We're frequently reminded that wind energy and agriculture are compatible land uses. Farmers who lease sections of their crop land for wind development can continue working the soil right up to the towers and earn extra revenue for farming expenses. A win-win business opportunity, right? Not so fast. In this two-part series (part 2 here), Windaction.org examines the wind-farming relationship in the State of Illinois and tests the claim that the two are a good fit. As with so many topics involving wind energy, there is another story behind the story.

Back in 2007, Windaction.org posted a document entitled "What have I done?" The piece, written by Don Bangart of Chilton, Wisconsin, was based on a two- hour interview he conducted with a farmer in Northeast Fond du Lac County who agreed to lease a portion of his land for wind development. In the interview, the landowner makes several observations including this about how his land was managed:

"I watched stakes being driven in the fields and men using GPS monitors to place markers here and there. When the cats and graders started tearing 22 foot wide roads into my fields, the physical changes started to impact not only me and my family, but unfortunately, my dear friends and neighbors. Later, a 4 foot deep by 2 foot wide trench started diagonally across my field.

 

 

 

 

 

 

 

 

 

 

"A field already divided by their road was now being divided again by the cables running to a substation. It was now making one large field into 4 smaller, irregularly shaped plots. ...We soon realized that the company places roads and trenches where they will benefit the company most, not the land owner. ... All of the rocks we labored so hard to pick in our youth were replaced in a few hours by miles of roads packed hard with 10 inches of large breaker rock. Costly tiling we installed to improve drainage had now been cut into pieces by company trenching machines."

The Wisconsin farmer's experience is not unique.

Illinois has some of the best farming soil in the world with McLean County, Illinois rated #1 for the darkest, blackest most productive soil in the world.

But after extensive land moving and excavation needed to build roads and erect the turbines, farmers tell Windaction.org that the ground is never the same afterward. The fertile soil around the towers is mixed with subsurface clay and compacted resulting in lower crop yields. Depending on the lease terms, developers may compensate landowners for crop reductions but payments are often not passed on to tenant farmers who suffer the actual losses.

Since compaction is assumed to be a construction-related impact, crop-loss payments are often time-limited up to five years. However, every time turbines require maintenance, the massive crane is brought back to the site making compaction an ongoing concern throughout the life of the project. And it's not limited to existing roads or turbine pads. Turbine maintenance crews prefer to crawl across fields -- flattening crops and ground -- for quicker access to turbines needing service.

If drainage tiles are cut or damaged during construction, you're apt to see farmers working around ponds that were previously nonexistent. Or worse, adjacent fields not under lease can flood. With competition for rentable farmland so fierce, local tenant farmers risk losing their farms if they complain.

Soil compaction and drainage issues are serious concerns, but some might argue their effects are localized, and thus manageable. But that cannot be said about the impact of wind turbines on aerial spraying -- a subject that gets very little exposure.

The ability to secure aerial spraying services is limited in areas where turbines are standing.

The message on the Illinois Agricultural Aviation Association (IAAA) website is clear: 

"...farmers with wind generators may lose the option of aerial application of farm protection products, seed, fertilizers, etc. on their farm ground. Possibly more significant is that their neighbor farmers, who have no wind generator(s) and consequently no income from them, stand to lose that option as well.

"Some proponents of wind farms tend to dismiss this possibility out of hand, with the explanation that "those guys can fly around them with no problem," or "just get a helicopter to do it." Others say that ground application can still be effectively performed so the aerial option is insignificant. Unfortunately, it is just not that simple. Sometimes weather problems and/or timeliness of application dictate an application from the air.

"The fact is, it is dangerous to fly within the confines of a wind generator farm."

As more and more towers go up, less and less fields can be sprayed. Experienced pilots can feel the wake effect of the towers from several miles away. Such turbulence is dangerous to fly through.

Helicopters may be recommended because they travel at slower speeds and can work in more confined spaces but they can't carry the same loads meaning more trips at higher costs. There are far fewer helicopters in the State (under 10 in total) so timely availability is a critical issue.

Some farmers try ground applicators but aircraft can cover crops faster and more efficiently than any ground rig. In cases of Asian soybean rust, farmers could experience an 80-100% yield loss if not treated within a week. Aphids or spiders mites can destroy a field within days. If infestations occur during wet years ground equipment on wet soil will cause compaction or ruts that lead to erosion.

Illinois County Boards tasked with approving new wind development appear willing to accept that aerial applications are still possible but with more difficulty and at a higher cost (most spray policies charge premiums up to 50% above standard costs on fields within a mile of the towers, whether a participating landowner or not). What they do not seem to realize is that as more wind farms are permitted, the cumulative effect will lead to fewer and fewer fields that can be sprayed, making total crop loss a real possibility.

