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Unless indicated otherwise, documents presented here are not the product of nor are they necessarily endorsed by National Wind Watch. These resource documents are shared here 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. • The copyrights reside with the sources indicated. As part of its noncommercial effort to present the environmental, social, scientific, and economic issues of large-scale wind power development to a global audience seeking such information, National Wind Watch endeavors to observe “fair use” as provided for in section 107 of U.S. Copyright Law and similar “fair dealing” provisions of the copyright laws of other nations.


Renewables, land use, and local opposition in the United States

Author:  Gross, Samantha; and Brookings Institution

Decreasing greenhouse gas emissions in the electricity sector is crucial to avoiding the worst impacts of climate change. The American public overwhelmingly favors renewable power, and the costs of wind and solar power have declined rapidly in recent years. However, inherent attributes of wind and solar generation make conflicts over land use and project siting more likely. Power plants and transmission lines will be located in areas not accustomed to industrial development, potentially creating opposition.

Wind and solar generation require at least 10 times as much land per unit of power produced than coal- or natural gas-fired power plants, including land disturbed to produce and transport the fossil fuels. Additionally, wind and solar generation are located where the resource availability is best instead of where is most convenient for people and infrastructure, since their “fuel” can’t be transported like fossil fuels. Siting of wind facilities is especially challenging. Modern wind turbines are huge; most new turbines being installed in the United States today are the height of a 35-story building. Wind resources are best in open plains and on ridgetops, locations where the turbines can be seen for long distances.

Even though people like wind and solar power in the abstract, some object to large projects near their homes, especially if they don’t financially benefit from the project. Transmission for renewable power can also be unpopular, and even more difficult to site when the power is just passing through an area, rather than directly benefiting local residents. This is an issue today building transmission to move wind power from the Great Plains and Upper Midwest states to cities in the east.

Technological and policy solutions can lessen the land use impact of renewable power and the resulting public opposition. Offshore wind eliminates land use, but it raises opposition among those concerned with the impact on the environment and scenic views. Building on previously disturbed land and combining renewable power with other land uses, like agriculture or building solar on rooftops, can minimize land use conflicts. Community involvement in project planning and regulations for land use and zoning can help to alleviate concerns. Nevertheless, there is no perfect way to produce electricity on an industrial scale. Policymakers must recognize these challenges and face them head-on as the nation transitions to a lower-carbon energy system.

Download original document: “Renewables, land use, and local opposition in the United States

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Date added:  January 13, 2020
Economics, ScotlandPrint storyE-mail story

Decade of Constraint Payments

Author:  Renewable Energy Foundation

2019 was the tenth year in which British wind farms have received constraint payments to reduce their output because of electricity grid congestion. There has been a total of £649 million paid out over the decade for discarding 8.7 TWh of electricity. To put this in context, this quantity of energy would be sufficient to provide 90% of all Scottish households with electricity for a year.

Because of a rapid growth in wind farms, particularly in Scotland, the total paid has tended to increase year on year in spite of grid reinforcements and new grid lines such as the £1 billion Western Link from Hunterston to Deeside, which was built specifically to export wind power from Scotland to English and Welsh consumers. Figure 1. displays this trend, showing payments rising from £174,000 in 2010 to a new record cost of more than £139 million. The quantity of electricity discarded in 2019 was also a new record at 1.9 TWh.

Figure 1: Annual constraint payments to wind farms via the Balancing Mechanism. Source: Balancing Mechanism, REF. Chart by REF.

Scottish onshore wind farms are far and away the largest beneficiaries of constraint payments, receiving 94% of the total in 2019, and approximately the same proportion averaged over the last ten years (see Figure 2). Scottish onshore wind received nearly £130 million in 2019, and more than £607 million over the decade. The remaining 6% of payments has largely gone to English offshore wind farms, with smaller fractions for Welsh onshore and Scottish and Welsh offshore wind farms. No English onshore wind farms have received constraint payments via the Balancing Mechanism.

Figure 2: Share of wind farm constraint payments 2010-2019, by wind location (onshore or offshore), and country, SC = Scotland, EN = England, WA = Wales (Rounding accounts for the sum not being equal to 100%). Source: Balancing Mechanism, REF. Chart by REF.

