Pacific Wind Energy Project DEIR - Appendix B

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Appendix B.2 Addendum to Visibility Analysis Technical Report

Transcript of Pacific Wind Energy Project DEIR - Appendix B

Page 1: Pacific Wind Energy Project DEIR - Appendix B

Appendix B.2 Addendum to Visibility Analysis

Technical Report

Page 2: Pacific Wind Energy Project DEIR - Appendix B

PACIFIC WIND ENERGY PROJECT ADDENDUM TO THE VISIBILITY ANALYSIS TECHNICAL REPORT

Prepared for: enXco Development Corporation

4000 Executive Parkway, Suite 100 San Ramon, California 94583

Prepared by: Sapphos Environmental, Inc.

430 North Halstead St. Pasadena, California 91107

May 24, 2010

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INTRODUCTION This Addendum to the Visibility Analysis Technical Report addresses the May 6, 2010, refined conceptual site plan developed by the enXco Development Corporation (enXco) to minimize potential impacts, maximize wind generation capacity, and optimize use of available property. On May 6, 2010, the refined conceptual site plan for the proposed project was modified to include the relocation of 120 wind turbine generators (WTG), relocation of three substations, realignment of two transmission corridors, and the additional option to connect to the Tehachapi Renewable Transmission Project (TRTP) transmission corridor. The new layout includes 69 REpower MM92 2.05-megawatt (MW) WTGs and 66 GE 1.5xle 1.5-MW WTGs, for a total of 135 WTGs (Figure R1.3-1, Conceptual Location of 2.05- and 1.5-MW WTGs). In addition to switching the generator type, the total number of turbines was increased to 135 WTGs. The project applicant is seeking approval for the May 6, 2010, refined conceptual site plan; however, two other conceptual site plans were evaluated in the March 8, 2010, Visibility Analysis Technical Report1 to understand the comparative level of impact resulting from using different wind turbine generators and the associated changes in density and distribution: (1) 120 Vestas V90 3.0-MW WTGs or (2) 125 REpower MM92 2.05-MW WTGs. Consequently, this Addendum revises the March 8, 2010, Visibility Analysis Technical Report with new analysis based on the May 6, 2010, refined conceptual site plan. This Addendum to the Visibility Analysis Technical Report was prepared to analyze the refined location of each turbine, create a photomontage of the new turbine locations, and update a Key Observation Point (KOP) that characterized the changes to the viewshed in a previously undeveloped area of the southwestern portion of the project area, resulting from the May 6, 2010, refined conceptual site plan. Since KOP-7 was analyzed as part of the March 8, 2010, Visibility Analysis Technical Report, the visual simulation for KOP-7 was rerun with the specifications for the May 6, 2010, refined conceptual site plan to account for the refined location, number, type of turbines. REVISIONS TO THE VISIBILITY ANALYSIS TECHNICAL REPORT 1.3 Project Description The May 6, 2010, refined conceptual site plan proposed project facilities would include WTGs, service roads, a power collection system, communication cables, overhead and underground transmission lines, electrical switchyards, up to three project substations, up to seven meteorological towers, and one Operations and Maintenance (O&M) facility. The refined project’s temporary facilities would include construction access roads, laydown areas, and concrete batch plants. Refined project elements are shown on Figure R1.3-1 and include:

• Up to a maximum of 250 1-MW WTGs not to exceed 500 feet in height with associated generators, towers, foundations, and pad-mounted transformers (each WTG could range from 1 MW to 3 MW), for a total generation capacity not to exceed 250 MW of electricity;

• Up to 7 meteorological towers;

1 Sapphos Environmental, Inc. 8 March 2010. Pacific Wind Energy Project Visibility Analysis Technical Report. Prepared for: enXco Development Corporation. Pasadena, CA.

