Wind Farms in Storey County
This web site is owned and operated by Jed Margolin to post documents and discuss the issue of wind farms in Storey County, Nevada . I am particularly interested in the Bureau of Land Management's New Comstock Wind Energy Project.
I live in the Virginia City Highlands, in Storey County, Nevada (here are some pictures of my neighborhood).
Jed Margolin
Virginia City Highlands, Nevada
February 20, 2009
The BLM Web site for Great Basin Wind's proposed New Comstock Wind Energy
Project is:
http://www.blm.gov/nv/st/en/fo/carson_city_field/blm_programs/planning/new_comstock_wind.html
Index
1. BLM News Release: December 1, 2008, BLM to Prepare an EIS on New Comstock
Wind Energy Project
2. Story County
Planning Commission Agenda for the meeting on February 19, 2009
3. Presentation graphics for BLM's presentation to the Storey County Planning
Commission on February 19, 2009.
4. Federal Register Notice Announcing Notice
of Intent to Prepare EIS (11/26/2008)
5. Project Informational Handout (December 2008)
6. Instruction Memorandum
No. 2009-043, Wind Energy Development Policy
7. H-1601-1 LAND USE PLANNING HANDBOOK – (Public)
8. Project Map (Initial Map
for Scoping - December 2008)
9. Minutes from the Storey
County Planning Commission Meeting of February 19, 2009.
10. The Laws that the BLM
operates under.
***************************************************************
11. Great Basin
Wind Application and Plan of Development (POD)
***************************************************************
12. My Analysis of the Great Basin Wind Application and Plan of Development
14. The Washoe County Planning Commission meeting on March 10, 2009.
15. New posting on BLM’s Web site - New Schedule
Public Comments to BLM Regarding the Project - Click here
Nevada Legislation – Click here
Storey County Ordinance for Wind Energy Systems – Click here
Documents
1. BLM News Release: December 1, 2008, BLM to Prepare an EIS on New Comstock Wind Energy Project
From
BLM Web site: (Click here)
Mirrored copy (PDF, Click here)
2. Story County Planning
Commission Agenda for the meeting on February 19, 2009. (Click Here)
It includes:
PRESENTATION:
by Daniel Jacquet of the Bureau of Land Management (BLM) on Great Basin Wind’s
proposed New Comstock Wind Energy Project
3. Presentation graphics for BLM's presentation to the Storey County Planning Commission on February 19, 2009. The presentation was given by Jane H. Peterson, who is the Renewable Energy Project Manager for the Carson City District BLM Office. (The actual presentation added "Storey County Planning Commission, February 19, 2009" on the front page.)
From BLM web site: (Click here)
Mirrored copy: (Click here)
4.
Federal Register Notice Announcing Notice of Intent to Prepare
EIS (11/26/2008)
Federal Register / Vol. 73, No. 229 /
Wednesday, November 26, 2008 / Notices
From
BLM Web site: (Click Here)
Mirrored copy: (Click here)
5. Project
Informational Handout (December 2008)
From BLM Web
site: (Click here)
Mirrored copy: (Click
here)
6. Instruction Memorandum No.
2009-043, Wind Energy Development Policy
|
From BLM (html): Wind Energy Development Policy (Click
here) 1 – BLM
Wind Energy Program – Policies and Best Management Practices (19 pp) (Click
here) |
|
1 – BLM Wind Energy Program – Policies and Best Management Practices (PDF: Click
here) 2 – Wind Energy Plan of Development (4 pp) (Click here) |
7. H-1601-1 – LAND USE PLANNING HANDBOOK –
(Public)
{mentioned in Wind Energy Development
Policy}
From
BLM: (Click
here)
Mirrored copy (PDF, Click here)
(html, Click
here)
8. Project Map (Initial Map for Scoping - December 2008)
From BLM: (Click here)
Mirrored copy: (Click here)
The BLM map is not very legible so I have
scanned the paper map in sections. The red square sections are one mile per
side.
1.
Turbines closest to Virginia City (Click here).
2. Turbines closest to Gold Hill (Click here).
3. BLM Map Legend (Click here).
4. BLM Map Scale (Click here).
5. Turbines closest to Geiger Summit (Click here).
Although the land North of Geiger Grade may be
Terra Incognito to BLM, some of us live here in the Highlands which includes
the Virginia City Highlands, the Highland Ranches, and the 40's.
Here is a map of the Virginia Highlands from
the Nevada Department of Transportation:
http://www.nevadadot.com/traveler/maps/areamaps/pdfs/VirginiaHighlands.pdf
Mirrored copy: Click here.
I have reproduced a section of the map and
placed a red dot to indicate the location of the turbine closest to the Highlands. (The entire map would not fit in my software) (Click here)
The map scale is the same as the BLM map with the red square sections being one
mile per side.
Finally, I have put the maps together in one file. The file size is
smaller and the resolution is lower than the individual maps. (Click here)
9. Minutes from the Storey County Planning Commission Meeting of February 19, 2009. (Click here)
At the end of the presentation:
"Commissioner Kiechler asked why the public meeting after the scoping was supposed to already be done. Jane Peterson said that the scoping was still open and that all comments would be taken into consideration."
This meeting was held on February 19, 2009. According to the BLM presentation:
• Scoping December 2008 - January 2009
Apparently, Ms. Peterson was not listening to
herself when she gave the presentation.
The following is the entire part of the meeting devoted to the BLM presentation.
PRESENTATION: by Daniel Jacquet
of the Bureau of Land Management (BLM) on Great Basin Wind’s proposed New
Comstock Wind Energy Project
Planner Osborne explained to the audience that this was just a presentation and
that no action would be taken tonight. The intention of tonight’s meeting,
Osborne explained, is for BLM to present this phase of their Environmental
Impact Statement (EIS). He also explained that BLM would be given the floor
tonight, Great Basin Wind’s President Rich Hamilton would be here to provide
technical support, and that there would be time allotted after the
presentation’s conclusion for questions and answers for the attending public.
