Department of Interior in 2014 expressed concern with the Sunshine Valley asolar project because of the potential for the project to kill endangered Yuma Ridgway’s rail, also know as the Yuma clapper rail.
Department of Interior in 2014 expressed concern with the Sunshine Valley asolar project because of the potential for the project to kill endangered Yuma Ridgway’s rail, also know as the Yuma clapper rail.
Department of Interior in 2014 expressed concern with the Sunshine Valley asolar project because of the potential for the project to kill endangered Yuma Ridgway’s rail, also know as the Yuma clapper rail.
United States Department of the Interior
FISH AND WILDLIFE SERVI
Nevada Fish and Wildlife Otfice
4701 North Torrey Pines Drive
Las Vegas, Nevada 89130
Ph: (702) 515-5230 ~ Fax: (702) 515-5231
ate: July 11,2014
File No. 84320-2014-TA-0022
Mr. Ken Borngrebe
First Solar, Inc.
135 Main Street, 6" Floor
San Francisco, California 94105,
Dear Mr. Borngrebe:
Subject: Comments on the Proposed Sunshine Valley Solar Photovoltaic Eleciic
Facility in Amargosa Valley, Nye County, Nevada
‘This eter tansmits the U.S. Fish and Wildlife Service's (Service) concems regarding new
information documenting impacts of solar photovoltaic (PV) facilites on the Yuma clapper ral
(Rallus tongirostris yumanensis), a species listed as endangered under the Endangered Species
Act of 1973, as amended (Act) (16 U.S.C. 1531 er seq). The proposed project would consist of a
110-megawattaltemating curent solar PV electric generating facility occurring cn approximately
745 acres of private lands and would include a 0.5-mil long, 138-kilovolt generation-tie
transmission line also occurring on private lands.
Because the entirety ofthe project would occur on private land, First Solar previously requested
technical assistance from the Service regarding development of a Habitat Conservation Plan
HCP) to support an application for an incidental take permit forthe federally threatened desert
tortoise (Gopherus agasizt) pursuant to section 10(a)(1)(B) ofthe Act. On November 20,2013,
the Service issued a letter of concurrence with Fest Solas assessment thatthe likelihood ofa desert
tortoise occurring onthe poject site would be very ow. Potential project impacts pertaining to the
‘Yuma clapper rail were not discussed or identified a that time,
Solar PV facilities present a new source of mortality for Yuma clapper rls. These facilities
reflect light durin the day and night, producing a lake or pond effect that may atract rail species
and other water-associated birds. This phenomenon is evidenced by the documestation of one
‘Yuma clapper rail, one likely Yuma clapper rail (based on range {morphologically the individual
overlapped with the endangered California clapper rail (Rallus ongirostrie obsoletus) and Light
footed clapper ral (Rallus longirostislevipes)) two Virginia rail (Ralls limiccla) and seven
sora (Porzana carolina) mortalities at five solar projects in California between August 21, 2012,Mr. Ken Bornrebe Fie No, 86520-2016-74.0022
and April 22, 2014. These mortality records reflect incidental observation only, as systematic
‘survey results are not yet available at projects that recently have become operational or currently
‘are under construction. Bird carcases are often removed by scavengers; therefore, the actual
‘number killed likely is larger than reported above.
‘Scientific research regarding the dispersal paterns of the Yumnaclapper rail i limited. However,
‘numerous colonization events and dispersal records in isolated patches of suitable habitat across
southern Nevada, central and eastern Arizona, and the Mojave-Sonoran deserts in California
demonstrates the dispersal capabilities of rail Species. Rails of all species including clapper
rails) are almost never seen flying by day and are assumed to move long distances at night
(Taylor and Anderson 1973; Taylor and Kershner 1986; USFWS 2003, 2006) as a raptor
avoidance strategy. Given the limited extent of remaining suitable habitat throughout its range
(USFWS 2006) and its highly eritorial behavior (Eddleman 1989), most dispersing clapper rails
are assumed to be subadlts evicted from natal territories (Zemtal et al. 1985), unpaired males
seeking lower-density populations to establish territories, or adult rails displaced from
established teritories by marsh senescence or disturbances, such as flood scouring, fre, grazing,
‘vegetation removal, and construction and maintenance activites (Smith 1975; Bennett and
‘Ohmart 1978)
‘We acknowledge assessing the potential risk a solar facility poses to Yuma clapper rails is
challenging given the limited dispersal information currently available. However, known
‘occupied marsh habitat for Yuma clapper rails exists approximately eight mile southeast of the
proposed project at Ash Meadows National Wildlife Refuge, and we believe incidental taking of
1 Yuma clapper rail i likely given the proximity of the proposed project o this occupied habitat;
the anticipated 25-year life of the project; and the likelihood of dispersing Yuma clapper rails due
to limited habitat availability at the Refuge. Based on this, we recommend First Solar considers