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SOURCE: SEI, enXco

FIGURE R.1.3-1Conceptual Location of 2.05- and 1.5-MW WTGs

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KWF\Q:\1378\1378-009\ArcProjects\WindPRO\AEIR\CncptSitePlan.mxd

LEGEND!( Residences!( GE 1.5-MW!( REpower 2.05-MW

Pacific Crest TrailExisting SCE Transmission Lines and TRTP Approved RouteFranchise RouteOverhead - 230 KV Route 1Overhead - 230 KV Route 2Overhead - 230 KV Route 3PdV and Pacific Wind Secondary Route - Route 4SubstationsProject Boundary

1:72,000

o0 0.5 1 1.5 2

Miles

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• On-site and off-site project access roads, control cables, power collection cables, and transmission lines necessary to serve the proposed project and connect to the California Independent System Operator (CAISO) grid;

• Up to three project substations to step up the voltage generated by the WTGs to meet the electrical transmission system’s 230-kilovolt (kV) voltage;

• One O&M buildings of approximately 4,800 square feet; • Up to 10 yards as temporary laydown construction yards that include up to six

temporary portable batch plant alternative locations for the construction phase of the proposed project (the number of actual batch plants is schedule-dependent, and no batch plants will remain after the completion of construction); and

• One yard would remain as the O&M facility, and up to three yards would remain for the project substation for ongoing use during the life of the proposed project.

The refined project site plan (Figure R1.3-1) is not intended to reflect the precise location of proposed WTGs and structures. Overhead Transmission Lines Transmission Lines to Serve the Proposed Project The project proponent is continuing to evaluate the final alignment of the transmission line and substation locations for the proposed project based on land acquisition and the availability of Los Angeles Department of Water and Power (LADWP) easement crossing rights. The project proponent is therefore proposing four different 230-kV double-circuited overhead transmission line options for interconnection into the proposed Southern California Edison (SCE) Whirlwind Substation location (Figure R1.3-2, Pacific Wind Transmission Alternatives). Transmission line routes, referred to as Route 1, Route 2, Route 3, and Route 4, are depicted on Figure R1.3-2. These transmission lines would consist of a three-phase electrical line design and would be carried on electric poles ranging from 28 feet (for lower voltage and communication lines) up to 150 feet in height. The electrical power poles support three insulators, cross arms, and conductors (wires) per circuit and may support two circuits. Transmission along at least one of these lines will run through the proposed project site to the Whirlwind Substation to serve the proposed project. In the event that construction of the proposed project is phased for purposes of sale or financing, it is possible, although unlikely, that some portions of up to three of these transmission lines would need to be constructed. The more likely scenario is that one or two, but not all three, of the potential transmission lines would be constructed to serve the project. Route 1 and Route 2 Routes 1 and 2 begin at a northerly boundary of the proposed project site and/or a proposed project substation location and then continue in a southerly direction on private easements to the SCE interconnection point. Route 2 would generally be located to the east of Route 1 until it would connect with the SCE interconnection. Route 1, Route 2, or both Routes 1 and 2 would potentially be built regardless of whether construction of the project is phased for purposes of sale or financing.

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o 0 21Miles

KWF\Q:\1378\1378-009\ArcProjects\WindPRO\AEIR\RevisedELEC.mxd

Pacific Wind Transmission Alternatives

LEGEND230 KV Transmission Alternatives

Overhead - 230 KV Route 1Overhead - 230 KV Route 2Overhead - 230 KV Route 3Existing SCE Transmission Lines and TRTP Approved RouteFranchise RouteManzana (formerly PdV) and Pacific Wind Secondary Route - Route 4SubstationsProject Boundary

