Resource Library Category: Virginia (22 items)
Documents presented here are not the product of nor are they necessarily endorsed by National Wind Watch. This resource library is provided to assist anyone wishing to research the issue of industrial wind power and the impacts of its development. The information should be evaluated by each reader to come to their own conclusions about the many areas of debate.
Denial of permission for met towers in George Washington National Forest
Source: U.S. Forest Service
Date: April 2, 2009
Timothy Williamson
Freedomworks, LLC
525 Wren Lane
Harpers Ferry, WV 25425
Dear Mr. Williamson:
This letter is sent in response to your application for permit to install three Meteorological Towers (MET) on Great North Mountain, located on the Lee Ranger District of the George Washington National Forest. The purpose of the towers is to collect meteorological data. As you indicated, the data collected will aid in preparation of a future proposal to install 131 wind turbines, each with the capacity to generate 2MW and create at least 500 acres of permanent openings. After careful consideration, I have concluded we can not accept your proposal.
As I understand it, you received the screening criteria we use to review proposals. The screening criteria are in Forest Service Handbook (FSH) 2709. There are two areas of immediate concern in relation to the criteria when applied to your proposal. The first criterion of concern is compliance with the George Washington National Forest Revised Land and Resources Management Plan (Forest Plan). The second criterion is the justification to utilize national forest land.
FSH 2709.11, Chapter 10, Section 12.21(2), states the proposal must be consistent or can be made to comply with standards and guidelines in the applicable forest land and resource management plan prepared under the National Forest Management Act. Your expressed intent to install 131 commercial wind turbines on Great North Mountain, requires me to consider this proposal in relation to our Forest Plan standards and guidelines.
Your proposal is within Management Area (MA) 14- Remote Habitat for Wildlife, as identified in the Forest Plan. This portion of MA14 is approximately 11,053 acres in size and currently has 0.9 miles of open road. The Forest Plan standard could accommodate an additional 1.9 miles of road. Your proposal requires construction of at least 16 miles of road. While the roads could be closed to all but the contractor, the amount of time the roads would be used, would constitute activity at a level equivalent to an open road, thus exceeding the Forest Plan standards.
Forest Plan Standards, pg 3-75, states the area is managed to meet a visual quality objective of partial retention. In order to meet partial retention, management activities must remain visually subordinate to the characteristic landscape. It would be difficult to say a tower over 400 feet in height overlooking the Shenandoah Valley is visually subordinate to the characteristic landscape. It would be even more difficult to portray a series of 131 towers, over 400 feet, along Great North Mountain, as subordinate to the characteristic landscape.
In addition to the visual concerns, the recreation opportunity assigned to this portion of Management Area 14 is Semi-Primitive Motorized. The description of Semi-Primitive Motorized areas is: “The area has high probability of isolation from sights of human activities, though an occasional primitive road, power line, or evidence of vegetation manipulation may be seen. Visitors perceive themselves as removed from human activity and experience solitude and serenity but occasional distant sounds may be heard. Motorized access by the public is highly restricted or non-existent. Existing roads are maintained and infrequently used for administrative purposes. Opportunity for self-reliance, challenge and risk exist. The area can be natural in appearance with occasional evidence of vegetation manipulation.” The towers, the access roads and the level of use on the road to maintain the towers do not meet the desired condition of Semi-Primitive Motorized Recreation.
MA14 areas are managed to maintain or enhance habitats for wildlife species by favoring a mature forest environment that provides a continuous supply of hard and soft mast and high value timber products. The area is characterized by dense vegetation cover and freedom from continued disturbance. Development of your project would permanently open-up at least 500 acres of forested land. This activity would not meet the desired conditions of providing remote habitat for wildlife as described above.
It is important to advise you of a new concern that recently emerged in Virginia and West Virginia that must be taken into account with the activities you wish to conduct; White Nose Syndrome (WNS) on bats. Within the last three months, this illness was discovered in caves in both states, south of your proposed project area. Unfortunately, WNS killed thousands of bats and has already killed hundreds in the newly discovered areas. This new discovery, combined with the history of commercial wind turbines killing bats, adds to the concerns over this project; especially when you consider the Indiana Bat, a Federally Endangered Species, are believed to be within your proposed project area and are hibernating in caves now affected by the WNS.
