AMC Works To Ensure Appropriate Siting
The AMC is committed to promoting clean alternative energy sources to help reduce damage to mountain ecosystems from air pollution and climate change. Wind power releases no air pollutants or greenhouse gases, but its commercial development in the Northeast is not without impacts to some of the very resources we are seeking to protect.
In our region, winds strong enough to support large-scale land-based wind power development are limited to ridgelines, with the strongest winds at higher elevations. These are the least developed parts of our landscape, and are often areas of high ecological, recreational and scenic value. Meeting the region's renewable energy goals could result in the development of many miles of mountain ridgeline. If this development is not carefully sited, the result could be the fragmentation of undeveloped lands, destruction of rare subalpine forest habitat, and the degradation of spectacular scenic vistas.
AMC's Wind Power Policy is included within the club's broader Energy Policies. The policy sets forth AMC's belief that "human actions are accelerating the rate of climate change, and this change poses a serious risk to society and the region's ecosystems. AMC recognizes that wind power and other renewable energy sources must have a substantive role in reducing greenhouse gas and air pollution emissions in our region." The policy sets forth our belief in the need for strong state policies and regulations that set specific criteria for determining suitable sites for development. It also includes guidelines by which AMC will evaluate specific projects.AMC's work on wind power development is guided by the following principles:
AMC is committed to promoting the use of clean alternative energy to reduce air pollution and protect the region's mountain environment from the effects of climate change.
AMC recognizes that commercial wind power development is not without negative impacts on some of the very resources we seek to protect.
AMC seeks to direct wind power development away from ecologically sensitive areas, and encourages state to adopt consistent wind power siting guidelines.
AMC focuses its wind power review efforts on projects with the potential to impact resources of state, regional or national significance.
AMC's perspective on wind power development is also set forth in a
white paper developed in cooperation with other environmental organizations.
AMC works to promote the development of state policies and regulations that address the specific characteristics of wind power development, provide a high level of protection to important natural resources, and guide development to suitable sites. To date our work has been focused in Maine, New Hampshire and Massachusetts.
AMC served as an alternate member of the Governor's Task Force on Wind Power Development. The recommendations of the Task Force were enacted into law in 2008. The new law provided a streamlined permitting path for wind power development in portions of the state deemed most suitable for this development, while retaining existing protection for natural resources. The law also changed the approach to evaluating scenic impacts in recognition of wind power's unique visual aspects, while retaining strong protection for scenic resources of state and national significance.
Since 2008, greater experience with wind power development, combined with changes in both technology and the regulatory environment, have made it clear that improvements to the 2008 law were needed. In recent years AMC has worked with other organizations to enact several improvements to the law, including:
Providing stronger protection to rare high-elevation habitat occupied by Bicknell’s thrush, one of the region’s rarest migratory songbirds.
Requiring the use of “best practical mitigation” to minimize unavoidable impacts from development.
Requiring the consideration of the cumulative impact of multiple projects on important scenic resources.
One major improvement to the law that is still needed is a change in the way visual impacts are considered. The 2008 law limited consideration of visual impacts to a distance of 8 miles from a project. However, since 2008 the size of commercial wind turbines has increased from under 400 feet tall to nearly 600 feet, with even taller turbines likely in the near future. These larger turbines are visible at much greater distances. We have been working and will continue to work with other organization to expand the distance for which visual impacts must be considered in project permitting, at least for the most significant scenic viewpoints such as the Appalachian Trail.
AMC, working in cooperation with the Audubon Society of New Hampshire, convened an ad-hoc group of stakeholders that developed Conceptual Wind Power Siting Guidelines for permitting and siting wind power in the state. The group included representatives of conservation organizations, the wind power industry, state agencies, and municipal interests. The guidelines were presented to the legislatively-established Energy Policy Commission and included in the commission's 2008 final report to the legislature. Since that time AMC has promoted the adoption of these guidelines into official state policy or regulation. In 2013, the legislature passed SB99, which would require the Site Evaluation Committee (which is responsible for permitting major energy projects in the state) to develop specific criteria for the permitting of wind power and other energy projects.
