December 21, 2021
The Honorable Tom Wolf, Governor
Commonwealth of Pennsylvania
238 Main Capitol Building
Harrisburg, PA 17120
Governor Wolf,
We, the undersigned environmental, business, faith-based and public education groups
collectively representing hundreds of thousands of members and supporters across the
Commonwealth, request your intervention in a process that has caused unnecessary, improper,
and potentially illegal delays to the proposed development of a wind farm known as Anthracite
Ridge.
This proposed wind project is located in Schuylkill County on land that was formerly a strip mine,
which is the ideal type of location for minimizing environmental impacts of renewable energy
development. It would also create hundreds of union construction jobs and ongoing revenue to
support local governments, all while creating significant amounts of pollution-free electricity that
is critical to addressing the climate crisis.
Unfortunately, the Department of Military and Veterans Affairs (DMVA) and the Pennsylvania
National Guard (PANG) have vigorously opposed the proposal before the Hegins Township
Zoning Board, causing the local permitting of the project to stall. DMVA and PANG have argued 1
that the project as proposed is “detrimental to the PANG’s national security mission,” claims that
other parties have contested. PANG further claims that there are no mitigation measures that
would allow it to approve of the project.
In fact it is not the role of PANG, or DMVA, or any other state agency to make these
specific determinations, nor to engage in this type of advocacy. Instead such issues are
governed by federal law,2 and administered by the Department of Defense (DoD). The
governing regulation includes the following policy statement:
It is an objective of the Department of Defense to ensure that the robust development of
renewable energy sources and the increased resiliency of the commercial electrical grid
may move forward in the United States, while minimizing or mitigating any adverse
impacts on military operations and readiness.3
1
Letter to Hegins Township Zoning Hearing Board from DMVA Office of the Adjutant General, dated
October 16, 2021.
2
This was authorized as part of the defense authorization act for FY 2011 (H.R. 6523, Pub.L. 111–383)
and codified as 32 CFR Part 211.
3
Section 211.4 Policy
In service of this policy objective, the DoD operates a Mission Compatibility Evaluation (MCE)
process, which “provides a timely, transparent, and science-based analysis of potential impacts
to military operations” and “works to identify mitigation strategies to minimize those impacts.”4
The MCE process is in the very early stages of evaluating the impacts of this project, and has
yet to reach any conclusions with respect to issues raised by DMVA and PANG. Unfortunately,
the agencies’ advocacy surrounding local permitting has occurred outside the DoD chain of
command and has complicated the MCE process.
Local governments are not in a position to evaluate the merits of PANG’s claims about the
impact of the proposal on its national security mission. However, the DoD MCE process is
designed specifically to do just that, and will involve stakeholders with much more experience
and expertise on best practices related to the successful coexistence of military operations and
renewable energy.
We ask only that you ensure that state agencies under your jurisdiction follow this process,
which is dictated by federal law, and do not engage in advocacy outside of the process that
could interfere with it. Specifically, we ask that you direct PANG and DMVA to suspend any
advocacy with local zoning and permitting authorities, and to rescind past arguments against the
proposal until such a time that the DoD’s MCE process can reach an informed conclusion as to
whether and how any alleged project impacts to military operations can be mitigated.
Respectfully,
Thomas Schuster Robert Altenburg
Clean Energy Program Director Senior Director for Energy and Climate
Sierra Club Pennsylvania Chapter Citizens for Pennsylvania’s Future (PennFuture)
[email protected] [email protected] Katie Blume Joe Minott
Political Director Executive Director and Chief Counsel
Conservation Voters of Pennsylvania Clean Air Council
[email protected] [email protected] David Masur Mark Szybist
Executive Director Senior Attorney
PennEnvironment Natural Resources Defense Council
[email protected] [email protected]4
https://www.acq.osd.mil/dodsc/, accessed 12/10/2021.
Veronica Coptis Liz Robinson
Executive Director Executive Director
Center for Coalfield Justice Philadelphia Solar Energy Association
[email protected] [email protected]
Kathy Cook Phyllis Blumberg
Environmental Policy Director Lead Organizer
League of Women Voters Pennsylvania Jewish Earth Alliance- PA chapter
[email protected] [email protected]Chad A. Forcey Tonyehn Verkitus
Executive Director Executive Director
Pennsylvania Conservative Energy Forum Physicians for Social Responsibility PA
[email protected] [email protected]Michael DiMonte David Heayn-Menendez
Convener Executive Director
Working for Justice Ministry St. Paul's Pennsylvania Interfaith Power and Light
United Methodist Church Allison Park, PA
[email protected]Ron Celentano Joy Bergey
President Director
PA Solar & Storage Industries Assoc. Environmental Justice Center of Chestnut Hill
[email protected] United Church
[email protected]Cc:
Sam Robinson
Sen. Bob Casey
