Craig Mountain Today
But for how long???
Craig Mtn simulation with turbines
view south toward Ramo Flats
Action Alerts & Announcements
also check Calendar & Events for details
If you have any experience regarding weeds, roads, water, geography, wet lands,
wildlife, archeology, historic sites, recreation, etc. let the city or county know!
April 5, 2018 5:30 PM FGRV invites public to an information - sharing session at Cook Library Community Room regarding open space uses.
April 11, 2018 9 AM Union County Commission Work Session
More about Article 52 Discussions
Article 52 Proposed Additions / Changes Submitted to County Commissioners
Public Comment on SB 1519 and SB 1537 rule making for Energy Facility Siting
Wishing you peace, health and joy this holiday season & throughout 2018!
Your friends, Stop B2H Coalition
Energy Department and council under fire for cutting out public
Your generous donations . . .
help us educate the public about the
true impact of wind energy.
Please send your donations to:
PO Box 116
Union, OR 97883
Make your check payable to FGRV.*
For more info call 541-910-8263
* As a 501 (c)(3) donations are tax deductible
FGRV Radio Ads1 2 3 4 5
3% Energy Challenge
Energy facts & figures
compliments of Irene
in Front Yards Across
3 % Challenge Begins
Grande Ronde Valley
prevent our wildlife - health - environment - economy from being thrown to the wind!
FGRV Yard Sale nets $875
During Union's Grassroots Festival on August 13th FGRV added $875 to its war chest forProtected eagle halts
future projects and possibly legal actions in its continuing fight to keep more wind industrial complexes out of the Grande Ronde Valley.
A bake sale and information table provided a little extra benefit to those stopping by for a good deal. Of course the best deal was the printed info and SWINDLE bumper stickers that were handed out.
Thanks to energetic FGRV members headed by orgainizer Bonnie Dunn more people have joined the fight while these funds were raised.
* Grassroots Festival provided another venue for the 'grassroots' efforts of FGRV.
* Union was highlighted as Oregon's 'Volunteer Town' in a PBS documentary several years ago. FGRV members continue the volunteer tradition by giving their time, talent and treasure to protect the Grande Ronde Valley.
by Ted Sickinger The Oregonian 9-29-10
The endangered golden eagle has grounded the first wind farm in Wasco County and is throwing another in Gilliam County into doubt.
read the rest of the article
Lightening Strikes Again
Idaho Power website gives
up todate info on what wind
actually brings to the consumer -
Find the following articles at getpluggedin.com
Idaho House, Senate Request
Changes to PURPA
by Michael Foley, Idaho Power
Ontario'w Wind Policy Blows
by Rob Granatstein, The Toronto Sun
Are Tax Incentives for Commercial Wind Farms Good for Idaho?
by Steve Priebe,
Idahoans for Responsible Energy Policy
excerpt: “We already give them massive federal subsidies,” Christensen told The Associated Press after the vote. “If they can’t survive on those alone, they should not have any more of our taxpayer dollars.”
read the entire article
Editors note: several attempts by Idaho's grassroots groups failed but they finally suceeded!
Our Congratulations to them for their efforts, and determination and victory.
Wind power is a technological, economic
and environmental failure."
John Droz, Physicist
Wind farms are not farms ...
they don't grow anything.
We call them factories.
Call, write, email
our county commissioners
and tell them
STOP wind power in Union County
1106 K Avenue
La Grande, Oregon 97850
How is this green?In Baotou, China, where neodymium is extracted, a vast man-made lake of foul-smelling radioactive waste, five-miles wide, has been created from the by-product. It has killed farmland for miles around, made thousands of people ill and put one of China's key waterways in jeopardy. One of the largest users is a top- capacity wind turbine that uses 4,400 lbs. of the neodymium-based permanent magnet material.
In advisory vote,
proposed wind farm
By a slim majority Tuesday, Union County voters said they don't like the idea of Horizon Wind Energy building the 300-megawatt Antelope Ridge Wind Farm near Union.
Excerpted from the article Dennis Wilkinson, the head of Friends of Grande Ronde Valley said: "With the defeat of Measure 31-75, the people of Union County have made an informed and educated decision that they do not want the Antelope Ridge Wind Farm in their community." ... the vote will "resonate throughout the country proving that people in rural communities are standing up to the foreign corporations that are attempting to destroy the land, way of life, wildlife, health and more in the name of 'clean, renewable energy."
click to read entire article
thanks to www.wind-watch.org
November 2, 2010
Totals 11/03/10 3:16 AM All 19 Precincts Counted 70.98 voter turnout total ballots cast 10,810
Measure 31-75"Do the citizens of Union County support the Antelope Ridge Wind Farm application currently before the Oregon Department of Energy?"
Yes 5,060 votes (48.09%)
NO 5,462 VOTES (51.91%)
OF OREGON'S RENEWABLE PORTFOLIO STANDARD
A Beacon Hill Institute & Cascade Policy Institute Policy Study March 2011
David G. Tuerck, PhD
Michael Head, MSEP
Paul Bachman, MSIE
This study takes into account a variety of factors and their effects to Oregon's employment, costs to industry and the public.
excerpts from Executive Summary:
Since renewable energy generally costs more than conventional energy, may have voiced concerns about highter elecrticity rates. Moreover, since Oregon has a liited ability to generate new renewable energy, the state will start from a low power generation base. In addition,m some renewable energy sources (wind and solar power in particular) require the installation of conventional backup generation capacity for cloudy, windless days. The need for this backup further boosts the cost of renewable energy.
