The Bingham County Idaho County Commissioners approved a wind proposal involving the construction of 81 miles of road and erecting 150 wind turbines across more than 17,600 acres of Wolverine Canyon. The area is locally designated as a Natural Resource/Agriculture district which, by definition, does not permit industrial, energy-producing, structures. The Commissioners ruled that since the wind energy facility was a "wind farm" it was therefore an agricultural use and thus permitted. The residents in the area filed an appeal with the courts. This document is one of several responsive briefs filed by the residents.