Virginia Regulatory Town Hall
Department of Environmental Quality
Department of Environmental Quality
Small Renewable Wind Energy Projects Permit by Rule [9 VAC 15 ‑ 40]
Action Establishment of permit(s) by rule for the construction and operation of small wind energy projects
Stage Proposed
Comment Period Ended on 8/20/2010
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8/20/10  10:02 pm
Commenter: JD



JD - Roanoke
The regulation will raise the cost of energy in Virginia. The subsidizing of the energy also increases each citizens’ tax burden (we each pay a part of the turbines). Neither issue is mentioned in the economic impact statements. Because wind power is not cost-efficient, it is subsidized - Europe is backing out of the subsidy game now because they simply can’t afford it any longer.  VA citizens can’t afford it either. Learn from these other formerly wind crazed countries.
The scientific basis for claiming that carbon emissions will be reduced by stripping miles of mountaintops must be quantified – as it appears to be some basis of the regulation. 
Less than 1 percent of U.S. electricity generation comes from oil, whether foreign or domestic. Wind will not replace carbon-based fuels because the wind does not blow when we need it and when it does blow we don’t need it. It is terribly inefficient in the mountains. The gross inefficiency must be considered against the amount of environmental impact involved for each PBR – over five miles of ridgeline for each project! 
The wind investors will profit nicely from the selling off of the Blue Ridge and other valuable mountaintop resources, yet the folks living in VA mountains will face the prospect of loosing 25% of their property values. The continual economic survival of rural communities depends on the concept of rural life and unspoiled countryside, away from the commercial and industrial development that is characteristic of our towns and cities. The devaluation of assets such as property by rural industrialization will inevitably reduce new economic injection into these areas. Allowing the proliferation of these industrial developments will likely trigger a slide back into rural economic deprivation as the lifetime savings of people living in these communities are eroded by the devaluation of their properties.
These are economic impacts. The impression that the regulation leaves is that there are no negative economic impacts. Its just not true.
The negative impacts on views, which are fundamental to Virginia tourism (its second largest economic sector) will be FOREEVER changed – making this permit unlike any other permit that the DEQ issues – it will permit the loss of the Blue Ridge, the Shenandoah, the Alleghany Mountains. What do we say when its gone? Crowned with these everlasting monuments to human gullibility. DEQ should require cleaner emissions from coal plants, and not struggle against itself to protect VAs resources by plundering the mountains. A vital part of Virginia will be lost forever for no meaningful gains. The desire of the wind industry (which were on the RAP) was to minimize the review of the impact of any site, but the DEQ must expose each project to a more reasonable assessment, not the narrow overview as proposed by the PBR. The distance of the scenic resource impacts must be expanded. Also, the loss of property values associated with view should also be determined as a component of each PBR application. This assessment must be available for public comment. 
Destroying miles of the Blue Ridge and other of our treasured ridges, lose ‘our’ Blue Ridge Parkway overlooks, have our electric bills go up, and pay increased taxes to subsidize it all is like throwing away the baby with the bathwater. One turbine complex in Roanoke Co. is proposed on the very mountain for which the adjacent Blue Ridge Parkway overlook is named and is the prominent feature. This is a ‘shortsighted’ regulation, which should not allow for these losses to such resources.   The regulation should actually require applicants to determine impacts to the BRPW and all other scenic assets at a range that reflects the view – which happens to be well over the 5 miles in the mountains, which all the regulation sees.   The DEQ will permit by rule the degradation of the Blue Ridge Mountain ridges, and then the Shenandoah, and all over VA mountains without any meaningful protections. To ignore the overall economic impact of these costs is irresponsible. The governor’s office should conduct an economic evaluation of the PBR claims.
Onsite evaluation of wildlife and plant communities should also be required. Desktop surveys have disclaimers – read them. The allowance to review impacts two miles away is not reasonable. Some of VA’s rarest treasures live in these remote mountains slated for the dynamite and bulldozers, and two miles away from an impacted site could completely miss relevant impacts to already threatened species. The “or” should read “and”.   
Community Health Impacts
Community concerns about health, safety, impacts on all wildlife and other natural resources (not just a select few), deserve to be considered in this process. These projects impact local communities. Many rural residents and communities will be exposed to a doubling of the background noise at nights. Some people are very sensitive to the low frequency noise, emitted from turbines - and suffer from sleep depravation and symptoms akin to sea-sickness as a result of living too close. Some assessment of the noise impacts to the folks living near these turbines should be required upfront.
Other comments:
Note that the recent PBR for composting is must more protective of the public health and safety – it can be done. The ‘Tiered’ approach was also wise. Has DEQ considered a tiered approach to differentiate between turbine complexes of 10 & 100 MW – because it involves the difference of several miles of impact? 
The ‘stringing’ of PBR sites – how is that dealt with? I can see that many PBR strung together would not receive any cumulative impact reviews. Are future wind development allowed within a contiguous line if they are submitted separately?
The PBR applicant should be required to assess all local community impacts to television, radar systems, air travel, etc, prior to considering coverage under PBR.
This was not a good piece of legislation that was handed to DEQ, but that doesn’t mean DEQ should go ‘light’ on its oversight on the siting, construction, and operation of these industrial complexes.  
CommentID: 14366