Energy Siting and Compatibility with the Military Mission

Jocelyn Durkay and Jennifer Schultz 5/20/2016

As states and localities increase renewable energy capacity and related electrical transmission to meet demand and fulfill renewable portfolio standards, the expansion into previously undeveloped land may affect the military mission.

While renewable energy can bring benefits to both military and civilian communities, its development may have unintended impacts on military operations by interfering with communication, airspace and test and training ranges. Often, impacts may occur miles from a planned development with the effects not always apparent to developers or civilian communities.

Technological Impacts

Renewable energy facilities and transmission lines can have unintentional impacts on military missions in a number of ways.

Wind turbines can interfere with surveillance, air traffic control and other radar systems depending on the position and proximity of turbines and radar. The rotation of turbine blades and their changing velocity based on winds may block or weaken signals and complicate accurate aircraft and weather detection.

Taller wind turbines, which may be as tall as 600 feet, may affect low-level flight or nighttime exercises if located near training routes and special use or restricted airspace. Offshore wind, currently in development in the U.S., could present similar challenges to the military.

Solar panels.Solar photovoltaic modules (panels), hot water heating systems and solar towers can create hazards for air operations through glint (a momentary flash of bright light) or glare (a continuous source of bright light).

Potential interference can either occur with stationary modules that are permanently oriented in one direction, referred to as fixed racking, or with tracking panels that rotate depending on the time of day and the path of the sun. Although many photovoltaic modules have an anti-reflective coating they may still create glint or glare.

Additionally, high-voltage transmission lines have the potential to create electromagnetic interference, ultimately degrading or “jamming” military communication and navigation.

Although the Department of Defense (DoD) is a strong proponent of renewable energy, it must ensure that wind turbines, solar modules and associated infrastructure located on or near military installations are compatible with test and training activities. This need for compatibility is increasingly imperative as renewable energy investment grows because of state renewable portfolio standards, cost reductions, increased demand and financial incentives, including federal tax credits. 

Several public and private entities are collaborating to mitigate technological impacts, however these may continue to present unexpected challenges in siting renewable energy, both near military installations as well as many miles away.

Case Study: California's Sunrise Powerlink Transmission Line

In 2009, the Bureau of Land Management issued a right-of-way to San Diego Gas and Electric (SDG&E) approving the construction of the 117-mile Sunrise Powerlink transmission line from Imperial County, Calif., into San Diego. As part of the policy screening process conducted by SDG&E, project managers consulted the San Diego County Airport Land Use Compatibility Plan and other planning documents.

 

The initially-proposed transmission route presented the possibility of encroachment on military installations at Naval Air Facility (NAF) El Centro, Mountain Warfare Training Camp (MWTC) Michael Monsoor and Marine Corps Air Station (MCAS) Miramar. The development of the transmission line had the potential to obstruct low level helicopter flights to and from NAF El Centro and MCAS Miramar, as well as negatively affect the quality of Naval Special Warfare training at MWTC Michael Monsoor.

 

In compliance with the California Environmental Quality Act, SDG&E issued a series of requests for public comment on the draft environmental impact report/environmental impact statement of the Sunrise Powerlink project. In a detailed response, the Navy communicated its concerns about the transmission line development. By carefully considering each detail listed in these letters, SDG&E was able to draft an alternative route that accounted for each of the concerns listed in the Navy’s initial response.

 

This revised route bypassed most areas of concern, with the exception of a substation and transmission lines on land managed by MCAS Miramar. Further communication between the Navy and SDG&E clarified the technical details of the project and MCAS Miramar was assured that its rotary-wing training and pilot safety would not be compromised. As a result of the site-specific feedback provided by the Navy and the collaborative effort of SDG&E, the potential effects of Sunrise Powerlink on San Diego’s military installations were mitigated. Work resumed on the Sunrise Powerlink project shortly thereafter.

 

NCSL thanks the California Governor’s Office of Planning and Research, the California Energy Commission and Navy Region Southwest for the contribution of this case study.

