Resource Documents: Law (33 items)
Documents presented here are not the product of nor are they necessarily endorsed by National Wind Watch. These resource documents are provided to assist anyone wishing to research the issue of industrial wind power and the impacts of its development. The information should be evaluated by each reader to come to their own conclusions about the many areas of debate.
Impact of bad choices for climate change mitigation
Author: Palmer, William
Presented at: 3rd Climate Change Technology Conference, May 27-29, 2013, Concordia University, Montreal, Quebec
This presentation will show the necessity to research beyond the simplistic impressions that are too often used to justify major public policy decisions when selecting choices. We will see that what may seem to be an obvious choice can actually have produce the wrong results. Instead of aiding the environment, the wrong choice can hurt the environment, and the public.
Bad choices do have adverse impacts.
There is probably general agreement in this room that wastage of any resources is not wise.
However, we must acknowledge that civilization requires energy to progress. Reducing energy consumption to zero may not be advisable, if it takes us back to cooking with fires and lighting with whale oil. We need to look at the impact of the choices we make.
An Ontario Power Authority was put in place to plan the future energy decisions for the province. Then, from May 2005 to February 2013, the Ontario Minister of Energy issued at least 65 “directives” to the OPA, telling it what decisions it was to make, tying its hands to make decisions by science – instead directives were often driven by ideology rather than careful thought, and the consequences were not always what was desired.
As examples, directives called to bring into service 10,800 MW of “new” renewable electrical generation by 2015. Mostly this would be wind generation. The Green Energy Act took away local planning, authority, and reduced normal business case evaluations.
The Ontario Auditor General noted in his annual review in 2011 that the directives had a number of undesired results, including these and rate increases.
Some of the directives failed to understand the basic principles of electrical generation. It was assumed that generation could be added to the system anywhere, and then users could draw from the system anywhere, as if the system was just a big bathtub. In reality it is more like a tub filled with sponges, that introduce time delays and losses.
Truth is, if generation travels long distances from the source to the consumer there will be little left, and stability issues become pronounced as transmission lines get longer.
Ideally generation wants to be located near the user – which in Ontario means close to the GTA, and yet, even while there is a major generating site at Pickering, the directives continue to predict that remote, intermittent wind and solar from as far as James Bay will replace Pickering.
It’s not that easy!
To select the best choices, we need to look at the electrical system.
Here is the Ontario electrical system from the data of the Independent Electrical System Operator (IESO) for a week in January. You can see that over 66% of the base (night time) load comes from continuously operating nuclear generators (red), supplying about 10,000 MW. Hydro (green) supplies some of the rest of the base load, with some contribution from gas fired generation (purple). Day time increases to peak loads were met by increases in hydro, gas, and coal (yellow).
The wind generation in Ontario (orange), with a nameplate capability of about 1720 MW supplied very little when the demand was highest. Yet, wind supplied best when the demand was lowest. This is not a coincidence, it is the nature of wind. Demand is highest in the winter when high pressure brings cold crisp weather, and then demand is lowest on mild days when the wind is blowing. You will also see that this winter, the system operators were maintaining a surplus of coal generation on the system about equal to the amount of wind generation to have a buffer for when the wind dropped – which it does.
You will even see that the day when wind was highest in output, the system demand was lowest, and what happened was that nuclear and wind output was reduced, even while some gas generation stayed on line.
If we look now at a spring week, the first thing to note is that the overall system demand is considerably lower … and with less day to night variation.
Wind is now a bit steadier, and you see that routinely excess generation results in reduction of nuclear and hydro generation.
These too have consequences, as we will see on the next slides.
Here are the charts for the 4 nuclear generators at Bruce B, for the months of October through December 2012. You can see how often these units were derated from nominally 800 MW to about 550 MW due to excess generation – mostly from wind. Each orange spike is an overnight generation reduction.
Each one of these spikes means that steam is diverted from the steam turbine to be dumped to the condenser. Each spike means a diversion of some 300 kg/sec of steam at 4100 kPA and 250 degrees C. There is very little actual reduction in reactor power, as the reactors must stay at high power. The energy is just wasted – with an unnecessary stress put on the plant each time. Yes, they have the capability to do this, but it is not desirable operation – simply because of a directive that says buy all the available wind.
It is not good planning, it is not minimizing risk, and it is certainly not minimizing cost. In short it is a result of adapting to a bad policy directive.
Let’s summarize – we might buy 1720 MW of wind at $135 per MWh. It already forces us to derate hydro and nuclear.
Derating hydro means OPG is paid less and has less funds to do maintenance.
Derating Bruce Nuclear accommodates the excess generation, but needs to be paid some $52 a MWh for the energy as the reactors stay at high power. If a reactor is shut down it is not available to return to power for some 40 hours.