FIGURE R.1.3-2

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Route 3 A third potential transmission alignment, Route 3, could be constructed in the event that project construction is phased due to sale or financing. Route 3 would initiate at a proposed project substation location in the central portion of the proposed project site and travel in a southwest direction parallel but outside of the southern margin of the LADWP aqueduct right-of-way (ROW) where it would turn southeast along the existing SCE 500-kV lines and then to the SCE interconnection point at Whirlwind. The solid line of this alignment was approved by the California Public Utilities Commission (CPUC) and subjected to the California Environmental Quality Act (CEQA) review process as part of the CPUC’s approval of the TRTP. The dashed portion of the line corresponding to Route 3 is the portion of the line analyzed for the Pacific Wind Energy Project. One or both of the dashed portions of the line could be built to support the interconnection of the project. Each of these potential overhead transmission alignments is anticipated to cross LADWP aqueducts No. 1 and/or No. 2, either at the approved crossing defined in the Manzana (formerly PdV) Wind Energy Project Environmental Impact Report (EIR) or the pending approval of preliminary design and authorization from LADWP. LADWP Aqueduct No. 1 is considered to be eligible for inclusion in the National Register of Historic Places (NRHP) as a contributing element to the proposed First Los Angeles Aqueduct Historical Archaeological District. These electrical crossings would span the entire LADWP easement, meeting the required electrical design criteria for spans and line sag and the lines would not touch the surface of the site at any time, and heavy equipment would not cross the aqueducts during construction except at the LADWP-approved crossing locations as defined in the approved Manzana Wind Energy Project. The proposed project would in addition require SCE 12-kV lines and communication lines for the project substations and O&M facility. These lines would be along 170th Street West, as approved for the Manzana Wind Energy Project and tiered off for the proposed project to the required locations as defined by SCE. The proposed project would also have some lines as required at the power collection system voltage of 34.5 kV, and up to three proposed project substation collection areas. Other Transmission Lines Crossing the Proposed Project Site In addition to the transmission line or lines that would serve the proposed project, one or more additional lines serving the already approved adjacent Manzana Wind Energy Project will run through the proposed project site to the Whirlwind Substation. One alignment route for the Manzana Wind Energy Project, referred to as the “Eastern Alignment,” begins at the collector substation on the Manzana Wind Energy Project site (not shown on Figure R1.3-2) and trends to the southeast across properties under the control of the project developer and is shown as the Manzana–Pacific Wind Secondary Route (Route 4) on Figure R1.3-2. The Eastern Alignment follows a route previously analyzed in the PdV Infill Wind Energy Project Addendum to the EIR for both an electric distribution line and fiber optic line to a point on the southeastern boundary of the Manzana Wind Energy Project site where the alignment joins 170th Street. Near the point where the Eastern Alignment would intersect 170th Street, the transmission line would trend north-south and cross the California Aqueduct. The Eastern Alignment remains on the west side of 170th Street and continues south for 3.25 miles, directly to the Whirlwind Substation.

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Alternatively, the Manzana Wind Energy Project could be served by a transmission line proposed to be located in or next to the Kern County ROW, referred to as the “Franchise Route.” The Franchise Route would begin from a proposed project substation and travel east to the north side of Los Angeles Department of LADWP Aqueduct No. 1 (Figure R1.3-2). The line would then turn south following the access route approved for the Manzana Wind Energy Project by Kern County in July 2008 and then along 170th Street West to the SCE Whirlwind Substation interconnection point. The portion of the line extending from the LADWP Aqueduct No. 1 to Rosamond Boulevard would be within or next to the alignment of an access road ROW that has been dedicated to the Manzana Wind Energy Project, but not yet accepted by Kern County. South of Rosamond Boulevard, the line would follow 170th Street West, an existing public road, to the SCE Whirlwind Substation. A final alternative transmission route being considered for the Manzana Wind Energy Project, referred to as the “Western Alternative,” could potentially pass through the proposed project site from the northwest to the southeast (Figure R1.3-2). The Western Alternative would originate near the center of the Manzana Wind Energy Project site and travel to the southwest for approximately two miles where it intersects the existing SCE transmission line corridor located on the western boundary of the proposed project site. The Western Alternative would then proceed in parallel on the east side of the SCE transmission corridor southeasterly to its intersection with the proposed SCE Whirlwind Substation. This alternative has been subject to environmental review by the CPUC under the TRTP. The use of overhead electrical lines in the proposed project site is limited to the interconnection from up to three substations and switchyard to the interconnection point of the utility. The 34.5-kV electrical collection systems would be double-circuited transmission structures. The structure type and design is not specified for the 230-kV overhead transmission lines; therefore, they could be wooden monopoles, wooden H-frames, or tubular steel poles (TSPs). TSPs would be visually compatible with the WTG monopoles of the proposed project. 3.2 Assessment Methods and Models At the request of Kern County, each KOP was described according to the four California Public Utilities Commission visual condition factors: visual quality, viewer types and volumes, viewer exposure, and visual sensitivity. KOP-7 was updated to characterize new project areas developed as a result of the May 6, 2010, refined conceptual site plan. KOP-7 is located southwest of the proposed project property at the intersection of 220th Street West and Avenue A (Figure R.3.2.1-1, Visibility Analysis Observation Point Index for 2.05- and 1.5-MW WTGs). These two roads have a low traffic volume. This observation point was chosen to give a representative view of the proposed project property from the southwest at a distance where the proposed project is in the background. Figure R.3.4.1-8, Key Observation Point 7 with 2.05-MW Turbines, is a photomontage that includes a photograph showing the existing conditions from KOP-7 and a visual simulation representing how the proposed project would appear after construction. The WTGs are minimally visible from this distance and appear to be two-inch vertical structures on the foothills of the Tehachapi Mountains.

