Arkansas Valley Audubon Society
www.SoCoBirds.org

AVAS exists to promote the conservation of nature through education, political action and field activities. Our focus is on birds, other wildlife, and their habitat in Southern Colorado.

SeEtta Moss
Conservation Chairperson
725 Frankie Lane
Canon City, CO 81212
January 26, 2012

Saguache County Commissioners
Saguache County Land Use Dept.
P.O. Box 326Saguache, Colorado 81149

REF:  1041 Application by Solar Reserve

Dear Board of County Commissioners:

Please accept these comments from the Arkansas Valley Audubon Society which is the local chapter of the National Audubon Society which represents approximately 500 members who live in the San Luis Valley as well as parts of So. Central and southeast Colorado.   Arkansas Valley Audubon Society is a proud supporter of the Sand Dunes National Park and the Baca National Wildlife Refuge, both of which are located predominately in Saguache County.   Many of our membership have recreated in your county as they engage in bird and wildlife watching.  I would add a personal note that I have visited Saguache County on many occasions to not only watch birds and the other wonderful wildlife resources in your county but to conduct wildlife surveys.  Like many others who are bird and wildlife tourists I have stayed in lodging in the Crestone area, visited the Alligator Farm on several occastions and purchased food in several locations in your county.

Conservation and enhancement of natural resources including birds, bats and other wildlife pay off for local areas.  The Department of the Interior's report, 2006 National Survey of Fishing, Hunting and Wildlife-related Recreation, found that in 23 million persons engaged in watching wildlife away from home in 2006--this is the number that not only watches birds and wildlife at home but travels away from home to do so.  They spent $12.9 Billion on trip related expenses.   There are additional economic impacts from hunting.  I point this out as I have serious concerns about the potential for serious negative impacts on the birds, other wildlife and their habitat from the industrial scale solar projects proposed by Solar Reserve.  I certainly understand that Saguach County is interested in the economic value that Solar Reserve states it has the potential to provide to the county.  However, if that project damaged the natural resources in Saguache County the long term economic interests of Saguache County residents could significantly reduce or even negate any economic value of locating this industrial project there.

I have reviewed the December 9, 2011 written comments from Colorado Parks and Wildlife that was available on your county website.  I was unable to find the comments from the United States Fish and Wildlife Service that I understand were also submitted and which also outlined serious concerns about the impacts from the proposed Solar Reserve industrial project.   The Arkansas Valley Audubon Society supports the concerns raised by Colorado Parks and Wildlife as well as their recommendations.  We especially support their recommendation that if Saguache County decides to provide a permit for this industrial project that the 1041 permit requires that Solar Reserve implement an avian protection plan and that it be accomplished and approved by the professionals in the Colorado Parks and Wildlife Department as well as the United States Fish and Wildlife Service. 

I would like to add an additional concern about the potential for serious deaths from the tall receiver towers and any supporting tall structures/guy wires to migrating birds during poor weather conditions.  It has been found in a number of other projects that the lights on tall lighted towers can attract large numbers of migrating birds that becomed disoriented in adverse weather conditions, often circling the towers endlessly.  Some of the birds collide with the towers and guide wires while others exhaust themselves.  If you approve this project even with the potential for serious deleterious impacts on birds and resultant negative impacts on the wildlife related economic values in Saguache County, it is vital that this be given proper monitoring and definitely not just chosing 3 or so days in a year to monitor.

In conclusion, Arkansas Valley Audubon Society has serious concerns about the impacts that the Solar Reserve industrial-scale solar project will have on the currently excellent wildlife resources in Saguache County.  There are so many potential issues that can result in serious injury, death and other consequences for the birds and wildlife that use migrate through and use this area that we would be most supportive of a denial of a 2041 permit for this project by the Saguache Board of County Commissioners. 

Sincerely,
SeEtta Moss, M.S.
Conservation Chairperson