, blades, and nacelle) securely to the ground. The WTG foundations would be one of three commonly used designs, depending on the geotechnical constraints at each WTG site and other factors, including wind patterns at the site, site access, material availability, and the type of WTG manufacturer selected for the Project. The three main possible types of WTG foundations are 1) Patrick and Henderson Inc. (P&H) patented tensionless foundation, 2) rock anchor, or 3) a modified spread-footing. The P&H foundation would be drilled or dug to approximately 16 to 45 feet, depending on the geotechnical conditions and loadings, and would be approximately 18 feet in diameter. The foundation would be in the configuration of an annulus—two concentric steel cylinders filled with structural concrete. The central core of the smaller, inner cylinder would be filled with soil removed during excavation. The cavity between the cylinders would be filled with concrete and include reinforcement steel and anchor bolts bolting the tower to the foundation. Using the high-strength anchor bolts provides post-tensioning to the concrete, assuring the concrete is always in compression, where it is strongest.

The rock-anchor foundation is an alternative to the P&H foundation. Six to 20 holes, depending on the geotechnical data, would be drilled approximately 35 feet into the bedrock, and steel anchors would be epoxy-grouted in place. A reinforced concrete cap containing the anchor bolts would be poured on the top of the steel anchors to support the tower structure. High-strength anchor bolts are embedded in the concrete to fasten the tower to the foundation.

A spread footing foundation also may be used. This foundation may be square or octagonal and formed with reinforcing steel and concrete. Depending on the geotechnical constraints at the site, this type of foundation may be as large as 50 × 50 feet and 6 to 10 feet thick. Total combined cut and fill volumes for the WTG foundations are estimated at up to 1,000 cubic yards. For all designs, the exposed concrete pad would be approximately 15 to 20 feet in diameter and extend about 1 to 2 feet above grade.

Temporary disturbance for construction of all turbines for both phases is estimated at one acre per turbine, or about 248 acres. for construction impacts. Permanent disturbance would total 101 acres, based on a 75-foot radius around each tower base.


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2.9 Electrical Construction Activities

2.9.1 Trenching and Installation of Underground Electrical and Communication Cables

In most areas, the underground electrical cable would be buried along the side of the project roads, generally in an area already disturbed by the road construction. Occasionally, it may be necessary to run the cable cross-country to shorten the length of cable and minimize operating losses due to resistance in the cable. The cable would not be run in the center of any of the roads to avoid unnecessary stress on the cables from vehicle traffic, as well as the potential for cable damage during road maintenance. For areas near the Project substations where several runs of cable would all be in the same area, CPR may use both sides of the road for the cable trenches. After final grading to approximately original contours, disturbed areas would be restored using native seed mixtures and techniques developed in consultation with the BLM.

There are two methods for the placement of the electrical collection system cable. The first is open trench placement, where a trench would be dug to the required depth of cable placement, the cable would be placed in the trench, and the trench would be then refilled. The second placement method would be direct placement using a trenching machine. These machines cut an opening just large enough for the cable and refill the hole in a combined single pass. Though very efficient, these machines are hampered in areas where the soil conditions are rocky.

If the geotechnical investigation shows that the soils present on-site do not conduct heat away from a buried cable properly, it may be necessary to import “engineered backfill” material to be placed around the cable for heat dissipation. If such backfill is necessary, the open trench approach would be required. Until the geotechnical investigation is completed, it is not known which method would be used.

Excess materials excavated from trenches would be used for road fill or aggregate. The medium-voltage electrical collection system cable would be placed a minimum of 48 inches below grade. The fiber-optic communications cable would be placed in the same trench a minimum of 18 inches below grade. The final depths would be determined by the geotechnical conditions of the area, and the manner in which the cable is installed. Buried cable would have a warning tape, stakes, and/or marker balls placed over the top of the cable at a depth of 12 inches, which would act as a visual reminder of the cable’s presence for future site work.

2.9.2 Bus Work and Electrical Line Connections

Much of the electrical work performed within the BLM lands would be underground. Some overhead electrical line and bus work (rigid overhead metal conductors) connections would be made at the Project substations. The electrical collection system may come into the substations underground, then transition overhead into the up to 34.5-kV bus work or come directly into the substations overhead via an overhead transmission line.

Bus work connects the WTGs on different feeder lines (about five to six WTGs per line) to a common bus. Any necessary voltage regulation devices would also connect to this bus work, which then connects to the low-voltage side of a substation transformer. On the high-voltage side of the transformer, an overhead connection would be made to the Project transmission tie-line using a riser structure. The bus work would be constructed using small overhead cranes, scissor-lifts, and other similar devices. The bus work components would be bolted together on-site, and placed on small foundations for support. All of this work would be performed within the fence of the Project substations.


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2.9.3 Communication of the Project Substations

Communications between the WTGs and the Project substations would be achieved by using underground fiber-optic cables, as described in Section 3. These cables would be buried above the electrical collection system cables utilizing the same trenches in order to minimize the impact to the environment. When overhead lines are utilized for the collection or transmission systems, the fiber-optic cables would be installed on the same poles as the lines. Communications to the Project substations would be achieved by a fiber-optic line to the O&M facility.

2.9.4 Construction of the Project Substation

Each Project substation would increase the voltage of electricity from approximately 34.5 kV to 230 kV. The substations would be located on a graveled site. A grounding grid would be installed beneath the gravel. Concrete foundations for the substation equipment would be designed and constructed for the soil conditions at each site.

To construct a substation, the following tasks are required: survey/stake the site; clear/grub site; perform site grading; excavate; install below grade grounding grid; install below grade raceway (conduit, duct bank, trench, etc.); place forms and rebar; pour concrete for foundations; install a sublayer of crushed rock surfacing; install substation steel structures and control enclosures; install substation electrical equipment (circuit breakers, transformers, disconnect switches, potential transformers, etc.); install above grade ground stingers; install substation bus conductors and jumpers; install control/relay and communication materials; install secondary control/power cable and terminations; install final layer of crushed rock surfacing; install perimeter fence; install snow fencing as required; perform substation testing/commissioning activities; and energize substation. Once the detailed engineering is performed, it would be determined if additional tasks would be required. Any additional tasks would be approved by the BLM and other agencies prior to their commencement.

2.9.5 Construction of the Overhead Transmission Line and Switching/Interconnection Structure

The Project would require an overhead transmission line from the Project substations to a switching station at the point of interconnection at the BOB switch yard near Eldorado. The overhead transmission line will be 230 kV. The ROW for the overhead transmission line route would be surveyed and designed, and a licensed surveyor would stake the location of the pole structures according to the design. The overhead transmission line would transmit electricity from the Project substations to the interconnection point. The legal description of the proposed transmission corridor is described in appendix A.

2.9.6 Grounding

Every WTG foundation would have a grounding mat cast in place where the base is constructed. This consists of a copper cable mat that discharges electric energy into the earth when the WTG builds up an electrical charge by being struck by lightning or equipment malfunction. The Project substations would also have a grounding grid laid below grade, in trenches around and across the substation site, to protect equipment and personnel in the case of electrical malfunction or lightning strike.

Transmission poles also require grounding. The grounding crew would follow behind the pole assembly and erection crew installing the grounds. This crew would install the ground rods and measure the ground resistance. If the proper ground resistance is not initially achieved, they would install additional ground


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rods until the acceptable ground resistance is obtained. Testing would involve inspections to ensure that all of the Project systems are working properly and according to design and the manufacturer guarantees.

2.10 Aviation Lighting

The FAA lighting requirements vary from site to site. Factors affecting the number of WTGs to be lit include height of nacelle/blade tip, proximity to airports or airways, and the FAA office or region responsible for the permits. To date, WTG lights required for wind projects by the FAA are strobes, steady red, or combinations, either independent or sequenced together. The type of bulbs used in the lighting generally rests with the Project proponent. Currently, the new light emitting diode (LED) lights offer very long life and low current draw but are premium priced. Until FAA requirements are known for this project, a good rule of thumb for preliminary permitting estimates that every sixth WTG would need to have FAA lighting. The threshold for FAA aviation obstruction lighting for the WTG structures, like other structures over 200 feet above ground level, required by the FAA is addressed in the February 1, 2007 FAA Advisory Circular (AC 70/7460-1K). This guidance has specific requirements regarding lighting of WTGs and MET towers. Once the NEPA process has progressed to the point where the final WTG layout has been determined, the FAA Form 7460.1 would be submitted for each structure taller than 200 feet above ground level. After review, the FAA would issue a determination as to which WTGs and MET towers would require obstruction lighting. Typically, obstruction lighting for a wind energy project includes medium-intensity synchronized red strobe lights on WTGs, which only flash during darkness (see Figure 2-3). MET towers may require white flashing lights, 20,000 candelas during the day and 2,000 candelas during the night. The WTGs lights would be installed on top of the nacelle prior to installation on the tower. Because they would be installed on the top of the respective nacelles, they would be partially shielded from the ground while providing full visibility to aircraft. CPR will work with the FAA to implement a lighting minimization strategy that may be similar to the strategy successfully implemented in Tehachapi, California, on the Alta Wind Energy Center turbines in 2014.

Figure 2-3. Typical WTG obstruction lighting.


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2.11 Site Stabilization, Protection, and Reclamation Practices

The final phase of construction is cleanup and reclamation of areas disturbed by construction but not required for facility operations and maintenance. Areas that have been temporarily disturbed by grading or other earth-moving activities would be restored to the original contours of the land to the extent possible and consistent with future operating needs. Reclamation work may consist of recontouring eroded areas, extending water bars, creating berms, installing rock barriers, establishing vegetation, and applying mulch to provide additional erosion control. Ungraded areas disturbed only by overland travel would be assessed in coordination with BLM to determine if reclamation would be needed for recovery of the area.

Disturbed areas which are not needed for operation or maintenance would be revegetated. Temporary disturbance areas on BLM-administered lands would be revegetated using seed mixtures and techniques developed in consultation with the BLM. The Construction Reclamation Plan will outline the criteria and monitoring protocols that would be used to assess the success of the revegetation efforts and to determine whether additional reclamation efforts are needed. Noxious weed control would continue on-site during the revegetation efforts, as well as a long-term management strategy development to prevent the induction of noxious weeds throughout the life of the 30-year project. The Noxious Weed Management Plan will outline the criteria and monitoring protocols that would be used to prevent the induction of noxious weeds during construction, reclamation, and operation of the Project.


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3 RELATED FACILITIES AND SYSTEMS

3.1 Transmission System Interconnect

CPR proposes to deliver power from the Project to the CAISO electrical system at an interconnection point located near the existing Eldorado substation (see Figure 1-2). To accomplish the interconnection, the proposed electrical system for the Project would include a double circuit three-phase, 230-kV overhead transmission line that would run between the Project substations to a proposed switch yard in eastern NV-2 and then run northeast to the point of interconnection near the Eldorado substation. The following material addresses the BLM’s POD information requirements related to the transmission interconnection. The project’s transmission system will be designed in accordance with all current and applicable rules, regulations, codes, and statutes issued and adopted by appropriate federal, state, county, and local regulatory agencies and in accordance with applicable requirements of Southern California Edison and Gridliance West TransCo. In cases where different agencies have different requirements for the same design, CPR would design to the more stringent of the requirements.

3.1.1 Existing and Proposed Transmission System

Building a new 230 kV transmission line near the existing SCE Eldorado-Mojave 500-kV transmission line, which passes from northeast to southwest between sites NV-1 and NV-2, would be the preferred option at this time, and will be the primary power transmission line for the Crescent Peak Wind Project (see Figures 1-2 through 1-7).

The proposed transmission system would be constructed in a 100-foot-wide ROW that would run between the proposed Project substations at each site to the point of interconnection to the BOB substation, near the Eldorado Substation. Additional alternative ROW transmission pathways from the Project to the final interconnection point may be considered.

The proposed transmission line would be supported by using either single steel poles or double wood poles. The distance between each pole structure would be in the range of 250 to 500 feet, depending on the terrain and type of pole structure used. The transmission line and poles would include devices to prevent raptor perching, including anti-perching triangles, and surge arrestor caps.

3.1.2 Substations

The project substations would increase the voltage of the electricity from approximately 34.5 kV as used in the Project collection system to the voltage specified by CAISO for the interconnection. CPR has identified 230 kV as the appropriate voltage of the interconnection.

The energy generated by the WTGs would be delivered to the Project substations via the electrical collection system described in Section 2.9. The substation component equipment would include circuit breakers, power transformers, bus and insulators, disconnect switches, relays, battery and charger, surge arrestors, alternating and direct current supplies, control house, metering equipment, SCADA, grounding, associated control wiring, and possibly a shunt reactor, capacitor, and metering equipment. Overhead conductors from the electrical collection system would carry the 34.5 kV power into the Project substations. Other overhead conductors would carry 230-kV power from the Project substations to the BOB switchyard.