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Observation Point 3

Observation Point 7

Observation Point 1

Observation Point 5

Observation Point 6

Observation Point 2

Observation Point 4

110t

h

Avenue A

170t

h

Rosamond

220t

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Avenue C

FIGURE R.3.2.1-1Visibility Analysis Observation Point Index for 2.05- and 1.5-MW WTGs

KWF\Q:\1378\1378-009\ArcProjects\WindPRO\AEIR\Viz_Index.mxd

LEGEND!( Residences!( GE (1.5-MW)!( REpower (2.05-MW)

A Observation Points

Roads

Pacific Crest Trail

Los Angeles Aqueduct

Proposed Project Property

o0 1 2 30.5Miles

1:84,000

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FIGURE R.3.4.1-8

Key Observation Point 7 with 2.05-MW Turbines

Existing Condition

Visual Simulation

KWF\Q:\1378\1378-009\ArcProjects\WindPRO\AEIR\Vis_Obs7_5-2010.mxd

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3.4 Results Although the refined location, number, and type of WTGs affect the locations from where these WTGs would be visible within the proposed project area, the analysis of the refined site plan indicates that the results remain the same as the original March 8, 2010, Visibility Analysis Technical Report. Due to the construction of the proposed project, impacts would be significant and unavoidable. Seven (7) KOPs were selected for detailed analysis in the Draft EIR, based on their ability to exemplify visual resource impacts at particular locations. KOPs that were analyzed are representative of project-induced visual resource impacts to this particular landscape. Visual Impacts at Specific KOPs There are two primary and paved public use roads from which the public could view the proposed project: Rosamond Boulevard and 170th Street West. In addition, there are some one-lane dirt roads inside and/or near the proposed project site from which the public could view the proposed project. The PCT runs through the middle of the proposed project site in a south-north direction and provides pedestrian and equestrian viewers with a close-up view of the project. The project would result in changes to the visual environment that may result in potentially adverse effects on visual quality throughout the project area. KOP-1 – Northbound 170th Street West KOP-1 is located on 170th Street West, just south of Rosamond Boulevard, heading northbound. KOP-1 provides expansive views north toward the proposed project site. The visual simulation photomontage indicates that 2.05-MW WTGs would be visible in the foreground, middleground, and background to viewers from this observation point. In addition, the proposed project would partially obstruct and degrade the view of the mountains in the more distant background from this vantage point. Viewers who would be affected by the aesthetic impacts at or nearby this observation point include drivers on 170th Street West and West Rosamond Boulevard, and residents of nearby homes along 170th Street to the south of this KOP. Overall Visual Change Construction of the proposed project would result in approximately 20 to 30 WTGs being visible in the foreground, middleground, and background range of views from KOP-1. However, the WTGs are set back from 170th Street and Rosamond Boulevard, and therefore would not be expected to impact the immediate foreground view. The WTGs closest to the mountains would be farthest from the viewer, or would be in the background range and therefore only slightly obstruct the view. Visual Sensitivity/Visual Change With the exception of a few residents located along 170th Street and Rosamond Boulevard, the majority of viewers would be traveling past this KOP only expecting to see low vegetation such as creosote bush scrub and native grassland. The addition of WTGs expanding beyond this intersection into the vegetation would be obvious, causing a change to the existing visual characteristics of the location.