Linda Kelly, Sierra Front Field Manager, gave a brief description of the split
into two office of the BLM in Carson City. Representing the BLM was also Ken
Nelson and Rich Channel.
Jane Peterson, Renewable Energy Project Manager, gave the following power point
presentation:
INTRODUCTION
• Carson City District Office
• Sierra Front Field Office - Linda Kelly, Field Office Manager
• NEPA Process - Jane Peterson, Energy Project Manager
• Cooperating Agencies
• Next Steps
• Project Overview - Rich Hamilton, Great Basin Wind
PROJECT OVERVIEW
• Approximately 71 turbines
- 210' to 330' tall ..•
- Blade length - 115' to 170'
• 20 miles underground electrical
lines
• 5 miles of 120 kV transmission line to substation
• Access roads
• Miscellaneous storage buildings and yards
RIGHT-OF-WAY PROCESS
• Federal Land Policy and Management Act – BLM authority for granting ROWs on
public lands
- Authorization to use a specific
piece of public land for a certain project for a term appropriate for the life
of the project
- Specifies authority to grant ROWs for systems to generate, transmit, and
distribute electric energy
• Further authority in the Energy Policy Act of 2005
- 10,000 MW of renewable energy projects located on public lands by 2015
ROW PROCESS - NEW COMSTOCK
• Great Basin Wind LLC submitted an SF-299
Right-of Way application to construct and operate a commercial wind turbine
facility and an initial Plan of Development
• BLM to prepare Environmental Impact Statement
• Decision on to be made on the ROW after completion of EIS is based on:
- Outcome of EIS
- Determination if proposal is in the public interest
- Consistency with Federal, State, or local laws
NATIONAL ENVIRONMENTAL POLICY ACT (NEPA)
• A public, interdisciplinary process to ensure informed decision-making
by federal agencies
• Requires agencies to follow a particular process
• Requires agencies disclose the information used to support those decisions
EIS COMPONENTS
• Scoping .
• Purpose and Need
• Alternatives Development
• Environmental Impact Analysis
• Draft EIS
• Public Meetings
• Public Review Period
• Final EIS
• Record of Decision (ROD)
SCOPING ISSUES TO BE ADDRESSED IN THE EIS
• Visual Resources • Socioeconomic
• Cultural Resources • Wildfire
• Noise • Invasive Species
• Wildlife • Erosion
• Recreation Access • Safety
• Tourism • Emergency services
• Vegetation • Travel management
• Electromagnetic Interference • Transportation
COOPERATING AGENCIES
• Objectives:
- Gain early and consistent
involvement of CA partners
- Incorporate local knowledge of economic, social, and environmental conditions,
as well as state and local land use requirements
- Address intergovernmental issues
- Avoid duplication of effort
- Enhance local credibility of the planning review process
- Encourage CA support for planning decisions
- Build relationships of trust and cooperation.
COOPERATING AGENCIES
• Eligibility:
• State, local, tribal and federal agencies with:
• Jurisdiction by law and/or
• Special expertise
• Memorandum of Understanding (MOU) establishes roles and responsibilities
COOPERATING AGENCIES
• Cooperating agencies participate in various steps of the EIS process as
feasible
- Collect data
- Identify interest groups/organizations
- Help identify alternatives
- Assist in analysis
- Assist in responses to comments
• All NEP A decisions remain
responsibility of the BLM
SCHEDULE
• Scoping December 2008 - January 2009
• Draft EIS Late 2009
• Final EIS mid-2010
• Record of Decision (ROD) Late 2010
The following representatives were present representing New Comstock Wind
Energy: Rich Hamilton, Great Basin Wind; Ed Duggan, Oak Creek Energy Systems;
Stuart Smith, Oak Creek Energy Systems; and Phil Tousignart, Kleinfelder. They
would provide any technical support needed.
Commissioner Tyler wanted to know why this particular location rather than in
TRI. Mr. Duggan answered that it had to do with the wind and the studies that
they had done.
Commissioner Kiechler asked who decided on the qualifying agency and if the BLM
intended to invite Storey County to participate in the process. Jane Peterson
said that this was part of the Scoping process and that they would be taking
all the comments into consideration.
Chairman Bucchianeri expressed his feelings in a comment that the BLM would
have the final say and that Storey County would be advisory.
Vice-Chairman Hammack was interested in the sub groups such as home owner
associations in this process. The sub groups would inform the county and the
county would advise BLM.
Commission Prater volunteered to be a staff member or point of contact for the
county on this project as part of the cooperating agency or be a part of a
sub-committee to work with county staff and the BLM. Commissioner Tyler said he
would also like to be part of the people representing Storey County to the BLM.
Jed Margolin, who lives in the Virginia City Highlands, wanted to know how the
wattage was gauged: was it during peak or usual wind? How many homes would be
supplied with electricity? With the BLM having the final decision and the
cooperating agency only having input, he objected in the strongest terms.
Jim Watson of the Virginia City Highlands was interested in the other uses of
the federal land and how this would affect them. There are seven applications
in for wind farms and only one is for private land. Will the BLM be receiving
money for the use of its land and would Storey County see any money from this
project?
Ken Nelson answered that there would be an annual rent determined by the watts
produced by the turbines which would amount to approximately $637,700.00 per
year. Storey County would only be getting the property taxes. Rich Hamilton
commented that it was more expensive to put the wind farms on public land and
that 85% of Nevada was public land. The other consideration was the amount of
energy that could be produced by the site. There are currently 18 wind mills in
Storey County. The wind monitoring was started in 2006.
Ron Engelbrecht of the Mark Twain Estates brought Senate bill 114 which has
just come out of committee that will not allow any local or county ordinances
to prohibit or be too restrictive on either Solar or Wind Energy. Chairman
Bucchianeri suggested that the Planning staff keep an eye on this legislation.
Joe Curtis, Virginia Convention & Tourism Authority, commented on the
complaints that had been received over the past couple of summers in regards to
a “significant noise” which was discovered to be the small test wind turbines
placed by Comstock Wind Energy to gather information. The BLM is using the
first person which means that they have already made their decision which is
evident from published comments in the media – “…they’ll just have to get used
to it”. He stated further that the visual impact would be significant to
tourism and would be the future demise of tourism in Storey County.
Caroline Lowman, Washoe County, commented that putting them on the ridge tops
was not necessary since turning the turbines had to do with the cooler air
rising off the valley floors. Second, where was the steel coming from to build
them and how about using the resources in Nevada for these projects?
Bob Fredlund, Carson City, thanked Planner Osborne for keeping him informed as
he owns three 40 acre parcels on Middle Hill and Abby Hill. He has concerns
about the environmental issues, wild horses and the springs. He would like to
be a stakeholder in this process.
Ron Reno, Silver City, said that he is Heritage Consultant and the Silver City
was looking to Storey, Carson, and Washoe Counties to protect them. They could
have the visual effect of the wind turbines. He wanted to know if the scoping
files were available and if they could be posted to the BLM website for
viewing. Jane Peterson said they were available at the office but that she had
not considered posting them to the website but take that into consideration.
Ralph Arista, Virginia City, commented that for two years the residents of Virginia City has to put up with the whooping sound of 15” wind turbine and that now the
silence was golden.
Christy Ann Strange, Virginia City, explained her story of having to live with
over 100 wind mills along a ridge line in Pennsylvania. There was constant
sound and electrical interference. They spoil the view and do cause the tourism
to drop.
Geri Baker, Virginia City Highlands, is a breast cancer survivor and has spent
a lot of time looking for a place for herself and her children. The noise of
the turbines would destroy the peace and quiet that she looked so hard for.
Tom Purkey, Virginia City, first wanted to know the obligation for the use of
the wind energy and second if a bond requirement was in place encase they went
out of business and the wind turbines had to be taken down. Ken Nelson replied
that $10,000 bond was required on each turbine.
Tom Gray, Virginia & Truckee Railroad, commented on the historical
significance of the project that has cost millions and what the visual effects
will do to the drop in tourism. Wind mills are not attractive to look at and
spoil the landscape.
County Manager Pat Whitten said that he would take both Commissioner Prater and
Commissioner Tyler earlier offer to help the county out into consideration. In
regards to the question about more advertising or noticing about the meetings
to be help, he said he would get with the local media and see what solution
could be found.
Commissioner Kiechler asked why the public meeting after the scoping was
supposed to already be done. Jane Peterson said that the scoping was still open
and that all comments would be taken into consideration.
10. The Laws that the BLM operates under.
From the BLM web site (PDF): Click here.
Converted
to html. I have added active links to some of the laws: Click here.
Some of the laws that may apply to the current issue are:
Federal Land Policy and Management Act of 1976, as
amended (43 U.S.C. 1701 et seq.)
National Environmental Policy Act of 1969 (42 U.S.C. 4321 et seq.)
The Endangered Species Act of 1973, as amended (16 U.S.C. 1531 et seq.)
Energy Policy Act of 2005 (P.L. 109-58)
The Paperwork Reduction Act of 1980 (44 U.S.C. 3501-3520)
The Electronic FOIA Act of 1996 (P.L. 104-231)
Taylor Grazing Act of 1934 (43 U.S.C. 315), as amended by the Act of August
28, 1937 (43 U.S.C.1181d)
Public Rangelands Improvement Act of 1978 (43 U.S.C. 1901-1908)
The Historic Sites Act (16 U.S.C. 461)
The National Historic Preservation Act of 1966, as amended (16 U.S.C. 470)
The Archaeological Resources Protection Act of 1979, as amended (16 U.S.C. 470a,
470cc and 470ee)
Wild Free Roaming Horse and Burro Act of 1971, as amended by the Public Rangelands
Improvement Act of 1978 (16 U.S.C. 1331-1340), and by P.L. 108-447, Division E,
Section 142
The Migratory Bird Conservation Act of 1929, as amended (16 U.S.C. 715) and
treaties pertaining thereto
The Wilderness Act of 1964 (16 U.S.C. 1131 et seq.)
March 18, 2009
11. Great Basin Wind Application and Plan of Development (POD)
Application For Transportation and Utility Systems and Facilities in Federal Lands, Form SF-299, dated April 18, 2008.
Scanned from a paper copy obtained from BLM: (Click here)
The document uses a small font size and is difficult to read, even the paper copy. I have used OCR to convert it to text to make it easier to read and to quote from: (Click here)
I was given two pages by
BLM. Page 2 says: "continued on page 3." The standard SF-299 form
contains 5 pages. Page 3 contains General Information and Specific
Instructions. Page 5 is Notices. That leaves Page 4 (Supplemental)
in which the Applicant is required to give business information. Either the
Applicant failed to file Page 4 or BLM did not give it to me. For the standard blank SF-299 form: Click here.
New Comstock Wind Energy Project Plan of Development - Draft, dated August 25, 2008.
Scanned from a paper copy obtained from BLM: (Click here)
Converted
to text using OCR to make it easier to read and to quote from: (Click here)
If you came here just for the Great Basin Wind Application and POD and are not
interested in my comments you can stop now.
12. My Analysis of the Great Basin Wind Application and Plan of Development
Some of
the items in the Great Basin Wind Application SF-299 have caught my attention.
Section 15:
The proposed project would be able to supply up to 192MW of renewable energy. The Nevada Public Utilities Commission requires regulated utilities in the State to supply a certain percentage of their energy mix from wind generated sources. The Governor of Nevada has provided direction to make Nevada energy independent and eventually become an energy exporter. Nevada will require an increasing amount of wind power to meet the increasing load demand from growth and also allow regulated utilities to meet the renewable energy requirement.
On March 19, 2009 I talked to Ms. Anne-Marie Cuneo, the Manager for Resource and Market Analysis for the Public Utilities Commission of Nevada (http://pucweb1.state.nv.us/PUCN/PUCHome.aspx)
I asked her if the statement is true. Are regulated utilities in the State required to supply a certain percentage of their energy mix from wind generated sources?
The answer is, “No.”
They are required to supply a certain percentage of power from renewable energy sources (some of which must be solar), but there is no requirement for wind.
This is contained in Nevada Revised Statutes (NRS) 704.7801 - 704.7828 .
This link (http://www.leg.state.nv.us/Nrs/NRS-704.html#NRS704Sec7801) contains CHAPTER 704 - REGULATION OF PUBLIC UTILITIES GENERALLY in its entirety so I have put 704.7801 - 704.7828 in its own page. (Click here)
NRS 704.7821 establishes the requirement of a portfolio standard. There is a schedule that Utilities must follow for producing energy from renewable sources with a minimum percentage from solar. Part of the portfolio standard may include energy efficiency measures.
Not less than 5 percent must come from solar. Not more than 25 percent may come from energy savings measures. (I have underlined those parts.)
Wind energy is one of the forms of renewable energy sources (NRS 704.7811 “Renewable energy” defined), but there is no requirement for wind.
Great Basin Wind has made a material false and misleading statement in its application.
NRS 704.7821
NRS 704.7821 Establishment of portfolio standard; requirements; treatment of certain solar energy systems; portfolio energy credits; renewable energy contracts and energy efficiency contracts; exemptions; regulations.
1. For each provider of electric service, the Commission shall establish a portfolio standard. The portfolio standard must require each provider to generate, acquire or save electricity from portfolio energy systems or efficiency measures in an amount that is:
(a) For calendar years 2005 and 2006, not less than 6 percent of the total amount of electricity sold by the provider to its retail customers in this State during that calendar year.
(b) For calendar years 2007 and 2008, not less than 9 percent of the total amount of electricity sold by the provider to its retail customers in this State during that calendar year.
(c) For calendar years 2009 and 2010, not less than 12 percent of the total amount of electricity sold by the provider to its retail customers in this State during that calendar year.
(d) For calendar years 2011 and 2012, not less than 15 percent of the total amount of electricity sold by the provider to its retail customers in this State during that calendar year.
(e) For calendar years 2013 and 2014, not less than 18 percent of the total amount of electricity sold by the provider to its retail customers in this State during that calendar year.
(f) For calendar year 2015 and for each calendar year thereafter, not less than 20 percent of the total amount of electricity sold by the provider to its retail customers in this State during that calendar year.
2. Except as otherwise provided in subsection 3, in addition to the requirements set forth in subsection 1, the portfolio standard for each provider must require that:
(a) Of the total amount of electricity that the provider is required to generate, acquire or save from portfolio energy systems or efficiency measures during each calendar year, not less than 5 percent of that amount must be generated or acquired from solar renewable energy systems.
(b) Of the total amount of electricity that the provider is required to generate, acquire or save from portfolio energy systems or efficiency measures during each calendar year, not more than 25 percent of that amount may be based on energy efficiency measures. If the provider intends to use energy efficiency measures to comply with its portfolio standard during any calendar year, of the total amount of electricity saved from energy efficiency measures for which the provider seeks to obtain portfolio energy credits pursuant to this paragraph, at least 50 percent of that amount must be saved from energy efficiency measures installed at service locations of residential customers of the provider, unless a different percentage is approved by the Commission.
(c) If the provider acquires or saves electricity from a portfolio energy system or efficiency measure pursuant to a renewable energy contract or energy efficiency contract with another party:
(1) The term of the contract must be not less than 10 years, unless the other party agrees to a contract with a shorter term; and
(2) The terms and conditions of the contract must be just and reasonable, as determined by the Commission. If the provider is a utility provider and the Commission approves the terms and conditions of the contract between the utility provider and the other party, the contract and its terms and conditions shall be deemed to be a prudent investment and the utility provider may recover all just and reasonable costs associated with the contract.
3. The provisions of paragraphs (b) and (c) of subsection 2 do not apply to a provider of new electric resources pursuant to chapter 704B of NRS with respect to its use of an energy efficiency measure that is financed by a customer, or which is a geothermal energy system for the provision of heated water to one or more customers and which reduces the consumption of electricity or any fossil fuel, except that, of the total amount of electricity that the provider is required to generate, acquire or save from portfolio energy systems or efficiency measures during each calendar year, not more than 25 percent of that amount may be based on energy efficiency measures.
4. If, for the benefit of one or more retail customers in this State, the provider, or the customer of a provider of new electric resources pursuant to chapter 704B of NRS, has paid for or directly reimbursed, in whole or in part, the costs of the acquisition or installation of a solar energy system which qualifies as a renewable energy system and which reduces the consumption of electricity, the total reduction in the consumption of electricity during each calendar year that results from the solar energy system shall be deemed to be electricity that the provider generated or acquired from a renewable energy system for the purposes of complying with its portfolio standard.
5. The Commission shall adopt regulations that establish a system of portfolio energy credits that may be used by a provider to comply with its portfolio standard.
6. Except as otherwise provided in subsection 7, each provider shall comply with its portfolio standard during each calendar year.
7. If, for any calendar year, a provider is unable to comply with its portfolio standard through the generation of electricity from its own renewable energy systems or, if applicable, through the use of portfolio energy credits, the provider shall take actions to acquire or save electricity pursuant to one or more renewable energy contracts or energy efficiency contracts. If the Commission determines that, for a calendar year, there is not or will not be a sufficient supply of electricity or a sufficient amount of energy savings made available to the provider pursuant to renewable energy contracts and energy efficiency contracts with just and reasonable terms and conditions, the Commission shall exempt the provider, for that calendar year, from the remaining requirements of its portfolio standard or from any appropriate portion thereof, as determined by the Commission.
8. The Commission shall adopt regulations that establish:
(a) Standards for the determination of just and reasonable terms and conditions for the renewable energy contracts and energy efficiency contracts that a provider must enter into to comply with its portfolio standard.
(b) Methods to classify the financial impact of each long-term renewable energy contract and energy efficiency contract as an additional imputed debt of a utility provider. The regulations must allow the utility provider to propose an amount to be added to the cost of the contract, at the time the contract is approved by the Commission, equal to a compensating component in the capital structure of the utility provider. In evaluating any proposal made by a utility provider pursuant to this paragraph, the Commission shall consider the effect that the proposal will have on the rates paid by the retail customers of the utility provider.
9. As used in this section:
(a) “Energy efficiency contract” means a contract to attain energy savings from one or more energy efficiency measures owned, operated or controlled by other parties.
(b) “Renewable energy contract” means a contract to acquire electricity from one or more renewable energy systems owned, operated or controlled by other parties.
(c) “Terms and conditions” includes, without limitation, the price that a provider must pay to acquire electricity pursuant to a renewable energy contract or to attain energy savings pursuant to an energy efficiency contract.
(Added to NRS by 2001, 2528; A 2003, 1866, 1876; 2005, 22nd Special Session, 82; 2007, 414)
NRS 704.7811
NRS 704.7811 “Renewable energy” defined.
1. “Renewable energy” means:
(a) Biomass;
(b) Geothermal energy;
(c) Solar energy;
(d) Waterpower; and
(e) Wind.
2. The term does not include coal, natural gas, oil, propane or any other fossil fuel, or nuclear energy.
3. As used in this section, “waterpower” means power derived from standing, running or falling water which is used for any plant, facility, equipment or system to generate electricity if the generating capacity of the plant, facility, equipment or system is not more than 30 megawatts. Except as otherwise provided in this subsection, the term includes, without limitation, power derived from water that has been pumped from a lower to a higher elevation if the generating capacity of the plant, facility, equipment or system for which the water is used is not more than 30 megawatts. The term does not include power:
(a) Derived from water stored in a reservoir by a dam or similar device, unless:
(1) The water is used exclusively for irrigation;
(2) The dam or similar device was in existence on January 1, 2003; and
(3) The generating capacity of the plant, facility, equipment or system for which the water is used is not more than 30 megawatts;
(b) That requires a new or increased appropriation or diversion of water for its creation; or
(c) That requires the use of any fossil fuel for its creation, unless:
(1) The primary purpose of the use of the fossil fuel is not the creation of the power; and
(2) The generating capacity of the plant, facility, equipment or system for which the water is used is not more than 30 megawatts.
(Added to NRS by 2001, 2527; A 2003, 1875)
The next item that caught my attention in the Great Basin Wind Application is Section 17:
There could be a long-term impact to visual resources resulting from the presence of turbine structures located on the ridge top, The turbine units could be visible from much of Washoe Valley and from specific locales in Carson City. The proposed project may result in temporary impacts to air and water quality associated with construction disturbance. Noise levels will be below 50 mhtz on the wind side.
The term “50 mhtz” has no scientific meaning.
People sometimes make a typo and write 50 MHtz when they mean 50 MHz, but saying “Noise levels will be below 50 MHz” would be irrelevant.
Since noise levels are involved, the Applicant might have meant “Noise levels will be below 50 dBA” but 50 dBA is loud and bothersome relative to the ambient noise in a rural community. In addition, noise levels produced by machines must specify the distance. If you get far enough away from a jet engine you will measure only 50 dBA.
Note that ‘dB” is a relative measurement. When it is relative to a standard, that standard is incorporated into the unit. The term “dBA” means “dB Acoustic.” Unfortunately, the “A” is usually left off, which is why hardly anyone understands what a “dB” is.
For sound pressure level, the reference level (for air) is usually chosen as 20 micropascals (20 µPa), or 0.02 mPa. This is very low: it is 2 ten billionths of an atmosphere. Nevertheless, this is about the limit of sensitivity of the human ear in its most sensitive range of frequency.
Thus, 0 dBA is considered the threshold of human hearing in someone with normal hearing.
And, Applicant mentions that the towers could be visible from much of Washoe Valley and from specific locales in Carson City. He left out Virginia City and the Highlands. Towers will be less than one mile away from those locations.
Section 16:
The proposed project could result in tax benefits to both Washoe and Storey Counties. Anticipated new jobs associated with the project equates to 2 temporary jobs/MW during construction and 10 to 16 long-term jobs during operation, in addition to the secondary job creation impact. The proposed project is sited away from residential development and is not anticipated to impact the rural lifestyle of the area. The project may have the potential to impact cultural resources and the project is partially located within the Comstock Historic District.
Applicant does not mention the potential for loss of tax benefits for Storey County due to decreased tourism and jobs lost in Virginia City (the Comstock Historic District).
Some of the proposed turbines will be less than a mile from Virginia City.
Applicant does not seem to be aware that Virginia City is not just an Historic District. People work there. People live there.
Applicant’s map ends just North of Geiger Grade. People live within a mile of the Northern-most turbine. Their roads are not shown on Applicant’s map.
Section 6:
In Section 6, Rich Hamilton (the authorized
agent for Great Basin Wind Energy, LLC) is asked if he is a U.S. citizen. He is.
However, in Section 12 we learn that Oak Creek Energy Systems (OCES) is a
majority partner in Great Basin Wind, and that Marubeni Corporation of Tokyo, Japan, has a controlling interest in OCES. Therefore, Marubeni controls Great Basin Wind.
Great Basin Wind possesses both the financial and technical capabilities
required to develop and operate wind power generation projects through majority
partner Oak Creek Energy Systems (OCES). OCES has an experienced team of 50
employees with extensive project development, permitting and operations
experience on both public and private lands in Kern County, CA. In early 2008
Marubeni Corporation of Tokyo, Japan acquired a controlling interest in Oak
Creek Energy Systems - giving OCES the financial resources needed to carry out
significant wind energy development in the coming years. Mountain Wind Energy
LLC will provide local knowledge and lead the permitting activities for Great
Basin Energy in Nevada. Contractors will be used in the permitting and
development process, as needed.
There do not seem to be any laws prohibiting
foreign ownership of electric generating capacity and distribution (unlike in
Broadcasting) so the point is simply that Great Basin Wind is not a small local
Nevada company. It is the front company for Marubeni, a large Japanese
company.
Here are some of the things Marubeni does (from the web site of their U.S. subsidiary):
A. Chemicals (http://www.marubeni-usa.com/our_business/chemicals.html)
MAC's business in this area is wide-ranging, as we handle agrochemicals, petrochemicals, plastics, specialty chemicals and electronic materials.
Our commodity chemicals Department is based in Houston at its industry's center. We trade petrochemical products and chlor-alkali related products, such as olefins, aromatics, carbon black feedstock, vinyl chloride monomer (VCM), polyvinyl chloride resin (PVC), caustic soda, and polyolefins, mainly between the U.S., Central and South America and Asia, to meet the increasing demand in Asia and in the U.S.
B. Energy (http://www.marubeni-usa.com/our_business/energy.html)
We are expanding our trading portfolios in the oil
and gas businesses in the U.S. and Latin America, while simultaneously
exploring opportunities for investment in related mid-downstream businesses in
both regions. We also lend support to two subsidiary companies in oil and gas
and nuclear fuel - MIECO and Energy U.S.A., respectively - which MAC owns
jointly with Marubeni Corporation. MIECO, with offices in California, Texas and
New Jersey, conducts trading of petroleum products, petrochemical feedstocks
and natural gas in the American and the Pacific Rim markets. Energy U.S.A., with offices in Washington, D.C. and Connecticut, trades natural uranium both domestically
and overseas for end-use in the generation of nuclear power.
C. Food (http://www.marubeni-usa.com/our_business/food.html)
MAC buys and exports grain, meat and other foodstuffs from the U.S. for the Japanese and Asian markets; engages in commodities trading through the Intercontinental
Exchange and the Chicago Board of Trade; and assists Marubeni Corporation in
conducting commodity trading with suppliers in North America and Central and South America. We export wheat, barley, rice, corn, sorghum, soybeans, canola, beef, pork
and other foodstuffs to the Japanese and Asian markets from the U.S., while also importing sugar and grape must to the U.S. from Central and South America.
and
MAC's largest subsidiary, Helena Chemical Company,
is one of the largest formulators of crop inputs and services in the U.S.
Helena offers a variety of crop protection products, agricultural chemicals,
seed, fertilizer and related products. For more information about Helena, please click on the tab labeled "Chemicals."
D. Forest Products (http://www.marubeni-usa.com/our_business/forest_products.html)
Through our subsidiary, Marubeni Pulp & Paper North America, we import, export and distribute pulp, wood chips and paper; meanwhile, our affiliate Pan Pacific Fiber collects various waste papers from local markets and sorts, bundles, and ships them worldwide.
Another of MAC's subsidiary companies, Intragrated Resources Holdings, sells printing paper to catalog houses and publishers in the U.S. and also provides consulting services to heavy corporate users of printing paper.
A.T. Clayton and Company, Inc.
Paper distributor and printing consulting
E. New Business (http://www.marubeni-usa.com/our_business/new_business.html)
MAC always targets growing industries for early or mid-stage investment. Our specialty is facilitating the bi-directional flow of technology and business between the U.S. and Japan (and other places in Asia). Current activities include private equity investment, partnerships, incubation, joint ventures, technology and product development sponsorships, and marketing and distribution.
Wherever MAC invests, our strategy is to promote growth by connecting the acquisition to the global network of business alliances that we and our parent, Marubeni Corporation, have cultivated. We seek sound opportunities whether in private equity funds, in strategic direct investment, or in middle-market acquisitions.
F. Power Products & Infrastructure (http://www.marubeni-usa.com/our_business/pp_infrastructure.html)
MAC is involved in business development related to the power industry in North America. Along with our affiliate, Marubeni Power International, Inc. , headquartered in New York City, we explore new areas of power generation, including nuclear power, delivery of utility-scale generation, including development, financing, ownership, and operation and maintenance. We also have several other affiliates in the power generation field, including Marubeni Sustainable Energy, an alternative energy and co-generation provider headquartered in San Diego California, Oak Creek Energy System, Inc. a wind power developer, also headquarted in San Diego, California and PIC Group of Companies a provider of maintenance and consulting service, headquartered in Atlanta, Georgia, and Marubeni Caribbean Power Holdings, which generates significant supplies of electric power for countries in the Caribbean basin.
MAC also partners with other North American companies to develop and commercialize new energy technologies and business models in Asia together with our parent company in Japan. Working in concert with Marubeni Corporation, we are able to act as a conduit between North America and Japan for new technologies, products, and business models in the power and energy industries. In addition we continue to support ongoing gas turbine component sales and developing business for gas turbine generators in North America.
Marubeni Caribbean Power Holdings, Inc.
Holding company for power plants and power
companies in the Caribbean area
Marubeni Power International, Inc.
Marketing and development of power projects
Marubeni Sustainable Energy, Inc.
