October 23, 2007
Mr. Michael J. Bartlett
United States Department of the Interior
Fish and Wildlife Service
New England Field Office
70 Commercial Street, Suite 30
Concord, NH 03301-5087
Dear Mr. Bartlett:
We represent residents and property owners in Vermont who are very concerned about potential adverse impacts to wetlands, vernal pools, prime bear habitat, birds and bats, and other wildlife, should the proposed UPC Sheffield Wind facility be built. Building seven miles of roads with rights of way 36 -100 feet wide, with fill 18 thick, and blasting for sixteen concrete bases 30 feet deep, on ridge lines above 2000 feet elevation, with wetlands, vernal pools and headwaters that flow both north and south, is unprecedented.
In your January 3, 2007 letter to Mr. Cowan of UPC (see: http://www.windaction.org/documents/7973), you clearly documented areas of concern pertaining to the preconstruction studies conducted by UPC. Expert witness, Professor William Kilpatrick of UVM, also submitted compelling evidence that showed UPC's bird & bat studies were lacking. Despite these criticisms Vermont's Agency of Natural Resources (ANR) supported the UPC project and signed a memorandum of understanding, which we believe was counter to the ANR's own guidelines. The Public Service Board, in turn, accepted UPC's studies as adequate and conditioned that post-construction surveys be done by UPC consultants instead of disinterested third party scientists.
As you know, studies at existing wind facilities located in the east (Mountaineer (WV), Maple Ridge (NY), Meyersdale (PA)), have shown high mortality rates for birds and, especially so, for bats. These studies also suggest even higher mortalities at high elevation ridge lines with wetlands.
Not mentioned in the hearings nor in any developer studies is the fact that ducks, geese, and other water fowl migrate over these ridge lines and stop over in the wetlands in the Sheffield project area. Threatened species of interior forest birds come north to live here for the warmer months. We are very concerned that their habitat and nesting will be severely interrupted. The rotor-swept area of the 316 foot diameter blades is 1.8 acres. The 16 turbines would create a 28.8 acre vertical area linearly aligned along the ridge thus accentuating the opportunity for strikes.
Given the political pressure in Vermont and New England to construct renewable electric generation developments, particularly industrial-scale wind plants, we are concerned that otherwise thoughtful biologists and wildlife experts are being compelled to ignore their best judgment. We encourage you and your colleagues in EPA and the Corps of Engineers to exercise your authorities to the fullest and hope that our state and federal officials will encourage you as well. Existing Vermont laws would normally prohibit this large scale ridge line development. We should not adjust our standards for the sake of "renewable energy"; all of us have an obligation to ensure that sufficient, scientifically legitimate studies are done before permit decisions are made. We thank you for your attention to this very important matter.
On behalf of the below 165 signatories (Signatures collected via online electronic petition. Verification of signatures provided upon request.):
cc: J. Douglas, Governor
P. Leahy, U.S. Senator
B. Sanders, U.S. Senator
P. Welch, U.S. Representative
J. Austin, VTDF&W
F. Hammond VTDF&W
S. Darling VTDF&W
C Gjessing VTANR
M. Adams, COE, Reg. Div. VT Ofc
A. Hoar, RP/ES
T. Sullivan, NYFO
A. Manville, WO/MB
P. Bosco, FWS/LE
D. Rothstein, Sol. Office, RO
1) UPC Wind was notified in August 2007 that the project was not eligible for authorization under the VT General Permit, and must be reviewed under the individual permit review procedure. See http://www.windaction.org/documents/12335.
2) Signatures collected via online petition (http://www.petition.com).