More Than Half The Voters Sign Petition

This letter to the US Army Corps of Engineers details the deficiencies in Noble Environmental Power's application to build a 99-megawatt wind energy facility in Coos County, New Hampshire. The US Fish and Wildlife Service makes a powerful case for why a full Environmental Impact Statement (EIS) should be undertaken in accordance with the National Environmental Policy Act (NEPA).

This letter to the US Army Corps of Engineers details the deficiencies in Noble Environmental Power's application to build a 99-megawatt wind energy facility in Coos County, New Hampshire. The US Environmental Protection Agency makes a powerful case for why a full Environmental Impact Statement (EIS) should be undertaken in accordance with the National Environmental Policy Act (NEPA).

The Nature Conservancy of New Hampshire submitted the below comments to the New Hampshire Site Evaluation Committee in response to a proposal pending before the committee. The proposal, known as the Granite Reliable Power (GRP, LLC) Wind Park, seeks to erect thirty-three 3.0MW turbines along the Kelsey, Owlshead, and Dixville peaks located in Coos County, NH. GRP, LLC is owned by Noble Environmental Power.

The Audubon Society of New Hampshire submitted comments to the New Hampshire Site Evaluation Committee in response to a proposal pending before the committee. The proposal, known as the Granite Reliable Power (GRP, LLC) Wind Park, seeks to erect thirty-three 3.0MW turbines along the Kelsey, Owlshead, and Dixville peaks located in Coos County, NH. GRP, LLC is owned by Noble Environmental Power.

Noble Environmental, operating under the name Granite Reliable Power, LLC is proposing to erect a 99 MW wind energy facility in northern New Hampshire. The New Hampshire Fish and Game has submitted prefiled testimony to the State's Site Evaluation Committee expressing its concerns with the impacts to wildlife.

Memo from the Massachusetts Department of Public Utilities Chairman, Paul Hibbard, to the ISO New England. Chairman Hibbard expresses his concerns over the push to regionalize costs for building expensive transmission lines to service renewable projects (wind) built far from load centers. Current FERC rules are unclear on how to justify distribution of the costs across all ratepayers within the region unless it can be shown such transmission is needed to ensure the reliability and integrity of the grid.

In July 2007, the New Hampshire Site Evaluation Committee (SEC) permitted, with conditions, the Lempster Wind LLC project owned by Iberdrola. The project will consist of twelve 2 MW Gamesa turbines along five miles of access roads. Iberdrola is now shopping around its neighbor agreement to non-participating landowners asking them to waive noise protections the SEC conditioned in the permit, among other protections. Iberdrola's agreement can be downloaded from the link below.

These public comments were filed with the New Hampshire Site Evaluation Committee in reference to the Lempster Wind proposal (NH SEC Docket 2006-01 - Lempster, NH). Ms. Martin's comments were prepared following interviews she had with residents living near the Mars Hill, Maine commerical wind project. The Mars Hill wind project went on line in early 2007; problems of noise were reported as early as December 2006.

This document includes studies in Maine, Maryland, Minnesota, New Hampshire, New York, Pennsylvania, Vermont, Virginia and West Virginia.

Why did you petition to become an intervenor in this matter before the NH SEC?

With New Hampshire’s recent reinstatement of PILOT agreements and legislative efforts to a Renewable Portfolio Standard, the regulatory groundwork is being laid for more wind facilities to enter the state. Yet, New Hampshire, like many states, has no consistent regulatory process in place for reviewing these projects to ensure our environmental, societal, and economic interests are protected. The work the NH SEC has agreed to undertake in reviewing this application is precedent setting. How the committee approaches its review and the weight it places on arguments presented by all sides will impact other developments in the State as pertains to renewable energy projects.

There are a multitude of conflicting issues at play when considering any wind project. My commitment to this process is to help provide, to the best of my ability, valuable and timely information that will assist the Committee in making an informed decision on this application.

Below are two Phase I Avian Risk Assessments reports, prepared by Paul Kerlinger, for Vermont's East Haven Wind Farm (July 2003) and New Hampshire's Lempster Mountain Wind Power Project (June 2005). Phase I assessments have proven inadequate in assessing mortality at several sites in the U.S. including Mountaineer in West Virginia and Meyersdale in Pennsylvania. The US Fish and Wildlife Interim Wind/Wildlife Guidelines calls for multi-year evaluation of avian and bat activity using remote sensing.

Starting with our first interagency meeting on April 8, 2005, we have generally discussed three broad categories of activities that pose a potential concern for fish and wildlife resources. These include the potential for bird and bat collisions with turbines, habitat fragmentation effects on wildlife and impacts to waters/wetlands. At the April 8, 2005 interagency meeting, we recommended that CEI collect three (3) years of radar data on spring and fall bird/bat migrations to document the spatial and temporal use of the airspace by these flying vertebrates. Three years of radar data should be sufficient to gather information on the spatial and temporal distribution of birds in the airspace, including the year-to-year variability in migration patterns at this site, and represent our normal request for these data at wind projects. We have consistently requested that this data be collected at our meetings and field visits and continue to make this request for radar information.

Renewable energy sources have disadvantages as well as advantages, however. Although their costs have decreased in recent years, many renewables are still more costly than traditional sources. Some are also available only intermittently; for example, wind can be variable and hydroelectric is seasonal. And while many people are in favor of renewables in principle, many are also unhappy when faced with the prospect of a windmill or a trash-burning power plant in their neighborhood. These facilities face the same siting and investment difficulties that any electrical facility would, as the developers of a proposed wind farm off the coast of Cape Cod have discovered in recent years.

...the MEA Report can be used to estimate the value (avoided emissions) of Renewable Energy Certificates (REC) by providing both REC suppliers and stakeholders with information that can be used to communicate the environmental benefits of RECs and works to enhance the overall REC marketplace.

Editor's Note: As noted below under Methodology [emphasis added], this report appears to substantiate the point that wind energy would not backdown "baseload" generation.

With the emergence of recent proposals, there appears to be growing interest in expanding renewable energy sources in New Hampshire. New Hampshire’s government has taken several steps to encourage the use of renewables, including setting net metering guidelines for small-scale generators (less than 25 kW) of photovoltaics, hydroelectric, and wind.1 Net metering guidelines in New Hampshire require that utilities purchase any electricity generated by small scale generators in excess of what they use. Further developing renewables beyond small-scale generation, particularly wind, can help New Hampshire increase the proportion of energy generated from renewable sources. In fact, developing the full potential of wind resources in the state holds great promise for helping to meet the state’s energy needs.