A Guide to Commenting on the US Forest Service SDEIS for Deerfield Wind

The public comment period on the Supplemental Draft Environmental Impact Statement (SDEIS) for a Special Use permit from the U.S. Forest Service for Iberdrola‘s 34 MW 2.0 MW Gamesa 400 foot tall wind turbine proposal for US Forest Service Green Mountain National Forest land in Readsboro and Searsburg, commonly referred to as “Deerfield Wind” closes on Friday, March 18, 2011.

The Vermont Public Service Board issued a Certificate of Public Good and Final Order for  7 turbines to be placed on the east side of Route 8 on the same ridgeline as the existing GMP Searsburg wind facility (Eastern Project Area), and 8 turbines along the ridgeline to the west of Route 8 in the northwesterly orientation (Western Project Area).

Eastern ridgeline, existing 197 foot turbines, simulation of proposed 400 foot turbines

The context of the area is extremely rural.  Turbines are proposed to be constructed 1.25 miles from the eastern border of the George D. Aiken Wilderness Area to the west. Several parcels of state forest land  are located to the south in Massachusetts.  Iberdrola has received approval for a second project called the Hoosac project 7 miles south of Deerfield Wind on Bakke Mountain in Florida and Crum Hill in Monroe.

North is to the left on this view of the area, up is east, down is west, south is to the right. The three red lines indicate 1) 1.25 miles to the border of George D. Aiken Wilderness to the west, 2) 4.25 miles from the eastern turbine array to where a photo (referenced below) was taken the on Feb. 23 from inside the wilderness area and 3) Seven miles to Iberdrola’s Hoosac wind project to the south.

Iberdrola has begun site preparation for 20 1.5 MW GE turbines for the Hooosac Wind and expects to have it completed by the end of 2011 or early 2012. The project will include approximately 5 miles of new gravel access roads, 3 miles of buried electrical collection lines and 8 miles of overhead electrical lines. Some of the electric lines will run through the public road system through the Monroe State Forest. More information on the issues can be found in these comments by the Berkshire Regional Planning Commission from 2009.

To assist you in making relevant comments on the Deerfield Wind project to the decision-maker, forest supervisor Colleen Madrid, we are providing information below. At the Open Houses she said that the most useful comments are those that speak to “cause and effect,” as in “if you do x, then y will happen.”

Her decision is appealable to the next higher level, the regional forester located in Milwaukee, Wisconsin.  His decision is final and is not appealable. Only people who file comments will have standing to bring an appeal.

Colleen Madrid has several choices:

Deerfield Wind LLC, has applied for a Special Use Permit to construct and operate a 17-turbine 34 Megawatt commercial wind energy facility on up to 80 acres of Green Mountain National Forest Service Land.  The alternative options are:

A) the Proposed Action consisting of 17 turbines as submitted by Deerfield Wind, LLC;

B) Alternative 1, No Action;

C) Alternative 2, or the Reduced West alternative, a reduction in turbines on the ridge west of Route 8 from 10 to eight (for a total of 15 turbines).  This is the Forest Service’s current preferred alternative;

D) Alternative 3, or the East Side Only alternative, which only includes turbines on the ridge east of Route 8 (for a total of seven turbines).

At the Open Houses held in Rutland and Readsboro, Colleen Madrid said she also has the option to find she does not have sufficient information on which to make a decision.  As outlined below, there is good reason to suggest that the record is insufficient.  Our recommendation will be to defer her decision and request further information. Specifically, we have found that the SDEIS is not the product of an independent evaluation of the issues surrounding the project.

Eastern Ridgeline, view from south

Western Ridgeline looking west

The SDEIS does not comply with Forest Service regulations 36 CFR 251.54(g)(2)(i) which requires that “the Proposed Action must be independently evaluated to determine whether the actions proposed at this site, as presented by the applicant, are consistent with applicable federal law, policy, and the Forest Plan, and can be authorized.”

The SDEIS was prepared by EDR Companies, an environmental consulting firm.  At the US Forest Service Open Houses in Rutland and Readsboro in January 2011, EDR was represented by John Hecklau (resume at p. 48), who USFS employees said was the third party contractor responsible for the preparation of the SDEIS.  In Readsboro, I asked him what other projects he has worked on.  He listed Maple Ridge, Madison Fenner, Cohocton wind projects, and he said he worked for the towns of Ripley and Westfield.  All the projects he listed are in New York.  He said he has never worked for the opposition, only for project developers.

