RWEI 2011 - Virginia Permit by Rule

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Presentation Description

Carol Wampler, Virginia DEQ, presented on Virginia's Permit By Rule that allows wind energy to be develop in Virginia at the fourth annual Southern Appalachian Regional Wind Energy Institute meeting in Washington, D.C. October 26, 2011. Details can be viewed at www.regionalwind.org. RWEI is a project of the Southern Alliance for Clean Energy - www.cleanenergy.org.

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Presentation Transcript

Virginia’s Wind Permit by Rule: 

Virginia’s Wind Permit by Rule Carol C. Wampler Virginia Department of Environmental Quality For RWEI Annual Meeting October 26, 2011 Washington, D.C.

Slide 2: 

VIRGINIA ACTS OF ASSEMBLY -- 2009 RECONVENED SESSION CHAPTER 808 & 854

Directs DEQ to develop by regulations : 

Directs DEQ to develop by regulations “ permits by rule . . . for the construction and operation of small renewable energy projects, including such conditions and standards necessary to protect the Commonwealth’s natural resources ”

Statutory Goals:: 

Statutory Goals : Promote renewable energy – provide certainty, timeliness, reasonable regulatory requirements Protect natural resources – provide enforceable standards that are protective of wildlife & historic resources at/near project site

What is a “small renewable energy project”?: 

What is a “small renewable energy project”?

An electrical generation facility producing electricity from . . . : 

An electrical generation facility producing electricity from . . . sunlight wind falling water motion tides geothermal power < 100 MW OR

An electrical generation facility producing electricity from . . .: 

An electrical generation facility producing electricity from . . . biomass energy from waste municipal solid waste < 20 MW

An electrical generation facility producing electricity from . . . : 

An electrical generation facility producing electricity from . . . WIND sunlight falling water motion tides geothermal power biomass energy from waste municipal solid waste Statutory Deadlines for Permits by Rule: January 1, 2011, for WIND July 1, 2012, for all others

PBR TIMELINE

WIND: 

WIND 22 Regulatory Advisory Panel Meetings during 2009-2010 2 Public Comment Periods 1 Public Hearing 1 Public Meeting Approval by DEQ Director Executive Review Final Regulation on December 22, 2010 Guidance Completed & Posted on DEQ Website

What process does the PBR replace?

Former Practice:: 

Former Practice : Developer applied to SCC for individual permit Environmental agencies submitted recommendations to SCC re proposed site SCC decided what environmental requirements to include in order

New System:: 

New System: Developer applies to DEQ for permit by rule (PBR) Environmental requirements are set forth “up front” in regulation for all sites DEQ, in consultation with other state agencies, reviews application If applicant meets requirements and submits required certifications, then DEQ notifies applicant that project is authorized under PBR

WHAT IS THIS “PERMIT BY RULE”?: 

WHAT IS THIS “PERMIT BY RULE”?

A Permit by Rule (PBR) is . . : 

A Permit by Rule (PBR) is . . Expedited permitting process used by DEQ for certain solid waste facilities Regulation stating “up front” the criteria that applicant must meet Requirement that applicant submit docs/certification that has met requirements Requirement that DEQ review submission for completeness & adherence to regulation If complete (& adequate), then DEQ notifies that project is authorized under the PBR

A Permit by Rule is not . . .: 

A Permit by Rule is not . . . An individual permit Site-specific Based on a case-by-case technical analysis

Statutory Permit by Rule Requirements

PBR’s 14 Criteria 10.1-1197.6.B: 

PBR’s 14 Criteria 10.1-1197.6.B Notice of intent Local-government certification Interconnection studies Final interconnection agreement PE certification of generation capacity Analysis of impacts on NAAQS

PBR Criteria (continued): 

PBR Criteria (continued) Analysis of impact on natural resources Determination of likely significant adverse impacts; mitigation plan & monitoring PE certification of design Operating plan (e.g., curtailment) Site plan (e.g., micro-siting) Certification re environmental permits Public meeting Public comment period

DEQ’s Operative Provisions 10-1:1197.6.B.7 & 8:: 

DEQ’s Operative Provisions 10-1:1197.6.B. 7 & 8 : Analysis of natural resources Determination of likely significant impact Wildlife Historic resources Mitigation & post-construction monitoring

Chief PBR Operative Provisions by Resource: 

Chief PBR Operative Provisions by Resource Analysis Wildlife HR Other Significant Wildlife HR impact ? Mitigation Wildlife HR & Monitoring

Does the PBR have “de minimis ” provisions like the SCC’s?

