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Resource Documents: Virginia (22 items)

RSSVirginia

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.


Senator Jay Rockefeller asked to reconsider his position on industrial wind

Author:  Spiggle, Wayne

Dear Senator Rockefeller,

Please accept my personal warm greetings. We have visited on several occasions, particularly on health care. You may remember me as a physician who yearns for an improved Medicare for All, as embodied in (H.R. 676).

I’ve just read with interest the email response you are making to people actively concerned about your policies on “renewable” energy and I’d like to make the following comments about industrial wind. Personally, I favor subsidies that go to small hydropower development and research on burning coal more cleanly and think they should be increased.

But, on industrial wind:

  1. The inefficiency of the turbines related to wind fluctuations will require far more land disruption than does strip mining for coal. First reported by the Nature Conservancy and subsequently documented elsewhere, even by Senator Lamar Alexander you will find it very apparent that if you pass laws that mandate even 15% of electricity be from sources like industrial wind you will be sentencing the majority of our celebrated West Virginia Hills to be pock marked with giant turbines and thousands of miles of new transmission lines to serve them. Tragically, this physical and ecologic transformation of West Virginia’s trademark landscape will have no significant amelioration of green house gasses because of the required co-generation of base load stand by.
  2. The federal and state tax subsidies for industrial wind (and solar) are far out of balance for other energy sources, 15 times more. Industrial wind must receive this largess to get started AND to keep going. Explain to me how it is good public policy to provide such a favoritism to an industry that cannot contribute to the global warming problem in a significant way?
  3. Imposing renewable standards will drive up electricity costs very significantly. That means the cost of this new energy policy will be disproportionally borne by the middle class and the poor. I feel very confident that is not your intent and will be very sad if it becomes your legacy.

Senator, I belong to The Allegheny Highlands Alliance (AHA), a relatively new grass roots organization with representation in WV, MD, PA, VA, and SC. Our mission is to, in an intellectually honest, scientifically based way; educate the public about the realities of industrial wind and the pending legislation that would further codify its undeserved position. There are several other issues, including impact on migrating song birds and raptors, destruction of habitat for rare terrestrials (both concerns of the USFWS and the WVDNR), negative health impacts from constant low frequency noise inflicted on people living close to an industrial wind facility, water resource disruption, to site a few.

We believe there is a better way to promote alternative energy than to dictate a percentage standard and then to sit back to see what happens. That is getting the cart before the horse. Once again, I implore you, with the assistance of staff to open your mind and investigate the above observations. AHA has extensive expertise on this subject and, if invited, we would appreciate the honor to meet with you for a briefing.

Thank you,

Wayne C. Spiggle, MD
West Virginia

(((( ))))

Allegheny Treasures notes:

Dr. Wayne Spiggle is well known in West Virginia and Maryland as an effective social justice advocate and environmental leader. As a former president of MedChi, the Maryland Medical Society, he pressed for universal health care and he is still involved in that fight. As a Mineral County commissioner, he has promoted quality of life issues and emphasized the importance of developing a welcoming environment to encourage jobs and business development. For his public health initiatives he was recently recognized by the West Virginia State Medical Society with their prestigious Excellence in Medicine Award.

Spiggle has studied industrial wind with the critical eye of a scientist. He has concluded that industrial wind is poor public policy because it requires base load back up from fossil fuel, cannot reduce green house gases, receives public subsidies some 15 times more than other energy sources, is destined to raise electricity bills for homes and businesses and is handicapped by very significant environmental issues sufficient to bring about a transformation of Appalachian ridge tops of geologic proportions while having a disastrous mortality on migrating song birds, raptors and resident bats.

A member of the Allegheny Highlands Alliance (AHA), he has joined their mission to inform the public about industrial wind by adhering to the principals on intellectual honesty and scientific based knowledge.

The Allegheny Highlands Alliance (AHA) is a consortium of citizen/environment organizations with membership in five states along the Allegheny Front. The AHA is in the process of discovering the facts about industrial wind, its potential to reduce green house gases, its economics and the impact of industrial wind energy project installations on the ecology and human health.

The purposes of AHA shall include but not be limited to the following:

  1. To advance public knowledge and understanding of the cultural, biological, environmental diversity, uniqueness, and sensitivity of the major ridgelines that comprise the Allegheny Highlands;
  2. To preserve and protect areas of particular scenic, geologic, biologic, historic, wilderness, and/or recreational importance in the Allegheny Highlands;
  3. To aid in the establishment of responsible policies to protect scientific, educational or aesthetic values;
  4. To conduct regional and resource studies as a basis for the wise use of the various resources of the Allegheny Highlands; to develop programs in energy conservation and wise production; and to serve local communities, the region, the people of the Allegheny Highlands as an agency for popular enlightenment, for cultural improvement, and for scientific advancement;
  5. To advocate governmental policies for the conservation and wise management of energy and natural resources of the Allegheny Highlands.

