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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5/29/23  10:09 am

The PBR process should have a rejection criteria.

The purpose of the PBR regulation was to simplify the permitting process for small renewable energy projects. Witnessing the process for the Rocky Forge project, the process goes too far by not having a rejection criteria. It is apparent that a company receives approval by simply submitting the required information, regardless of its content or accuracy . A couple of examples are:

  • PBR requires a interconnect agreement. The one presented for Rocky Forge had expired, yet accepted. The permit should have been rejected until Apex submitted a valid agreement.
  • Apex had not decided on the type of turbine and its capacity rating, yet DEQ accepted the certification from an engineer, while not knowing the type or number of turbines, certified the rated capacity of the project anyway. 
  • The original noise survey was flawed, yet accepted. 

The regulation should be modified include some higher rejection criteria other than just checking off boxes.

I agree with other comments addressing the size vs rated energy capacity.




CommentID: 217034