In summary, there are serious problems with the draft Programmatic Environmental Impact statement (PEIS). The comments that follow are focused primarily on the portions of the draft that deal with the economics of wind energy development. The data and conclusions reflected in those parts of the draft are invalid because: · Major elements of the true costs of producing and delivering electricity from wind energy have not been taken into account. · The “economic model” underlying the economic analysis is defective. It is important that Department of the Interior (DOI) and Bureau of Land Management (BLM) officials recognize that much of the information relied on by those drafting the statement has come from organizations that promote wind energy development. This information is often biased and should not be relied on as a basis for BLM decisions. The net effect of the deficiencies is that the draft PEIS grossly overstates the potential benefits of wind energy while grossly understating the true costs. In fact, it is far from clear that the PEIS justifies any development of wind energy on BLM-administered lands. Any conclusions in that regard will have to await correction of the fundamental deficiencies in the economic analysis.

Download: 211 Wind BLM Draft EIS Comments.pdf

Note: As you probably know, the US Bureau of Land Management (US Department of the Interior) has been granting permission to build "wind farms" on US-owned, BLM-administered lands. Other proposed projects are now being considered. On September 10, 2004, BLM published a "Draft Programmatic Environmental Impact Statement (DPEIS) in the Federal Register with a request for public comments -- which were due (or had to be postmarked) yesterday. My comments are attached. (The first few paragraphs are quoted below if you'd like to avoid reading all 9 pages.) There is a lot of useful information in the draft PEIS (which you can find at http://www.windeis.anl.gov ). However, key parts of the draft are bad. The way the draft PEIS was developed is also a sad commentary on the way "our" federal government operates. BLM apparently contracted with the US Department of Energy's Argonne National "Laboratory" (ANL) to prepare the draft PEIS. The people at Argonne then contracted with none other than DOE's National Renewable Energy "Laboratory" (NREL) for a significant part of the work, including a so-called "Economic Analysis." Both ANL and NREL are 99% (if not 100%) financed with our tax dollars. NREL, of course, is the organization that has, for years, been developing, supporting and/or distributing highly biased "analyses" and "reports" about wind energy and has played a major role in misleading the public, media and government officials about the costs and benefits of wind energy. As a result, the so-called "Economic Analysis" in the DPEIS is just what you would expect -- as summarized below. Isn't it fun to see your tax dollars spent in this way? Glenn Schleede