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Sierra Club Conservation Policies

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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