RICHMOND - Late last Friday, before a hearing scheduled for Tuesday this week, Highland New Wind Development submitted further analysis of its wind project to the Virginia Department of Historic Resources.

The hearing was set by the State Corporation Commission following a complaint from DHR that a condition attached to HNWD's state permit for Virginia's first wind utility were not being met. DHR said it believed the SCC's condition to "coordinate with DHR for guidance regarding the potential need for archaeological and architectural surveys, recommended studies and field
surveys to evaluate the project's impacts to historic resources," had meaning, and that HNWD was not coordinating with the agency as ordered.

HNWD and DHR have exchanged discussion on these issues for more than two years, until the developer told the agency it would not communicate further with DHR until after construction started on its 38-megawatt utility.

DHR submitted its complain to the SCC on Aug. 19. HNWD and DHR met more than a week ago to discuss things further, after whic  DHR said the hearing would be held as scheduled for Oct. 12.

But Friday, HNWD submitted new information, and the state Attorney General's office attorney Steven Owens asked the SCC to postpone the hearing, to give DHR time to review the new information HNWD supplied.

That information consisted of a more detailed description of the project site by HNWD's archaeological consultant Dr. Linda Perry, and an explanation of the photo-simulations provided by HNWD principal Tal McBride. HNWD's project consultant, Heidi Lestyan, a renewable energy analyst with Antares Group Inc., explained that due to the existing constraints on the project, moving turbines more than a couple of hundred feet was is all that's possible, and would not mitigate the visual impact to the protected Allegheny Mountain Civil War battlefield nearby.

No archaeological significant findings, consultant says

Perry's Oct. 9 report explained that roughly 76 acres will be disturbed for the wind energy project. "The site plan shows various permanent and temporary construction areas," she wrote, "including 19 turbine sites, one substation, two potential locations for portable concrete plants, two locations for topsoil stockpiles and the approximate location of underground transmission lines. Roads on the property are in the process of being constructed and approved to accommodate heavy cranes and delivery trucks. All areas that will be impacted by the construction were surveyed."

Perry said that as part of studying the water quality of Laurel Fork, which crosses the project property, vegetation surveys "including assessments of soil degradation and erosion" were compiled by Lucile Miller, a downstream landowner. The study, done by Dr. Pamela Dodds, was included as an attachment of Perry's report. "To summarize those findings," Perry said, "the
property has been subject to ranching activities including cattle grazing and logging. These activities, combined with road building, have resulted in a lowering of both floral and faunal biodiversity in the study area. Additionally, soils have been thinned due to erosion by both the elements and human activities."

Today, Perry continued, "the property is characterized by two major types of landscape: open pasture that is leased for cattle grazing, and patches of secondary forest, mainly mixed hardwoods, that have been subject to logging that was supervised and approved by the Virginia Department of Forestry. Since 1958, the McBride family (owners of HNWD) has been
improving the forest using DOF guidelines. Both activities, cattle grazing and logging, have been ongoing for more than 50 years. Due to the heavy use of the property, the area is currently characterized by a very thin (often only 1-2 cm in depth) layer of dark brown sandy silt over bedrock."

Perry concluded, therefore, that the property is "believed to be of very low archaeological potential."

So, she said, "it is highly unlikely that the construction of the wind farm by HNWD will impact any archaeologically significant sites."

She pointed out that DHR's archives show no known sites of archaeological significance within the "footprint" of the project.

"On Oct. 19, 2008, Kathleen Kilpatrick (DHR director) and Roger Kirchen (DHR archaeologist) inspected the property and concurred that there is diminished potential for archeological sites within the proposed footprint," Perry added.

She characterized the property as having a "thin layer of dark brown sediment over bedrock. The soils are so thin that there is little to no potential for buried deposits throughout the construction site."

Further, Perry said, "The thin sediments present across the property also precluded the possibility of performing standard shovel testing; thus, with the exception of the areas bordering (U.S.) 250, the construction site was assessed using filed survey on foot."

Perry did her survey on May 8-9 this year.

Perry's report also described Tamarack Ridge and Red Oak Knob, where the two arrays of 400-foot towers are planned.

