Wind is a renewable, clean energy source that will be an important factor in the replacement of carbon-emitting energy sources in the United States and elsewhere. New Hampshire's hill and mountain topography and its flat but limited, densely populated seacoast area, however, are relatively unsuitable for the development of significant wind power facilities in comparison to other parts of the nation. Thus, New Hampshire provides few suitable locations for wind farms.
The New Hampshire Legislature has mandated that electricity providers include a substantial proportion of wind energy in their generation portfolios and the Governor has announced a similar goal. New Hampshire has no comprehensive policy for implementing this goal and Federal guidelines for wind energy development do not address New England's particular conditions.
A stakeholder group developed Proposed Windpower Siting Guidelines for New Hampshire, which were forwarded to the NH Energy Policy Committee Wind Siting Subcommittee in 2007. However, as of the date of this policy statement these have not been formally adopted nor implemented. New Hampshire Audubon is particularly concerned about impacts of wind development on high elevation habitats and potential mortality of migrating birds and bats.
Statement of Policy
New Hampshire Audubon will review wind power projects proposed within the State, wherever located, with particular attention to their proper siting. Audubon will be especially involved where its interests, including abutting property, species of special interest, Important Bird Areas, major migration flyways and habitats of critical importance could be jeopardized. NH Audubon strongly urges:
• that developers and operators of wind power facilities and the New Hampshire Site Evaluation Committee and other permitting authorities to be guided by the American Bird Conservancy's Policy Statement on Wind Energy and Bird-Smart Wind Guidelines, many of whose specific points are found or paralleled below.
• that pre-construction bird, bat and other wildlife studies be conducted by independent organizations using accepted scientific protocols, including the collection of adequate data over multiple seasons and for at least three years, and that these data be publicly available.
• that operation of wind facilities will minimize impacts on wildlife and wildlife habitat through adoption of new technologies and operating procedures, such as advanced blade design and facility lighting, burial of transmission lines and seasonal or time of day restrictions that minimize the risk to migrating and resident birds and bats. Furthermore, it will urge that post-construction monitoring for bird and bat mortality be conducted following appropriate scientific protocols.
• that there will be mitigation of facility development and impacts on the environment through the permanent legal protection of the site and available undeveloped property in the vicinity to assure that road access does not result in future residential or commercial development of the site and its approaches. It further expects the developer to give legal assurance through bonding or otherwise that upon abandonment of the facility for any reason all structures shall be removed and the site returned as close as possible to its original state.
As warranted by the relevant criteria cited above and in the following Environmental Criteria for Evaluating Individual Wind Power Projects, New Hampshire Audubon will apply for intervenor status when appropriate and submit written testimony and/or appear at public hearings to express its concerns or request modification of plans to meet those concerns. NH Audubon may consider opposition to a project whose negative aspects as defined by these criteria are such that modification of plans would be insufficient or where it perceives that critical aspects of the plan are unlikely to be addressed. Audubon will cooperate with partner organizations to the extent possible, keeping in mind that the effects on wildlife and wildlife habitat are its paramount consideration.
NH Audubon staff will review and prepare recommendations to oppose or not oppose a project, or to propose modifications. It will review these recommendations with the Environmental Policy Committee, which will forward staff recommendations to the Board of Trustees for approval.
Environmental Criteria for Evaluating Individual Wind Power Projects
1. What is known about raptor migration in the project area?
2. What is known about passerine migration in the project area?
3. What is known about waterbird migration in the project area?
4. What is known about bat migration in the project area?
5. How do these migration data compare with that from other sites in the State and region
6. What proportion of what habitat types will the project adversely effect in the ecoregion and town(s) in which the project is located?
7. Will the project affect habitat for Federal- or State-listed endangered or threatened plant or animal species or other species of conservation concern?
8. What fragmenting effects will the turbine string and associated roads and transmission corridors have on existing blocks of unfragmented forest lands, wetlands, open fields and stream corridors?
9. Do proposed pre-construction studies and proposed post-construction monitoring programs follow accepted scientific protocols and are they adequate in scope and time?
10. Does the lighting plan reflect Federal Aviation Administration requirements and does it minimize risk to migrating birds?
11. Does the operational plan provide for suspending operations during high risk periods for migrating bats and/or birds?
12. Does the construction schedule avoid land clearing, terrain alteration and road-building activities during key periods in the annual cycles of wildlife, such as bird nesting periods?
13. Are safeguards in place to prevent other types of ridge-top development if the project is decommissioned in the future?
14. What is the extent of terrain alteration required for road-building and turbine placement?
15. Does the application include a stormwater management plan?
16. What is the plan for wildfire response?
17. What concerns do state and federal wildlife biologists have regarding this project?
18. Where are the nearest wildlife sanctuaries and management areas?
19. Have provisions been made for permanent protection of the site and adjacent properties?
20. What is the plan for decommissioning the proposed facilities at the end of their useful life or upon abandonment for financial, economic or other reasons?
21. What is the project's anticipated contribution to the region's renewable energy supply or the reduction in greenhouse gas emissions?