Oregonians will begin to see these higher costs on their electric bill this year. Pacific Power and Portland General Electric Implemented rate increases (in some cases double-digit percentage increases) directly tied to SB 838. read the entire study
Oregonian Editorial Board www.oregonlive.com
March 15, 2011
excerpt: Oregon has
stopped throwing money at anyone who mouths the magic
words: "Green energy." But a three-part
series in The Oregonian made it clear this week that the
state must further tighten the rules --- and the
oversight --- of its Business Energy Tax Credit program.
Given the enormous cost, the green subsidies demand
stronger scrutiny from lawmakers, the governor and
the public than they've received. Former Gov.
Ted Kulongoski's energy policy --- y'all come ---
ignored the mounting cost until hundreds of millions
of dollars were committed, no small amount of it to
companies that failed to live up to the promises of
jobs, economic development and green energy.
excerpt: ... If we're
going to toss $300 million to green energy developers
every two years, we should know exactly what we're
getting in return.
Reasons for projected OTEC
rate increases in 2011
thanks to Super Talk Radio
www.otecc.com Pod Casts 9-16-10
Werner Buehler, OTEC's General Manager, and Steve Schauer, OTEC's Manager of Member Services discuss a BPA wholesale rate increase scheduled for October 2011.Date: Thursday, September 16, 2010
Part 1, length 8:25
Part 2, length 9:52
When Green Subsidies are gone this is what is left!
Komoa wind farm abandoned
The Gas Is Greener
by Robert Bryce June 7, 2011
published in The New York Times
Oregon green energy tax breaks
face sweeping changes, cutbacks
Harry Esteve June 9, 2011
published in The Oregonian
Editors note: This article discusses Oregon House Bill 3671
excerpt: "As written, the bill would stop the practice of subsidizing half the construction cost of wind and solar energy developers, who receive tens of missions of dollars worth of tax credit."
Here's the link to the full article
More about Article 52 discussions
March 22, 2018 by Ray Randall
Article 52 is our (Union) county guideline for the siting of any wind farm in Union County. It will be reanalyzed and modified in the near future. The County Commission has indicated that they will set some parameters for this process in a work session on April 11, 2018 beginning at 9:00 am and there will be an opportunity for public comment. The Commission has not yet publicized its April 11th agenda which is not very helpful. But, for those of us who wish to have a say about wind farms, we must prepare for this potential now.
The Friends of the Grande Ronde Valley is inviting all interested citizens to an information-sharing session at the Cook Library Community Room on Thursday, April 5, 2018. The doors will open at 5:30 pm and we hope to finish by 7:00 pm. If you have concerns about the trashing of our open spaces, please attend.
Article 52 Proposed Additions / Changes
Submitted to Union County Commissioners
2-24-18 authored by Jed Farmer, John Milbert, Chuck LeBold, Ray Randall; sent to Commissioners January 2018
Union County Article 52 "Therefore, the purpose of this ordinance is to clarify existing rules governing the siting and development of wind generators with the intention to encourage wind power renewable energy resource development."
Proposed Additions / Changes to current Article 52 was Submitted to Union County Commissioners January 2018 by authors Jed Farmer, John Milbert, Chuck LeBold and Ray Randall as members and on behalf of Friends of the Grande Ronde Valley.
Set backs is a major part of the proposed changes. Currently set backs are 1500 feet. Umatilla County has increased their set back to 2 miles.
County Commissioners Work Session April 11th 9 AM agenda will be The Proposed Additions / Changes. Location of the meeting is Joseph Annex Building 1106 K Ave., La Grande, Oregon.
public comment for submission for SB 1519 and SB 1537
by Irene Gilbert FGRV / Legislative Analyst February 5, 2018
included is PDF Irene sent to Senator Beyer and Committee members
I am providing this submission to you as my previous comments were written under the belief that these rules were going to remove rule making from the Energy Facility Siting Division and Energy Facility Siting Council.
Unfortunately, as I found out during public comments today, they exclude this group. The bills are positive, unfortunately, they do not include the worst offenders. I certainly hope there is some effort to address the Siting Division this session rather than continuing to allow ODOE to work for developers at the expense of the public.
As long as the governor continues to appoint people to the Energy Facility Siting Council like Marcia Grail who currently works for IBEW 125 and their retirement fund, the only possible way to get a neutral evaluation of developments is through removing control over portions of the process from the Oregon Department of Energy. I question how impartial a person can be who knows that every time she votes to approve a development, she is making jobs for her employer. Perhaps someone can find out who vetted Marcia and why they did not question the conflict of interest, or why the governor has insisted that this does not pose a conflict of interest.
Wishing you peace
December 30, 2017
Energy Department and council
under fire for cutting out public
from The Oregonian 12-13-17
read the full article in The Oregonian
The state panel responsible for siting large energy facilities is under fire for adopting rules that conservation groups and others say will limit transparency and cut the public out of decisions. ...
In the end, critics say it's another example of the dysfunctional Energy Department ignoring the public interest, interpreting rules and statues unlawfully, and cozying up to the industry that pays its bills. ...
