Commercial Wind Development in Vermont:
A Primer for Local Officials and Citizens
December 2005
“Windfarm Vermont” by Sabra Fields
Public Administration 306
Brendan Andrews
Marc Bilodeau
Erica Spiegel
DRAFT – Page 1
TABLE OF CONTENTS:
INTRODUCTION: -------------------------------------------------------------------------------------------------------------------------- 3
Purpose of the Guide--------------------------------------------------------------------------------------------------------------------- 3
ELECTRICAL POWER GENERATION IN VERMONT --------------------------------------------------------------------------- 4
The State Electricity Plan --------------------------------------------------------------------------------------------------------------- 3
THE POWER OF WIND: ------------------------------------------------------------------------------------------------------------------ 4
Wind Power in Vermont’s Past -------------------------------------------------------------------------------------------------------- 4
Wind Power in the Present -------------------------------------------------------------------------------------------------------------- 4
Wind Power and Public Opinion ------------------------------------------------------------------------------------------------------ 5
Where is the Wind in Vermont? ------------------------------------------------------------------------------------------------------- 5
APPLICABLE LAWS AND REGULATIONS: ---------------------------------------------------------------------------------------- 6
The Vermont Public Service Board and Title 30 V.S.A. -------------------------------------------------------------------------- 6
The “Section 248” Process ------------------------------------------------------------------------------------------------------------- 6
Is “Section 248” the Right Process? -------------------------------------------------------------------------------------------------- 7
WHAT CAN LOCAL OFFICIALS DO? ------------------------------------------------------------------------------------------------ 7
Municipal and Regional Plans - Why They Matter! ------------------------------------------------------------------------------- 7
Why Address This Issue in a Town or Regional Plan? ---------------------------------------------------------------------------- 8
Case Studies and Sample Language --------------------------------------------------------------------------------------------------- 9
Bennington, Vermont ---------------------------------------------------------------------------------------------------------------------- 9
Newberry, Vermont ---------------------------------------------------------------------------------------------------------------------- 10
Montgomery, Vermont ------------------------------------------------------------------------------------------------------------------ 10
Middlebury, Vermont -------------------------------------------------------------------------------------------------------------------- 10
Northeastern Vermont Development Association ----------------------------------------------------------------------------------- 11
TECHNICAL ISSUES: ------------------------------------------------------------------------------------------------------------------- 11
Siting Wind Turbines ------------------------------------------------------------------------------------------------------------------ 11
Mechanical Issues ---------------------------------------------------------------------------------------------------------------------- 11
Size of Turbines--------------------------------------------------------------------------------------------------------------------------- 11
Wind Speed -------------------------------------------------------------------------------------------------------------------------------- 12
Safety --------------------------------------------------------------------------------------------------------------------------------------- 12
Noise ---------------------------------------------------------------------------------------------------------------------------------------- 12
Use and Output ---------------------------------------------------------------------------------------------------------------------------- 12
Wind Turbine Aesthetics -------------------------------------------------------------------------------------------------------------- 12
Mitigating Aesthetic Impacts --------------------------------------------------------------------------------------------------------- 13
Roads --------------------------------------------------------------------------------------------------------------------------------------- 13
Transmission Lines and Substations -------------------------------------------------------------------------------------------------- 13
Uniformity of Wind Turbines ---------------------------------------------------------------------------------------------------------- 13
Color of Turbines ------------------------------------------------------------------------------------------------------------------------- 14
Lighting ------------------------------------------------------------------------------------------------------------------------------------ 14
Environmental Considerations ------------------------------------------------------------------------------------------------------- 14
Wildlife ------------------------------------------------------------------------------------------------------------------------------------- 14
Erosion ------------------------------------------------------------------------------------------------------------------------------------- 15
Emissions ---------------------------------------------------------------------------------------------------------------------------------- 15
Land Clearance---------------------------------------------------------------------------------------------------------------------------- 15
Economic Considerations ------------------------------------------------------------------------------------------------------------- 15
Land Values ------------------------------------------------------------------------------------------------------------------------------- 15
Impacts on Tourism ---------------------------------------------------------------------------------------------------------------------- 16
Economic Development ----------------------------------------------------------------------------------------------------------------- 16
SUMMARY & CONCLUSIONS: ------------------------------------------------------------------------------------------------------ 17
INFORMATION RESOURCES: ------------------------------------------------------------------------------------------------------- 18
VERMONT WIND RESOURCES MAP: -------------------------------------------------------------------------------------------- 15
DRAFT – Page 2
with Hydro-Quebec will expire. As such, Vermont
must begin the process of diversifying its energy
portfolio.
A more diverse energy portfolio
increases stability and decreases vulnerability,
preventing Vermont from becoming too
dependant on any one source of electricity.
INTRODUCTION:
Purpose of the Guide
Recognizing that local officials and town planners
play in important role in the current wind power
debate, this guide is intended to give those
decision makers, as well as citizens, a “road map”
to the various issues and information resources
surrounding wind power development in
Vermont. This guide specifically does not address
“small wind” projects, as defined as turbines
under 120 feet in height and with blades less than
20 feet in diameter; but rather, focuses on “big
wind” or commercial wind power projects.
Part of the state permitting process for power
generating facilities, including wind turbines,
considers the compatibility of a proposed project
with applicable local town plans and regional
plan. It is important that towns and regional
planning organizations recognize the important
role their planning documents have. Likewise, it
is important for local officials and citizens to have
the proper information to help determine how to
address this potential land use within their
planning documents.
For utility-scale wind
energy to be successful in Vermont, local officials
must understand and address both the real and the
perceived environmental and community impacts.
Renewable energy sources will be increasingly
vital to Vermont’s future energy portfolio if the
state is to become more energy self-sufficient.
Currently, renewable sources of energy supply
twelve to fifteen percent of Vermont’s total
energy needs.2
While hydroelectric power
comprises the majority of that percentage, over
time, wind power will grow to be an important
component of renewable energy.
The State of Vermont Department of Public
Service released the “Vermont Electric Plan
2005” in January 2005. This almost 300 page
document mostly catalogues and documents the
state’s existing energy system. Despite its name,
the document does not specifically plan for the
state’s energy future, admitting “this plan does not
and cannot responsibly prescribe a specific
electric supply portfolio for Vermont utilities. The
electricity market is complex and ever changing.”
