20110615 Ver 2_More Info Received_20111219

I[3ERDROLA
RENEWAI3LE5
December 19 2011
Re Desert Wind Pro�ect
Action ID No SAW 2010 00903
Dear Ms Wheeler
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DEC 1 9 2011
DENR WATER QUALI7Y
WETLANGa AND STOR+uIWATER BF,ANCH
Tracey Wheeler
U S Army Corps of Engineers
Wilmington District
2407 W 5th Street
Washmgton NC 27889
This letter has been prepared in response to your comment letter dated December 15 2011
regarding the Desert Wind Pro�ect Below please find each of the questions/comments
provided in your letter with a response to each quest�on comment or request for additional
information
1 Does this pro�ect need to be located within North Carolina for Virgima Electric and Power
Company (VEPCO) to receroe credit for meeting the North Carolina Renewable Energy
Portfolio Standard (NCREPS)�
In 2007 with the signing of Session Law 2007 397 (Senate Bill 3) North Carolma became the
first state in the southeast to adopt a Renewable Energy and Energy Effiaency Portfolio
Standard (REPS) Senate Bdl 3 established that it is the policy of the State of North Carolina to
promote the development of renewable energy and energy efficiency through the REPS Under
Senate Bill 3 investor owned utilit�es in North Carolina are required to meet up to 12 5% of
the�r energy needs through renewable energy resources or energy eff�ciency measures by 2021
Rural electric cooperatives and municipal electric suppliers are sub�ect to a 10% REPS
requirement which must be met by 2018 Investor owned utilities electric cooperatives and
municipal electric suppliers demonstrate compliance with Senate Bill 3 through the direct
purchase of renewable energy or purchase of renewable energy certificates (RECs)
While REPS permits some of its obligations to be fulfilled by out of state renewable energy
resources the Purpose of the Desert Wind Pro�ect as stated in the Executive Summary of the
IBERDROLA RENEWABLES Inc
201 Kmg of Prussia Rd Suite 500
Radnor PA 19087
Telephone[phone]
www iberdrolarenewables us

in�tial Application (page i) and again in Section 4 0 Pro�ect Purpose and Need (page 34) and
further clarified m our response letter submitted to the USACE on November 7 2011 is to
construct a wmd energy generation facility m North Carolina (emphasis added] As clarified in
the November 7 2011 response letter after complet�on of the Pro�ect wind generated power
would help utilities which have a compliance obligation under NCREPS satisfy the requirements
of the REPS While the Pro�ect will be connected to VEPCO s existing 230kV Winfall to Suffolk
transmission Jme this in no way creates any sort of requirement that the energy be purchased
by VEPCO to meet NCREPS obligations if any
a If not must the p�o�ect be located within North Carolina�
The stated Purpose of the Desert Wind Pro�ect �s to construct a wind energy generation facility
m North Carolina (emphasis addedJ and as such any pro�ect located outside of North Carolina
would not meet the stated Purpose of the proposed Desert Wind Pro�ect Further the primary
purpose of the NCREPS is to promote the development of renewable energy and energy
efficiency in the State through implementation of Renewable Energy and Energy Efficiency
Portfolio Standard (REPS)
b Are there other alternatives Iocated in Virgirna (or other states) that meet the pro�ect
purpose as well as your stated site selection criteria a� high quality wind resource b)
location and capaaty of transmission lines and c) available prrvately owned
unconstrained land? These alternatives may also provide for opportumties to further
avoid and minimize impacts to waters of the United States includmg wetlands
As previously stated the Purpose of the Desert Wind Pro�ect is to construct a wind energy
generation facility in North Carol►na (emphasis addedJ This also supports the primary purpose
of the NCREPS as stated above to develop renewable energy in the State of North Carolina
Therefore alternatives located in Virginia or other states would not meet the Pro�ect Purpose
nor support the primary purpose of the NCREPS
2 Must the pro�ect be accomplished within one contiguous area� Is it possible to meet the
pro�ect purpose by developing the pro�ect within smaller areas that would further avoid and
mimmize impacts to waters and wetlands7
There is an increase in efficiency that is realized with a larger contiguous pro�ect In
comparison a pro�ect of simdar output but not designed m a contiguous manner becomes
infeasible and not practicable from various perspectives including
• Cost/Financial —The cost of a larger less dense Pro�ect increases considerably for
reasons including but not limited to longer lengths of overhead and underground
transmission lines greater conductor size and/or capacity (in order to compensate from
losses associated with longer lengths) more roads to connect the infrastructure and a
greater number of properties and/or landowners
2

