POSITION STATEMENT ON WIND ENERGY DEVELOPMENT  

State and Federal Regulators have required a complete Environmental Impact Report (EIR) and bird surveys for a project proposed in Nantucket Sound while sites in the Berkshires have been given approval with no EIR, no planning, and no meaningful bird studies.  

Berkshire Natural Resources Council calls for the creation of a statewide siting plan and a consistent permitting process prior to the development of Wind Energy in Massachusetts.  From Nantucket Sound to Berkshire County there must be a consistent policy regarding Wind Power Facilities that establishes consistent standards for Site Selection, Environmental Review, and Stewardship. 

While recognizing the global imperative to reduce carbon emissions, and the role that wind power generation may play in this goal, Berkshire Natural Resources Council can not support wind energy development that fails to meet high standards for environmental review, production efficiency and long-term economic sustainability.

Site Selection

1. Land held for conservation purposes, public or private, should not be considered for Wind Energy Development.
2. A statewide plan for siting wind energy should be developed, with public input, covering development of wind energy over the next five to ten years.  The resulting plan should identify areas where the wind energy is commercially viable in the long-term and environmental impacts are minimized. 3.      Standard siting criteria should be developed for evaluating the site-specific environmental impacts such as roads, ridge clearing, and stream crossings, of projects within the statewide plan.  

Environmental Review

1. All potential sites for Wind Energy development in the Berkshires and throughout the Commonwealth should be contingent on MEPA review, the completion of an Environmental Impact Report (EIR), and other studies.
2. Pre-construction surveys should be required to document the site’s flora and presence/absence of birds, bats and other fauna.  Post-construction monitoring should be required to document bird and bat mortality and other ecological impacts.

  Decommissioning

1. Establish standards for the decommissioning of non-operative facilities (eg. gating roads, planting trees, grass, and shrubs and removing culverts).
2. Financial security sufficient to meet the established decommissioning standard should be built into the development costs and set aside to ensure they will be removed when the facility reaches the end of its useful life.
3. Establish statewide standards for identifying non-operative or “mothballed” facilities in order to start decommissioning.

  Federal and State Policy of Tax Credits & Renewable Portfolio Standards An economically stable approach should be used to encourage the development of wind power.  BNRC is concerned that “Boom and Bust” development will occur under the current system of Renewable Portfolio Standards (RPS) and Federal Tax Credits. Large energy corporations, such as FPL Group, are in a financial position to take advantage of the established tax incentives.  To realize these credits they will target sites where there is little opposition regardless of environmental degradation or availability of the best wind resource.  However, Wind Energy is being promoted as a viable source of renewable energy with little environmental impact and therefore site selection should be directed to areas with the greatest wind potential and the least negative impact.  Under the current system, BNRC is concerned that there is potential for ridgeline sites in the Berkshires to be abandoned once tax advantages have been realized and equipment begins to fail.  If the sites have only moderate production capacity and have high maintenance costs there will be little incentive to maintain the facilities.  Berkshire County residents will be left with hollow promises and large roads inviting residential development up some of our last pristine ridges. Tax credits and Renewable Portfolio Standards can provide the incentive to build facilities quickly; BNRC wants the facilities sited and built judiciously.    

Draft Position Statement prepared by Narain Schroeder, April 14, 2005. Approved by the BNRC Board of Directors April 15, 2005