4.7 Livestock Grazing

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1 This section of the Draft Plan Amendment, Draft Environmental Impact Statement/Environmental Impact Report (Draft EIS/EIR) addresses potential impacts of the Alta East Wind Project (AEWP) on livestock grazing resources. Mitigation measures that would reduce impacts are also discussed. The applicable environmental and regulatory settings are discussed in Chapter 3.7. significance criteria for livestock grazing; therefore, for the purposes of CEQA, grazing is discussed in Section Methodology for Analysis The analysis of the effects of the AEWP must comply with NEPA requirements given the BLM land jurisdiction related to the proposed AEWP. This analysis focuses on whether the proposed AEWP would conflict with the management goals and activities on BLM-designated grazing allotments. Potential effects may occur from conflicts with the on-site grazing allotments, the Warren and Hansen Common Allotments. The following is the Project Proponent s intended plan for compliance with the standards and regulations set forth by the BLM for these allotments: The Allotment Management Status Categories set by the BLM for the Warren and Hansen Common Allotments identify no known resource conflicts involving use or resource conditions. Further, according to the BLM, if an energy developer leases grazing land for purposes which would preclude grazing; the BLM would initiate the two year notification process to the affected Rancher with the expectation that the land could be used for grazing in the future. Through the process of this Draft EIS/EIR, and proper coordination with the BLM, the Project would comply with the development standards and requirements identified by the BLM for rangeland management areas. (CH2MHILL 2011f) However, as part of the ROW grant, BLM may implement requirements in order to minimize interference with grazing activities, such as the suspension of grazing activities during the construction period or design standards. As such, the following analysis discusses the potential impacts associated with construction, operation and decommissioning, as well as any requirements that may be included in the ROW grant CEQA Thresholds of Significance and Criteria Livestock grazing allotments are designated by the BLM s CDCA Plan; therefore, no CEQA significance criteria are defined for livestock grazing designations. For the purposes of CEQA, grazing is discussed in Section 4.15, Special Designations and Agriculture Alternative A: Project Direct and Indirect Impacts The following is the Project Proponent s intended plan for compliance with the standards and regulations set forth by the BLM for these allotments: The Allotment Management Status Categories set by the BLM for the Warren and Hansen Common Allotments identify no known resource conflicts involving use or resource conditions. Further, according to the BLM, if an energy developer leases grazing land for purposes which would preclude grazing; the BLM would initiate the two-year notification process to the affected Rancher with the expectation that the land could be used for grazing in the future. Through the process of this Draft EIS/EIR, and proper June Alta East Wind Project (AEWP)

