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Wind Energy PEIS Comments

DEFENDERS OF WILDLIFE • CALIFORNIANS FOR WESTERN WILDERNESS • JACKSON HOLE CONSERVATION ALLIANCE • NATURAL RESOURCES DEFENSE COUNCIL • NEW MEXICO WILDLIFE ASSOCIATION • SAN JUAN CITIZENS ALLIANCE • SOUTHERN UTAH WILDERNESS ALLIANCE • THE WILDERNESS SOCIETY • WESTERN RESOURCE ADVOCATES • WYOMING OUTDOOR COUNCIL

December 19, 2003

To:
BLM Wind Energy Programmatic EIS Scoping
Argonne National Laboratory EAD/900
9700 S. Cass Avenue, Argonne, IL 60439

Re: Wind Energy Development Programmatic EIS Scoping Comments

Dear Reviewers:

The undersigned groups support the federal government's commitment to developing a Wind Energy Programmatic Environmental Impact Statement (Wind PEIS) to guide future development of wind energy resources on lands administered by the Bureau of Land Management. In the materials released with the announcement of intent to prepare a Wind PEIS, BLM has done a good job of identifying the major issues.

As the PEIS goes forward, BLM should bear in mind that it is difficult to overstate the importance of continued popular support for wind energy development. At least as much as the economic and technology issues, the future of wind development depends on its continued perception as "green" power with minimal environmental impacts as well as being a renewable energy source. Accordingly, BLM needs to ensure that wind projects are carefully designed and sited to reduce and mitigate impacts, by assuring full public participation throughout the planning process. One poorly sited or designed project with highly publicized negative impacts could give the entire industry a black eye and substantially set back the cause of renewable energy generation from public lands. Therefore, we encourage BLM to err on the side of caution with regard to siting, design and public involvement.

We also encourage BLM to undertake a comprehensive PEIS for natural gas and coal exploration and development on federal lands in the Rocky Mountain States. The impacts from fossil fuel development and power plants are generally greater than those associated with wind, making a compelling case for a broader PEIS. The National Energy Plan's emphasis on natural gas production in the Rockies establishes an urgent need for a PEIS analyzing which combination of energy sources makes the most sense for the West and the nation.

The following scoping comments are offered to guide the preparation of a Draft EIS.