Irene Gilbert, a La Grande resident and researcher for the Friends of the Grande Ronde Valley, has opposed numerous windfarms in Eastern Oregon based on their impacts on wildlife, wetlands, noise levels, and their visibility from towns or areas designated as wild and scenic. She says the council, at the recommendation of the Energy Department, has denied every one of her requests for a contested case. By her count, the council has rejected more than 80 requests for contested cases and not granted a single one. ...
"They control the whole process, and their determination over and over again is no significant impact," she said. "They get paid by the applicants. They bill for every hour of work on an application, then charge developers to monitor projects. So, in effect, they're working for the applicant." ...
FGRV meeting 2 PM December 14, 2017
Agenda includes Updates on ODOE / EFSC activity & county Article 52 status.
See date on Calendar & Events page for more info
Location is downstairs at Union Library in City Park on Main Street
THE OREGON PUBLIC UTILITY COMMISSION
WILL HOLD A PUBLIC MEETING November 2nd
IN ONTARIO, OREGON ON IDAHO POWER’S APPLICATION TO BUILD THE BOARDMAN TO HEMINGWAY (B2H) TRANSMISSION LINE
from B2H coalition 10-28-17
Idaho Power’s own sales figures show that demand has been flat for ten years. You will pay if the line is ever built, and you will also pay Idaho Power a guaranteed profit for building it. Come to the meeting to voice your concerns to the members and staff of the Oregon Public Utility Commission. It’s very important and they want to hear from you.
For more information, contact: firstname.lastname@example.org
THIS IS THE TIME TO MAKE YOURSELF HEARD: Idaho Power customers will pay hundreds of millions of dollars for a line that may never be needed.
August 23, 2017 Meeting 6 PM
Union County & City of La Grande 2nd Joint Public Meeting
on location of B2H Transmission Line
County Commissioners and City of La Grande
are hosting a second Boardman to Hemingway
siting meeting. It will be on Wednesday,
August 23rd at 6 pm in the
Blue Mountain Conference Center (aka
the Armory). Since we had over 140 people
at the last meeting they are moving the
event to the big conference room. We’d
like to fill the room to express our
support for our elected representatives in
letting Idaho Power know that their
transmission line is not welcome here!
and city are in the process of reviewing
Idaho Power’s application for
“completeness” and there are huge gaps in
the application. We have found many areas
where Idaho Power has missed key
information that should be considered by
the State of Oregon before determining
that the application is complete. Heck
they didn't even know we have a helipad at
the hospital for life-flight. Their report
does not describe in detail the 100+ miles
of new or improved roads they want to
build; nor proper weed or fire protection
plans. And the list of incompleteness goes
meeting the city/county will inform us on
the work that they have done so far
and they are asking for all of us to
help. YES, asking us to help! The
application is HUGE and there is a limited
amount of time to submit comments to the
If you have any experience
regarding weeds, roads, water,
geography, wet lands, wildlife,
archeology, historic sites,
recreation, etc. let the city or
application is on Union County web site at
If you have any knowledge in any of these
areas, please get involved!
be future opportunities for public comment
as the state process progresses over this
coming year. We need to make sure that the
state considers everything that could
negatively impact our homes and our
environment. We need to be heard and our
elected representatives want to hear from
us – how often does that happen ;-)!
information: Contact Union
County directly 541-963-1001;
Pass the Word! Forward this email & look forward to seeing you there! -Stop B2H Coalition
DATE AND TIME: Monday,
August 14th, 2017 at 5:00
pm at the Baker County
Commissioners’ Chamber, Baker County
Courthouse The County and City
have until September 1 to make
comments before Idaho Power’s
application is accepted as complete by
the Oregon Department of Energy
The county and city want to
know your opinion about the impacts
this transmission line will have on
the valley and YOU. Idaho
is only notifying landowners within
500 feet of these steel giants, which
they are planning. The line will enter
the valley from Ladd Canyon
by I-84 coming into Baker County;
travels due south along the eastern
edge of irrigated, agricultural fields
and passes west (in front of) the
National Historic Oregon Trail
Interpretive Center; then continues
south to Durkee and Huntington, and
passes east of the Oywhee Reservoir
into Idaho. Come to the meeting
to talk to our elected officials with
your questions/opinions and conditions
you want to see them recommend. THIS IS THE TIME TO
EXPRESS YOUR CONCERNS regarding
impacts to views, wildlife, police and
fire, noise, traffic, groundwater,
flooding, agricultural and forest
impacts such as invasive weeds,
setbacks from homes, the Oregon Trail,
including the viewscape impact from
the National Historic Oregon Trail
Interpretive Center, and historical
resources, etc. For more
DATE AND TIME: Monday, August 14th, 2017 at 5:00 pm at the Baker County Commissioners’ Chamber, Baker County Courthouse
The County and City have until September 1 to make comments before Idaho Power’s application is accepted as complete by the Oregon Department of Energy (ODOE). The county and city want to know your opinion about the impacts this transmission line will have on the valley and YOU. Idaho Power is only notifying landowners within 500 feet of these steel giants, which they are planning.
The line will enter the valley from Ladd Canyon by I-84 coming into Baker County; travels due south along the eastern edge of irrigated, agricultural fields and passes west (in front of) the National Historic Oregon Trail Interpretive Center; then continues south to Durkee and Huntington, and passes east of the Oywhee Reservoir into Idaho.