2 Bureau of Land Management/County of Kern coordination with the BLM, the AEWP would comply with the development standards and requirements identified by the BLM for rangeland management areas (CH2MHILL 2011f). Construction According to the Standards for Rangeland Health and Guidelines for Livestock Grazing Management, there are instances where specific terms and conditions will be applied to grazing use authorizations for reasons other than those directly related to rangeland health, such as to accommodate other resource needs and land uses or to meet administrative requirements. Management changes will be considered and evaluated by the BLM through the NEPA process prior to making final determinations. If reductions in permitted grazing are necessary, the animal unit months (AUM; the amount of forage needed to sustain one cow, five sheep, or five goats for one month) by which the permitted use is reduced will be held in suspension until the authorized officer determines that rangeland health has recovered and all or part of the suspended permitted use can be restored. Per correspondence with Sam Fitton at the BLM Ridgecrest field office, due to this suspension, the BLM has to give the rangeland permittee ample notice ( a couple years ) that there may be a change in their grazing status as a result of energy projects. As stated above, based on the Project Proponent s plan, it is implied that a two-year notification for removal of the allotment would be issued for the leased portion of the AEWP site within the Warren Allotment. Assuming that construction of the AEWP was to begin within this two-year period, construction activities within the boundaries of the Warren Allotment would include the installation of 19 wind turbine generators (WTGs) and access roads throughout the allotment. Construction activities are anticipated to commence in the spring of 2012 and require nine to 12 months to complete. The sequence of construction activities for the AEWP would generally be site preparation, access road installation, WTG foundation construction, electrical collection system installation, collector substation construction, WTG installation, final testing and turbine commissioning, and cleanup and restoration. This level of construction would preclude the use of the Warren Allotment for sheep grazing for the duration of construction which would extend through the life of the AEWP, and would result in the conversion of rangeland to a non-rangeland use. Construction of would also preclude the use of the portion of the Hansen Common Allotment within Section 28 of the AEWP site; and also may result in temporary indirect impacts which may include changes in the air quality due to the prevailing wind direction towards the east and northeast, and geologic conditions, i.e., erosion. In addition, the type of fencing that is used will also affect the grazing activities. Either perimeter fencing or the fencing of individual WTGs will be installed. Perimeter fencing would preclude grazing activities on the AEWP site; however, the fencing of individual, or groups of WTGs would allow of on-site grazing to continue. However, in order to minimize interference with grazing activities, as part of the ROW grant, BLM may require a suspension of grazing activities during the construction period and upon completion of construction grazing would resume within the designated grazing allotments. In addition, the ROW grant may also require the fencing of individual turbines in the portions of Section 28 that are within the Hansen Common Allotment, and the turbines within the Warren Allotment (all of Section 34). If construction takes longer than two years the Project Proponents may apply for an extension of the period of no grazing; and the request should state why an extension would be needed and give a reasonable estimate of the period of extra time that would be needed to complete construction. Operation and Maintenance As mentioned above under Construction, Alternative A would preclude the on-site grazing under the Warren and Hansen Common Allotments, which would continue through the life of the AEWP, and would result in the conversion of rangeland to a non-rangeland use. However, in order to minimize this permanent disturbance to grazing activities, as part of the ROW grant, BLM may require a suspension of grazing activities during the construction period and upon completion of construction grazing would Alta East Wind Project (AEWP) June 2012

3 resume within the designated grazing allotments. The following is a discussion of the permanent disturbance that would be associated with this course of action for each of the allotments. As reported in Section 3.7, the Warren Allotment is 584 acres, and the permitted use for the Warren Allotment is 55 perennial AUM. The AEWP s WTGs and access roads within the Warren Allotment would result in a permanent disturbance of 12.7 acres (2.2 percent of the allotment). At 55 perennial AUMs, a 2.2 percent decrease would take 1.2 AUMs out of grazing and result in 53.8 AUMs for the Warren Allotment. In current conditions, with 55 AUMs (5 x 55 = 275 AUMs) a band of 800 sheep would use their allotted feed on the allotment in 10 days. As such, with approval of the AEWP, the permanent disturbance would reduce the available forage, thereby reducing the AUMs available for grazing. In addition, the WTGs and associated fencing would limit movement on the allotment. The AEWP s WTGs and access roads would result in a permanent disturbance of 8.2 acres within the Hansen Common Allotment, which accounts for 0.01 percent of the 74,000-acre allotment. Similar to the Warren Allotment, the permanent disturbance would reduce the available forage, thereby reducing the AUMs available for grazing. However, considering the difference in the size of the allotments, this reduction would be considerably less of a disturbance and reduction to the Hansen Common Allotment in comparison to the Warren Allotment. However, continued cattle grazing activities on the Hansen Common Allotment would be more difficult to monitor cattle grazing than sheep grazing because there is no herder constantly monitoring the herd; therefore, finding and disposing of cattle carcasses would be more difficult. In turn, grazing and management activities may interfere with routine operation and maintenance activities associated with the AEWP. Due to the proximity to condor habitat, the allotment s rancher is responsible for removing any carcasses of dead sheep in order to avoid attracting condors to the AEWP site. However, the Project Proponent would be responsible for designating an area for the burial of carcasses; and if Project personnel found carcasses they would be responsible for contacting the rancher directly or calling the BLM. Section 4.21 (Wildlife Resources) includes Mitigation Measure (California Condor) which requires a full-time monitor to ensure immediate removal of carcasses on the AEWP site and requires designated areas for the burial of carcasses. Decommissioning As mentioned above under Construction, the Alternative A would preclude the on-site grazing under the Warren and Hansen Common Allotments. Decommissioning activities would cause a temporary, indirect disturbance to users of the land, which would preclude grazing. However, upon completion of the decommissioning activities, the AEWP site would be available for grazing activities to resume. Therefore, impact would be less than significant CEQA Significance and Impact Determinations, Alternative A: Project respect to this resource. However, for the purposes of CEQA, impacts associated with grazing and agriculture are discussed in Section Alternative B: Revised Site Layout Direct and Indirect Impacts In comparison to the AEWP, Alternative B consists of a revised site layout, relocating a number of WTG locations and resulting in the rerouting of access roads. All other features associated with Alternative B would remain unchanged compared to that discussed above for the AEWP. June Alta East Wind Project (AEWP)