 

The Department of Defense and Renewable Energy 

DoD, as well as the individual services, have a series of renewable energy and energy efficiency initiatives to increase domestic energy independence, improve energy security and strengthen combat effectiveness. 

Military helicopter.The Air Force, Army and Navy have each committed to producing 1 gigawatt of renewable energy by 2020 and the Navy has pledged to use renewable sources for 50 percent of consumed energy by the same year. These efforts have led to collaboration with national laboratories to plan, site and integrate newer technologies while strengthening the military mission.

In addition, President Obama issued an Executive Order in March 2015 directing federal agencies to reduce emissions 40 percent below 2008 levels by the year 2025, and requiring that 30 percent of building electrical energy consumption be from renewable sources.

These renewable energy commitments are substantial as DoD’s energy consumption is the largest of any federal agency. In fiscal year 2014, DoD consumed 730 trillion BTU—more than 16 times greater than the next federal agency and roughly 77 percent of the federal government’s total consumption.

Considering these goals, state legislatures can collaborate with military organizations on renewable energy research and development and assist with military self-generation goals by streamlining the process for renewable energy facilities on military lands. For example, Hawaii enacted House Bill 1513 in 2015, which established a two-year matching grant fund for entities that have contracted with DoD’s Office of Naval Research on renewable energy and energy efficiency research and development. Several states, including Kansas, Utah and Vermont, have enacted legislation in recent years to provide financial incentives or regulatory policies for increased use of renewable energy at military installations. 

The Department of Defense’s Siting Clearinghouse

Wind generators.The secretary of defense created the DoD Siting Clearinghouse in 2010 to address the potential impacts to military testing, training or operations from renewable energy development.

The clearinghouse has reviewed thousands of projects, the vast majority of which have been found to have minimal or no impact on military operations and readiness. The clearinghouse will review project or geographic data to identify any missions that may be of concern. When compatibility concerns are identified, the clearinghouse works with the energy proponent to identify reasonable and affordable impact mitigation solutions.

For example, the clearinghouse and a developer reached an agreement in New Mexico to allow modified siting of wind turbines to lessen impacts on Cannon Air Force Base. This process is best used as early in siting decisions as possible, and is designed to be collaborative, rather than to deliver a final DoD position. DoD’s regulation on this process is Part 211 of title 32, Code of Federal Regulations.

The clearinghouse works closely with state and local governments, developers and other federal agencies to provide timely, coordinated reviews of proposed energy projects to prevent or minimize operational impacts through its Mission Compatibility Evaluation Process. The clearinghouse is not a regulatory authority and generally serves an advisory role to the appropriate permitting agency.

The clearinghouse website contains information on DoD’s ongoing efforts to include the military mission in energy siting decisions, as well as a library of relevant reports and copies of all signed mitigation agreements. Most important, the website provides a portal for state and local governments to contact DoD for an impact assessment. The clearinghouse’s informal review process, which is most often used by developers to gain early siting information, can also provide mission compatibility information to public entities.

State Action

At the state level, legislatures are working to prevent and mitigate energy-related encroachment on military installations early in the siting process to reduce costs, streamline the permitting process and preserve the military mission.

Encroachment is often unintentional, and state and local siting authorities may not be aware of the need to include military operations in planning discussions. State lawmakers can help ensure these projects will be compatible with military activities by including DoD and representatives from nearby military installations in stakeholder discussions with local, state and federal siting authorities, state utility commissions, state agencies, permitting offices, tribal governments and local communities. Early coordination can often overcome energy-related compatibility challenges, saving states and localities from unplanned mitigation expenses and permitting obstacles.

Legislatures can ensure compatibility of new energy projects with military operations through several processes, including:

  • Requiring early notification to DoD of potential projects.
  • Requesting an informal review from the DoD of potential projects.
  • Ensuring any conflicts are resolved before completing project permitting and construction.
  • Enacting planning guidelines or siting ordinances using maps of military mission conflict areas.

California has adopted comprehensive policy measures to increase coordination with nearby military installations.