Since crop insurance will not cover the farmer in cases of insects or plant disease where damage is "due to insufficient or improper application of pest control measures or disease control measures", crop loss could lead to significant financial losses for farmers.

Illinois has nearly 1900 megawatts of wind turbines installed across thousands of acres of farm land and thousands more slated for development. Absentee landowners may be gaining financially from the development, but the idea that "wind farming" is a compatible agriculture use is more myth than reality in Illinois.

Special thanks to Rick Reed, president of IAAA, who provided valuable information on aerial spraying.

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In August 2007, First Wind, LLC received approval from the Vermont Public Service Board to erect sixteen 2.5 megawatt wind turbines in Sheffield, Vermont. Residents of Sheffield, neighboring Sutton, and others in the region fought the project from the beginning. And when First Wind was issued a NPDES storm water permit in 2009 from the State, the permit was appealed . The appellants argued that First Wind failed to identify the full extent of the area of disturbance, impacts to streams and stream biota, and violated the VT Water Quality Standards.

In advance of the Environmental Court proceedings, First Wind approached the appellants and others who opposed the project seeking settlement discussions.

A draft agreement was prepared by Kurt Adams¹, executive vice president at the company. It allowed for a $500,000 settlement to be paid over 20 years and allocated according to proximity to the project. The expectation was that those living closest to the project would receive more money; those further away would receive less.

Adams explained that the payment represented the "financial component" for sound easements only and that no consideration would be given for other negative effects caused by the turbines. In fact, a clause in the agreement specifically released the company from any and all actions, claims, or suits that might arise due to impacts of the project except those attributable to negligence of First Wind or its affiliates.

Adams also required that the stormwater appeal be dropped.

The parties overwhelming opted not to settle. Aside from problems with the agreement itself, the parties refused to be placed in the position of approving the destruction of Sheffield's mountain tops and felt that by agreeing to the terms they would pave the way for industrial wind development throughout Vermont. It was also important to them that they preserve future options. "None in the group could tolerate the thought of signing the non-disclosure, non-disparagement clause in the proposed agreement, nor did they believe First Wind would be around for 20 years to make good on the payments," one resident told Windaction.org.

Windaction.org has learned that upon hearing no deal, Kurt Adams upped the offer to $2 million. Still no agreement. 

The trial proceeded as scheduled, and good that it did. Expert testimony revealed that the area of disturbance impacted by the project would be 40% greater than First Wind claimed. Is this the reason Adams tried to settle now?

[1] Recent press accounts show that Kurt Adams accepted his job with First Wind prior to leaving his position as Chairman of the Maine Public Utilities Commission. First Wind is the largest developer of wind in the State of Maine with 124 megawatts installed and more proposed. A law suit filed by residents living near First Wind's Mars Hill wind energy facility is still pending.

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Last month, New Hampshire's Gov. John Lynch announced that 25-percent of the electricity powering the state's government buildings will now come from wind power.

Following a competitive bidding process the state signed a $4.4 million load-service contract with ConEdison Solutions , to supply electricity from both renewable and traditional fuel suppliers in the period from July 1, 2009 to May 31, 2010.

Lynch touted the agreement as "...another step in our efforts to protect our economy and our natural resources by ensuring 25 percent of the electricity used by state government comes from clean, renewable wind power."

The specifics of the contract are straightforward. The state locked-in its purchase of 47,352,000 kilowatt hours (kwh) at a fixed price of 9.2 cents per kwh. The price was all-inclusive and did not distinguish between electricity acquired from wind versus that from other fuel sources. Any added charges associated with transmission or distribution of the energy were excluded from the price and will be billed separately by the local utility.

The state's Energy Manager, Karen Rantamaki, told Windaction.org that New Hampshire had been purchasing its electricity from Unitil Corporation. When asked what the State would have paid in electricity costs had it stayed with Unitil she directed us to Unitil's website.

What we found surprised us.

Unitil's large customer prices are well below 9.2 cents per kwh. And with natural gas prices at a seven-year low and expected to remain depressed for the next 6-18 months, we anticipate electricity prices to remain stable[1]. New Hampshire's decision to sign with ConEdison appears less about saving taxpayer money and more about buying wind.

So what exactly did New Hampshire purchase for the higher electricity prices? Not much.

According to ConEdison Solutions, the "wind power" it sells is derived from its partnership with Community Energy, Inc., (owned by Spanish energy giant Iberdrola S.A.) who buys and sells renewable energy credits (RECs) from around the country.

