Approved by Conservation Programs Committee 6/13/96, Revised 12/07/06
AMC's position on windpower has been developed in light of our mission statement:
"The AMC supports the protection, enjoyment, and wise use of the mountains, rivers, and trails of the Northeast. "
AMC’s position has also been developed in coordination with other approved AMC policies. Since many potential sites for large commercial windpower facilities are located in the Northern Forest, the siting of windpower facilities should avoid or minimize compromising the first two goals outlined in AMC’s "Summary of Northern Forest Lands Policy and Strategy” (April 7, 1991):
- "Conserve the integrity of the Northern Forest Lands as a vast, unfragmented natural resource."
- "Sustain and protect ecologically vigorous, healthy, and diverse ecosystems."
AMC’s Energy Policy (adopted November 30, 2005) directs the organization to:
- "selectively engage in those components of the energy issue where the nexus is strong with AMC’s mission and strengths, and where AMC can make a meaningful contribution.”
- “support significant increases in renewable energy that results in actual greenhouse gas and air pollutant reductions and is balanced with strong protection of natural and recreational resources of statewide, regional or national significance.”
- “develop wind power siting policies at the state level, based on landscape constraint analysis that locates wind power development to sites that contain few to no recognized natural and recreational resources of statewide, regional or national significance.”
The following general principles will guide AMC’s decisions about future windpower projects:
- The AMC believes 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 windpower and other renewable energy sources must have a substantive role in reducing greenhouse gas and air pollution emissions in our region.
- The AMC posits that state policies or regulations specific to windpower are needed. Unlike most other technologies, siting of windpower is constrained by the need for an adequate wind resource, much of which is located in undeveloped areas of potentially high ecological, recreational and/or scenic value. State windpower policies or regulations should provide for an assessment of cumulative impacts, mitigation for impacts, set specific criteria for determining suitable sites, and implement appropriate regulations for windpower development, permitting, operation and decommissioning. They should assure that an appropriate balance between the development of windpower and protection of higher-elevation areas and associated resource values is maintained, and provide strong direction as to which sites will be considered suitable or less suitable for windpower development. Effective state policies or regulations should also reduce project siting conflicts and permitting delays and provide more certainty to windpower developers in the regulatory process. The AMC reserves the right to decline to support any project that does not take place in the context of an adequate and official state windpower siting policy, or where proposed mitigation does not include provisions for the protection of mountainous areas of equal or greater value as a condition for permitting.
- Windpower projects should lead to a verifiable replacement of electrical generation from dirtier fossil fuel power sources within the project’s service region. They should not just provide for cheaper power or replace other renewables or pollution reductions derived from conservation or demand side management programs.
- Projects should include provisions to provide for decommissioning if the project is no longer producing power (including rehabilitation of roads and revegetation of cleared areas). Project permitting should be conditioned on payment into a decommissioning fund, or some other mechanism, to ensure that rehabilitation of abandoned sites will take place.
- Project permits should contain adaptive management provisions, such that if an unanticipated impact occurs, project operations would be modified to reduce or eliminate such impacts (i.e. unanticipated bird migration mortality that could be eliminated with temporary turbine shut downs during the migration period).
The AMC believes that appropriate state-initiated windpower siting guidelines can reduce siting conflicts and will assist with the efficient development of windpower. AMC will work cooperatively with states, the wind industry, conservation organizations, and other interested parties to develop balanced and realistic state windpower siting policies, regulations and statutes.
Specific Siting Guidelines
This section sets forth guidelines that address issues associated with the siting of commercial windpower facilities in Northeastern mountain environments. (Issues associated with other areas, such as the seacoast and offshore are not addressed because they are outside the AMC’s current area of expertise.) The AMC intends to use these guidelines as a framework for evaluating large-scale windpower project proposals; smaller individual or local-use windpower facilities may involve different considerations. These guidelines are intended to address those issues that are generally associated with windpower projects, but we recognize that additional site-specific factors or concerns may arise. These more site-specific issues will also be taken into consideration in evaluating any project.
