My comments are the result of research and experience in opposing the Rocky Forge project on North Mountain. In that process, I found a number of areas in the regulations that can be amended to address the problems of constructing wind turbines in karst-riddled mountains. Since it is inappropriate for such large machines to be constructed on fragile terrain, the best solution would be to protect such areas. The other troublesome concern I have is the lack of protection for adjoining county lands.
While there are several other additions needed for the PBR to be effective, I will limit my suggestions to site location and the lack of protection for all natural resources.
9 VAC15-40 -10: Definitions
ADD –
>“Geological features” means the underlying landforms of valleys, ridges, beaches, etc.
> “Impact zone” means all geographic areas, regardless of political boundaries and including geological and water features, that will be affected by construction, operation & maintenance, vibrations, blasting for the purpose of siting wind turbines.
> Under “Small wind energy project” ....... Add (iii) project not to exceed 50 acres
>“Water features” means streams, wetlands, springs.
9 VAC15-40-20: Authority and Applicability
CONSIDER–
> Repealing parts that allow “small wind” projects to be developed in mountainous karst areas and that would require more than 50 acres of land.
9 VAC15-40-30: Application for permit by rule for wind energy projects
Application A -2.
ADD –
> Projects that lie on the border of another political entity (county) will need the applications and the approval of both local governments.
9VAC15 -40-30: Application for permit by rule for wind energy projects
Application A-7
ADD –
> Water features within the impact zone need to be identified and protected by a permit that includes stormwater and erosion & sediment regulations approved by DEQ. The plan also needs to indicate how dependable oversight and enforcement will be provided.
> Geological features that will be destroyed during the construction need to be identified. Blasting required to level and eliminate ridgelines needs to be identified by site and an engineer’s design submitted for approval.
The omissions of these obvious“natural resources” is puzzling. Other than the Natural Heritage program which is mainly concerned with plants and DGIF’s website with probable fish & wildlife, a complete analysis of the natural resources is not required in the current regulation.
[A one-minute You Tube site shows construction for a 500 foot turbine, requiring on flat land excavation 9.8 feet deep and 100.7 feet diameter. https://www.youtube.com/watch?v=Q2o5P-6zm6Y. For comparison, Rocky Forge: 25 turbines, 550 feet high, on steep slopes]
9VAC15 -40-30: Application for permit by rule for wind energy projects
Application A - 8
ADD –
> to the “significant adverse impacts ....” add “geologic features, water features ....”
The significant destruction of these natural resources needs to be recognized and included in any honest appraisal of the construction of turbines.
9VAC15-40 -40: Analysis of the beneficial and adverse impacts on natural resources
ADD to C –
> Geological features and water features: identify these features within the impact zone and provide analysis of the expected impact.
9VAC15 - 40 -50: Determination of likely significant adverse impacts.
ADD –
> C. The department shall find that significant adverse impacts to geologic features and water features are likely to occur whenever a proposed project diminishes any aspect of the natural resource's integrity.
(Reference the geologic and water features that are identified on an updated site plan 9VAC15-40-70)
9VAC15-40-60: Mitigation plans
ADD –
> D. Mitigation measures for significant adverse impacts to geologic features to include the loss of the ridge top of a mountain which cannot be replaced. (Essentially turbine construction amounts to mountaintop removal)
> E. Mitigation measures for significant adverse impacts to water features to include the cost of cleaning up the streams, springs, and wetlands.
9VAC15-40 -70: Site plan and context map requirements
in application A ...
ADD –
> in (i) change to “the boundaries of the impact zone”
> in (ii) Add size of base of turbine and materials used for each turbine site.
in application B ...
Change –
> “.... the area encompassed by the site and within five miles of the site boundary” .... to “ .... the area encompassed by the impact zone.”
Thank you for the opportunity to comment on the PBR for wind turbines.
Sandra Stuart
Virginians for Responsible Energy