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Due to the number of WTGs visible from this KOP and considering viewers would be in motion, the overall visual sensitivity would be considered low to moderate while the overall visual change would be moderate, adverse but not significant. KOP-2 – Northbound PCT KOP-2 is located on northbound PCT, the usual direction that through-hikers would take on this stretch of the PCT. At this point, hikers and equestrians have been walking or riding through the flat desert landscape of the northern Antelope Valley for approximately 20 miles. This observation point is located on a dirt road south of the proposed project site, looking northeast along the PCT. KOP-2 provides expansive views north and east toward the proposed project site from the PCT. The visual simulation photomontage indicates that the 2.05-MW WTGs would be visible in the middleground and background to viewers from this vantage point. Viewers who would be affected by the aesthetic impacts at this observation point include hikers and equestrians along the PCT. Overall Visual Change From KOP-2, only a few WTGs would be visible in the middleground after construction of the proposed project. In the background range, approximately 10 to 15 WTGs would be visible. However, these WTGs would appear to be very small. As a result, there would be very little visual change for the viewer from this KOP. Visual Sensitivity/Visual Change If a viewer were standing at the location of KOP-2, they would see vegetation on both sides. Off in the distance, the viewer would see small rolling hills covered predominantly with creosote bush. The majority of viewers traveling on the PCT include hikers and equestrians. These users are considered to be very sensitive to aesthetic changes to their environment. Construction of WTGs along-side the PCT would be of moderate-to-high concern to these visitors. However, given the low number of WTGs in the middleground and the distance from the WTGs in the background, the overall visual sensitivity would be considered moderate while the overall visual change would be low-to-moderate. KOP-3 – Northbound PCT KOP-3 is located on northbound PCT, the usual direction that through-hikers would take on this stretch of the PCT. At this point, hikers and equestrians are located near the middle of the proposed project site on a dirt road. KOP-3 provides expansive views from within the proposed project site along the PCT in the four cardinal directions. An approximately 5-mile portion of the PCT bisects the proposed project site from north to south. Users of the PCT are recreational hikers that would be expected to be highly sensitive to changes in visual quality. The visual simulation photomontage indicates that 2.05-MW WTGs would be visible in the foreground, middleground, and background to viewers from this observation point. In addition, the proposed project would partially obstruct and degrade the view of the mountains in the more distant background from this vantage point. Viewers who would be affected by the aesthetic impacts at this observation point and along the PCT as it crosses the proposed project site include hikers and equestrians. In addition, the WTG layout include WTGs that would be within 300 feet of the PCT and thus, within the immediate foreground distance zone for trail users; at this proximity, the aesthetic impacts of the proposed project would be more severe.

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Overall Visual Change Several WTGs visible from KOP-3 are located within the foreground range and a few WTGs fall into the background range, partially blocking the mountains. The overall number of WTGs visible from KOP-3 would be less than five, but the impact of adding WTGs in this remote section of the PCT would be potentially significant to the visiting recreational users. Visual Sensitivity/Visual Change The majority of viewers utilizing the PCT include hikers and equestrians who are considered to be highly sensitive to changes to their aesthetic environment. At this section of the PCT, viewers are generally surrounded by small rolling hills and native vegetation. The Tehachapi Mountains are visible to the north. Due to the KOP being centralized in the project and surrounded on all four cardinal sides by the natural beauty of the terrain, the overall visual sensitivity would be considered moderate-to-high while the overall visual change would be moderate, adverse and potentially significant. KOP-4 –PCT Looking South KOP-4 is located on the PCT at the northern extent of the proposed project site. At this location, the PCT is a single-track hiking and equestrian trail, rather than a dirt road, as was the case for KOP-2 and KOP-3. KOP-4 provides expansive views south toward the proposed project site from the PCT. The visual simulation photomontage indicates that the 2.05-MW WTGs would be visible in the foreground, middleground, and background to viewers from this vantage point. Viewers who would be affected by the aesthetic impacts at this observation point include hikers and equestrians along the PCT. Overall Visual Change From KOP-4, only a few WTGs would be visible in the middleground, as well as the background range, after construction of the proposed project. In the background range, those three to four WTGs visible would appear to be very small as a result of the distance. Although the WTGs would not be in the immediate foreground or foreground, the viewer would be on the PCT at the northern most section of the project, which borders the approved Manzana Wind Energy Project. Visual Sensitivity/Visual Change The PCT is popular with viewers such as hikers and equestrians, who are considered to be sensitive to changes to their aesthetic environment and who would most likely be adversely affected by the addition of WTGs within the middleground range. With low vegetation and no landforms or structures obstructing the view of the WTGs from the PCT, viewers’ attention would be drawn to the 500-foot-tall structures. As a result of the KOP being south of the approved Manzana Wind Energy Project, the visual change resulting from the Pacific Wind Energy Project would not be substantial. The overall visual sensitivity and overall visual change from this KOP would be considered moderate-to-high. resulting in an adverse and potentially significant impact for visitors.

