Resource Documents — latest additions
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.
Author: Vermonters for a Clean Environment
1. Wind is a mature industry – it’s time for it to stand on its own. The Joint Committee on Taxation reports that between 1992 and 2015 , the cumulative cost of the PTC, without extension, will be approximately $17 billion with the bulk of this claimed by wind resources constructed since 2006. These costs are in addition to the anticipated $22.6 billion in direct cash outlays under the Section 1603 grant program now expired. Yet, after decades of government support of multiple kinds, the wind industry remains economically unviable.
2. The wind-sector slow-down is not tied to the end of the PTC. The wind industry insists it’s at risk of a slow-down without the PTC and jobs will be lost. But this view ignores crucial factors driving development in the United States. Demand for wind has eroded, in part, due to states meeting their renewable mandates. Lower natural gas prices have further reduced wind’s attractiveness as a ‘fuel saver’. Faced with these market conditions, wind developers are tabling projects. The Energy Information Administration  now forecasts flat growth in the wind sector for this decade regardless of what happens with the PTC.
3. Wind energy is costly, and government efforts to offset the cost distort the markets. Wholesale power contract prices for onshore wind are roughly two- to three- times the price of more reliable generation, making wind one of the most expensive power sources in the U.S. even after the PTC is factored in. The PTC offsets the high price of wind energy, giving the false impression that wind is competitive with other resources, but at 2.3¢/kWh, the subsidy’s pre-tax value (3.5¢/kWh) equals, or exceeds the wholesale price of power in much of the country. The size of the subsidy relative to wholesale prices is distorting competitive wholesale energy markets and harming the financial integrity of other, more reliable generation .
4. The industry’s job-creation claim is based on one-sided, simplistic modeling. The wind industry insists the PTC enables American jobs but ignores potential jobs that would be created given alternative spending of federal funds. Further, industry job forecasts fail to report on the more important net job creation. In states like Vermont, government models have shown that above- market energy costs tied to renewables reduce any positive employment impacts of renewable energy capital investment . This is without taking into account additional costs associated with wind-related transmission build-out and grid integration costs associated with wind energy’s intermittency.
 M. Sherlock Testimony, April 2012. http://science.house.gov/sites/republicans.science.house.gov/files/documents/hearings/HHRG-112-SY21-WState-MSherlock-20120419.pdf
 Energy Information Administration. EIA Reference case for wind energy, June 2012. http://www.eia.gov/oiaf/aeo/tablebrowser/#release=AEO2012&subject=0-AEO2012&table=16-AEO2012®ion=0-0&cases=ref2012-d020112c
 Northbridge Group, Negative Electricity Prices and the Production Tax Credit. September 2012. http://www.nbgroup.com/publications/Negative_Electricity_Prices_and_the_Production_Tax_Credit.pdf
 Vermont Department of Public Service, The Economic Impacts of Vermont Feed in Tariffs. December 2009. http://publicservice.vermont.gov/planning/DPS%20White%20Paper%20Feed%20in%20Tariff.pdf
Author: Residents of Ohio
Sorry, this post has been removed, to be published later.
The undersigned residents of Ohio communities affected or threatened with industrial wind development wish to bring to your attention the untenable situation we face due to the failure of the Ohio Power Siting Board (“OPSB”) to protect the public interest. We assert that the OPSB has not adopted rules that adequately and faithfully implement the requirements of siting statutes. Moreover, it has acted in ways that contribute to public confusion resulting in the loss of due process. The actions and omissions of the OPSB have abridged our fundamental constitutional right to be protected and secure in the possession of our property. We call for legal reforms to curb the errors and failures in the Board’s administration of the wind power siting program over the past six years.
For example, the OPSB was supposed to complete a mandatory five-year review of its rules through a proceeding it initiated in July 2012; to this end it issued orders adopting new rules in Case No. 12-1981-GE-BRO. Throughout that rulemaking proceeding, OPSB invited the input of utilities, wind developers, parties who recently filed applications, and their attorneys. However, the Board never notified or solicited the input of members of the public who intervened in OPSB matters. The Board did not even notify intervenors who were extensively involved in the development of the Board’s original wind power siting rules in 2008-09. Furthermore, the Board never filed notice of the proposed or final rules in the Register of Ohio, presumably because the OPSB and PUCO are exempt from the notice-and-comment rulemaking requirements of R.C. Chapter 119. In sum, while the Board’s recent rulemaking was open to utilities, wind developers, other regulated entities, and their attorneys, the process was entirely “under the radar” as far as the public was concerned.