The state enacted Senate Bill 1468 in 2002 requiring cities and counties to consider the impacts of new growth on military readiness activities when preparing or updating their general plans for lands adjacent to military facilities or underlying designated military aviation routes and airspace. Additionally, the bill required the state Office of Planning and Research (OPR) to prepare and publish a compatibility planning handbook for local officials, planners and builders that explains how to reduce land use conflicts between civilian development and military readiness activities. Assembly Bill 1108 (2002) amends the California Environmental Quality Act to ensure military agencies are provided notice of proposed projects within two miles of installations or underlying training routes and special use airspace. 

Soldier with a rifle.Subsequent legislation, Senate Bill 1462 (2004), requires the governor to develop a conflict resolution process for proposed projects that could potentially affect military readiness activities. The bill also requires planning agencies to notify DoD of the adoption or substantial amendment of a community’s general plan, if the proposed project lies within 1,000 feet of a military installation, beneath a low-level flight path or within special use airspace, provided that the DoD provides electronic maps to OPR.

OPR in cooperation with Navy Region Southwest developed an online mapping tool, the California Military Land Use Compatibility Analyst (CMLUCA). CMLUCA is used by developers, the public and local and state agencies to determine whether specific development projects meet the criteria for referral of an application to the military.

Additionally, Senate Bill 926 (2004), revised the definition of open space to include areas adjacent to military installations, military training routes and restricted airspace as eligible for designation by local governments to provide buffer zones for military installations and readiness activities.

Legislation enacted in 2012, Senate Bill 1409, requires OPR to serve as a liaison to coordinate inclusion of the DoD in state energy and environmental policy and identify state agencies that develop and implement energy and environmental policies that directly affect the DoD’s energy security and military mission goals. The identified agencies are required to consider those impacts when developing or implementing their policies.

Recent legislation, Assembly Bill 442 (2015), codified the Governor’s Military Council under the direction of the State Military Department. The council advises the governor and state legislature on efforts relating to military installations and operations within the state, and coordinates and focuses those efforts.

Case Study: California Legislation in Action

To support the implementation of the legislation referenced above, the California Governor’s Office of Planning and Research (OPR), in coordination with Navy Region Southwest (NRSW), was awarded a grant from the Department of Defense’s Office of Economic Adjustment to develop the California Strategic Coordination and Engagement Program. This program provides direct technical assistance, mapping and other tools to cities and counties to help them comply with statutory requirements. To date, OPR and NRSW have provided mapping and technical assistance to 27 municipal agencies across the state and fostered collaboration with several federal and state agencies.

 

California has also taken significant measures to coordinate energy development projects with the branches of the military. For example, in March 2013 Governor Brown announced the creation of the Governor’s Military Council, which was subsequently codified in 2015. The goal of the council is to maintain California’s importance in the military’s mission. The council—made up of 18 members including military, civic and stat leadership—communicates military missions, goals and values to state leaders. The Governor’s Military Council is actively pursuing ways in which the state can support the armed forces’ renewable energy goals.

 

Additionally, the Desert Renewable Energy Conservation Plan, a landscape-scale, multi-agency, joint environmental impact report/environmental impact statement planning effort for 22.5 million acres in the R-2508 Complex (Edwards Air Force Base) in California’s Mojave desert, was developed in direct consultation with representatives of the military to limit potential conflicts with military testing and training from renewable energy and transmission development. The state continues to coordinate closely with the military in other planning processes, most recently in the identification of least-conflict lands for solar development in the San Joaquin Valley, home to Lemoore Naval Air Station. The California Energy Commission is working closely with the military on several demonstration projects of new and emerging technologies on military bases in California.

 

Members of the Governor’s Office, Governor’s Office of Planning and Research, California Energy Commission, California Department of Transportation's Division of Aeronautics and the California Department of Fish and Wildlife participate as members of the Western Regional Partnership (WRP). WRP provides a proactive and collaborative framework for senior-policy level federal, state and tribal leadership to identify common goals and emerging issues in the states of Arizona, California, Colorado, Nevada, New Mexico and Utah.