Owner and operator of renewable generation plants
Wind energy development in the Southwestern United
States
Global service provider to the power generation industry
While these activities probably don’t disqualify Marubeni from building a project on BLM land, Marubeni has no right to claim the Moral High Ground in this matter. Nevada’s winds are only another resource to exploit for profit.
I have a question about water.
Aircraft are washed periodically in order to maintain the efficiency of their aerodynamic surfaces. (Dirt increases drag.)
Is Great Basin Wind planning to periodically wash the turbine blades to maintain their aerodynamic efficiency?
If so, how much water do they expect to use and where do they plan to get it?
Will they be trucking the water in?
Will they be drilling wells?
If they will be drilling wells, how many do they plan to drill? Have they bought water rights? How will their use of water be monitored?
How do you wash blades that are on 330 ft. towers?
March 22, 2009
14. The Washoe County Planning Commission had a meeting on March 10, 2009.
Here is the web page for the Washoe County Planning Commission:
http://www.co.washoe.nv.us/comdev/boards_commissions/pc/pc_agenda_minutes_index.htm
The members of the Washoe County Planning Commission are (according to the minutes of the 1/6/09 meeting):
Christy Magers, Chair
Dian A. VanderWell, Vice Chair
Neal Cobb
Roger M. Edwards
Roy H. Hibdon
Keith Lockard
William Weber
On the agenda for the March 10 meeting was the New Comstock Wind Project.
(Agenda: http://www.co.washoe.nv.us/comdev_files/bc/bc_pc_2009_agendas/031009ag.pdf)
5. NEW COMSTOCK WIND PROJECT – Information regarding the Environmental Impact Statement (EIS) being developed by the Bureau of Land Management (BLM) Carson City District-Sierra Front Field Office for the New Comstock Wind Energy project, which will analyze the potential impacts resulting from construction of the project. This project is being proposed for the Virginia Range north of Carson City and within Washoe, Storey and Lyon Counties.
BLM Staff Representative: Dan Jacquet, BLM, Carson City Office
Staff Representative: Bill Whitney, Planner, 775.328.3617
The Washoe County Planning Commission has posted a recording of the March 10 meeting:
http://www.co.washoe.nv.us/comdev_files/bc/bc_pc_2009_minutes/031009.MP3
It is a 47 MByte mp3 file and the audio level in the file is very low, so:
1. I converted it to a .wav file;
2. Selected out the section of the meeting devoted to the New Comstock Wind Project;
3. Boosted the volume level;
4. Converted it to a Microsoft wma file, specifying “mono” instead of stereo and reducing the bitrate to less than CD quality.
The resulting file is 5.6 MB. Click Here for the New Comstock Wind Project discussion. If you cannot use wma files, you can download the County’s mp3 file.
The following is not a summary of the meeting, just what caught my ear.
The following times are referenced to the wma file.
00:36 Start of the discussion of the New Comstock Wind Project. The Chair gives the floor to Bill Whitney, Department of Community Development. (44: 27 of the Washoe County mp3 file)
Mr. Whitney gives a brief description of how BLM’s Carson City Office is organized, the numerous projects BLM has already done with Washoe County, and the process of coordinating approval of BLM projects.
6:00 The Chair introduces Linda Kelly, Sierra Front Field Office Manager.
Linda Kelly points out the other members of her office who are at the meeting:
Ken Nelson - Realty Specialist
Jane Peterson , who will be giving the presentation
Dan Jacquet - Community Relations Liaison
Mark Struble - Public Information Officer
She also points out Rich Hamilton, President of Great Basin Wind.
07:50 Jane Peterson begins the presentation
10:20 - The Energy Policy Act of 2005 (NEPA) requires that, “10,000 MW of renewable energy projects will be located on public lands by 2015.”
[My observation: There are several types of renewable energy sources, like solar. Renewable does not automatically mean wind.]
21:30 Questions from the Commissioners
One Commissioner had a question about power transmission lines where only a portion went through public land and the other part was on private land.
Jane Peterson: It’s a difficult question to answer; we look at the actual impacts that would occur.
24:40 Commissioner Edwards: They have already done Environmental Impact Statements for other projects. Why does every Developer have to go through it? Why can’t they streamline the process? Doing an EIS for each project causes the project to be pushed off and more costly to the Developer.
27:40 Linda Kelly responds: BLM has to identify impacts and address public comments for each project.
31:17 The Chair explains to Commissioner Edwards that BLM is following the steps required by law and if he wants the law changed he should work through Congress
32:00 Commissioner Lockard says there are also ways around it.
Commissioner Edwards says BLM (since they are on the inside) should be the ones to say to Senator Harry Reid that the process should be streamlined. He then repeats his statements that, although he does not want to ignore community input, he wants BLM to streamline the process.
36:08 Jane Peterson: The steps are very well established and moving away from that process is probably the best way to make the document vulnerable to litigation.
36:38 Commissioner Lockard: How much wind energy will be produced, how it will meet the Community’s needs, and where will the project be located?
37:18 Jane Peterson has Rich Hamilton answer the question: The project will produce 200 MW. 1 MW will produce power for 300 homes. Gives location of project.
39:10 A Commissioner asks where the wind turbines will be produced. Are they American made?
Rich Hamilton responds: Most are foreign made. Great Basin Wind is looking at two American manufacturers.
40:20 Commissioner Lockard: Will the project require a Special Use Permit from Washoe County?
40:50 Bill Whitney from Community Development: Each County (Washoe, Carson, and Storey) will see the project as [needing] an individual Special Use permit.
41:42 The Chair reads a letter from Linda Bisset (Government Affair Division, Nevada Energy): NV Energy strongly supports the development of renewal energy resources such as wind, solar, and geothermal. NV Energy maintains a confidential RFP contract process with potential Developers. They do not share information about any particular project or Developer.