So, consumers pay $135 per MWh for wind, whether needed or not, plus for most wind generators an additional $10 a MWh federal EcoEnergy grant. Then consumers pay Bruce $52 a MWh to dump steam.
When there is still an excess consumers pay other utilities to take the excess.
The consumer pays over $350 a MWh for energy that is not even needed.
Does it help to make the consumer pay 3× for unneeded power? Is this conservation?
When the Ontario Minister of Energy announced the Green Energy and Environment Act in 2006, he predicted it would result in an electricity price increase of about 1% a year. Yet the actual prices have increased from 30% to 80% in 6 years, and the costs are increasing even faster now as more new transmission lines to handle intermittent wind come into service.
And Ontario has directives to progress from 1720 MW of wind now to some 8400 MW by 2015 and eventually to 10,800 MW – and maybe more.
As the consumer pays more, they have less flexibility to make wise choices. Manufacturing has a harder time to pay energy bills. It is not a coincidence that Xstrada moved its electricity consuming smelting operation from Ontario to Quebec, or that Caterpillar moved jobs out of Ontario, or Stony Creek Dairy moved out of Ontario … or that more jobs are being lost. How long will Ontario have an automotive industry when suppliers have plants in the USA with energy costs half of Ontario’s?
The decisions are not aiding climate change mitigation, they are only driving the effects elsewhere.
Let’s look at 4 years in January of system demand (in blue) and wind output (scaled from 0 to 100%) in red.
You can see that wind has the nature to be available when the system demand is low, and then drop rapidly as the system demand rises. Wind also routinely is of low availability for days on end when the system demand is highest. Storage for days is not what is talked about by the street corner battery banks – they are talking of perhaps 15 minutes of storage. Converting wind energy to hydrogen and then burning hydrogen (in fuel cells or generators) will increase the costs by several orders of magnitude again.
If we look at 4 years of July wind versus system data, we find that in the second time of the year when the system demand peaks, the summer. Wind does even more poorly. The overall wind system performance in the summer is in the order of 10 to 15% on average, and it is often less than 10% for days on end. Seasonal storage from spring to summer would be even greater as we convert wind energy to hydrogen and store it in caverns.
It’s not good for the environment to have to overbuild the system to accommodate the variations of intermittent supply. …
Let’s look at the actual data from the IESO and predecessor organizations of Ontario Power Generation and Ontario Hydro.
You can see Darlington Nuclear Generating Station coming on line in the early 1990’s (purple) resulting in fossil fuel (black) dropping in output.
Then, as costs increased, the government changed and took initiatives to reduce costs – laying off senior Ontario Hydro staff, and reducing maintenance. Output dropped in the nuclear generators. A decision was made to layup the Pickering A and Bruce a generators to restore the newer plants to higher performance. Coal output went up.
Then as the nuclear units started to come back on line in 2003, coal started to drop again. In 2006, with the recession, the demand decreased, and coal dropped further. New (higher cost) natural gas generators lowered the coal demand further … it certainly was not the 4 TWh of wind that reduced coal from 40 TWh a year to under 4 TWh.
The other argument heard was that bringing on stream new renewables in wind and solar would improve health.
If we look at the unbiased data from the Institute for Clinical Evaluative services (ICES) we find that from the early 1990’s even as coal output increased, then decreased (black line), the Asthma Incidence Rate for infants (yellow line) continued to decrease.
Looking at the incidence rates for older children it can be seen that the peak in infant asthma rate in the early 1990’s moved through the older age groups and is now decreasing in all groups … but the link to coal is tenuous at best.
Perhaps the decrease in infant asthma is more closely linked to parents not smoking in front of children?
It certainly did not reduce due to wind turbines. …
Download original document: “Impact of bad choices for climate change mitigation”
Reply Brief to Whistling Ridge Application
Author: Friends of the Columbia Gorge and Save Our Scenic Area
REPLY TO STATEMENTS OF THE CASE
The Applicant argues that it “stipulated that no more than 38 turbines would be constructed” as part of the Project. WRE Br. at 5. This is incorrect, because the Applicant never proposed a 38-turbine project in compliance with EFSEC’s mandatory procedures. Instead, the proposal reviewed below was the 50-turbine proposal in the Application.
The Applicant, citing a letter written by its company president, Jason Spadaro, asserts that it “conducted more . . . wildlife surveys than any other previously proposed project.” WRE Br. at 4 (citing AR 15791). Mr. Spadaro’s self-serving and unsupported statement is patently incorrect. The Applicant did not even comply with the bare minimum requirements of the WDFW Wind Power Guidelines and EFSEC’s rules (see infra Part III.B)—let alone conduct more surveys than other projects.