The number of Scottish windfarms receiving constraint payments has increased from three in 2010 to sixty-eight in 2019. The largest increase in wind farm numbers occurred in 2017, when eighteen new windfarms received constraint payments for the first time.

Figure 3: Wind farms receiving constraint payments for the first time, an animated geographical display. Click the play arrow on the map above to track the increase in Scottish wind farms receiving constraint payments over the decade 2010–2019 and their location. Each wind farm is coloured yellow and named in the year that it first received constraint payments.

Of the sixty-six onshore wind farms in Scotland receiving constraint payments over the decade, two large windfarms – Whitelee and Clyde – received nearly a third of the decade’s total, taking £108 million and £80 million respectively. The animated bar chart (Figure 4) shows how the costs of constraints to windfarms have accumulated over the decade from a slow start in 2010 when payments were made on only three days, increasing to eighty-two days in 2011, with a peak in 2017 when constraint payments were made on 244 days of the year. Wind farm constraint payments were made on 229 days of 2019.

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019

Figure 4: Cumulative constraint costs by year for the top ten earning wind farms, an animated bar-chart race. Click the play button above the bar chart to view the animation. The colour of each wind farm indicates the year it first received constraint payments. Note that the intra-month costs are linearly interpolated for the purposes of the animation and the costs on each bar are shown to 2 significant figures only. (Animation adapted from Observable Bar Chart Race.)

It is perhaps unsurprising that Whitelee, being the largest UK onshore wind farm and one of the earliest entrants into the constraint market, has received the largest constraint payment total. However, recent years have seen newer and smaller wind farms overtaking Whitelee, suggesting that the sites currently being chosen for wind farm development are in locations with poorer grid connection. Whether this is a deliberate choice, designed to maximise average earnings per MWh generated, is open to debate.

The animated bar chart below shows how constraint costs grew in 2019 and reveal that Kilgallioch, which was built in 2017 and is less than half the size of Whitelee, has received more in constraint payments in 2019. Similarly, Stronelairg, built in 2018 and also less than half the size of Whitelee, has risen immediately to fourth in the annual league table of constraint payments.

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019

Figure 5: Cumulative constraint costs in 2019 for the top ten earning wind farms, an animated bar-chart race. Click the play button above the bar chart above to view the animation. The colour of each wind farm indicates the year it first received constraint payments. Note that the intra-month costs are linearly interpolated for the purposes of the animation and the costs on each bar are shown to 2 significant figures only. (Animation adapted from Observable Bar Chart Race.)

In 2019, six wind farms were responsible for 50% of the constraint payment receipts, namely Clyde, Kilgallioch, Whitelee, Stronelairg, Fallago Rig, and Dunmaglass. It is particularly notable that of these six highly constrained wind farms:

a) Stronelairg received planning permission in spite of being behind a grid bottleneck and was subject to a Judicial Review due to its impact on wild land. Moreover, there are currently two further neighbouring applications in process for Glenshero owned by the GFG Alliance, and Cloiche, which is proposed by SSE, the operator of Stronelairg.

b) Whitelee, which opened in 2007 with a capacity of 322 MW, and was one of the first wind farms constrained off in the Balancing Mechanism, has been extended very significantly, with a further 217 MW entering service in 2012.

c) Clyde was completed in 2009, but permission to extend the site with an additional 74 (172.8 MW) turbines was granted in July 2014 and completed in 2017.

d) Fallago Rig is currently seeking an extension to add a further 12 turbines.

e) Kilgallioch is also seeking an extension.

Wind farm owners charge more per unit to reduce output than they earn through generating. For wind farms subsidised under the Renewables Obligation (RO) the income foregone when instructed to reduce output is the value of the Renewable Obligation Certificates (ROC). Typically, wind farms ask to be paid much more than the lost income, and in the early days of wind farm constraint payments, the premiums charged for not generating were very high indeed. For example, in 2011, Crystal Rig 2 charged £991 per MWh to reduce output compared to the value of the ROC at that time of £42 per MWh. Kilbraur, Millennium, Farr, An Suidhe were charging between £200 to £320 per MWh constrained-off in 2011.

This was regarded as an abuse of market power, and the Government introduced the Transmission Constraint Licence Condition (TCLC) in 2012, which sought to prevent excessive bid prices in the event of a constraint. While there can be no doubt that the TCLC resulted in a reduction in prices, they are still well in excess of the subsidy foregone in 2019 as Figures 6 and 7 demonstrate.

