The proposed Granite Reliable Windpark is located in the heart of northern New Hampshire’s high mountain country. In the summer of 2008 AMC filed as an intervenor in the permitting of this project by the New Hampshire Site Evaluation Committee. At that time, we had not taken a position on the project. After reviewing the application and materials submitted by state agencies, and conducting two site visits to the project area, we have taken the position outlined below and set forth in pre-filed testimony filed with the SEC
What is AMC’s specific position on this project?
The Appalachian Mountain Club (AMC) supports the development of the Fishbrook and Owlhead turbine strings (18 turbines). These ridgelines contain relatively common forest types that have been impacted by previous timber harvesting and do not possess significant natural resource values. They lie at lower elevation and contain fewer steep slopes and wetlands than the Mount Kelsey and Dixville Peak ridgelines.
We do not support development of the Kelsey (8 turbines) and Dixville (7 turbines) turbine strings as proposed, but would consider supporting a project that eliminates the turbines on Mount Kelsey and includes a more comprehensive mitigation plan.
We believe that development of the Kelsey and Dixville ridgelines as proposed would constitute an unreasonable adverse impact on the natural environment under the provisions of NH RSA 162-16:H.IV, and would conflict with the goals of other existing state policies, most notably the State Wildlife Action Plan and potentially the adaptation goals of the New Hampshire Climate Change Action Task Force (currently under development).
The Mount Kelsey ridgeline contains an old-growth subalpine spruce-fir forest that provides high quality habitat for several of the state’s rarest and most vulnerable wildlife species (the state-listed American marten and three-toed woodpecker as well as Bicknell’s thrush). Dixville Peak possesses similar characteristics as Mount Kelsey, though we judge it to be of somewhat lower overall ecological value. Development of these ridgelines would fragment and degrade significant blocks of high-elevation habitat and create an unacceptable risk to these species.
Development would also adversely affect the ability of these areas to serve as refugia for spruce-fir forests (and the species that depend on them) during future climatic warming. Research on post-glacial climate changes has shown that high-elevation areas maintain a relatively stable component of spruce-fir forest during warmer periods when forests at lower elevations undergo significant changes. Recent research on Mount Washington has shown higher-elevation areas to be more resistant to climate change than lower-elevation areas. We believe that the high-elevation mitigation plan proposed by the applicant provides little value in compensating for the impact to this critical habitat. Similar concerns were expressed by the NH Department of Fish and Game in their pre-filed testimony
We also have serious concerns about the impacts of construction of the massive project roads on fragile steep high elevation soils and ridgeline wetlands, and believe the project application understates the risks of this construction, and does not adequately consider the unique conditions at higher elevations (most notably much greater precipitation).
Because of its high ecological value, we do not believe that Mount Kelsey should be developed under any circumstances. However, we would consider supporting a scaled-back project that included the turbines on Dixville Peak if it included a significantly improved mitigation plan. Such a reconfigured project would have a capacity of 75 MW – nearly three times the size of the Lempster project. It would also have the benefit of retaining some of the existing but limited transmission capacity for the development of wood biomass facilities.
What is AMC’s general approach to ridgeline wind power development?
The AMC supports terrestrial wind power development when it is avoids significant impacts to ridgeline areas with ecological, scenic and/or recreational values of recognized state, regional or national significance. We clearly recognize the adverse impacts that our society’s continued reliance on fossil fuels can have on mountain ecosystems. We strongly support efforts to develop non-polluting sources of energy, and recognize that wind is one of the region’s most viable indigenous sources of renewable energy. We have a demonstrated track record of supporting appropriately-sited projects.
The AMC adopted its General Policy on Wind Power in 1996 and revised it in 2006. This policy sets forth our overall position on wind power development in the region and lists specific criteria by which we will evaluate individual projects. The AMC has used these criteria to review all proposed terrestrial commercial wind power projects in New England.To date we have actively supported three (most recently the 132 MW Kibby project and the 57 MW Stetson project in Maine) and opposed one (the 90 MW Redington/Black Nubble project, also in Maine). We did not take official positions on other projects that have reached the permitting stage (including Lempster Mountain), as they did not raise issues of sufficient concern relative to the interests and expertise of AMC.
How has AMC been involved in the development of wind power policy in New England?
The core of the Appalachian Mountain Club’s mission is to “promote the protection, enjoyment, and wise use of the mountains, rivers, and trails of the Appalachian region.”The development of commercial-scale wind power projects on high-elevation ridgelines has the potential to significantly impact our mission, both positively and negatively. Since the early 1990s the AMC has been actively involved in the issue of wind power siting in the Northeast.
The AMC is a recognized leader in promoting the development of state-based wind power siting policies. In New Hampshire, we convened and led a multi-stakeholder group that developed proposed wind power siting guidelines that were presented to, and included in the final report of, the legislatively established Energy Policy Commission. AMC was represented on the Governor’s Task Force on Wind Power Development in Maine, the recommendations of which were unanimously enacted into law by the state legislature. In Massachusetts, AMC is represented on the Energy Facilities Siting Commission established under the Green Communities Act.
