ANR’s draft certification for GMP’s wind project allows Lowell Mountains’ water quality to be degraded
ANR’s Draft Certification for GMP’s Wind Project Allows Lowell Mountains’ Water Quality to be Degraded
Public Comments Question Project’s Ability to Meet Clean Water Act and Vermont Water Quality Standards
This week comments were filed with the Vermont Agency of Natural Resources (ANR) on Green Mountain Power’s Lowell wind project’s 401 Water Quality Certification. The certification requires Vermont to determine that the project’s construction and operation will comply with Vermont’s Water Quality Standards and the Federal Clean Water Act. Several groups submitted public comments, including Energize Vermont, the Towns of Albany and Craftsbury and the Lowell Mountains group, numerous citizens, and Vermont Natural Resources Council (VNRC).
The groups’ comments were critical of the project’s plans and the state’s draft Water Quality Certification for use of experimental best management practices, failure to require baseline water quality monitoring, allowing the filling of hundreds of feet of headwater streams, underestimation of the volume of stormwater runoff, and the unquestionable damage that would occur to aquatic life, including native brook trout, from degradation of water quality.
“The Lowell wind project is a high-risk site with steep elevations and very erodible soils, the Applicants have proposed the use of alternate Best Management Practices, which are essentially untested and unproven at scale this large,” stated Geoff Goll of Princeton Hydro, the experts hired by Energize Vermont to examine the application.
Alternate Best Management Practices at the site include the extensive use of rock level spreaders. Goll cited expert sources that indicate level spreaders have a dismal record in practice. The industry-recognized King County, Washington Surface Water Design Manual is highly critical of level spreaders at similar sites, “They are frequently under-designed and, despite the best installations, are rarely perfectly level, which results in the release of stormwater at a particular point. This concentrated runoff can result in catastrophic erosion downslope. Given such design failures, the use of spreaders is not encouraged.”
The lack of appropriate mitigation techniques exposed the application to criticism across a range of areas. One of the largest concerns was the lack of proposed baseline pre-construction monitoring. Goll argued that “The ANR’s logic is flawed in not requiring baseline data, as without such information, there is no manner in which to monitor impacts to existing uses and the fact that there was a lack of an approved quality assurance plan for the sampling conducted by VHB on one day in October 2010 hardly meets the minimum standards for repeatable results and would not stand up to a rigorous statistical analysis.”
Princeton Hydro’s comments also cited “specific impacts to headwater streams and wetlands that will affect downgradient hydrology and therefore biota and their habitat.” They noted that the application calls for more than half a dozen headwater streams to be filled, some for 100 feet or more.
The Towns and Energize Vermont both question whether several of the calculations took into account the right amount of impervious surfaces. The Towns recalculated the potential for runoff across the gravel roads and turbine pads and found that GMP’s application substantially underestimated the amount of potential discharge at the site. The Towns’ expert Andres Torizzo stated that without the appropriate calculations, “There is no assurance that the proposed operational stormwater controls and measures will protect the physical and chemical, and biological integrity of the receiving waters.”
The groups’ concerns did not end there; they also questioned the impact the project could have on native brook trout, other aquatic life and the nearby Missisquoi River. Several of the site’s headwater streams discharge into the the Missisquoi, which is currently under study by the National Parks Service to be designated as a Wild and Scenic River.
Comments filed by VNRC refer to the history of damage to streams associated with high elevation development at ski areas, and the difficulty of restoring water quality once the water quality is degraded. “Shallow soils and steep slopes are characteristic of these areas,” said Kim Greenwood, VNRC’s Water Program Director. “These areas present a very high risk of erosion and the lessons we have gleaned from working with ski resort development provide cautionary information to inform wind development in similar environs.”
“Our concerns are numerous and we are hopeful that the ANR will take them fully into account when evaluating the application,” Goll commented. “In the absence of a comprehensive analysis regarding secondary and cumulative impacts to aquatic resources by the applicant, the project as proposed does not satisfy the standards set forth in the Clean Water Act and therefore the application’s request for 401 water quality certification should be denied,” Goll concluded
“Qualified experts have shown that mixing some of our state’s most pristine headwater streams with massive industrial development could have catastrophic results on water quality and aquatic life in the area,” said spokesperson for Energize Vermont Lukas Snelling.
Snelling continued, “Isn’t it time we use some common sense and look for solutions that do not carry these vast negative impacts on our natural resources? We can put community and residential solar solutions on already disturbed lands and completely avoid many of these issues.”
Energize Vermont was created to educate and advocate for establishing renewable energy solutions that are in harmony with the irreplaceable character of Vermont, and that contribute to the well-being of all her people. This mission is achieved by researching, collecting, and analyzing information from all sources; and disseminating it to the public, community leaders, legislators, media, and regulators for the purpose of ensuring informed decisions for long term stewardship of our communities.
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FOR IMMEDIATE RELEASE
July 21, 2011
Contact: Lukas B. Snelling
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