The Interior West possesses an abundance of wind energy potential that can make a significant contribution to the region's electric resource mix. Good wind areas, found on approximately 6% of the land in eleven Western states, could supply more than five times the region's current electricity consumption.¹
Wind resources are a clean energy source and provide an excellent opportunity for the West to reduce its reliance on environmentally harmful fossil fuels such as coal and natural gas.
Wind energy affords the benefit of a cleaner environment because, as opposed to fossil fuel combustion, wind generation and transmission produces no air emissions that endanger public health, results in no greenhouse gas emissions which contribute to global warming, and requires very limited water use.
If developed properly, wind energy has fewer and less significant impacts to land, air, and water than fossil fuel extraction and combustion.
Wind energy offers the opportunity to shift the balance of energy development on public lands from high-impact fossil fuel technologies that create boom-bust economic cycles to lower-impact, sustainable technologies that make lasting economic contributions to local communities.
Properly sited and designed wind energy projects are an appropriate use of some federal lands
Wind energy development should be treated the same as any other proposed use of federal lands, subject to thorough, site-specific analysis and public participation in the planning process as mandated by the National Environmental Policy Act, Federal Land Policy Management Act, Endangered Species Act, Migratory Bird Treaty Act, and other federal law.
Wind energy projects, as with other types of development, are not appropriate for all public lands, such as Wilderness Areas, Wild & Scenic River corridors, Areas of Critical Environmental Concern (ACEC), Wilderness Study Areas, National Monuments, National Landscape Conservation System Units, Native American sacred sites, roadless areas, citizen-proposed wilderness areas, areas BLM recognizes as exhibiting wilderness characteristics, and critical habitat. With respect to visually sensitive areas, VRM Class I and II objectives are, respectively, to "preserve" or "retain" the existing character of the landscape. Siting guidance could be modeled on provisions in the Surface Mining Control and Reclamation Act "designating areas unsuitable for surface coal mining," 30 U.S.C. 1272.²
Wind energy projects should be sited to minimize new road construction for both wind farms and transmission capacity.
Specific resources and impacts that should be considered for individual wind power projects include:
1. Wildlife and wildlife habitat, with special attention to any threatened, endangered or other special status species and essential wildlife migration corridors. Adequate buffers should be provided for certain habitat such as nest locations. Full protection should be accorded to vital winter range which is shrinking across the West.
2. Plants and plant habitat, with special attention to any threatened, endangered or other special status species
3. Avian species (especially migratory birds, raptors and bats) and important flyways and raptor concentration areas. Project siting and design should minimize bird and bat mortality. Projects should be sited to avoid key migration routes. Design of turbines and supports should avoid creating perching opportunities for birds—columns are generally better than lattice towers in this respect.
4. Visual environment, including scenic view-sheds.
5. Noise. To avoid creating a nuisance, decibel levels should be limited to acceptable standards and siting should be an acceptable distance from the nearest residences or recreational use areas.
6. Electro-magnetic interference.
7. Proximity to areas such as and National Parks and Wilderness Areas.
Siting should avoid incompatible land uses. Wind farms are most appropriately located where there are existing compatible land uses, such as agriculture.
Federal wind projects should ensure compliance with local zoning laws and land-use regulations.
New road construction and major improvements (such as paving and widening two-track dirt routes) should be minimized and existing routes relied on where possible. Best management practices on everything from road location to grading and maintenance should be required to minimize erosion, sedimentation of surface waters, forage losses, invasive species and habitat disruption.
Initial site evaluation will be an important aspect of the planning process. Western Resource Advocates has published the Renewable Energy Atlas of the West: A Guide to the Region's Resource Potential (2002, www.energyatlas.org) that provides baseline data and maps showing the potential for wind and other renewables in the West.
Transmission issues are an important aspect of wind energy development. Projects should be sited to take advantage of existing transmission capacity, minimize power loss during transmission, and minimize the construction of new transmission infrastructure. The Renewable Energy Atlas of the West is a useful resource for transmission planning, as it inventories resources in reference to existing infrastructure, such as transmission lines and substations.
Once built, comprehensive monitoring and evaluation will be needed to minimize impacts and improve siting and design of future projects.
Wind energy technologies should be considered with an eye to maximizing power production and minimizing environmental impacts.
The role of wind power in achieving a greater measure of energy self-sufficiency in the West and lesser reliance on imported fuels should be evaluated.
Coal issues. Many new coal-fired power plants have been proposed across the West. The Wind PEIS should include a comparative analysis of the costs and impacts associated with wind vis a vis increasing the region's reliance on coal.
Tradeoffs. Wind energy is a free, renewable resource and a source of clean, non-polluting electricity. The Wind PEIS should include comparative data on wind energy's offset of fossil fuel consumption, the land and water impacts of fossil fuel development, emissions from conventional power plants and greenhouse gases associated with fossil fuels.
Conservation. The PEIS should consider the energy conservation and greenhouse gas potential of each alternative, as required by NEPA implementing regulations at 40 CFR §§ 1502.16 (e), (f).
Multiple Use. Whether BLM is considering wind, oil and gas, coal, or other energy development, the agency needs to heed the letter and spirit of the "multiple-use, sustained yield" and "unnecessary and undue" degradation provisions in the Federal Land Policy Management Act. That means that the level of energy development must be compatible with other uses of the federal lands and healthy functioning ecosystems.
The BLM's notice of intent to prepare a Wind PEIS raises the issue of why BLM has not prepared a regional Natural Gas Programmatic EIS on the impacts of implementing the National Energy Plan on federal lands in the Rocky Mountain States. Most of the reasons that the Wind PEIS is a good idea apply equally or more forcefully to the need for a Natural Gas PEIS:
1. The National Energy Plan targeted selected Resource Management Plans across the region as "Time-Sensitive Plans" requiring urgent revision to facilitate stepped up exploration and development of natural gas.
2. Leasing acres, seismic exploration projects and drilling projects have all surged since BLM began implementing the National Energy Plan in the Rockies. However, BLM has not studied the cumulative impacts of new natural gas activity across the region.
3. Despite the fact that Western watersheds, airsheds and migration corridors do not follow the same administrative boundaries as BLM Resource Areas, BLM has not adequately studied the cumulative impacts of new natural gas policies and projects on a regional or sub-regional basis.
4. BLM and other federal agencies have taken concrete steps to facilitate natural gas development in the Rockies, such as preparing TSPs, promulgating new policies and directives, and forming the inter-agency Rocky Mountain Energy Council.
5. The public was not allowed to participate in the formation of the National Energy Plan and it was never made subject to public review or comment. In fact, the administration continues to oppose efforts to make public government documents associated with the Plan's development.
6. Addressing regional impacts and alternative strategies to meet energy demand at the programmatic level can reduce controversy and analysis when approvingspecific projects.

We appreciate the opportunity to offer scoping comments on the Wind PEIS and look forward to continuing our participation in this important undertaking.

Sincerely,

Mike Chiropolos
Lands Program Director, Western Resource Advocates

Sharon Buccino
Senior Attorney, Natural Resources Defense Council

Michael J. Painter, Coordinator
Californians for Western Wilderness

Tom Darin
Public Lands Director, Jackson Hole Conservation Alliance

Dan Heilig
Executive Director, Wyoming Outdoor Council

Dan Randolph
Oil and Gas Organizer, San Juan Citizens Alliance

Nada Culver
BLM Legal Analyst, The Wilderness Society

Matthew Niemerski
Government Relations Associate, Defenders of Wildlife

Larry Young
Executive Director, Southern Utah Wilderness Alliance

Oscar Simpson
President, New Mexico Wildlife Federation

***

¹Renewable Energy Atlas of the West (at 8)

²The National Academy of Sciences recommended policies to maintain healthy ecosystems and protect wilderness quality lands from oil and gas leasing and development in Land Use Planning and Oil and Gas Leasing on Onshore Federal Lands (1989). Specifically, the NAS study (at 115) recommended that, prior to leasing, other resources should be analyzed to determine whether oil and gas development can be regulated to control its impacts on other values to acceptable levels, with such stipulations as the planning process indicates are required to protect those other values. We urge BLM to adopt these recommendations for its fluid minerals program.

P.S.: The contact information for submitter of this scoping letter is:

Mike Chiropolos
Lands Program Director
Western Resource Advocates
2260 Baseline, Suite 200
Boulder, CO 80302
303 444 1188 x 217, phone; 303 786 8054, fax
mike@westernresources.org

WRA » Land

Wind Energy PEIS Comments

December 19, 2003

Dear Reviewers: