Wind turbine DEIS comments instructions & tips

LIF STRAND Forums Red Hill Wind Farm Wind turbine DEIS comments instructions & tips

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    Lif Strand
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    wind turbine on fireComments are due on or before November 7, 2019 – your voice counts!

    INSTRUCTIONS    |    COMMENT POINTERS

    Those of us who went to the last public circus meeting put on by the already-established BLM + NextEra partnership know that it was more of the same:  omission, misdirection, and downright lies.  But that’s just my opinion — your thoughts not only matters, but could make the difference between NextEra’s success or not.

    I’ve been researching and have read several articles now about how just one (1) stubborn landowner who stands firm and refuses to give in to the bully tactics of NextEra can bring a project to a screeching halt.  Yes, it helps if a letter threatening legal action comes from an attorney, but first there must be a landowner who states loudly and clearly, NO WIND TURBINES AND THIS IS WHY.

    I can’t emphasize enough how important it is for you to comment and to do it in a way that has the most impact. BLM says in their own Tips document,

    The most effective comments are those that provide useful information to the BLM. Comments on the DEIS are not counted as votes or as part of a referendum on BLM decisions. They are used to improve the document and analyses, and to ensure that the impacts are adequately determined before the BLM makes a final decision on the proposed project. Therefore, avoid comments that state “I am in favor of this project” or “I am opposed to this project.” Remember that the more clear, concise, and relevant to the DEIS your comments are, the more effective they will be and the more likely it is that they will be utilized to improve the final documents and affect the agency decisions.

    You can submit your comments in one fell swoop or you can submit several times, but the important thing is to submit no later than November 7, 11:59 PM as evidenced by a postmark on your envelope or a date stamp on your electronic submission (i.e. online form at BLM, or email).  

    INSTRUCTIONS

    You can email your comments to Kristen Long at BLM or use the ePlanning site.  I like to use the ePlanning site because once I get my submission ID # I know it’s been received.  Not that I don’t trust an email submission, but…

    Either way, be sure you get a Submission ID # for your comment!  If you use email be sure to ask for that ID # because that’s the only way you know for sure that your comment becomes part of the official Administrative Record for the project.

    • Write your comments out in full using Word or Notepad or whatever works for you.  You can use the format that I use (changing the address and salutation, of course) or any format you want — just be sure that it makes sense and that you clearly state the issue/concern you have, and how you want BLM to address that concern.
    • Save your comments with a filename that includes your name & Borderlands’ or NextEra’s or BLM’s –anything that will be easy for you to identify the file when you look for it again.  Of course, save it to a folder that you can find again, too!
    • If your comments are relatively brief, then you can paste them directly into the ePlanning form.
    • If your comments are multi-paged, then you can write a cover comment directly in the form and attach your comments document.

    So let’s get going.

    Start by going to BLM’s project page.  Here’s the link in case you find it easier to copy/paste from the full URL: https://eplanning.blm.gov/epl-front-office/eplanning/planAndProjectSite.do?methodName=dispatchToPatternPage&currentPageId=171852  

    1. Below is a screenshot of what you’ll see. Click on the box I’ve circled, “Comment on Document” DEIS comment submission first step
    2. A pop-up box appears with the submission form.  You can see I filled in the title to my comment (circled).  In this case, my comment is actually a copy of a letter I sent to the Catron County Commission.  You can also see in the box that I provided a summary of my comments in that letter.
      If your comments aren’t as long as my letter is, then you can copy and paste them all in the box instead of attaching anything.
      But if your comments are long, then you can attach them.  Scroll down a bit in the pop-up box and you’ll see a button “Choose File”.  Click on that and then find your file and attach it.  When your file has been successfully attached you’ll see it’s title (or part of the title) next to the “Choose File” box.
      Then click on the “Next” button in the lower right corner.
      screenshot #2
    3. What you see next is the Name/address window.  Note that you only have to fill in the boxes with the red stars.  You can fill out more if you want of course.  Then click on “Next” in the lower right corner.Screenshot #3
    4. The Review Submission window is displayed.  Check over your info.  If it’s all correct, then click on the appropriate Disclaimers and Agreements responses (circled) and then on “Submit” in the lower right corner.Screenshot #4

    What you next see is very important!  This is the screen with your Submission ID #.  Make sure you download and/or print it!

    Screenshot #5

    1. If you have any problems with this, please contact me.  Just make sure you submit by midnight New Mexico time, November 7, 2019!

    COMMENT POINTERS

    Whichever way you choose to submit your comments, please also send copies to our legislators AND to the media.  We don’t want BLM to have any way to claim they didn’t receive anything from  you but also we want to establish a public foundation of clear documentation of our opposition in case litigation becomes necessary.  

    Extensive comments opposing a wind turbine project in Massachusetts.

    American Bird Conservancy webpage with lots of resources

    Imagine That article on how wind power depends on hydrocarbons

    Adverse health effects of industrial wind turbines journal article on wind turbine impacts on health

    Common failure modes for wind turbines [PDF] from a pro-wind turbine site 

    Tips from Burning Man in Nevada. Obviously you won’t use the exact phrases but I’m including them here to give you an idea.

    Remember: the more clear, concise, and relevant to the DEIS your comments are, the more effective they’ll be and the more likely it is that they’ll be utilized to improve the final documents and affect the agency’s decisions. The most effective comments should follow these guidelines:

    • Be as specific as possible with your comments and refer to sections, chapters, special studies, page numbers and paragraphs in the DEIS.
    • Back up your statements with explanations, facts, personal experience, and references, as appropriate.
    • Support statements with details. If, for example, you are concerned about impacts to the playa surface or traffic management, it is helpful to focus on a particular problem or issue, such as BLM’s recommendation for K-rail and jersey barriers around the Black Rock City perimeter: “It appears the Draft EIS failed to adequately consider the environmental impacts of the transportation and placement of millions of pounds of concrete and plastic barriers around the perimeter.” or
    • Comments can take the form of questions like: “I have not experienced problems with firearms or drugs at Burning Man. Did BLM consider the costs of running an increased search operation at the Gate, and the effects on wait times and individual rights?”
    • It’s important to look at the base assumptions that lead to BLM’s new requirements. For instance: “It appears BLM relied on very few observations in the Artificial Light at Night Assessment.”
    • You should include your experience. For example: “I have been to Burning Man seven times and my camp does everything we can to ensure our loads are secure and that we leave no debris. It seems the recommendation for dumpsters is extreme and not supported by enough evidence.”
    • You should state your qualifications, such as: “I am a biologist in Nevada studying bird migration and can tell you that the analysis in this respect is beyond reason. The extremely tiny level of risk to bird species posed by activity at Burning Man does not warrant BLM’s proposed monitoring or mitigations.”
    • Submit comments if you find:
      • an error in analysis that may affect the outcome
      • new information that would change the analysis and conclusions
      • something that should be clarified
      • a substantially different alternative that meets the purpose and need statement and has not been considered.

    Comments that simply reflect an opinion about the project will not be as effective. For example, a comment that states, “I don’t like the idea of concrete barriers around the event,” or “ I oppose putting dumpsters on Gate Road on principle” typically result simply in a response of “Comment Noted.” An effective comment might start with: “Concrete barriers would be detrimental to the Burning Man event because ___,” or “The event would be negatively affected by dumpsters on Gate Road because ___.”

     

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