AHA Contact Larry Thomas, President, at larryvthomas@aol.com

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Date added:  October 13, 2010
Regulations, Virginia, WildlifePrint storyE-mail story

Comments and Questions on Proposed Wind Energy Permit by Rule

Author:  Webb, Rick

Date: October 5, 2010

To: Virginia Department of Environmental Quality

Re: Follow-up Comments and Questions on Proposed Regulation; 9VAC15-40. Small Renewable Energy Projects (Wind) Permit by Rule (adding 9VAC15-40-10 through 9VAC15-40-140)

This submission includes follow-up comments, questions, and requests for information concerning the regulations proposed by Virginia Department of Environmental Quality (DEQ) to implement the Permit by Rule (PBR) legislation for wind energy projects. These follow-up comments, questions, and information requests focus on the DEQ’s responses to specific questions posed in my original comments, dated August 18, 2010.

I have three major objections to the process followed by the DEQ in the development of the proposed regulations.

1) Decisions concerning a number of critical regulatory requirements are described by the DEQ as based on Regulatory Advisory Panel (RAP) consensus. This is evasive or nonresponsive to requests for the basis of important rule-making decisions. As specified below, I am asking that the DEQ identify the objective criteria that served as the basis for RAP consensus decisions. I am also asking that the DEQ provide the documents and other information that were considered by the RAP as the basis for its consensus decisions.

2) Contrary to the stated intent of the PBR legislation and the DEQ’s stated intent in the notice of proposed regulation, the DEQ indicates that it intends to rely in a number of instances on guidance “to be developed” for implementation of the PBR rather than setting forth permit requirements “up front.” This both defeats the intent of the legislation to provide certainty in the permitting process and denies the public a meaningful opportunity to comment on the rules that will ultimately be in effect.

3) The DEQ failed to respond to my specific comment and question concerning the basis for ruling that only T&E and SGCN wildlife species warrant site-specific data collection. The DEQ also fails to explain why, for onshore wind projects, mitigation plans to provide wildlife protection are only required when state T&E wildlife or bats are found within the defined disturbance zone. The PBR legislation does not limit wildlife protection to only these few species, nor does it define “significant adverse impacts to wildlife” to exclude consideration of impacts to wildlife other than state T&E species and bats. The DEQ’s proposed regulations are thus not compliant with the PBR legislation.

Specific additional comments, questions, and requests for information related to my original comments (in green) and DEQ responses follow. The numbering of my original comments is the same as in my original comment submission.

1. How was it determined that a disturbance zone defined as the directly impacted area plus a margin of 100 feet provides a sufficient criterion for evaluation of potential wildlife impacts?

4. Given that the legislation does not appear to impose any such limitation, how was it determined that only T&E and SGCN wildlife species warrant site-specific data collection?

5. What protocols or standards does the DEQ intend to require, and if it is the intent of the legislation to create a PBR process that clearly establishes permit review requirements “upfront,” is it not necessary to include explicit language in the regulations concerning protocols and standards required for all surveys, data collection, and analysis?
6. If the public is to be provided an actual opportunity to make informed and meaningful comments on the proposed PBR regulations, doesn’t the public need an opportunity to examine and comment on the protocols and standards for required surveys, data collection, and analysis?
15. Will the DEQ review and approve monitoring plans, and what criteria, including search methods, search frequency, search area, and searcher qualifications, will the DEQ consider in approving monitoring plans?

7. Does the DEQ plan to require access to all wildlife data and analysis results?
16. Will the DEQ require submission of all monitoring data, and will this data be made available to the public?

9. Is there a threshold of potential environmental harm that will result in permit denial or substantial project modification?
10. Can wind energy projects be permitted in cases where significant adverse impacts to state-listed T&E wildlife cannot be avoided?

11. What does this mean [“development of reasonable and proportionate mitigation plans that offset adverse impacts”]; does it mean that an applicant might satisfy mitigation requirements by providing protection for historic resources other than the particular historic resource that is adversely affected by the project?

DEQ response to (11): Questions on this were resolved by consensus of the RAP with DHR input. DEQ will draft guidance.

Follow-up comment: The DEQ should make requirements known “up front,” and requirements should be proposed as regulations rather than guidance. The public should be provided a new formal comment period to review and provide input on these requirements.

Request for information: Please provide copies of the RAP’s recommended guidance provisions.

12. What criteria or rationale support the decision to limit money spent on, or cost of, avoidance of bat mortality to $5,000 per turbine?

14. Why hasn’t the DEQ required curtailment or turbine shutdown to protect raptors and migratory birds?

Please consider the above requests for documents and information as Freedom of Information Act requests. I also requests that a new formal public comment period be provided once the DEQ has provided the requested information and completed development of a complete set of proposed regulations to implement the PBR.

