Glebe Mountain Group: Comments To Windham Region Planning Commission Regarding June 12, 2006 Draft of Regional Plan
Vermont regional commissions are responsible for updating their respective 'plans' every five years. The Windham Regional Commission (WRC), comprised of representatives from the 27 towns in Windham County, submitted a draft of its updated plan for public comment in late June 2006.
Given the prevailing public concerns regarding energy, the energy section of WRC's draft plan was of particular interest. Specifically, the Glebe Mountain Group, an incorporated non-profit organization that has been actively engaged in protecting Glebe Mountain from industrialization, felt is was imperative that industrial wind generation projects not be encouraged or accorded any presumption that they serve the public good.
The Glebe Mountain Group's comments on the plan are attached as is the original 'draft' WRC plan. Some of the specific comments related to wind energy are extracted below as is the conclusion. These comments were fully endorsed by The Friends of Glebe Mountain, an unincorporated 100% volunteer group comprised of residents of and non-resident property owners in the towns of Londonderry and Windham.
With respect to Soils and Topography, the Plan provides the following policy directive:
1. Avoid intensive development (other than recreational trails and ski lifts) in areas predominated by slopes exceeding 25 percent or above 2,500 feet in elevation; (WRDP at 74) (emphasis added)
The Windham Regional Plan and its policy directives, have been relied upon by the Vermont Environmental Board in several decisions that rejected development plans for failure to conform with the land use planning goals and policies of the Regional Plan. In a recent case of particular relevance, Re: Peter S. Tsimortos, #2W1127-EB (August 29, 2003), the Environmental Board determined that the construction of a residence and clearing of 12.5 acres of land above 2,500 feet in elevation in Dover, Vermont, failed to conform with the Windham Regional Plan. The Environmental Board relied upon the policy directives which require the preservation and protection of Resource Lands and Fragile Areas. Excerpts from the Tsimortos decision are provided as follows:
The project, as it includes lands above 2,500 feet in elevation, is located in the lands described in the ‘Resource Land’ subsection of the Regional Plan’s Land Use section, lands which the Regional Plan finds worthy of ‘special protection’. Appropriate uses for these lands include ‘conservation, forestry, recreation, and low impact, very low density rural uses’. The Plan’s ‘Resource Land policies’ seek to ‘ensure that new development reflects existing settlement patterns, is low impact and low intensity, and does not conflict with the resources, but rather sustains these natural resources’ and to ‘ensure protection of lands over 2,500 foot elevation.’...
The project is not a conservation, forestry, recreation, or other low impact use. While it is certainly a very low density residential use, the Board questions whether it is a very low density rural use. But the Board’s decision does not hinge alone on the project’s impacts designated by the Regional Plan as ‘Resource Lands’.
More significant than the project’s location in Resource Lands is its location in a ‘fragile area’ as defined by the Regional Plan: ‘Areas above 2,500 feet in elevation constitute fragile areas in Vermont.’ The Regional Plan’s Policies for ‘fragile areas’ state: ‘Protect natural and fragile areas from development. When development is proposed near a natural or fragile area, a buffer strip designed in consultation with the appropriate state agency, must be designated and maintained between the development and natural or fragile area.’
This project is contrary to the Plan’s mandates as to fragile areas. The Regional Plan requires that, when development is proposed near a fragile area, a buffer strip between the development and the area ‘must be designated and maintained’. Here, the development occurred within the fragile area itself, a per se violation of the buffer requirement.” (#2W1127-EB at 23-24) (emphasis added)
The language relied upon by the Environmental Board in determining the project’s nonconformance with the Windham Regional Plan has been carried forward into the Draft Plan. The definitions of Resource Lands, Fragile Areas, and the Natural Resource Policies remain fully applicable to large-scale commercial wind projects.
Large-scale commercial wind projects cause substantial land disturbance in fragile high elevation habitats and are a complete distortion of the natural ridgelines.
Vermont’s ridgelines are the most visually dominant features of our regional landscape. Large commercial wind generation projects are massively out of proportion to any structures currently existing or permitted upon or within Vermont’s high elevation areas.
There can be no question but that the directives and policies of the Windham Regional Plan are designed to preserve and protect fragile high-elevation “Resource Lands” and “Natural and Fragile Areas” and “Scenic Resources” against large-scale commercial development. The Draft Plan makes it very clear that any development within Resource Lands must be of a “low impact, very-low density rural use” without nighttime illumination.
In light of these clear directives, the Regional Plan should include in its “Energy” section a statement making it clear that large-scale commercial wind generation projects are not appropriate for the ridgelines and fragile high elevation areas within the 27 town Commission region because such projects are contrary to the Plan’s intent to protect and preserve ridgelines and fragile high elevation habitats from development.
III. Large-Scale Commercial Wind Generation Projects Should Not Be
Encouraged and Should Not Be Accorded Any Presumption That They Serve the Public Good
In the Draft Plan’s section on Energy, there is an emphasis on promoting the use of renewable energy resources to promote energy diversity, achieve greater reliability in Vermont’s energy supply, reduce energy costs and reduce environmental impacts. The Plan also appropriately recognizes that conservation may present our “greatest—and closest to home—new energy source.” (WRDP at 33-34)
Glebe Mountain Group is concerned that the Draft Plan accords wind energy a level of credibility that has not been demonstrated within the Vermont context. While there is a role for wind power, Glebe Mountain Group believes that individual net-metering projects and small scale community facility oriented generation are more appropriate for Vermont. Technological advances in the development of renewable energy resources will soon allow individuals and small projects to garner the benefits of wind power without the wholesale despoliation of mountain ridgelines. There is language in the Draft Plan that suggests that aesthetic impacts are the primary basis of opposition to such projects. Physical impacts upon visually dramatic ridgelines are but one area of concern. Glebe Mountain Group is opposed to large-scale commercial wind generation projects in Vermont because there has been no demonstration that they will play a significant role in meeting Vermont’s future energy needs, their contribution to reducing emissions is marginal, the real cost per kilowatt hour remains substantially higher than other sources of power , and the area of land disturbance and environmental impacts created by such projects are grossly disproportional to the claimed benefits.