The document does lay out long range goals,
specific objectives and recommended actions to
meet Vermont’s future electricity needs. The
complete document is available on the web at:
http://publicservice.vermont.gov/pub/stateplans/state-plan-electric2005.pdf.
ELECTRICAL POWER
GENERATION IN VERMONT:
The State Electricity Plan
Vermont is on the cusp on an energy
transformation. Currently, just two sources – the
Vermont Yankee Nuclear Power Plant and HydroQuebec - supply two thirds of Vermont’s
electricity.1 However, within the next ten years,
those two sources may no longer be available. In
2012, Vermont Yankee’s federal license will
expire, and in 2016 the state of Vermont contract
Vermont Department of Public Service, “Vermont’s Power
Supply, 2003.”
<http://publicservice.vermont.gov/electric/electric.htm>.
1
The Vermont Public Interest Research Group
(VPIRG) was critical of the plan released by the
Department of Public Service. VPIRG pointed out
that it will take longer than two years to create the
new electrical capacity needed to replace Vermont
Yankee. Permits must be filed under a lengthy
state process and developers need time to line up
investors and do research in order to present their
case to the Public Service Board. Thus, VPIRG in
support of renewable sources of energy notes that
action must be taken now to incorporate those
sources into the state’s energy portfolio.
Vermont Department of Public Service, “Electric Plan
2005.” (2005). <http://publicservice.vermont.gov/pub/stateplans/state-plan-electric2005.pdf>.
2
DRAFT – Page 3
In addition to energy efficiency and other forms of
renewable power, VPIRG advocates that 15% of
the state’s future electric be derived from
commercial wind power.
THE POWER OF WIND:
Wind Power in Vermont’s Past
Historically, Vermont had been a leader in wind
energy production. The first commercial wind
turbine in the United States, the Smith-Putnam
turbine, became operational in 1941 on Grandpa’s
Knob, twelve miles south of Rutland.3 The
turbine generated electricity and supplied that
electricity to the local grid until 1945,
demonstrating that “wind…could be harnessed on
a large scale.”4 Supply shortages during World
War II shut down the turbine and for unknown
reasons n, the turbine never came back on line
after the War’s end. In the early 1980’s, a private
company erected and operated four turbines near
Manchester, Vermont, but these operated
sporadically and were dismantled several years
later.5
Today, Vermont’s only commercial wind farm is
located in Searsburg in southern Vermont. In
1997, when the Searsburg Wind Project was
completed by the Green Mountain Power
Corporation, it was the first commercial wind
farm east of the Mississippi River.6 However,
since that time, many other states have passed
Vermont in terms of developing viable
commercial wind power sources.
Wind Power in the Present
The Vermont Public Interest Research Group
(VPIRG) issued a report, “Clean Energy in
Vermont: A Plan Today for Tomorrow in the
Summer 2004.” In it, VPIRG describes one of
the bigger challenges facing the state as “the one
big answer” mindset. VPIRG advocates a mixture
of energy sources to end Vermont’s dependence
on its two current major sources. There is no
magic source that will meet all the state’s needs.
3
Robert W. Righter, Wind Energy in America: A History, p.
131.
4 Righter, p. 134.
5 http://publicservice.vermont.gov/energyefficiency/ee_files/wind/windpacket.htm
6 Renewable Energy Vermont, Vermont Wind: Looking
Towards Our Energy Future, DVD, 2004.
Since 2000, several new wind farms have been
proposed, but few have completed the state review
process. Most of the proposals have triggered
local opposition and have been slowed by the
state’s reticence to embrace commercial wind
farms. Instead, Vermont has chosen to focus wind
energy development on a smaller, “Vermontscale” which promotes individual and residential
applications for wind turbines and is incompatible
with larger, commercial projects.7
The policy challenge now in the state is how to
appropriately balance the long-term energy needs
of all Vermonters, with the concerns of the small
and localized interest groups that are more
directly affected by the presence of large wind
turbines.
VPIRG’s complete report: “Clean Energy in
Vermont: A Plan Today for Tomorrow” is
available
on
their
website:
http://www.vpirg.org/downloads/2004.08.27_Clean_
Energy_for_Vermont_final_version.pdf
Many say that wind energy is a natural fit for
Vermont. Wind is abundant and free and does not
pollute the environment. Increasing the state’s
reliance on wind energy will continue a tradition
begun in the 1940’s on a hill outside of Rutland.
Thus, state policies and administrative processes,
as well as local planning documents must address
the development of large scale commercial wind
projects for that legacy to continue.
Some industry experts estimate that developing
six to ten commercial wind sites in Vermont could
supply ten to twenty percent of the state’s energy
needs, greatly reducing the state’s dependency on
both out-of-state and non-renewable electricity
resources.8
In July of 2004, Governor Jim Douglas issued an
executive order to create a Commission on Wind
“Meeting Vermont’s Energy Needs,” Opinions by Gov. Jim
Douglas and Mayor Peter Clavelle, Burlington Free Press, 22
Aug. 2004.
8 Ibid.
7
DRAFT – Page 4
Energy Regulatory Policy. The Commission, in
the course of its work, recognized and reaffirmed
that “there is no statewide consensus on the
development of large wind generation projects in
Vermont.”9
however, support tends to increase once again
when the project is complete and operational.
Wind Power and Public Opinion
Renewable Energy Vermont, in conjunction with
ORC Macro, conducted a general survey of
Vermont
residents
in
March
2004.
Overwhelmingly, Vermonters favored using
renewable sources energy over nuclear, coal, oil
and natural gas. The survey also included a
question on visibility and aesthetic acceptability
of wind turbines. The survey, of four hundred
Vermonters from across the state, found that 74%
of the respondents said they would consider wind
turbines along a Vermont mountain ridge either
beautiful or acceptable.
A copy of the REV survey is available on the web
at: http://www.revermont.org/Macro_poll.pdf
VPIRG conducted a similar survey, which
demonstrated that “the vast majority of
Vermonters support wind power development,” as
evidenced by the 11,000 signatures VPIRG
gathered in the summer 2003 in support of
renewable energy and the more than 1,000
Vermonters who testified or wrote comments in
support of siting wind power on state lands during
the winter 2004 Agency of Natural Resource
hearings.10
However, as the chart below demonstrates,
acceptance of commercial wind energy projects
can be inconsistent. Acceptance for wind energy
projects, in the abstract, is typically high. Support
generally lessens when actual projects are
proposed and constructed. After installation,
Commission on Wind Energy Regulatory Policy, “Findings
and Recommendations,” 2004, 4-12.