On Tamarack, she noted, nine turbine sites are in a roughly east-west line spanning about 1.16 miles at elevations between 4,000 and 4,300 feet. Each site is about 700 feet from the others, and they were marked by HNWD with steel fence posts. She surveyed both between those sites and within about a 100-foot radius of each post. All the sites, she said, are in grass-covered cattle pasture and sandy silt soils that cover underlying bedrock, often exposed. The thin soils, she said again, precluded shovel tests. "Foot survey revealed no evidence of any archaeological resources," she said.

At Red Oak Knob, 10 turbine sites are planned. Seven stretch approximately east to west in a line across the top of the knob for 4,750 feet, at elevations of 4,000-4,200 feet. Three sites, she said, are north of this line stretching along about 1,750 feet from southwest to northeast at elevations 4,000-4,189 feet. These, too, are about 700 feet from one another, and all but one are in the same kind of pasture/soil environment. One turbine, she said, was surrounded by brush that was cleared by HNWD. Again, Perry said, "foot survey revealed no evidence of archaeological resources."

Within the line of turbine sites on each ridge there is a site set aside for a potential portable concrete plant, she explained. "These sites measure approximately 150x250 feet." On Tamarack, she said, this site is between turbine sites No. 4 and 5, and was included in her survey. On Red Oak, the site is between the lines of turbines to the north of tower No. 1 and 2, and south of No. 8. "Foot survey of these areas located no archaeological resources," she said.

Perry also surveyed the areas where topsoil will be stockpiled and reached the same conclusion. The same was true for the substation site, transmission lines, and existing and new roads. She also looked at the two entrances to the project area from U.S. 250. The south entrance, just
south of where Laurel Fork crosses the road, was cut through a small hill, "and sediment has washed from this cut down to the entrance site," she said. "Shovel tests to a depth of 1.5 shove blade lengths (about one foot) were performed to the north and south of the entrance" about a meter from the edge of the existing road. "Both excavations revealed mixed gravel and bedrock fragments overlain by dark brown sandy silt that appears to have been deposited from sediment wash from both the higher-lying road cut to the south and the slope to the east. The area has been heavily disturbed by the building of (U.S.) 250," she said.

At the north entrance, east of the line of turbine sites on Tamarack, she attempted shovel tests about 100 feet to the west of the entrance, "and we were unable to complete this test due to the close proximity of the bedrock to the surface," Perry said. "This area, in which a road is scheduled to be constructed, was surveyed on foot. Shovel tests were performed ... both to the north and south of this entrance approximately one meter from the existing road." She reached the same conclusion as she died for the other entrance.

Finally, Perry said, the eroded topsoil on the property "precludes the possibility that there are any buried resources on the land. The construction of this project will not impact any known archaeological resource of significance. No further action is recommended."

No way to mitigate impact on battlefield, company says

The Antares Group visual impact study provided by Lestyan said little could be done to mitigate the towers' impacts on the area.

"After conducting the analysis, HNWD acknowledges that there will be a visual impact to Camp Allegheny as a result of several turbines currently sited on Tamarack Ridge," Lestyan said. "Those turbines will be visible from certain portions of Camp Allegheny, at a distance of approximately two miles from the closest turbine. Unfortunately, due to constraints on turbine siting imposed by (Highland County officials), there is not any additional, available method beyond those imposed by the county that can be used to minimize the visual impact."

Further, she said, "DHR is of the opinion that the visual impact is ‘adverse." HNWD does not believe the visual impact is ‘adverse." During the Oct. 6, 2009 consultation between HNWD and DHR, DHR handed HNWD a copy of a paper titled, ‘Assessing Visual Effects on Historic Property.' This guidance paper defines an ‘adverse visual effect' as a substantial diminishment of
the qualities of a place. Despite this disagreement as to whether or not the wind farm has an adverse visual effect on Camp Allegheny, the county-imposed viewshed minimization requirements are the only minimization tools available."

Lestyan's report then explains how siting for the turbines was conducted and how the visual simulations were done.

Lestyan explained that most of the property owned by the McBride family isn't suitable for the project. And, she said, the conditions of the conditional use permit issued by the county stipulate that each tower must be 1,600 feet from property lines, unless an easement is granted by the neighboring property owner. "In addition," she said, "the project is observing a minimum
setback of 400 feet from U.S. 250, and American Electric Power has requested that HNWD observe a 300-foot setback from the existing 69 kV transmission line, or get approval from AEP's civil engineers before constructing at a closer distance."