Figure 6 shows the five onshore wind farms which received the largest premiums above the subsidy forgone and the five which received the smallest premiumin 2019. It is interesting to note that Andershaw, Blackcraig, Beinneun, Cour and Sanquar, which are receiving a high premium over lost income, are newer wind farms accredited after the ROC banding for onshore wind was reduced such that they receive 0.9 of a ROC per MWh in subsidy. Assuming the 2019 ROC value will be approximately £55, these wind farms would receive £49 per MWh if generating but ask for and receive £96-£98 per MWh not to generate and thus get a premium of £47–£49 above the subsidy when constrained off. The five wind farms with the lowest constraint prices are older wind farms which receive 1 ROC per MWh. In 2019, they were setting constraint prices of £64-£69 per MWh to reduce output, thus getting a premium of £10-£15 per MWh.

Figure 6: Average premium price (per MWh, above the foregone Renewables Obligation subsidy) paid to reduce output when constrained off in 2019 for the five most expensive and five least expensive onshore wind farms. The calculation assumes a ROC value of £53 for Jan-Mar 2019 and £55 for Apr-Dec 2019.

The RO-subsidised offshore windfarms which received constraint payments fall into various subsidy bands: 1, 1.5, 1.8 and 2.0 ROCs per MWh. Taking these variations into account, it is again the newer wind farms that are charging higher constraint payments with the most expensive five offshore wind farms making £52 – £74 per MWh more than the site-specific subsidy forgone. The five least expensive received £20 – £38 per MWh over their subsidy.

Figure 7: Average premium price (per MWh, above the foregone Renewables Obligation subsidy) paid to reduce output when constrained off in 2019 for the five most expensive and five least expensive offshore wind farms. This calculation assumes a ROC value of £53 for Jan-Mar 2019 and £55 for Apr-Dec 2019.

It is difficult to see any justification for compensation over and above the subsidy lost, and indeed REF has suggested, as many economists would argue, that constraints are a normal and entirely foreseeable commerical risk and should not be compensated at all. Indeed, REF infers from the data presented above that constraint payments are actually encouraging the siting of onshore wind farms in grid constrained areas. This is clearly not in the public interest, and entails a significant cost to electricity consumers, who ultimately fund constraint payments through their bills.

Finally, it must be remembered that the cost of mislocating wind farms in areas with weak grid connection or behind constraints is much greater than the direct payments to wind farms themselves, large though these are. When a wind farm is constrained off the grid on one side of a grid bottleneck, National Grid as the system operator is required to make up the short fall in electricity by paying other generation (usually gas-fired) to increase generation on the other side of the bottleneck. Over the last ten years, the overall cost of constraints has risen by nearly 400%, from £165 million in 2010 to £636 million in 2019, reflecting the expense and difficulty of integrating a large wind fleet, and increasingly a large solar fleet, into the GB electricity grid.

Figure 8: Running twelve month total cost for all grid constraints from January 2010 to December 2019 demonstrating the four-fold increase over the decade.

30 December 2019

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Date added:  November 17, 2019
Economics, Law, Ohio, U.S.Print storyE-mail story

Wind leasing: an all or none proposition

Author:  Thompson, Gene

[Editor’s note: The doctrine of correlative rights limits use of a common groundwater source to a share in proportion to the landowner’s property above it. Many states apply the doctrine to oil and gas fields as well. Gene Thompson argues here that it should also be applied to the extraction of wind power.]

Producing energy for everyday use has been a necessity for a long time. Oil Exploration and Production companies (E&Ps) have been at it for over 150 years. Wind farm companies have been at it for around 20 years. There are some regulations and laws still in the making that will guide both industries as they become more sophisticated and thus more productive. However, as of today, there is at least one big difference in the way the that the two industries operate. Unlike the wind industry, the oil companies are mandated to follow the doctrine of correlative rights. The wind companies are not.