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Each substation site would be surrounded by 8-foot-high, chain-link fence topped with barbed wire. Each would be equipped with an outdoor downcast lighting system. Warning signage would be mounted on the fence and would include “Keep Out,” “Danger,” and “High Voltage.” A small control building would exist within each substation for electrical metering equipment, and the SCADA system for the substation. Riser poles at each substation connection point would have a pole-top, three-phase disconnect switch (operable from the ground), surge protection, insulated cable terminations and jumper wires, wildlife boots (a protective covering over cable terminators to protect birds from accidental electrocution), and lightning arrestors.

3.1.3 Status of Power Purchase Agreements CPR has not yet completed (an) agreement(s) for sale and purchase of power (PPA) generated at the Project. The market for a PPA for the Project would be all California and Nevada investor-owned utilities and municipal utilities as well as corporate buyers (such as Google, Amazon, Tesla, Apple and the like)), Community Choice Aggregators. and municipal utilities. It is common practice in the wind industry to complete power purchase agreements after key permits for a project have been obtained and after the Interconnection Study 2 results have been released (scheduled to be released Nov 22, 2017).

3.1.4 Status of Interconnect Agreement

The Project has worked with CAISO, Valley Electric (now Gridliance West TransCo), and SCE on a plan for interconnection of up to 500 MW. The Project is partaking in CAISO’s interconnection process in Cluster 9 and request for interconnection and deposit was submitted in April 2016. The Project has posted a substantial monetary deposit in April 2017 and are scheduled and ready to post another deposit in early 2018. The Project is in a favorable situation being able to take advantage of existing electric infrastructure to connect to Bob switching station, now understood to be under construction by GridLiance. CPR recently initiated a dialogue with NV-Energy and we are investigating a second option to interconnect directly to NV-Energy facilities to cost efficiently serve loads in Nevada.

3.2 Meteorological Towers

There are currently seven MET towers installed in the project area. These towers would be left in place during the development phase. This will allow CPR to continue to enhance the wind resource database.

Two of the currently permitted MET tower locations are also permitted for Sonic Detection and Ranging (SoDAR) remote sensing devices. These devises typically are located close to access existing roads and have minimal disturbance “footprints” of less than 15 × 15 feet.

At the end of the development period, the 8 existing MET towers would each either be upgraded to become permanent MET towers or, if an existing MET tower is located at a planned wind turbine location, it would be used as wind turbine site calibration tower during the development and early construction period and then removed. In addition, up to 13 additional MET towers locations would be constructed in advance of the turbine construction phase, with a goal of bringing the total number of MET towers to somewhere between 16 and 20 towers, which would allow for all planned wind turbines to be within 1.5 miles (2.5 km) of a MET tower. This will also allow for site calibrations prior to turbine erection.

Once turbines are constructed, permanent MET towers would be required to be installed on every major turbine row and/or one permanent MET tower for every 20 to 30 wind turbines installed at the Project, to measure ambient weather conditions and to evaluate the performance of the WTGs. These readings


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would include wind speed and direction, barometric pressure, humidity, and ambient temperature. The permanent MET towers and their associated access roads would be sited within the WTG array corridors. These permanent towers would be installed prior to the installation of the WTGs and remain throughout the operational term of the Project.

CPR anticipates using guyed monopole (temporary), guyed lattice (temporary or permanent), or non-guyed lattice (permanent) MET towers. The MET towers would be equipped with anti-perching devices on horizontal surfaces to minimize perching and nesting by birds and with BLM-approved guy-wire markers at sufficient spacing to ensure visibility. All remote sensing devices would be either mounted on a trailer or set directly on the ground, with optional fencing to prevent vandalism. All permanent MET towers would have a concrete/rebar foundation. A small access road would be constructed to each permanent MET tower site to allow for installation, maintenance, and data collection. Appropriate fencing would be installed around guy-wire anchors if determined necessary by the BLM.

3.3 Other Related Systems

In addition to underground and overhead electric cabling and transmission facilities, the Project would include communication systems. The proposed communications system would allow local control of the WTGs, both at each WTG and in the control room at each substation. It would also allow remote control of the WTGs and substations via authorized remote Internet access to the communications system. Each individual WTG would come equipped with an integrated SCADA system that is capable of controlling the WTG. However, the WTG control systems must be able to coordinate with the rest of the system. To accomplish this, each WTG within a project site communicates with a central control system at the site substation that can monitor and control all of the WTGs at that site simultaneously. Most WTG suppliers supply a control system capable of doing this. A few of these systems are capable of communicating with and controlling equipment in the substations.

If required by the final selection of WTGs, CPR may need to install a separate communications monitoring and control system, which is capable of providing the overall system monitoring and control function, along with providing a systems interface at the established control center or on a personal computer authorized to log into the system, regardless of its location. The proposed communications system would consist of the following:

WTGs would communicate via Ethernet over fiber-optic cables run adjacent to the electrical collection system, either on the same overhead poles or in the same underground trenches. Industrial Ethernet switches would make up the network backbone and one switch would be installed inside each WTG tower.

MET tower communications would be established in the same manner as the WTGs. Additional enclosures may be required inside the bottom of the towers to house the Ethernet switches and fiber-optic terminations. Wireless connections will be used to minimize environmental impact where appropriate.

The fiber-optic communication lines would terminate inside the substations into an Ethernet switch. All of the substation equipment relays, programmable logic controllers, etc., would be connected to the control system. If required, high-speed data acquisition may be provided, but it would require a separate physical network to be used to protect the main control room network from the higher bandwidth requirements of the high-speed data.

A high-speed radio link would be installed between each on-site control room and the closest available high-speed Internet service provider. A hard-wired link would also be established, if necessary, to serve as a backup to the radio link.


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4 OPERATIONS AND MAINTENANCE

CPR would initiate long-term operation and maintenance of the Project once construction and testing of the Project facilities are completed. The Project is expected to have an operating life of at least 30 years. Technical advances in wind energy equipment often result in replacement of WTGs at a specific project with new equipment (a process termed repowering), resulting in an extension of the operating period of the Project.

4.1 Operations and Facility Maintenance Needs

The proposed Project would require an on-site operations and maintenance presence during its operating life. A workforce would keep the Project facilities in proper working order. More specific information about the operation and maintenance crew and their activities is provided in Sections 4.2 and 4.3. The maintenance and operation of the facility would be consistent with the existing permitted land uses including grazing and dispersed recreation. Public access is not anticipated to be restricted unless vandalism becomes a significant problem or there is a threat to public safety.

In general, the WTGs would operate during all hours of the year when the wind is blowing at sufficient speeds to operate the WTGs, except during times when the DOD has requested a curtailment related to testing activities in the area. CPR has collected regional and project-specific meteorological data within the project area. Each WTG would likely require scheduled mechanical and electrical maintenance. Routine maintenance would occur at an interval dictated by the manufacturer, and each WTG would receive an annual inspection. Long-term monitoring of the Project would also require periodic visits by consulting scientists involved in biological monitoring, meteorological station maintenance, and vegetation control.

After the proposed Project facility is commissioned and deemed operational, limited materials would be required for Project operations. The only materials that would be brought onto the site would be those related to maintenance or replacement of elements, e.g., nacelle or WTG components, lubricants, and electrical equipment. Potentially hazardous materials used for operations and maintenance of the WTGs and associated facilities may include mineral oils (WTG lubricant and transformer coolant), synthetic oils (WTG lubricant and gear oil), general lubricants, general cleaners, ethylene glycol (anti-freeze), vehicle fuel, and herbicides for weed control. These materials would be stored at the O&M facility. Disposal of liquid and solid waste produced during operation of the Project facility and the transmission line would be done so as not to impact human health and the environment.

4.2 Maintenance Activities

Long-term O&M activities for the Project would include the following functions:

Routine maintenance of the WTGs would be necessary to optimize performance and to detect potential malfunctions. Operation and maintenance procedures would be established that define specific routine WTGs maintenance and inspection activities based on the WTG manufacturer’s recommendations.

The Project substations would include routine, scheduled equipment maintenance, grounds keeping, and emergency maintenance in the event of equipment failure. Step-up transformers and pad-mounted transformers would be maintained as part of normal operations and maintenance activities.


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Periodic inspection and/or maintenance of underground electrical collection lines may be required during the life of the Project. Maintenance activities would be conducted pursuant to prudent utility practices.

The transmission line would be inspected on a regular basis by ground or aerial patrols, and maintenance would be performed as needed. Emergency maintenance would involve prompt movement of crews to repair or replace any damaged equipment. Specific training would be provided to all maintenance crews instructing them on plans, procedures, and policy requirements.

The site access roads would be inspected on a regular basis. When necessary, repairs would be performed to the permanent SWPPP features to assure continued control of storm water runoff and erosion. Typically, simple grading and compacting of the roads around trouble spots is adequate to return the roads to as-built conditions. Occasionally, especially after severe storms or winters, it may be necessary to bring in a third-party contractor to perform general maintenance of the road system.

Once reclamation is complete and vegetation is stable following construction of the Project facility, noxious weed surveys would continue as is necessary. Routine maintenance of the Project facility would include weed monitoring and treatment as outlined in Section 1.3.11.

When access is required for maintenance and repairs, the same precautions identified for original construction would be followed. Crews would be instructed, in accordance with specific maintenance plans and procedures, to protect livestock, crops, vegetation, wildlife, and other resources of significance. Restoration procedures following completion of repair work would be similar to those prescribed for original construction.

Some water might be used for WTG blade washing during project operations. On average, the blades on each WTG might need to be washed about once a year due to build up on the blades from dirt, insects, etc. However, blade washing is very dependent on the area that the WTGs are located. For example, wind energy project sites located near agriculture, livestock, etc., require more cleaning than those wind projects located in high-altitude, dry areas. Since the Project is located in a higher elevation and a drier climate, the WTG blades may need to be cleaned only about every 2 years or less frequently. With the sophisticated software monitoring the WTG performance, diminished performance can be detected and blade cleaning can be determined based on need rather than as a part of a routine maintenance plan. After the Project has been operating for a period of time, a blade washing plan can be determined. The amount of water used per WTG for blade washing varies, but typically, only clean, non-potable water is used. Depending on the cleaning needs of the WTG model, some blades may require a biodegradable solvent/cleaner to be added to the water during the cleaning process. Any solvents utilized during the blade cleaning process would be an environmentally safe and biodegradable.

4.3 Operations Workforce, Equipment, and Ground Transportation

The Project operations is estimated to employ approximately 15 to 25 people. The operations work force would include an on-site facility manager, administrative support, SCADA instrument and WTG technicians, and other operations and maintenance personnel. The majority of the employees would be full-time, and would be employed throughout the anticipated life of the Project.

Equipment used by the operations workforce would include pickup trucks, sport utility vehicles, boom trucks, welding rigs, motor graders and water trucks (road maintenance), and all-terrain vehicles. All


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equipment used in the operation of this project would be maintained and inspected regularly by authorized and trained facility staff. A complete schedule would be established before the start of operations.

The access roads built and used during the construction phase would be maintained throughout commercial operations. During operations, all Project access roads would be evaluated and graded as necessary to facilitate operations and maintenance. In addition to grading, the application of new gravel may be necessary to maintain road surfaces. Water would be used as needed for dust control.


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5 ENVIRONMENTAL CONSIDERATIONS

5.1 General Description of Site Characteristics and Potential Environmental Issues

To assess Project environmental feasibility and environmental issues inherent in constructing and operating a large-scale wind energy facility, CPR retained SWCA Environmental Consultants (SWCA) to conduct a constraints analysis (SWCA 2011) and begin pre-construction surveys. Information was collected from a variety of sources, including published literature, reports, maps, aerial photography, databases, public records, and available geographic information system (GIS) data sets, as well as a field reconnaissance visit and surveys. Using this information, risk categories were identified for important resources and a risk level assigned based on the potential for each issue to negatively affect the implementation, cost, schedule, or permitting for wind energy development. Because the risk levels are based entirely on the evaluation of existing data, there is a potential that detailed site-specific studies would reveal additional risks, or elevate or diminish currently identified risk levels. SWCA’s comprehensive study included the resource categories shown in Table 5-1.

Table 5-1. Resources Analyzed

Resource Rationale

Land use (including BLM, private, towns, Areas of Critical Environmental Concern, National Preserves, Wilderness, other Federal and State Lands)

Lands within the four project sites are primarily undeveloped and typical of this area of Clark County. None of the land uses occurring within the project sites would preclude renewable energy development.

Ground transportation (roads and railroads)

Several miles of BLM-maintained roads occur within the project sites. No railroad alignments or Clark County–maintained roads occur within the project sites. The proposed project would not affect existing transportation or access routes.


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Table 5-1. Resources Analyzed (Continued)

Resource Rationale

Airports and aviation (private, commercial, FAA, and military)

No Military Operation Areas or Military Training Routes have been identified over the project sites. Several airports authorized under the Airport Act of 1928 are within 50 miles of the project sites. Further consultation with the FAA and Department of Defense to complete an Airspace Obstruction Evaluation may be necessary to determine conflicts with structure heights or facility lighting.

Communications and radio facilities Three communications sites are located on BLM lands within Sites NV-1 and NV-2. Another radio communications facility is located on private land within Site NV-1. Microwave Beam Path Analysis and coordination with the facility owner/operator would be needed to avoid conflicts with facility operations.

