Document
These comments concern the application of Highland New Wind Development, LLC for a certificate to construct and operate a generating facility in Highland County. They are submitted on behalf of Virginia Wind, a not-for-profit organization addressing the need for effective environmental assessment prior to utility-scale wind development in the western Virginia and central Appalachian region.3 We submit to the Commission that the proposed Highland New Wind Development (HNWD) project presents a risk of unacceptable environmental harm and that the potential benefits of the project are minimal.
These comments concern the application of Highland New Wind Development, LLC for a certificate to construct and operate a generating facility in Highland County. They are submitted on behalf of Virginia Wind, a not-for-profit organization addressing the need for effective environmental assessment prior to utility-scale wind development in the western Virginia and central Appalachian region.3 We submit to the Commission that the proposed Highland New Wind Development (HNWD) project presents a risk of unacceptable environmental harm and that the potential benefits of the project are minimal.
• The risk of environmental harm associated with the proposed HNWD project is large and insufficient study has been conducted to allow informed development of mitigation strategies and permit conditions.
• Adherence to FWS guidelines for wind project siting and specific recommendations for the HNWD proposal is clearly warranted based on both the applicant’s environmental studies and natural resource agency review comments. The guidelines and recommendations include: (1) avoidance of bird and bat concentration areas, (2) study of wildlife use over a period of three years and during all seasons, (3) involvement of agency and independent wildlife specialists in all wildlife studies, and (4) evaluation of cumulative impacts of potential regional-scale wind energy development.
• The potential for electricity generation associated with estimated total onshore wind development capacity in Virginia is relatively small compared with current and projected electricity demand, and the potential for electricity generation associated with the proposed HNWD project is insignificant.
• Wind energy development in Virginia’s mountains will not obviate or significantly reduce the need for new power generation facilities to meet the increasing demand for electricity during summertime (when state and regional demand for power is at its highest) because the generation of electricity from industrial wind turbines sited in the Central Appalachian region is minimal and at its lowest level during the summer months.
• The potential for pollution offsets associated with estimated total onshore wind development capacity in Virginia is relatively small compared with total pollutant emissions associated with electricity production in Virginia, and the potential for pollution offsets associated with the proposed HNWD project is insignificant.