Come to the meeting to talk to our elected officials with your questions/opinions and conditions you want to see them recommend.
THIS IS THE TIME TO EXPRESS YOUR CONCERNS regarding impacts to views, wildlife, police and fire, noise, traffic, groundwater, flooding, agricultural and forest impacts such as invasive weeds, setbacks from homes, the Oregon Trail, including the viewscape impact from the National Historic Oregon Trail Interpretive Center, and historical resources, etc.
For more information, contact: email@example.com
Union County & City of La Grande
Boardman to Hemingway
Union County & City of La Grande
Boardman to Hemingway
the Oregon Department of Energy informed
local government units along the B2H route
that they would have until September 1st
to comment on the “completeness” of Idaho
Power’s Amended Application for a “Site
Certificate” (or, in other words, the
application for a permit for the right of
way to build B2H.) There
are NO public hearings at this stage of
the game in the Oregon siting process but
there will be later in this process. However,
County and the City of La Grande have
graciously agreed to conduct their own
public meeting to solicit input from
citizens, before they comment on the
The meeting will be starting at 6 pm on Tuesday, August 1st at the Blue Mtn Conference Center (aka Armory) at 404 12th Street in La Grande. PLEASE Mark your calendars NOW!
and City have until Sept. 1 to make comments
before Idaho Powers application is accepted
as complete by the Oregon Department of
The county and city want to know your
opinion about the impacts this transmission
line with have on the valley and you. Idaho
Power is only notifying landowners within
500 feet of these steel giants which they
will enter the valley from the west where
the current 230 kv does then run behind the
hospital, over Morgan Lake road, and follow
the foothills alongside Ladd Marsh, visible
to all, and out Ladd Canyon by I-84.
Come to the meeting to talk to our elected officials with your questions/opinions and conditions you want to see them recommend. THIS IS THE TIME TO EXPRESS YOUR CONCERNS regarding impacts to views, wildlife, police and fire, noise, traffic, Ladd Marsh, groundwater, flooding, agricultural and forest impacts such as invasive weeds, setbacks from homes, the Oregon Trail, historical resources, etc.
The format will be informal in that no decisions will be made and there will be no strict times for speaking—more of a listening session—according to Commissioner McClure. He wants to hear from everyone! He says now is the time to put all of your concerns on the table about the B2H and/or the sighting application. He has asked Idaho Power to come and present too. They will have their maps and renderings—probably similar to what we showed you in our last Stop B2H newsletter, but fancier (if you did not receive our newsletter—or couldn’t open it, please contact us right away.)
The Stop B2H Coalition’s research working group is meeting this week to coordinate our research and writing for the citizen portfolio that we will be submitting soon to the Public Utility Commissions of Idaho and Oregon (PUC's) – AND – also to prepare for this meeting! At this stage, it is important to let the public officials know:
· What you think the city and county should be looking for in the application for completeness.*
· What conditions you want them to insist will be in the Site Certificate (if one is granted.)
· And, of course: What is important to You!
We hope to post some talking points for everyone later in the week. However, the main thing is to show up! Speak from the heart (or mind) and tell your story. You do not need to be an expert. However, if you would like to prepare more yourself, here is the link to the Amended Application: http://union-county.org/b2h-amended-preliminary-application-for-site-certificate/
It is overwhelming! So, a tip for review would be: go to the Chapter/Exhibit that you are interested in; read the section that you have an interest (or the geographic areas you're interested in); and see if they have covered your concerns. This will make your reading shorter & directly in line with your interests.
For more information: Contact Union County directly 541-963-1001; or, Stop B2H Coalition: firstname.lastname@example.org
proposed DOE rule amendments below
Energy Facility Siting Council (EFSC) Public hearings February 23 and 24, 2017
Thursday, February 23,
8:30am – 5:00pm Cousins' Country Inn,
2114 W 6th St, The Dalles, OR 97058, USA
The Department of Energy is planning to implement two amended rules which will cause irreparable damage to Wildlife and citizen's right to due process when actions are taken to build energy developments in the state.
I encourage you to review the attachments and consider submitting comments and objections to the impacts they will have. Public hearings will be held on these two rule amendments on February 23 and February 24.
SUMMARY OF DEPARTMENT OF ENERGY PLANNED CHANGES TO AMENDMENT CONTESTED CASE RULES
The Department of Energy (DOE) is once again demonstrating that they should not have control of the hearings process. Currently the DOE is the only state agency which writes regulations, receives incomes from developer applicants, controls who is allowed a contested case, and hires its own hearing officers to hear contested cases about their decisions. The proposed amendments reinforce the existing process; they lack objective criteria necessary for guiding transparent, equitable decisions. The current 8 pages of rules are being replaced by 32 pages of amendments, all apparently designed to deny the public access to the decision making process. To date, DOE has a 100% record. It has denied every request for a contested hearing on amended site certificates. The new and confusing rules will further complicate the process and guarantee the same questionable outcomes.
rule changes will:
Continue to give the DOE and EFSC total control over who is allowed a contested case hearing.
Create procedural barriers to further complicate the process and provide additional procedural justifications for 100% denials of contested case requests.
Increase time to process amendment requests.
Increase costs to developers requesting amendments.
Allow DOE to hire additional staff to deal with the new process which developers will have to pay for.
Eliminate required notification to all special advisory groups when amendment requests are being reviewed.