<http://publicservice.vermont.gov/energyefficiency/ee_files/wind/WindCommissionFinalReport-1215-04.pdf>.
10 Vermont Public Interest Research Group, “Clean Energy
for Vermont: A Plan Today for Tomorrow,”
<http://www.vpirg.org/downloads/2004.08.27_Clean_Energy
_for_Vermont_final_version.pdf>.
9
Source: Wind Power In View
Where is the Wind in Vermont?
Developers consider many factors when choosing
a potential site, but primarily consider who owns
the land and the “speed and sustainability” of the
wind at a particular site.11
The wind industry has developed a seven-tiered
system for classifying the speed of the wind. A
Class 1 wind site has insignificant average wind
speeds; whereas, a Class 7 wind site has very high
winds.12
Wind Class
Class 1
Class 2
Class 3
Class 4
Class 5
Class 6
Class 7
Wind Speed (mph)
11.4 mph
13.2 mph
14.6 mph
15.7 mph
16.6 mph
18.3 mph
24.7 mph
Sites in the state that have Class 4 or better
average wind speeds are typically “of interest to
developers.”13
However, wind studies done
across the state show that very little land within
the state is suitable for commercial wind
development.
Colin Haller, “Does a Manager Know Which Way the
Wind Blows?” Public Management, May 2004, 25.
12 “Vermont Agency of Natural Resources Wind Fact
Sheets,”
<http://vermontwindpolicy.org/factsheets/glossary1.pdf>.
13 Ibid.
11
DRAFT – Page 5
The Department of Public Service, together with
Green Mountain Power Corporation, NRG
Systems, and Vermont Environmental Research
Associates, Inc. (VERA), conducted a wind
resource assessment for Vermont to identify
where wind energy projects could be developed.
The project “conducted measurements at four sites
across the state that were representative of the
wind resource needed for commercial wind
developments. The measurement sites were
geographically and topographically dispersed.”14
The VERA study found that just 2.9% of the land
in the state has the wind capacity to be suitable for
commercial wind development. Of that total,
15% is federally owned land, mostly in the Green
Mountain National Forest, 17% is state owned
land, and .14% is owned by various local
governments.15 Nearly all of the state-controlled
public land in Vermont is under the jurisdiction of
the Agency of Natural Resources. The Agency of
Natural Resources has previously announced its
policy not to allow any large-scale wind energy
development on state owned lands, further limited
the potential land available for commercial
development. The remainder is privately held
land.
Thus, the amount of land that is
economically and physically suitable for wind
power is very small.
A copy of the “State of Vermont Wind Resources
and Transmission” map is attached.
APPLICABLE LAWS AND
REGULATIONS:
The Vermont Public Service
Board and Title 30 V.S.A.
quality of service, and overall financial
management of Vermont's public utilities, which
includes electric power companies.16 The work of
the Board is guided by Title 30 of the Vermont
Statutes Annotated, which covers issues related to
public service. One of the functions of the Public
Service Board is to review the environmental and
economic impacts of all energy purchases and
facilities in Vermont. Through hearings and other
legal proceedings, if the Board determines that a
particular proposal or project is in the best
interests of the public in the state, then it issues a
“Certificate of Public Good.”
While Title 30 does not precisely define “the
public good,” the statute does establish criteria on
which entities and proposals must be evaluated.
The Public Service Board is charged with
reviewing proposals and will approve projects if
“the Public Service Board first finds that the same
[activity] will promote the general good of the
state.” 17 Only then will it “issue a certificate to
that effect.”18
The “Section 248” Process
The relevant section of Title 30 of the Vermont
Statutes Annotated that governs how new
electrical power plants are approved is commonly
referred to as “Section 248.” Public participation
in the Section 248 process is generally limited to
the immediate affected municipality and other
groups like the Agency of Natural Resources and
the Department of Public Service that have party
standing in the proceedings. The process includes
a series of public and technical hearings designed
to discover the impact of a particular project. This
process can be rather intimidating; hence, a
forthcoming “Guide to the Vermont Public
Service Board’s Section 248 Process” will soon
be available from the Department of Public
Service (DPS) in print and online.
The Vermont Public Service Board (PSB) is a
“quasi-judicial board” that supervises the rates,
“Mission Statement, Vermont Public Service Board,
<http://www.state.vt.us/psb/site/mission.stm>.
17 Title 30 Vermont Statutes Annotated,
<http://www.leg.state.vt.us/statutes/sections.cfm?Title=30&C
hapter=005>.
18 Ibid.
16
“Vermont’s Wind Resource,” Vermont Department of
Public Service, <http://publicservice.vermont.gov/energyefficiency/ee_files/wind/ee-wind.htm>.
15 Ibid.
14
DRAFT – Page 6
Is “Section 248” the Right
Process?
criteria of Act 250 are incorporated into the
Section 248 process by reference.
In July 2004, Governor Douglas issued an
executive order to create a Commission on Wind
Energy Regulatory Policy. This commission was
given the specific task of evaluating whether the
existing regulatory framework for siting and
permitting power plants in Vermont (30 V.S.A
Section 248) was the appropriate review process
for commercial wind generation projects.
Currently under state law, Section 248 projects are
exempt from local zoning and from Act 250,
Vermont’s Land Use and Development Law.
Based on the recommendations of the Vermont
Commission on Wind Regulatory Policy, in
October 2005, the Public Service Board proposed
new rules for the Section 248 process to apply to
wind power projects specifically. These rules
would apply to any new applicants, establishing
more stringent requirements, most notably,
requiring developers to notify the affected
communities sixty days before applying for a
Certificate of Public Good and expanding the
notice requirement to all communities within to a
ten-mile radius of a proposed wind turbine.
After five months of research, hearings, and
deliberation, the Commission issued its final
report in December 2004. It noted that “Section
248 is the appropriate vehicle for siting
commercial
wind
generation
projects.”19
However, it recommended that several
modifications be made to the Section 248 process
for wind projects due to their “unique
characteristics.”20
The complete report of the Vermont Commission
on Wind Regulatory Policy is available at:
In its report, the Commission examined the
differences between Section 248 and Act 250 in
great detail. The fundamental difference between
the two regulatory processes is the notion of
public good. The Commission found that Section
248 is “more appropriate for reviewing proposed
wind generation projects due to the requirement
that the Public Service Board (PSB) consider
‘public good,’ including a project’s impact on the
state’s energy needs.”21 Unlike Section 248, Act
250 does not include consideration of public good.
