Comments on the DEIS for the Deerfield Wind Project 

Comments on the Draft Environmental Impact Statement [DEIS] for the Deerfield Wind Project, Federal Register, Volume 73, No. 193, page 57620, October 3, 2008.

As we clearly stated in our August 2005 scoping comment letter, we are very concerned about the impacts of any development on the Lamb Brook area which we believe should be recommended for designation as Wilderness. We do not believe these and other issues first raised in 2005 were adequately addressed in this DEIS.

The DEIS Is Premature
NEPA [National Environmental Policy Act of 1969] Requires Meaningful Public Involvement
Forest Service National Wind Energy Policy Is Not Yet Final
The Public Service Board Process Is On-Going
Proponent vs. Permit Holder Is Unclear

The DEIS Is Flawed
The Purpose and Need Are Too Narrowly Drawn
Weighting the Screening Analysis to the Proponent’s Proposal Was Arbitrary and Capricious
An Inadequate Range of Alternatives Is Proposed
Conditions of the Permit Are Not Disclosed
Bias and Forest Service Responsibilities Are a Concern When Using Proponent-Financed Contracting

Failure to Comply with the National Historic Preservation Act (NHPA) and NEPA
State Historic Preservation Officer (SHPO) Concurrence Has Not Been Obtained
Effects under NEPA Have Not Been Disclosed

The Issue of Federal Preemption

Lamb Brook: The Injunction and Future Uses
Only a Court of Law May Lift the Injunction
The DEIS Fails to Address the Injunction
The DEIS Does Not Improve Discussion of Mitigation Measures for Illegal ATVs
Forest Service Fails to Disclose Potential Future Logging in Lamb Brook

The Lamb Brook Roadless Area Was Not Properly Considered in the GMNF [Green Mountain National Forest] Plan
Roadless Inventory on the GMNF Is Flawed

The Forest Service Fails to Take a “Hard Look” as Required Under NEPA

Effects on Bears

The Effect on Bats Has Not Been Adequately Disclosed
Bats Are at Risk
Pre-construction Surveys Can Not Predict Mortality
Deerfield Wind Is Similar to Other Sites with High Mortality
Bigger Turbines Kill More Bats
New Information Regarding Mode of Bat Kill Needs to Be Considered
Impacts to Bats from Wind Energy Are Cumulative

Climate and Air
Displacement of Emissions Is Not Adequately Analyzed
The DEIS Fails to Adequately Consider the Carbon Storage Values Lost in Building a Wind Energy Facility

Visuals
Nighttime Views in Vermont Is Not Addressed

Social and Economic Effects
Power Capability and the Capacity Factor Are Not Accurately Calculated

Mary C. Krueger
Forest Policy Analyst
The Wilderness Society
950 Pearl Hill Road
Fitchburg, MA 01420
(978) 342-2159
mary_krueger@tws.org

Mollie Matteson
Conservation Advocate
Center for Biological Diversity
Northeast Field Office
P.O. Box 188
Richmond, VT 05477
(802) 434-2388
mmatteson@biologicaldiversity.org

Download original document: “Comments on the DEIS for the Deerfield Wind Project”