Eliminate required evaluation of an entire development’s impacts when processing amendment requests to increase the size of a facility.
Allow waiving some requirements of the proposed rules for developers; no such waiver will be available to the public.
Fail to provide the objective criteria necessary for evaluating contested cases based on the impacts of given amendments.
strongly encouraged to submit
comments regarding these
They are unnecessary,
burdensome, costly and, in several
areas, inconsistent with
Attached are the specific rules which are going to change. Feel free to sign this in its entirety or pull from it any information or references you wish to emphasize.
Irene Gilbert, Legal Research Analyst
Friends of the Grande Ronde Valley
1) DEPARTMENT OF ENERGY PLANNED AMENDMENT RULES DENY PUBLIC ACCESS TO CONTESTED CASE PROCESS:
County Board of Commissioners work
The Union County Board of Commissioners will hold a Work Session regarding the 305 mile Boardman to Hemingway (B2H) Transmission line that is proposed by Idaho Power, on December 21, 2016 at 6:00 p.m. The meeting will take place in the Misener Conference Room, 1001 Fourth Street, La Grande, OR.
At the Work Session there will be a presentation, a "360 view of B2H from a citizen's perspective." Instructions, talking points and protest letters will be shared and details on how to file a protest and/or comment on the Final Environment Impact Statement (FEIS) will be discussed. The Final Environment Impact Statement (FEIS) was published on November 25, 2016 and the deadline for filing protests and comments is Christmas Day and must be mailed and postmarked by December 23, 2016 in order to be received on time.
The 360 presentation will: 1) look Idaho Powers Integrated Resource Plan which is the document that starts the process of building the transmission line and the role the Idaho and Oregon Public Utility Commissions play in the process; 2) the role BLM plays in developing the Environmental Impact statement for federal lands, and 3) the role that the Oregon Department of Energy's' Facility Sitting Committee plays for locating the line on private and state lands. Seventy percent of the transmission line will be on private land.
If this transmission line is build it could become a de-facto utility corridor and other utilities could use this right of way for their projects.
For more information contact, Jim Kreider at email@example.com.
"Hello" to Stop B2H Coalition Members and Others
from Jim Kreider of the Stop-b2h coalition 12/07/16
Hello Stop B2H Coalition Members & Other interested parties,
By now, you may have been notified about the release of the Final Environmental Impact Statement (FEIS) on the Boardman to Hemingway project last Friday. There is limited time—only 30 days for public comment--so much for Senator Wyden’s request for more time?! The comment period is also limited to “protest comments” on technicalities of the FEIS and/or the Land Use Plan amendments of the BLM and USFS.
While this may sound like too much to take on, especially over this holiday timeframe, take a breath and we’ll attempt to simplify and prepare. That said, this is a work in progress and expect that you will receive more emails from us over the next few weeks. What follows are:
· some initial pointers for better understanding the 3000+ pages and maps!;
· how you can learn more;
· how you can prepare for submitting your public comment; and
· as an FYI: a brief summary of our strategies and progress to date.
Pointers: These are a few tips we have learned over the past week. As we understand the document better, we will share anything new.
· Go to the B2H web site or the local library to read the FEIS.
· There is much confusion with the executive summary narrative, including maps and tables because they continue to intertwine the, “Applicant’s Preferred Route,” the “Environmentally Preferred Alternative route,” and the “Agency Preferred Alternative.” When reading be sure you are clear which they are talking about.
· If you go to the web site there is a cool new feature that BLM added to the maps: i.e. Interactive Maps. Here, you can use the filtering feature called “Layers” to examine parts of the routes in more detail. For example, you can filter by land use, ownership, sage grouse habitat, historic trails, and more. It also has a feature where you can put in your name or address (or someone you know) and see it pinned on the maps.
Pointer: once you put in a name or address and click "go" the results appear in the lower right of the page and you might have to scroll down to see the results. Then you'll need to click on the name or parcel identifier and scroll back up to the map to see the results. Then normal Google map controls work. Nice.
· One of the most important parts of the Maps (Project or Interactive) is to be clear on the “Agency Preferred” which is the light blue line. Why they confuse it with all the others is well?... being comprehensive I guess?
· The Table of Contents (including Acronyms) is 50 pages! However, if you don’t understand their format it will be difficult to jump to the place you want to read. Probably good practice to read the Exec Summary (only 72 pages); but it is confusing because it references the links to all the sections. My head was spinning. The outline of the document was much clearer after studying the table of contents. Then, I knew which sections to go to—for my own interests. You will likely need to do the same.
· Finally, if you received a packet with a DVD and packet of printed maps—beware! These maps are NOT the Agency Preferred Alternative! Rather, they are simply all the alternative and variations that they studied.
Learn More: If you would like to talk about this, feel free to call or email Jim or Fuji anytime. We are anticipating a public informational meeting the week of the 12/12 or 12/19; and we will keep you informed.
Preparing your comments: The “Dear Reader” document attached to the FEIS, outlines the structure and rules for submitting protests/comments. It also states that this is “not a public comment period but a protest period.”
· You have every right to comment! They may not consider your comments; however, we advise that you still “go on record.” This might be helpful if we ever need to litigate.
· We will need to submit our protests/comments in writing (via mail post or overnight.) You may submit via email; but it must be followed up by a written document. This is different from the Draft EIS. This is important for your timing—remember these are due on 12/25 - Christmas. (Their gift to us?!)
