Individual members of the grassroots group Ridge Protectors Inc., filed an appeal in Vermont's Environmental Court arguing that more ground would be disturbed by the Sheffield wind facility than was approved in the storm water discharge permit issued by the State's Agency of Natural Resources (ANR). The wind developer, First Wind has been approved by the Vermont Public Service Board to erect sixteen 2.5 megawatt wind turbines along a ridgeline in Sheffield, Vermont. The final brief filed by the Ridge Protector appellants can be accessed by clicking on the link at the bottom of this page. An excerpt of the brief is posted below.

Abstract: The allure of an environmentally benign, abundant, and cost-effective energy source has led an increasing number of industrialized countries to back public financing of renewable energies. Germany’s experience with renewable energy promotion is often cited as a model to be replicated elsewhere, being based on a combination of far-reaching energy and environmental laws that stretch back nearly two decades. This paper critically reviews the current centerpiece of this effort, the Renewable Energy Sources Act (EEG), focusing on its costs and the associated implications for job creation and climate protection. We argue that German renewable energy policy, and in particular the adopted feed-in tariff scheme, has failed to harness the market incentives needed to ensure a viable and cost-effective introduction of renewable energies into the country’s energy portfolio. To the contrary, the government’s support mechanisms have in many respects subverted these incentives, resulting in massive expenditures that show little long-term promise for stimulating the economy, protecting the environment, or increasing energy security. In the case of photovoltaics, Germany’s subsidization regime has reached a level that by far exceeds average wages, with per-worker subsidies as high as 175,000 € (US $ 240,000)

E.ON Netz GmbH manages 7600 megawatts of wind generation in Germany, representing 41% of the installed capacity for wind in the country. According to this report, wind operated at 18% capacity on average, with the lowest generation of 8 megawatts occurring in May 2005.

The November passage of Initiative 937 adds Washington to the states with renewable portfolio standards. Wind-powered generation is a resource of choice in meeting renewable standards, and it has been highly touted for its environmental benefits. Considered in isolation, the environmental benefits of a wind resource are undoubtedly warranted. However, it is misleading to consider wind on an isolated basis—that is, outside of the context of the full power-supply portfolio that is necessary to serve load. In the context of an integrated portfolio, much of the environmental benefit disappears and may even be non-existent as compared with other resource portfolio choices. In particular, a full assessment of the impact of wind resources on the environment necessitates a look at the energy consequences of adding wind-generation to an integrated portfolio in the context of meeting load. Accounting for energy, it is likely that there is no significant environmental difference between a resource portfolio adding wind generation and one adding high-efficiency combined-cycle gas turbines. It is also likely that the wind-based portfolio results in little reduction, if any, in the need for fossil fuels and therefore little reduction in the exposure to their price swings and environmental consequences. That is, the emissions and fossil-fuel impacts of a wind-based portfolio appear little better than a non-wind-based portfolio.

Editor's Note: This paper makes a critically important point re. wind's purported environmental benefits, i.e. "...it is misleading to consider wind on an isolated basis—that is, outside of the context of the full power-supply portfolio that is necessary to serve load. In the context of an integrated portfolio, much of the environmental benefit disappears and may even be non-existent as compared with other resource portfolio choices." In short, wind's environmental benefits (if any) will be grid-specific depending on the emissions generated (if any) of the reliable generating source(s) required to back it up.

California is in the process of implementing a broad portfolio of policies and regulations aimed at reducing greenhouse gas emissions. This paper summarizes the initiatives likely to impact the electricity generating sector. We present calculations showing that there is a substantial risk that two of the most prominent policies could simply result in a reshuffling, on paper, of the electricity generating resources within the West that are dedicated to serving California. This reshuffling is different from the conventional leakage problem as it involves no physical changes to the way electricity is generated across regulated and unregulated regions, but is instead driven by a contractual reshuffling of who buys power from whom. The problem is similar to an ineffective consumer boycott. The problem is still present but less severe if more Western states adopt carbon limitations. We also show that some of the least market-based initiatives, the renewable portfolio standards (RPS), are likely to have the biggest near-term impact on the carbon-intensity of electricity generation in the West. Thus the scale of RPS programs may be limiting the potential role of non-renewable options in reducing carbon emissions from the electricity sector.

An indictment of the Scottish Executive and regulatory incompetence and indifference......‘One is left with a clear impression of inertia, bungling, duplicity, poor communication, procrastination, obfuscation and, quite frankly, shoddy and incorrect decision-taking both in temporal and technical terms'.

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.

Rube Goldberg would admire the utter purity of the pretensions of wind technology in pursuit of a safer modern world, claiming to be saving the environment while wreaking havoc upon it. But even he might be astonished by the spin of wind industry spokesmen. Consider the comments made by the American Wind Industry Association.s Christina Real de Azua in the wake of the virtual nonperformance of California.s more than 13,000 wind turbines in mitigating the electricity crisis precipitated by last July.s .heat storm.. .You really don.t count on wind energy as capacity,. she said. .It is different from other technologies because it can.t be dispatched.. (84) The press reported her comments solemnly without question, without even a risible chortle. Because they perceive time to be running out on fossil fuels, and the lure of non-polluting wind power is so seductive, otherwise sensible people are promoting it at any cost, without investigating potential negative consequences-- and with no apparent knowledge of even recent environmental history or grid operations.

Eventually, the pedal of wishful thinking and political demagoguery will meet the renitent metal of reality in the form of the Second Law of Thermodynamics (85) and public resistance, as it has in Denmark and Germany. Ironically, support for industrial wind energy because of a desire for reductions in fossil-fueled power and their polluting emissions leads ineluctably to nuclear power, particularly under pressure of relentlessly increasing demand for reliable electricity. Environmentalists who demand dependable power generation at minimum environmental risk should take care about what they wish for, more aware that, with Rube Goldberg machines, the desired outcome is unlikely to be achieved. Subsidies given to industrial wind technology divert resources that could otherwise support effective measures, while uninformed rhetoric on its behalf distracts from the discourse.and political action-- necessary for achieving more enlightened policy.

Today, we adopt an interim greenhouse gas (GHG) emissions performance standard for new long-term financial commitments to baseload generation undertaken by all load-serving entities (LSEs), consistent with the requirements and definitions of Senate Bill (SB) 1368 (Stats. 2006, ch. 598).2 Our adopted emissions performance standard or “EPS” is intended to serve as a near-term bridge until an enforceable load-based GHG emissions limit is established and in operation.......
Under SB 1368, the EPS applies to “baseload generation,” but the requirement to comply with it is triggered only if there is a “long-term financial commitment” by an LSE. The statute defines baseload generation as “electricity generation from a powerplant that is designed and intended to provide electricity at an annualized plant capacity factor of at least 60%..........
Pursuant to SB 1368, the performance level of the EPS must be “no higher” than the emissions rate of a CCGT powerplant.11 However, the statute does not specify the emissions rate for a CCGT. Based on our review of emissions rates associated with a broad range of CCGT powerplants of varying vintages, we adopt an EPS emissions rate of 1,000 pounds of carbon dioxide (CO2) per megawatt-hour (MWh).

Editor's Note: This provides interesting insight into the rationale behind establishing 1,000 pds of CO2/MWh as an Emissions Performance Standard (EPS) for baseload generation. Please note that in Figure 1 "Net Emissions Comparison Data' the net emissions accorded 'wind electricity' should have been accorded to 'solar thermal with Gas Assist'.