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KOP-5 – Northwest Corner of Project KOP-5 is located in the northwest corner of the proposed project site. This observation point was chosen to give a representative view of the proposed project from the northwest. It is representative of the view from a residence that is located near this observation point. KOP-5 provides views toward the proposed project site in a southeasterly direction from the proposed project’s northwestern corner. The visual simulation photomontage indicates that the 2.05-MW WTGs would be visible in the foreground and middleground to viewers from this vantage point. Viewers who would be affected by the aesthetic impacts at or nearby this observation point include the nearby resident. Overall Visual Change The location of KOP-5 is remote and somewhat difficult to access without a four-wheel-drive vehicle but this vantage point is important because of its isolation from major roads or the popular PCT and the fact there are several residences nearby. WTGs will be visible in the foreground, middleground, and background range of KOP-5. Visual Sensitivity/Visual Change There are no landforms or structures in the vicinity and only low vegetation with the San Gabriel Mountains in the background. As a result, there would be unobstructed views of the WTGs from the residences. Although WTGs are not blocked from any vantage point near KOP-5, the location is remote, and the number of viewers is expected to be low. Visual impacts from this KOP would generally affect residents. As a result, visual sensitivity would be low-to-moderate. KOP-6 – Northeast Corner of Project KOP-6 is located east of the northeastern portion of the proposed project site. This observation point was chosen to provide a representative view of the proposed project from the east at a distance where the proposed project is in the middleground. This location is representative of the view from a residence that is located near this observation point. KOP-6 provides expansive views west toward the proposed project site. The visual simulation photomontage indicates that the 2.05-MW WTGs would be visible in the middleground and background to viewers from this observation point. In addition, the proposed project would partially obstruct and degrade the view of the mountains in the more distant background from this observation point. Viewers who would be affected by the aesthetic impacts at or nearby this observation point include the nearby residents. Overall Visual Change All WTGs visible from KOP-6 are either in the middleground or background range. The immediate foreground and foreground would not be altered after construction of the proposed project. The 8 to 10 WTGs visible in the middle and background range will partially obstruct the view of some vegetation and a portion of the view of the mountains in the distance. Visual change from KOP-6 would be considered low-to-moderate.

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Pacific Wind Energy Project Addendum to the Visibility Analysis Technical Report May 24, 2010 Sapphos Environmental, Inc. W:\PROJECTS\1378\1378-009\Documents\Tech Report Addenda_20100517\Addendum Vis Tech Report.Doc Page 10

Visual Sensitivity/Visual Change KOP-6 was chosen due to its proximity to a small residential community that is outside the proposed project area but close enough to be considered visually sensitive to the project. Although the number of WTGs being constructed for the proposed site within the view of this community is approximately 10, the approved Manzana Wind Energy Project would also be visible in the distance, behind the WTGs proposed for the Pacific Wind Energy Project. As a result, the proposed project will not substantially alter the existing visual character of the site. Although nearby residents may be accustomed to seeing WTGs in the project vicinity, adding additional WTGs as a result of the proposed project would result in a visual sensitivity level of moderate-to-high, or adverse but not significant. KOP-7 – 220TH Street West and Avenue A KOP-7 is located at the corner of 220th Street West and Avenue A approximately two miles southwest of the project. This observation point was chosen to provide a representative view of the proposed project from the southwest at a distance where the proposed project is in the background. This location provides an example of the view from local unimproved roads with low traffic volume. KOP-7 provides expansive views northeast toward the proposed project site. The visual simulation photomontage indicates that the 2.05- and 1.5-MW WTGs would be visible in the background to viewers from this observation point. In addition, the proposed project would partially obstruct and degrade the view of the mountains in the more distant background from this observation point (Figure R.3.4.1-8). Overall Visual Change Construction of the proposed project would result in up to 250 WTGs being constructed along the foothills of the Tehachapi Mountains. These WTGs would be visible in the background range from KOP-7. All WTGs would not be visible from this KOP as a result of the distance and topography. The Tehachapi Mountains would be partially obstructed, and the visual change would be considered low-to-moderate. Visual Sensitivity/Visual Change Potential viewers who would be sensitive to visual impacts from this observation point include drivers on the two local roads (Figure R.3.4.1-8). Although nearby residents may be accustomed to seeing WTGs in the project vicinity, adding additional WTGs as a result of the proposed project would result in a visual sensitivity level of moderate-to-high, or adverse but not significant.