· There is an outline of what the “protest” comment should contain within the Attachment with the “Dear Reader.”
· We hope to have talking points or other information to help you with your comments by the week of the 19th. We will send another posting that week. Sorry for the tight timeline; but I guess that’s part of the X-mas gift? .... Plz mark your calendars.
Strategies: The following correlates to our Stop B2H 4-pronged strategy. It is only informational.
1) Protest/Comments on the Federal Environmental Impact Statement & Land Use Plan Amendments: all of the above.
2) Utility ‘Need’ & PUC regulatory processes: a number of us continue to attend the monthly Idaho Power Co (IPC) Integrated Resource Planning (IRP) meetings to learn –and hopefully debunk—the utility’s “need” for the project. This is a parallel process to the federal EIS process; but I wanted you to know that while it could be a long shot, we believe we have made significant headway. Briefly, we have learned that IPC is consistently under-reporting their energy conservation and over-forecasting their energy need! We have made new and unusual allies. The biggest thing to know is in the end, it will be the Public Utility Commissions of both states who will allow the utility to forward the costs on to the ratepayers. If this is not approved; the project will unlikely proceed. Anyway, if you are interested in this, I can tell you more on a phone call.
3) State of Oregon Dept of Energy’s Energy (ODOE) Facility Siting Council (EFSC): there are a couple of areas we have been working to prepare in anticipation of the EFSC process, which is another entity involved in siting the transmission line, specifically on state and private lands which is about 70% of the length. The County’s B2H Advisory Committee should have public briefings from ODOE staff early in 2017 to explain more of their regulations to us/the public. Secondly, a number of rulemaking changes have been proposed by ODFW/ODOE/EFSC. The reason this is important is because some of the proposed rules will lessen wildlife protections for siting wind farms and other energy facilities. One person in our group follows this closely and a number of us have submitted public comments/testimony. Another comment period is ending on 12/16. Pfff… like we don’t have our hands full already?! If you'd like a copy of our summary and suggested comments to ODOE let me know.
Finally, we have also participated via comment, to the State Legislature’s Oversight Committee on the ODOE. Save you the details, but it’s about the fact that ODOE is an agency that forecasts, plans, sites, monitors, regulates, etc… all within one agency including hiring their own hearing officers and doing their own rulings on “contested cases.” It is a bit of a revolving door with state and industry people trading roles over the years – like, the “fox watching the hen house.” We would like to see some of the agency broken up and housed in other state agencies. Again, if you are interested in this, I can tell you more on a phone call.
4) Coalition Building: basically we have 5 organizations who have joined our Stop B2H Coalition and we are looking for more. We foresee this going on for a while longer; and so, the more the merrier?! The other thing is that we might find ourselves litigating somewhere along the line & fundraising for an attorney which be critical.
Hope this informs you well. Moreover, we really hope that we can count of you for your continued interest and support over the next couple of weeks!
All the best,
Your Letters of Concern requested by Stop-b2h
from Jim Kreider of the Stop-b2h coalition 10/28/16
Intern Committee on Department of Energy
Oversight will be having a meeting
on November 4, 2016. Their agenda is here.
The Oregon Department
of Energy (ODOE) has had a troubled past
that is effecting our future. This
bipartisan committee has asked for citizen
input on how to improve ODOE’s
operations. Currently ODOE writes,
applies, and interprets the rules,
controls the hearings process, and
monitors compliance to its rules. Their
performance has been less than stellar.
The Oregonian has done several stories on
the ODOE and this story
gives a nice overview.
The oversight committee
will review and discuss recommendations
that have been made to them by the public
on November 4, 2016. Our voices need to be
Our friend, Irene
Gilbert, Legal Research Analyst for
Friends of the Grande Ronde Valley
(FGRV) has been urging us all to
submit comments and has shared many draft
ideas and letters to submit.
These draft ideas and
letters have been merged into one letter
that we all can send to the oversight
committee. In order to focus our voice
we’re using Change.org. Their web tools
allow people everywhere to start
campaigns, mobilize supporters, and work
with decision makers to drive solutions. This
is the link to our letter/petition and
we ask that you go there, read the
letter, and sign the letter/petition.
The letter will go to all the oversight
committee members and you’ll get a
If you’d like to
personalize or edit the letter/petition
and send it yourself to the committee
members their email addresses and the
letter is below.
================= If you’d like to edit and send separately =======================
are the members of the oversight committee
Lee Byer : firstname.lastname@example.org
Use this to cut and paste the names
above into the to header of your email
If you use this method please cc me at email@example.com so we can track responses. Thanks!
To: Joint Legislative Oversight Committee Department of Energy
Testimony - ODOE Oversight Committee
Hearing Nov 4th
The State of Oregon’s
Energy Siting Process and Department of
Energy (ODOE) have long been problematic
and I am grateful that this committee has
been established to investigate and make
recommendations for improving or changing
the Department. Thank you for your good
The main problem that I
see is that ODOE controls all parts of the
siting and oversight of energy
developments in the state. They write the
rules, apply the rules, interpret the
rules, control the hearings process, and
monitor compliance with the rules. The
ODOE hires their own hearings officers who
consistently support the department's
recommendations. There is no place to file
complaints/appeals if the hearings
officer behaves in an unethical manner.
