Virginia Regulatory Town Hall
Department of Environmental Quality
Department of Environmental Quality
Small Renewable Wind Energy Projects Permit by Rule [9 VAC 15 ‑ 40]
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5/25/23  9:09 am
Commenter: Tenney Mudge

Repeal the Permit by Rule Regulation for Small Renewable Wind Energy Projects

The Permit by Rule Regulation (PBR) regulation process for small renewable wind energy projects fails to protect citizens, communities, the environment and governmental entities.

  • The PBR regulation fails to protect counties and governmental jurisdictions located close to or adjoining proposed industrial wind turbine project areas.  The PBR regulation process must allow for all jurisdictions in close or adjoining proximity to a proposed project to be involved in the approval or denial permitting process from beginning to conclusion.
  • The PBR regulation fails to protect citizens from property value reductions resulting from industrial wind turbine construction negatively impacting the marketability of previously serene and desirable areas to live.
  • The PBR regulation fails to protect land owners and land conserved by Conservation Easements.
  • The PBR regulation fails to protect the public health, safety and welfare of citizens by not addressing sound dB levels, low frequency noise limitations and shadow flicker each having public health adverse impacts.
  • The PBR regulation falsely implies that small renewable wind projects are small.  These are large-scale industrial construction projects.  The corporations that build industrial turbine projects are not small but are multi-billion dollar corporate enterprises.  Impacts of multi-county view shed annihilation, commercial destruction and habitat loss of hundreds of acres of fragile mountain topography, road construction erosion, adverse watershed and wildlife impacts are not small.
  • The PBR regulation does not address that wildlife and environmental analyses that become invalid and exceed their defined shelf-life during the project permitting process must be redone and resubmitted.
CommentID: 217026