Resource Documents: Connecticut (3 items)
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Author: Ambrose, Stephen; and Rand, Robert
At the request of FairWindCT, Inc., we submit our professional opinions for the review of the proposed Connecticut Siting Council Draft Wind Regulations dated 12 April 2012. …
Industrial wind turbine noise has proven to be a source of public complaints for non-urban neighbors living up to a mile away. This is especially true in locations where wind speeds can be calm to light at ground level and strong at the turbine blade heights, and/or wind directions differ from low to high elevation. The change in wind speed and/or angle with increased elevation is called “shear”. Changes in topographical elevation produce “turbulence”. Shear and turbulence are strong in New England, but mild at manufacturer test locations where winds are steady and there are small changes in wind speed with increased elevation.
Comment 1: Wind shear and turbulence consideration is omitted.
Comment 2: Low-frequency noise consideration is omitted.
Wind turbine manufacturer test data is obtained and published with A-weighting (as required by the IEC 61400-11 standard). This is very misleading since A-weighting filters out low frequency noise contributions and excludes infrasonic energy. Data published by wind turbine manufacturers discounts the significance of low frequencies and infrasonic energy. Un-weighted (linear or “dBZ”) field measurements have confirmed that most of the acoustic energy produced by wind turbines is low frequency and infrasonic (below 200 Hz).
Low frequencies are a well documented common complaint for wind turbine noise; i.e., it sounds like “a jet plane that never lands”. This is especially true indoors, where the higher frequencies are blocked and the longer wavelengths of low-frequency and infrasonic energy pass easily through the through exterior walls and roof into the home. The predominance of low frequencies inside homes is a leading cause for complaints.
The proposed regulations should include mandatory considerations for wind turbine low frequency noise by requiring the inclusion of a maximum low frequency limit for proposed facilities. A maximum of 55 dBC, outdoors at night (measured using the broadband “dBC” filter found on professional sound level meters) has a growing consensus by environmental acoustic and public health professionals. …
Comment 3: Proposed requirements are too lax to protect neighbors from excessive noise and adverse public health and well-being impacts. As written these requirements would result in widespread complaints and strong adverse community reactions. These findings are supported by the long-standing, industry-recognized and accepted community noise assessment methodologies published by USEPA dating back to the 1970’s.
Comment 4: Proposed requirements continue to “noise level excursions” (exceedances) allowed under the existing Connecticut law. These “allowances” would intensify wind turbine noise impacts especially at night when most people are trying to sleep.
Comment 5: Setback distances for noise must be greater than proposed for safety.
A setback distance of 1.1 times the wind turbine height, or the manufacturers recommended safety setback distance, may be appropriate for mechanical failure of the turbine structure and break-away parts. The safety setback does not address noise impacts. A reasonable and appropriate setback for noise is at a minimum 10 times the turbine height. This is supported by actual in-situ noise level measurements made in the vicinity of industrial wind turbines.
Taking the WHO night-time maximum limit guideline of 40 dBA and applying the wind shear design safety factor of 5 to 8 dB reveals a more realistic and appropriate maximum nighttime noise limit of 32 to 35 dBA. These noise limits may be achievable using a minimum noise setback distance of 10 times the turbine height (tower base to maximum blade height). Wind turbines rated at up to 2 MW require a setback of approximately 1 mile which is supported by in-situ wind turbine noise measurements in quiet areas (under 30 dBA nighttime); protecting public health and welfare. Short-term noise excursions, allowed by the existing Connecticut law, have been associated with sleep disturbance and should be disallowed. Low-frequency noise produced by wind turbines must be limited and considered to be a critical factor for determining the viability for a proposed site to be a good acoustic neighbor.
Author: Lawrence, David
What is the basis of your testimony to the Siting Council?
I have concerns about the siting of wind turbines in residential areas due to documented health risks if adequate setbacks are not established. …
What is the basis for your concerns about setback distances?
