In September, the U.S. Forest Service released its Draft Environmental Impact Statement (DEIS) for the first wind energy project proposed for national forest lands.
Iberdrola's Deerfield Wind application proposes to erect fifteen 2-MW turbines in the Green Mountain National Forest located in southern Vermont. The project site is adjacent to the older Searsburg project erected on private land in 1997.
A review of the DEIS reveals disturbing information regarding the Forest Service's assessment of this project's impacts in the context of the National Environmental Policy Act or NEPA.
The "purpose and need" section appears designed to achieve a predetermined result of siting an industrial wind energy facility on Forest Service land adjacent to the existing Searsburg site. Justifications used for considering the project application include (quoting the document):
- "The Project would provide a reliable and much needed source of power, contributing to long-term cost stability, in a region where the availability of cost-stable resources is quickly diminishing", and
- "The addition of wind energy to the regional electric grid has the benefit of decreasing the emission of harmful air pollutants, and decreasing reliance on natural gas and other fossil fuels."
Neither statement is accurate nor is there any attempt to substantiate these assertions. The Forest Service has no basis for claiming the project will provide "long-term cost stability" given the unpredictability of the wind resource and Iberdrola's inability to secure a long-term power purchase agreement for the energy. Since the New England states are participants in the regional cap and trade program, Regional Greenhouse Gas Initiative or RGGI, the Forest Service cannot claim emissions will decrease should the project be built. Emissions will only be displaced.
In the alternatives analysis, the Forest Service never contemplates an alternative where the project is built on private land, an obvious omission. The only three alternatives provided, including a 'No Build' option, reflect variants of the original. The message is clear -- the Forest Service is committed to seeing this project built here and built now.
But the most offensive aspect of the DEIS document is how it reads more like a repackaging of Iberdrola's application rather than a serious assessment under NEPA in many important topics including aesthetics, economic benefits, impact on wildlife and the natural environment, and safety (ice throw, blade and turbine failure). It appears the Forest Service shamelessly accepted Deerfield Wind's studies, with no apparent attempt to validate the assumptions and conclusions made by the developer on project benefits and impacts.
For example, on Noise impacts, the Forest Service accepts Iberdrola's recommendation that the Project meet a nighttime guideline for protection against sleep disturbance of 45 A-weighted sound pressure levels (dBA) averaged over an eight-hour night at the wall of nearby residences.
By doing so, the Forest Service ignores the growing body of data, detailing the risk of turbine noise in rural communities. WHO recommends that sound levels during nighttime and late evening hours be less than 30 dBA during sleeping periods and that for sounds containing a strong low frequency component (typical of wind turbines), WHO asserts these limits may need to be even lower to avoid health risks. They also recommend that the criteria use dBC frequency weighting instead of dBA for sources with low frequency content.
The Forest Service also fails to note that the International Standards Organization (ISO) in ISO 1996-1971 recommends 25 dBA as the maximum night-time limit for rural communities. Sound levels of 40 dBA and above are only appropriate in suburban communities during the day and urban communities during day and night. There are no communities under this standard where 45 dBA is considered acceptable at night.
It's not possible to determine whether the Forest Service willingly conceded its responsibility to Iberdrola in assessing the impacts of the project or whether it did so out of ignorance, but the outcome is the same.
If the Federal Government is serious about understanding and documenting the impacts of wind energy projects on our National Forests, the American public deserves more. This DEIS cannot be allowed to set a precedent. Windaction.org advises the Forest Service to scrap the Deerfield Wind DEIS and begin again, but this time with a focus on research, not reproduction.
If our readers share these concerns, please take a moment to e-mail your thoughts to the Forest Service. The deadline for comments is Friday, November 28.