Also, FSH 2709.11, Chapter 10, Section 12.32a states; the proponent must explain the selection of the location of the proposed use and why use of National Forest System lands is necessary and why lands under other ownership cannot be used. Forest Service policy goes on to state “Deny proposals for use of National Forest System lands when the request is based solely on affording the proponent with a lower cost or less restrictive location than can be obtained on non-Federal lands”. A significant part of your rationale for the use of Great North Mountain focuses on needing to generate power within a 100 mile radius of Washington DC. A cursory look of that 100 mile radius shows numerous opportunities for your proposal in areas other than national forest. Some of these areas exist in the ocean; which is said to provide the best wind resources near D.C., other areas exist in the Chesapeake Bay, and on dozens and dozens of ridgelines in VA, MD, WV, and PA. I believe there are ample opportunities to implement your project in areas other than National Forest System lands and your proposal does not provide sufficient rationale as to why these areas can not be utilized.
If you choose to consider pursuing another wind proposal on National Forest land, the proposal must address Forest Plan compliance requirements and provide a sufficient justification for why private lands can not be utilized. Should you have any questions or concerns please contact District Ranger James Smalls at 540-984-4101.
Sincerely,
/s/Maureen T. Hyzer
MAUREEN T. HYZER
Forest Supervisor
BP Option and Wind Energy Easement Agreements
Source: BP Wind Energy North America
Download original document: “BP Option Agreement”
Download original document: “BP Wind Energy Easement Agreement”
Gone With The Windmills? A Plea to President Obama to Save the National Forests of Appalachia
Source: Bolgiano, Chris
Dear President Obama:
Thanks to you, America is turning green again, nearly forty years after I went “Back to the Land” as part of the first Earth Day generation You came within twenty miles of my passive-aggressive solar homestead on Cross Mountain last October, when you spoke in Harrisonburg, Virginia.
Surely, as you flew into the Shenandoah Valley airport, you noticed to the west the long, sinuous lines of forest-covered mountains, fall colors blazing in faux fire.
A century ago you would have seen smoke billowing from real fires, caused by a rampage of steam-powered logging. Flooding caused by deforestation of the mountains became so costly by 1911 that Congress passed the Weeks Act, authorizing the U.S. Forest Service to buy land from willing sellers and repair environmental damage. Some of the highest ridges you saw when you looked westward are in national forests that were established then, along the spine of the Southern Appalachian Mountains.
These forests now face their greatest threat in a century.
Reflecting a nearly 50% nationwide increase in wind electricity plants in 2007, developers are arriving in what they themselves called “a gold rush” at a recent industry conference. There, a wind map ranked thin red currents along the highest Appalachian ridges as just possibly strong enough to power turbines for massive industrial wind installations.
Glossy ads for wind power always show turbines in open fields, never in forests. That’s because every turbine requires up to five acres of deforestation. Hundreds of turbines are being built here, burgeoning to tens of thousands if the U.S. Department of Energy indiscriminately pursues its “20% Wind Energy By 2030” program. Do the math, and factor in the forest fragmentation that multiplies the loss of habitat, and the super-wide new roads that destroy the last remote, wild ridges.
Slender, rocky ridges are blasted and bulldozed to flatten pads for turbines. Each pad requires hundreds of tons of concrete. After the 25 year life span of the huge machines, the pads remain as dead ground but possibly good tennis courts in a summer camp for giants in the future.
Deforestation is the largest source of greenhouse gas emissions after fossil fuel burning. The rest of the world agreed at the recent U.N. climate summit to protect maturing forests that sequester huge amounts of carbon dioxide — like those now healing from old abuse in the Southern Appalachians. In Transition to Green, the 400 pages of nature tips sent you by a coalition of environmental organizations, the first recommendation for the U.S. Department of Agriculture is to “manage the national forest system to secure climate benefits.”
Industrial wind will blow this opportunity away.
It’s already blowing away a lot of wildlife. Turbine blades reach 450 feet above ridge crests where songbirds migrate, bats feed, and eagles rise on thermals. Just across the state line in West Virginia, thousands of creatures are being killed every year at new wind plants, the highest kills ever documented worldwide from turbines. The U.S. Fish and Wildlife Service strongly recommends against turbines on nearby Shenandoah Mountain due to the likelihood of killing endangered species, yet several projects are underway.
Some of the people living near turbines suffer from chronic sleeplessness and other symptoms of Wind Turbine Syndrome (including depression over loss of property values).
