As a tax payer/resident of Apache County, I am OPPOSED to the proposed Lava Run and Black Ridge wind turbine and solar projects. These projects, primarily driven by foreign companies, threaten to strip away the unique beauty and tranquility of our pristine natural environment. Our land, which has been cherished and preserved for generations, now stands at the brink of irrevocable change.  

The stakes are high, but YOU have the power to stop that.

Environmental Concerns:

• Water - The construction of these projects would require massive amounts of water - water that is already in scarce supply - to make the concrete footings for both wind turbines and solar panels.  Water will be needed during construction to keep dust down from construction and traffic.  Where is this water going to come from, and how does this impact an already drought stricken county?  If wells go dry, if people can’t get water, not only will their property values plummet, they can’t grow food or water their livestock, and they may be forced to leave.
• These projects will cause significant land disruption, which could result in soil erosion, vegetation loss, and habitat loss, as well as becoming a blight on the natural landscape.  People come to Apache County to live and recreate because of the natural beauty.  Wind turbines and solar fields take away from the natural beauty, and are a blight on the landscape. These changes will be irreversible.
• Decommissioning - what happens to what is left when the project - which has an expected lifespan of only 20 years - is finished being useful.  None of the components of the wind turbines and solar panels are biodegradable.  They will have to be disposed of somewhere.  They are too big for a land fill, and will become a blight on the earth.  The remaining concrete footings - also not biodegradable - will be left in place, forever changing the landscape and ecosystem.  Posts cut off below ground will also remain, making the land difficult to farm.  Thousands of miles of cables will remain buried in the ground, and the cables that will be removed will cause the land to be disrupted once again.
• An additional impact to the environment is the massive amount of oil required to keep wind turbines moving.  Leakage of oil from even one turbine could lead to land and ground water contamination, creating a HAZMAT site.  
• Wildfire - wind turbines have been known to malfunction and catch fire.  Arizona is already prone to wildfires, and the presence of these turbines increases that risk.  Due to their height, fires could be sparked over a wide area, causing catastrophic loss of property and even life.  Solar fields, and high tension power lines also pose a risk of starting wild fires.    Have we learned nothing from the Camp Fire in Paradise, CA, sparked by faulty power equipment?  Who will ensure there is adequate monitoring and maintenance of these turbines and panels to ensure they don’t spark wildfires?  Does the county have the resources to fight such fires, and what happens if a wildfire destroys all the equipment and infrastructure?  Who foots the bill for cleanup, or will it become an abandoned wasteland?
• The ecosystem here is delicate, and the introduction of vast wind turbines and solar installations poses a substantial risk to local wildlife habitats. Birds, in particular, face the threat of turbine blades, potentially disrupting migration patterns and leading to population declines.  Fencing will lead to habitat fragmentation, changing or restricting the movement of wildlife, impacting migration, feeding patterns and mating, and overall habitat loss.  Bat activity was 20 times higher at control sites compared to wind turbine sites. Million, et al., 2018 

Health Concerns:

There is a real and present threat to the health of those of us living in proximity to these sites. 

• Studies have shown that wind turbine noise and vibrations can lead to disturbances in sleep patterns, increased stress levels leading to harmful cortisol levels, and other health issues for nearby residents:
  “Pierpont documented symptoms reported by individuals exposed to wind turbines, which include sleep disturbance, headache, tinnitus, ear pressure, dizziness, vertigo, nausea, visual blurring, tachycardia, irritability, problems with concentration and memory, and panic episodes associated with sensations of internal pulsation or quivering when awake or asleep.” Pierpont N. Wind turbine syndrome: a report on a natural experiment. Santa Fe, NM: K-Selected Books; 2009
• Causes - “Suggested causes of symptoms include a combination of wind turbine noise, infrasound, dirty electricity, ground current, and shadow flicker.” Havas M, Colling D. Wind turbines make waves: why some residents near wind turbines become ill. Bull Sci Technol Soc. 2011;31(5):414–26.
• Valley Fever - The fungus that causes Valley Fever lives in the soil in Arizona, and large scale construction projects like the ones proposed will release more spores into the air, significantly increasing the likelihood of more cases.
• Disturbances are not limited to humans.  Animals are also affected, as seen in increased beaching of whales from wind turbines in the oceans.  There have not been enough studies to determine if egg and milk production are affected in animals, although it was shown that foals raised near wind turbines had an increase in foot deformities.

Other Concerns:

• Destruction of roads and highways due to heavy truck traffic during construction.

Who Really Benefits:

These projects do not provide any tangible benefits to our community. 