Public services and utilities There are no public services or utilities located within the project sites. Although there are no concerns associated with existing utilities, any renewable project is dependent on the ability to distribute power to a utility. Coordination with NV Energy and the Nevada Public Utilities Commission will be required. A permit to demonstrate compliance with Utility Environmental Protection Act must be obtained.

Active mines and mining claims Several mine sites are found within the boundaries of the project sites. Coordination with claimants and validity exams of mine claims may be required prior to development.

Visual resources and Visual Resource Management (VRM) classifications

The project sites are located on lands managed as VRM Class II and Class III. A BLM Resource Management Plan (RMP) amendment would be required to change the VRM Class II. The BLM Southern Nevada District is currently in the process of updating its RMP, which may include adjusting this VRM Class. Visual Contrast Rating Analysis from Key Observation Points supported by photographic visual simulations will be needed. All temporary disturbances would be restored in accordance with BLM restoration standards. Further discussion is included in Section 5.2.

Biological resources No special or unique vegetation communities have been identified in any of the project sites. Cactus/yucca density estimates, mapping of mesquite and acacia habitat, a Noxious Weed Risk Assessment, and preparation of a Vegetation Restoration and Weed Management Plan will likely be required. The federally threatened Mojave desert tortoise has the potential to occur in the project area. Several species protected by the BLM and/or State of Nevada have the potential to occur within the project sites, including desert bighorn sheep, a species also protected as a Nevada Department of Wildlife big game species. Many species of birds are protected by the Migratory Bird Treaty Act and the Bald and Golden Eagle Protection Act. Detailed analysis for these species, as well as other State-, BLM-, and USFWS-protected species is required, and further discussion is included in Section 5.2.

Water resources Aerial photography indicates that several springs and one well are present in the project area, which may indicate presence of a wetland. Additionally, a number of ephemeral wash channels are present that may qualify as waters of the U.S. If wetlands or waters of the U.S. cannot be avoided, a jurisdictional determination and wetland delineation report should be prepared. In addition, the following permit requirements would need to be met: CWA Section 404 permit issued by the U.S. Army Corps of Engineers, Water Quality Certification under Section 401 issued by the Nevada Department of Environmental Protection, Bureau of Water Quality Planning, and a Notice of Intent and SWPPP to comply with Section 402 of the CWA.

Flood hazard zones There are no flood zones identified within the project sites.

Geologic hazard zones Several faults are known to occur within three of the four project sites. Soil testing and geotechnical studies to determine suitability to support wind energy turbines and associated infrastructure will be required.

Recreation The project sites are not located within a Special Recreation Management Area, and, therefore, fit within the Southern Nevada Extensive Recreation Management Area. No additional work is required.

Air quality The project sites are within hydrographic basins 164b, 167, and 214. National Ambient Air Quality Standards for air pollutants were reviewed, and each hydrographic basin is located within the non-attainment area for 8-hour standard for O3. The project sites are in attainment for all other pollutants regulated by the EPA. A Dust Control Permit for construction activities will be needed, along with coordination with the Clark County Department of Air Quality and Environmental Monitoring.

Table 5-1. Resources Analyzed (Continued)


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Resource Rationale

Noise Field reconnaissance and a review of available GIS data identified two to three permanent, occupied residences within Site NV-1 as potential sensitive noise receptors. Standard setback requirements and siting away from noise receptors should minimize noise issues. The PEIS recommends that proponents of a wind energy facility conduct site-specific noise analysis to obtain background noise levels and compare with anticipated project noise levels (BLM 2005).

Hazardous materials No Recognized Environmental Conditions were identified for the project sites; however, several mining operations were identified within the outer boundaries of the project sites, as well as mine shafts, prospects, adits, wells, and a corral. An American Society of Testing and Materials Standard 1527-05 Phase I Environmental Site Assessment may be required, per the prospective lender’s requirements.

Cultural resources and Native American concerns

Several cultural resources have been recorded within the project sites, and a number of these resources are likely eligible for inclusion in the National Register of Historic Places. Additionally, it is likely that there are undocumented historical and prehistoric resources within the project sites. Additional survey work will be required, as well as consultation with any local Native American tribes. Further discussion is included in Section 5.2.

Paleontological resources Miocene to Quaternary alluvium, present in two of the four sites, may have paleontological resource potential and is determined to have an unknown sensitivity; therefore, a paleontological resources museum locality search and field reconnaissance may be required.

Environmental Justice No Environmental Justice populations occur near the project area; however, because the most recent data available are from the 2000 Census, follow-up review of 2010 Census data should be conducted.

Socioeconomics The nearest populated communities to the project sites are Searchlight and Cal-Nev-Ari, Nevada. Issues for these communities are expected to be similar to those identified during the public scoping period for other wind energy projects in the area, including concerns over decreased property values and changes to the quality of life. Because the most recent data available are from the 2000 Census, follow-up review of 2010 Census data should be conducted.

The Constraints Analysis cataloged project risks in the context of the BLM’s Las Vegas Resource Management Plan (RMP) (BLM 1998) to provide a preliminary risk assessment profile of potential issues that could negatively impact the Project’s development. A summary of the Constraints Analysis by site is provided below.

5.1.1 Site NV-1

Visual resources, bats, and cultural resources are the primary environmental issues for the site. Since this site is currently designated as a VRM Class II area, wind development is not compatible. However, the BLM is currently revising the RMP, and it is likely this area will be downgraded to a VRM Class III or IV due to wind development potential. If the VRM class is not changed, development of the site would require a land use plan amendment to change the VRM class. Changing the VRM class after the RMP revision may be difficult if that change is considered and not selected as part of the RMP. Bats are a concern at most wind sites, due to the increased risk of bat mortality. Lastly, with the large amount of mines in the area, the potential for cultural resources is high at Site NV-1, which would require higher survey and mitigation efforts.

5.1.2 Site NV-2

Visual resources, bats, and birds are the primary environmental issues for the site. Since this site is currently designated as a VRM Class II area, wind development is not compatible. BLM has been in the process of revising its current RMP. If the revised RMP is processed prior to this project, it is likely this area will be downgraded to a VRM Class III or IV due to wind development potential. If the VRM class is not changed, development of the site would require a land use plan amendment to change the VRM class. Changing the VRM class after the RMP revision may be difficult if that change is considered and


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not selected as part of the RMP. Birds and bats are a concern at most wind sites, and this area contains better habitat than some of the other sites, increasing the risk of bird and bat mortality at this site.

5.1.3 Site NV-3

The only issue identified for this site is visual resources. Since this site is currently designated as a VRM Class II area, wind development is not compatible. BLM has been in the process of revising its current RMP. If the revised RMP is processed prior to this project, it is likely this area will be downgraded to a VRM Class III or IV due to wind development potential. If the VRM class is not changed, development of the site would require a land use plan amendment to change the VRM class. Changing the VRM class after the RMP revision may be difficult if that change is considered and not selected as part of the RMP.

5.1.4 Site NV-4

Birds and cultural resources are the primary environmental issues for the site. Birds are a concern at most wind sites, and this area contains better habitat than some of the other sites, increasing the risk of bird and bat mortality at this site. With the large amount of prehistoric sites in the area, the potential for cultural resources is high, which would not likely stop development, but would require higher survey and mitigation efforts. Additionally, its proximity to Spirit Mountain may require intensive Native American consultation.

5.2 Resources of Concern

Of the 19 resources analyzed in the constraints analysis (SWCA 2011) and summarized in Table 5-1 above, three of these were considered higher risk than the rest. These resources—biological resources, cultural resources, and visual resources—are discussed in detail in this section.

5.2.1 Biological Resources

Impacts to biological resources are typically one of the major concerns for the development of wind energy facilities, especially impacts to birds and bats. In March 2012, the U.S. Fish and Wildlife Service (USFWS) Wind Turbine Guidelines Advisory Committee issued its guidelines on developing effective measures to mitigate impacts to wildlife and their habitats related to land-based wind energy facilities (USFWS 2012).

The following sections detail the biological resources considered higher risk than other resources for the proposed project sites and discuss potential issues related to those resources. Biological resources that were not considered high risk, such as general vegetation and general wildlife, have been omitted from this discussion.

THREATENED AND ENDANGERED SPECIES

The USFWS is responsible for enforcing the Endangered Species Act (ESA), which provides protection for species whose populations are in peril. Within Clark County, 16 species have been listed as threatened or endangered under the ESA. Of those species, the desert tortoise (Gopherus agassizii; Threatened) is the only species with the potential to occur within parts of the project sites. A review through the USFWS Information for Planning and Conservation (IPaC) system identifies southwestern willow flycatcher (Empidonax traillii extimus; Endangered) and yellow-billed cuckoo (Coccyzus americanus; Threatened) as also having potential to occur in the area (USFWS 2015). These species require riparian habitat with open water, which does not occur in or adjacent to the project area. Therefore, they may rarely pass through, but are not supported within the project area.


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The USFWS emergency listed the Mojave population of the desert tortoise as endangered on August 4, 1989 (54 Federal Register [FR] 32326) in response to a dramatic decrease in numbers of the tortoise throughout its entire range. The tortoise was then proposed under normal listing procedures on October 13, 1989 (54 FR 42270) and subsequently listed as threatened on April 2, 1990 (55 FR 12178). The State of Nevada has listed the desert tortoise as a fully protected species and has also designated the species as its official state reptile. As part of the listing, critical habitat was designated in 1994, which are areas that contain habitat vital to the survival and reestablishment of the species. Disturbance of critical habitat requires consultation with the USFWS under the ESA. The Paiute-Eldorado Critical Habitat Unit shares the eastern border of Site NV-4.

While the majority of the project sites occur at elevations higher than typical tortoise habitat, a total of approximately 700 acres of desert tortoise habitat occurs within the four project sites and along the 230-kV gen-tie line to the Eldorado Substation. Tortoise was recorded in Site NV-1 in 2005, and several have been recorded in nearby areas in the Piute Valley to the east. The BLM will determine any additional information needed to evaluate Project impacts to federally listed threatened and endangered species, but it is anticipated that this will include desert tortoise surveys following USFWS protocol (USFWS 2012), preparation of a biological assessment, and formal consultation with the USFWS if turbines or other Project components are within tortoise habitat, and possibly preparation of a desert tortoise relocation or translocation plan.

SENSITIVE SPECIES

The BLM and the State of Nevada also maintain lists of sensitive and protected species, respectively. The Statewide Wildlife Survey Protocols (BLM 2014) includes a list of sensitive species in Nevada. Additionally, the USFWS IPAC report for the project area indicates that other special-status species may have potential to occur in the study area. Of the sensitive and special-status species with the potential to occur, preliminary assessment indicates that 30 species have a moderate to high potential to occur within at least one of the four project sites. These species are shown in Table 5-2.

Table 5-2. Sensitive Species with potential to occur in the Project Area.

Common Name Scientific Name Status*

Allen's big-eared bat Idionycteris phyllotis SS

Banded gila monster Heloderma suspectum cinctum SS

Bendire's thrasher Toxostoma bendirei SS, BCC

Big brown bat Eptesicus fuscus SS

Big free-tailed bat Nyctinomops macrotis SS

Bighorn sheep Ovis canadensis SS

Brazilian free-tailed bat Tadarida brasiliensis SS

Brewer's sparrow Spizella breweri SS, BCC

Burrowing owl Athene cunicularia SS, BCC

California leaf-nosed bat Macrotos californicus SS

California myotis Myotis californicus SS

Cave myotis Myotis velifer SS

Common Name Scientific Name Status*

Ferruginous hawk Buteo regalis SS

Fringed myotis Myotis thysanodes SS

Golden eagle Aquila chrysaetos SS


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Greater western mastiff bat Eumops perotis californicus SS

Hoary bat Lasiurus cinereus SS

LeConte's thrasher Toxostoma lecontei SS, BCC

Loggerhead shrike Lanius ludovicianus SS, BCC

Long-eared myotis Myotis evotis SS

Long-legged myotis Myotis volans SS

Pallid bat Antrozous pallidus SS

Pinyon jay Gymnorhinus cyanocephalus SS, BCC

Sage thrasher Oreoscoptes montanus SS, BCC

Silver-haired bat Lasionycteris noctivagans SS

Spotted bat Euderma maculatum SS

Townsend's big-eared bat Corynorhinus townsendii SS

Western pipistrelle Pipistrellus hesperus SS

Western red bat Lasiurus blossevillii SS

Western small-footed myotis Myotis ciliolabrum SS

*SS = BLM Sensitive Species; BCC = USFWS Bird of Conservation Concern

As mentioned above, desert tortoise are known to occur within at least one of the project sites and within nearby areas in the Paiute Valley. During initial avian surveys in 2011, two sensitive birds designated as having a moderate to high potential to occur in the project sites were recorded; golden eagle and loggerhead shrike. The burrowing owl was not recorded during avian surveys; based on field surveys finding less suitable habitat than expected, it is likely that the potential for this species to occur in the project area was overestimated. As discussed below, the project sites contain thousands of acres of crucial bighorn habitat, and several were seen during helicopter raptor nest surveys, particularly in areas in and around Site NV-4. Of the species that have yet to be seen in the project sites—banded Gila monster, common chuckwalla, and Brazilian free-tailed bat—all are expected to occur in the project area to some degree.