4 Bureau of Land Management/County of Kern Construction During construction of this alternative, potential impacts to livestock grazing would be the same as described under Construction for Alternative A. Operation and Maintenance During operation and maintenance of this alternative, potential impacts to livestock grazing would be the same as described under Operation and Maintenance for Alternative A. Decommissioning During decommissioning of this alternative, potential impacts to livestock grazing would be the same as described under Decommissioning for Alternative A CEQA Significance and Impact Determinations, Alternative B: Revised Site Layout Alternative C: Reduced Project North Direct and Indirect Impacts Under Alternative C, all WTGs and ancillary facilities would remain identical to that of Alternative A. However, Alternative C would eliminate the central parcel within the AEWP boundary, which is located north of SR 58. As described in Section 3.7, this alternative would result in no direct disruption to the Hanson Common Allotment of Parcel 28; however, as discussed below, indirect impacts may occur. The Alternative C area comprises 2,342 acres, reducing the amount of BLM lands utilized to a total of 1,750 acres (CH2MHILL, 2011p). Construction During construction of this alternative the Hanson Common Allotment of Parcel 28 would not be a part of the AEWP site, and therefore, would not preclude the existing sheep. However, due to the proximity of the allotment to the AEWP site, construction activities may result in temporary indirect impacts to range conditions, which may include changes in the air quality due to the prevailing wind direction towards the east and northeast, and geologic conditions, i.e., erosion. Potential impacts to the Hansen Common Allotment would be the same as described under Construction for Alternative A. Operation and Maintenance During operation and maintenance of this alternative, the Hansen Common Allotment would not be a part of the AEWP site, and therefore, would not present a permanent disturbance to an active allotment. However, the impacts associated with the Warren Allotment would be the same as Alternative A Decommissioning During decommissioning of this alternative, the Hansen Common Allotment would not be affected by decommissioning activities. However, if the allotment were to be actively grazed at the time of decommissioning, decommissioning activities could temporarily disrupt grazing due to the proximity of the allotment to the AEWP site. Alta East Wind Project (AEWP) June 2012

5 CEQA Significance and Impact Determinations, Alternative C: Reduced Project North Alternative D: Reduced Project Southwest Alternative D would eliminate the southwestern most parcel, the Warren Allotment, within the AEWP boundary to reduce the potential to impact existing and allowed livestock grazing on this parcel of BLM land. Figure 2-12 displays the Alternative D site layout and existing BLM and Kern County land use designations. Currently, sheep grazing occurs within this southwestern parcel. The removal of this parcel and reduction in the project size would avoid conflicts with grazing activities during both construction and operational activities, and would eliminate 19 WTGs through loss of land or requirements imposed by setbacks (CH2MHILL, 2011p) Direct and Indirect Impacts Construction During construction of this alternative, the Warren Allotment would not be a part of the Project site, and therefore, would not preclude the existing sheep grazing. However, potential impacts to the Hansen Common Allotment would be the same as described under Construction for Alternative A. Operation and Maintenance During operation and maintenance of this alternative, the Warren Allotment would not be a part of the Project site, and therefore, would not present a permanent disturbance to the existing sheep grazing. Decommissioning During decommissioning of this alternative, the Warren Allotment would not be affected by decommissioning activities. However, if the allotment were to be actively grazed at the time of decommissioning, decommissioning activities could temporarily disrupt grazing due to the proximity of the allotment to the Project site CEQA Significance and Impact Determinations, Alternative D: Reduced Project Southwest, Alternative E: No issuance of a ROW Grant or County Approval; No LUP Amendment (No Project) Direct and Indirect Impacts Under this alternative, the BLM and County would not approve the AEWP and would not amend the California Desert Conservation Area (CDCA) Plan. As a result, no wind energy project would be con- June Alta East Wind Project (AEWP)