Furthermore, under Ohio law, agencies such as the OPSB must file newly adopted rules with the Joint Committee on Agency Rule Review (“JCARR”) so that the rules can be evaluated by the General Assembly based on specified legal criteria. Yet, although the OPSB adopted its new set of rules on February 18, 2014, the OPSB has not filed its newly adopted wind power siting rules with JCARR and is thereby denying the public an opportunity to address the mismatch between the OPSB’s rules and the requirements specified by the Ohio General Assembly.
Time and again OPSB’s hearing process has proven hostile to public participation. Before approving a power siting certificate, the Board must hold both a “public hearing” at which any interested party may be heard and an “evidentiary hearing” at which only the applicant, Board Staff, and approved intervenors may participate. But the Board representatives conducting public hearings refuse to answer questions about the project and refer members of the public back to the wind developer for responses to their questions. In evidentiary hearings, the Board routinely imposes a discriminatory double standard by requiring intervenors (usually members of the public) to submit live expert witness testimony while allowing developers to submit reams of documentary information as “evidence” without expert support. The Board delegates the oversight and conduct of both hearings to an Administrative Law Judge employed by the PUCO, who then prepares the written decision and certificate for the Board’s approval (usually at a single meeting with minimal discussion). No Board member participates in the hearings, which calls into question the depth of the Board members’ understanding of the issues they are called on to decide.
From the perspective of local property owners, who strongly object to the placement of wind farms near their homes and property, we must spend our time and our own money to do the job that the OPSB should be doing for the public and yet we feel we are being undercut by the OPSB at every turn. The net result of OPSB actions works to effectively deprive us of any meaningful opportunity to be heard. At the same time, the OPSB is issuing, over the strong objections of local property owners and local government officials, more certificates authorizing the construction of new industrial wind facilities that intend to violate the minimum setback requirements in current law. In other cases, the OPSB is allowing certificated wind farms to evade the General Assembly’s new setback requirements by improperly extending the life of those certificates before the effective date of the setback requirements.
Contrary to the statutory requirements enacted by the General Assembly, the OPSB is complicit in and protective of unfair and unreasonable wind industry practices. Examples include:
- Permitting legal notice of public hearings to appear at times when the public is least likely to see them;
- Scheduling public hearings at times the public is least able to attend;
- Allowing wind companies to conduct required pubic information meetings without specifying the location of proposed wind turbines;
- Allowing wind companies to meet the Board’s public notification requirements using maps that lack necessary detail, such as roads or parcel boundaries, to enable landowners to assess the potential impact on their properties;
- Enabling wind companies to negotiate unfair and one–sided contracts that obligate the signer to waive impacts they often do not understand; that burden the entirety of a property for up to 45 years; that are negotiated using a divide and conquer strategy ; that include no right of rescission; and that include onerous and overbroad confidentiality clauses. Oftentimes, the property owner is elderly and may not be in a position to understand or negotiate in his or her best interest.
- Failing to establish clear and enforceable standards for audible noise and instead allowing the use of vague “design goals” that fail to consider worst-case impacts;
- Failure to establish any standards at all for inaudible low frequency noise emissions;
- Refusing to consider a report from a Wisconsin power siting proceeding that cited new scientific findings regarding low frequency noise from wind turbines and concluded that there is now enough evidence to classify low-frequency noise and infrasound from wind turbines as “a serious issue, possibly affecting the future of the wind industry.”
- Failing to require that setback waivers be obtained from all adjacent property owners as required by law;
- Failing to require wind developers to specifically articulate the alleged benefits accruing to the described project area and, instead, accepting alleged benefit claims that pertain to unrelated and distant communities even though the impact/burden of the project is borne by the local property owners;
- Failing to accord due weight to local governments who object to applications on the basis of harms to the community’s economic health and welfare or cultural identity;
- Failing to adopt rules for siting industrial wind turbines near public and private recreational areas, including Indian Lake as well as numerous golf courses and equestrian facilities;
- Extending certificate expiration dates without following the statutory requirements for amendment of certificates, such as the requirements for investigation by the OPSB staff and for public hearing to consider substantive changes in the assumptions underlying the original certificate (chief among these changes is the dramatic increase in blade length which increases vibration and low frequency emissions as well as recent medical studies concerning related health effects);
- Failing to consider cumulative impacts in areas where multiple projects are sited;
- Failing to require developers to establish a complaint resolution protocol acceptable to the community prior to issuing a certificate; and
- Blaming insufficient funding/lack of resources to fully carry out their duties.