The BLM will determine any additional information needed to evaluate project impacts to both BLM- and State-protected species, but it is anticipated that they would require sensitive plant surveys within the project footprint. Depending on the size of the project, the BLM may also require a Habitat Assessment to delineate a survey area for sensitive plants based upon the presence of suitable habitat for target species within the project site. All additional sensitive species work is covered under their respective resource sections.

BIG GAME SPECIES

The desert bighorn sheep is listed as a BLM special-status species and is also regulated by Nevada Department of Wildlife (NDOW) as a big game species. Desert bighorn sheep occupy mountains and foothills containing shrub-steppe or open grassland communities and require steep, rocky terrain such as cliffs and talus slopes for suitable habitat. Within Hunt Unit 263, this species is often found in the McCullough Range between McCullough Pass and Black Mountain (NDOW 2010).

Potential effects on big game species, such as bighorn sheep, resulting from wind energy development include: displacement from suitable habitat; interference with behavioral activities such as migration, foraging, or reproduction; and reduction in habitat quality (BLM 2005).

Bighorn sheep habitat data provided by the BLM (1998) show a total of 9,497 acres of crucial desert bighorn sheep habitat and 7,491 acres of desert bighorn sheep winter range occurs within the project sites.


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Several bighorn sheep were seen during helicopter raptor nest surveys, particularly in and around Site NV-4.

BATS

Currently, no federally protected bat species are within Nevada; however, five bat species are protected by the State of Nevada. Additionally, the BLM PEIS (BLM 2005) states that:

Turbines should not be located near known bat hibernation, breeding, and maternity/nursery colonies, in migration corridors, or in flight paths between colonies and feeding areas.

Bat use of the project area should be evaluated, and the project should be designed to minimize or mitigate the potential for bat strikes. Both macro- and micro-siting options can be considered to minimize impacts to bats.

Due to the highly mobile nature of bats and limited study of their current distribution, there is potential to identify a number of bat species that disperse throughout the study area. It is likely that a variety of bat species use the Colorado River as a migratory corridor, as it provides ample water and forage in the dry Southwest, especially for tree-roosting species. Analysis of individual sites is predominantly based upon the diversity of available habitat as identified by Southwest Regional Gap Analysis Project (SWReGAP) (U.S. Geological Survey 2004). A moderate amount of cliff habitat and numerous mine adits, particularly at Site NV-1, are present throughout the project sites, which could provide roosting habitat for pallid bat (Antrozous pallidus), Townsend’s big-eared bat (Corynorhinus townsendii), big brown bat, California myotis (Myotis californicus), western small-footed myotis (M. ciliolabrum), western mastiff bat (Eumops perotis), big free-tailed bat (Nyctinomops macrotis), and Brazilian free-tailed bat. It is anticipated that acoustic bat surveys (1 to 2 years) and possibly mist-netting or harp-trapping will be needed throughout the project sites. Radar surveys are possible, but unlikely.

AVIAN

The regulatory framework for protecting birds includes the ESA, the Migratory Bird Treaty Act of 1918 (MBTA), the Bald and Golden Eagle Protection Act of 1940 (Eagle Act), and Executive Order 13186. The PEIS discusses the ESA in Section 4.6.5.1, and other regulations stated above are discussed in Section 4.6.2.2.6 (BLM 2005). All of the sensitive birds as well as numerous other bird species that likely occur in the project sites are protected by the MBTA. The MBTA prohibits the take of migratory birds and does not include provisions for allowing unauthorized take. Although it is not possible for the USFWS to absolve individuals, companies, or agencies from liability, the USFWS and Department of Justice have executed prosecutorial discretion in the past for those who have made good faith efforts to avoid take of migratory birds (USFWS 2012). The Eagle Act is similar to the MBTA in that it prohibits the take of bald eagles (Haliaeetus leucocephalus) and golden eagles. The USFWS published a Final Eagle Permit Rule (Eagle Permit Rule) on September 11, 2009, under the Eagle Act, authorizing limited issuance of permits to take bald eagles where the take is associated with but not the purpose of an otherwise lawful activity. However, they went on to say that golden eagle take permits (herein Take Permit) would not be issued until better data on the species were obtained and a process for issuing permits was put in place. Since that time, the USFWS has issued numerous guidelines, recommendations, and gray literature describing the compliance process, often times contradicting one another. Most recently the USFWS issued their Eagle Conservation Plan Guidance: Module 1 – Land-based Wind Energy, Version 2 (ECPG) in April 2013 (USFWS 2013).

The ECPG suggests that any project with potential to take bald or golden eagles should apply for a Take Permit. Should CPR seek to obtain a Take Permit once available, it is recommended that a Bird and Bat Conservation Strategy (BBCS) and Eagle Conservation Plan (ECP) be prepared that meet the intent of the Guidance for BBCSs and ECPs. The BBCS and ECP should outline any additional data collection needs,


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avoidance and minimization measures, post-construction monitoring, and adaptive management. The BBCS and ECP should be completed in coordination with the USFWS (Ecological Services and Migratory Birds Offices) to ensure it meets their requirements to protect the species.

Little is known about impacts to avian species from operation of wind energy facilities in arid desert habitats. Raptors are of particular concern because they are slow to recover from anthropogenic impacts due to their long lifespan, long time required to reach sexual maturity, and low reproductive rate relative to other bird species. Based on preliminary data, the Project does not appear to be located in a migratory pathway for raptors. Impacts to other groups of birds have been less worrisome. Passerines make up the majority of mortalities at most wind generating facilities (AWWI 2017) and may most commonly include horned larks (Eremophila alpestris), sparrows, and warblers (Erickson 2003). Mortalities at wind generating facilities, however, appear to be several orders of magnitude smaller than other anthropogenic sources of mortality, and, aside from a few raptor species, does not seem likely to lead to population-level declines (AWWI 2017).

Aside from concerns about wintering and migratory habitat for raptors, risk to avian species would likely be highest in areas that provide unique habitats in otherwise homogenous vegetation communities (e.g., the Colorado River in the middle of the Mojave Desert). Additionally, placing a wind energy facility in areas that provide habitat for sensitive avian species could also equate to elevated levels of risk.

Aerial raptor nest surveys, which included bald and golden eagles, were completed in 2011 and again in 2016/2017. In December 2017, the four project sites and a 10-mile radius around them were surveyed by helicopter following USFWS-recommended protocol (USFWS 2013). Due to concerns over disturbing desert bighorn sheep (Ovis canadensis nelsoni) during the lambing season, the second occupancy surveys of the project sites and 10-mile buffer were conducted via ground-based surveys between February and March 2017. In total, 499 raptor species/raven nests were documented, the vast majority of which were observed outside of the project site boundaries. Of the 17 raptor nests located within the project site boundaries, three of these were occupied during the 2017 breeding season: one occupied (activity status unknown) red-tailed hawk (Buteo jamaicensis) nest in Site NV-4, one active (adult incubating) red-tailed hawk nest in Site NV-2, and one active (adult incubating) golden eagle nest in Site NV-2.

One hundred thirty-three of the raptor nests recorded during the 2016/2017 surveys were golden eagle nests; however, ten of those nests were occupied but not active and an additional eight nests were active with adults incubating eggs or brooding very young chicks. Two unoccupied golden eagle nests and three unoccupied possible golden eagle nests (species undetermined) were observed in Site NV-4. One unoccupied possible golden eagle nest was located in Site NV-2. The nearest occupied, but inactive golden eagle nests are 0.56 mile (0.90 km) southwest of Site NV-4.

Other pre-construction avian field studies began on November 3, 2015, and were completed on October 26, 2017. Avian surveys at the four project sites included:

eagle use counts

large-bird use counts

small-bird use counts

golden eagle prey base surveys

Avian use counts and golden eagle prey base surveys commenced on November 3, 2015 and were completed on October 26, 2017. Data collected for these surveys will be analyzed to calculate avian use within the project sites, as this is the primary quantifiable measure for predicting risk at wind energy facilities (USFWS 2013). Eagle use data will also be used to generate model-based predictions of annual eagle fatalities for the project and to map eagle flight paths (inclusion recommended in the ECPG) across the project sites to identify areas of eagle concentration.


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Data analysis for the Project is ongoing and will be included in the final avian report. In general, bird diversity is low throughout the four project sites. Several sensitive species were documented within the project sites, but use of those species is expected to be generally low. Golden eagle use and golden eagle nests was identified in proximity to the proposed project.

5.2.2 Cultural Resources

Cultural resources in Nevada are protected by federal and state laws, regulations, and statutes. Section 106 of the National Historic Preservation Act (NHPA), as amended in 2000, requires government agencies to take into account the effects of their actions on properties listed or eligible for listing in the National Register of Historic Places (NRHP). To determine whether a project would affect NRHP-eligible properties, cultural resources must be inventoried and evaluated for eligibility for inclusion in the NRHP. The BLM, in consultation with the Nevada State Historic Preservation Officer (SHPO) and in accordance with the regulations set forth in 36 CFR 800, will determine the area of potential effects and the methods to be used during identification efforts.

Cultural resources also include traditional cultural properties, defined as properties that are important to a community’s practices and beliefs and that are necessary for maintaining the community’s cultural identity. Cultural resources refer to both human-made and natural physical features associated with human activity and, in most cases, are finite, unique, fragile, and nonrenewable. Cultural resources that meet the eligibility criteria for the NRHP are considered “significant” resources and must be taken into consideration during the planning of federal projects. Federal agencies are also required to consider the effects of their actions on sites, areas, and other resources (e.g., plants) that are of religious significance to Native Americans as established under the American Indian Religious Freedom Act (PL 95-341). Native American graves and burial grounds are protected by the Native American Graves Protection and Repatriation Act (PL 101-601).

Although cultural resources can generally be avoided and impacts minimized through standard procedures and mitigations, projects are still subject to compliance with the state and federal requirements described above. Cultural resources surveys have not yet been conducted for this project, but cultural resources are known to exist in the four project sites. The project sites, particularly around Site NV-1, have been mined for more than 100 years, and numerous mining sites have been recorded. A significant number of these resources are likely to be eligible for inclusion in the NRHP. Historical trash scatters and prehistoric lithic scatters and sites, including rockshelters, petroglyphs, and quarry sites, are known throughout portions of the project sites as well, particularly around Site NV-4. Additionally, it is expected that unrecorded sites exist throughout the project sites, especially in washes and canyons near springs and seeps. A Class I and Class III cultural resources inventory will be needed in order to determine the effect of the proposed Project on resources within the area of potential effects. The BLM should consult with Native American tribes about concerns they may have about the project area.

5.2.3 Visual Resources

Visual resources (the landscape) consist of landform (topography and soils), vegetation, bodies of waters (lakes, streams, and rivers), and human-made structures (roads, buildings, and modifications of the land, vegetation, and water). These elements of the landscape can be described in terms of their form, line, color, and texture. Normally, the more variety of these elements there is in a landscape, the more interesting or scenic the landscape becomes, if the elements exist in harmony with each other.

Through the land use planning process, the BLM sets objectives for the management of landscape preservation and change. All lands are placed into one of four Visual Resource Management classes that identify the degree of acceptable landscape change or alteration, giving consideration to the scenic value of the landscape and other resource values and uses of the land. Class I objectives are established in areas


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where no landscape change is desired. Class IV objectives are set for landscapes where the BLM manages for uses that will result in substantial landscape changes (e.g., mining, energy development, wind farms). Classes II and III allow for varying degrees of landscape preservation and change between Classes I and IV.

VRM Class I Objective. Preserve the existing character of the landscape. The level of change to the characteristic landscape should be very low and must not attract attention.

VRM Class II Objective. Retain the existing character of the landscape. The level of change to the characteristic landscape should be low.

VRM Class III Objective. Partially retain the existing character of the landscape. The level of change to the characteristic landscape should be moderate.

VRM Class IV Objective. Provide for management activities that require major modification of the existing character of the landscape. The level of change to the characteristic landscape can be high.

The visual impact of wind turbines is often raised as an issue during project development. The risk for each site is determined by evaluating the proximity to viewers with greater sensitivity and whether the potential effects on visual resources would meet the BLM VRM Class objectives established within each of the project sites. The installation of wind turbines would result in changes to the aesthetics of the landscape with the addition of tall towers and rotating blades. The access roads, construction disturbance, vehicles, and dust would also impact visual resources. The project area already contains gravel roads, and construction/reconstruction of additional roads would result in similar contrasts. Per FAA guidelines, a certain number of turbines must have flashing lights, which would create a visual impact.