We asked ConEdison Solutions the following four simple questions that NH's Ms. Rantamaki could not answer for us.

Question 1: Where are the wind facilities located that will be supplying the electricity?

Answer: The bulk of the RECs ConEdison sold in the last year came from Texas.

Question 2: When will the electricity be generated?

Answer: All renewable energy credits ConEdison sells are certified by GREEN-E. According to GREEN-E, certified RECs "include only renewables that are generated in the calendar year in which the REC is sold, the first three months of the following calendar year, or the last six months of the prior calendar year". For New Hampshire, the wind energy must be produced in the period from July 1, 2008 to March 31, 2010.

Question 3: What is the price of each REC?

Answer: National Green-e Certified Wind RECs are trading between 0.0012 cents and 0.0015 cents per kilowatt hour. At 0.0015 cents per kwh, the RECs acquired by New Hampshire would have a total market value of just under $18,000.

Question 4: Since the wind projects are already operational, are there any assurances that the money paid for the RECs will go toward expanding wind power facilities?

Answer: No. There are no stipulations on how revenue earned through the sale of RECs is to be spent.

Given these facts, we wonder if Governor Lynch is even aware of the misrepresentations in his claim above.

For example:

1. Electricity produced by turbines in Texas stays in Texas. The ConEdison agreement will have no effect on the state's consumption of fossil fuel.

2. GREEN-E certified RECS sold to New Hampshire could well have been "created" entirely in the year leading up the contract being signed, demonstrating the irrelevancy of the ConEdison agreement relating to wind.

3. There is no way to show how paying higher electricity prices will protect the state's economy or its natural resources. In fact, the higher price per kwh locked-in with ConEdison will result in costs far exceeding the market value of the contracted RECs.

At a time when the state is struggling to meet its budget, the pricey ConEdison contract does nothing more than raise electricity prices, line the corporate pockets of REC brokers ConEdison Solutions and Community Energy, and provide Lynch the PR opportunity to flaunt his "greenness" before an un-informed public -- Greenwashing at its best!

[1] According to the ISO-New England's August 7, 2009 presentation (Slide 54), wholesale electricity prices in the region are closely tied to natural gas prices.

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New Hampshire's Site Evaluation Committee is deliberating on Noble Environmental's  proposal to erect a 99-megawatt wind energy facility in northern Coos County.

The project has caught the attention of several high profile environmental groups in the State including New Hampshire Audubon, The Nature Conservancy, and Appalachian Mountain Club (AMC) - all of whom issued strong letters, and in the case of AMC, testimony, detailing the significant impacts to sensitive wildlife habitat should the project proceed.  Biologists at New Hampshire Fish and Game (NHF&G) submitted equally strong testimony arguing the project will produce an unreasonable adverse effect on the natural environment.

The facts proffered by the above mentioned groups are consistent.

The project located on managed timber land spans four ridgelines. The bulk of the thirty-three turbines are slated for rare, pristine old-growth forest that, according to NH's Wildlife Action plan accounts for only about four-percent of the state's land area but whose habitat type supports sixty-six vertebrate species including several threatened species. In particular, this high-elevation spruce-fir forest is home to the Bicknell's thrush, American martin, and the three-toed woodpecker, all known to be resident at the project site. Tracks of the Canada lynx, now believed to be pioneering back to the State have been observed onsite.

The project proposes to build 33 miles of roads involving 50-foot ledge cuts and surface widths ranging from 24 to 150 feet wide. Noble's engineer confirmed under oath that this photo taken at the Kibby Mountain wind facility in Maine accurately represents what can be expected in New Hampshire.

The project also seeks to fill over thirteen (13) acres of wetlands including the destruction of eight vernal pools.

The US Army Corps of Engineers has informed Noble that the alternatives analysis conducted on the project is inadequate and more needs to be done to prove that the proposed site location and plan layout is the least impacting. Technical letters prepared by the US Fish and Wildlife Service and EPA concur with the Army Corps finding.

Still, Noble Environmental has resisted all requests to relocate or remove turbines that might reduce the environmental damage complaining that any changes to the plan will harm the project's economic viability. No concrete evidence has been supplied by Noble to substantiate this point.

But it would appear that by Noble holding firm at least two parties have caved to its will - AMC and NHF&G. In the final days leading up to the State hearings, AMC, NHF&G, and Noble hastily slapped together an agreement termed the High Elevation Mitigation Agreement. The key conditions of the agreement are simple:

1) Land surrounding one of the four turbine strings sited on one of the four peaks (Kelsey Mountain) will be deeded to the State of New Hampshire as conservation land.

2) Two offsite parcels totaling 260 acres will be deeded to the State.

