On behalf of MAREC Action (MAREC informally stands for “Mid-Atlantic Renewable Energy Coalition”), I respectfully submit the following comment in SUPPORT of retaining Virginia’s Small Renewable Wind Energy Projects Permit by Rule (PBR) regulations. MAREC Action is a non-profit coalition of utility-scale wind, solar and energy storage businesses dedicated to the growth and development of renewable energy in Virginia and across the PJM grid region.

The PBR regulations continue to work well in Virginia, allowing for the deployment of low-impact wind (and solar) projects less than 150 megawatts (MW) in a comparatively expedient fashion. Renewable energy sources, with no fuel consumption, are some of the least expensive sources of energy available today. As the PJM Interconnection notes in their Third Phase of Energy Transition Study (published Feb. 2023), it is critical for more energy sources to come online with power plant retirements at risk of outpacing the construction of new resources. Virginia’s PBR regulations help ensure that state law does not contribute to or worsen various, and sometimes project-killing, delays. Even as the PBR rules expedite project permitting, they preserve public feedback and rigorous environmental assessments.

Permitting more wind farms, faster, will unlock private investment and job creation across Virginia. Already, Virginia’s clean energy industry has created nearly 7,000 in-state jobs and invested over $5 billion in the Commonwealth. Though much of the current clean energy development pipeline utilizes solar technology, wind projects should be encouraged to compete and be permitted where technologically feasible. Ensuring robust deployment of solar, wind, and other clean energy resources will provide Virginia’s homes and businesses with affordable, reliable power for years to come.

Streamlined PBR regulations are a good fit for the wind industry. Wind energy arguably has the smallest environmental impact of any energy resource, producing no air or water pollution and creating comparatively small disruption to the landscape. Those already small impacts continue to shrink as technology improves. The average capacity of newly installed U.S. wind turbines in 2021 was 3.0 megawatts (MW)—up 9% since 2020 and 319% since 1998–1999. This upward trend in the power rating of individual wind turbines has resulted in reduced project footprints over time.

As previously stated, we support the retention of the PBR program for small wind projects. We also suggest one amendment that would better align the regulation with the development process. As projects proceed from land acquisition through permitting, it is common that small design adjustments or technological enhancements are identified that could improve a project’s efficiency or lessen local impacts. For example, wind turbine technology is advancing rapidly to the point of more efficient turbines with a smaller footprint potentially being available at the end of the development process compared to what was proposed at the start of the PBR application. We propose that the PBR process could be modified to allow some minor changes to project design without triggering a full permitting reset and restudy, assuming studies of the originally proposed project show minimal or no impact to various environmental resources.

We thank the Virginia Department of Environmental Quality for its diligence in implementing regulations that protect the environment and enable the deployment of wind energy and other energy resources. MAREC Action staff and its members would be glad to elaborate on the merits of this program, our proposed amendment, and address questions from the Department.

Respectfully,

Evan Vaughan

MAREC Action