A few days after the Readsboro Open House, an article about Iberdrola’s Groton, New Hampshire Wind project appeared on-line, and at the end of it was a link to the application and filings in the regulatory proceeding for the project.  Appearing on behalf of Iberdrola as an expert witness on aesthetics is John Hecklau of EDR. See page 25 of this prefiled testimony, dated March 2010.

At the same time that John Hecklau of EDR was working as a paid consultant for Iberdrola advocating for the approval of the Groton NH wind project, John Hecklau was preparing the SDEIS for the US Forest Service’s Special Use permit application by Iberdrola for the Deerfield VT wind project.  When asked who he had worked for, Mr. Hecklau did not disclose his paid relationship with Iberdrola on the Groton NH wind project.  John Hecklau’s role as a paid consultant to Iberdrola creates a clear conflict of interest that violates the public’s trust in the independence of the SDEIS.  The Special Use permit should not be issued or denied based on this flawed document.  We recommend the forest supervisor seek an independent contractor who does not have a conflict of interest to prepare a new EIS.

The Independent Contractor lacked fundamental knowledge of the project.

“No Stream Crossings.” I have become increasingly concerned about the impacts these big wind projects can have on headwater streams, so at the Readsboro USFS Open House I asked John Hecklau if there were any stream crossings involved in the Deerfield projects.  He told me there are “no stream crossings.”  I went home and checked the Final Order issued by the PSB. On age 50, it says “Four stream crossings are planned for the Project.”

“No Viewpoints” from the Wilderness. I asked John Hecklau why the SDEIS did not include any simulations or photos of views from the George D. Aiken Wilderness area, the boundary of which is less than 2 miles from the proposed western turbine array.  He said there are “no viewpoints” of the project from the wilderness area. The photo above was taken by photographer John Geery on Feb. 23, 2011 from the location inside the wilderness area 4.25 miles from the ridgeline (as pinpointed on the Google Earth map, above), which is where the eastern turbine array is proposed to be constructed.  There are viewpoints of the ridgeline proposed for wind turbines from deep inside the George D. Aiken Wilderness, but the 3rd party independent contractor who prepared the SDEIS said there are none.

More evidence of bias

Noise

Ken Kaliski

Birds

Curry & Kerlinger

Insufficient Information

George D. Aiken Wilderness

Site Closure and Public Safety Issues Conflict with Public Access.

Need for the project to meet renewable energy goals has not been shown.

To submit comments:

In order to be considered, comments should be provided orally or in writing (phone, facsimile, mail, or email), and received (postmarked or facsimile imprinted) no later than the closing date of the comment period, March 18, 2010. Written comments are preferred. Please make your comments as specific as possible as they relate to the Proposed Action, alternatives, and anticipated impacts of the proposed activities. Please include your name, address, and, if possible, telephone number and email address.

All comments should be sent to: Bob Bayer, Project Coordinator, USDA Forest Service, 2538 Depot Street, Manchester Center, VT 05255 (mail); (802) 362-1251 (facsimile).

Comments submitted electronically via email should be sent to “comments-eastern-green-mt-finger-lakes-manchester@fs.fed.us” (no quotes). Electronic comments should be in TXT, RTF, DOC, PDF or other Microsoft Office-compatible formats, with the Subject titled “Deerfield Wind SDEIS Comments”.

Comments may also be submitted by telephone to 802-362-2307 ext. 218 (voice mail is available) during normal working hours of 8:00 to 4:30.

Comments received in response to this letter, including name and address of those who comment, will be considered part of the public record for this Project and will be available for public review1. If you would like more information concerning the Project or this Invitation to Comment, please contact Bob Bayer at (802) 362-2307 ext. 218 (voice) or rbayer@fs.fed.us (email).

Email comments on the SDEIS will ONLY be accepted to the comments email address in the paragraph above, “comments-eastern-green-mt-finger-lakes-manchester@fs.fed.us” (no quotes), and NOT at the “rbayer@fs.fed.us” email address.


 

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About vermontersforacleanenvironment

VCE's mission is to raise the voices of Vermonters and hold corporations accountable for their impacts on our people, our land, our air and our water. We are united in the belief that Vermont's future lies in conserving its clean, rural, small-town environment. We have joined together to pursue the common goals of encouraging economic development with minimal environmental impacts and preserving Vermont's natural beauty. VCE is committed to providing facts and information so that people can make informed decisions. We encourage your participation.
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