6 Bureau of Land Management/County of Kern structed, and the BLM would continue to manage the site consistent with the existing rangeland allotment. Because there would be no amendment to the CDCA Plan and the proposed zone changes would not be approved, no wind project would be approved for the site under this alternative, no new structures or facilities would be constructed or operated on the site and no new ground disturbance would occur. As a result, none of the impacts on special designation areas from construction or operation of the AEWP would occur. In particular, no direct or indirect impacts on grazing allotments would occur. However, the land on which the AEWP is proposed would become available to other uses that are consistent with the BLM s CDCA Plan, including another renewable energy project CEQA Significance and Impact Determinations, Alternative E: No issuance of a ROW Grant or County Approval; No LUP Amendment (No Project) Alternative F: No issuance of a ROW Grant or County Approval; Approval of a Land Use Plan Amendment to Exclude Wind Energy Development on the Site of the Project (No Project) Direct and Indirect Impacts Under this alternative, the BLM and County would not approve the AEWP and would amend the CDCA Plan to make the proposed site unavailable for future wind energy development. As a result, no wind energy project would be constructed on the site, and the BLM and would continue to manage the site consistent with the existing rangeland allotments. Because the CDCA Plan would be amended to make the area unavailable for future wind energy development, it is expected that the site would remain in its existing condition unless another use is designated in this amendment. As a result, the grazing allotments are not expected to change noticeably from existing conditions and, as such, this No Project Alternative would have no adverse impact on grazing allotments within and adjacent to the site in the long term CEQA Significance and Impact Determinations, Alternative F: No issuance of a ROW Grant or County Approval; Approval of a Land Use Plan Amendment to Exclude Wind Energy Development on the Site of the Project (No Project) Alta East Wind Project (AEWP) June 2012

7 4.7.9 Alternative G: No issuance of a ROW Grant or County Approval; Approval of a Land Use Plan Amendment to Make Site Available for Future Wind Energy Development (No Project) Direct and Indirect Impacts Under this alternative, the BLM and County would not approve the AEWP and would amend the CDCA Plan to allow for other wind projects on the site. As a result, it is possible that another wind energy project could be constructed on the site. Because the CDCA Plan would be amended, it is possible that the site would be developed with the same or a different wind technology. As a result, it is likely that impacts on special designation areas would result from the construction and operation of the wind technology and resulting ground disturbance and would likely be similar to the impacts to grazing allotments from the AEWP. Different wind technologies require different amounts of grading; however, it is expected that all wind technologies would require grading and maintenance. As such, this No Project Alternative could result in impacts on grazing allotments similar to the impacts under the AEWP CEQA Significance and Impact Determinations, Alternative G: : No issuance of a ROW Grant or County Approval; Approval of a Land Use Plan Amendment to Make Site Available for Future Wind Energy Development (No Project) Cumulative Impacts Geographic Extent/Context Several rangeland allotments are located in the general vicinity of the AEWP area. In addition to the Warren and Hansen Common allotments, the allotments within 10 miles of the AEWP site include the following: Cantil Common, Bissell, Rudnick Common, Nellies Nipple, Oak Creek, Double Mountain, Antelope Valley, and Bittercreek Drainage. The total acreage of these allotments is approximately 620,000 acres. Due to the presence of these allotments in the vicinity of the AEWP site, as well as the AEWP s potential contribution to cumulative impacts on these areas, the geographic extent of analysis is a 10-mile radius from the AEWP site. Beyond this 10-mile radius, potential cumulative impacts associated with construction activities would be greatly reduced. Potential cumulative impacts could occur for the entire duration of the AEWP, from the initiation of construction to the conclusion of facility decommissioning Existing Cumulative Conditions The AEWP site and surrounding area consists of undeveloped land, open space land, scattered rural residences, and the unincorporated Community of Mojave. Past and ongoing development throughout these areas has resulted in alterations to the natural landscape and the conversion of designated lands, such as rangeland. The following are the existing wind energy systems, as presented in Table (Section 4.1) of this Draft PA, Draft EIS/EIR: Manzana Wind Energy Project Alta Oak Creek Mojave Wind Project June Alta East Wind Project (AEWP)