Death, destruction and insomnia are marketed to urban consumers as “green” electricity, what little there is of it. Turbines produce only about 30% or less of their maximum rated capacity, and some of that is lost along hundreds of miles of transmission lines. When the wind does blow, the aging lines can hardly handle the surge.
What drives this high-cost/low-benefit gold rush is the federal production tax credit. More tax breaks beckon in national forests, where no local property taxes are levied so local communities wouldn’t share in revenues produced by turbines, plus the Forest Service helps pay for building roads. In the three years that the federal tax credit hasn’t been reauthorized since first enacted in 1992, the skyrocketing wind industry plateaued like a mountaintop-removal coalmine.
The coal mining that has ravaged the land and people in part of Appalachia for a century is our major source of electricity, and is obscenely destructive to forests. But destroying more forests in order to stop destroying forests doesn’t make sense. And building industrial wind plants in Appalachia isn’t change. It’s a 21st century version of the same old pattern of taking value out and leaving costs behind.
These ancient mountains are well-documented as the biologically richest temperate woodlands in the world, one of North America’s greatest natural treasures, rich in globally rare species and communities, including human ones. So you can’t dismiss my aging hippie protest merely as NIMBY, which in any case is simply love of place. It breaks my heart to see these murdered old mountains assaulted again.
Since 1911, the Forest Service has salvaged the land and regenerated trees in watersheds that, today, supply drinking water to millions of people (not to mention clean air). Tens of millions of people depend on these national forests for access to the outdoors, spending in local economies as they go. Timber from regulated harvests supports local companies. National forests are the last vestige of the rural commons …
Raptors and Wind Energy Development in the Central Appalachians
Source: Katzner, Todd; Brandes, David; Lanzone, Michael; Miller, Trish; and Ombalski, Dan
There is little current available information as to how wind energy projects in the central Appalachians area will affect bird populations (NRC, 2007). However, it is known that diurnal raptors are generally at higher risk for collision with turbines than are many other avian species (NWCC, 2004). Furthermore, potential cumulative effects on birds are broader than just those from direct collisions. In particular,
- increased energetic costs of migration,
- avoidance of preferred migration pathways, and
- change or loss of migration habitat
are of special concern. In spite of the variety of potentially significant environmental impacts on birds and other wildlife, the impact of large numbers of turbines along Appalachian ridge-tops is not well studied. These environmental impacts need to be investigated and quantified at both the site and regional scales so that well informed decisions can be made about where bird-friendly wind energy facilities can be constructed. …
At present there are no peer-reviewed scientific studies that quantify risk — collision, behavioral or otherwise — to raptors from turbines in the Appalachian region. The few post-construction studies conducted have not been published in peer-reviewed journals and it is difficult to assess their quality. Furthermore, these studies provide little generalized information because when they identify turbines that kill few raptors, they do not differentiate between areas with many birds (low risk) from areas with few birds (low exposure). Thus, the existing mortality data, generated at installations away from known migration pathways and concentration areas, cannot be extrapolated beyond these specific sites (Drewitt and Langston, 2006; Madders and Whitfield 2006). In short, there is no reasonable basis to conclude that risk of new turbine development will or will not affect raptors without additional studies designed to quantify the impact of turbines.
Due to the lack of data discussed above, we strongly recommend a coordinated effort by raptor biologists, regulators, and developers to study the impacts of wind turbines on raptors in the Appalachian region. Valid assessments require extensive studies at proposed and existing sites using Before and After Control Impact (BACI) study design, as well as regional-scale research on the potential impacts of wind energy facilities on migration and wintering behavior (NWCC, 1999). Mitigation methods such as micro-siting (e.g., setbacks from sloping terrain), improved rotor tip visibility, and/or flexible operation schedules that reduce turbine speeds during peak conditions for migration could then be developed to reduce risk to eagles and other raptors.
It seems reasonable to predict that turbines sited away from primary migration pathways and topographic “leading lines” such as ridge-tops and prominent escarpments, are relatively less likely to pose significant risk to raptors than are turbines on those pathways and leading lines. However, data are needed to confirm this hypothesis. Therefore, we believe that all wind energy sites proposed in the Appalachian Mountains must be monitored for wildlife interactions with a multiyear pre-and post-construction scheme using transparent and peer-reviewed methodology. Such an approach is the only way to provide the data required to understand the actual risk at specific sites and to identify sites that are likely to pose the least risk to golden eagles and other flying animals.