As the Ohio Supreme Court has stated, “It is axiomatic that the federal and Ohio constitutions forbid the state to take private property for the sole benefit of a private individual.” Norwood v. Horney (2006), 110 Ohio St.3d 353, 365. Yet that is exactly what the Power Siting Board has repeatedly permitted to occur. The constitutionally protected property rights of Ohioans are being harmed in favor of industrial wind development. These massive industrial power plants are being imposed in rural residential communities by private for-profit developers. The developments are structured as limited liability
companies owned more often than not by foreign private equity firms. These massive industrial power plants are not public utilities and are not empowered with the right of eminent domain but through the faulty administration of the law by the Ohio Power Siting Board that is effectively the result. Ohio’s administration of wind power development is unregulated under the guise of regulation.
We request that you halt further consideration of any active industrial wind power siting case until lawful rules are established, eliminate the exemption from rulemaking due process currently afforded to the Ohio Power Siting Board under Revised Code Chapter 119, and require that any application for certificate amendment or extension be subjected to the due process of meaningful public notice, a full investigation, and a fair hearing. If the State of Ohio is unable to administer a fair regulatory program that protects her citizens, siting decisions must be returned to local zoning and control.
Should you have any questions or require additional information, please contact Julie Johnson at juliejohnson/ctcn.net or call 614-284-6151. Thank you for your consideration.
Signed by Residents of Ohio [Whose Names and Addresses Were Attached Hereto]
November 11, 2014
TO: Governor John Kasich
State of Ohio
Riffe Center, 30th Floor
77 South High Street
Columbus, OH 43215-6117
Lt. Governor Mary Taylor
Senator Keith Faber, President, Ohio Senate
Speaker William Batchelder, Ohio House of Representatives
Senator William Seitz, Chairman, Senate Public Utilities Committee, Ohio Senate
Rep. Peter Stautberg, Chairman, House Public Utilities Committee
Chairman Tom Johnson, Public Utilities Commission of Ohio
Author: Electric Reliability Council of Texas
The Electric Reliability Council of Texas (ERCOT) is the independent system operator (ISO) for the Texas Interconnection, encompassing approximately 90% of electric load in Texas. ERCOT is the independent organization established by the Texas Legislature to be responsible for the reliable planning and operation of the electric grid for the ERCOT interconnection. Under the North American Electric Reliability Corporation (NERC) reliability construct, ERCOT is designated as the Reliability Coordinator, the Balancing Authority, and as a Transmission Operator for the ERCOT region. ERCOT is also registered for several other functions, including the Planning Authority function.
In June 2014, the U.S. Environmental Protection Agency (EPA) proposed the Clean Power Plan, which calls for reductions in the carbon intensity of the electric sector. The Clean Power Plan would set limits on the carbon dioxide (CO₂) emissions from existing fossil fuel-fired power plants, calculated as state emissions rate goals. For Texas, EPA has proposed an interim goal of 853 lb CO₂/MWh to be met on average during 2020-2029, and a final goal of 791 lb CO₂/MWh to be met from 2030 onward. EPA calculated the state-specific goals using a set of assumptions about coal plant efficiency improvements, increased production from natural gas combined cycle units, growth in renewables generation, preservation of existing nuclear generation, and growth in energy efficiency.
ERCOT has evaluated the potential implications of the proposed Clean Power Plan for grid reliability and conducted a modeling analysis of the impacts to generation resources and electricity costs in the ERCOT region. Based on this analysis, ERCOT anticipates that implementation of the proposed Clean Power Plan will have a significant impact on the planning and operation of the ERCOT grid. ERCOT estimates that the proposed CO₂ emissions limitations will result in the retirement of between 3,300 MW and 8,700 MW of coal generation capacity, could result in transmission reliability issues due to the loss of generation resources in and around major urban centers, and will strain ERCOT’s ability to integrate new intermittent renewable generation resources. The Clean Power Plan will also result in increased energy costs for consumers in the ERCOT region by up to 20% in 2020, without accounting for the costs of transmission upgrades, procurement of additional ancillary services, energy efficiency investments, capital costs of new capacity, and other costs associated with the retirement or decreased operation of coal-fired capacity in ERCOT. This summary report describes the results of ERCOT’s analyses.