Lestyan said the developer also tried to restrict turbines to the open pastureland instead of clearing forested areas. The size of the project was also constrained by the available capacity of the 69 kV line, she added. "A set of interconnection feasibility studies conducted by PJM has determined that HNWD can add up to 39 megawatts of electricity to this transmission line via a project substation.

"The West Virginia state line crosses the McBride property ... along the fall line of Tamarack Ridge," she continued. "In order to ensure that all turbines were sited completely within Virginia, the precise location of the state line was surveyed by Jeffrey Hiner in accordance with the defined boundary, who also verified sufficient distance between the turbine foundations and
the state line to ensure that no portion of the foundation would cross into West Virginia."

Lestyan explained the kind of turbine chosen was based on criteria, including what types were available within a certain time. "Because the county placed a 400-foot height limitation on the turbines, the availability of appropriate tower heights was also a limiting factor," she said.

"Project economics dictate that a larger project will be the most attractive to utility customers. HNWD is allowed a maximum of 39 MW and a maximum of 22 turbines. Therefore, turbines must be rated at a minimum of 1.77 MW in order to achieve the desired 39 MW project size." Since no 1.77 MW are made, HNWD chose 2 MW turbines, and will use 19 towers.

Lestyan was the one who determined the preliminary layout of the towers on the site. "The portion of buildable area located on Tamarack Ridge has the greatest wind resource potential, due primarily to the terrain elevation and the orientation of the ridge, roughly perpendicular to the direction of the prevailing wind," she said. "For this reason, turbine siting on this section of
the project area was given highest priority."

The layout proposed was validated by Gamesa, which manufactures the turbine equipment. "The project area is located within complex terrain, which creates a more turbulent wind regime; in accordance with standard industry procedures, additional load studies were undertaken by Gamesa over an approximately six-month prior to ensure that the anticipated effects on the
turbine were within acceptable parameters," she explained.

As for the visual simulations, they were created using WindPro 2.4. "This software is created by the Danish company EMD," Lestyan said, "and is described on their website as ‘the world's most comprehensive software package for design and planning wind farm projects.' ... The visual simulation process relies upon digital elevation models of the terrain, and user-created photographs, and data input to describe the geographic location, elevation, time, data, focal length, and aspect ratio of the photograph."

The elevation models, she added, were obtained from the U.S. Geological Survey, and used to create a three-dimensional wireframe of the topography between the viewer and the wind project. Tal McBride took photos with a GPS unit on several dates "documenting the coordinates of the location, date, time, and elevation of image capture," the report says, and after the simulations were created they were provided to state agencies reviewing the project.

Because of all the constraints on the project, Lestyan notes, "it is not possible to relocate the turbines within the project area in order to minimize visual impact to Camp Allegheny. However, there are several other factors which are organically combining to reduce impact; namely, the distance between the closest turbine and Camp Allegheny."

Lestyan reiterates the biggest constraint is the 1,600-foot setback from property boundaries, which "severely restricts the possible placement" of the towers. "There is slight leeway for moving the turbine in a more or less southeasterly direction along the buildable area of Tamarack, while staying within the pasture land. However, the two turbines that are closest to
Camp Allegheny fall within a narrower section of the cleared area; any directional movement would be limited to approximately 200 feet."

Lestyan explains it's not possible to move any towers from Tamarack to Red Oak without adversely impacting Red Oak's towers, and its' not possible to move any of them closer together without negatively impacting their "production potential, and jeopardizing their site certification from Gamesa."

She said HNWD considered using larger turbines but no larger one were available within the required time period to meet the 400-foot height restriction. Also, even if they were available, they would still be on Tamarack. "This is because the wind resource available across the HNWD project site is strongest in the area of Tamarack Ridge, and this is the area of the site that is most easily built," she said.

HNWD considered moving the towers to be less visible from the Civil War site, too, Lestyan said. "This proposed minimization measure was presented to the Highland County Technical Review Committee, but rejected because there is not sufficient buildable area within the project to allow the array to be reconfigured without adversely impacting turbine mechanical integrity
and energy production potential. What movement is available would be incremental, approximately 200 feet, in a direction that is lateral to the primary vantage points from within Camp Allegheny, which has no impact on the appearance of the turbine size."

The reports provided to DHR are "under review," said Kilpatrick Friday.

The hearing was rescheduled for Tuesday, Nov. 10, at 10 a.m. in Richmond.