The Golden Eagle as a High-Risk Species
The size of the eastern North American population of golden eagles is small and therefore highly vulnerable to demographic perturbations. Even low levels of turbine-associated or other mortality may be significant for long-lived species with low reproductive rates and slow maturation rates (Drewitt and Langston, 2006; Katzner et al., 2006). Golden eagles tend to migrate and winter within areas of the central Appalachians that are currently under development or targeted for future development by wind energy companies. This species commonly uses slope soaring and ridge updrafts during migration and foraging, flight patterns which are known to increase collision risk (Barrios & Rodriguez, 2004; Hoover & Morrison, 2005). It is for these reasons and others that golden eagles are therefore highly susceptible to collision with some wind turbines (Hunt, 2002; Smallwood & Thelander, 2004). Because of their demography, migration and winter flight behavior, and vulnerability to wind turbines, we consider eastern golden eagles to be the raptor species at greatest risk of population-wide impacts from wind energy development in the Appalachians.
Available monitoring data and modeling strongly suggest that eastern golden eagles migrate through a narrow corridor in south-central Pennsylvania (particularly during spring; Brandes & Ombalski, 2004). This corridor includes portions of Bedford, Blair, Centre, Fulton, Huntingdon, Mifflin, and Somerset Counties and likely extends southward through Maryland into West Virginia. Thus, we consider the Allegheny Front and the five adjacent ridges to the east to be a zone of high risk for potential impacts to golden eagles. A primary area for potential development of wind energy is exactly in this same corridor that golden eagles use so heavily (USFWS, 2005). In addition to this corridor, the Kittatinny Ridge (Blue Mountain) is well known as a significant migration pathway for golden eagles and many other raptor species and is also an area of high risk for conflict between birds and wind turbines.
Audubon Christmas Bird Count data and a great deal of anecdotal information suggest that some regions of Virginia (Highland County, Tazewell County) and West Virginia (Pendleton County, Grant County) are important wintering areas for golden eagles. There also is mounting evidence that immature golden eagles regularly summer in these areas. In addition, our preliminary telemetry data and remote camera surveys suggest that many more golden eagles winter in Pennsylvania than indicated by CBC data. Studies suggest that raptors are at highest collision risk when foraging (Hunt, 2002; Hoover & Morrison, 2005), thus wind energy projects in wintering areas should include pre- and post-construction monitoring throughout the year, not just during migration periods.
Our Research
The over-arching objective of our research is to develop a quantitative understanding of where, when and how migrating golden eagles and other raptors traverse the Appalachian Mountains. Currently, we are pursuing this on three fronts: (1) the use of state-of-the art telemetry to collect detailed data on individual golden eagle movements throughout the region, (2) collaboration with existing hawk migration monitoring sites to collect additional data on flight patterns and behavior, and (3) the development of quantitative spatially explicit migration models using both theoretical and empirical approaches. Our work focuses in particular on the interactions between topography, weather, and golden eagle movements at local and regional scales. Currently we are not involved with studies to determine the behavioral response of raptors to turbines at wind energy sites. However, under certain conditions we would consider collaborations with wind energy developers, wildlife advocacy organizations or state or federal agencies on such studies. …
Conclusions
Our current understanding of the interaction between raptors, wind energy development and society leads us to the following conclusions:
- Risks posed by wind turbines to raptors depend on a variety of site-specific, species-specific, meteorological, and seasonal factors;
- Existing data presently are insufficient to make any conclusion about the magnitude of the risks posed to raptors by wind turbines;
- Wind energy sites on leading lines within the high potential risk area for golden eagles discussed above should not be constructed until scientifically valid peer-reviewed studies quantify potential impacts and appropriate mitigation methods are implemented. Studies that are not subject to peer review are substantially less credible and have less value for resolving these important issues;
- On migration routes of high ecological significance (the Kittatiny Ridge and others) wind energy facilities should be constructed only if replicated studies show conclusively that there will not be harm to natural resources -birds, bats, habitat, etc. In these cases there must be an especially high burden of proof to show that harm will not be caused;
- We strongly recommend a coordinated effort by raptor biologists, regulators, and developers to study the issue comprehensively. …
17 August 2008
Todd Katzner, National Aviary
David Brandes, Lafayette College
Michael Lanzone, Carnegie Museum of Natural History, Powdermill Avian Research Center
Trish Miller, Carnegie Museum of Natural History, Powdermill Avian Research Center
Dan Ombalski, State College Bird Club
Download original document: “Raptors and Wind Energy Development in the Central Appalachians”