Municipal and Regional Plans Why They Matter!
http://publicservice.vermont.gov/energyefficiency/ee_files/wind/WindCommissionFinalRepo
rt-12-15-04.pdf.
WHAT CAN LOCAL
OFFICIALS DO?
Before the Public Service Board (PSB) will issue
a Certificate of Public Good, it must determine
whether any proposed project, in this case, a
commercial wind farm:
“will not unduly interfere with the
orderly development of the region
with due consideration having been
given to the recommendations of the
municipal and regional planning
commissions, the recommendations
of the municipal legislative bodies,
and the land conservation measures
contained in the plan of any affected
municipality.”23
The report concluded that “applying both Section
248 and Act 250 to proposed wind generation
projects would result in a duplicative and
inefficient process, and serve to diminish the
PSB’s authority to consider statewide ‘public
good’ in its deliberations.”22 In fact, most of the
19
Vermont Commission on Wind Energy Regulatory Policy:
Findings and Recommendations,” 15 Dec. 2004,
<http://publicservice.vermont.gov/energyefficiency/ee_files/wind/wind_commission_final_report1215
04.pdf>.
20 Ibid.
21 Ibid.
22 Ibid.
23
30 V.S.A. § 248,
<http://www.leg.state.vt.us/statutes/fullsection.cfm?Title=30
&Chapter=005&Section=00248>.
DRAFT – Page 7
Thus, planning and land use documents become a
critical factor in determining whether or not a
project qualifies for a Certificate of Public Good.
Why Address This Issue in a
Town or Regional Plan?
The Vermont Planning Information Clearinghouse
(VPIC) suggests that since municipalities cannot
regulate utilities through zoning bylaws, in
addition to expressing their views during Public
Service Board hearings, they must modify their
planning and land use documents to reflect their
values and opinions about public utilities like
wind turbines. VPIC suggests that “participation
in that review process can be buttressed by
adopting policies on wind and other similar
projects in the municipal plan.”24
Vermont municipalities enact plans pursuant to 24
V.S.A § 4302, Vermont’s Planning and
Development Act.25 Plans must contain ten
specific sections or “elements,” including a
section about a town’s “energy plan.”26 It must
include “an analysis of energy resources, needs,
scarcities, costs and problems with the
municipality, a statement of policy on the
conservation of energy…to implement that policy,
a statement of policy on the development of
renewable energy resources, a statement of policy
on patterns and densities of land use likely to
result in conservation of energy.”27
Other
required elements in a town plan include a utility
and facility plan map, showing existing and
proposed public sites including power generating
plants and power lines and a statement on the
preservation of “rare and irreplaceable natural
areas, scenic and historic features and
resources.”28
Vermont Planning Information Clearinghouse, “Chapter
117 Frequently Asked Questions,”
<http://www.vpic.info/chapter117/faqs/zoning.htm#34>.
25 Title 24, Vermont Statutes Annotated,
<http://www.leg.state.vt.us/statutes/chapters.cfm?Title=24>.
26 Ibid.
27 Vermont Department of Housing and Community Affairs,
“Planning Manual for Vermont Municipalities,” 137.
28 Ibid.
24
The Department of Public Service published a
“Guide to Municipal Energy Planning” to help
towns form the “energy element” of their town
plans, as required by the state’s Planning and
Development Act. Although written in 1993, this
guide is still cited by both DPS and VPIC as the
primary planning tool for towns on this topic. The
Guide describes the process of creating a plan,
suggests a model of how to structure a plan, and
gives some technical information on available
energy sources.
With respect to wind energy development, the
1993 guide recommends notes that “the most
appropriate role for the energy committee [of the
town] may be to become a local informed
resource on the subject and to provide support for
proposed private wind generators in the town.”
With respect to commercial “wind farms,” the
1993 guide says:
“A vision for the future of large-scale
wind energy in Vermont might include
a small number of wind farms, each
from 25 to 200 acres, in relatively
remote locations throughout the state.
The typical wind farm might have 100
generators in the 250-500 kW range
(having rotor diameters of 65 – 100
feet). These sites are less likely to be on
prominent mountaintops because of
concerns about their visual impact in
scenic areas.”
The complete “Guide to Municipal Energy
Planning” is available from the Department of
Public Service. It is not a document currently
available in digital format on their website.
Thus, the most practical way in which a town or
community can influence the development of
commercial wind power - either through
restrictive or permissive language - is by
addressing the issue in its town plan. While town
and regional plans cannot deny projects that serve
the “public good,” plans can be used to express
the values of a town by restricting the height of
structures; limiting construction of any
development above a certain elevation; protecting
views from public or historic buildings, declaring
a hillside or mountain a prominent view shed, or
conversely, by expressing acceptance of wind
DRAFT – Page 8
farms by describing techniques to encourage
development.
Wind turbines are connected to the energy grid
and hence are considered utilities. In contrast, cell
phone telecommunications towers are not. Title
24, Section 4409 does not allow municipal bylaws
to prohibit certain land uses from locating within a
municipality to ensure that uses intended to serve
community or “public” goods are not denied a
reasonable opportunity to locate in Vermont.29
While municipalities may - through a local zoning
bylaw or ordinance - regulate cell towers, they
cannot enact laws related to commercial wind
turbines.
Since municipalities do not have jurisdiction over
regulating commercial power generation, the
Vermont Land Use Education and Training
Collaborative suggests:
“Communities that want to influence the
location of generation and transmission
facilities within their borders should
identify and address related concerns –
and define clear community standards
to be applied to such projects – in their
municipal plan, for consideration in the
Public Service Board’s Section 284
review process.”30
Many business-savvy developers will “scope out”
a potential project ahead of any formal project
proposal or permit submissions. This is an early
opportunity for local officials and citizens in the
surrounding community to give initial feedback as
developers investigate the environmental,
economic and social and political impacts of a
project.
issue for every town, nor will all towns view
commercial wind energy in the same way, the
case studies below provide examples of varying
degrees of permissive or exclusionary language
that could be included in a town plan to reflect a
town’s stance on commercial wind energy
development, whatever it may be.