3) Funds totaling $950,000 will be paid to NHF&G of which $200,000 will be used to conduct post-construction studies on the effects of wind facilities on high-elevation species and the remaining $750,000 will go towards purchasing additional conservation lands.

AMC's and NHF&G's firm opposition to certain turbine strings being constructed was not firm at all. When faced with a choice between managed commercial timbering in the area - a regulated industry active in the state for decades (and now green-certified) - and the project, the project was deemed the lesser evil.

This position taken by AMC and NHF&G is even more incredible after considering AMC's David Publicover's own statements that timbering at high elevations in New England typically produces low commercial value and the steep slopes significantly impede harvest due to cost. This aerial photo of the Kelsey ridgeline showing an area near-black with forest appears to validate this point.

The haste in which the agreement was negotiated and signed did not go unnoticed during the hearings. Windaction.org, a party to the proceedings before the State, had the opportunity to cross-examined AMC and NHF&G on the agreement, a summary of what was revealed detailed below:

Did AMC or NHF&G perform a trade-off analysis that looked at total acreage impacted by the project including forest interior habitat lost?

Answer - "No." NHF&G stated in testimony that 3747 acres of high-elevation habitat would be affected.

Did AMC or NHF&G consider how far into the forest the direct edge effects of building the road, turbine pads, and associated transmission would be felt?

Answer - "No." AMC's Dave Publicover added under oath that "We knew those edge effects were there. We knew approximately what they were. ...We weren't basing our mitigation on any specific, you know, mitigation acreage ratio."

Did AMC or NHF&G visit the mitigation land to determine the quality of the habitat and whether it was comparable to the habitat that would be lost?

Answer - "No." In fact, some of the mitigation land was recently timbered, confirmed in aerial photos obtained by Windaction.org.

Did AMC or NHF&G prepare a scope of work for any post-construction studies and did either validate whether the $200,000 was sufficient to cover costs including administrative costs?

Answer - "No."

Did either AMC or NHF&G consider how much land could be purchased for the $750,000 and the availability of comparable habitat elsewhere in the State that was not already protected?

Answer - "No." Under oath, NHF&G stated it was difficult to tell what landowners will demand for land but the Department knows of several properties that had recently been cut.

It remains to be seen whether the State of New Hampshire will endorse the agreement signed by NHF&G, AMC, and Noble Environmental. Windaction.org would hope the Committee will hold a higher standard for the State than what NHF&G and AMC have demonstrated. The lesson learned in this case is that we cannot assume those negotiating mitigation settlement agreements have the knowledge, experience, or commitment to protect the natural resources at stake, even when that's their job. 

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Last week, First Wind (formerly UPC Wind) hosted a ribbon-cutting ceremony at its newest wind farm in New England, the Stetson wind energy facility located in Danforth, Maine. The event celebrated completion of the 38-turbine (57-megawatt) facility and was attended by 100 state and local officials including Maine's Governor Baldacci, construction company representatives, and local business owners.

The Governor addressed the crowd by praising his administration's proactive agenda on wind power development and the State's willingness "...to change for the future while safeguarding its natural resources."

Washington County Commissioner Chris Gardner thanked First Wind for its investment and called the company "tremendous stewards of our environmental resources and, most importantly, the public trust."

The public fawning by Maine's officials is typical of what we've come to expect from Baldacci and other politicos in Maine and its neighboring States of Massachusetts and New Hampshire, but in this case one needn't dig too deep to realize the "feel-good" messages belie the harsh realities surrounding Stetson.

The Stetson wind project involved two separate permit applications submitted to two different State regulatory bodies. The primary application covering the wind farm itself was submitted to and approved by Maine's Land Use Regulatory Commission (LURC). The second, known as the "Line 56 Project", detailed construction of a 38-mile, 115 kV (Line 56) transmission line from Stetson Wind to the Keene Road substation in Chester, Maine and was approved by the State's Department of Environmental Protection (ME-DEP).

According to the "Line 56 Project" application, the 38-mile line involved impacts to 81.1 acres of wetlands including crossing the Penobscot River, the Mattagodus Stream Wildlife Management Area¹, and the Mattawamkeag River twice! Windaction.org wonders whether Governor Baldacci was even aware of what his ME-DEP approved when he praised Maine for "safeguarding its natural resources". Impacts to the natural environment notwithstanding, First Wind described the aesthetic impact of building Line 56 as ‘Low' despite the fact that 173 dwellings were located within 300-feet of the line.

But the situation surrounding Stetson is more dire.

In June 2007, three months prior to First Wind submitting its application for permission to construct Line 56, the final draft copy of the Interconnection System Impact Study was released detailing the local- and grid- wide impacts to the New England power grid should Stetson feed 57 MW to the grid. The findings of the study were clear.