By regulation . . .: 

By regulation . . . 500 kW & below: NO REQUIREMENTS >500 kW to 5 MW: NO SUBSTANTIVE REQUIREMENTS

Note :: 

Note : All necessary environmental permits (obtained or applied for) are a statutory prerequisite for PBR coverage (including DEQ permits).

Further Note:: 

Further Note: 10.1-1197.6.A DEQ has authority over CONSTRUCTION and OPERATION of small renewable energy projects

But – Phases of a Project:: 

But – Phases of a Project: Siting CONSTRUCTION OPERATION Decommissioning

Local Government Authority: 

Local Government Authority Siting – compliance with local land-use ordinances Decomissioning Health, safety, welfare Police powers

Remember . . .: 

Remember . . . Local government certification of compliance with land-use ordinances is a prerequisite for PBR coverage

Local Outreach: 

Local Outreach Chairman, DEQ Director David Paylor First meeting of informal Stakeholder Group held on March 31, 2011. Fourth meeting November 3, followed by November 16 Tentative goals include model ordinances, technical support, and repository of research

Local Outreach Informal Stakeholder Group includes:: 

Local Outreach Informal Stakeholder Group includes: Local Government Developers NGO’s/Citizens State government Academia

Notes on Statutory Construction

“Small Renewable Energy Project” PBR: 

“Small Renewable Energy Project” PBR Virginia Energy Policy Permit by Rule Reality e=protect local resources Legality E=promote renewable energy

“Paylor Principle”: 

“ Paylor Principle” We should not make it more difficult to permit a renewable-energy facility than to permit other types of development, unless there is a very good reason. (e.g., wind turbines’ impact on bats – a special, unique impact)

Our special challenges:: 

Our special challenges: One-size-fits-all regulation vs. site-specific resource protections Authority vested in DEQ Director – a first Substantive expertise resides in other state agencies; however, regulatory authority resides in DEQ Significant experience in renewable-energy development lies outside state government RAP must complete work on 9 renewable media in roughly 3 years, when one regulatory action usually = 1 ½ to 2 years

Now that the Wind PBR is final, how is it working?

Permitting Process: Suggestions: 

Permitting Process: Suggestions Informal pre-application meetings with DEQ – early and often DEQ will invite sister agencies as requested or appropriate DEQ will issue written decisions regarding pre-application plans, if requested By regulation, permit decision within 90 days after complete application submitted

Federal requirements . . .: 

Federal requirements . . . Although not referenced in our state regulation, federal requirements must be met. Potentially, for example: Army Corps, FAA, US Fish & Wildlife, National Park Service

Our Policies & Goals include . . .: 

Our Policies & Goals include . . . Certainty – for both developer & environmental interests Timeliness Balance between facilitating renewable energy & protecting natural resources Sound science Consensus-based decisions where possible Partnership of local, state, & federal authorities Potential “lessons learned” for other states and federal government?

Example: Wildlife: 

E xample: Wildlife Pre-construction analyses – limited by statute to 12 months; regulation requires extensive studies Necessity & dimensions of mitigation plan based on analyses, but adjusted per post-construction adaptive management (modifications without fee for 1st 3 years) Post-construction monitoring required by statute By regulation, monitoring extends for life of project, but after first year, costs of mitigation & monitoring are capped at an overall budget of $5000/turbine/year

Example: CAPZ “Coastal Avian Protection Zones” Mitigation Offsets : Research or Habitat Protection

Will we be successful in meeting our PBR goals?: 

Will we be successful in meeting our PBR goals? Doing our best! Stay tuned . . .

Thanks for your interest!: 

Thanks for your interest! Website: www.deq.virginia.gov Program Information – Renewable Energy

Contact information . . .: 

Contact information . . . Carol C. Wampler, DEQ 629 E. Main Street Richmond, VA 23219 804-698-4579 carol.wampler@deq.virginia.gov carol.wampler.renewable.energy@gmail.com

Questions?