Hinesburg, Vermont
The Town of Hinesburg updated its plan in June
of 2005 to reflect its values about commercial
wind energy. This represents one of the more
accepting town plans for commercial wind
energy. In the energy section of its plan,
Hinesburg notes that “reliance on imported fuels
negatively affects the local economy.”31 The
Town goes on to explain how it will support the
development of alternative energy sources by
“working with developers to find suitable sites for
wind generators…and by exploring town tax
incentives to encourage the use of renewable
energy systems.”32 It also pledges to “preserve
any existing or potential renewable source by
exploring amending zoning regulations to make
sure landscaping and new structures do not
interfere with…valuable access to the wind.”33
Collectively, these statements convey a sense of
acceptance for commercial wind turbines.
Bennington, Vermont
The Town of Bennington, in a draft copy of its
Town Plan, also notes the importance of
renewable sources of energy:
“Generation of energy from renewable
energy resources supports conservation
of non-renewable energy resources
while helping to maintain a clean
environment….The
Town
should
support development of renewable
energy generating equipment where
appropriate and cost-effective. Support
programs and facilities that provide
Case Studies and Sample
Language
Many town plans do not specifically address wind
energy or provide any indication of town values
regarding commercial wind energy development.
Given that commercial wind energy is not a major
29
24 V.S.A. § 4409,
<http://www.leg.state.vt.us/statutes/fullsection.cfm?Title=24
&Chapter=117&Section=04409>.
30 Vermont Land Use Education & Training Collaborative,
Bulletin #5, November 2004.
“Hinesburg Town Plan 2005,”
<http://www.hinesburg.org/townplan_current.html>.
32 Ibid.
33 Ibid.
31
DRAFT – Page 9
stable, affordable, and clean renewable
sources of energy.”34
However, Section 4.7 of the town’s zoning laws
includes height restrictions which say that:
“No structure in any district shall
exceed the maximum height specified
for that district, but this limit shall not
apply
to
spires
but…including
windmills, solar collectors or similar
structures.”
goal.36 The plan lists the goals the town would
like to obtain including “limiting developing on
slopes greater than fifteen percent, maintaining
natural vegetation on slopes, limiting development
above 1,600 feet in elevation to preserve scenic
ridgelines, and promoting development in areas of
existing infrastructure.”37 These goals provide
some insight into the values of the town – it does
not want development to occur along its
ridgelines.
Newberry, Vermont
Middlebury, Vermont
The Town of Newberry is in the process of
updating its town plan. While most of the land
within the town is not at an elevation high enough
to be suitable for commercial scale wind
development, the town chose to articulate a set of
values regarding wind energy as a symbolic
statement:
Middlebury has also recently updated its town
plan in a number of areas, including issues related
to wind energy. The excerpt from the 2000 Town
Plan uses unequivocal language to demonstrate
the town’s stance against large scale wind energy
development:
“The benefits of alternative generation
must be weighed against the aesthetic
impacts and siting must not despoil
important public scenic views. Wind
generators are not appropriate in the
downtown historic districts or in
locations that substantially interfere
with the setting of historic landmarks.
To protect the general scenic character
of the Town, this Plan does not provide
for commercial wind farms or
individual wind generators over 110’
high.
Permitting of alternative
generation facilities should continue
under the conditional use review process
and additional safeguards as specified in
the Zoning.”38
“While there are benefits in capturing
renewable energy, the location and
design of wind generators can adversely
interfere with scenic and historic
resources. Project planning and design
must incorporate planning principles
that are sensitive to the landscape or
character of the area. Highly visible
projects should be planned to fit the
context of the setting. No project should
unduly impact a scenic or historic
resource or site.”
Montgomery, Vermont
The 2005 Montgomery Town Plan enumerates
several goals that provide insight into the town’s
stance on wind energy. The town lists the
“development of renewable energy resources” as
an important goal.35 However, the plan also
suggests the “development of site plan review in
the zoning bylaws to enable the town to impose
conditions regarding the utilization of renewable
energy resources” should also be an important
“Bennington Proposed Town Plan,
<http://www.bennington.com/government/PUTPD.PDF>.
35 “Chapter 10 Energy,” Montgomery Town Plan 2005,
http://vermonttowns.org/montgomery/townplan/10Energy.pdf
34
Middlebury provides, perhaps, the best example
of a town plan that includes language to clearly
articulate a set of values and a vision about wind
turbines within its boundaries.
36
Ibid.
“Chapter 15 Land Use,” Montgomery Town Plan 2005,
http://vermonttowns.org/montgomery/townplan/15LandUse.pdf
38 “Middlebury, Vermont 2005 Town Plan,”
<http://www.middlebury.govoffice.com/vertical/Sites/%7BC
A36F8A3-652B-4085-AA8EDD3623CC0020%7D/uploads/%7B30501156-D66B-4DE1ABF6-B99476352AE3%7D.PDF>.
37
DRAFT – Page 10
Northeastern Vermont Development
Association
Regional planning agencies in Vermont are also
articulating their opinions about commercial wind
energy within their planning documents. The
Northeastern Vermont Development Association
(NVDA) recently issued its draft 2005 regional
plan which supports larger scale wind tower
development within its region:
TECHNICAL ISSUES:
This section is intended to give local officials a
brief overview of the numerous technical,
aesthetic, environmental, and financial issues
concerning wind power, and to provide references
on where to find further information on specific
concerns.
Siting Wind Turbines
“The region should acquire and use
energy in a way that benefits the
region’s economic vitality.
Wind
towers should be seen as beneficial to
the region. As a statement of policy,
NVDA supports the construction of
wind towers. We believe this is too
important a power source to be
excluded from our overall energy mix.
At the same time, the Board does not
believe wind towers should be imposed
on communities that don't want them
within their borders. Therefore, town
plans that exclude the construction of
wind towers will still be considered in
compliance with the Regional Plan.” 39
From an engineering stand point, both optimal and
suboptimal sites exist for locating a wind turbine.
In Vermont, the most advantageous location for
siting wind turbines is along ridgelines where
there are “favorable winds.”40 The west to east
flow of the wind and the increasing strength of the
wind at higher elevations makes “Vermont’s
topography particularly well-suited for wind
generation.”41 However, as previously discussed,
only a few locations exist that meet the necessary
wind criterion, are “both accessible and yet
remote enough,” and are economically and
politically feasible.42
While the plan does support commercial wind
energy development, it also allows individual
towns to articulate a different point of view.