There is safety in distance. Wind turbines emit sound energy that includes audible sound as well as infrasound. Infrasound has been documented to have acute medical effects in high doses over short periods. At lower doses over a prolonged period of time, there are also established negative health effects. The way to protect the exposed population is to ensure that there is a safe distance from the wind turbines. The current Connecticut sound ordinance standards would allow infrasound exposure to exceed safe levels. Given the unique qualities of wind turbines, new standards must be established and enforced regarding protection from infrasound and other harmful noises. Standards set by wind turbine manufacturers do not adhere to science and do not afford adequate protection to neighboring residents.
What evidence do you have about the harmful effects of infrasound from acute exposure?
The Health Protection Agency of the United Kingdom compiled research regarding ultrasound and infrasound to establish safe limits on exposure in a paper, “Health Effects of Exposure to Ultrasound and Infrasound: Report of the Independent Advisory Group on Non-ionizing Radiation” (February 2010). While the authors acknowledge that there is not a lot of research to review regarding infrasound, a number of available studies demonstrated that high energy exposure — usually about 100 dBA — over short periods in a repeated fashion can have physiologic and psychologic effects on animals and on humans. That is to say, the energy from infrasound can have a negative impact on living beings. …
Since wind turbines are already set back to limit sound energy maximum to 55 dBA daytime, 45 dBA nighttime, what are your concerns about exposure to infrasound from them?
Levels of 55/45 dBA are clearly too high. Connecticut environmental sound regulations were developed in the 1970s. They can not possibly account for the unique issues of infrasound generated by wind turbines. A significant number of scientific investigators from around the globe have demonstrated that sound levels exceeding 30-35 dBA have negative health effects. In a series of studies by Pedersen and others in The Netherlands it has been shown that there is a significant increase in annoyance above 30-35 dBA.
The World Health Organization in its position papers “Guidelines for Community Noise” (1999) and “Night Noise Guidelines for Europe” (2009) notes that noise has detrimental effects on health above 30dBA, especially for “vulnerable populations”, that is, children and the elderly. These negative health effects include sleep disturbance with associated issues of daytime fatigue, reduced performance and accidents, as well as cardiovascular disease, depression and mental illness. The WHO furthermore states that “It should be stressed that a plausible biological model is available with sufficient evidence for the elements of the causal chain”.
Geoff Leventhall, a highly respected acoustics expert in the UK, has numerous publications regarding infrasound. In his paper “Low-Frequency Noise and Annoyance” (Noise and Health, 2004, 6; 23: 59-72) he notes that infrasound and low-frequency noise (10-200 Hz) “ha[ve] been recognized as a special environmental noise problem”, “that the A-weighted level underestimates the effects of low-frequency noise”, and that “there is a possibility of learned aversion to low-frequency noise, leading to annoyance and stress which may receive unsympathetic treatment from regulatory authorities” [emphasis added]. In a report on the effects of infrasound and low-frequency noise for the UK Department of Environment, Food and Rural Affairs, “A Review of Published Research on Low-Frequency Noise and Its Effects” (May 2003), Leventhall reviews the science behind his concerns. Quoting Leventhall (section 13.60):
There is no doubt that some humans exposed to infrasound experience abnormal ear, CNS [central nervous system], and resonance-induced symptoms that are real and stressful. If this is not recognized by investigators or their treating physicians, and properly addressed with understanding and sympathy, a psychological reaction will follow and the patient’s problems will be compounded. Most subjects may be reassured that there will be no serious consequences to their health from infrasound exposure and if further exposure is avoided they may expect to become symptom free. [emphasis added]
Are you familiar with a position paper authored by leading experts that dismiss concerns about infrasound?
