Rick Webb's presentation on October 17 at the Energy Virginia conference provides a thought provoking analysis of the costs and benefits of industrial wind energy.

Virginia Wind (Dan Boone & Rick Webb) has submitted the attached comments (selected extracts appear below) to the Virginia State Corporation Commission (SCC) in response to material filed by and on behalf of Highland New Wind Development (HNWD) purporting to quantify air pollution emission reductions that the Highland County wind project would achieve.

The HNWD submission to the SCC responds to a request from the Virginia Department of Environmental Quality (DEQ) for a "backdown study" to determine potential emissions displacement by identification of electrical generators that will reduce output in response to the HNWD wind project.

The HNWD submission to the SCC makes the extreme and unusual claim that emissions displaced by the proposed HNWD project would be entirely from coal-fueled electrical generating units rather than from a mix of generator types, including the cleaner quick-start units that are generally higher on the economic dispatch order.

The HNWD claim is based on material submitted by Alden Hathaway and Deborah Jacobsen, who are affiliated with the state-supported Virginia Wind Energy Collaborative. Their arguments largely rely on an appended report by the consulting firm Resource Systems Group (RSG), which, in turn, supports its conclusions with summaries of confidential data that are not available to the SCC, the DEQ, or the public.

The RSG report claims similar benefits for proposed wind energy projects in Virginia's Roanoke and Patrick Counties.

Virginia Wind contends that uncritical acceptance of claims and analysis regarding unverifiable benefits would be well outside the norm for either scientific debate or public policy deliberations, especially in a contested case such as this.

Virginia Wind has accordingly requested that the SCC and the DEQ defer any consideration of HNWD's "backdown" study until all of the data that underlie the analysis, including detailed wind power data for the actual project site, are provided and made available for public and agency review. Virginia Wind has also requested an opportunity to provide additional comments once the data necessary for informed review are provided.