These six case studies exemplify how towns and
regional planning commissions can modify their
planning documents to address commercial wind
energy. Whether through general statements of
support for commercial wind or through
increasing levels of restrictiveness, town plans
can be made to reflect the vision and opinions of
particular communities. Regardless the vision,
articulating that vision is critical. It provides
written proof and a vision, which is heavily relied
upon in the Section 248 regulatory process.
Mechanical Issues
Size of Turbines
As technology has advanced, wind turbines have
gotten larger and can produce more electricity.
The Searsburg Wind Project facility has eleven
550 kilowatt turbines that are each 198 feet high
to the top of the rotors.43 While the technology
was state-of-the-art at the time, today, to produce
the same 6 megawatts of electricity, only three to
four turbines would be necessary. The average
wind turbine used today has a hub height of 200 to
250 feet high, with total heights ranging from 300
to 450 feet high.44
40
David Inglis, Wind Power and Other Energy Options, 49.
Vermont Department of Public Service, “Wind Energy
Planning Resources for Utility-Scale Systems in Vermont,”
October 2002.
42 Ibid.
43 “The Existing Searsburg Wind Facility,”
<http://www.searsburgwind.com/current/index.html>.
44 Technical Manuals: GE, Vestas, Mitsubishi.
41
Northeastern Vermont Development Association, “Draft
Regional Plan,”
<http://www.nvda.net/pdf/regionalplan/DraftRegionalPlan20
05.pdf>.
39
DRAFT – Page 11
turbines in icy conditions can reduce the
prevalence of ice throw.48
Noise
When rotating, wind turbines do produce a
“whooshing sound” as they encounter turbulence
in the air.49 However, that sound is often masked
by other background noises and the levels of noise
produced are typically “no higher than that of a
moderately quiet room or a refrigerator at
distances of 750 to 1,000 feet.”50
Use and Output
Source: Vermont Agency of Natural Resources
Wind Speed
“Cut in speed” refers to the minimum wind speed
needed to turn the rotors. A typical 1 to 2 MW
turbine has a cut in speed of 8 mph. “Cut out
speed” refers to the wind speed that will force a
turbine to shut down. The typical cut out speed is
56 mph. Minimum wind speed to achieve
turbines rated output is 27-32 mph. Revolutions
per minute range from 5 to 21 depending on size
and wind speed.
Safety
The biggest safety concern about wind turbines
has been about “ice throw.”45 In the winter, ice
accumulating on the spinning blades of a turbine
can be projected outward from the turbine. The
prevalence of ice throw has not been clearly
established.46 Some studies demonstrate that
chunks of ice up to 2.5 pounds can be throw
distances of 600 to 825 feet; however, most of the
time, ice simply falls off the blades.47 Measures
can be taken to minimize the effect of ice throw.
Using black blades, which are warmed by the sun,
helps keep ice from accumulating on the blades in
winter and installing automatic shutoffs for
An average household consumes about 750
kilowatt-hours per month. A 1.5 megawatt turbine
operating at peak efficiency produces 1,000 kWh
every hour and enough to power five hundred
homes in Vermont.
The average cost for
electricity generated by wind turbines is 5
cents/kWh, compared with 4.8-5.5 cents/kWh for
coal, 5.1-11.3 cents/kWh for hydropower, and
11.1-14.5 cents/kWh for nuclear power.51
Wind Turbine Aesthetics
One of the more divisive issues surrounding wind
power development in Vermont is a question of
aesthetics. There is considerable literature, both
applied and academic, about landscape aesthetics.
Unfortunately, the visual impacts of a project are
the least quantifiable of all criteria.
“Some members of a community may
find wind turbines
unappealing,
unsuitable for a given landscape,
industrial in appearance, or even
downright ugly. Many others find them
suitable in a proposed location, graceful
“Vermont Agency of Natural Resources Wind Fact
Sheets,”
<http://www.vermontwindpolicy.org/factsheets/Wind%20En
ergy%20Overview2.pdf>.
49 “Wind Energy Myths,” U.S. Department of Energy Office
of Energy Efficiency and Renewable Energy.
50 Haller, 27.
51 Ibid, 25.
48
“Vermont Agency of Natural Resources Wind Fact
Sheets,”
<http://www.vermontwindpolicy.org/factsheets/FAQ1.pdf>.
46 Ibid.
47 Ibid.
45
DRAFT – Page 12
in their slow-moving sweep, and may see
in them a majestic beauty.” 52
Much of the literature says that aesthetic values
and beliefs must be viewed in their cultural and
historic contexts. Some have argued that Vermont
has a history and a culture of a “working
landscape,” which includes barns, silos, water
towers, ski lifts, and communication towers.
Arguably, all of these visible objects have become
part of the state’s working landscape.
Likewise, the issue of aesthetics involves the issue
of visibility. For most Americans, including
many Vermonters, electricity generation and
distribution is a vague concept. Most do not see
where their electricity is generated.
The
development of commercial wind turbines
challenges that invisibility of electricity
generation by creating a highly visible and
moving source of electricity generation.
are often built wider than absolutely necessary.54
Minimizing the width of the road and by using
natural vegetation to screen the road, these access
roads typically cannot to be seen from off site.
Transmission Lines and
Substations
Transmission lines from the turbines to a
transformer and to a substation can be buried to
reduce maintenance costs and to keep them from
being seen. Substations can be painted dark
colors and screened with natural vegetation to
further reduce visual impact.
The picture below shows the preferred way for
mitigating the visual impacts of transmission lines
and substations.
Thus, the development of future projects will
“depend on the efforts of government and industry
to mitigate environmental objections and the Not
In My Backyard (NIMBY) phenomenon.”53
Mitigating Aesthetic Impacts
Techniques exist to diminish the aesthetic impact
of wind turbines. Town planners can work with
developers to ensure that projects will not create
an undo aesthetic burden on the landscape and for
local residents.
Roads
Roads to and from the proposed site of the
turbines need to be wide enough to accommodate
the crane needed to erect the turbines. After
initial construction, roads are needed for site
access for routine maintenance. However, roads
Source: Wind Power In View
Uniformity of Wind Turbines
An important aesthetic criticism of commercial
wind projects is their lack of “visual order.”55
Wind farms with wind turbines of varying design
and height appear cluttered, becoming prominent
and unsightly features of the landscape.
52
U.S. Department of Energy, New England Wind Forum,
<http://www.eere.energy.gov/windandhydro/windpoweringa
merica/ne_issues_yard.asp>.
53 Robert Righter, Wind Energy In America: A History,
(Norman Oklahoma: University of Oklahoma Press, 1996),
275.
