Tri Global Energy Panther Grove Wind Project November

Tri Global Energy Panther Grove Wind Project November 2020

Mr. Terry Van. De. Walle • Personal Qualifications • • • BS in Animal Ecology; MA in Biology Manage Stantec’s Independence, IA office 14 years experience in the wind industry 27 years experience in Environmental Consulting Pre- and Post-Construction natural resource surveys and permitting at over 150 wind farms in 21 states • Avian, bat, and environmental studies and permitting at 35 wind farms in Illinois

Stantec Consulting Services Inc. • Over 250 offices across North America • Over 3, 900 environmental and engineering staff throughout North America • 250 environmental staff in the Midwest • Stantec has provided environmental and engineering services to more than 400 wind energy projects in the U. S. and Canada • Our Independence, Iowa office is recognized as one of Stantec’s Wind Hub Offices.

Panther Grove Wind Project Consultation History • September 30, 2019 – Illinois Department of Natural Resources (IDNR) Eco. CAT Consultation initiated on a larger study area which included the smaller Project Area • October 31, 2019 – Meeting with IDNR • November 14, 2019 – Meeting with the U. S. Fish and Wildlife Service • January 24, 2020 – IDNR Consultation Letter

Tiered Site Characterization • Conducted a desktop habitat assessment and field studies for species of concern in compliance with the USFWS’s Land-Based Wind Energy Guidelines (LWEG; USFWS 2012). • Tier 1 (Preliminary Site Evaluation) - landscape-scale screening process using existing information sources to identify blocks of native habitat, ecological communities, and other areas of broadscale wildlife value. • Tier 2 (Site Characterization) - focuses on site-specific natural resource information and existing information specific to the Project area to evaluate potential risks to sensitive or protected natural resource features. • Tier 3 (Field Studies) - field studies to document wildlife and habitat and predict potential impacts

National Land Cover Dataset Land Cover Type Total Acres Percent of Total 18, 641. 2 95 940 4. 8 0. 8 <0. 1 Herbaceous/Grassland 1. 6 <0. 1 Open Water 13. 4 <0. 1 Barren Land 2. 5 <0. 1 0 <0. 1 Agricultural Lands (Cultivated Crops and Hay/Pasture) Developed Lands (Open Space and Low to High Intensity Development) Forest (Deciduous, Evergreen, and Woody Wetlands) Emergent Herbaceous Wetland Total 19, 599. 5

National Wetlands Inventory Wetland Type Total Acres Percent of Total Riverine (R 2, R 4, & R 5 types) 90. 1 0. 5 Palustrine Emergent Wetland (PEM) 65. 9 0. 2 Pond (PUB) 7. 3 <0. 1 Freshwater Forested/Shrub Wetland (PFO & PSS) 1. 9 <0. 1 0 0 Lake (lacustrine unconsolidated bottom (L 1 UB)) Total 19, 599. 5

LWEG Species of Concern Migratory Birds • Stantec conducted 1 year of monthly small bird use surveys at 29 survey points from June 2019 -May 2020 (Tier 3 Study). • Cultivated crops and hay/pasture make up 95% of the project area and provide limited breeding habitat. • Total of 41 species observed. The 10 most frequently observed species make up 90. 5% of observations - Lapland longspur, redwinged blackbird, common grackle, European starling, American robin, tree swallow, killdeer, barn swallow, mourning dove, and horned lark. • The state-endangered upland sandpiper was also observed.

LWEG Species of Concern Eagles • Stantec conducted a raptor nest search on February 27 and 28, 2020. No eagle nests were found within 1. 5 miles of the Project. • Stantec is conducting a 2 -year eagle use survey (June 2019 -May 2021) in compliance with the USFWS Eagle Conservation Plan Guidance. 1. 60 -minute point counts are conducted within an 800 -m radius by 200 -m height survey plot at 29 points. 2. To-date (17 survey events), there have been 6 bald eagle observations during 493 survey hours for a total of 10 eagle flight minutes. 3. Results to-date indicate low eagle use of the Project area.

LWEG Species of Concern Other Large Birds • Surveys on-going (June 2019 -May 2021) using the same methods as for eagles. • To-date, 14 species have been observed. • The 5 most frequently observed species (88. 5% of observations) include Canada goose, turkey vulture, American crow, red -tailed hawk, and mallard. • The Canada Goose makes up 43% of all observations. • The state-endangered northern harrier has been observed.

LWEG Species of Concern Panther Grove Commits to the following Conservation Measures for Birds to Minimize Collision Risk • MET towers will be self-supporting, unguyed, lattice steel towers. • Collection and communication lines are buried to minimize and avoid collision and electrocution risks to eagles and other avian species. • In accordance with the LWEG, all project substation lights are a low voltage light (white incandescent), pointed downward, and used only when needed. • All employees on-site are required to turn off internal lights in turbines at night when lights are not required for safety or compliance purposes. • Personnel involved in the construction and operation of the Project will receive annual environmental awareness training and all wildlife injuries and mortalities found within the project area will be reported via an avian and bat incident report form. • Panther Grove has prepared a Bird and Bat Conservation Strategy describing the Project’s avian conservation measures.

LWEG Species of Concern Threatened and Endangered Species • The IDNR Eco. CAT report (September 30, 2019) identified the upland sandpiper as a state-listed wildlife species with known records in the project vicinity. • Upland sandpipers were observed during the small bird use survey. Agricultural lands with grassed waterways provide suitable nesting and stopover habitat for the upland sandpiper. Generally considered to be at lower risk of collision mortality. • Northern harriers were observed during avian use surveys. Generally considered at a lower risk of collision mortality due to their hunting habits. • Two federally- and state-listed bat species that have ranges that include Woodford County: 1. 2. Indiana Bat Northern Long-eared Bat

Bat Habitat Assessment and Acoustic Survey (Tier 3 Study) Location Within Project Area Suitable Summer Habitat Unsuitable as Summer Habitat (acres) 0. 9 54. 5 • Acoustic survey conducted August 2 – August 4, 2019 using USFWS survey guidelines • Total of 9 bat species recorded. • Results indicate probable absence of the Indiana bat and northern long-eared bat during the summer maternity season.

LWEG Species of Concern Panther Grove Commits to the following Conservation Measures for Bats to Minimize Collision Risk • Per USFWS recommendations, all turbines have been sited more than 1000 feet from suitable bat habitat to avoid summer risk. • Per the IDNR’s recommendations, from sunset to sunrise from August 15 through October 15, turbine cut-in speeds will be raised to 5. 0 meters per second (m/s) at all project turbines. • Panther Grove has prepared a Bird and Bat Conservation Strategy describing the Project’s bat conservation measures.

IDNR Consultation Letter (January 24, 2020) Recommendation #1: The Department recommends that the County consider requiring the applicant to curtail wind turbine operations below 5. 0 meters per second, from sunset to sunrise, between July 15 and October 15 to minimize the risk of take of listed bat species and to minimize mortality of all bat species more generally. ______________________________ • • • Panther Grove agrees to comply with this recommendation. Please note this will replace the language in Panther Grove’s application which stated cut-in speed would be raised to 4. 0 m/s from sunset to sunrise from July 15 – October 15 when air temperature is above 50 F. After further consideration, Panther Grove has decided to take the more protective approach.