AMC was actively involved with a coalition of other environmental organizations in the rule-making process. The revised rules adopted in 2015 adopted many of our recommendations and provided clearer and stronger guidance to how impacts on natural, scenic and historic resources would be evaluated during permitting decisions
AMC served on the Renewable Energy Siting Task Force, established by the Green Communities Act of 2008. The Task Force drafted legislation that would create a more straightforward permitting process for wind power projects, while directing the state to develop standards for siting projects that are at least as protective of natural resource values as existing state regulations. The legislation has not advanced in the legislature but if enacted AMC will continue to play an active role in the development of the siting standards.
AMC has been a strong advocate for the use of radar-activated lighting (RAL), which would reduce nighttime light pollution by activating the flashing aircraft warning lights only when radar detected an aircraft in the vicinity of a project. In late 2015 the Federal Aviation Administration approved the use of this technology for wind power projects. AMC believes that the use of this technology should be required for all future projects.
Wind power development on public lands is being considered across the region. The Green Mountain National Forest has approved the first proposal for wind power development on any National Forest, and development on state lands has been a topic of considerable discussion, particularly in Massachusetts and Vermont. AMC has been urging public land managers to update and clarify their land management plans to address wind power development, and to conduct comprehensive assessments of their land holdings to determine what areas (if any) could be considered for development without compromising the high level of resource protection expected of public lands.
AMC uses a GIS-based approach to understand the relationship between potential wind power development sites and identified ecological, recreational and scenic resources of state or national significance. The purpose of this research is to understand the potential conflicts between wind power development and important natural resource values across the landscape, and to identify areas of high resource value that are inappropriate for development.
The first approach utilized ridgelines as individual study units. Ridgelines with high wind resource were identified from published wind resource data. These ridgelines were then assessed for the presence of natural resource values such as rare natural vegetation communities, wildlife habitat, roadless areas, steep slopes and hiking trails. The result is a composite resource value for each ridgeline. A pilot study using the Berkshire Mountains of western Massachusetts tested this approach successfully with a stakeholder oversight committee. This approach was then applied to a more thorough analysis of the state of Maine.
This assessment is not the final word on siting wind power. Not all factors that go into siting a wind power project are included in the analysis, and statewide data for some resources is incomplete or unavailable. However, this "first cut" assessment does identify ridgelines or broader mountain regions with known high resource values that make them incompatible with and unsuitable for wind power development. It also provides initial guidance for wind power developers as to which ridgelines have few if any known conflicts with state or nationally significant resources.
AMC and Wind Power (Video)
A Methodology for Assessing Conflicts Between Windpower Development and Other Land Uses ( Berkshire pilot study - AMC Technical Report, PDF, 550 KB)
Assessing Potential Conflicts Between Wind Power Development and Other Land Uses (Poster, PDF, 1.4 MB)
Balancing Windpower Development and Open Space Conservation: An Analytical Approach to Evaluating Potential Conflicts and Promoting Appropriate Siting (Poster presented at the 2006 American Wind Energy Association Annual Meeting, PDF, 1.3 MB)
Ridgeline Wind Power Development in Maine: An Analysis of Potential Natural Resource Conflicts ( AMC Technical Report, PDF, 3.4 MB)
As the next step in this research, AMC is evaluating the conservation status, current condition and ecological value of all areas of high elevation land across New England and New York. Areas above 2700 feet in elevation comprise a small fraction of the regional landscape, but provide critical habitat values and have an important role to play in allowing the region's ecosystems to adapt to future climate change. High-elevation spruce-fir and subalpine forests are recognized in many regional wildlife conservation plans as a distinct and significant habitat. Among other values, this forest type provides the critical habitat for Bicknell's thrush, a species of global conservation concern and the northeast's rarest migratory songbird. Wind power development within high-elevation subalpine forest has been the most controversial ecological issue facing this technology in the region. This research assesses the condition and relative ecological value of high-elevation areas across the region as a guide to future conservation and to better identify unprotected areas of high-elevation habitat that are not suitable for development. A final project report is in preparation.
As part of this work we have developed an on-line Google Earth application (download kmz) that provides extensive information on these areas in a web-accessible map-based format. The application shows all areas above 2700 feet across the region, provides data on the presence of a wide range of identified ecological values within each area, and includes additional data layers on conservation lands, documented and potential subalpine forest occurrences, development and timber harvesting.