The process of building a large oil drilling unit is very different than building a wind farm. When the oil company begins, they must gather leases, analyze plat maps, and then determine the best chances of finding a group of adjoining properties with a high percentage of neighbors that want to be part of the drilling unit. Before production can begin, the unit will need to contain 100% leased land. If not, the E&P must either reshape, relocate the unit boundaries or attempt to negotiate with any remaining unleased landowners. Sometimes it doesn’t work out and the holdouts are left outside the production zone. Essentially, the E&P sand the government legislators have both come to realize that not everyone wants to participate in a large-scale unitized drilling unit. When 50 to 100 landowners are asked to come together and cooperate with the development of a unit, it is inevitable that some landowners will hold out for varying reasons. More money, environmental concerns, and loss of peaceable enjoyment of the land are a few of the reasons. However, there are some instances where unleased, yet essential, land can be force pooled. That is a process wherein a landowner is forced to accept their just and equitable share of production. Additionally, prior to any force pooling, the holdout will have many opportunities to lease with competitors. This drives competition and is a win for the landowner. Ultimately, the State and E&P reserve the option to utilize rules of capture (correlative rights) and force pooling to bring the unit to completion. All states recognize that capturing our natural resources is for the greater good and is essential. Our laws consider it unfair for one unwilling landowner to have control over natural resource production that will ultimately benefit our society. And so, the majority claims correlative rights. Conversely, 95% of wind farm owners have zero correlative rights. Additionally, wind farm residents have no force pooling rules.

With that in mind, it is important to note that If the residents of a proposed area of development are heavily divided on oil production, the towel gets thrown in early on and the oil company keeps looking for clusters of landowners that want to participate. Lands that are chosen for development must pass EPA surveys and observe established rules for the industry. As a unit nears completion, the correlative rights doctrine comes into play as a tool to guarantee the rights of the majority. Generally, when landowners become informed of their rights and the value of their resources, development gets much easier. Better informed people are more willing to sign leases and participate in the production of oil. That is yet another difference between wind and oil production. Although similar, both industries encumber large clusters of acreage to capture a resource. Unfairly, yet with the government’s blessing, the wind industry pays disproportionately to very few. The oil industry pays proportionately to all.

The success of energy development either succeeds or fails depending how the rules are applied. In Ohio, wind energy is getting tremendous opposition because the industry is held to an entirely different set of standards. Perhaps that has something to do with legislators that do not have enough experience to understand the old drilling rules (150 years in the making) versus the relatively new rules for wind (20 years in the making). It’s no secret that noncompensated landowners in wind farms feel cheated and bullied. The absence of correlative rights for wind farm members is extraordinary.

Comparing wind to oil, the rules for wind farms dictate that profit be paid only to turbine hosts, and the majority of landowners will receive not one nickel. The majority will never be able to sign a lease with a competitor. They will never have a “cash-generating turbine” on their land. The only sharing aspect for wind farm inclusion is that the majority will share equally the burden of any ill effects. Their right to capture is worthless and is totally lost. The noncompensated wind farm resident has no voice as the state conveys our tax dollars to the wind company for support along with the exclusive right to capture. Hence, thousands of acres become stranded from any future production as one company monopolizes the production zone with the blessing of ill-informed or misguided state regulators. Consider this: If every person that lies within the bounds of a wind farm wanted to build their own industrial turbine, they could not because of setback rules. In contrast, the government would never consider allowing an oil company an exclusive right to drill and to then pay only to the landowner that hosts the wellhead. The wind turbine host enjoys that exact scenario to their exclusive benefit. If legislators can see fit to ensure fairness to every landowner that is encumbered in an oil drilling unit, then why not have similar protective rules for the wind farms?

The rule for force pooling in the oil industry wasn’t created until 1965, after 100+ years of drilling. After years of abuse and inappropriate interpretation, public awareness worked to drive a change. Since we now live in the information age, it shouldn’t take us 100 years to wise up to the wind companies. Our legislators must be aware of the inconsistent rules for energy production. The rules for wind farms need to be updated to keep pace with the changes in technology and rapid development. If the wind industry and our government expect landowners to go green and buy into the turbine idea, then they both need to take a lesson from the rules set forth in the oil industry and then consider the upside of sharing the profit fairly.

Gene Thompson
Tiffin, Ohio

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Date added:  November 15, 2019
Aesthetics, California, ImpactsPrint storyE-mail story

Letter from City of Rio Dell to County of Humboldt Planning Commission in opposition to wind energy project

Author:  City of Rio Dell, Calif.