The System Impact Study asserted Stetson would have "no significant system impact to the stability, reliability, and operating characteristics" of the New England transmission system but that conclusion tells only part of the story. The study also showed that the existing transmission Line 64, into which Line 56 would feed, was at full capacity (151 MW) servicing Brookfield Power's 126 MW hydroelectric system and Indeck's 25 MW biomass power plant - both base load renewable generators. With the introduction of Stetson energy into Line 64, energy output from Brookfield and/or Indeck would have to be significantly curtailed resulting in a 0 MW net gain in renewable generation for the region. Put another way, Stetson Wind, an intermittent unpredictable generator, could displace existing reliable base load renewables.

In its March 13, 2008 letter to the ME-DEP, Brookfield Power New England LLC correctly stated through its attorney Matthew D. Manahan that "It is not in the public interest for new intermittent renewable generation to be constructed and to pass over Line 56 if it simply displaces existing renewable generation - that can provide capacity to Maine - on another transmission line, Line 64."

Regardless the environmental, visual and transmission impacts of Line 56, ME-DEP granted First Wind the permit.

It's not certain how much, if any of Stetson's 57 MWs of wind energy will ever reach the New England power grid, but according to a recent article in the Bangor Daily News, the ISO-New England and Maine state officials assured Brookfield and Indeck that the established power generators' needs would come first when the Stetson Mountain project goes active. Brookfield Renewable Power Inc.'s general manager told the paper "In layman's terms, they [First Wind] were going to have to take a back seat to our transmission needs." That may be true, but Windaction.org wonders whether First Wind's banker, HSH Nordbank, who wrote a letter endorsing First Wind and the Stetson proposal to ME DEP is aware of this fact. And did Governor Baldacci know this last week when he bowed before the massive towers.

Still, none of these issues have dampened First Wind's plans to build Stetson II, a 17-turbine 25.5 MW facility. According to published documents submitted to LURC in November 2008, Stetson II will connect to the same substation as Stetson I and has no need for additional transmission. (The same holds for First Wind's proposed 60 MW Rollins Wind project.)

First Wind's Stetson II (and Rollins Wind) will further exacerbate the congestion on Line 64, and its energy may never get to the New England grid.

But apparently, First Wind is confident it will still get Maine's permission to build Stetson II. 

Windaction.org has learned First Wind has already taken delivery of Stetson II's seventeen turbines. These photos (photo1, photo2) dated December 20, 2008 show the turbine components on the Stetson Mountain leased property and at the old staging area for Stetson I. 

With powerful wind proponents like Governor Baldacci and First Wind's Chief Development Officer Kurt Adams (former chairman of Maine's Public Utilities Commission, Maine's primary regulator of transmission infrastructure), First Wind has no reason to sweat the hard questions. But to be safe, Bill LD 199 was introduced in the legislature to squash all possible local obstacles. The summary of LD 199 states:

"The bill grants the state-level wind power siting authority, which is the Department of Environmental Protection or the Maine Land Use Regulation Commission depending on the location of a given wind power development, sole jurisdiction for approving the construction and initial operation of a wind energy development. Specifically, the bill prohibits any other state or local governmental entity from requiring any approval, permit or other condition for the construction or initial operation of a wind energy development that has been certified or permitted by the wind power siting authority."

Contrary to Washington County Commissioner Chris Gardner praise of First Wind as "tremendous stewards ...of the public trust", in fact, First Wind, and those Maine officials entrusted to protect the environment and the health, safety, and welfare of the residents have shown nothing but contempt for the public trust.

Unfortunately, it will be Maine's citizens and the greater New England region who pay the price for Baldacci's ignorance, Kurt Adams audacity, and First Wind's arrogance.

¹The Mattagodus wetland system includes one of New England’s most ecologically significant fens (groundwater-fed wetlands), at least ten endangered and threatened species including the Clayton’s copper butterfly (which only occurs at ten sites in the world), and a rare mayfly species whose only known occurrence is in Maine.

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In September, the U.S. Forest Service released its Draft Environmental Impact Statement (DEIS) for the first wind energy project proposed for national forest lands.

Iberdrola's Deerfield Wind application proposes to erect fifteen 2-MW turbines in the Green Mountain National Forest located in southern Vermont. The project site is adjacent to the older Searsburg project erected on private land in 1997.

A review of the DEIS reveals disturbing information regarding the Forest Service's assessment of this project's impacts in the context of the National Environmental Policy Act or NEPA.