In evaluating proposed windpower projects, AMC will consider the extent and nature of any conflicts with natural resource values of recognized state, regional or national significance, as well as any proposed mitigation for such impacts. The guidelines seek to make distinctions based on objective standards where possible. In practice any decision by the AMC to support, oppose or remain neutral with respect to any proposed project will be based on all of the factors addressed by the guidelines and any important site-specific factors. In some cases a single severe conflict may render a site unsuitable for development; in other cases a combination of less severe resource conflicts may, in the aggregate, render the site unsuitable. In other cases, the type, scale or number of conflicts may not render the site unsuitable, after considering proposed mitigation for impacts or changes to an applicant’s design plans.
The AMC recognizes that there has been relatively limited experience with windpower facilities in the Northeast, and expects that the guidelines set forth here will be reviewed and revised based on future experience and on the development of state siting guidelines or regulations for windpower projects.
Ownership and Land Use
Commercial windpower facilities should be located on private or already developed public lands. When additional infrastructure is required, impacts should be minimized. Most appropriate are sites that already contain the necessary infrastructure (roads, transmission lines, etc.). Public lands set aside for natural resource protection, scenic attributes and/or backcountry recreation should not generally be considered for windpower development, particularly if the construction of commercial windfarms would be incompatible with the purposes for which public land was set aside.
Windpower development should be restricted to areas that have seen major commercial activities (e.g. agriculture, timber harvesting, etc.) and associated road building in the past or are likely to in the near future. Higher elevation areas where future timber harvesting is unlikely ("non-commercial timberland") should not be developed for windpower, since these areas will most likely remain relatively undisturbed in the future. AMC encourages windpower siting in areas where human development already dominates (e.g. agricultural and urban areas).
Most suitable: Private land with existing infrastructure and agricultural land. Developed public lands (e.g. municipal waste treatment facilities, school or hospital campuses, etc.), assuming that projects are at an appropriate scale for the site and do not seriously impact other major public values.
Moderately suitable: Private commercial timberland with infrastructure in relatively close proximity.).
Moderately unsuitable: Private non-commercial timberland.
Least suitable: Undeveloped public land.
Soils and Topography
Soils in potential mountain windpower areas are generally cryic (cold regime) and thus inherently more fragile than soils at lower elevation. Disruption of these soils will be a likely consequence of windpower development in high-elevation areas. Therefore siting criteria should aim to minimize soil disruption by siting these facilities in topographically suitable locations.
Suitable: Sites with relatively even ridgelines and gradual approach slopes. Access routes and turbine strings should be able to avoid steep slopes (in excess of 15-20%) in order to prevent excessive sidecuts and fill areas. Potential for sedimentation of streams and ponds must be low.
Moderately suitable: Suitable sites (as defined above) but with small and unavoidable wet soil or steep slope areas where the impacts can be mitigated. Construction must avoid extensive cut and fill for individual turbine pads or road sections.
Moderately unsuitable: Sites with some inclusion of steeper slopes requiring significant terrain alteration on access roads and turbine strings.
Least suitable: Ridgelines with steep slopes, extensive areas of wet or seepy soils or subsurface drainage patterns, uneven topography or large bedrock outcrops requiring extensive terrain alteration along turbine strings and access roads.
Roads and Access
High-elevation areas may be the least accessible parts of an otherwise accessible landscape. Windpower facilities located in more remote areas may compromise the remote character of the site.
Most suitable: Areas with existing permanent and secondary access, including roads into and through the proposed site.
Moderately suitable: Areas with well-developed, permanent and secondary access in the vicinity of the site (i.e., lower elevations) but limited access within the site.
Moderately unsuitable: Areas with limited existing access in the vicinity of the site (i.e., few permanent roads or very low road density even in adjacent low-elevation areas).
Least suitable: Areas in which construction of the facility would have a significant impact on large areas that are essentially roadless.
Vegetation and Natural Communities
Commercial windpower facilities will generally be located in montane boreal forest or upper-slope northern hardwood forest. Potential sites could also encompass subalpine boreal forest, krummholz, alpine areas, or bare rock. In addition, these areas may include areas of high-elevation wetlands or unusual natural communities.
Most suitable: Agricultural lands and areas dominated by relatively common second-growth northern hardwood or spruce-fir forest types. Most preferable would be areas of younger hardwood forest showing obvious evidence of past harvesting.
