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Direct and rebuttal testimony of Pamela Dodds  

Author:  | Environment, Filings, Regulations, West Virginia

‘As a member of the Laurel Mountain Preservation Association (“LMPA”), I elected to assess certain portions of AES Laurel Mountain, LLC’s (“AES”) Application and provide my professional analysis as to the quality and depth of the data pertaining to the surface water and groundwater impacts provided in the Application. In addition, I utilized the data I gathered in a visit to the site of the proposed facility to formulate my own assessment of what the likely impacts to surface water and groundwater would be if the proposed facility were constructed. …

‘It is important to understand that surface water, groundwater, precipitation, and evapotranspiration are all part of the hydrologic cycle. Groundwater occurs at the surface where springs and seeps issue to the surface. When there are drought conditions, groundwater typically supplies water to streams. Groundwater and surface water are, therefore, a unified, integral system. Groundwater and surface water are considered a single resource. …

‘My overall impression of Sections 11 and 13 is that a thorough hydrologic study was not conducted at the proposed project site. Such a study should be conducted throughout an entire year, if not longer. The study should include a comprehensive inventory of surface water and groundwater, including springs and seeps. The discharge rates should be obtained for streams, springs, and seeps, and this data should be related to meteorological data. The study for the hydrology report submitted in the AES application was conducted during the summer and fall of 2007, which was, unfortunately, during a drought. …

‘Q. DO YOUR FIELD OBSERVATIONS AND RESEARCH SUPPORT THE FINDINGS OF THE AES HYDROLOGY REPORT, AQUIFER STATEMENTS, SOILS DESCRIPTIONS, AND GEOLOGY REPORT?

‘A. Generally, no. …

‘Laurel Mountain is one of the essential mountain ridges providing groundwater recharge and maintaining unique aquatic habitats in the headwaters for the Tygart Valley River watershed, which is part of the Monongahela watershed … In addition to storing water from rainfall, the overhead trees on the Allegheny mountain ridges, such as Laurel Mountain, intercept rainfall so that it gently penetrates the ground as groundwater (Exhibit PD-12) rather than flowing overland as runoff. This means that 1) the rain will gently fall to the ground and recharge groundwater and 2) the surface flow of rainwater on the ground will be slower than in cleared areas, thereby reducing the velocity and quantity of stormwater drainage. Conversely, in cleared areas, such as those cleared for construction of wind turbines, increased stormwater drainage results in habitat destruction within streams and the consequent death of aquatic organisms. In the headwater areas, aquatic organisms consist mostly of insects capable of shredding organic materials into compounds used by organisms downstream. … The wind turbines and access roads, where proposed on Laurel Mountain by AES, would intercept numerous springs. The interception of springs, which supply water to the headwater areas and the streams, would divert the water into stormwater drains. The stormwater drains provide a conduit through which the spring waters will flow more quickly and in greater amounts, bypassing the headwater areas the spring waters previously sustained. Also, increased surface runoff and stormwater flow effectively reduces the groundwater recharge potential, which ultimately affects the amount of surface water, or stream water, available for residential, farmland, or commercial use. …

‘Springs and intermittent streams are located throughout most of the area where all the roads would be constructed. The specifications for the wind turbine haul/access road indicate the road will be 35 feet wide with a 10% maximum allowable grade and with no crests or dips greater than 6 inches in every 50-foot road increment. The approximate location of the access road, provided on the USDA soils maps, crosses contours equal to a 20-foot to 40-foot vertical change at most locations. A 35-foot-wide road on a 15% ground slope would require 5 feet of excavation into the slope to provide a relatively flat road. It is important to note that the slope varies from 15% to 35% where the road is proposed. The location of the turbine haul/access road, provided on the USDA soils map, coincides with numerous areas where I observed springs.

‘Construction of wind turbines on Laurel Mountain would create acres of clear-cut areas, resulting in reduced groundwater recharge and increased surface runoff in greater volumes and at greater velocities. The compacted crushed stone wind turbine haul/access road alone would create over 38 acres of increased surface run-off, with the additional complication of intercepting springs. Clear-cutting of trees and the resulting increased surface runoff negatively impacts headwater areas. (The CN runoff coefficient, commonly used in hydrologic studies, is least in woodlands, greater in cleared areas, and greatest on roads.) Blasting associated with construction of the wind turbines has the potential of changing the flow of groundwater through rock fractures. This can result in changed springwater patterns and reduce or stop the flow of spring water to nearby residences and farms. Road construction would intercept springs and negatively impact headwater areas. …

‘West Virginia is heavily dependent on groundwater. Surface water and groundwater are totally integrated. The DEP report recognizes that drought is not simply the result of meteorological conditions. Drought can be categorized as hydrological drought, which can occur due to “unsustainable withdrawal and consumptive use rates,” such as increased surface runoff resulting from clear-cutting forested areas and intercepting springs. The Allegheny Mountains receive greater amounts of precipitation than the surrounding lowlands and therefore serve as the most important areas for groundwater recharge, and for maintenance of aquatic habitats in the headwaters of streams that support trout and other species. The reduction of groundwater recharge in the Allegheny Mountains will ultimately result in drought conditions throughout the watershed. …

‘Construction of the turbine towers includes excavating an area approximately 50 feet in diameter and at least as much as 50 feet deep. This excavation into bedrock requires blasting, which typically causes changes in groundwater flow. Additionally, the material excavated from these foundation areas must be placed somewhere, probably on the hillside. This results in disturbing the headwater habitats and allowing a tremendous threat of sediment entering streams. Storm drainage ditches or ponds, as well as sediment, will cause changes to groundwater flow and will harm stream habitats. Storm water drainage channels greater quantities of surface water at greater velocities to streams. This greater quantity and velocity of water destroys stream habitats.

‘Finally, I note that the Natural Streams Preservation Act (W. Va. Code §22-13-2), is designed to “secure for the citizens of West Virginia of present and future generations the benefits of an enduring resource of free-flowing streams possessing outstanding scenic, recreational, geological, fish and wildlife, botanical, historical, archeological or other scientific or cultural values.” Again, the activities associated with excavation and storm water control will negatively impact streams and thereby negatively impact geological, recreational, fish and wildlife, botanical, historical, and archeological values.’

Download original document: “Direct and rebuttal testimony of Pamela Dodds

This article is the work of the author(s) indicated. Any opinions expressed in it are not necessarily those of National Wind Watch.

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