Virginia DEQ proposal of permit by rule for “small” wind farms criticized on many fronts. UPDATED 8/26/10

Challenge to the proposal by Virginia’s Department of Environmental Quality to establish permit(s) by rule for the construction and operation of “small” (100MW or less) wind energy projects is growing.

Joining Rick Webb of VA Wind in criticizing the proposal are several knowledgeable individuals who have made their views known to the Department of Environmental Quality.

For your convenience, we will re-post Mr. Webb’s commentary below, as well as additional comments we received from readers which were sent to the Virginia DEQ.

First, a brief review of the proposal as provided by the VA DEQ:

The purpose of this regulatory action is to implement 2009 state legislation requiring the Department of Environmental Quality to develop one or more permits by rule for wind-energy projects with rated capacity not exceeding 100 megawatts. By means of this legislation, the General Assembly moved permitting authority for these projects from the State Corporation Commission to DEQ. By requiring a “permit by rule,” the legislature is mandating that permit requirements be set forth “up front” within this regulation, rather than being developed on a case-by-case basis. The legislation mandates that the permit by rule include conditions and standards necessary to protect the Commonwealth’s natural resources. The proposal establishes requirements for potential environmental impacts analyses, mitigation plans, facility site planning, public participation, permit fees, inter-agency consultations, compliance and enforcement. The legislation requires DEQ to determine if multiple permits by rule are necessary to address all the renewable-energy media. DEQ determined that multiple permits by rule are necessary. This proposal constitutes DEQ’s permit by rule for wind energy projects.”

Now, the comments:

1 – Rick Webb, VA Wind:

AT Note:

Rick Webb is a Senior Scientist with the Department of Environmental Sciences at the University of Virginia, where his primary research focus is on the effects of air pollution on streams associated with forested mountain watersheds in the central Appalachian Mountain region.  Previously he worked with conservation organizations concerned with the direct environmental effects of coal extraction.  He recently co-authored a Landscape Classification System for Wind Project Siting in Virginia and he presently co-maintains the Virginia Wind Website ( , which addresses the need for environmental assessment prior to wind energy development.  He recently served on a National Research Council committee investigating “Environmental Impacts of Wind Energy.”

2 – Richard Laska, Laska’s Grove:


3 – Arthur W. Dodds, Jr., President, Laurel Mountain Preservation Association, Inc.:

Arthur W. Dodds, Jr., is a professional cartographer who worked for NOAA as a supervisor managing the instrument approach procedures charts for airports throughout the U.S.  His credentials include training and management concerning the heights of objects which could impact flight patterns; electromagnetic field impacts on RADAR; and viewshed analysis.  Mr. Dodds is also certified by the West Virginia DNR as a Master Naturalist.  Mr. Dodds serves as President of the Laurel Mountain Preservation Association.

4 – Pamela C. Dodds, Ph.D., Registered Professional Geologist:

Pamela C. Dodds, Ph.D., is a Registered Professional Geologist who has worked as a geologist/hydrogeologist for the Virginia DOT, Virginia DEQ, and an environmental firm near Bristol, Tennessee.  She has concentrated on groundwater contamination investigations and is currently conducting hydrological investigations in watersheds which will be impacted by industrial-scale wind turbine projects and by extensive high voltage transmission lines.  Dr. Dodds is also certified by the West Virginia DNR as a Master Naturalist.  Mrs. Dodds serves as Treasurer of the Laurel Mountain Preservation Association.

5 – Allegheny Front Alliance:

The Allegheny Front Alliance is a legal state incorporation, organized of local community and regional residents are interested in protecting the Allegheny Front’s cultural and natural environment. We seek to protect the natural scenic resources along the Allegheny Front from the destructive development of industrial wind turbines.

6 – Lucile S. Miller:

Lucile Miller earned a Master of Interdisciplinary Studies with a focus in Environmental Studies in 2002 from Virginia Commonwealth University.  Since 2004 she has focused on the wildlife and water quality impacts of industrial scale wind turbines located on Appalachian ridges.  She has attended meetings where bird and bat experts presented papers on the  the impacts of wind energy facilities and has spoken on the subject to interested groups.

7 – Friends of Beautiful Pendleton County:

The Friends of Beautiful Pendleton County was formed by a group of concerned citizens and property owners in Pendleton County, West Virginia to preserve our rich heritage, protect the priceless natural environment, and ensure that citizens receive responsible, factual information. We have endeavored to determine the possible impacts of the proposed siting of industrial wind energy projects on the pristine ridge tops of the State of West Virginia.

8 – Allegheny Highlands Alliance:

The Allegheny Highlands Alliance (AHA) is a consortium of citizen/environment organizations with membership in five states along the Allegheny Front.  The AHA is in the process of discovering the facts about industrial wind, its potential to reduce green house gases, its economics and the impact of industrial wind energy project installations on the ecology and human health.

The purposes of AHA shall include but not be limited to the following:

(A) To advance public knowledge and understanding of the cultural, biological, environmental diversity, uniqueness, and sensitivity of the major ridgelines that comprise the Allegany Highlands;

(B) To preserve and protect areas of particular scenic, geologic, biologic, historic, wilderness, and/or recreational importance in the Allegheny Highlands;

(C) To aid in the establishment of responsible policies to protect scientific, educational or aesthetic values;

(D) To conduct regional and resource studies as a basis for the wise use of the various resources of the Allegheny Highlands; to develop programs in energy conservation and wise production; and to serve local communities, the region,  the people of the Allegheny Highlands as an agency for popular enlightenment, for cultural improvement, and for scientific advancement;

(E) To advocate governmental policies for the conservation and wise management of energy and natural resources of the Allegheny Highlands.

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1 Response to Virginia DEQ proposal of permit by rule for “small” wind farms criticized on many fronts. UPDATED 8/26/10

  1. Pingback: Virginia DEQ proposal of permit by rule for “small” wind farms … Lamar university

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