 

WRP seeks to develop solutions that support its partners, protect natural resources and promote sustainability, homeland security and military readiness. The governor’s adviser for military affairs is the principal to the WRP, the deputy director from the Office of Planning and Research is on the Steering Committee and a member of the California Energy Commission is co-chair of the Energy Committee. Other state department representatives participate on a variety of WRP committees and support various projects being undertaken by the WRP.

 

NCSL thanks the California Governor’s Office of Planning and Research, the California Energy Commission and Navy Region Southwest for the contribution of this case study.

 

In the 2013 legislative session, North Carolina enacted House Bill 484 to establish a permitting process for wind energy siting that includes consideration of any effects on military operations and readiness at each point in the application process. For example, prospective permit applicants must submit a pre-application package with information on the project and any possible impacts to military installations. Prospective applicants must also give written notification to military installations potentially affected by the development. At other points in the application process, the commanding officers of each major military installation are notified of the project in writing and invited to provide input. There is currently one utility-scale wind development in the state, which was in development when legislation was enacted (see case study below).

In the same year, the state enacted House Bill 433 placing limits on building heights for new construction or retrofits within five miles of military installations to protect airspace. Included in the legislation is the development of a study examining the feasibility and desirability of creating a North Carolina Military Clearinghouse to prevent incompatible development.

Case Study: North Carolina Wind Permitting Process

State Representative John Bell (R) led the effort to protect North Carolina’s military bases from incompatible development. A first-term legislator at the time, Bell was informed that a utility-scale wind development had been proposed within a low-level flight path near Seymour Johnson Air Force Base.

 

In combat, aircraft may need to operate at altitudes as low as 100 feet to avoid detection by ground missile radar and dodge surface-to-air-missiles, anti-aircraft artillery and enemy fighters. Flight paths like those around Seymour Johnson are critical in developing the skills pilots need to perform in realistic environments.

 

“When you have a 500-foot windmill in an area where military pilots are regularly flying at altitudes of 500 feet or less, you have a problem.”

 

According to Bell, wind development in such close proximity to the base would have limited access to valuable flight routes for military training, raising concerns that the state might lose the base entirely.

 

“If F-15s can no longer train, there is really no reason for them to be there.”

 

As a resident of Goldsboro, just outside the base, Bell is aware of the many economic benefits of military presence, both for the state and local communities. Seymour Johnson Air Force Base is one of five major installations in North Carolina, which together support 540,000 jobs, $30 billion in personal income and $48 billion in gross state product, according to a 2013 study. This amounts to roughly 10 percent of the state’s overall economy.

 

Recognizing the need for action, Bell worked with the city, county and fellow legislators to draft a bill establishing a statewide permitting program for wind energy facilities that considers military training needs along with other potential adverse impacts.

 

The DoD Siting Clearinghouse eventually reached an agreement with the wind developer to allow modified siting of wind turbines to lessen impacts on Seymour-Johnson Air Force Base.

 

NCSL thanks Representative John Bell of North Carolina for his contributions to this case study.

 

The state of Washington enacted House Bill 1570 in 2011, requiring the Energy Facility Site Evaluation Council, cities, towns and counties to provide written notice to DoD of permit applications for energy projects connected to transmission lines of 115 kilovolts or greater.

Power linesEnergy-related encroachment may be exacerbated by differences in states’ siting authorities. A number of states authorize energy installations, such as wind turbines, at the county or municipal level, rather than through a state permitting office. In Oregon, for example, siting for wind energy facilities under 35 megawatts is regulated by local governments. The state Department of Energy has developed a model ordinance on energy projects for local governments that includes guidance on siting renewable energy and transmission lines.

In Virginia, the state Corporation Commission provides a certificate for the siting of all new utility facilities and localities may adopt separate siting ordinances. The Virginia Department of Environmental Quality’s Local Government Outreach Stakeholder Group has developed a series of model renewable energy ordinances for localities. In the model ordinance for utility-scale wind energy, resources for notifying DoD of proposed installations are included.

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