Moderately suitable: Areas similar to the above but with some inclusions of wetlands, rare communities, or rare plant populations; construction must be able to be located so as to avoid disrupting these sites.
Moderately unsuitable: Mature second-growth spruce-fir forests as this habitat is in short supply across the northern New England landscape. Subalpine boreal forest with little or no commercial timber potential.
Least suitable: Krummholz and alpine areas or sites with extensive inclusions of wetlands or rare communities. Areas where no evidence of previous harvesting is present. Areas containing populations of rare plants where construction would threaten the viability of these populations.
Wildlife
Wildlife impacts must be addressed including the site-specific impact on species resident at the site (including small mammals, herps, and birds), the cumulative effect on wide-ranging species (e.g. lynx) and migratory birds and bats, and the potential for the onsite-project habitat modifications to attract species and put them at risk.
Most suitable: Areas away from major bird and bat migration routes and containing little or no known habitat for species of concern. Areas where local habitat has already been altered or disturbed by past activity.
Moderately suitable: Areas away from major bird and bat migration routes but containing known small-scale habitats for species of concern (such as certain small mammals or birds); construction must be able to be located so as to avoid disrupting these sites.
Moderately unsuitable: Areas with significantly higher-than-average passage rates for migratory birds and bats. Areas containing potential habitat for species of concern. Areas that have a high potential, due to habitat manipulation from project construction, to attract wildlife and put them at risk.
Least suitable: Areas containing extensive or critical habitat for species of concern that is known to be currently occupied, such that construction could not avoid impacting these sites or the species that utilize them. Areas identified as priority focus areas in state Wildlife Action Plans where development would degrade the habitat that was the rationale for delineation of the area. Large areas of mature, unfragmented habitat where this habitat is absent or uncommon in the surrounding landscape. Areas located along major bird and/or bat migration routes, which have a relatively narrow funnel across the landscape that intersects with a site.
Scenic
Any windpower development will have unavoidable scenic impacts. Assessment of impacts must consider not only impact on existing recreational areas but also the potential impact on areas with high potential for expanded recreational use in the future. Considering only current scenic impact may lead to a conflict with the goal of protecting remote areas by promoting siting in remote areas with high potential for expanded recreational use.
Scenic impacts should be evaluated according to their effect on actual or potential impact in areas where a natural-appearing landscape is important. Thus the impact in areas that already show extensive development (such as in the vicinity of towns or highways) should not be AMC's primary concern, though it may be important to the residents of these areas.
Most suitable: Areas where evidence of permanent human development is already a noticeable component of the landscape, e.g. agriculture, highly developed recreational areas like ski areas, etc.
Moderately suitable: Areas where the primary scenic impact is to the view from developed areas (roads, settlements); areas beyond the midground (approximately 5 miles) of current or potential public recreational areas that depend on a natural landscape for their appeal.
Moderately unsuitable: Areas within the foreground (less than ½ mile) of less intensively used public recreation areas (such as minor hiking trails).
Least suitable: Areas within the fore- and midground (approximately 0-5 miles) of major recreational use areas (such as the Appalachian Trail, state and national parks, Wild and Scenic Rivers, etc.), exceptions being where there is already evidence of extensive human development within the viewshed.
Recreation
As with scenic impacts, impact on recreational use must consider the likely closure of the project site to the public for safety and security reasons, and the project’s impact on the recreation experience. Existing and future recreational use should be included in the evaluation, as growth in recreational demand may mean the expansion of recreational activity into new areas in the future.
Most suitable: Areas with little current use and limited appeal for increased use in the future, and areas that will not create barriers to recreational trail corridors.
Moderately suitable: Areas where current use is limited to activities that co-exist well with managed forest landscapes (ex. snowmobiling, hunting), where current backcountry use is low, and where there is limited opportunity for increased backcountry recreation in the future.
Moderately unsuitable: Areas that contain scattered features with moderate backcountry recreational use (such as hiking trails to minor peaks), or where the project could pose a barrier to identified recreational trail corridors.
Least suitable: Areas that currently receive a high level of backcountry recreational use, or where the landscape features and location are such that the potential for increased backcountry use is high. Sites traversed by existing regional or long-distance trails.
