The Virginia Department of Game and Inland Fisheries (VDGIF) has submitted comments to the State Corporation Commission (SCC) concerning the proposal for a commercial wind project in Virginia’s Highland County.
A copy of the September 20, 2006 comment letter, with highlights added, is attached. The complete set of comments, including attachments and specific responses to arguments presented by the applicant, can be accessed on the SCC website and at: http://vawind.org/Assets/Docs/Comments/DGIF-092006.pdf
The September 20, 2006 VDGIF letter states: “We support the use of alternative energy sources, including wind energy. However, based on review of the information provided thus far by the Highland project applicant, in the absence of accountable mitigation conditions . . . we feel this project presents an unacceptable risk to wildlife.”
The VDGIF states particular concern about the potential significant adverse impacts upon birds and bats, citing:
· the project’s location relative to caves that support large numbers of bats (200,000+) ““ including Endangered and Threatened species
· high passage rates of birds and bats identified in an onsite radar study ““ the highest passage rates recorded in the eastern U.S.
· significant bat fatality rates at other Allegheny wind projects ““ foretelling high fatality rates in Highland County
· high numbers of bald eagles and golden eagles in Highland County relative to other parts of the Allegheny Mountains ““ and their use of ridges
If the project is to be licensed by the SCC despite wildlife concerns, the VDGIF calls for additional preconstruction studies and three years of post construction monitoring, including fatality searches for bats and birds between April and October and fatality searches for raptors (particularly eagles) in winter. All fatalities searches would be conducted daily to avoid underestimates due to scavenger removal.
The VDGIF would also require that monitoring and study protocols be approved by the SCC, the VDGIF, and the US Fish and Wildlife Service (USFWS), that the sites and searches be subject to surveys and observation by representatives of SCC, VDGIF, and USFWS to evaluate and review survey efforts and methodologies, and that all data be made available to the public. The VDGIF would further require that bird and bat fatalities would not exceed 3.5 birds and 1.8 bats per turbine per year, including any Threatened or Endangered species killed, but not authorizing any such killing of Threatened or Endangered species.
The VDGIF also expressed concern about the precedent that will be established for future wind projects in Virginia, pointing to proposed projects in Highland, Patrick and Roanoke Counties, U.S. Department of Energy objectives for wind development, and federal subsidies promoting wind power, as indications of a pending substantial increase in commercial-scale wind project proposals for the Appalachians.
Virginia Wind endorses the need for multi-year, multi-season studies of bird and bat use at this proposed wind project site prior to permitting by the SCC. In the context of well-established environmental risk, the minimal energy supply and air-quality benefits associated with the proposed project do not warrant proceeding before completion of such studies and review by the VDGIF and USFWS.