The "purpose and need" section appears designed to achieve a predetermined result of siting an industrial wind energy facility on Forest Service land adjacent to the existing Searsburg site. Justifications used for considering the project application include (quoting the document):

• "The Project would provide a reliable and much needed source of power, contributing to long-term cost stability, in a region where the availability of cost-stable resources is quickly diminishing", and
  

• "The addition of wind energy to the regional electric grid has the benefit of decreasing the emission of harmful air pollutants, and decreasing reliance on natural gas and other fossil fuels."

Neither statement is accurate nor is there any attempt to substantiate these assertions. The Forest Service has no basis for claiming the project will provide "long-term cost stability" given the unpredictability of the wind resource and Iberdrola's inability to secure a long-term power purchase agreement for the energy. Since the New England states are participants in the regional cap and trade program, Regional Greenhouse Gas Initiative or RGGI, the Forest Service cannot claim emissions will decrease should the project be built. Emissions will only be displaced.

In the alternatives analysis, the Forest Service never contemplates an alternative where the project is built on private land, an obvious omission. The only three alternatives provided, including a 'No Build' option, reflect variants of the original. The message is clear -- the Forest Service is committed to seeing this project built here and built now.

But the most offensive aspect of the DEIS document is how it reads more like a repackaging of Iberdrola's application rather than a serious assessment under NEPA in many important topics including aesthetics, economic benefits, impact on wildlife and the natural environment, and safety (ice throw, blade and turbine failure). It appears the Forest Service shamelessly accepted Deerfield Wind's studies, with no apparent attempt to validate the assumptions and conclusions made by the developer on project benefits and impacts.

For example, on Noise impacts, the Forest Service accepts Iberdrola's recommendation that the Project meet a nighttime guideline for protection against sleep disturbance of 45 A-weighted sound pressure levels (dBA) averaged over an eight-hour night at the wall of nearby residences.

By doing so, the Forest Service ignores the growing body of data, detailing the risk of turbine noise in rural communities. WHO recommends that sound levels during nighttime and late evening hours be less than 30 dBA during sleeping periods and that for sounds containing a strong low frequency component (typical of wind turbines), WHO asserts these limits may need to be even lower to avoid health risks. They also recommend that the criteria use dBC frequency weighting instead of dBA for sources with low frequency content.

The Forest Service also fails to note that the International Standards Organization (ISO) in ISO 1996-1971 recommends 25 dBA as the maximum night-time limit for rural communities. Sound levels of 40 dBA and above are only appropriate in suburban communities during the day and urban communities during day and night. There are no communities under this standard where 45 dBA is considered acceptable at night.

It's not possible to determine whether the Forest Service willingly conceded its responsibility to Iberdrola in assessing the impacts of the project or whether it did so out of ignorance, but the outcome is the same.

If the Federal Government is serious about understanding and documenting the impacts of wind energy projects on our National Forests, the American public deserves more. This DEIS cannot be allowed to set a precedent. Windaction.org advises the Forest Service to scrap the Deerfield Wind DEIS and begin again, but this time with a focus on research, not reproduction.

If our readers share these concerns, please take a moment to e-mail your thoughts to the Forest Service. The deadline for comments is Friday, November 28.

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The New York Times recently published "Thinking Anew About a Migratory Barrier: Roads" in which reporter Jim Robbins explores the impacts of road development on wildlife habitat at Glacier National Park in Montana.

Noting that scientists now understand the impacts of roads crisscrossing the landscape, Robbins writes "Some experts believe that habitat fragmentation, the slicing and dicing of large landscapes into small pieces with roads, homes and other development, is the biggest of all environmental problems."

Dr. Michael Soulé, retired biologist and founder of the Society for Conservation Biology is quoted: "It's bigger than climate change. While the serious effects from climate change are 30 years away, there's nothing left to save then if we don't deal with fragmentation. And the spearhead of fragmentation are roads."

For perspective as to the enormous roads which have been built along forested Appalachian ridgetops for industrial wind energy projects, Windaction.org examined these images prepared by Dan Boone, which provide before and after aerial photos of the very southern end of the NedPower windplant in West Virginia. The NedPower facility is the most recently constructed wind energy project in the mid-Atlantic region, comprised of 132 2-MW Gamesa wind turbines, each nearly 400 foot tall and a 3-blade rotor assembly with diameter of more than 260 feet.

The average width of the area bulldozed for the road corridor and other project infrastructure varies from about 75 to 100 feet. We estimate that over a square mile of forest was lost due to this one wind facility, about 650 acres, or roughly 5 acres of forest cleared on average for each wind turbine. The forest acreage loss is greatly exceeded by the amount of ecologically-significant "forest-interior" habitat that was eliminated by the extensive fragmentation of the area's forest coverage.