8 Bureau of Land Management/County of Kern Coram Brodie Wind Project Pine Tree Wind Development Project Sky River Wind Energy Facility Reasonably Foreseeable Projects A wide variety of existing development projects could contribute to the cumulative conditions for livestock grazing lands in regards to effects from air quality and geologic conditions in the cumulative analysis area. Table lists cumulative projects in the vicinity of the AEWP site and surrounding area. Consideration of the following projects identified in Table and shown on Figure in Appendix A was used to develop this analysis of cumulative effects: PdV Infill Project Tehachapi Renewable Transmission Project Pacific Wind Energy Project Pacific Wind Infill Project Windstar Energy Project Alta Infill II Wind Project Windstar Energy Project Tylerhorse Wind Project Catalina Renewable Energy Project Lower West Wind Energy Project Morgan Hills Wind Energy Project North Sky River & Jawbone Wind Energy Projects Clearvista Wind Project Avalon Wind Energy Project Aero Energy Wind Project Distributed Solar Projects (10 individual solar projects) The Aeromen, LLC (four solar projects) High Desert Solar Project Several types of development projects could contribute to the cumulative impact of the AEWP and alternatives, particularly renewable energy projects, which occupy large areas of land, such as rangelands. These types of reasonably foreseeable projects could combine with potential impacts of the AEWP or an alternative to affect special designations within the geographic extent of this cumulative analysis Construction Since the majority of the existing and proposed renewable energy developments included in the cumulative projects list are not located on BLM lands, these projects do not result in the conversion of rangeland allotments. However, due to the proximity of the cumulative projects to rangelands, temporary construction indirect impacts may occur that are similar to the AEWP, which would include impacts associated with air quality and geologic conditions, i.e., erosion Operation and Maintenance As mentioned above under Construction, the majority of the existing and proposed renewable energy developments included in the cumulative projects list are not located on BLM lands. Therefore, the cumulative projects would not result in permanent conversion of rangeland allotments Decommissioning The decommissioning of the cumulative projects may result in temporary indirect impacts to surrounding rangeland allotments. Under the AEWP, decommissioning activities would cause temporary disturbances to users of the land, which would preclude grazing; however, after the AEWP has been decommissioned, users would experience a beneficial impact, as the site would return to its undeveloped state and the site would be available for grazing. Therefore, the AEWP would not contribute to cumulative impacts. Alta East Wind Project (AEWP) June 2012

9 CEQA Significance and Impact Determinations, Cumulative Appendix G of the State CEQA Guidelines does not provide specific significance criteria for livestock grazing; therefore, no significance determination has been made with respect to this resource. Therefore, for the purposes of CEQA, grazing is discussed in Section Mitigation Measures Mitigation Measure (5b) in Section 4.21 (Wildlife) requires that during periods of livestock grazing, a full-time monitor shall be present to ensure immediate removal of carcasses on the AEWP site Residual Impacts After Mitigation Construction of the AEWP would temporarily preclude grazing from the Warren and Hanson Common Allotments. However, in order to minimize impacts to grazing activities, as part of the ROW grant, BLM may require a suspension of grazing activities during the construction period and upon completion of construction, grazing would resume within the designated grazing allotments. During the operation and maintenance period, the AEWP would result in a minimal permanent disturbance of grazing land as a result of the WTGs and access roads. June Alta East Wind Project (AEWP)