The paper in question is “Wind Turbine Sound and Health Effects: An Expert Panel Review” (December 2009). It was sponsored by American and Canadian Wind developers and should stand as an embarrassment to them. The positions taken by the experts have omissions, misstatements, and unsupported conclusions. They offered little science to back their claims, and at times contradicted the science they presented. A fairly comprehensive critique with exposure of many of the misstatements was published as “An Analysis of the American/Canadian Wind Energy Association Sponsored ‘WTSHE/EPR’” (January 2010). I will add that when I read the report I felt that there were even more errors that those critics pointed out. All in all the “WTSHE/EPR” paper was poorly done and can not be considered seriously in siting guidelines. As a troubling aside, Geoff Leventhall, quoted by me in question 5, was one of the co-authors. By co-authoring the paper, he stands in contradiction to his own work, even if it is tacit approval of the statements. I say this to point out that apparently even a highly respected researcher can bend the rules of integrity with the right incentives.
Do you have any comments about studies raised by researchers such as [doctors] Nina Pierpont and Amanda Harry?
I think that time will validate much if not all of the findings that these researchers claim. They [the findings] are dismissed by the wind farm developers because they are not blinded studies and are based on reporting as opposed to concrete facts. However, given scientific studies in the lab and with study groups that show harm at acute, high-level exposure, and studies that demonstrate annoyance and related health issues above 30-35 dBA, it is reasonable to think that wind-related health issues as determined in these studies are real. The practice of medicine approaches evaluation and care of patients scientifically. Data are gathered, patients are assessed, and conclusions are based on probabilities. If someone is evaluated for a fever, even though there is a tremendously long list of possible causes, one can usually determine its cause through evaluation and taking into consideration likelihoods. In that way I believe that the researchers noted have sound reason to draw the conclusions they have. …
In your opinion as a medical doctor, would you agree that annoyance can cause negative health effects?
Annoyance even vaguely defined would include emotional responses that could easily affect physical and psychologic well-being. As stated by the WHO and others, annoyance is associated with sleep disorders, cognitive impairment, headaches, agitation, and depression among other issues. Annoyance is seen to be a factor that causes stress. In the practice of medicine we recognize stress a s a risk factor for heart disease, high blood pressure, migraine and tension headaches, fibromyalgia, and anxiety and depressive disorders, to name some of the prominent problems. Therefore there is a natural connection with annoyance and physical and psychologic disorders. In my clinical practice I have seen significant physical and health problems that have at least in part been caused and or made worse by stress. …
How do you propose the Siting Council establish safe standards?
The Siting council would do well to collate the abundance of data that is available from researchers and from experiences with existing wind farms. Siting guidelines should conform to WHO standards of limiting exposure to 30-35 dBA. Distance from the source, i.e., the wind turbines, is the only reasonable way to limit exposure. Kamperman and James (“Simple Guidelines for Siting Wind Turbines to Prevent Health Risks”; Noise-Con 2008, 2008 July 28-31) review various sound considerations and propose guidelines that would set back wind turbines a minimum of 1000 meters. Petersen and Waye (“Wind Turbine Noise, Annoyance and Self-Reported Health and Well-Being in Different Living Environments”, Occupational and Environmental Medicine 2007; 64: 480-486) account also for site topography, stating:
Perception and annoyance were associated with terrain and urbanization: (1) A rural area increased the risk of perception and annoyance in comparison with a suburban area; and (2) in a rural setting, complex ground (hilly or rocky terrain) increased the risk compared with flat ground.
Professor John Harrison recommend specifically addressing the additive noise impact of wind turbulence as well as the summation of direct sound plus sound reflected from the ground (i.e., coherent reflection) (“Disconnect Between Turbine Noise Guidelines and Health Authority Recommendations”, white paper, Queen’s University, Ontario). …
Do you have any concluding remarks?