High-Elevation Spruce-Fir Forest in the Northern Forest: An Assessment of Ecological Value and Conservation Priorities (Paper submitted to proceedings of 2012 ECANUSA Forest Science Conference)
Subalpine and High-elevation Spruce-fir Forest in the Northeast: An Assessment of Ecological Value and Conservation Priorities (Poster presented at the 2011 Northeast Alpine Research Workshop)
AMC becomes involved in the permitting process for specific projects when they have the potential to impact ecological, recreational or scenic resources of state, regional or national significance that are of high interest to the club and our members, or when permitting decisions will set important precedents for future projects. Over 30 commercial wind power projects have submitted permitting applications across New England. On most projects we have not taken an official position because we felt they were appropriately sited or because the impacts were to resources of primarily local concern. However, we have opposed a small number of projects (in whole or in part) where we felt the impacts to important ecological or scenic resources outweighed the renewable energy benefits.
The region around Cardigan Mountain has become a focus of commercial wind power development. In addition to the existing Groton Wind project (see below), two additional projects are in the permitting or planning stages. These proposed projects would have a very serious impact on the view from the summit, and the cumulative impact of all three projects could be devastating - over 75 turbines visible in a 180 degree arc around one of the state's most significant mountain viewpoints south of the White Mountains. AMC will be closely monitoring these projects and will be actively engaged once they enter the permitting process.
AMC is closely monitoring potential wind power development in a number of areas across the region:
The region around Cardigan Mountain has become a focus for commercial wind power development. One project has been constructed (Groton Wind, see below), one has been proposed but withdrawn (Wild Meadows, see below), one is under active development (Spruce Ridge, see below), and others may be under consideration. These proposed projects would have a very serious impact on the view from the summit, and the cumulative impact on one of the state's most significant mountain viewpoints south of the White Mountains could be devastating. AMC will be closely monitoring these projects and will be actively engaged if and when they enter the permitting process.
This project would be located north of Mount Cardigan on property abutting AMC's Cardigan Reservation. It is in the early planning stages and few details are known. AMC has commented in opposition to the construction of meteorological test towers in both Alexandria and Groton.
One project in this region has been denied a permit (Redington/Black Nubble, see below) and another submitted an application that was subsequently withdrawn (Highland Plantation). However, other projects in the region are under consideration. This area contains some of the most iconic alpine hikes along the entire Appalachian Trail, with potential future impacts on Bigelow Mountain of particular concern.
Two projects are in the early stages of development southwest of Moosehead Lake. AMC has made a considerable investment in this region through its Maine Woods Initiative and we will be tracking these projects to determine if they will adversely affect the scenic character of Maine's most important lake.
One project has been constructed in this region (Granite Reliable, see below). Another is under consideration but is currently constrained by the lack of available transmission capacity. However, approval of the Northern Pass transmission line as currently proposed could open this region to additional development. The primary concern is the potential impact on high-elevation spruce-fir habitat.
AMC opposed this 30 turbine, 90 MW project in the Western High Mountains region of Maine between Saddleback and Sugarloaf mountains, which would have constructed turbines on the only unprotected 4000-foot summit in the state very close to the Appalachian Trail. Our opposition was based on the impact to pristine high-elevation subalpine forest and Bicknell's thrush habitat, one of the largest roadless areas in the state, and the scenic character of one of the most remote and spectacular stretches of the Appalachian Trail. We were joined in opposition by Maine Audubon, the Maine Appalachian Trail Club, the Appalachian Trail Conservancy and the National Park Service. The project application was denied by Maine's Land Use Regulation Commission (LURC).
AMC supported this 44 turbine (132 MW) project in the northern Boundary Mountains of western Maine. While much of the project is located above 2700 feet in elevation, it successfully avoided impact to pristine subalpine forest and Bicknell's thrush habitat. Our support was contingent on negotiation of a mitigation settlement agreement with the developer, under which three higher-value ridgelines in the project area were permanently protected from future wind power development, and funds were provided for conservation of additional high-elevation lands. These funds were used to help conserve the Stowe Mountain tract in the Mahoosucs region of western Maine, which contains portions of the summit of Sunday River Whitecap and the Grafton Loop Trail. AMC was joined in our position by Maine Audubon and the Natural Resources Council of Maine. The project was approved and is operational.
AMC supported this 38 turbine (57 MW) project in eastern Maine. We felt that the project was appropriately sited on a lower elevation ridgeline containing common forest types that had already been heavily impacted by timber harvesting and road construction. The project was approved and is operational.
