Regulatory Town Hall Comment
Small Renewable Wind Energy Projects Permit by Rule
Being one of just a few dozen people in Virginia who have had personal experience with the PBR for “small” wind projects, I believe that I am highly qualified to make some comments “to determine whether this regulation should be repealed, amended, or retained in its current form.” My opinion is that the current form of the PBR is a complete failure with respect to its goal of being “necessary for the protection of public health, safety, and welfare or for the economical performance of important governmental functions; (ii) minimizes the economic impact on small businesses in a manner consistent with the stated objectives of applicable law; and (iii) is clearly written and easily understandable.” My conclusion is that the current PBR should be repealed or significantly amended. My reasons for this conclusion are listed below.
As some background before I begin the list, I have been involved with the effort to prevent the construction of the Rocky Forge Wind project in Botetourt County along a mountain ridgeline which is zoned as a Forest Conservation District. This project will require the construction of several miles of access roads, and destruction of over 200 acres of forest habitat that is a watershed for class IV wild trout streams. The proposed turbines will be 680’ to the tips of the blades, the tallest structures on land in Virginia, and will kill eagles and bats. Blasting foundations will result in altered surface and groundwater flows, and will require hundreds of loads of concrete. The total cost for this project is many millions of dollars. It is important to note that Rocky Forge is the only project for which the PBR for wind has been applied.
Below are my comments on the failures of the PBR.
May 18, 2023