From an ecological perspective, roads create "edges" which severely affect "forest interior" wildlife.  For example, woodland birds which nest near forest "edges" are more likely 1) to have their eggs or young taken by scavengers/predators who disproportionately frequent "edges", and 2) to be "parasitized" by brown-headed cowbirds who lay their eggs in other birds' nests. In addition, there are a host of ecological concerns associated with created "edges" within the "forest interior" such as:

1) increased sunlight and evapotranspiration (drying) which changes vegetation structure and composition along the zone of forest that adjoins edges, with penetrating effects up to several hundreds of feet, and

2) greatly increased dispersal and colonization of forest edges by invasive, non-native species of plants and animals.

Wind developers typically downplay the size of the roads and press for mitigation to compensate for the impacts. But it's nonsensical to assume 'X' acres of disturbed forest-interior can be mitigated with 'Y' acres of some arbitrary parcel some distance away.

Trisha White, director of the Habitat and Highways Campaign for Defenders of Wildlife notes, "the downside of mitigating road impact is thinking that it heals all wounds. The biggest danger is thinking that we can put in new roads with crossings and things will be just fine. There are so many more impacts. Nothing could be more incorrect.”

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This week, UNESCO, the cultural agency of the United Nations, threatened to act against Britain for failing to protect "world heritage sites". Their complaints included a proposed wind energy facility that would impact Neolithic sites on Orkney.

Also in the news, a wind project planned for public lands in Nevada would site seventy-two massive turbines overlooking the Comstock Historic District and Virginia City National Historic Landmark, the largest federally designated historic district in the United States.

In Virginia, Highland New Wind Development is fighting a condition of its approval requiring an archaeological study and viewshed analysis, among other studies. Of special concern is the impact the towers will have on Camp Allegheny, a Civil War battlefield atop Allegheny Mountain less than a mile from the project site.

Finally, Windaction.org was forwarded these photos (image1, image2) of Colorado's Pawnee Buttes, a site memorialized in the movie version of James Michener's epic Centennial. The Pawnee Grasslands have been changed forever with the construction of the Cedar Creek wind energy facility, a 275 turbine project that went online last January. Colorado Governor Bill Ritter, who dedicated the Cedar Creek, praised the development calling it good for Colorado's economy, its environment, and energy independence. Apparently the honorable governor never stopped to consider whether it was good for the United States' heritage. And Windaction.org questions whether Ritter ever asked for concrete numbers that show the environmental and energy benefits of the project justified the industrialization of this historic area. 

Wind proponents are shrewd at creating pre-construction simulations that blunt the appearance of the massive towers through the use of simulated camera angles and long-distance views. First Wind (formerly UPC Wind) went one step further in disguising the visual impact of its Sheffield Wind project in Vermont using views up to the hub height only. When asked what turbine height they assumed in creating their visual exhibits they stated "We commonly rely on hub height rather than the tip of the blade... as the rotor top when extended vertically directly above the hub does not represent a fixed height or "top" as it is a moving element of the turbine... and viewshed analyses are based on fixed points."

From Britain's moors to the mountains of Maine and New Zealand, from the plains of Australia to the canyons of Idaho, those who cherish the natural beauty of our open spaces need to defend our viewsheds against the march of the turbines. Otherwise, our only option is to capture the images before they're lost, as recommended by our colleagues in Idaho.

Furthermore, if view sheds surrounding historic landmarks worldwide are so easily tossed aside in the name of renewable energy, how can we ever ensure "lesser" views are preserved. But in many cases, those approving the projects have no idea the scale and magnitude of the visual impacts and apparently have little regard for the heritage of hundreds, thousands, or millions of years ago, yet is so wantonly defaced or even demolished.

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In 2004, the U.S. Government Bureau of Land Management (BLM) granted Pacific Wind Development LLC (now Iberdrola/PPM) a 3-year Right-of-Way Temporary Use Permit for 17,617 acres of public lands for "wind energy testing and monitoring facilities". The testing right-of-way was permitted without the benefit of public notice or comments, apparently based on the assumption that wind testing would not prove controversial. Letters objecting to the right-of-way grant were submitted by the Center for Biological Diversity, the San Diego Sierra Club, the San Diego County Board of Supervisors and others.

In December 2007 the BLM released an updated Eastern San Diego County Proposed Resource Management Plan (PRMP) and Final Environmental Impact Statement (FEIS) that allowed Iberdrola/PPM to develop wind energy in the vicinity of McCain Valley on 6,931 acres, reduced from the initial 17,617 acres granted. Opposition mounted and letters of protest were lodged with the bureau of which only one, written by Iberdrola/PPM, argued that more land should be granted.