• Urban areas - The energy generated from these sites is destined for urban areas far removed from our county, offering us nothing in return, neither in terms of energy supply nor economic gain. Those communities need to find ways to create their own power.
• The state - may benefit from tax revenue for K-12 schools.  How much will actually reach Apache County?
• Apache Co - Increased tax revenue for the county?  How much will this be negated by the cost to repair roads, the increase in health care costs, lost revenue from declining property values, and the costs of fire prevention and fire fighting efforts?
• Jobs - Temporary construction jobs, and the promise of a few jobs for the 20 year lifespan the project will be in operation will not meaningfully benefit the community in the long run.  How many of these jobs will be filled by local residents?  The two existing power plants will provide more stable long-term jobs for members of the communities where they are located.
• A few ranchers will benefit from the sale or lease of their properties.
• The companies proposing these projects are not local, or even from the state.  They are taking advantage of the inexpensive land, and hoping the residents don’t put up a fight.  They are the big winners in this entire scenario, and none of the money generated by these projects will stay local.   

The Lava Run and Black Ridge projects are not a good trade off and are a heavy price to pay for a community that receives no benefit but bears all the burdens.  Instead, we are faced with the prospect of increased traffic, possible declines in property values, potential health impacts, a compromised quality of life, and degradation of our environment.

In light of these concerns, I urge the Board of Supervisors in Apache County to seriously reconsider the approval of the Lava Run and Black Ridge projects. Our community deserves to have its voice heard, and our communities and the environment deserves protection from interventions that do not serve its best interests.  YOU, as the Board of Supervisors have the responsibility to serve and protect our community from being exploited by foreign companies that will profit at our expense.

ZONING ORDINANCE OF APACHE COUNTY, ARIZONA

ARTICLE 1 

PURPOSES AND ADOPTION OF THE ORDINANCE 

In order to classify, restrict and regulate, and encourage the orderly use of the land in Apache County and to conserve public health, safety, peace, comfort, convenience and general welfare, there is hereby adopted and established a zoning ordinance for Apache County, Arizona, as amended, as provided for by Arizona State Law. More specifically, the ordinance is adopted to achieve the following objectives: 

1. To foster a wholesome, serviceable and attractive living environment.
2. To secure adequate light and air, to prevent the overcrowding of land and undue concentration of population, to secure safety from fire, panic and other dangers, to lessen or avoid congestion in the streets, to facilitate the adequate provision of transportation, water, sewerage, schools, parks, and other public facilities, and otherwise to promote the health, safety, convenience and general welfare of the citizens of Apache County, Arizona.
3. To protect and promote appropriately located commercial and industrial activities, in order to preserve and strengthen the County's economic base, protect and enhance real property values and the County's natural assets.
4. To ensure unimpeded development of such new urban expansion that is logical, desirable, and in conformance with objectives and policies of such Comprehensive Plans and Specific Plans as may be adopted. 
   ***

We, the undersigned residents and taxpayers of Apache County, respectfully petition the Board to take the following actions immediately:

1. Impose an immediate moratorium on all new industrial-scale wind, solar, and battery storage projects, Conditional Use Permits, and Development Agreements, including Lava Run and Black Ridge until all fully transparency and independent studies are completed.  

At minimum, an independent water-use study analyzing all water needs for construction, dust suppression, and maintenance and how this will impact local water sources.  We simply cannot afford to deplete our precious water sources for a project that has no lasting benefit to the community.

2. At minimum, amend the following sections of the existing and/or proposed Zoning Ordinance Article 4:

• Section 438. Zones in Which Allowed / CUP Required, Preferred Criteria Renewable Energy Generation facilities are allowed only in the Agricultural-General and Industrial Zones  Agricultural Zones are not compatible with Renewable Energy Generation facilities.  Limit projects to already established Industrial Zones
• Section 440. Noise Requirements and Mitigation Measures, Subsection D. should be eliminated.  No one will truly know what the noise impact will be until the equipment is installed.  It is the duty of the Board of Supervisors to protect its citizens, and they should not give away their rights.  
• Section 441. Setbacks Wind Project Setbacks, Subsection B Participating Parcels and Vacant Parcels  Non-occupied residential property should be treated the same as occupied residential property for purposes of setbacks.  Setbacks should not be determined until an independent study has determined a realistic buffer zone that prevents the measurable effects from noise and vibration from the wind turbines, or any other equipment to be installed.  The proposed 1.5 times the turbine height from the base of the turbine is not based on any scientific data.

While we laude the County’s efforts to provide a uniform and comprehensive set of standards for the entitlement and operation of commercial-scale renewable energy systems in Apache County we, the undersigned, believe that large scale industrial-scale wind, solar, and battery storage projects are not compatible with the Purposes of Article 1 of the Zoning Ordinance of Apache County, Arizona, as stated above, and we respectfully urge the board to act in the best interest of the people of Apache County and ban all current and planned projects.  There is too much at stake, and the changes are irreversible.  

Choose wisely, this is your legacy.

Respectfully,