The EENF as submitted does not provide a meaningful opportunity for public review as required. A meaningful opportunity for review of a project cannot occur when the proponent fails to provide details or plans of anticipated environmental impacts and then claim that such plans or details will be worked out at a later date thereby circumventing a complete and adequate MEPA review of the project. It is the proponent’s responsibility to provide detailed information about the project’s anticipated environmental impacts and proposed mitigation measures. The proponent has failed to provide adequate details in the EENF, as discussed below, to enable meaningful public review of the Minuteman Savoy Wind Project.
The Commission would like to take this opportunity to voice its concern about an emerging and troubling pattern of MEPA filings for wind energy projects in Berkshire County concerning project segmentation. For example, the land disturbance calculations for Berkshire Wind and Hoosac Wind have increased substantially since their first ENF filings. It is understandable that as a project develops and evolves land disturbance and other calculations may vary. However, projects submitted for MEPA review should be at a sufficient level of design to provide an accurate and realistic snapshot of the anticipated environmental impacts and proposed mitigation measures. Proposed wind farms, such as the Minuteman Savoy Wind Project, are enormous projects and as such should be thoroughly scrutinized. A thorough MEPA review is best accomplished when all environmental impacts, both on-site and off-site, and proposed mitigation measures are fully documented, understood and considered at one time.
In 2004, the Berkshire Regional Planning Commission approved Wind Power Policy Siting Guidelines that sets forth the position of the Commission on MEPA reviews for wind energy projects. The Commission believes that a complete EENF should be required for all wind energy projects over 100′ in height. The Wind Power Policy provides standards that an EENF should meet in order to be considered “complete.” In accordance with these standards, the Commission finds that the EENF appears wholly inadequate for the MEPA process because it is impossible to determine the total level of impacts based on the level of information submitted. …
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