Summary of ERCOT Concerns with the Clean Power Plan
ERCOT approaches this analysis from the perspective of an independent grid operator in a competitive market which has achieved significant success in using competition to drive efficient outcomes. Existing market policies and investments in transmission in ERCOT have incentivized market participants to maximize the efficiency of the generating fleet and develop new technologies including renewable generation. With recent investments in transmission, more than 11 GW of wind capacity have been successfully integrated into the ERCOT grid. The ERCOT region maintains a forward-looking open market and provides affordable and reliable electricity to consumers in Texas.
ERCOT’s primary concern with the Clean Power Plan is that, given the ERCOT region’s market design and existing transmission infrastructure, the timing and scale of the expected changes needed to reach the CO₂ emission goals could have a harmful impact on reliability. Specifically, implementation of the Clean Power Plan in the ERCOT region, particularly to meet the Plan’s interim goal, is likely to lead to reduced grid reliability for certain periods and an increase in localized grid challenges. There is a natural pace of change in grid resources due to advancing cost effective technologies and changing market conditions.
This pace can be accelerated, but there is a limit to how fast this change can occur within acceptable reliability constraints. It is unknown based on the information currently available whether compliance with the proposed rule can be achieved within applicable reliability criteria and with the current market design. Nevertheless, there are certain grid reliability and management challenges that ERCOT will face as a result of the resource mix changes that the proposed rule will induce:
- The anticipated retirement of up to half of the existing coal capacity in the ERCOT region will pose challenges to reliable operation of the grid in replacing the dispatchable generation capacity and reliability services provided by these resources.
- Integrating new wind and solar resources will increase the challenges of reliably operating all resources, and pose costs to procure additional regulating services, improve forecast accuracy, and address system inertia issues.
- Accelerated resource mix changes will require major improvements to ERCOT’s transmission system, posing significant costs not considered in EPA’s Regulatory Impact Analysis.
Negative health impact of noise from industrial wind turbines: How the ear and brain process infrasound
Author: Punch, Jerry; and James, Richard
This article, the final of three installments, discusses the relationship between various health effects and our current understanding of the processing of infrasound by the ear and brain. [Part 1: Some Background; Part 2: The Evidence.]
As noted in the second installment of this series, Dr. Geoff Leventhall, a co-author of the 2009 AWEA/CanWEA report, attributes the health complaints of people who live near industrial wind turbines (IWTs) to psychological stress, but does not acknowledge that IWTs can be detrimental to health because infrasound and low-frequency noise (ILFN) emitted by wind turbines are largely inaudible to humans. He stands on the argument, therefore, that what we can’t hear can’t hurt us.
We know that things we cannot see, touch, taste, or smell can hurt us, so why is it unreasonable also to believe that what we can’t hear might also hurt us?
Dr. Nina Pierpont, in describing Wind Turbine Syndrome (WTS), has expressed her belief that many of the symptoms comprising WTS are mediated by overstimulation of the vestibular system of the inner ear by ILFN. Recent evidence supports the general view that the functioning of both the vestibular and cochlear components of the inner ear, and their interconnections with the brain, mediate the type of symptoms that Pierpont and others have described.
INFRASOUND: MORE OF A PROBLEM THAN WE THOUGHT?
Industrial-scale wind turbines generate peak sound pressure levels at infrasonic frequencies, especially between 0.25 and 3 Hz, as the blades pass in front of the tower. Most of us do not experience the energy in this lowest of low-frequency regions as sound; instead, we perceive a variety of other sensations. When present, infrasound can be more of a problem than audible sound.