There has been a lack of accountability
for the projections energy developers are
making, a failure in assuring ongoing
compliance with site certificate
requirements and a failure to allow public
access to the increasing amount of
information which is developed or changed
after the site certificate is
There is a growing lack
of credibility within the Oregon
Department of Energy, confirmed and fueled
by media coverage, resulting in a lack of
trust that their siting process and
monitoring processes are fair and neutral.
Please consider implementing some of the
suggestions below. I understand that there
will be multiple options available to you,
but please take at least one step forward
in the direction of improved
accountability, transparency and effective
public policy implementation. The first
five recommendations are structural in
nature and the remaining are more process
Thank you for your time
and consideration. Please keep me informed
of the work and recommendations of this
#1. Remove the whole Siting
Division or at a minimum, remove the
Contested Case process from the control
of the Oregon Department of Energy.
The Contested Case process is probably
the biggest “hot button” item within ODOE.
This function needs to be transferred out
of the department if any credibility to
the state’s siting process is to regain
ODOE has shown little or no interest in
addressing problems with the process. They
were directed to make changes to the
contested case process for amended site
certificates two years ago. They have yet
to update the rules. The Administrative
Judges are employees of the ODOE and they
are quick to deny standing to parties
opposing development or aspects of a
development. They only allow hearings on
specific siting requirements as opposed to
hearings based upon other related rules
such as a decision to ignore timeframes,
failure to follow procedures, etc.
They require details in contested case
requests that are not required by the
statutes or rules; and they have never
allowed even one contested case on an
amended site certificate no matter how
great the changes being proposed are.
Finally, they require strict adherence to
judicial rules from the public even though
this is a quasi-judicial process.
These are just a few of the numerous
complaints that have been placed on the
record from lay persons, attorneys and
organizations throughout the state
claiming unprofessional and biased
handling of contested cases.
I believe Contested Cases should be
transferred to Land Conservation and
Development Commission (LCDC). Site
certificates are basically a land use
determination and LCDC already handles
most land use contested cases. This would
be a logical fit.
#2. Eliminate the Energy
Facilities Siting Council (EFSC) or
separate them from ODOE.
The people on the Council are political
appointments. They may not have the
expertise to make the decisions regarding
the siting of energy developments in the
state. As a result, they simply approve
whatever recommendations come to them from
the ODOE staff. If ODOE is going to be
making the decisions, they should be held
accountable for those decisions and the
results. There is no point in having
another layer of bureaucracy when they are
not really serving any purpose other than
rubber stamping decisions being made by
If it is determined that EFSC should
still exist, then it should be moved under
the Office of Administrative Hearings
where it would be required to adhere to
the hearing procedures that other agencies
are required to follow.
#3. Move the
staff currently responsible for
monitoring compliance with the site
certificate requirements to Oregon
Occupational Safety and Health Division
(OSHA). Include processing of
complaints in that position description
and allow the public access to the
results of the monitoring visits.
There is a growing lack
of credibility within the ODOE resulting
in a lack of trust that their monitoring
process is fair and neutral. This
perception is magnified by the fact that
the monitoring results are not made
public. Currently, monitoring
appears to focus on the types of
activities occurring at the site rather
than evaluating whether or not the site
certificate requirements are in
place. There is no third party
testing or audit verification to show
whether there is compliance with such
items as noise to determine if the
projections were accurate. Adding to this
issue is the fact that a “Public Complaint
process” is not consistently available and
the results are not compiled so that
problems can be categorized, analyzed and
Oregon OSHA is in the
business of conducting inspections to
determine whether or not businesses are in
compliance with regulatory
requirements. Oregon OSHA staff
receive ongoing education in relevant
topics such as Violation Identification
and Documentation, Environmental Hazards,
Noise, Report writing, Electrical, etc.
which are topics necessary to perform this
function effectively. Oregon OSHA
also has Industrial Hygiene staff
qualified to do testing, including Noise
Monitoring to confirm that developers are
not exceeding the limits. Since the
statutes state that the developer is
responsible for paying for staff work
required to issue and monitor site
certificates, this would be budget neutral
for Oregon OSHA. It makes sense to
place the monitoring and enforcement
duties under an agency which specializes
in doing regulatory-type work.
#4. Allow the individual
Counties to decide whether they want to
process Energy Facility Applications,
Requests for Amendments, and Site
Certificates for any size development
that will be constructed within the
boundaries of a single county.
This could be a function delegated by
the state to counties.
The Oregon Department of Energy is
removed from the resources and protections
necessary to maintain the quality of life
at the local level. They make decisions
absent an understanding of the
significance of protected areas, local
geology, and why local land use plans
include the protections they do. The
Oregon Department of Energy is quick to
revert to the general rules included in
the state land use plan and override the
wishes and intent of the local
communities. Frequently they use the
statement "no significant impact" to
describe impacts that most people living
in an area would consider major impacts on
Most counties that currently have wind
farms or other energy developments have
already gone through the siting process
for at least one industrial energy
development. For example, Baker County,
Union County, Morrow County, Umatilla
County, Harney County, Sherman County and
Deschutes Counties have all sited wind
developments. Allowing the siting to occur
in the counties impacted by the
development is more likely to assure
appropriate siting locations which honor
the resources important to the people
living in the area and supports better
relationships between the developers and
the communities impacted by the
#5. Establish a third party
location for people to lodge complaints
regarding the Department of Energy as
well as energy developments (e.g.: wind,
gas, solar, transmission, etc).
