After consulting with the American Battlefield Protection Program (ABPP) of the National Park Service regarding the documented boundary of Camp Allegheny Battlefield, Kathleen Kilpatrick, Director of the Virginia Department of Historic Resources (DHR), drafted a letter to John Flora, attorney for Highland New Wind Development (HNWD), on November 17.
Location and Significance of Battlefield Verified
In her letter, Ms. Kilpatrick expresses the Department's concern that the Visual Impact Study prepared for HNWD by the Antares Group "does not take into account the full nature and extent of the impacted resource." As justification, she cites the ABPP's 2009 update to the 1993 Civil War Sites Advisory Commission study, which defines Camp Allegheny Battlefield as including not only the area of the Confederate encampment, gun emplacements and trenches located at the western end of the property, but also the site of the early morning Union attack at the eastern end of the property, in the vicinity of the Varner Cemetery.
Line-of-sight analyses have shown that this area is between one and 1.5 miles from the three closest proposed wind turbines. The following explanation, provided to DHR by the ABPP, vindicates not just Brightside, but all of the historians, archaeologists, and citizens who have continued to insist, despite HNWD statements to the contrary, that this area is indeed an integral part of Camp Allegheny:
"The eastern portion of the Battlefield includes the area where Federal troops first encountered Confederate pickets along the Staunton-Parkersburg Pike, where Federal regiments moved east off the turnpike toward the Varner Cemetery...where they deployed in line of battle at the east end of the broad ridge across the summit (just south of the Varner Cemetery), and the open land over which the Confederates marched to meet the oncoming enemy and upon which heavy fighting occurred for more than two hours."
The first paragraph on page two of Kilpatrick's letter includes the revealing note that DHR actually provided the ABPP-defined geographical boundaries of the Battlefield to HNWD way back in January, 2009, and again in October, at which time DHR requested that HNWD consider the entire Battlefield in their visual impact study. Ms. Kilpatrick confirms that, despite this request, the study HNWD produced focuses only on the central and western portion of the Battlefield, and excludes the eastern portion, which is closest to the wind turbines.
We find the revelation that HNWD has been in possession, since January, of National Park Service information defining Camp Allegheny as including land in the vicinity of the Varner Cemetery very interesting. Despite this knowledge, the company's representatives have stated repeatedly in op-eds, interviews, on-line forums, and even directly to the SCC Hearing Examiner on September 23, that Camp Allegheny is "more than two miles" from the closest wind turbine.
Ms. Kilpatrick further states that the Visual Impact Study provided by HNWD "does lack an appreciation of the resource's integrity, specifically its integrity of location, setting, and feeling, which are particularly relevant when considering battlefield landscapes." She goes on to say: "Our own visit to the Battlefield confirmed a relative lack of modern intrusion on the historic landscape and its ability to convey to the visitor the sense of where, why and how the battle took place."
Adverse Effect of Wind Turbines Confirmed
Finally she concludes: "After consideration of all available information it is our opinion that the HNWD project will have an adverse effect on the Battlefield by diminishing the integrity of the Battlefield's setting and feeling."
In her letter, Ms. Kilpatrick makes only one recommendation: "We recommend further discussions between DHR, HNWD, and affected stakeholders on mitigation strategies to address the project's impact to historic resources."
She states that these efforts should be reasonable and proportionate to the scale of the project, significance of the resource and severity of the impact and should "result in a direct benefit to the Battlefield to offset the adverse impact."