This 33 turbine (99 MW) project was proposed for four ridges south of Dixville Notch in northern New Hampshire. AMC supported development of the two lower-elevation ridgelines but opposed development of the two higher-elevation ridgelines because of impact to old-growth subalpine forest and habitat for several rare species including Bicknell's thrush and American marten. We were joined in this position by the New Hampshire Department of Fish and Game. AMC and NHFG withdrew our opposition after negotiating a significant mitigation settlement agreement with the applicant that would permanently conserve 1,700 acres of high-elevation land in the project area and provide funding for additional habitat conservation. The project was approved by the New Hampshire Site Evaluation Committee and is operational.
This 15 turbine (45 MW) expansion of the Kibby project was proposed for Sisk Mountain, located to the west of the original project. AMC supported development of the northern half of the project but opposed development of the southern half because of the impact to pristine subalpine forest, Bicknell's thrush habitat and the outstanding scenic quality of the Chain of Ponds. We were joined in this position by Maine Audubon and the Natural Resources Council of Maine. The developer subsequently amended its application, reducing the project to 11 turbines. AMC and its partner organizations opposed the amended project, feeling that it did not sufficiently reduce the project's impacts. However, the smaller project was approved but has not yet been constructed.
This 39 turbine project was proposed for several ridgelines southeast of Bigelow Mountain. AMC intervened in the permitting of this project, and joined with the Maine Appalachian Trail Club and the Appalachian Trail Conservancy to present a common position. We have serious concerns about the impact of parts of the project on the scenic character of a particularly significant portion of the Appalachian Trail. The project application was withdrawn and has not been resubmitted. We are continuing to monitor possible re-emergance of this project.
This 10 turbine (30 MW) project would have been located about 13 miles north of Mount Monadnock. At nearly 500 feet, the turbines were the tallest proposed anywhere in New England at that time. AMC neither supported nor opposed this project, but signed a Memorandum of Agreement with the developer that would have required the project, if approved, to install radar-activated aircraft warning lighting once this technology was approved by the Federal Aviation Administration. (This technology turns the lighting on only when an approaching aircraft is detected, eliminating the need for flashing warning lighting to be constantly on, thus reducing nighttime visual impacts). In February 2013 the New Hampshire Site Evaluation Committee denied a certificate for the project, citing the "undue adverse impact" it would have on the visual character of important natural resources in proximity to the project. A slightly reduced project has been resubmitted and AMC will be monitoring the permitting process to ensure that radar-activated lighting (now approved by the FAA) will be required.
This 17 turbine (34 MW) project was proposed in the southeastern part of the Green Mountain National Forest, just north of the existing earlier generation Searsburg facility. It was the first commercial wind power project in the country proposed for National Forest land. The AMC did not support the full project as proposed because of potential visual impact on the Appalachian Trail, in particular from the summit of Glastenbury Mountain. Our preferred alternative was for a smaller project, and only if the use if radar-activated aircraft warning lighting was required. In 2012 the Forest Service approved a 15 turbine project, and required the use of radar-activated warning lighting after an appeal by the Appalachian Trail Conservancy. This project has not yet been constructed.
This 24 turbine (48 MW) project lies about eight miles north of Cardigan Mountain. AMC took no position on the project but submitted comments regarding the inadequate assessment of the scenic impact on the mountain in the project application. The project was approved by the Site Evaluation Committee and is operational.
This 23 turbine, 76 megawatt (MW) project would have been located southeast of Mount Cardigan. At their closest the 492-foot tall turbines would have been about four miles from the summit of Mount Cardigan, and some would have been visible from open areas adjacent to Cardigan Lodge. The application to the Site Evaluation Committee was submitted in January 2014 but was rejected as incomplete. AMC announced its opposition to this project and its intention to intervene in the SEC permitting process. However, in May 2014 the developer abandoned the project, citing an unfavorable political and regulatory climate in New Hampshire.
This 62-turbine project is located south of the Appalachian Trail in central Maine. The project will be visible from the Moxie Bald Mountain and Pleasant Mountain viewpoints along the AT, but the closest turbines lie beyond the eight-mile limit under which visual impacts can be considered under Maine law. In partnership with the Maine Appalachian Trail Club and the Appalachian Trail Conservancy, AMC reached an agreement under which the developer will voluntary provide mitigation for the project's visual impacts on the AT by funding the conservation of other important AT viewsheds. AMC did not oppose the project, which was approved by the Maine Department of Environmental Protection and is under construction.