Comments from Dudley Greeley December 12, 2007 Some observations: 1.As I get older I may be getting more pragmatic but I am bothered that this process proposes to give a contentious, self-interested minority the ability to prevent a project that might offer tremendous benefit to the state just because the small minority is willing to launch into conflict mode and the individuals are willing to continue to force the external costs of the power they use onto others. The state of Wisconsin attempted to deal with this concern in a more straightforward and objective manner by passing a law that prevents a local jurisdiction/group from ruling against a renewable-energy project unless the basis is health or public safety (or similar - don't have reference handy but task force should have this statute in hand and it deserves careful review). While I am up near the front of the line when it comes to advocating that society not force a minority to accept clearly unfair burdens, I also support protection of the interests of the many over the preferences of the few. 2. The document would benefit tremendously from a glossary that clearly defines many of the terms - particularly terms such as "wildlands". If we define "wildlands" as being areas designated at National Wilderness Areas, State and National Parkland, and Wildlife Preservation Area..., this is a clear metric, without a definition, we have done little to move the issue of establishing workable standards. Without more agreed-upon "objective" standards Maine could go through this task force effort and functionally not be much better off than it currently is regarding siting battles. 3. I propose requiring evaluation of any given project to include evidence that the likely alternatives to the proposal will not result in forcing more severe external costs on the citizens of Maine or elsewhere. Maine has a moral obligation to do its part to mitigate total impacts. A question that deserves to be answered in any siting question is: If not this project, What? It isn't as if a given project will be denied and there will thus be no impact..... 4. Community and small scale wind: I am an enthusiastic supporter of efficient, sustainable, distributed power systems. As everyone engaged in this process probably knows, the efficacy of wind projects is a function of some well-established physical principles: A given wind technology's generation rate is a function of the cube of the wind velocity and the square of the diameter of a typical two or three bladed turbine. Small wind systems in poor or marginal wind resource areas do not deserve public support unless they demonstrate they offer avoided GHG emissions at lower cost than available options. A knowledgeable critic of a marginally-located, small wind system pointed out that the system was rated BY ITS MANUFACTURER to offer an expected hourly average generation rate of .15 kWh/hour over the course of the year (1314 kWh/year). The critic went on to note that the same expected GHG emissions benefits could be had by replacing two 100 Watt incandescent lamps with two 23 Watt CFLs if the lamps had to be "on" for 24 hours every day of the year. The math checks out. The turbine installation in question cost $15,000. The light bulbs are available for less than $2.00 in Maine and less than $15 just about anywhere in the country. So, put the same small wind system in a great wind resource and that might be the equivalent of replacing 50 or even 100 inefficient incandescents ? Maine should replace light bulbs and get rid of inefficient fridges before it subsidizes inefficient, small-scale wind. Let the rich states experiment and let Maine focus on making better use of more efficient systems that are underused in the state. Maine should be working on strategic improvements, not dabbling in what some call "Enviro-Bling". Regards, Dudley Greeley University of Southern Maine Environmental and Economic Sustainability Office