[It sounded diplomatic and non-committal to me.]
43:39 Request to speak from a member of the public: Stewart Smith
(1:27:38 of the Washoe County mp3 file)
[Then the mic seemed to go dead. Either Mr. Smith was not there or his remarks were removed from the recording.]
44:10 Request to speak from Danny Costello with the Iron Workers. He is for the project even though he lives in Washoe Valley and will see the towers.
44:49 Commissioner Lockard quoted from a document containing a section Help Identify Alternatives. He asked, “What kind of alternatives are there to windmills?”
Jane Peterson discussed alternatives to the project in terms of different turbine sizes and locations.
[My observation: There are different types of alternative energy. She did not discuss them.]
46:12 End of discussion of New Comstock Wind Project.
(1:30:05 of the Washoe County mp3 file)
If someone has a good speech recognition program and wants to make a transcript I would be happy to post it.
- Jed Margolin
15. New posting from BLM’s Web site for the project (September 24, 2009):
(http://www.blm.gov/nv/st/en/fo/carson_city_field/blm_programs/planning/new_comstock_wind.html)
Initial Public
Scoping December
2008-January 2009
Supplemental Scoping Fall 2009
Draft EIS
(DEIS)
Late 2010
Final EIS
(FEIS)
Early 2011
Record of Decision (ROD) Mid-2011
As of September 2009, BLM still considers this
project proposal by Great
Basin Wind, LLC (GBW), to be in the scoping phase.
GBW is in the process of revising their right-of-way application by
altering the specific BLM-administered lands proposed to be used for the wind
energy development and the number/location of specific wind turbine
towers - this is being done primarily to address concerns raised by the
public during early project scoping in late 2008-early 2009.
This revised proposal (including a revised project map) will be presented to the public and cooperating agencies during fall 2009 (meeting sites/locations are yet to be determined).
What I think (Jed Margolin)
1. The original schedule called for the Draft EIS in late 2009. (Click here: New Comstock Wind Proposal, PDF Page 14). The new schedule calls for Late 2010.
2. There will be more meetings (Fall 2009).
3. It looks like BLM listened to the public comments.
Thank you, BLM.
BLM’s new schedule contains a link to Great Basin Wind’s Web site: http://www.greatbasinwind.com/
Great Basin Wind has a page showing proposed views from various places, none of which are Virginia City or the Highlands.
http://www.greatbasinwind.com/projects/new-comstock/
Presumably, these are the views for the original proposal.
March 27, 2012
16. The project is canceled
From: http://www.blm.gov/nv/st/en/info/newsroom/2012/january/new_comstock_wind.html
Release Date: 01/31/12
Contacts: Lisa Ross, 775-885-6107, lross@blm.gov
News Release No. 2012-13
Carson City, Nev. — The Bureau of Land Management (BLM) Carson City District-Sierra Front Field Office, in cooperation with Great Basin Wind LLC (GBW), has cancelled the proposed New Comstock Wind Energy Project. GBW submitted a Type III right-of-way application to construct and operate a wind energy facility north of Carson City and west of Virginia City, Nevada.
On November 26, 2008, the BLM published in the Federal Register the Notice of Intent to prepare an Environmental Impact Statement (EIS) for the New Comstock Wind Energy Project. Because the Project has been cancelled, the EIS will not be completed.
For further information please contact Colleen Sievers, Project Manager, at 775-885-6000 or csievers@blm.gov.
The BLM manages more than 245 million acres of public land, the most of any Federal
agency. This land, known as the National System of Public Lands, is primarily
located in 12 Western states, including Alaska. The BLM also administers 700
million acres of sub-surface mineral estate throughout the nation. In Fiscal
Year (FY) 2011, recreational and other activities on BLM-managed land
contributed more than $130 billion to the U.S. economy and supported more than
600,000 American jobs. The Bureau is also one of a handful of agencies that
collects more revenue than it spends. In FY 2012, nearly $5.7 billion will be
generated on lands managed by the BLM, which operates on a $1.1 billion budget.
The BLM's multiple-use mission is to sustain the health and productivity of the
public lands for the use and enjoyment of present and future generations. The
Bureau accomplishes this by managing such activities as outdoor recreation,
livestock grazing, mineral development, and energy production, and by
conserving natural, historical, cultural, and other resources on public lands.
--BLM--
Last updated: 02-03-2012
I discovered this press release only today, by accident. (I was looking for something else.)
I was on the email list for the project. I didn’t get anything. You would think BLM would consider this news important to those of us who were interested enough to sign up for their email list.
I sent an email to Colleen Sievers and asked her why the project was canceled.
She responded:
Good Morning
The BLM cancelled the project because the company was not quite ready to move forward with development at this time. If you have more questions, please let me know.
Regards,
Colleen Sievers
Project Manager
BLM-Carson City District
5665 Morgan Mill Rd.
Carson City, NV 89701
That leaves the door open for the project to restart.
For her email, click here.
So, at least for now, the project has ended as it began, in stealth mode.
Jed Margolin
Virginia City Highlands, NV
June
21, 2009
Nevada Legislation
Nevada SB114 - Makes various changes
relating to systems for obtaining and using solar energy and other renewable
energy resources. (BDR 58-380)
It says it will have no fiscal impact on local government.
Nevada Senate homepage for SB114: Click
here.
Here it is as approved by the Governor: http://www.leg.state.nv.us/75th2009/Bills/SB/SB114_EN.pdf
Storey County Ordinance for Wind Energy Systems
August 5, 2010
Storey County is working on an ordinance regulating Wind Energy Systems.
To help the County I have written the following:
A Short Course on Sound and Human Hearing.
Click here for html (contains active links to references)
September 6, 2010
And now for Part 2:
A Short Course on Sound and Human Hearing - Part 2
Click here for html (contains active links to references)
.end