I believe that there is strong scientific evidence to conclude that wind turbine have inherent health risks related to low-frequency noise and infrasound. I believe that the safety of the pubic must be upheld over the ideals of green energy production, and that to protect the public wind turbine setbacks must be long enough to minimize the intensity of the sound such that it does not exceed 30-35 dBA at the residences. The lower level should be applied for children and the elderly, who are the most vulnerable. The setbacks are the be determined not only be distance, but must also accounting for site topography, turbulence and coherent reflection. Furthermore, as this case sets a precedent for future wind turbine siting, the outcome of these hearings must uphold the greater good of the residents of Connecticut regardless of political pressures and potential financial gains. This should be about what is right and correct, not “who wins the battle”.
Connecticut, Emissions, Maine, Massachusetts, New Hampshire, New York, Regulations, Rhode Island, Vermont •
Author: Short, William
What were the original goals of state RPS programs and RGGI [Regional Greenhouse Gas Initiative]?
• The generation of energy either from new renewable or “threaten” existing renewable generation.
• The reduction of Greenhouse Gas emissions.
• Note the Absence of Qualifications.
What are the principal causes of the need to integrate renewables?
State Renewable Portfolio Standards –
• One MWh of Renewable Energy equals one Renewable Energy Certificate (“REC”).
• With no locational, time-of-day or time-of-year adjustments.
• Total focus on energy with no consideration of the reliability value or locational aspects of renewable generation.
Regional Greenhouse Program –
• Equal focus on renewable projects regardless of location or time of operation.
What are the principal results of the failure to integrate properly renewables?
The results –
• Transmission lines to nowhere.
• Encouraging unreliable, uncommitted renewable generation.
• Need for back-up generation and storage.
What is incrementally satisfying New England RPS programs?
• Empty Renewables – those renewables which provide limited capacity values.
• Nowhere Renewables – those renewables which require significant transmission upgrade costs to be borne by ratepayers.
• Worthless Renewables – those renewables which provide no long-term value to New England consumers and retain the ability to participate in their out-of-region RPS programs on a moment’s notice.
What is not incrementally satisfying New England RPS programs?
• Local Renewables. Example, solar energy and off-shore wind.
• Reliable Renewables. Example, landfill gas and biomass.
• Committed Renewables. Example, resources committed to ISO-NE capacity market.
What are the other principal flaws of state renewable energy programs?
Other material flaws –
• A binary market.
• No price support (floor) mechanism.
• Alternative Compliance Payment not related to Value of the Renewable Generation.
What should be the public policy for the integration of renewables and correcting flaws in RPS policy?
A sound public policy that:
• Values more renewable sources built closer to load (the locational argument).
• Values these sources more if they generate during on-peak hours (the time-of-day argument).
• Values these sources more if they generate during on-season hours (the time-of-season argument).
• Requires that these sources be committed to deliver all of their energy and capacity to New England customers (the capacity argument).
• Sets a Floor Price for REC equal to the lower of Alternative Compliance Price or the Value Produced by the Renewable Generation (the price taker argument).
What should be solutions to the integration of renewables?
The solutions –
• Locational, Time-of-Day, Time-of- Season Adjusted and Committed Capacity Renewable Energy Certificates. What are the solutions for state renewable energy programs?
• An unlimited requirement for renewable energy based upon a payment equal to the lesser of the value of REC (for the hour or period of the year in question) or the Alternative Compliance Price.
• A Central Buyer of RECs who purchases any and all RECs under the preceding condition.
What is the value of renewable energy generation to the public?
• The NYISO/NYSERDA wind study found that wind generation (primarily off-peak generation) would lower all energy prices by $1.80/MWh. Assuming a 6% RPS requirement, this value implies a price suppression value accruing to the wind generator of $30.00/MWh.
• ISO-NE’s RSP-06 found that price taker generation (base load) would lower all energy prices by $4.41/MWh. Assuming a 5.9% RPS requirement, this value implies an approximate price suppression value accruing to the price taker generation of $75.00/MWh.