In response to the protest letters, the BLM filed a public notice of "significant change" in the Federal Register last month in which it stated: "Concerns have been raised by the public that the Eastern San Diego County PRMP is overly restrictive regarding wind energy development and is not adequately responsive to national goals and directives... regarding renewable energy development on public lands". Per its public notice, the BLM now proposes downgrading an additional 13,000 acres of public land to allow for Iberdrola's development plans. The land in question is immediately adjacent to areas of critical environmental concern, and BLM Wilderness Areas.

In its detailed letter of protest to the BLM, the Boulevard Planning Group wrote "Any plans to industrialize (rape) our local public lands, especially at the expense of US taxpayers and local property owners, will be met with fierce scrutiny and opposition. We are not alone." Written comments on the changes to the PRMP will be accepted until August 27, 2008.

Windaction.org encourages all of its subscribers to join the Boulevard Planning Group and file protest comments with the BLM.

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Wind energy developers commonly downplay the impact of road construction through proposed project areas. For most ridgeline project proposals which Windaction.org has reviewed, applicants quietly state that roads will only require 11-meters (36-feet) width during construction, and quickly add that these areas will be allowed to re-vegetate back to 16-foot mountain trails. Yet, a reading of the actual road plans tells a very different story, as do actual results at completed developments.

First, be cognizant that 36-foot wide roads are as wide as a 3-lane interstate highway in the U.S. Given steep slopes and the potential for damaging runoff, comprehensive measures are needed to prevent erosion - all of which adds to the width of the cleared area. The road's subsurface and related compaction of road surface will likely prohibit re-growth beyond shallow grasses; it is questionable whether the impacted area will ever return to a forested state for decades.

The application for the Deerfield Wind project in the Green Mountain National Forest in Vermont, a 42.5 megawatt (17 turbine) facility, will add approximately five linear miles of expansive road with a minimum 38-foot surface width. Windaction.org determined through discovery that the actual ridgeline roads would vary between forty and 160-feet.

Aerial photos of the Bear Creek, PA facility, an operating 12-turbine, 24 megawatt site clearly show a road structure that is nearly 100-feet wide. As do photos from Mars Hill that show clearings up to 100-feet wide. Road development at Pennsylvania's Allegheny Ridge wind site suffered 100-150 foot corridors cut through the forest. These are typical examples.

Windaction.org encourages reviewers to be mindful of the extent of road development impacts particularly in areas that are undisturbed. The true impacts should be scrutinized and developers held accountable prior to approving any project permits.

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National Audubon’s newly released position statement on wind energy development is short, sweet, and dangerous.  Notable deficiencies in the Statement include:

1) Audubon’s use of italics of the word "population" in an apparent effort by Audubon to a) limit concern over wind plant development's impact to wildlife species and b) discourage concern over the numbers killed.  The notion that only "population" level impacts should be of concern is an unacceptable flaw in this document since no one can determine what constitutes a "population" for most species of nocturnal migrant songbirds or bats. 

2) Audubon asserts that “habitat impacts” can occur and fails to acknowledge the considerable habitat loss that IS OCCURRING.  The document omits the term “fragmentation" when describing impacts of wind energy development and appears to only grudgingly concede there may be impacts.

3) Audubon's call for guidelines is weak, and represents thinking that is several years behind the times.  Guidelines that do not require mandatory compliance by the wind industry are meaningless. We question whether Audubon understands that the U.S. Fish and Wildlife Service has had wind/wildlife guidelines available for 5 years and that this voluntary guidance has been largely ignored by the wind industry.

4) Most egregious is Audubon’s failure to recognize the threat of wind energy development on our national forests and state-owned lands. Audubon should be calling for a ban on wind development on public lands as long as suitable privately-owned lands are available. Further, Audubon should be insisting that wind projects on public lands comply with more stringent siting and monitoring requirements than any provided via "guidelines".
(Analysis by D. Daniel Boone)

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Two different, but very similar news reports (CBS News: Winds of change blow in Texas and NPR: Winds of change blow into Roscoe, Texas) were published in the last two weeks. Each highlighted the economic opportunities resulting from wind energy development in West Texas and the revitalization of otherwise land-rich, resource-poor communities of the State. CBS termed it a "wind energy gold rush".

These stories stand in stark contrast to the message offered in this short video from the same area. Further, not all landowners who lease land for wind development continue to support their decision after the turbines are operational. This paid ad, which appeared in a Wisconsin paper in October 2007, tells a disheartening story of a landowner who recognized the fallout of his decision after the damage was done.

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