Download original document: “Comments and Questions on Proposed Wind Energy Permit by Rule

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Date added:  September 21, 2010
Environment, Siting, Virginia, WildlifePrint storyE-mail story

Site Analysis: Poor Mountain proposed wind project

Author:  Hartman, Hollister

These charts present data relevant to the wind siting guidelines provided by Sierra Club Wind Siting Advisory dated Nov. 2003, as applied to the wind project proposed for siting at Poor Mountain.

The salient change is that each Wind Siting Criterion now is associated with descriptions of features which allow a site to be characterized as either Most, Marginally, or Least appropriate with respect to each criterion. Any site which scores Least Appropriate on one or more criteria would render serious doubt as to suitability for a wind project.

Most of Sierra Club’s criteria actually are surrogates for “amount of wildlife habitat to be bulldozed”; which given the source as being Sierra Club – an organization sworn to protect wilderness values – is understandable. For example, under “Infrastructure” more credit is given to sites with preexisting power transmission lines. This avoids the need to build extensive new power lines, at the cost of bulldozing large areas of wildlife habitat. Similarly, being near major population centers reduces the amount of land which would have to be disrupted to access a new wind project. And to eliminate any trace of doubt as to their intent, Sierra Club also explicitly includes the variable, “Impact on Wildlife and/or Habitat”.

The value of using surrogate criteria rather than actual environmental impacts in the early phases of siting efforts is that it’s usually much faster and less costly to screen large areas of land qualitatively rather than quantitatively. By putting forth environmentally-conscious criteria for use by energy developers, Sierra Club performed the public service (intentionally or otherwise) of providing a means to orient attention away from what might end up being contentious sites which drain time, energy, and money from both developers & opponents. …

Strictly speaking, because Poor Mountain does not satisfy Sierra Club’s sole EXCLUSIONARY criterion of wind power potential, the proposed site should be eliminated from further consideration. However, in light of current confusion surrounding industry-standard siting practices, Evaluative criteria also are discussed in the following charts [full discussions are included in the original document, available for download below].

Current and/or Recent Land Use: federally excluded areas: national parks, wilderness areas, etc.; critical habitat for rare, threatened or endangered species; habitat for indigenous species critical to regional/state biodiversity. – Least appropriate

Infrastructure: existing infrastructure would require expanding and/or upgrading. – Marginally appropriate

Geographic Relation to Human Population: near major population and/or other power consumption centers [how near? how large a population?]. – Marginally appropriate

Impact on Wildlife and/or Habitat: unacceptable impact on wildlife or habitat, IAW credible environmental review [what level or type of impact is acceptable? to whom? how is reviewer credibility determined?]. – Least appropriate

Impairment of Scenic Value: important scenic values would be impaired [how is a scenic value deemed unimportant? what degrees or types of change constitute “no impairment”? how can scenic impairment be mitigated? what level or type of impairment is acceptable?]. – Least appropriate

Bottom Line: The Weight of Evidence shows that Poor Mountain must be rejected as UNSUITABLE for siting the proposed wind project.

Hollister Hartman is the author of several publications related to the fields of Civil Engineering and Natural Resource Management. She received her BS Degree in Biology from Yale University and her PhD in Population Biology (Applied Mathematics) from the University of California, Riverside. She also received certification in Multi-Attribute Decision Making from the Massachusetts Institute of Technology.

Dr. Hartman’s professional siting experience includes instituting integration of Geographic Information Systems, managing geophysical/biocultural modeling for compliance of EPA regulations, and developing/implementing site selection methodologies for Hard Mobile Launcher, Small ICBM, and Peacekeeper deployment.

Additionally, she identified pivotal geological and engineering criteria underlying intractable nuclear waste repository siting issues for the U.S Department of Energy Yucca Mountain Project, overseeing project performance against federal, state and local regulations.

Dr. Hartman served in leadership positions with the National Research Council, the American Institute of Aeronautics & Astronautics (AIAA) and numerous consortium appointments. She serves her community as Vice Chair of the Sierra Club/Roanoke, VA Group; Member of the Franklin County Planning Commission Technical Advisory Committee and Technical Analyst for defenders of Poor Mountain, VA.

Download original document: “Site Analysis: Poor Mountain proposed wind project

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Date added:  February 27, 2010
Economics, VirginiaPrint storyE-mail story

Economic and Fiscal Impacts of the Proposed New Highland Winds Project on Highland County, Virginia

Author:  Siegel, Michael

Summary of Impacts on Highland County

Jobs

Property Taxes

Local Services

Preliminary Report
Prepared by: Michael Siegel
Presented at the Highland County Wind Forum
Sponsored by the Chamber of Commerce of Highland County, Virginia
May 20, 2004

Download original document: “Economic and Fiscal Impacts of the Proposed New Highland Winds Project on Highland County, Virginia

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