These complaints could then be tracked and, hopefully, addressed prior to them becoming significant political issues. The information would then be available to the department, the legislature and the public and should reinforce the fact that progress is being made in reducing the number of concerns regarding the department and the site certificates that they are issuing.
Currently there is no designated
repository for complaints regarding the
Oregon Department of Energy or individual
energy developments. As a result, by the
time issues raise to the surface, it is
often in the form of a newspaper article
or other public forum. There would be an
advantage to the persons siting energy
developments, as well as the legislature
in identifying what the bulk of the
concerns are as this would provide an
opportunity to be proactive in addressing
them prior to them becoming larger.
#6. The minutes of the Energy
Facility Siting Council need to include
information about the content of the
public comments so that the reader knows
what the concern was or the
recommendation that was made.
The recordings of the Energy Facility
Siting Council should be available on line
just like the legislature hearings are
available for the public to review
immediately after the hearings are heard.
The minutes of the meetings are not
posted until several months after the
meetings are held and they do not include
important information regarding the public
comments that are made. This means that no
action occurs on public comments and the
public is discouraged from making
The Energy Facility Siting Council
(EFSC) or Department of Energy (ODOE)
should be required to make some kind of
response to formal public comments. Either
answer the question, say what they are
going to do about the issue, recognize in
writing that they got a comment and what
they are going to do about it, or not do
The minutes of the meetings do not say
what the public comments were or what the
Energy Facility Siting Council action or
response is. They only make vague
statements that someone made a public
comment or that someone made a public
comment on a topic, but not what the
comment was. The public does not believe
that there is any point in making public
comments as no one listens or cares what
they have to say. The current system makes
people believe that it is a waste of their
time to even try to give information
during the public comment periods since
nothing will come of it.
#7. Require a showing of
“need” prior to issuing a site
There was a presumption that market
forces would control the number and timing
of applications for site certificates when
the rule was enacted. That has not
occurred. This has been partially due to
the number and amounts of subsidies and
tax credits available to wind and solar
developments. What has actually occurred
is that developers have gone through the
process of obtaining site certificates
even though there was no market for the
energy they would produce. These
developers have asked for multiple
amendments to the site certificates due to
changes in the technology and to keep the
site certificates active in the hopes that
there will be a market for the energy at
some future date.
This has resulted in ODOE spending
hundreds of hours processing site
certificates and amendments on
developments that have never been
constructed. In the meantime, the material
in the files has become more and more
dated. It also has resulted in active site
certificates which are for developments
that have not been constructed. This makes
it difficult to assess the actual impact
of these developments on the resources of
the state or to have a realistic sense of
what the cumulative impacts of the
multiple developments will be on the
environment and quality of life for those
living in proximity to the planned
#8. Require notice to
property owners within one mile of a
proposed energy development that a
proposal has been made to build a
development within a mile of their
Currently the notices are only sent to
people living within 100, 250 or 500 feet
of a proposed development, depending upon
the zoning and type of land. The Oregon
Department of Energy Rules in Division 20
identify the distances from a wind farm or
other energy development used to notify
people living around a proposed
development that it is planned.
It is common that people who live or own
property beyond these distances do not
even know that a development is planned
until it is too late to make any comments.
Individuals with property within one mile
of a proposed energy development should
receive notice when a Letter of Intent is
filed informing that there is a potential
development that will be located within a
mile of their homes or property. How would
you feel if the first you heard that a
wind farm was going to be built within
1000 feet of your home was when the
developers started to build it?
#9. Require Department of
Energy to implement recommendations from
the US Fish and Wildlife Department
related to federally protected species
or provide documentation regarding why
the recommendations lack merit.
The US Fish and Wildlife Department
makes ongoing recommendations about how to
limit the deaths of federally listed
threatened and endangered species. The
Department of Energy and Energy Facility
Siting Council largely ignores the
comments regarding things like setbacks
from nest sites for federally endangered
birds because they are only required to
honor state laws. The rule under OAR
345-022-0070 (2) says" For wildlife
species that the Oregon Fish and Wildlife
Commission has listed as threatened or
endangered under ORS 469.172(2), the
design, construction and operation of the
proposed facility, taking into account
mitigation, are not likely to cause a
significant reduction in the likelihood of
survival or recovery of the species."
The impacts to wildlife of the state are
cumulative; the more energy developments
that are built in Oregon, the greater the
risk of bringing a species of animals to
extinction. This cumulative impact is
being ignored for energy developments. The
ODOE and EFSC use an arbitrary "Threshold
of Concern" before they consider
mitigation or changes to reduce the
fatalities at wind farms. Continued use of
this standard which includes deaths of
both state and federally listed threatened
and endangered species absent any
scientifically valid basis means they are
approving the deaths of protected animals.
There is no reason to believe that the
continued use of this standard will not
result in increasing the likelihood of
survival or recovery of the species.
Require ODOE to obtain data that supports the determination that the predicted number of threatened and endangered species they are including in their "Threshold of Concern' will not reduce the likelihood of survival or recovery of the species.
Stop-b2h Meeting September 29th
6 PM @ ORA Office, La Grande
from Fuji & Jim Kreider September 25, 2016
movement is alive and well!