2.
Response
to
Comments
2.9
Individual
Responses
to
Comments
from
Organizations
impacts
to
bat
species
that
shall
be
implemented
in
the
final
design
and
placement
of
wind
turbines.
Utilization
data;
digital
elevation
modeling;
slope
attributes;
techniques
to
identify
saddles,
notches,
and
benches;
and
associations
between
bird
utilization
and
topography
may
be
included,
for
example.
The
report
shall
include
adaptive
management
during
and
after
Project
Site
construction
using
information
gathered
in
the
pre-construction
assessment
to
guide
possible
Project
modifications,
mitigation,
or
the
need
for
and
design
of
post-construction
studies;
post-construction
studies
can
test
design
modifications
and
operational
activities
to
determine
their
effectiveness
in
avoiding
or
minimizing
significant
adverse
impacts
(USFWS,
2010b).
The
design
of
wind
turbines
shall
minimize
the
use
of
above
ground
electrical
cabling;
be
designed
with
solid
surfaces
that
are
not
conducive
to
perching;
not
run
when
visibility
is
poor,
such
as
at
night
and
during
periods
of
heavy
fog;
and
be
designed
with
low
rotor
speeds
(20
rpm
maximum).
This
comment,
which
focuses
on
Mitigation
Measure
4.C-1f
ignores
the
specific
requirements
of
Mitigation
Measure
4.C-1e,
which
requires
wind
turbines
be
designed
to
address
site-
specific
bird
and
bat
flight
patterns,
and
to:
Minimize
the
use
of
above
ground
electrical
cabling;
Be
designed
with
solid
surfaces
that
are
not
conducive
to
perching;
Not
run
when
visibility
is
poor,
such
as
at
night
and
during
periods
of
heavy
fog;
and
Be
designed
with
low
rotor
speeds
(20
rpm
maximum).
Please
note
that
even
with
implementation
of
Mitigation
Measures
4.C-1e
and
4.C-1f,
the
Draft
EIR
states
that
impacts
to
raptors
and
bats
would
be
significant
and
unavoidable
on
page
4.C-43.
Mitigation
Measure
4.C-1f
would
help
develop
information
that
could
change
this
situation,
but
analysis
in
the
Draft
EIR
acknowledges
on
page
4.C-43
that
impacts
to
raptors
and
bats
would
nevertheless
be
significant
due
to
uncertainties
in
our
understanding
of
the
biology
of
localized
flight
patterns
for
birds
and
bats,
and
the
current
state
of
knowledge
in
terms
of
managing
the
interface
between
them.
The
commenter
does
not
identify
or
recommend
any
mitigation
that
could
reduce
this
impact
to
less
than
significant.
Further,
the
Draft
EIR
acknowledges
that
energy
facilities
and
their
current
technologies
are
relatively
new
and
their
impacts
are
still
little
understood
in
terms
of
bird
and
bat
interactions
with
turbines
and
solar
panels.
The
body
of
data
is
growing
consistently
as
energy
projects
are
monitored,
studied,
and
used
to
create
and
test
site-specific
and
technology-specific
means
of
avoiding
impacts
to
bats
and
birds.
Nevertheless
Mitigation
Measure
4.C-1f
would
require
pre-
and
post-construction
surveys
for
raptors
and
bats,
and
post-construction
monitoring
of
these
species
that
would
apply
to
all
future
Baylands
energy
generation
development.
Mitigation
Measure
4.C-1e
and
4.C-1f
are
designed
to
provide
for
Brisbane
Baylands
Final
EIR
2.9.9-3
May
2015