Sites NV-1, NV-2, and NV-3 are located on lands predominantly managed under VRM Class II. The level of change to the characteristic landscape should be low, but would still require a BLM land use plan amendment to change the VRM Class II designation within the project sites. The BLM Southern Nevada District is currently in the process of updating its RMP, which may include adjusting this VRM Class. The remaining portions of the project sites, including all of Site NV-4, are managed under VRM Class III, which would require no change to the BLM land use plan. However, Site NV-4 is located 5 miles west of the community of Cal-Nev-Ari, Nevada, which means there would be greater sensitivity to changes in the characteristic landscape visible from this community. Visual Contrast Rating Analysis from Key Observation Points supported by photographic visual simulations will be needed.

5.3 Design Criteria Proposed by Applicant and Included in POD

CPR has actively worked to reduce potential impacts to environmental resources and address other constraints during the planning and development of the Project. CPR will incorporate as many BMPs from the NEPA document as possible or appropriate. All Project activities will be completed pursuant to all appropriate federal and state laws, regulations, local policies and ordinances. This includes but is not limited to: FLPMA, NEPA, the Clean Air Act, Section 7 of the Endangered Species Act, Section 106 of NHPA, State Historic Preservation Act, Native American consultation, the Antiquities Act, the Clean Water Act, etc., in order to minimize or avoid any damage or undue degradation to the land, water, air, or resources as a result of the Project.

If the final ROW is approved, CPR will schedule a preconstruction meeting with the BLM and all key subcontractor department leads to discuss all terms and conditions of the ROW grant(s) which may include the WTG sites, transmission line, and road access. After the completion of the NEPA document, it may be determined that specialized training may be required for individual workers prior to start of


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project. If this is determined to be necessary, a training plan will be developed for approval by the BLM, and training classes will be held with each of the appropriate personnel prior to their commencement of work on the job site. A certification process will be developed with a certificate of their completion kept on file on the job site for inspection. CPR will ensure that a copy of the all ROW grants, terms and conditions, BMPs, the Final POD, and other approved documents along with a list of appropriate contact numbers for the BLM office will be maintained in the construction office during construction and remain on file during the life of the grant.

As standard practice, CPR applies impact-minimization principles to the siting, planning, and design of its wind projects. The wind industry understands that use of these principles makes for better wind projects and facilitates the permitting and environmental review process. In addition to representing a proactive, responsible approach to wind energy development, this practice is consistent with the wind energy program policies that the BLM has established. The following sections include additional design criteria proposed by CPR.

5.3.1 Facility Commitments

Use existing roads and utility corridors wherever possible.

Use tubular, conical steel turbine towers for the wind turbines; tubular towers do not provide locations for raptors to perch, which decreases the risk of collisions with turbine blades.

Use underground transmission collection systems where possible; this reduces the visual impact of overhead transmission as well as the potential impact to avian and bat species from collisions.

5.3.2 Construction, Operation, and Decommissioning Commitments

Construction vehicle movement within the Project boundary would be restricted to predesignated access, contractor-required access, and public roads.

A qualified third‐party contractor will serve as an Environmental Inspector to ensure compliance with all Project authorizations, permits, and approvals.

In construction areas where ground disturbance is unavoidable, surface restoration would consist of recontouring and reseeding with a BLM-approved seed mix. A full list of BMPs would be included in the Project’s Construction, Operation, and Maintenance Plan.

For all excavations, the crews will be instructed to minimize the period of time that a trench or hole is open; however, in some cases excavations will be left open overnight or for several days, (e.g., for turbine foundations). For all excavations left overnight, measures will be put in place to prevent injury to wildlife. Those measures include either covering holes or installing temporary visible barriers around trenches/holes.

A Traffic Management Plan will be followed for the site access roads to ensure that no hazards would result from the increased truck traffic and that traffic flow would not be adversely impacted. This plan shall incorporate measures such as informational signs, flaggers when equipment may result in blocked throughways, and traffic cones to identify any necessary changes in temporary lane configuration. Additionally, CPR would consult with local planning authorities regarding increased traffic during the construction phase, including an assessment of the number of vehicles per day and their size and type.

A Lighting Plan will be followed to ensure that lighting is installed to meet safety and FAA requirements.


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5.3.3 Resource Conservation Measures

CULTURAL RESOURCES

To minimize impacts to cultural resources, CPR will implement the following measures:

A Cultural Resources Monitoring and Discovery Plan will be created, which describes procedures to follow, in accordance with state and federal laws, if archaeological materials or human remains are discovered. Adherence to this plan will protect cultural resources that are discovered, assist construction personnel in complying with applicable laws, and expedite the Project in the event of discovery.

Direct avoidance (or mitigation if avoidance cannot be completed) of any NRHP-eligible cultural resources.

SOILS

The following measures will be implemented to minimize impacts to soils:

Certified weed-free straw mulches, certified weed-free hay bale barriers, silt fences, and water bars will be used to control soil erosion.

Soil erosion control measures will be monitored, especially after storms, and will be repaired or replaced if needed.

Surface disturbance will be limited to that which is necessary for safe and efficient construction.

All surface-disturbed areas will be restored and reclaimed in accordance with easement agreements with private landowners and the ROW with respect to BLM land.

Construction activities in areas of moderate to steep slopes (15%–20%) will be avoided, where possible.

A site-specific SWPPP will be prepared for the Project.

SPECIAL-STATUS SPECIES

To minimize impacts to State-listed species, CPR will implement the following measures:

A worker education awareness program providing instruction on avoiding harassment and disturbance of wildlife, especially during reproductive (e.g., courtship, nesting) seasons, will be provided to all construction employees prior to ground-breaking activities.

Limit the surface-disturbed areas to those that are needed for safe and efficient construction.

Consult and coordinate with the BLM, USFWS, and NDOW for all mitigation activities related to raptors and special-status species, and their habitats.

Conduct a raptor nest inventory during the nesting season prior to construction, and if raptors are found nesting within or near the project area, sequence construction to avoid certain construction activities within a recommended buffer of any active nest until the young have fledged or the nest has been abandoned or has failed. The buffer will be determined at time of construction, season, and raptor activity and occurrence.

Conduct surveys for federally and/or State-protected species and other species of concern (including BLM special-status plant and animal species) within the project area and design the Project to avoid (if possible), minimize, or mitigate impacts to these resources.

Prepare a project-specific BBCS and ECP based on pre-construction data collection.


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Implement mitigation measures and advanced conservation practices as outlined in the project BBCS and ECP.

Weed management in areas of special-status species will carefully consider the impacts of the treatment on the organism. Whenever possible, manual control or spot treatment using herbicides is preferred over less species-specific methods. Do not conduct noxious and invasive weed control within 0.5 mile of nesting and brood rearing areas for special-status species during the nesting and brood rearing season.

Reclaim all disturbed areas not needed for operation as soon as possible after construction is complete.

Limit traffic speed and volume to that which is necessary for construction and O&M.

Use state-of-the-art turbine technology, including free standing tubular towers and slow-rotating, upwind rotors.

Construct overhead power lines following the most current Avian Power Line Interaction Committee (APLIC) standards. Suggested Practices for Avian Protection on Power Lines—the State of the Art in 2006 (APLIC 2006) and Reducing Avian Collisions with Power Lines: The State of the Art in 2012 (APLIC 2012) provide the most recent standards.

Survey for listed species prior to construction, and design the Project or sequence construction to avoid occupied habitat.

Conduct post-construction mortality monitoring as outlined in a project BBCS and ECP.

VEGETATION

The following measures will be implemented to minimize impacts to vegetation:

Surface disturbance will be limited to that which is necessary for safe and efficient construction.

All surface-disturbed areas on BLM land will be restored to the approximate original contour and reclaimed in accordance with easement agreements and the ROW.

A Noxious Weed Management Plan will be developed.

Where appropriate, vehicles and heavy equipment used for the completion, maintenance, inspection, or monitoring of ground-disturbing activities; for emergency fire suppression; or for authorized off-road driving would be free of soil and debris capable of transporting weed propagules. Vehicles and equipment would be cleaned with power or high-pressure equipment prior to entering or leaving the work site or project area. Vehicles used for emergency fire suppression would be cleaned as a part of check-in and demobilization procedures. Cleaning efforts would concentrate on tracks, feet, or tires, and on the undercarriage. Special emphasis would be applied to axles, frames, cross members, motor mounts, on and underneath steps, running boards, and front bumper/brush guard assemblies. Vehicle cabs would be swept out, and refuse would be disposed of in waste receptacles.

Prior to the entry of vehicles and equipment to a planned disturbance area, a weed scientist or qualified biologist would identify and flag areas containing weeds. The flagging would alert personnel or participants to avoid areas of concern whenever possible.

To minimize the transport of soil-borne noxious weed seeds, roots, or rhizomes, infested soils or materials would not be moved and redistributed on weed-free or relatively weed-free areas. In areas where infestations are identified or noted and infested soils, rock, or overburden must be moved, these materials would be salvaged and stockpiled adjacent to the area from which they were stripped. Appropriate measures would be taken to minimize wind and water erosion of these


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stockpiles. During reclamation, the materials would be returned to the area from which they were stripped, as practicable.

Removal or disturbance of vegetation will be minimized through site management (e.g., by utilizing previously disturbed areas, designating limited equipment/materials storage yards and staging areas, scalping) and reclaiming of all disturbed areas not required for operations.

Surveys for sensitive plant species will be conducted prior to ground-disturbing activities. If any species are found, CPR will work with the BLM to determine what course of action to take.

WATER RESOURCES

To minimize impacts to water resources, CPR will implement the following measures:

A site-specific SWPPP will be prepared for the Project.

Refueling and staging will occur at least 300 feet from the edge of a channel bank at all stream channels.

Sediment control measures will be utilized.

Vegetation disturbance will be limited to that which is necessary for construction.

WILDLIFE

The following measures will be implemented to minimize impacts to wildlife:

A worker education awareness program providing instruction on avoiding harassment and disturbance of wildlife, especially during reproductive (e.g., courtship, nesting) seasons, will be provided to all construction employees prior to ground-breaking activities.

A BBCS and ECP will be prepared, which will describe initial mitigation requirements, post-construction monitoring requirements, and an adaptive mitigation strategy.

Prior to performing geotechnical studies, boring sites will be cleared for any wildlife or ongoing monitoring will be implemented.

CPR will review existing information on species and habitats in the vicinity of the project area to identify potential concerns as required by NEPA and NDOW.

CPR will identify important, sensitive, or unique habitats in the vicinity of the Project and design the Project to avoid (if possible), minimize, or mitigate impacts to these habitats.

CPR will evaluate avian and bat use of the project area and design the Project to minimize or mitigate the potential for bird and bat strikes (e.g., development will not occur in riparian habitats and wetlands).

CPR will determine the presence of active raptor nests (i.e., raptor nests used during the breeding season). Measures to reduce raptor use at a project site (e.g., minimize road cuts, maintain either no vegetation or non-attractive plant species around the turbines) will be considered.

If construction is planned between March 15 and July 30, migratory bird clearance surveys would be conducted no more than 1 week before construction. Evidence of active nests or nesting would be reported immediately to the BLM to determine appropriate minimization measures (i.e., avoidance buffer would be established until birds have fledged the nest) on a case-by-case basis.

A habitat restoration plan will be developed to avoid (if possible), minimize, or mitigate negative impacts to wildlife while maintaining or enhancing habitat values for other species. The plan will identify revegetation, soil stabilization, and erosion reduction measures that will be implemented to ensure that all temporary use areas are restored. The plan will require that restoration occur as


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soon as possible after completion of activities to reduce the amount of habitat converted at any one time and to speed up the recovery to natural habitats.

Procedures will be developed to mitigate potential impacts to special-status species.

Facilities will be designed to discourage their use as perching or nesting substrates by birds. For example, any overhead power lines and poles shall be configured to minimize raptor electrocutions and discourage raptor and raven nesting and perching. The BLM and CPR will consult with NDOW on the final deterrent design.

CPR will advise Project personnel regarding appropriate speed limits on roads to minimize wildlife mortality due to vehicle collisions. Potential increases in poaching will be minimized through employee and contractor education regarding wildlife laws. If violations are discovered, the offending employee or contractor will be disciplined and may be dismissed by CPR and/or prosecuted by the BLM.

Travel will be restricted to designated construction areas and project roads; no off-road travel outside of designated work areas will be allowed except in emergencies.


6 LITERATURE CITED AMERICAN WIND WILDLIFE INSTITUTE (AWWI). 2017. WIND TURBINE INTERACTIONS WITH WILDLIFE

AND THEIR HABITATS: A SUMMARY OF RESEARCH RESULTS AND PRIORITY QUESTIONS. WASHINGTON, DC. AVAILABLE AT WWW.AWWI.ORG.

Avian Power Line Interaction Committee (APLIC). 2006. Suggested Practices for Avian Protection on Power Lines—the State of the Art in 2006. PIER Final Project Report CEC-500-2006-022. Washington, D.C., and Sacramento, California: Edison Electric Institute, Avian Power Line Interaction Committee, and California Energy Commission. Available at: http://www.dodpif.org/downloads/APLIC_2006_SuggestedPractices.pdf. Accessed June 28, 2012.

———. 2012. Reducing Avian Collisions with Power Lines: The State of the Art in 2012. Washington, D.C.: Edison Electric Institute and Avian Power Line Interaction Committee.