The City of Rio Dell is writing in response to the Humboldt Wind Energy Conditional Use Permit (CUP) and Final Environmental Impact Report (FEIR) for the proposed project. As you know the project is proposed to be located immediately south and southwest of the City and the Town of Scotia on Monument and Bear River Ridges.

As stated in our letter dated June 5, 2019, a copy attached hereto, regarding the Draft Environmental Impact Report (DEIR), the City supports alternative renewable energy, including wind energy. However, as documented in the FEIR, the proposed location will result in a number of unavoidable and significant impacts, obviously including visual impacts. These iron giants will dominate the visual landscape of the entire region, including the communities of Rio Dell, Scotia, Fortuna, the Eel River valley and the entire north coast. Some believe these iron giants will be seen from as far away as Trinidad, Kneeland, Fickle Hill, Bridgeville and even Black Lassic in Trinity County.

Humboldt County hosts one of the most beautiful landscapes in the State, if not the entire Country. Millions of travelers from all over the world come to Humboldt County each year to enjoy its scenic qualities, redwoods, rivers and beaches. The forested ridge tops, open meadows and the Scotia‐Rio Dell bluffs surrounding Rio Dell create a visually stunning landscape. These views are represented on the Rio Dell city seal. If the Planning Commission and/or the Board of Supervisors approves this project, residents and visitors alike will ask “Why did you allow this project at this location?”

Many residents choose to live in Rio Dell and in fact Humboldt County due to its outstanding visual surroundings. The project if approved and built will have a dramatic adverse change not only to the City’s surroundings, but to the entire region. The City believes the project will impact current and potentially future residents desire to live in Rio Dell, Scotia, Fortuna, Loleta and surrounding areas, materially affecting property values in the City. It’s very likely that the increase property taxes from the Humboldt Wind project will be offset by the decreased property values in the surrounding areas.

In addition, to the visual impacts, the FEIR concludes that the project will result in significant and unavoidable impacts to:

The City still has a number of other concerns associated with the proposed project, including timberland conversion, increased fire danger, significant amounts of grading, erosion, geologic stability and sediment discharges into the Eel River. The City’s primary water source (an infiltration gallery) is just a couple miles downstream from the project site.

The applicant is requesting and the FEIR supports earth moving activities during the winter months. The City believes this is reckless and irresponsible given the significant amount of required grading, the erosion hazard ratings of the soils and the geologic instability of the area. The sediment discharge into to the creeks and rivers will be significant even with wet‐weather Beast Management Practices (BMP’s). The City is not aware that the required Storm Water Pollution Prevention Plan (SWPPP) has been prepared pursuant to the Federal Clean Water Act and the State Water Resources Control Board, Water Quality Order No. 97‐03‐DWQ, “Waste Discharge Requirements” (WDRs).

The City continues to have concerns regarding the use of local roads to access the site. Although the FEIR states that heavy truck and equipment traffic would be restricted from using City roads, without seeing the recommended Conditions of Approval or the required Mitigation Monitoring and Reporting Program (MMRP), it’s all but impossible for the City to understand how this will be enforced. There is no consideration of Monument Road as an alternate and emergency access should the Jordan Creek road experience closures. There is no mention of these towers attracting visitors. Traffic would have to go through the City to get to Monument Road.

In regards to the Mitigation Monitoring and Reporting Program (MMRP), the City is disappointed that it was not included in the FEIR as required by Section 15097 of the CEQA Guidelines. Without this important component of the FEIR, it is very difficult if not impossible for the City, the public and decision makers to determine how effective the proposed Mitigation Measures will be. It should be noted that the agreement between the County and Environmental Consultant AECOM, clearly states (Board Item C‐20, June 19, 2018, page 34) that the required MMRP would be included in the FEIR.

The County’s consultant (AECOM) informed the County as part of their proposal that “Because the project may result in impacts to federally and state listed‐bird species, such as the marbled murrelet, and the northern spotted owl, the project will (emphasis added) require an Endangered Species Act (ESA) incidental take permit from the U.S. Fish and Wildlife Service (USFWS) and California Endangered Species Act, Section 2080.1 concurrence or Section 2081 permit from the California Department of Fish and Wildlife (CDFWS).” AECOM further states that a Habitat Conservation Plan (HCP) and an Environmental Impact Statement (EIS) pursuant to the National Environmental Policy Act (NEPA) would be required as well. See Board Item C‐20, June 19, 2018, page 19. To date, the City and the rest of the community is not aware of the apparently required Habitat Conservation Plan (HCP) and Environmental Impact Statement (EIS) that the County’s environmental consultant told them was required over a year ago.