IDNR Consultation Letter (January 24, 2020) Recommendation #2: The Department recommends the County consider requiring three years of mortality monitoring to statistically quantify bird and bat mortality, by species, due to turbine operations. If the County chooses not to do so, the applicant should consider implementing such a program to demonstrate the level of mortality experienced and the species affected. • The Department recommends a proposal on bird and bat mortality monitoring be sent to the Department for review and concurrence on methods and a report on results annually. The project proponent should seek the necessary research permits from the Department’s Office of Resource Conservation to handle birds and bats. If state-listed species are found during this monitoring, ITA would likely be recommended. __________________________________________ • Panther Grove agrees to comply with this recommendation. • Panther Grove will conduct three fall seasons of post-construction mortality monitoring. Standardized carcass searches will be conducted on the roads and pads within 40 meters of the turbine center at all turbines from July 15 – October 15. Searcher efficiency and carcass removal trials will be completed once during each survey season to aid in statistical analysis of results. • Panther Grove will maintain records of findings of wildlife fatalities using project environmental documents. The method for estimating overall bird and bat fatality rates will make use of contemporary, peer-reviewed equations. An annual report describing the methods and results of the post-construction monitoring will be prepared and submitted to Woodford County and the IDNR. • Panther Grove will submit the 3 -year post construction monitoring plan to IDNR for approval. Panther Grove will provide the County with the IDNR’s approval of the plan as part of the Project’s County Building Permit application. • If at some point during bird and bat mortality monitoring of the project a state-listed species is found, Panther Grove will seek an Incidental Take Authorization (ITA) from the IDNR for that listed species.

IDNR Consultation Letter (January 24, 2020) Recommendation #3: The Department has coordinated with the applicant as it pertains to setbacks from the Mackinaw River Illinois Natural Areas Inventory site that bisects the proposed project footprint. The Department has previously recommended 0. 5 mile wind turbine setbacks from all INAI sites. After review, the Department has determined that a 0. 5 mile setback is not necessary north of CR 1600 N due to the agricultural and channelized nature of the river in this area of the project. • South of CR 1600 N, the Department recommends a 0. 5 mile setback from the Mackinaw River INAI site still be applied to turbines. • Additionally, the Department requests further coordination for any instream work required for the installation of this facility that occurs south of CR 1350 N. This request has been previously discussed with the applicant. __________________________________________________________________ • Panther Grove has implemented all recommended setbacks.

Woodford County Zoning Ordinance - Section 154. 28. 15 A. An avian study shall be conducted by a qualified third-party professional, such as an ornithologist or wildlife biologist, to determine if there is any potential impact the WECS project may present to migratory birds. The study must provide assurances that the WECS project does not negatively impact the path of migratory birds. The applicant’s plan for the avian study must be brought to the Zoning Board of Appeals public hearing, and the final results of the study shall be provided to the Zoning Enforcement Officer prior to the issuance of a building project. __________________________________________________________________ • • On behalf of Stantec, Mr. Van. De. Walle has conducted pre- and post-construction natural resource surveys and permitting at over 150 wind farms in 21 states; including avian, bat, and environmental studies and permitting at 35 wind farms in Illinois. A small bird use survey that included the spring and fall migratory seasons was conducted at Panther Grove from June 2019 to May 2020. Large bird/eagle use surveys were started in June 2019 and are on-going with surveys scheduled to be completed in May 2021. Results of the Tier 1 – 3 studies and the Project’s landscape position (i. e. , not along a major migratory pathway) indicate the Project will not negatively impact the path of migratory birds.

Woodford County Zoning Ordinance - Section 154. 28. 15 B. Pursuant to the Illinois Endangered Species Protection Act (520 ILCS 10/1 -11), the Illinois Natural Areas Preservation Act (525 ILCS 30/1 -26), and the Interagency Wetland Policy Act (20 ILCS 830), the Illinois Department of Natural Resources shall be consulted by the WECS applicant and final evaluations of the findings shall be provided to the Zoning Enforcement Officer prior to the issuance of a building permit. __________________________________________________________________ • Panther Grove initiated consultation with the IDNR in September 2019 and consultation will continue as necessary as the project moves forward, including but not limited to, providing a post-construction monitoring plan for IDNR approval and providing results of the 3 -year post-construction mortality monitoring as available.