Bureau of Land Management (BLM). 1985. Manual 9113–Roads. Washington, D.C.: U.S. Department of the Interior, Bureau of Land Management. Available at: http://www.blm.gov/pgdata/etc/medialib/blm/mt/blm_programs/energy/oil_and_gas/operations/gold_book.Par.10040.File.dat/9113.pdf. Accessed June 28, 2012.

———. 1998. Proposed Las Vegas Resource Management Plan and Final Environmental Impact Statement. Las Vegas, Nevada: Bureau of Land Management, Las Vegas Field Office.

———. 2005. Final Wind Energy Programmatic Environmental Impact Statement. Washington, D.C.: U.S. Department of the Interior, Bureau of Land Management.

———. 2014. Draft Statewide Wildlife Survey Protocols. Bureau of Land Management, Nevada.

Energy Information Administration (EIA). 2009. Annual Energy Outlook 2009: With Projections to 2030. Washington, D.C.: U.S. Department of Energy. Available at: http://www.eia.doe.gov/oiaf/aeo/. Accessed October 19, 2009.

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Kerlinger, P., R. Curry, L. Culp, A. Jain, C. Wilkerson, B. Fischer, and A. Hasch. 2006. Post-Construction Avian and Bat Fatality Monitoring Study for the High Winds Wind Power Project Solano County, California: Two Year Report. Prepared for High Winds, LLC, FPL Energy. McLean, Virginia: Curry and Kerlinger, LLC.

Nevada Department of Wildlife (NDOW). 2010. Desert Bighorn Sheep Hunter Information Sheet for Hunt Unit 263. Available at: http://www.ndow.org/hunt/resources/infosheets/dbh/south/263dbh.pdf. Accessed April 26, 2010.

SWCA Environmental Consultants (SWCA). 2011. Greater Searchlight Renewables Wind Projects Constraints Analysis. Prepared for Greater Searchlight Renewables, LLC. Las Vegas, Nevada: SWCA Environmental Consultants.


2

U.S. Department of Energy (DOE). 2008. 20% Renewable Energy by 2030: Increasing Wind Energy’s Contribution to U.S. Electricity Supply. DOE/GO-102008-2567. Available at: http://energy.gov/sites/prod/files/2013/12/f5/41869.pdf. Accessed December 29, 2015.

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———. 2013. Eagle Conservation Plan Guidance: Module 1 – Land-based Wind Energy Guidance, Version 2. Available at: http://www.fws.gov/windenergy/eagle_guidance.html. Accessed October 26, 2015.

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CRESCENT PEAK WIND PROJECT LEGAL DESCRIPTIONMARCH 2017

Phase TRS township range section SECDIVLAB qqqsection QQ QQQNV‐1 28S 61E 28S 61E 13 NENE NENE NE 1/4 of the NE 1/4

NENW NENW NE 1/4 of the NW 1/4 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWNW NWNW NW 1/4 of the NW 1/4 NWNW NWNW NW 1/4 of the NW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 NWSW NWSW NW 1/4 of the SW 1/4 NWSW NWSW NW 1/4 of the SW 1/4 NWSW NWSW NW 1/4 of the SW 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSE SWSE SW 1/4 of the SE 1/4 SWSW SWSW SW 1/4 of the SW 1/4 SWSW SWSW SW 1/4 of the SW 1/4 NWSW NENWSW NW 1/4 of the SW 1/4 NE 1/4 of the NW 1/4 of the SW 1/4SWSW NESWSW SW 1/4 of the SW 1/4 NE 1/4 of the SW 1/4 of the SW 1/4SWNW NWSWNW SW 1/4 of the NW 1/4 NW 1/4 of the SW 1/4 of the NW 1/4NWSW SENWSW NW 1/4 of the SW 1/4 SE 1/4 of the NW 1/4 of the SW 1/4SWNW SESWNW SW 1/4 of the NW 1/4 SE 1/4 of the SW 1/4 of the NW 1/4SWSW SESWSW SW 1/4 of the SW 1/4 SE 1/4 of the SW 1/4 of the SW 1/4NWNW SWNWNW NW 1/4 of the NW 1/4 SW 1/4 of the NW 1/4 of the NW 1/4NWSW SWNWSW NW 1/4 of the SW 1/4 SW 1/4 of the NW 1/4 of the SW 1/4SWNW SWSWNW SW 1/4 of the NW 1/4 SW 1/4 of the SW 1/4 of the NW 1/4

NV‐1 28S 61E 28S 61E 14 NENE NENE NE 1/4 of the NE 1/4 NENE NENE NE 1/4 of the NE 1/4 NENE NENE NE 1/4 of the NE 1/4 NENW NENW NE 1/4 of the NW 1/4 NESE NESE NE 1/4 of the SE 1/4 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWNW NWNW NW 1/4 of the NW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 NWSE NWSE NW 1/4 of the SE 1/4

1


NWSE NWSE NW 1/4 of the SE 1/4 NWSW NWSW NW 1/4 of the SW 1/4 SENE SENE SE 1/4 of the NE 1/4 SENE SENE SE 1/4 of the NE 1/4 SENE SENE SE 1/4 of the NE 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSE SWSE SW 1/4 of the SE 1/4 SWSE SWSE SW 1/4 of the SE 1/4 SWSE SWSE SW 1/4 of the SE 1/4 SWSW SWSW SW 1/4 of the SW 1/4 NESE NENESE NE 1/4 of the SE 1/4 NE 1/4 of the NE 1/4 of the SE 1/4NWSE NENWSE NW 1/4 of the SE 1/4 NE 1/4 of the NW 1/4 of the SE 1/4SENE NESENE SE 1/4 of the NE 1/4 NE 1/4 of the SE 1/4 of the NE 1/4SWSE NESWSE SW 1/4 of the SE 1/4 NE 1/4 of the SW 1/4 of the SE 1/4NESE NWNESE NE 1/4 of the SE 1/4 NW 1/4 of the NE 1/4 of the SE 1/4NENE SENENE NE 1/4 of the NE 1/4 SE 1/4 of the NE 1/4 of the NE 1/4NWSE SENWSE NW 1/4 of the SE 1/4 SE 1/4 of the NW 1/4 of the SE 1/4SENE SESENE SE 1/4 of the NE 1/4 SE 1/4 of the SE 1/4 of the NE 1/4SWNE SESWNE SW 1/4 of the NE 1/4 SE 1/4 of the SW 1/4 of the NE 1/4SWSE SESWSE SW 1/4 of the SE 1/4 SE 1/4 of the SW 1/4 of the SE 1/4SENE SWSENE SE 1/4 of the NE 1/4 SW 1/4 of the SE 1/4 of the NE 1/4

NV‐1 28S 61E 28S 61E 15 NESE NESE NE 1/4 of the SE 1/4 NWSE NWSE NW 1/4 of the SE 1/4 SENE SENE SE 1/4 of the NE 1/4 SESE SESE SE 1/4 of the SE 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWSE SWSE SW 1/4 of the SE 1/4

NV‐1 28S 61E 28S 61E 22 NENE NENE NE 1/4 of the NE 1/4 NWNE NWNE NW 1/4 of the NE 1/4 SENE SENE SE 1/4 of the NE 1/4 SWNE SWNE SW 1/4 of the NE 1/4

NV‐1 28S 61E 28S 61E 23 NENE NENE NE 1/4 of the NE 1/4 NENW NENW NE 1/4 of the NW 1/4 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NESW NESW NE 1/4 of the SW 1/4 NESW NESW NE 1/4 of the SW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWNE NWNE NW 1/4 of the NE 1/4

2


NWNE NWNE NW 1/4 of the NE 1/4 NWNW NWNW NW 1/4 of the NW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SESW SESW SE 1/4 of the SW 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSE SWSE SW 1/4 of the SE 1/4 NWNE NENWNE NW 1/4 of the NE 1/4 NE 1/4 of the NW 1/4 of the NE 1/4NESW NWNESW NE 1/4 of the SW 1/4 NW 1/4 of the NE 1/4 of the SW 1/4SESW NWSESW SE 1/4 of the SW 1/4 NW 1/4 of the SE 1/4 of the SW 1/4NWNE SENWNE NW 1/4 of the NE 1/4 SE 1/4 of the NW 1/4 of the NE 1/4NESW SWNESW NE 1/4 of the SW 1/4 SW 1/4 of the NE 1/4 of the SW 1/4SESW SWSESW SE 1/4 of the SW 1/4 SW 1/4 of the SE 1/4 of the SW 1/4

NV‐1 28S 61E 28S 61E 24 NENE NENE NE 1/4 of the NE 1/4 NENW NENW NE 1/4 of the NW 1/4 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWNW NWNW NW 1/4 of the NW 1/4 NWNW NWNW NW 1/4 of the NW 1/4 NWNW NWNW NW 1/4 of the NW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 NWSW NWSW NW 1/4 of the SW 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSE SWSE SW 1/4 of the SE 1/4 SWSW SWSW SW 1/4 of the SW 1/4 NWNW NENWNW NW 1/4 of the NW 1/4 NE 1/4 of the NW 1/4 of the NW 1/4NWNW SENWNW NW 1/4 of the NW 1/4 SE 1/4 of the NW 1/4 of the NW 1/4

NV‐1 28S 61E 28S 61E 25 NENE NENE NE 1/4 of the NE 1/4 NENW NENW NE 1/4 of the NW 1/4 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NESW NESW NE 1/4 of the SW 1/4 NESW NESW NE 1/4 of the SW 1/4

3


NESW NESW NE 1/4 of the SW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWNW NWNW NW 1/4 of the NW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 NWSE NWSE NW 1/4 of the SE 1/4 NWSE NWSE NW 1/4 of the SE 1/4 NWSW NWSW NW 1/4 of the SW 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSE SWSE SW 1/4 of the SE 1/4 SWSW SWSW SW 1/4 of the SW 1/4 NESW NENESW NE 1/4 of the SW 1/4 NE 1/4 of the NE 1/4 of the SW 1/4NWSE NENWSE NW 1/4 of the SE 1/4 NE 1/4 of the NW 1/4 of the SE 1/4NESW NWNESW NE 1/4 of the SW 1/4 NW 1/4 of the NE 1/4 of the SW 1/4NWSE SENWSE NW 1/4 of the SE 1/4 SE 1/4 of the NW 1/4 of the SE 1/4NESW SWNESW NE 1/4 of the SW 1/4 SW 1/4 of the NE 1/4 of the SW 1/4

NV‐1 28S 61E 28S 61E 26 NENE NENE NE 1/4 of the NE 1/4 NENW NENW NE 1/4 of the NW 1/4 NENW NENW NE 1/4 of the NW 1/4 NENW NENW NE 1/4 of the NW 1/4 NENW NENW NE 1/4 of the NW 1/4 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWSE NWSE NW 1/4 of the SE 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SENW SENW SE 1/4 of the NW 1/4 SENW SENW SE 1/4 of the NW 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWSE SWSE SW 1/4 of the SE 1/4 SENW NESENW SE 1/4 of the NW 1/4 NE 1/4 of the SE 1/4 of the NW 1/4NENW NWNENW NE 1/4 of the NW 1/4 NW 1/4 of the NE 1/4 of the NW 1/4SENW NWSENW SE 1/4 of the NW 1/4 NW 1/4 of the SE 1/4 of the NW 1/4NENW SENENW NE 1/4 of the NW 1/4 SE 1/4 of the NE 1/4 of the NW 1/4SENW SESENW SE 1/4 of the NW 1/4 SE 1/4 of the SE 1/4 of the NW 1/4NENW SWNENW NE 1/4 of the NW 1/4 SW 1/4 of the NE 1/4 of the NW 1/4SENW SWSENW SE 1/4 of the NW 1/4 SW 1/4 of the SE 1/4 of the NW 1/4

4


NV‐1 28S 61E 28S 61E 33 NESE NESE NE 1/4 of the SE 1/4 SENE SENE SE 1/4 of the NE 1/4 SESE SESE SE 1/4 of the SE 1/4

NV‐1 28S 61E 28S 61E 34 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 NWSW NWSW NW 1/4 of the SW 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSE SWSE SW 1/4 of the SE 1/4 SWSW SWSW SW 1/4 of the SW 1/4

NV‐1 28S 61E 28S 61E 35 NENE NENE NE 1/4 of the NE 1/4 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWSE NWSE NW 1/4 of the SE 1/4 NWSW NWSW NW 1/4 of the SW 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSE SWSE SW 1/4 of the SE 1/4 SWSW SWSW SW 1/4 of the SW 1/4

NV‐1 28S 61E 28S 61E 36 NENE NENE NE 1/4 of the NE 1/4 NENW NENW NE 1/4 of the NW 1/4 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWNW NWNW NW 1/4 of the NW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 NWSW NWSW NW 1/4 of the SW 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSE SWSE SW 1/4 of the SE 1/4

5


SWSW SWSW SW 1/4 of the SW 1/4 NV‐1 28S 62E 28S 62E 17 NWNW NWNW NW 1/4 of the NW 1/4