The Counties make several statements about the economics of Skamania County. Counties Br. at 1–6, 15, 27. The Supreme Court should disregard these statements, which the Counties do not even attempt to tie to any applicable statute or rule, and which have no bearing on the issues presented in this appeal and no relevance to the applicable law.
Finally, State Respondents argue incorrectly that Petitioners “conceded” that they do not seek a reversal of the decisions. State Br. at 9. To clarify, Petitioners seek both reversal and remand of the decisions listed at pages 3 and 4 of the Opening Brief. However, Petitioners do not challenge State Respondents’ authority to regulate and approve wind energy projects, in contrast to the arguments made in the “ROKT” case. See Residents Opposed to Kittitas Turbines v. State EFSEC, 165 Wn. 2d 275, 305–11, 197 P.3d 1153 (2008). …
CONCLUSION
Because EFSEC failed to resolve numerous important issues that were contested below, and also violated and ignored multiple statutory and regulatory requirements in the course of its review, the Project’s true impacts were never evaluated and the decision to approve the Project was uninformed. The Court should reverse and remand for further review.
Download original document: “Whistling Ridge Petitioners Reply Brief”
Weaver Residence Wind Turbine Noise Assessment
Author: Kouwen, Nicholas
This report outlines the findings of an informal wind turbine noise assessment at the Weaver residence at 7624 Wellington Road 12 just south of Arthur, ON, February‐March 2013.
The Weaver property abuts the 22.92 MW Conestogo Wind Farm in Mapleton Township near Arthur, ON. The wind farm consists of 9 Siemens AG2.3 MW IWT’s and 1 Siemens AG 2.221 MW wind turbine. A location diagram is located in Appendix A. The Weaver residence is shown as receptor 65 where the “worst case” IWT sound levels were predicted to be 39.2 dBA by the proponent.
The investigation suggests that the IWT generated noise does not comply with the MOE noise guidelines ~50% of the time and that SPLs are above the predicted “worst case” ~59% of the time.
A journal of the quality of life and health problems experienced by the occupants of the home is attached as Appendix B.
Methodology
The equipment and methodology for the study is the same as that described in detail in my Grey Highlands 2012 Wind Turbine Noise Survey.
In the following part of the report, the results are paired for the two sites shown in Figures 1 & 2. Figure 1 shows the microphone location at the Weaver residence and Figure 2 shows the microphone location as a similar background site, approximately 10 km from the nearest IWT.
There are four separate comparisons:
- The time series of the A weighted sound pressure levels (SPLs) (dBA) along with the 10m wind speed in m/s and wind direction as well as ground wind speed.
- The A weighted SPL (dBA) covering all data versus 10 m wind speed.
- The A weighted SPL (dBA) versus 10 m wind speed for night time 1‐5 am only.
- The L50 versus 10m wind speed. Unweighted SPLs (dBZ) are also plotted.
In the following report, the MOE noise limits are those in NPC‐232 “Sound level limits for stationary sources in Class 1 & 2 Areas (Rural)”
When referring to the MOE protocol for determining compliance NPC‐103 “Compliance Protocol for Wind Turbine Noise” the methodology in this protocol is noted but is replaced by the more objective and workable approach adopted herein.
Download original document: “Weaver Residence Wind Turbine Noise Assessment”
Impact of wind turbine noise in the Netherlands
Author: Verheijen, Edwin; Jabben, Jan; Schreurs, Eric; and Smith, Kevin
The Dutch government aims at an increase of wind energy up to 6 000 MW in 2020 by placing new wind turbines on land or offshore. At the same time, the existing noise legislation for wind turbines is being reconsidered. For the purpose of establishing a new noise reception limit value expressed in Lden, the impact of wind turbine noise under the given policy targets needs to be explored. For this purpose, the consequences of different reception limit values for the new Dutch noise legislation have been studied, both in terms of effects on the population and regarding sustainable energy policy targets. On the basis of a nation-wide noise map containing all wind turbines in The Netherlands, it is calculated that 3% of the inhabitants of The Netherlands are currently exposed to noise from wind turbines above 28 dB(A) at the façade. Newly established dose-response relationships indicate that about 1500 of these inhabitants are likely to be severely annoyed inside their dwellings. The available space for new wind turbines strongly depends on the noise limit value that will be chosen. This study suggests an outdoor A-weighted reception limit of Lden = 45 dB as a trade-off between the need for protection against noise annoyance and the feasibility of national targets for renewable energy.
Noise Health. 2011 Nov-Dec;13(55):459-63
doi:10.4103/1463-1741.90331
Edwin Verheijen, Jan Jabben, Eric Schreurs, Kevin B. Smith
National Institute for Public Health and the Environment, Centre for Environmental Monitoring, Bilthoven, The Netherlands
