The first problem with both the legislation and the proposed regulations is the definition of a "small wind energy project," which is specified as any wind project up to 100?MW rated capacity. By any reasonable definition a 100-MW wind energy project is a "large wind energy project."
A 100?MW project could consist of a string of fifty 500-foot turbines and connecting roads occupying seven miles of mountain ridgeline. Apparently the notion that the Permit-by-Rule (PBR) will apply only to small wind energy projects has provided the rationale, both in the General Assembly and in the DEQ, for the relaxed environmental review and mitigation requirements that the PBR will establish. Despite pretensions to the contrary, the regulations proposed by the DEQ will provide only minimal protection for western Virginia's natural resources from degradation associated with what is, in fact, large?scale industrial development. There is apparently no condiion or potential level of environmental harm that will stop a project from going forward or even require substantial project modification.
My complete comments, which are posted on VaWind.org, have been submitted directly to the DEQ.
