1.   Setback requirements need to be set by law.   Leaving requirements relating to how far wind turbines must be from shore, or from a state or national park, to the DNRE fails to provide the public the protection it deserves.

2.   Criteria relating to wind factory parcel selection; size and shape of parcels; and measurement criteria for benefits and adverse impacts needs to be specified in the legislation itself.  To do otherwise leaves these decisions vulnerable to a political process in which the public will lose.

3.   Most favorable, conditional, and exclusion areas need to be set by law.  Given the importance of these designations, and given the public interest in this matter, the legislature in public debate, not the DNRE behind closed doors, must identify which great lakes areas are subject to possible offshore wind development.

4.   The public must be given the right to legally challenge DNRE decisions.  As the draft legislation stands only the DNRE can legally challenge the DNRE.  This makes no sense and there must be some rein on the DNRE’s power.

5.   Affected communities must be given a role in the decision-making process.  Draft legislation provides only for an informational meeting with no requirement that public feedback be taken into account.  This is grossly unfair to those most affected.

6.   By law, only proven experience and technology should be permitted in the great lakes.  It is dangerous to our great lakes environment to permit technology which is unproven under conditions comparable to those found in the great lakes.  It is also dangerous to authorize a developer who has not successfully completed a project comparable to that being proposed.

Thank you for your consideration.