• Electrical Infrastructure — Larger pro�ects utilize more centralized infrastructure (electric
substations operations & maintenance buildmgs etc) where non contiguous or tess
dense pro�ects may require additional infrastructure as distance between turbines
increase This could result in a larger pro�ect footpnnt simply spread over more area
• Power Generation Efficiency — As power is transmitted over longer distances a certain
portion of energy is lost due to the inefficiencies of transmission The resulting energy
losses are often referred to as Line Losses A larger less dense Pro�ect impedes the
effiaent collection and transmission of the generated power due to the increased
distance between turbmes electrical infrastructure and interconnection points
Resulting line losses can compound in a less dense pro�ect to reach levels prohibitive of
development
• Environmental Impact — a larger pro�ect footprint ultimately would result in an mcreased
area of disturbance having increased impacts on varying land uses could potentially
increase impacts to wetlands and waters of the U S in other locations and would
expand the locations of turbines and supporting infrastructure potentially increasing
other environmental impacts
3 Please provide specific information related to the potential constraints leasing permittmg
economic and operational factors that influenced your decision to pursue a 300MW facdity
(see Page 8 paragraph 6 of your response letter) Is it possible to meet the pro�ect purpose
w�th fewer turbines that would further avoid and mimmize impacts to waters and wetlands�
A detailed history of the siting of the proposed Desert Wind Pro�ect was provided for in the
November 7 2011 response letter As previously noted the initial goal was to develop as much
as 450 MW in the Initial Pro�ect Area Specifically constraints and other factors that influenced
the decision and ultimately led the Applicant to pursue a smaller 300 MW pro�ect include
• Proximity to environmentally sensitive areas including but not limited to National
Wildlife Refuges Albemarle Sound known habitat of Threatened and Endangered
Species
• Proximity to transmission infrastructure
• Proximity to existing homes
• Proximity to public roads
• Proxim�ty to railroads rights of way
3

• Proximity to and potential disruption of microwave beam paths
• Proximity to Department of Defense exclusion zones and restricted airspace
• Proximity to sensitive archaeological cultural or historic resources
• Soil bearing capaaties sufficient to support wind turbine infrastructure
• Areas of insufficient wind resource
• A 300 MW pro�ect achieves economies of scale while being capable to fulfill the
requirements of renewable energy Requests for Proposals (RFPs) from multiple utility
companies
• Atlantic Wind secured agreements with all of the landowners within the pro�ect area
that expressed interest in the Pro�ect However leasing efforts were constrained in
some areas by landowners that were not interested in the proposed Pro�ect Additional
or other parcels of non contiguous land was available for lease but could not be
physically connected to the Pro�ect when other landowners would not participate in the
Pro�ect The eventual amount of land that was secured through lease agreements was
suffiaent to support a 300 MW pro�ect
• A 300 MW pro�ect would take advantage of and maximize economies of scale which are
not achievable by a smaller pro�ect or multiple smaller pro�ects The cost advantages
realized through the efficiencies achieved through a larger pro�ect (i e 300 MW) make
the Pro�ect economically superior and practicable A smaller sized pro�ect or multiple
smaller pro�ects would not be as cost effiaent and therefore would not be economically
viable or feasible or practicable under current market conditions and would not meet
the stated Purpose included within the Application
With regards to wetland mitigation to offset unavoidable permanent impacts to Waters of the
U S associated with the construction of the proposed Desert Wind Pro�ect Atlantic Wind is
accepting of the mitigation ratios suggested m your December 15 2011 letter Specifically
Atlantic Wind proposes to mitigate for impacts to Pine Flat Wetlands at a ratio of 1 25 1 and
impacts to Hardwood Flat Wetlands at a ratio of 2 1 through credits from the Great Dismal
Swamp Restoration Bank (GDSRB) Timberlake Farm As described in the Application the pro�ect
proposes to impact 27 76 acres of Pine Flat Wetlands and 147 acres of Hardwood Flat
Wetlands Based on these areas of impact and mitigation ratios mitigation bank credits to
offset 37 64 acres of impact will be acquired
4

We appreciate the opportunity to respond to your letter If you have any additional questions
or comments or require any additional information specific to the Pro�ect please do not
hesitate to contact me at [phone] or [phone] or via email at
mclavton@iberdrolaren com
We look forward to hearing from you soon regarding this matter
Sincerely
�j
Michael Clayton
Permit Manager
Iberdrola Renewables Inc
Cc David Lekson/USACE
Craig Poff/IRI
Walter Meisner/IRI
Beth Reed/Kimley Horn
lan McMillan/NCDWQ
Stephen Rynas/NCDCM