Carolina Mountain Club Position
Wind Energy, Proposed Forest Service Directives January, 2008
The Carolina Mountain Club supports capturing wind energy on National Forest Service lands. As stewards of our national forests, the Forest Service must uphold its mission to protect our public natural resources while managing wind resources optimally. The implementation of wind energy technologies on public lands must not compromise the recreational, health, spiritual, and economic benefits of our natural environment. Unless strong protections are established for the siting of wind turbines on public lands, erection and maintenance of the turbines and necessary roads and transmission lines could have serious and permanent impacts on limited and irreplaceable public natural treasures. There are large, untapped opportunities for reducing the use of fossil fuels that do not involve the unavoidable, permanent environmental damage to these irreplaceable natural treasures. Specifically, Wind turbines and necessary roads and transmission lines are essentially permanent facilities. The Forest Service must, therefore, use extra care before approving wind projects as special uses. The Forest Service must require thorough site-specific analysis and it must include public participation, with a 90-day comment period, in every project.
CMC requests that all wind energy permits mandate monitoring requirements of individual facilities, and require mitigation measures should monitoring reveal significant impact to natural resources. Processes and funding should be required in all projects to do this and to remove turbines after their useful lives. Wind projects should not impact special places that have exceptional biological, scenic, recreational, and tourism attributes. These include: Wilderness and Wilderness Study Areas; proposed wilderness, recreation, and scenic areas; National and State Parks; significant historic and cultural sites; Inventoried Roadless Areas; long distance trails, such as the Appalachian Trail, and North Carolina Mountains-to-Sea Trail and Art Loeb Trail; and Mountain Treasures as recognized by The Wilderness Society.
CMC opposes the conversion of any USFS-designated hiking trails into service roads for wind energy projects, with special consideration given to Western North Carolina’s signature hiking trails, such as the Appalachian Trail, Mountains-to-Sea Trail, Art Loeb Trail, and others. CMC opposes dual designation for these trails. The Forest Service must manage the capture of wind energy proactively so that optimal locations for wind projects are chosen. For example, locating wind turbines in areas that can also support concentrating solar technologies may minimize overall environmental impacts while reducing costs. When siting wind projects, the USFS should consider how noise, lighting, and dust would affect recreational use, especially hiking. Where USFS proposed language aims to restrict wind energy project noise levels to 10 decibels above background noise levels “when possible”, CMC favors a mandatory restriction not to exceed 10 decibels above background levels. Environmental Assessments and Environmental Impact Statements must be required for all projects, and no wind-related activities can be Categorically Excluded.
The Energy Policy Act of 2005 requires that the Department of the Interior approve projects on public lands with the capacity to generate at least 10,000 megawatts of electricity from non-hydropower renewable energy. DOI has until 2015 to do this. The National Forest Service has issued a proposed directive related to wind energy that supplements existing directives for special use projects on National Forest Service land. Public comment is invited by January 23. Our calculations show that about 5000 wind turbines would be needed to generate 10,000 megawatts, which represents about 0.66% (less than one percent) of projected 2008 US electricity usage. Unless strong protections are established for the siting of wind turbines on public lands, erection and maintenance of the turbines and necessary roads and transmission lines could have serious and permanent impacts on limited and irreplaceable public natural treasures. There are large, untapped opportunities for reducing the use of fossil fuels that do not involve the unavoidable, permanent environmental damage to irreplaceable natural treasures caused by the erection, operation and maintenance of wind turbines. Use of more efficient light bulbs is one of the provisions of the federal energy bill recently signed into law. Switching to more efficient bulbs will eliminate the need for about 60 mid-sized power plants. As the worldwide demand for more efficient energy increases, new technologies will be developed. We found information on several possibilities without trying. The January, 2008 issue of “Scientific American” contains an article on a “Solar Grand Plan” to supply 69 percent of U.S. electricity demand with solar energy by 2050. The January 2, 2008 Wall Street Journal has an article about a joint venture to commercialize a new, proven type of solar-power plant that uses molten salt to store the sun’s heat so it can be converted to electricity when the sun isn’t shining.
For more information:
Federal Register notice and longer texts of the proposed changes:
National Renewable Energy Laboratory publications:
“Assessing the Potential for Renewable Energy on National Forest System Lands"
Energy consumption data