NWSW NWSW NW 1/4 of the SW 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSW SWSW SW 1/4 of the SW 1/4

NV‐1 28S 62E 28S 62E 18 L 10 L 11 L 12 L 5 L 6 L 7 L 8 L 9

NENE NENE NE 1/4 of the NE 1/4 NENW NENW NE 1/4 of the NW 1/4 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWSE NWSE NW 1/4 of the SE 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWSE SWSE SW 1/4 of the SE 1/4

NV‐1 28S 62E 28S 62E 19 L 10 L 11 L 12 L 5 L 6 L 7 L 8 L 9

NENE NENE NE 1/4 of the NE 1/4 NENW NENW NE 1/4 of the NW 1/4 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWSE NWSE NW 1/4 of the SE 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4

6


SWSE SWSE SW 1/4 of the SE 1/4 NV‐1 28S 62E 28S 62E 20 NWNW NWNW NW 1/4 of the NW 1/4

NWSW NWSW NW 1/4 of the SW 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSW SWSW SW 1/4 of the SW 1/4

NV‐1 28S 62E 28S 62E 29 NWNW NWNW NW 1/4 of the NW 1/4 SWNW SWNW SW 1/4 of the NW 1/4

NV‐1 28S 62E 28S 62E 30 L 10 L 11 L 12 L 5 L 6 L 7 L 8 L 9

NENE NENE NE 1/4 of the NE 1/4 NENW NENW NE 1/4 of the NW 1/4 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWSE NWSE NW 1/4 of the SE 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWSE SWSE SW 1/4 of the SE 1/4

NV‐1 28S 62E 28S 62E 31 L 10 L 11 L 12 L 13 L 5 L 6 L 7 L 8 L 9

NENE NENE NE 1/4 of the NE 1/4 NENW NENW NE 1/4 of the NW 1/4 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWSE NWSE NW 1/4 of the SE 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4

7


SWNE SWNE SW 1/4 of the NE 1/4 NV‐1 29S 61E 29S 61E 1 L 1

L 4 L 3 L 3 L 2 L 2 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SENW SENW SE 1/4 of the NW 1/4 SENW SENW SE 1/4 of the NW 1/4 SENW SENW SE 1/4 of the NW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SENW NESENW SE 1/4 of the NW 1/4 NE 1/4 of the SE 1/4 of the NW 1/4SWNE NESWNE SW 1/4 of the NE 1/4 NE 1/4 of the SW 1/4 of the NE 1/4SENW NWSENW SE 1/4 of the NW 1/4 NW 1/4 of the SE 1/4 of the NW 1/4SWNE NWSWNE SW 1/4 of the NE 1/4 NW 1/4 of the SW 1/4 of the NE 1/4SENW SESENW SE 1/4 of the NW 1/4 SE 1/4 of the SE 1/4 of the NW 1/4SWNE SESWNE SW 1/4 of the NE 1/4 SE 1/4 of the SW 1/4 of the NE 1/4SENW SWSENW SE 1/4 of the NW 1/4 SW 1/4 of the SE 1/4 of the NW 1/4SWNE SWSWNE SW 1/4 of the NE 1/4 SW 1/4 of the SW 1/4 of the NE 1/4

NV‐1 29S 61E 29S 61E 2 L 1 L 2 L 3 L 4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4

NV‐1 29S 61E 29S 61E 3 L 1 L 2 L 3 L 4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4

NV‐1 29S 62E 29S 62E 6 L 2 L 3 L 4

8


L 5 NESW NESW NE 1/4 of the SW 1/4 SENW SENW SE 1/4 of the NW 1/4 SWNE SWNE SW 1/4 of the NE 1/4

NV‐2 27S 61E 27S 61E 26 NWNW NWNW NW 1/4 of the NW 1/4 NV‐2 27S 61E 27S 61E 27 NENE NENE NE 1/4 of the NE 1/4

NENW NENW NE 1/4 of the NW 1/4 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NESW NESW NE 1/4 of the SW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWSE NWSE NW 1/4 of the SE 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWSE SWSE SW 1/4 of the SE 1/4 NESW NENESW NE 1/4 of the SW 1/4 NE 1/4 of the NE 1/4 of the SW 1/4NWNE NENWNE NW 1/4 of the NE 1/4 NE 1/4 of the NW 1/4 of the NE 1/4SENW NESENW SE 1/4 of the NW 1/4 NE 1/4 of the SE 1/4 of the NW 1/4SESW NESESW SE 1/4 of the SW 1/4 NE 1/4 of the SE 1/4 of the SW 1/4NWNE NWNWNE NW 1/4 of the NE 1/4 NW 1/4 of the NW 1/4 of the NE 1/4NENW SENENW NE 1/4 of the NW 1/4 SE 1/4 of the NE 1/4 of the NW 1/4NESW SENESW NE 1/4 of the SW 1/4 SE 1/4 of the NE 1/4 of the SW 1/4SENW SESENW SE 1/4 of the NW 1/4 SE 1/4 of the SE 1/4 of the NW 1/4SESW SESESW SE 1/4 of the SW 1/4 SE 1/4 of the SE 1/4 of the SW 1/4NWNE SWNWNE NW 1/4 of the NE 1/4 SW 1/4 of the NW 1/4 of the NE 1/4

NV‐2 27S 61E 27S 61E 33 NESE NESE NE 1/4 of the SE 1/4 SENE SENE SE 1/4 of the NE 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWSE SWSE SW 1/4 of the SE 1/4 SWSW SWSW SW 1/4 of the SW 1/4 SWSW SWSW SW 1/4 of the SW 1/4 SWSW SWSW SW 1/4 of the SW 1/4 SWSW SWSW SW 1/4 of the SW 1/4 SWSW NESWSW SW 1/4 of the SW 1/4 NE 1/4 of the SW 1/4 of the SW 1/4SWSW NWSWSW SW 1/4 of the SW 1/4 NW 1/4 of the SW 1/4 of the SW 1/4

9


SWSW SESWSW SW 1/4 of the SW 1/4 SE 1/4 of the SW 1/4 of the SW 1/4SESW SWSESW SE 1/4 of the SW 1/4 SW 1/4 of the SE 1/4 of the SW 1/4SWSW SWSWSW SW 1/4 of the SW 1/4 SW 1/4 of the SW 1/4 of the SW 1/4

NV‐2 27S 61E 27S 61E 34 NENE NENE NE 1/4 of the NE 1/4 NENW NENW NE 1/4 of the NW 1/4 NENW NENW NE 1/4 of the NW 1/4 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWSE NWSE NW 1/4 of the SE 1/4 NWSW NWSW NW 1/4 of the SW 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SENW SENW SE 1/4 of the NW 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSE SWSE SW 1/4 of the SE 1/4 SWSW SWSW SW 1/4 of the SW 1/4 NENW NENENW NE 1/4 of the NW 1/4 NE 1/4 of the NE 1/4 of the NW 1/4SENW NESENW SE 1/4 of the NW 1/4 NE 1/4 of the SE 1/4 of the NW 1/4NENW SENENW NE 1/4 of the NW 1/4 SE 1/4 of the NE 1/4 of the NW 1/4SENW SESENW SE 1/4 of the NW 1/4 SE 1/4 of the SE 1/4 of the NW 1/4

NV‐2 28S 60E 28S 60E 1 L 2 L 3 L 4 L 4 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 NWSW NWSW NW 1/4 of the SW 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSE SWSE SW 1/4 of the SE 1/4 SWSW SWSW SW 1/4 of the SW 1/4

NV‐2 28S 60E 28S 60E 2 L 1 NV‐2 28S 60E 28S 60E 12 NENE NENE NE 1/4 of the NE 1/4

NENW NENW NE 1/4 of the NW 1/4

10


NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWNW NWNW NW 1/4 of the NW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 NWSW NWSW NW 1/4 of the SW 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSE SWSE SW 1/4 of the SE 1/4 SWSW SWSW SW 1/4 of the SW 1/4

NV‐2 28S 60E 28S 60E 13 NENE NENE NE 1/4 of the NE 1/4 NENW NENW NE 1/4 of the NW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWNW NWNW NW 1/4 of the NW 1/4

NV‐2 28S 61E 28S 61E 2 NWSW NWSW NW 1/4 of the SW 1/4 SWNW SWNW SW 1/4 of the NW 1/4


NV‐2 28S 61E 28S 61E 4 L 1 L 2 L 3 L 4 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 NWSW NWSW NW 1/4 of the SW 1/4

11


SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSE SWSE SW 1/4 of the SE 1/4 SWSW SWSW SW 1/4 of the SW 1/4

NV‐2 28S 61E 28S 61E 5 L 2 L 3 L 4 L 1 L 1 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 NWSW NWSW NW 1/4 of the SW 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSE SWSE SW 1/4 of the SE 1/4 SWSW SWSW SW 1/4 of the SW 1/4

NV‐2 28S 61E 28S 61E 6 L 1 L 2 L 3 L 4 L 5 L 6 L 7 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWSE SWSE SW 1/4 of the SE 1/4

NV‐2 28S 61E 28S 61E 7 L 1 L 2 L 3

12


L 4 NENE NENE NE 1/4 of the NE 1/4 NENW NENW NE 1/4 of the NW 1/4 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWSE NWSE NW 1/4 of the SE 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWSE SWSE SW 1/4 of the SE 1/4

NV‐2 28S 61E 28S 61E 8 NENE NENE NE 1/4 of the NE 1/4 NENW NENW NE 1/4 of the NW 1/4 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWNW NWNW NW 1/4 of the NW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 NWSW NWSW NW 1/4 of the SW 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSW SWSW SW 1/4 of the SW 1/4

NV‐2 28S 61E 28S 61E 9 NENE NENE NE 1/4 of the NE 1/4 NENW NENW NE 1/4 of the NW 1/4 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWNW NWNW NW 1/4 of the NW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 NWSW NWSW NW 1/4 of the SW 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSE SWSE SW 1/4 of the SE 1/4 SWSW SWSW SW 1/4 of the SW 1/4

13


NV‐2 28S 61E 28S 61E 10 NENE NENE NE 1/4 of the NE 1/4 NENW NENW NE 1/4 of the NW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWNW NWNW NW 1/4 of the NW 1/4 SENW SENW SE 1/4 of the NW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4

NV‐2 28S 61E 28S 61E 16 NENE NENE NE 1/4 of the NE 1/4 NENW NENW NE 1/4 of the NW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWNW NWNW NW 1/4 of the NW 1/4

NV‐2 28S 61E 28S 61E 17 NENE NENE NE 1/4 of the NE 1/4 NENW NENW NE 1/4 of the NW 1/4 NWNW NWNW NW 1/4 of the NW 1/4

NV‐2 28S 61E 28S 61E 18 L 1 NENE NENE NE 1/4 of the NE 1/4 NENW NENW NE 1/4 of the NW 1/4 NWNE NWNE NW 1/4 of the NE 1/4

NV‐3 29S 61E 29S 61E 1 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 NWSW NWSW NW 1/4 of the SW 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSE SWSE SW 1/4 of the SE 1/4 SWSW SWSW SW 1/4 of the SW 1/4 SWNE SESWNE SW 1/4 of the NE 1/4 SE 1/4 of the SW 1/4 of the NE 1/4SENW SWSENW SE 1/4 of the NW 1/4 SW 1/4 of the SE 1/4 of the NW 1/4SWNE SWSWNE SW 1/4 of the NE 1/4 SW 1/4 of the SW 1/4 of the NE 1/4

NV‐3 29S 61E 29S 61E 2 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 NWSW NWSW NW 1/4 of the SW 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4

14


SWSE SWSE SW 1/4 of the SE 1/4 SWSW SWSW SW 1/4 of the SW 1/4

NV‐3 29S 61E 29S 61E 3 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 NWSW NWSW NW 1/4 of the SW 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSE SWSE SW 1/4 of the SE 1/4 SWSW SWSW SW 1/4 of the SW 1/4


NV‐3 29S 61E 29S 61E 11 NENE NENE NE 1/4 of the NE 1/4 NENW NENW NE 1/4 of the NW 1/4 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWNW NWNW NW 1/4 of the NW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 NWSW NWSW NW 1/4 of the SW 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4

15


SWSE SWSE SW 1/4 of the SE 1/4 SWSW SWSW SW 1/4 of the SW 1/4



NV‐3 29S 61E 29S 61E 14 NENE NENE NE 1/4 of the NE 1/4 NENW NENW NE 1/4 of the NW 1/4 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWNW NWNW NW 1/4 of the NW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 NWSW NWSW NW 1/4 of the SW 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4

16


SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSE SWSE SW 1/4 of the SE 1/4 SWSW SWSW SW 1/4 of the SW 1/4

NV‐3 29S 61E 29S 61E 15 L 1 L 2 L 3 L 4 L 5 L 6 L 7 L 8 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWSE SWSE SW 1/4 of the SE 1/4

NV‐3 29S 61E 29S 61E 16 L 8 NV‐3 29S 61E 29S 61E 22 L 3

L 4 L 5 L 6 L 7 L 8

NV‐3 29S 61E 29S 61E 23 L 1 L 2 L 3 L 4 L 5 L 6 L 7 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4

