The following letter was submitted to the Clerk of the State Corporation Commission Oct. 26.
Dear Members of the State Corporation Commission:
Once again I respectfully write to urge you to ponder deeply what the impact would be upon rendering a decision favoring the construction of industrial wind turbine to the environment, the wildlife and the people of Highland County. It is regrettable that we now find ourselves confronted by a vexing situation that a super majority of citizens opposed from the very beginning. It does not seem justifiable that they should suffer the consequences of a decision by two members of the board of supervisors which could lead to the marring forever of the face and the pristine identity of their beloved county.
In the recent report of the hearing examiner, I found many of his recommendations to be cogent and thoughtfully arrived at; however, his methodology for determining what should be expended for monitoring and mitigation are arbitrarily derived.
He proposes that a fixed cap be set at $150,000 for monitoring carcass searches for the first two years and that a cap be set for mitigation at 0.85 percent of the revenues of the prior years. He does not speculate what the revenues might be.
According to a report from another source, Highland New Wind Development’s annual profit is projected to be $4.2 million. Based on this, approximately $357,000 ($4.2 million times .085) would be available for mitigation.
The primary means for mitigation is stopping the blades of the turbines from turning and, thereby, lessening the birds and bats killed. One day’s loss of revenue without the blades turning would amount to approximately $11,506 ($4.2 million divided by 365 days).
This would allow shutting down the blades for 31 days ($357,000 divided by $11,506 ) which would qualify for a mitigation measure in name only.
The hearing examiner proposes a cap of 1.75 percent of the prior year’s revenue to be used for monitoring for the remaining years of the project, amounting to approximately $73,500 ($4.2 million times .0175), about half that allotted for monitoring in the beginning. The cap for mitigation remains at 0.85 percent of the prior year’s revenue which provides for only 31 days down-time from spinning blades.
Regardless of whatever the annual revenues are, the maximum number of days for mitigation will be 31 in this plan, which is designed to make the cost of mitigation proportional to revenue in order to reduce risk for prospective investors. By the same token it increases the risk to wildlife.
The plan does not adequately provide for contingencies such as the massive bird and bat kills that occurred at a wind facility in West Virginia. The plan recommends that monitoring be conducted only from April 1 through Oct. 31. This does not furnish any data as to the number of bats and birds killed from Nov. 1 through March 31.
It is crucial that monitoring be maintained on a 24/7 basis in order to detect unpredictable flight patterns and for shutting down the turbines as the need arises in order to prevent massive kills. It requires a person or persons to be employed full-time on the premises. Such persons must have wildlife management skills and be of unimpeachable integrity.
It is not apparent that any consideration has been given to this matter. Due to HNWD bias, all management of monitoring and mitigation should be under an independent entity such as the Virginia Department of Game and Inland Fisheries or the U.S. Fish and Wildlife Service who should have complete authority for selecting a manager and staff for the biological aspect of the operation, in essence a biological station, the funding of which should be the responsibility of HNWD. Such an operation for the life of the project is likely to be very costly, but to ensure the least impact on the wildlife and environment it is absolutely necessary.
Regarding endangered and protected species, there is no proposal that adequately addresses this issue. HNWD is said to have stated that it will comply with all state and federal laws regarding species protection. Does that apply to the eagles that have been observed to be present in Highland year-round? Should an eagle be killed by an HNWD turbine, does that mean that the organization will submit to a fine of possibly $500,000 and possibly two years incarceration in accordance with U.S. Fish and Wildlife Service guidelines? Or will there be an effort made to obtain permission for “incidental takes [kills]” and then develop pay- ment rates for killing the various species?
Who could set the price of an eagle or any other protected species? And who can say that HNWD would not pay the price until all those species no longer exist in Highland County?
What would the word be that would describe genocide occurring among animals? Would it not be the same word since we are all animals, biologically speaking?
Given Highland County’s abundant and rich biodiversity, placing industrial turbines on its mountaintops would be analogous to putting a giant ceiling fan in the top on an aviary.
Please do not destroy one of the last great places in Virginia.
Dr. Orren L. Royal
1 November 2007
|Wind Watch relies entirely
on User Funding