As unjustified as it would be to 'permit by rule' an individual project which could intrude on hundreds of square miles of viewshed, the lack of a reasonable standard for approval of additional nearby permits is irresponsible in the extreme.  The impact upon wind energy resources alone should require that abuttors or nearby landowners be allowed to protect their private property rights, their wind rights, against theft by first comer.  Just as landowners whose land straddles a river do not have the inherent right to dam or divert that river, owners of upwind land have no right to steal wind energy from their neighbors.

In addition, wind resources in Virginia are clearly delineated by the Federal Department of Energy.  If one permit is applied for it is irrational not to expect others to be proposed nearby.  Prior to the approval of any single permit in a particular airshed, an analysis of potential cumulative impacts upon such concerns as natural, economic, historic, aesthetic, environmental and endangered species resources in the vicinity of that airshed is essential.  Without such prior analysis, all of those concerns are rendered without value by the first of what may be multiple permits.  If this permit-by-rule were to take effect without adequate consideration of cumulative impacts, an entire rainbow of concerns, interests and laws would suffer the death of a thousand cuts.  This is not permit-by-rule, it is grand-theft-by-rule.

Please advise the citizens where, in the proposed rule, is the consideration of cumulative impacts delineated?  What intra-agency analyses are required to ensure that potentially applicable State and Federal laws and regulations are not violated?  This appears to be a proposed rule which was rushed into review by an ideologically blinded administration to serve the interests of a few influential power brokers.  The public interest is nowhere to be found in this draft regulation.

In closing, the presumption that industrial wind facilities are of benefit to electricity consumers, taxpayers, the environment or the citizens of Virginia is assumed without any factual evidence whatsoever.  When a rule is propounded, at a minimum it must meet the standard of serving the public interest.  There is no data whatsoever on record to justify issuance of this rule based upon the public interest.  Precisely what public interest would be served by this rule?

There is no legally or scientifically credible rationale for issuance of this importune rule.  Without such rationale, the justification for issuing such a rule is as transparent as the Emperor's New Clothes.  And equally embarassing.