54
Martin J. Pasqualetti, Paul Gipe, & Robert W. Righter,
Wind Power in View, (San Diego: Academic Press, 2002),
196.
55 Ibid, 180.
DRAFT – Page 13
Lighting
Source: Wind Power In View
By restricting wind turbines to a uniform size and
by clustering towers into smaller groups,
designers can bring order to projects and reduce
the visual impact of wind farms.
The Federal Aeronautics Administration (FAA)
requires that all structures over 200 feet in height
or within 3.75 miles of a commercial runway have
aircraft warning lights that blink red at night and
white during the day.58 While these warning
lights will be unavoidable on most new turbines,
developers can minimize the security lighting at a
wind farm to “decrease the contrast between the
wind plant and the nighttime landscape in rural
areas.”59
Focal Points and Prominence
Some landscapes in Vermont are natural focal
points because of their profile or prominence,
such as Camel’s Hump. Wind turbines are ideally
sited in areas of less prominence and visual
character. Additionally, turbines can be kept from
being a prominent focal point in a landscape by
offsetting the turbines from prominent vistas and
screening them with vegetation.
Environmental Considerations
Source: Wind Power In View
Color of Turbines
There are two major schools of thought on the
appropriate color for wind turbines both of which
recognize that wing turbines will “always be
visible on the landscape.” 56 One school of
thought advocates that since wind turbines cannot
be camouflaged, they should be white in color.
The other school of thought believes that the
choice of color can help minimize their presence.
While in arid climates, a light tan color works
best, in more temperate climates, light gray or offwhite colored turbines better blend into the
background and will reduce the visual impact of
the turbines.57
Much has been written about the potential
environmental
impacts
of
wind
power
development. The State of Vermont Agency of
Natural Resources has conducted a series of
hearings and issued a series of working papers
about the known environmental effects of wind
energy development.
Information on the Agency of Natural Resources
Wind Power Working Group is available at:
http://www.vermontwindpolicy.org/wrkpaprs.html
Wildlife
Concerns that wind turbines kill birds are
generally overstated. The average number of
“Vermont Agency of Natural Resources Wind Fact
Sheets,”
<http://www.vermontwindpolicy.org/factsheets/Wind%20En
ergy%20Overview2.pdf>.
59 Pasqualetti, Gipe, & Righter, 197.
58
56
57
Ibid, 198.
Ibid, 199.
DRAFT – Page 14
collisions per turbine is 2.19 per year60 and the
number of deaths attributed to wind turbines is far
fewer than those caused by other “human-related
causes” such as buildings, communication towers,
and traffic.61 Only one wind farm, in Altamont
Pass, California has had serious bird mortality
problems.62 In that instance, raptors frequently
became entangled in the lattice framework of
turbines. New tubular turbine hubs do not offer
birds a place to perch and thus, have greatly
reduced that situation from reoccurring.
Additionally, bird mortality rates generally are
lower than anticipated because “birds instinctively
shy away from moving objects”63
Emissions
Unlike other power generating sources, wind
turbines do not release sulfur dioxide, nitrogen
oxides, or particulate matter to the atmosphere.66
Land Clearance
In Vermont, to ascertain that wind turbines will
not adversely affect wildlife, the Vermont Agency
of Natural Resources recommends “predevelopment wildlife investigations [that] should
be rigorous and 2-3 years in duration with the
costs borne by the applicant.”64 These studies are
recommended to ascertain the risk of mortality to
migrating birds and bats, and the loss of habitat
for moose, black bear, and bobcat.
The amount of land required to support a
commercial wind project varies, depending on the
number of turbines. The turbine hubs require
very little ground space, but the overall project
requires more clearance for access roads,
underground power lines, and auxiliary structures.
For example, the Searsburg Wind Project cleared
35 acres of land. Ten years later, much of the
cleared vegetation has returned.67
The 30megawtt Hoosac Wind Project in Massachusetts, a
project five times the size of the Searsburg
Project, cleared 49 acres during installation.
Twenty acres remain open while the remaining
land has been replanted.68
The Agency of Natural Resources guidelines can
be found at:
Economic Considerations
http://www.vermontwindpolicy.org/factsheets/Natu
ral%20Resources%20and%20Development1.pdf
Erosion
High elevation soil is generally thinner and part of
a more fragile ecosystem so care must be taken to
mitigate the effects of road and foundation
construction with erosion control measures.65
Use of natural vegetation for erosion control and
for screening is critical to sustaining these high
elevation ecosystems.
In addition to technical considerations, there are
economic considerations of which local official
needs to be aware.
Land Values
Some opponents of wind power development
claim that properties within view of wind turbines
will be negatively affected by declining property
values. One of the more comprehensive studies
done to date is a report conducted by the
Renewable Energy Policy Project (REPP) titled
“The Effect of Wind Development on Local
Property Values.” The group examined ten wind
project developments nationwide, including the
60
Haller, 27.
Pasqualetti, Gipe, & Righter, 197.
62 “Wind Energy Myths,” U.S. Department of Energy Office
of Energy Efficiency and Renewable Energy.
63 Inglis, 181.
64“Vermont Agency of Natural Resources Wind Fact Sheets,”
<http://www.vermontwindpolicy.org/factsheets/Natural%20R
esources%20and%20Development1.pdf>.
65 Jean Vissering.
61
“Vermont Agency of Natural Resources Wind Fact
Sheets,”
<http://www.vermontwindpolicy.org/factsheets/Air%20Emm
issions1.pdf>.
67 “Agency of Natural Resources Wind Fact Sheets,”
<http://www.vermontwindpolicy.org/factsheets/Project%20C
onstruction%20Requirements1.pdf>.
68 Ibid.
66
DRAFT – Page 15
Searsburg Project in Bennington County. REPP
collected data on property sales within a 5-mile
radius of each project and used a statistical
analysis to determine whether the presence of a
wind power project had an influence on the prices
at which properties were sold. According to REPP
findings, wind turbines do not have a negative
affect on property values:
“If property values had been harmed
by being within the view-shed, then we
expected that to be shown in a majority
of the projects analyzed. Instead, to the
contrary, we found that for the great
majority of projects the property values
actually rose more quickly in the view
shed than they did in the comparable
community. Moreover, values increased
faster in the view shed after the projects
came on-line than they did before.