The City still believes the project is being fast‐tracked at the community’s expense in favor of big business. A prime example is the fact that the FEIR was released on November 4th and the Planning Commission will hold its first meeting on November 7th. The FEIR contains almost 900 pages not including the almost 6,000 pages of comments and associated reference materials that were submitted in response to the DEIR. It is unfathomable that the public and the decision makers have four days to review the document before the Planning Commission meeting.

The City supports the concerns and the opposition of the project expressed by a number of State and Federal Agencies, organizations and thousands of Humboldt County residents. Below is a list of some of those agencies and organizations:

Required CUP Findings

Pursuant to Section 312‐17 et. seq. of the Humboldt County Zoning Regulations in order to approve the project, the Planning Commission must find:

The proposed development and conditions under which it may be operated or maintained will not be detrimental to the public health, safety, or welfare or materially injurious to properties or improvements in the vicinity. [emphasis added]

Obviously, the City believes this finding cannot be made. It’s very clear to this City Council that there is no doubt that the proposed project, if approved, will be detrimental to the public health, safety or welfare and will be materially injurious to properties and improvements in the vicinity. The increased fire danger, biological impacts, sediment discharge and visual impacts are all detrimental to the public health, safety or welfare to our communities, residents and environment.

In addition, the project will affect property values, having a direct and substantial impact on the materially wellbeing of the City of Rio Dell. According to a September 2015 article, “Do Wind Turbines Lower Property Values?” in Forbes Magazine, it’s “clear that wind power DOES impact property values”. The article refers to a long list of other articles, studies and court cases documenting how wind power does affect property values. A copy was provided in the City’s June 5, 2019 comments on the DEIR.

In addition the Commission must also make the following Supplemental Findings:

Agricultural Use; §312‐18.1.1: The proposed use will not impair the continued agricultural use on the subject property or on adjacent lands or the economic viability of agricultural operations on the site.

Timber Use; § 312‐21.1.1: The proposed use will not significantly detract from, or inhibit the growing and harvesting of timber on the site or on adjacent properties.

The proposed project will in fact impair the agricultural use of the properties. Each turbine will have a graded 350’ x 350’ pad (2.8 acres). It is assumed these graded pads will be fenced‐ off for security purposes. The will result in the loss of 132+/− acres of grazing land.

The proposed project will in fact inhibit the growing and harvesting on timber. Tree removal associated with the widening of the access roads and transmission line will inhibit (eliminate) the growing and harvesting of timber.

Another supplemental finding that applies in the Coastal Zone and not the inland areas of the County should be applied County wide. See below:

Wind Electrical Generating Facilities; §312‐31.3.1: The facility will have no significant adverse impact on sensitive habitat resources.

There is no opportunity for the adoption of a “Statement of Overriding Considerations” for the required findings.

Should the project be approved, the City is concerned regarding the removal of the WTGs after the projects life (30+/− years). Apparently the removal of WTGs has been an issue in a number of communities throughout the Country and in fact the world. The City recommends, if the project or one of its alternatives is approved that a Performance Bond be required to ensure the visual blight (WTGs), the foundations, transmission facilities are removed and the natural contours restored.

For the reasons discussed herein the City of Rio Dell officially opposes the proposed Humboldt Wind Energy project and recommends the “No Project” alternative.

Sincerely,
~~~
Debra Garnes
Mayor
City of Rio Dell
November 12, 2019

To:
Robert Morris
Chairperson
County of Humboldt Planning Commission
Eureka, California

Subject:
Humboldt Wind Energy Project
Case No. PLN‐13999
Environmental Impact Report; SCH 2018072076

Copy:
Humboldt County Board of Supervisors
Humboldt Redwood Company
Russ Ranch and Timber Company

Download original document: “Letter from City of Rio Dell to County of Humboldt Planning Commission in opposition to wind energy project

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