My comments are below, if you want to read & comment (by Friday
this is where:
http://www.fs.fed.us/r9/forests/greenmountain/htm/greenmountain/links/projects/deerfield_wind.htm
November 26, 2008
Bob Bayer
Project Coordinator
USDA Forest Service
2538 Depot Street
Manchester Center, VT 05255
Gentlemen:
Although I am generally in favor of wind power, I support the No Action
alternative to the Deerfield Wind Project proposal. The treatment of
recreation in the Draft Environmental Impact Statement is so superficial
as to invite an appeal if this project is approved without recreation
mitigation, and the unreasonable and irrational consideration given to
one special interest group is enough to call the impartiality of the DEIS
into question.
To deal with the latter issue first, the DEIS Section 3.12 says that
Vermont Fish & Wildlife estimates the recent number of bears in Vermont
at 4,600 to 5,700. This is 130% to 190% of what it was in 2003 which
itself was more that it has been any time in 200 years. Obviously bears
are doing well in Vermont and whatever happens in the project area will
make little difference in their numbers.
Since the human population of Vermont is much greater than Colonial times
and the land much more developed, a more impartial judgment might be that
with the present bear numbers there are far too many predators at the top
of the food chain and that bear numbers should be drastically reduced so
that other species don't suffer. Even Vermont Fish and Wildlife proposes
to stabilize the population and harvest surplus bears. Instead, the
Forest Service is proposing a vast recreational closure to pedestrians
that was not even reviewed by the bear panel. This closure is unnecessary
and irrational and the Forest Service either carelessly or deliberately
skimped on the recreational analysis so it could be proposed.
In contrast to the multiple studies and years of data on bats, bears, and
birds, the Forest Service apparently made no attempt to collect
recreational use data. They did not contact hiker, skier, and hunter
groups for participation data, install register or card systems at likely
access points to the project area, or use researchers or cameras to
estimate user numbers over a period of years. Backcountry glade skiing is
not even mentioned as a recreational use. Thus the whole DEIS is based on
poor assumptions which tend to minimize and ignore recreational use.
The lack of attention paid to recreation is evidenced by the many
conflicting statements regarding recreational use:
* Section 1.4.3 states "Public access to public lands would not be
restricted, except in the immediate vicinity of the wind turbines and the
ancillary facilities."
* Section 3.12 states "a forest closure order would close the proposed
wind facility roads and surrounding ridge top areas adjacent and
underneath the turbines to all public uses, including foot traffic..."
Depending on the amount of ridgetop land included, this would directly
eliminate access to a substantial part of the area and indirectly limit
access to Forest land that would no longer be accessible except across
private land.
* Section 3.17.2.2.2 states "A public access control plan similar to the
plan in place for the existing Searsburg Wind Facility would be
developed." That private land bans recreational use entirely which would
be totally unacceptable on National Forest lands.
Different recreation user types will be affected differently by the
proposal. Skiers are probably the least affected. If the project roads
are plowed, this will cut off some runs even in the absence of any
closures. If the overhead powerline swath is closed, access to most of
the open area will only be possible via a dangerous walk down VT-8 from
the parking area.
Hunting potential in the area will automatically be restricted as no
reasonable hunter will shoot near or in the direction of the turbines.
Banning hunters from roads and ridgetops will further reduce the area
available to hunters, including areas of National Forest land that would
be inaccessible without crossing roads or private land which have
apparently not been noticed by the DEIS preparers. If game is wounded, it
will become illegal to follow it if it crosses project roads. Due to the
overabundance of bears statewide and the notation in Section 3.12 that
bears presently coexist fine with hunters in the project area, there is
no reason for the irrational road closure.
Hikers with no particular destination in mind will be less affected by
the project than peakbaggers who care mostly about summits. In
particular, peak 948+m is one of the 100 highest peaks in Vermont and
continuing numbers of hikers will wish to climb it. If the Forest Service
unreasonably bans access to this peak, some hikers will continue to climb
it illegally and will develop a general disrespect for Forest Service
rules and policies. The more law abiding will probably not bother to
start a list of peaks they can't finish and may choose to climb the 100
highest of the Adirondacks or New Hampshire instead. At perhaps $50 per
day spent in the local economy, Vermont hospitality providers may not
wish to lose those 100 visits per hiker.
So what do I consider reasonable recreational access? Here is a suggested
plan:
* Substations and the .065 acre permanent footprint of each turbine would
be closed to the public except as allowed by the permitee and the Forest
Service, see below for summit access.
* Project roads would be closed to public vehicular use and would not be
used as part of trail systems, but pedestrians could cross them and walk
short portions. Wounded game could be tracked on roads as far as it goes.
* Ridges and cleared areas including assembly areas near turbines would
remain open to the public. Only specific proven safety hazards and
drastic reduction in bear numbers would allow for review of this item.
The statement in section in 3.13.2 that "No significant issues were
raised during public scoping in regard to the direct impacts of the
Proposed Action on developed and dispersed recreation..." is simply not
true. I expressed my concern about continued hiker access to the high
points of both the East and West ridges (peaks 948+m and 888+m) in an
e-mail comment 8/19/2005 (duly receipted by the Forest Service) but the
bear-bedazzled Forest Service chose to ignore this issue. It would have
been a zero-cost option to shift the turbines slightly at design stage to
avoid summit encroachment but would probably be considerably more
expensive to change things now. In lieu of adjusting turbine locations, I
propose that the following Recreation Mitigation Requirement be written
into the Record of Decision:
"Forest visitors will be allowed access at no charge to summit areas at
reasonable times by appointment with the permittee. To preserve the
previous hiking experience, they may be required to hike without trail
from VT-8 as before, or for safety reasons they may be required to follow
reasonable designated routes at the option of the permittee."