The following points highlight a number of issues and environmental impacts unique to wind generation projects.
• Although wind generation theoretically contributes to the diversification of Vermont’s energy mix, it does not make any substantial contribution to reliability of Vermont’s energy supply. Intermittent power generation is an inherent deficiency common to all wind projects. The region will need to build the same amount of baseload generation to meet grid reserve margin requirements and insure electricity reliability. Overall, the region will have to invest more capital to meet its electric needs with wind in the mix than without wind in the mix.
• Wind generation projects will not replace any baseload generation presently providing power within or to the State of Vermont. Wind power projects can provide energy but not capacity. Utilities must have a baseload generation capacity that they can call upon at any time to satisfy minimum reserve capacity regulatory requirements to meet their load requirement. Wind power production does not obviate the need to build or purchase new power capacity to meet load requirements. As such, wind power is not a reliable energy source and is not a source of energy independence, energy stability or credible “diversity”.
• Wind energy’s environmental “benefit” of reducing emissions has been overstated. Increasingly, the evidence suggests that wind energy’s “net impact” on reducing emissions is marginal because of the need to continue to build baseload capacity to meet demand and to maintain dispatchable resources (normally natural gas generation) on “stand by” when the turbines are online.
• Transportation and coal burning plants of the Midwest are the primary sources of emissions which contribute to a decline in air quality and contribute to acid rain. Vermont wind projects will not address either problem. Power generated within Vermont will never reach the polluting Midwest because of transmission limitations. Additionally, if the Vermont project sells renewable energy credits or “green tags” on the emissions trading market, that will enable a polluting generator to meet its renewable energy regulatory requirements while enabling it to continue operations without achieving any reduction in emissions.
• Wind generation is not a source of peak power because it is not available on demand. The primary source of peaking power is natural gas generation which is responsive on demand. Summer peak demands are likely to occur on calm days when the weather is warmest. Winter peak demands are likely to occur when temperatures are extreme and wind is limited.
• Commercial wind turbine projects have a large footprint and disturb hundreds of acres of land. The projects must be accessed by a service road, which must be kept open 365 days per year. During construction is not uncommon for service roads to have a travel way of at least 35 feet in width. The travel roads must be capable of accommodating massive construction equipment and a 200-400 ton class crane. Current model turbines normally require a 35 foot deep base filled with steel-enforced concrete. Thus, in addition to roadway clearing, there must be extensive excavation and clearing for each turbine and a crane pad at each turbine location. The construction of service roads, installation of turbine bunkers and installation of crane pads will, in many cases, require blasting. Blasting permanently alters the physical features of the resource area and has the potential to disrupt or permanently alter local aquifers.
• Literature and personal experience has documented that turbines are capable of high velocity ice sheers extending several hundred feet from the turbine blades. The project developer may find it necessary to fence off the turbine corridor for security measures and protection of public safety. If a corridor is established along the project array, the project will have potential to restrict public access to hundreds of acres of land.
• Large-scale commercial wind energy projects have high potential to adversely impact wildlife habitat, large and small mammals, and bird and bat populations. Migratory bird collisions have been reported at many wind generation facilities in the United States. Bicknell’s Thrush is listed as a species of special concern in Vermont and is known to prefer high elevation spruce-fir forest habitats such as is found on a number of Vermont ridgelines. Bats may be especially vulnerable to adverse impacts from wind turbines given the results of elevated mortality rates experienced at wind turbine sites located in eastern forested high elevation areas and the low reproductive potential, generally producing only one offspring per year.
• It is not possible to make generalizations about the economic viability of wind generation projects. The economic viability or vulnerability of any wind generation project is site specific and can only be determined on a case by case basis taking into account a number of factors. The net power produced by such projects must take into account the quality, duration, direction and timing of wind resources throughout the year and over the life of the proposed project and the reductions in output due to intermittencies of wind, cold weather, icing, lightening, equipment failures, turbulence and array losses, and transmission losses
• When wind power is compared to other resource options, including energy efficiency measures, the cost associated with development of large-scale commercial wind projects exceed any benefit to Vermont and its residents.
Vermont is the envy of other states who have compromised their beautiful landscapes and irreparably altered natural resource areas through misguided land use and energy policies. Vermont does not have to embrace large-scale wind power projects to show that it is committed to a healthy environment. Vermont can continue to support energy efficiency initiatives, development of renewable energy technologies and promote renewable energy projects on a scale appropriate for Vermont and consistent with preservation and protection of our natural resources.
Glebe Mountain Group respectfully requests the Windham Regional Plan to make a clear statement that large-scale commercial wind energy projects are not appropriate for the ridgelines and fragile high elevation areas within the 27 town Commission region. Alternatively, we request the Regional Plan to expressly recognize that some member towns through their local plans and ordinances may choose to prohibit or limit commercial wind energy projects within their boundaries and that the Regional Commission recognizes and supports their initiatives to do so. 3