• An analysis of the RSP06 data indicates that the price suppression results are not the same for all hours. This analysis indicates that the price suppression values are worth approximately –
– $300-360/MWh for super on-peak hours (Monday-Friday, noon to six p.m. in the summer months and Monday-Friday, 4 p.m. to 8 p.m. in the winter months).
– $90-120/MWh for all other on-peak hours.
– $30-40/MWh for all off-peak hours.
• An analysis of the RSP06 data also indicates that the price suppression values in on-peak hours exceed an Alternative Compliance Price of approximately $60.00/REC. Thus, the more RECs purchased during these hours, the lower the price of energy to the ratepayer even when the cost of the RECs are included. For the other hours, when the price suppression is less than the ACP, it will be necessary to lower the payments to the renewable generator in order to create ratepayer savings.
• Since the public benefit exceeds the cost to the public, a Central Buyer scheme (similar to that of NYSERDA) should be implemented to ensure that the ratepayer receives the maximum amount of renewable energy that is cost effective.
Normalizing these values, produces the following REC values from this renewable generation:
• Three RECs for each MWh of super on-peak hour energy produced (Monday-Friday, noon to six p.m. in the summer months and 4 p.m. to 8 p.m. in the winter months).
• One and one-half RECs for each MWh of energy produced during all other on-peak hours.
• One-third REC for each MWh of energy produced during all off-peak hours.
How does this compare with what we have now in New England?
• Presently, a 1 MW generator operating at 100 % capacity factor makes 8,760 MWh and 8,760 RECs.
• As proposed, that same generator operating under identical conditions would make the same MWh and same RECs, but with REC production focused on the on-peak periods:
1,950 RECs during the super on-peak hours (650 hours);
5,265 RECs during the balance of the on-peak hours (3,510 hours);
1,545 RECs during the off-peak hours (4,600 hours).
What are the locational adjustment factors for renewable energy generation?
• Generation built closer to load has lower congestion and marginal loss.
• Generation built closer to load will require less transmission improvements.
• Generation built closer to the host state of the RPS will produce greater economic impact, jobs, property tax, electric infrastructure to the host state than generation built further way.
Using these factors, what would be reasonable locational adjustment factors for Renewable Generation qualified for the Massachusetts RPS?
• Massachusetts – no discount.
• Adjacent New England state to Massachusetts – 5% discount.
• Two states away from Massachusetts but still in New England – 10% discount.
• Eastern New York – 20% discount.
• Western New York and Canada – 30% discount.
Combining these two ideas, what are the values for a renewable generator’s RECs under central procurement for the Mass RPS?
• Massachusetts – $180/MWh on super on-peak REC, $90/MWh all other on-peak REC and $20/MWh for off-peak REC.
• Adjacent NE State – $171/MWh on super on-peak REC, $85.50/MWh all other on-peak REC and $19/MWh for off-peak REC.
• Maine – $162/MWh on super on-peak REC, $81.00/MWh all other on-peak REC and $18/MWh for off-peak REC.
• Eastern New York – $144/MWh on super on-peak REC, $72.00/MWh all other on-peak REC and $16/MWh for off-peak REC.
• Western New York and Canada – $126/MWh on super on-peak REC, $63/MWh all other on-peak REC and $14/MWh for off-peak REC.
What would be the outcomes if these policy changes were implemented?
• RECs would be adjusted for their time-of-day, time-of-year and locational values.
• Central Buyer concept would stabilize the REC market and provide a better structure to permit long-term financing.
• RECs would always produce value to the ratepayer greater than the cost to the ratepayer.
• Lowest energy prices for ratepayers (with the savings largely paid for by fossil and nuclear generators) What would be the outcomes if these policy changes were implemented?
• Transmission lines to nowhere would not be built.
• Storage projects for off-season, off-peak energy would not be needed.
• Back-up generation for unreliable or uncommitted renewable capacity would not be constructed.
• With less transmission requirements, less stress on the environment.
William P. Short, III, Consultant, November 18, 2008