I am speaking today on behalf of the Maine Appalachian Trail Club and the Appalachian Trail Conservancy. For more than 50 years I have hiked and worked on the Appalachian Trail through the area that would be impacted by the proposed Maine Mountain Power development. The central issue, from the perspective of the Appalachian Trail Community, is aesthetics--beauty. That is the core of the Trail experience. The proposed development would have the greatest negative visual impact on users of the Appalachian Trail in Maine in the 72-year history of the Trail. Moreover, although the LURC Staff analysis with regard to visual impacts focuses almost exclusively on Appalachian Trail users, aesthetics is also at the core of much of the attractiveness of Franklin County to tourists and full-time residents.

I have long admired the Maine Land Use Regulation Commission. It has been a great force for good in our state. Although the Appalachian Trail community has been involved in LURC decisions that have not always been favorable to the Trail community's interests LURC has, in my opinion, generally followed a path of fair analysis and sound judgment. The Staff recommendation for Zoning Permit 702 does not reflect the LURC process that I have admired in the past. Perhaps that past admiration explains why the Staff recommendation came as such a shock. Let me highlight several examples, from the 116-page recommendation, to explain my deep concerns.

* Nowhere in the entire 116 pages of ZP702 is there any mention at all of one of the most striking differences between the proposed development and every other kind of P-MA development that LURC has ever considered: motion. Unlike radio towers, roads, buildings, and ski trails, these wind machines will move. That will have an enormous effect on their visual impact. Nor will these wind machines be like a kitchen fan. The blades, though moving rapidly, will so huge that they will be clearly visible throughout their range of motion. The skyline along Black Nubble and the Redington Range will appear to crawl. And, keep in mind, this will be a skyline view for most viewers. The LURC Staff received written and verbal testimony regarding this matter and chose to ignore it.

* Throughout the report, the Staff emphasized local support for the development, as represented by the petitioner, and belittled evidence of opposition. The Staff noted (Page 77) that the Appalachian Trail Conservancy had "prepared and made available on-line a letter for its membership to sign and electronically submit to LURC in opposition to the RWF. Fifty-three such letters were submitted from ATC members living primarily in the United States. Of these letters, four were submitted by Maine residents." Nowhere in the report is there mention of the massive support campaign initiated by developer. Astonishingly, while listing a petition from the Portsmouth Naval Shipyard with 40 signatures supporting the project, the report fails to even acknowledge the more than 1,800 signatures of mostly local people on a petition circulated by the Friends of the Western Mountains opposing the project.

* The Staff based some of its findings on information from LURC contract visual impact expert witness Dr. James Palmer. According to ZP 702 (page 98), Dr. Palmer suggested that, " If a hiker did not prefer the view of the RWF, he/she could take in the view in the other direction." Dr. Palmer evidently has never hiked across Saddleback. You could not hike the Appalachian Trail northbound across the Saddleback Range without seeing the wind farm unless you never lifted your eyes from the footpath or walked backwards. This advice suggests incompetence on the part of this "visual expert" or, at best, unprofessional sarcasm.

* Dr. Palmer also stated (ZP 702, Page 98) that, "The open views from high points are more of a consideration when assessing visual impact, but it is difficult to determine the nature of the hikers’ appreciation of landscape features." Understanding that appreciation has been the focus of many years of research by visual impact scientists. The resulting science underlies the analysis presented by the NPS, using USDA Forest Service expertise. I suggest that it is at least as difficult to determine the nature of appreciation for wind energy among windpower advocates within the hiking community who have never set foot on the Appalachian Trail in the Redington area. At the LURC hearing in August, 2006, I testified that, "From personal experience, I tell you that no simulated or photographic representation of the views of the proposed development site from along the A.T. comes close to the views experienced from the Trail itself."

* In its recommendations (ZP 702, Page 570) the Staff state that, "Letters received by the Commission, letters submitted by the petitioner to support its demonstration of need, and the results of the petitioner’s surveys collectively indicated that the proposed RWF will be received positively by as many hikers in Maine using the AT than those expressing a negative response." This is an extraordinary stretch of limited evidence, presented from the developer's side, to a sweeping conclusion that barely, if at all, passes a straight face test.

* LURC Staff ignored ATC’s testimony that there were clear flaws in the methodology and interpretation of the hiker survey. There is reference to the survey of hikers (p. 29, 60) that claims that hikers would only be slightly negatively impacted by the construction of the wind farm and that these impacts are similar to the effects of clear cuts and roads. There is also a statement that ATC, MATC and NPS participated in the survey and that it found that a majority of the respondents felt that the wind farm was appropriate. This assertion is simply not true and was challenged by ATC. Through our testimony we provided much evidence that shows that the developer’s conclusions from the hiker survey were not supported by the data and are misleading. The Staff Recommendation ignores all of this testimony and the conclusion by LURC Staff is contravened by the data.

The Staff recommendation quotes many of the standards for development that the developer must meet to prove that the project will have no undue adverse impact. However, there are explicit statements that wind energy projects do not fit well into the existing LURC rules. The implication is that the Staff is willing to hold this developer to a different (lower) standard than other developers. The Staff recommendation defers to the developer on many of the relevant standards for rezoning and the issuance of a development permit. This is contrary to the LURC rules and Maine statute. A wind farm must meet the same standards as a ski area, shopping center, or warehouse. As much as the Staff might like to treat Maine Mountain Power differently, they cannot selectively apply the rules.

The net effect is that if LURC is to adopt this recommendation and approve the Redington project then no Maine mountains other than perhaps Katahdin, Bigelow or Cadillac would be off limits to development. The Redington project is the largest, highest elevation, most remote wind energy project ever proposed in the Northeastern United States. No other wind project in the country has ever been proposed within one mile of a unit of the National Park System. No development has been approved for the summit ridge of a 4,000 foot mountain in New England in over 40 years. If this Staff recommendation is adopted the precedent will be set that the Mountain Protection Subdistrict (which was intended in the existing LURC rules to be a very restrictive zone) will be open for development throughout Maine.

THE APPALACHIAN TRAIL CONSERVANCY, www.appalachiantrail.org, is a volunteer-based nonprofit organization dedicated to the conservation of the 2,175-mile Appalachian National Scenic Trail, a 250,000-acre greenway extending from Maine to Georgia. Our mission is to ensure that future generations will enjoy the clean air and water, scenic vistas, wildlife and opportunities for recreation and renewal along the entire trail corridor.

THE MAINE APPALACHIAN TRAIL CLUB is a volunteer nonprofit corporation that manages 267 miles of the Appalachian Trail in Maine, including its facilities and corridor.

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Statement by David B. Field Regarding the LURC Staff Recommendation To Approve the Redington Wind Farm

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Statement by David B. Field Regarding the LURC Staff Recommendation
To Approve the Redington Wind Farm