17


SWSE SWSE SW 1/4 of the SE 1/4 NV‐3 29S 61E 29S 61E 24 NENE NENE NE 1/4 of the NE 1/4

NENW NENW NE 1/4 of the NW 1/4 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWNW NWNW NW 1/4 of the NW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 NWSW NWSW NW 1/4 of the SW 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSE SWSE SW 1/4 of the SE 1/4 SWSW SWSW SW 1/4 of the SW 1/4

NV‐3 29S 61E 29S 61E 25 L 1 L 2 L 3 L 4 L 5 L 6 L 7 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSE SWSE SW 1/4 of the SE 1/4

NV‐3 29S 61E 29S 61E 26 L 3 L 4 L 5 L 6 L 7 L 8

NV‐3 29S 61E 29S 61E 36 L 3 L 4

NENE NENE NE 1/4 of the NE 1/4 NV‐3 29S 62E 29S 62E 6 L 5

L 6

18


L 7 NESW NESW NE 1/4 of the SW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESW SESW SE 1/4 of the SW 1/4 SWSE SWSE SW 1/4 of the SE 1/4

NV‐4 29S 62E 29S 62E 28 SESW SESW SE 1/4 of the SW 1/4 SWSE SWSE SW 1/4 of the SE 1/4 SWSW SWSW SW 1/4 of the SW 1/4

NV‐4 29S 62E 29S 62E 32 NESE NESE NE 1/4 of the SE 1/4 SESE SESE SE 1/4 of the SE 1/4 SWSE SWSE SW 1/4 of the SE 1/4


NV‐4 29S 62E 29S 62E 34 NWSW NWSW NW 1/4 of the SW 1/4 SESE SESE SE 1/4 of the SE 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSE SWSE SW 1/4 of the SE 1/4 SWSW SWSW SW 1/4 of the SW 1/4

NV‐4 29S 62E 29S 62E 35 SWSW SWSW SW 1/4 of the SW 1/4 NV‐4 30S 62E 30S 62E 2 L 4

SWSW SWSW SW 1/4 of the SW 1/4 NV‐4 30S 62E 30S 62E 3 L 1

L 2 L 3 L 4 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 NWSW NWSW NW 1/4 of the SW 1/4

19


SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSE SWSE SW 1/4 of the SE 1/4 SWSW SWSW SW 1/4 of the SW 1/4


NV‐4 30S 62E 30S 62E 5 L 10 L 11 L 12 L 13 L 14 L 5 L 6 L 7 L 8 L 9

NESW NESW NE 1/4 of the SW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 SENW SENW SE 1/4 of the NW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWSE SWSE SW 1/4 of the SE 1/4

NV‐4 30S 62E 30S 62E 6 L 10 L 8 L 9

NV‐4 30S 62E 30S 62E 8 L 3 L 4

20



L 2 L 3 L 4 L 5 L 6 L 7 L 8

NENW NENW NE 1/4 of the NW 1/4 NESW NESW NE 1/4 of the SW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWSE NWSE NW 1/4 of the SE 1/4 SENW SENW SE 1/4 of the NW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWSE SWSE SW 1/4 of the SE 1/4


NV‐4 30S 62E 30S 62E 11 NWNW NWNW NW 1/4 of the NW 1/4 NWSW NWSW NW 1/4 of the SW 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSW SWSW SW 1/4 of the SW 1/4

NV‐4 30S 62E 30S 62E 14 NWNW NWNW NW 1/4 of the NW 1/4 NWSW NWSW NW 1/4 of the SW 1/4 SWNW SWNW SW 1/4 of the NW 1/4

NV‐4 30S 62E 30S 62E 15 L 1 L 2 L 3 L 4 L 5

21


L 6 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NESW NESW NE 1/4 of the SW 1/4 NESW NESW NE 1/4 of the SW 1/4 NESW NESW NE 1/4 of the SW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSE SWSE SW 1/4 of the SE 1/4 NESW NENESW NE 1/4 of the SW 1/4 NE 1/4 of the NE 1/4 of the SW 1/4NESW NWNESW NE 1/4 of the SW 1/4 NW 1/4 of the NE 1/4 of the SW 1/4NESW SENESW NE 1/4 of the SW 1/4 SE 1/4 of the NE 1/4 of the SW 1/4NESW SWNESW NE 1/4 of the SW 1/4 SW 1/4 of the NE 1/4 of the SW 1/4L 6

NV‐4 30S 62E 30S 62E 16 L 5 L 6 L 7

NV‐4 30S 62E 30S 62E 22 L 6 L 7


L 2 L 3 L 4 L 5 L 6 L 7 L 8

NENW NENW NE 1/4 of the NW 1/4 NESW NESW NE 1/4 of the SW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWSE NWSE NW 1/4 of the SE 1/4 SENW SENW SE 1/4 of the NW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWSE SWSE SW 1/4 of the SE 1/4

NV‐4 30S 62E 30S 62E 24 NENE NENE NE 1/4 of the NE 1/4 NENW NENW NE 1/4 of the NW 1/4 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWNE NWNE NW 1/4 of the NE 1/4

22


NWNW NWNW NW 1/4 of the NW 1/4 NWSE NWSE NW 1/4 of the SE 1/4 NWSW NWSW NW 1/4 of the SW 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWNW SWNW SW 1/4 of the NW 1/4 SWSE SWSE SW 1/4 of the SE 1/4 SWSW SWSW SW 1/4 of the SW 1/4

NV‐4 30S 62E 30S 62E 25 L 1 L 2 L 3 L 4 L 5 L 6 L 7 L 8 L 9 NESE NESE NE 1/4 of the SE 1/4 NWSE NWSE NW 1/4 of the SE 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SWNE SWNE SW 1/4 of the NE 1/4

NV‐4 30S 62E 30S 62E 26 L 6 L 7 L 8

NV‐4 30S 62E 30S 62E 36 L 6 L 7

NV‐4 30S 63E 30S 63E 19 L 1 NV‐4 30S 63E 30S 63E 30 L 1

L 2 L 3 L 4

NENE NENE NE 1/4 of the NE 1/4 NENW NENW NE 1/4 of the NW 1/4 NESE NESE NE 1/4 of the SE 1/4 NESW NESW NE 1/4 of the SW 1/4 NWNE NWNE NW 1/4 of the NE 1/4 NWSE NWSE NW 1/4 of the SE 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4

23


SESE SESE SE 1/4 of the SE 1/4 SESW SESW SE 1/4 of the SW 1/4 SWNE SWNE SW 1/4 of the NE 1/4 SWSE SWSE SW 1/4 of the SE 1/4

NV‐4 30S 63E 30S 63E 31 L 10 L 11 L 12 L 13 L 5 L 6 L 7 L 8 L 9 NESE NESE NE 1/4 of the SE 1/4 NWSE NWSE NW 1/4 of the SE 1/4 SENE SENE SE 1/4 of the NE 1/4 SENW SENW SE 1/4 of the NW 1/4 SESE SESE SE 1/4 of the SE 1/4 SWNE SWNE SW 1/4 of the NE 1/4

NV‐4 31S 63E 31S 63E 5 L 10 NV‐4 31S 63E 31S 63E 6 L 10

L 11

24

CRECSENT PEAK WINDGENTIE TO ELDORADO LEGAL DESCRIPTION

Township Range Section Q section QQ section QQ25S 62E 02 SE NW NW 1/4 of the SE 1/4

SE SW SW 1/4 of the SE 1/425S 62E 11 NE NW NW 1/4 of the NE 1/4

SE NW NW 1/4 of the SE 1/4NE SW SW 1/4 of the NE 1/4SE SW SW 1/4 of the SE 1/4

25S 62E 14 NW NE NE 1/4 of the NW 1/4SW NE NE 1/4 of the SW 1/4NE NW NW 1/4 of the NE 1/4SW NW NW 1/4 of the SW 1/4NW SE SE 1/4 of the NW 1/4SW SW SW 1/4 of the SW 1/4

25S 62E 22 NE NE NE 1/4 of the NE 1/4SE NE NE 1/4 of the SE 1/4SE NW NW 1/4 of the SE 1/4NE SE SE 1/4 of the NE 1/4SE SW SW 1/4 of the SE 1/4

25S 62E 23 NW NW NW 1/4 of the NW 1/425S 62E 27 NW NE NE 1/4 of the NW 1/4

SW NE NE 1/4 of the SW 1/4NE NW NW 1/4 of the NE 1/4SW NW NW 1/4 of the SW 1/4NW SE SE 1/4 of the NW 1/4SW SW SW 1/4 of the SW 1/4

25S 62E 33 NE NE NE 1/4 of the NE 1/4SE NE NE 1/4 of the SE 1/4NE SE SE 1/4 of the NE 1/4SE SE SE 1/4 of the SE 1/4SE SW SW 1/4 of the SE 1/4

25S 62E 34 NW NW NW 1/4 of the NW 1/426S 62E 04 SW NE NE 1/4 of the SW 1/4

NW SE SE 1/4 of the NW 1/4SW SE SE 1/4 of the SW 1/4NE SW SW 1/4 of the NE 1/4SW SW SW 1/4 of the SW 1/4L 6 L 6

26S 62E 08 SE NE NE 1/4 of the SE 1/4NE SE SE 1/4 of the NE 1/4SE SE SE 1/4 of the SE 1/4

26S 62E 09 NW NW NW 1/4 of the NW 1/4NW SW SW 1/4 of the NW 1/4

26S 62E 17 NE NE NE 1/4 of the NE 1/4SW NE NE 1/4 of the SW 1/4NE NW NW 1/4 of the NE 1/4SE NW NW 1/4 of the SE 1/4SW SE SE 1/4 of the SW 1/4


Township Range Section Q section QQ section QQNE SW SW 1/4 of the NE 1/4

26S 62E 20 NW NE NE 1/4 of the NW 1/4SW NE NE 1/4 of the SW 1/4SW NW NW 1/4 of the SW 1/4NW SE SE 1/4 of the NW 1/4SW SW SW 1/4 of the SW 1/4

26S 62E 29 NW NW NW 1/4 of the NW 1/4SW NW NW 1/4 of the SW 1/4NW SW SW 1/4 of the NW 1/4SW SW SW 1/4 of the SW 1/4

26S 62E 30 SE SE SE 1/4 of the SE 1/426S 62E 31 NE NE NE 1/4 of the NE 1/4

SE NE NE 1/4 of the SE 1/4NE SE SE 1/4 of the NE 1/4L 15 L 15L 16 L 16L 17 L 17

27S 61E 25 SE NE NE 1/4 of the SE 1/4NE SE SE 1/4 of the NE 1/4SE SE SE 1/4 of the SE 1/4SE SW SW 1/4 of the SE 1/4

27S 61E 35 SE NE NE 1/4 of the SE 1/4SE SE SE 1/4 of the SE 1/4SE SW SW 1/4 of the SE 1/4

27S 61E 36 NW NE NE 1/4 of the NW 1/4NE NW NW 1/4 of the NE 1/4SW NW NW 1/4 of the SW 1/4NW SE SE 1/4 of the NW 1/4NW SW SW 1/4 of the NW 1/4

27S 62E 06 SE NE NE 1/4 of the SE 1/4NE SE SE 1/4 of the NE 1/4SE SE SE 1/4 of the SE 1/4L 1 L 1

27S 62E 07 NE NE NE 1/4 of the NE 1/4NE NW NW 1/4 of the NE 1/4SE NW NW 1/4 of the SE 1/4NE SW SW 1/4 of the NE 1/4SE SW SW 1/4 of the SE 1/4

27S 62E 18 NW NE NE 1/4 of the NW 1/4SW NE NE 1/4 of the SW 1/4NE NW NW 1/4 of the NE 1/4NW SE SE 1/4 of the NW 1/4SW SE SE 1/4 of the SW 1/4

27S 62E 19 NW NE NE 1/4 of the NW 1/4NW SE SE 1/4 of the NW 1/4L 2 L 2


Township Range Section Q section QQ section QQL 3 L 3L 4 L 4

27S 62E 30 L 1 L 1L 2 L 2

28S 61E 02 SW NE NE 1/4 of the SW 1/4SW NW NW 1/4 of the SW 1/4NW SE SE 1/4 of the NW 1/4NE SW SW 1/4 of the NE 1/4SW SW SW 1/4 of the SW 1/4L 2 L 2

28S 61E 03 SE SE SE 1/4 of the SE 1/428S 61E 09 SE SE SE 1/4 of the SE 1/428S 61E 10 NE NE NE 1/4 of the NE 1/4

SW NE NE 1/4 of the SW 1/4SE NW NW 1/4 of the SE 1/4NE SE SE 1/4 of the NE 1/4SW SE SE 1/4 of the SW 1/4NE SW SW 1/4 of the NE 1/4SW SW SW 1/4 of the SW 1/4

28S 61E 15 NW NW NW 1/4 of the NW 1/4

CRESCENT PEAK WIND PROJECT PLAN OF DEVELOPMENT …

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