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best identified substitute for State Environmental Guidance for Small Wind Projects is the New <br />Jersey Department of Environmental Protection's "Technical Manual for Evaluating Impacts of <br />Wind Turbines Requiring Coastal Permits" which allows small wind projects with a rotor-swept <br />area of less than 2,000 square feet lo be constructed without surveys or mitigation. Since the <br />proposed wind turbine will have a rotor swept area of less than 2,000 square feet, no additional <br />surveys or mitigation should be required. <br />4. While there have been a multitude of studies (e.g. in the Altamont Pass Wind Resource Area and- <br />elsewhere) those studies cannot be applied to this project because they a) include multiple wind <br />turbines in close proximity to one another; and/or b) analyze significantly larger turbines with <br />different operating characteristics. Further, the study results are unclear, inconclusive or <br />conflicting making it difficult to assert aliy definitive causal relationship related to the wind <br />turbines and avian fatalities in a particular location. Specifically, the Altamont study results are <br />not appropriate to this project due to: <br />a. Differences in topography and landscape <br />b. Differences in types of bird species and their flight characteristics <br />c. Turbine height and density <br />5. The bird species at highest risk in the area in proximity to the proposed project are the local <br />populations of California clapper rails and California black rails. However any risk proposed by <br />the proposed turbine would be greatly reduced due to the distance from the habitat area and rails' <br />ground-dwelling behavior and relatively little time spent in flight. These species are far more <br />likely to be impacted by human activities including pedestrian trails, leashed and unleashed dogs, <br />the adjacent power substation and transmission towers. A small wind turbine is likely to blend in <br />with the "background noise" of existing structures and recreational activities. <br />6. Bird fatalities are relatively infrequent events at wind farms and therefore a single wind turbine <br />poses little risk. Higher bird fatalities occur when turbines are taller and when the elevation is <br />higher. In this case the turbine is small (100' to the blade tip) and the elevation is only 8.5' <br />above sea level. Study results summarized by Curry and Kerlinger (2007) indicate that the <br />nocturnal migration of waterfowl, shorebirds, and songbirds occurs in most places across broad <br />7. Based upon the comparison of the proposed project with available data, it is estimated that the <br />small turbine would result in 0.152 bird deaths per year. At that rate, it would take 6.5 years of <br />continuous operation to result in the death of one bird. This would not be a significant biological <br />impact to common bird populations, but could be construed as significant for listed endangered <br />or threatened species. <br />Project Description <br />Halus Power Systems, a SaiiLeaiidro supplier of remanufactured wind turbines, is requesting approval from the <br />City of San Leandro of a Variance to exceed the 60 foot height limit and allow an 80-foot tall (100 feet to the <br />fully extended blade height), single, 50kW wind turbine to be located in the middle of their property located at <br />2539 Grant Avenue in the I-G Zoning District (see Figure 1, Project Location). <br />2