Finally, after projects came on-line,
values increased faster in the view shed
than they did in the comparable
community. In all, we analyzed ten
projects in three cases; we looked at
thirty individual analyses and found
that in twenty six of those, property
values in the affected view shed
performed better than the alternative.”
Vermont Environmental Research Associates
(VERA), the group responsible for managing the
Searsburg Wind Project, believes that wind farms
can be a draw for tourists. VERA operates tours
for school groups and tourists during the summer
months and notes that interest in the site has
steadily increased.71
While U.S. studies are limited, the East Haven
Wind Farm/Institute for Rural Tourism issued an
October 2003 report on their survey regarding
tourism impacts of proposed East Haven Wind
Farm 72 The survey claimed that “95 percent of
visitors to Vermont’s Northeast Kingdom would
not be deterred from further visits by the existence
of a proposed four-turbine wind farm.”
The complete survey is available on the web at:
http://www.easthavenwindfarm.com/filing.html
Economic Development
69
The complete report can be found at:
<http://www.repp.org/articles/static/1/binaries/wind
_online_final.pdf>.
Impacts on Tourism
Some opponents have argued that in states like
Vermont, which rely so heavily on tourism, the
presence of a wind energy facility may negatively
affect local tourism.
However, no studies have been able to positively
identify a relationship between declining tourism
and wind turbines.
According to the New
England Wind Project, “a wind farm may be
perceived as a complement or an enhancement to
tourism for those interested in the technology or
Renewable Energy Policy Project, “The Effect of Wind
Development on Local Property Values,”
<http://www.repp.org/articles/static/1/binaries/wind_online_f
inal.pdf>.
69
as an opportunity for the community to build
awareness and education around clean energy. In
other cases it could be seen as having an adverse
impact to the local tourism industry by deterring
visitors.”70
Many organizations in other parts of the country
are touting commercial wind power as an
economic development tool for rural areas. In the
Midwest, wind power is being described as “the
Crop of the 21st Century.” Farmers, receiving less
and less income from traditional crops, are turning
to alternative sources of revenue, including
leasing land for commercial wind farms. The
turbines do not interfere with traditional grazing
and farming uses.
Here in Vermont, Renewable Energy Vermont
(REV) notes several economic benefits of wind
energy. According to the advocacy group, if just
six wind farms were located in Vermont, they
could produce 10% of the state’s electricity needs.
U.S. Department of Energy, “New England Wind Forum,”
<http://www.eere.energy.gov/windandhydro/windpoweringa
merica/ne_issues_yard.asp>.
71 Martha Staskus, Vermont Environmental Research
Associates.
72 “Tourism Questionnaires,”
<http://www.easthavenwindfarm.com/filing.html>.
70
DRAFT – Page 16
The development and construction phases of these
six wind farms would create more than 400 jobs
for Vermonters – a mix of highly skilled laborer,
construction, engineering and other jobs.73
Additionally, REV notes that over $1 billion is
spent annually to purchase out-of-state energy.74
Wind farms in Vermont can add to the local and
state tax base and provides steady income to
landowners through lease payments.
interest. While the Public Service Board does not
always accede to those planning documents,
having a clearly articulated vision is a powerful
tool for local officials.
Wind energy in Vermont is a complex issue and
this guide provides a solid informational
foundation for local officials from which they can
work to address wind energy in their
communities.
A full discussion of the report, “The Economic
Benefits of Wind Farm Development in
Vermont” is available online at their website:
http://www.revermont.org/windfarm_benefits.pdf
SUMMARY &
CONCLUSIONS:
Commercial-scale wind energy in Vermont will
be an increasingly important part of the state’s
energy portfolio. In addition to the current
proposed projects, it is likely several more will be
developed over the next five years. Towns must
be proactive in addressing commercial wind
energy in their planning documents; articulating
their visions before a project is proposed for those
locales.
Whether permissive language that
welcomes commercial wind or restrictive
language that limits development above certain
elevations and protects scenic or historic views
and areas, a Town Plan represents a
municipality’s best chance at regulating
commercial wind turbines.
The Public Service Board, in considering whether
or not to issue a Certificate of Public Good, looks
to town and regional plans for indications of
“clear, written community standards” about wind
energy.75
Those standards are important in
deciding whether or not a project fits with the
surrounding community and is truly in the public
Renewable Energy Vermont, “Wind Energy: Powering
Vermont’s Economy,”
<http://www.revermont.org/windfarm_benefits.pdf>.
74 Ibid.
75 “In Re: Petition of Tom Halnon,” State of Vermont Public
Service Board decision, 15 March 2001.
<http://www.state.vt.us/psb/orders/2001/files/cpgnm25_final
_order.pdf>.
73
DRAFT – Page 17
**********
INFORMATION RESOURCES:
Renewable Energy Vermont
http://www.revermont.org
Description: An advocacy group which promotes
renewable energy use in Vermont.
Vermont Natural Resources Council
http://www.vnrc.org/energy/
Description: An environmental conservation and
advocacy group has issued a statement on wind
development and mountain ridgelines.
There is considerable information on the Web
concerning large-scale wind power development.
Listed here are links to organizations that can
provide further information on the topics covered
in the guide.
Vermont Department of Public Service
http://publicservice.vermont.gov
Description: This state agency acts as an advocate for
rate payers and the public interest at large. Follow
the link to “Renewables and Efficiency” for
documents related to energy planning.
Vermont Public Service Board
http://www.state.vt.us/psb/
New England Wind Forum
http://www.eere.energy.gov/windandhydro/windpoweri
ngamerica/newengland.asp
Description: A U.S. Department of Energy sponsored
web site which provides single comprehensive
source of up-to-date information on a broad array
of wind-energy-related issues pertaining to New
England.
Vermont Planning Information Center
http://www.vpic.info
Description: A clearinghouse of information for those
involved in planning and regulating in the state of
Vermont. Provides in-depth guidance on how to
create and modify a town plan.
Description: This is the quasi-judicial board that
reviews wind development proposals and makes
determination on Certificates of Public Good.
American Wind Energy Association
http://www.awea.org
Description: This wind advocacy organization has
much basic and detailed information about Utilityscale wind production.
Vermont Agency of Natural Resources State Land
Wind Power Policy Development
http://www.vermontwindpolicy.org/wrkpaprs.html
Description: A series of fact sheets and working papers
about the potential environmental impacts of wind
development on state lands in Vermont.
DRAFT – Page 18
VERMONT WIND
RESOURCES MAP:
DRAFT – Page 19
DRAFT – Page 20