Recent basic research on the inner ear conducted by Dr. Alec Salt and colleagues at the Washington University School of Medicine in St. Louis has provided a feasible and coherent explanation of how sound that is normally not audible can result in the kinds of negative reactions reported by people who are exposed to wind turbine noise. That research has shown that extremely low-frequency sound is largely inaudible to humans because the outer hair cells (OHCs) in the inner ear detect and effectively cancel it before it reaches the inner hair cells (IHCs). The IHC stereocilia, which do not contact the tectorial membrane, are fluid-coupled and sensitive to stimulus velocity, while the OHC stereocilia are sensitive to displacement. IHCs rapidly become less sensitive as stimulus frequency is lowered.
Readers familiar with the anatomy of the ear know that approximately 95% of the fibers innervating the IHCs lead to the brain as afferent fibers, while only about 5% of the fibers innervating the OHCs are afferent fibers. Thus, we hear through our IHCs, and our hearing sensitivity is comparable to the calculated IHC sensitivity. The OHCs, which respond physiologically to infrasound, serve as a pathway for infrasound to reach the brain. Infrasonic signals that reach the brain are normally not perceived as sound, but are believed to stimulate centers other than auditory centers, resulting in perceptions that may be unfamiliar and disturbing.
Similar pathways to various centers of the brain also exist through the vestibular, or balance, mechanisms of the inner ear, meaning that it is biologically plausible for infrasound to produce the variety of sensations described by Pierpont, sensations such as pulsation, annoyance, stress, panic, ear pressure or fullness, unsteadiness, vertigo, nausea, tinnitus, general discomfort, memory loss, and disturbed sleep.
Salt and colleagues have also found that when higher-pitched sounds (150-1500 Hz) are present, they can suppress infrasound. This means that the ear is most sensitive to infrasound when higher-frequency sounds are absent. This occurs at night when wind turbine noise is present, ambient sound levels are low, and higher-pitched sounds are attenuated by walls and other physical structures.
Another relatively recent discovery is that there is likely a cause-effect relationship between AHEs and ILFN that mirrors that occurring in motion sickness. An experiment in the late 1980s, conducted using training-mission scenarios with Navy pilots, showed that motion sickness was associated with significant amounts of acoustic energy inside the flight cabin over the frequency range from just under 1 Hz to as low as 0.05 Hz (the nauseogenic range). Maximum sensitivity occurred at approximately 0.2 Hz. That experiment resulted in the conclusion that flight simulator sickness may be, to a significant extent, a function of exposure to infrasonic frequencies. This phenomenon is akin to seasickness, except that the acoustic energy causes nausea without body movement or visual stimulation.
Dr. Paul Schomer, nationally and internationally known for his work in acoustics and acoustic-standards development, has suggested that because the Navy test subjects responded to acoustical/vibratory energy with symptoms similar to motion sickness, many of the similar symptoms reported by people living near IWTs can be explained by exposure to infrasound from wind turbines at frequencies similar to those observed in the Navy’s test environment. Persons affected by wind turbine noise appear to be responding directly to acoustic stimulation of the same nerves and organs affected in that experimental environment.
DATA SUPPORT REPORTED SYMPTOMS AS BIOLOGICALLY PLAUSIBLE
These research efforts of Salt and colleagues, Schomer, and others are leading the way in establishing the biological plausibility of the harmful effects of ILFN generated by wind turbines.
Dr. Salt dismisses the common perception that what we can’t hear can’t hurt us and has stated unequivocally that “Wind turbines can be hazardous to human health.”
Decisions regarding the siting of industrial wind turbines deserve careful attention to limiting noise exposure levels in community residents through specified restrictions on either distance or noise levels, or both. The right of the public to enjoy health and well-being should be paramount to the economic and political interests of the wind industry and governmental bodies. These rights need to be protected on a proactive, and not just on a retroactive, basis. Industrial-scale wind turbines should be sited only at distances from residents that are sufficient to minimize sleep disturbance and that do not put them at risk for a variety of other serious health problems.
Jerry Punch is an audiologist and professor emeritus at Michigan State University in the Department of Communicative Sciences and Disorders. Since his retirement in 2011, he has become actively involved as a private audiological consultant in areas related to his long-standing interest in community noise.
Richard James is an acoustical consultant with over 40 years of experience in industrial noise measurement and control. He served as an adjunct instructor in Michigan State University’s Department of Communicative Sciences and Disorders from 1985-2013 and currently serves as an adjunct professor in Central Michigan University’s Department of Communication Disorders.
[Originally published at Hearing Health & Technology Matters, Nov. 18, 2014]