The VA SCC issued its final order that conditionally approves the Highland New Wind Development, LLC application to construct and operate a wind energy generating facility in Highland County, Virginia, near the West Virginia border. The proposed facility would consist of up to twenty (20) wind turbines of up to 2.00 MW capacity each. The order included comprehensive monitoring and mitigation for wildlife impacts (bird and bat) and could serve as a model for other projects. One of the commissioners dissented on a provision in the monitoring and mitigation plan.

To reiterate, if the SCC chooses to license this project, we request adherence to the monitoring and mitigation recommendations described in this letter and attachments. In the absence of such conditions, we feel this project would pose an unacceptable risk to the Commonwealth’s wildlife resources.

These comments concern the application of Highland New Wind Development, LLC for a certificate to construct and operate a generating facility in Highland County. They are submitted on behalf of Virginia Wind, a not-for-profit organization addressing the need for effective environmental assessment prior to utility-scale wind development in the western Virginia and central Appalachian region.3 We submit to the Commission that the proposed Highland New Wind Development (HNWD) project presents a risk of unacceptable environmental harm and that the potential benefits of the project are minimal.

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.