Ganje Memo on Decommissioning

Attorney David Ganje of South Dakota submitted a memo to the state's Legislative Research Council (LRC) that responds to the LRC's recent memo on wind energy. In particular, Attorney Ganje challenges the LRC for not emphasizing the importance of project decommissioning. The introductory letter accompanying the memo is provided below. The full memo can be downloaded from this page. The LCR memo can be accessed here

Subject:  Wind Energy Development Memo // Decommissioning
Date:  August 27th, 2018
From:   David L Ganje, Esq. //
To:  Wenzel J Cummings // Senior Legislative Attorney LRC // 

Mr. Cummings:

On behalf of the Legislative Research Council (LCR) you recently prepared for the legislature a Memo on Wind Energy Development.  This is a significant issue for the state and includes several important points.  One such is the matter of wind project decommissioning.

I have looked at the Memo.  The Memo mentions a requirement “to provide funding for the decommissioning and removal of the wind energy facility.”  No further discussion is advanced in the Memo on the decommissioning question.  I have in the recent past spoken and written on public project decommissioning. I will in this memo outline some of the concerns I have on this matter. I would ask that you review my comments and share this memo with legislative leaders as they consider and review your Memo on the subject.  

Thank you.


Ganje Decommissioning Recommendation Memo

Download file (238 KB) pdf

AUG 27 2018
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