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Energy Facilities Siting
The Sierra Club believes that the protection of human life, public welfare, and the
environment are essential factors to be considered by all levels of government when making
siting decisions. We believe that siting decisions should be made only as part of the
overall land-use planning and should include protection of air and water quality. Such
facilities should be excluded from certain categories of land, and should proceed only
after a need for them has been demonstrated. They should be located near load centers and,
when possible, on or near existing industrial facilities. In locating such facilities,
each level of government should be involved in critical decisions in such a way as to
ensure the most stringent environmental standards. Public participation in siting
decisions should be assured at all stages of decisionmaking. Each state should have an
energy facility siting mechanism with open and complete processes. Actions of applicants
for sites should not be allowed to prejudice siting decisions, and the "banking"
of sites should give guidance rather than allowing early licensing and should not preclude
small-scale renewable energy alternatives. In furtherance of these goals, the following
guidelines should be considered in evaluating specific proposals, plans, and legislation
related to energy facility siting:
Energy Facility Siting Guidelines
1. Decisions about the siting of energy-related facilities can only be made in the
context of sound overall land-use planning. At a minimum the following categories of land
should be excluded from consideration as sites for such facilities:
- Land included in federal, state, or local park or natural area systems, or in
wildlife refuges or management areas, or in such proximity as to threaten the
environmental quality of protected areas;
- Units of the National Wilderness Preservation System, the Wild and Scenic Rivers
System, the National Trails System, or the National Landmarks System;
- Areas reserved for ecological, scenic, natural, wildlife, geological, educational, or
scientific value including Primitive Areas, Roadless Areas, Natural Areas, and Pioneer
Areas;
- De facto wilderness or wild areas on federal lands that are under active study by
citizens groups or government agencies prior to submission of formal proposals and final
action by the Congress for inclusion of the lands in the above systems;
- Wild, natural, scenic or pastoral portions of coasts or shores, including bays,
estuaries, wetlands, lakes and rivers;
- Coastal or riverine areas serving as spawning grounds for commercial and sport
fishing;
- Habitats of rare, endangered, or threatened plant or animal species;
- Areas containing outstanding examples of plant communities, such as virgin timber
stands;
- Valuable archeological or historic sites;
- Prime agricultural lands;
- Lands that play a vital role in the hydrologic cycle such as aquifer recharge areas
and wetlands;
- Land characterized by adverse geological or geophysical characteristics such as
earthquake zones or floodplains.
2. The siting of large, energy-related facilities should not proceed unless a
definitive need for them has been demonstrated, through open public disclosure and
certification of need, which cannot be met through conservation and smaller-scale
alternatives. In the case of electric generating facilities, the impact of large size on
raising required reserve margins should be considered as well.
3. Generating plants should be located as close as possible to load centers to avoid
unnecessary, long, wide transmission corridors; to encourage conservation and pollution
abatement by linking the environmental burdens of power generation with its benefits; and
to maximize efficient use of energy through utilization of waste heat for beneficial
purposes. Where this policy conflicts with clean air goals, emphasis should be placed on
reducing the emission of pollutants rather than relying on remote siting. Since airborne
pollutants have been found to cause damage to the natural environments far form their
source (e.g., via acid rain), remote siting will not prevent environmental degradation.
Any tradeoff between impacting urban and rural/wild environments should be discussed
explicitly, with input from spokespeople on behalf of both environments. In general, new
energy facilities should be located on land that has little other productive value, be
sited in such a way as to be compatible with and encourage the use of waste heat and waste
water and the development of renewable energy resources.
4. The development of new electric transmission line corridors, as a general principle,
should be kept to an absolute minimum. To that end, new transmission lines should,
whenever possible, utilize corridors already established for highways, railroads, and
pipelines, and/or share previously established electric transmission corridors.
5. The need to protect other important resources, such as water resources and quality,
air quality, and minerals, should be carefully considered in the planning for and siting
of energy facilities by all levels of government.
a. Air quality. Three scales of impact on air quality must be considered:
- 1. Local scale. Environmental Protection Agency ambient air quality standards and
non-degradation standards must be met and potential future growth must be allowed for.
- 2. Sub-regional scale. Cumulative impacts on the order of air quality control regions or
air basins must be considered such as result from persistent air flows.
- 3. Regional scale. Long-range transport of pollutants must be considered on the order of
several states or air basins. In addition, impairment of visibility must be assessed in
preventing degradation of air quality, and the potential impacts of cooling towers must be
considered.
b. Water resources
- 1. There should be no net depletion of groundwater.
- 2. Municipal and industrial wastewater should be used for cooling purposes whenever
possible.
- 3. Stream flow should not be depleted so as to harm aquatic species or alter the scenic
or wild character of designated or candidate rivers.
- 4. Alternate requirements for water must be considered and priorities for use set.
c. Water quality
- 1. Sites for disposal of ash and sludge and other solid waste products should be free of
all flood potential and should not lead to runoff or leaching to surface or groundwater.
- 2. In siting more than one plant along a shoreline or river, both cumulative and
interactive effects of power plant discharges must be considered in terms of thermal
effects and destruction of aquatic life.
6. In the siting of such facilities, each level of government affected should be
involved in the decisions to allow a balancing of national/ regional and state/local
energy and land-use policies. When federal policies are found to conflict with state
policies, the state should be allowed to promulgate more stringent, but not less
stringent, standards than the federal government. The federal government should not be
allowed to pre-empt state control over energy facility siting except that in cases where a
facility, such as a pipeline, by necessity impacts more than one state, the federal
government must act to ensure the least environmental damage for the overall project.
7. Full public participation should be part of all phases of the decisionmaking process
at all levels of government, with appropriate funding made available. Funding of public
interest groups should be at a level to allow their use of expert witnesses and lawyers in
order to present their case in a credible manner. Reimbursement should be by the applicant
or by the government entity initiating the planning process. Public notice in a form
easily understood by the local population should be published in all areas impacted
environmentally or economically by the proposed facility to inform the public regarding
its opportunity to participate, the purpose of the hearing, and the hearing schedule.
Hearings should be held during hours accessible to the working public whenever public
comment is solicited.
8. Each state should create an energy facilities planning and siting mechanism in the
context of statewide land-use planning which includes an independent board or commission
and which provides for full public participation. Decisions should incorporate the
principles detailed above and should be made in the context of their long-run
implications. In addition, consideration should be given to the impact of all phases of
production, including mining or drilling, transportation, and waste disposal.
9. When considering a specific facility, a full record should be developed in order for
the least environmentally damaging alternative to be selected. The decision should be made
on the record by the independent board or commission selected in advance.
10. Applicants should not be allowed to purchase land or equipment in advance of site
approval since this invariably skews considerations in favor of the applicants' preferred
site and mode, thereby biasing the final decision against alternatives that might minimize
environmental impact. The value of the land should be fixed at the time of the declaration
of the site, with the final price subject to increases based only on increases experienced
by comparable land types elsewhere.
11. Any proposal to bank power plant sites by selecting potential sites in advance of
need should: a. ensure the selection of sites that represent the minimum adverse
environmental impact; b. include sites presenting a range of options, rather than relating
exclusively to one mode and/or scale of generation; c. provide funding for public
participation in the site-selection process; d. preserve all licensing procedures for
final approval of a specific plant on a specific site; e. be subject to periodic review to
allow consideration of changing circumstances; and f. be a state, not a federal,
prerogative.
Adopted by the Board of Directors, November 10-12, 1978
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