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Mass Audubon Urges Wind Turbine Standards

July 14, 2005

Mr. David Cash, Director of Air Policy
Executive Office of Environmental Affairs
100 Cambridge Street, 9th Floor
Boston, Massachusetts 02114

Re: Wind Turbine Pre-Construction Environmental Reviews and State Siting Guidelines

Dear Mr. Cash:

Mass Audubon appreciates the work you are doing to develop statewide guidelines and/or standards for the siting of wind power projects. As you know, Mass Audubon supports efforts to address climate change, including energy efficiency and conservation as well as the development of renewable energy sources such as wind turbines. A key question is what are the most appropriate locations for wind farm facilities. We are also concerned about the lack of consistently applied standards for what types of pre-construction environmental studies are needed for wind farms. As noted in the attached letters, these issues have been of concern to Mass Audubon for some time now. The concerns expressed in these letters remain unaddressed in large part. The fact that you are undertaking an effort to develop statewide siting guidance is a step in the right direction. Therefore, we are writing this letter to further explain our concerns and to ask again that these issues be addressed in statewide policy, standards, and/or guidance documents as well as through MEPA and permit decisions on specific projects.

While we recognize that the level of pre-construction study needed will vary depending on the location and scale of the particular project, some degree of predictability is nevertheless needed to ensure that environmental impacts and risks are properly evaluated before projects are constructed. In particular, we are concerned that some projects, notably the Hoosac project, have been allowed to proceed without full environmental review through the MEPA process and no avian or bat studies were required. The MEPA Certificate on the Hoosac project reached unfounded conclusions that the project presented little or no risk to wildlife. Given the remote high ridge location of the project within a large unfragmented block of forest, the lack of site specific information on avian or bat activity at the site, and presence of caves in the general area, we continue to believe that pre-construction avian and bat surveys should have been required. The recent avian study at East Mountain in Vermont shows that many birds are below 400 ft AGL when migrating over some high ridge type features¹ . This reinforces our assertion that there is a the need for site-specific studies for potential wind farms on high ridges in Massachusetts, to determine whether similar avian activity exists in locations such as Hoosac.

Meanwhile, the commonwealth is also developing landscape level forest protection and management plans as well as a statewide Comprehensive Wildlife Conservation Strategy. Maintaining large blocks of forest unfragmented by roads and development is an important goal of these other statewide initiatives. Statewide guidelines on wind siting need to take ecological considerations into account and be as consistent as possible with these other planning initiatives.

We realize that some avian studies are being conducted at the Hoosac wind project site, on a voluntary basis and with the assistance of funding from the Massachusetts Technology Collaborative (MTC). Mass Audubon has provided input to MTC on the protocols for these studies, and we appreciate the opportunities provided by EOEA and MTC for us to be involved. Nevertheless, we remain concerned that the studies that are being conducted may not be adequate. The scope of these studies is limited by the amount of funding available from MTC. EnXco may also be doing some additional studies with their own funding, but we remain concerned that the MEPA Certificate did not require wildlife studies. While we recognize that funding and timing will always be constraints in relation to pre-construction studies for wind projects, we do not think that it is appropriate for cost considerations to be the primary driver in evaluating impacts in sensitive ecological settings. The state needs to establish and enforce parameters for adequate pre-construction surveys, particularly for projects in settings like Hoosac (high, remote ridgetop). The cost of environmental studies should be integrated into applicants' financial plans for projects.

In addition to the need to balance cost and environmental considerations in determining what pre-construction surveys are required, there is also another reason standards are needed. As much as possible, studies should be conducted with the same or similar methodologies so that results from one site are comparable to those at another. This is vital for building the baseline information needed to properly evaluate the effects of wind energy development and to ensure consistency and fairness for different projects. In our experience, developers of any type of project prefer well-defined standards that provide predictability in permitting. It is our firm belief that statewide wind siting guidelines and associated pre-construction review standards will facilitate wind energy development by making the siting process more transparent and predictable and will help steer projects to the most appropriate sites.

I hope that you find these comments constructive as you continue to develop draft guidelines for siting of wind projects in Massachusetts. Mass Audubon is willing and eager to continue to advise state agencies on these topics and to work toward establishment of standards that meet the needs of both the wind power industry and environmental protection. Please let me know if you have any questions.

Sincerely,

John J. Clarke
Director of Advocacy