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: Reider, Sandy
Public Service Board Hearing, July 29, 2014:
Good afternoon. My name is Sandy Reider, I am a primary care physician in Lyndonville, and I have been practicing clinical medicine in Vermont since I received my license in 1971. In the interest of full disclosure, I am not being paid for involvement in this issue, nor did I seek this out; rather, it found me by way of a patient I had known well for several years, and who, in late 2011, suddenly developed severe insomnia, anxiety, headaches, ringing ears, difficulty concentrating, and frequent nausea, seemingly out of the blue. This puzzled us both for a few months before we finally came to understand that he suffered from what was, then, a relatively new clinical entity known as “wind turbine syndrome”, related in his particular case to the comparatively small NPS 100 KW turbine that began generating power atop Burke Mountain in the fall of 2011. In the course of the 2012 legislative session, I described this patient in detail in testimony for the Senate Natural Resources and Health Care Committees, as well as the Governor’s Siting Commission. Since his symptoms were so typical and similar to those described by thousands of other individuals living too close to large wind turbines all over the globe, I have attached my testimony for the Senate Health Care Committee and encourage you to review it for its very characteristic description of what it is that this board, I trust, hopes to mitigate by recommending more protective sound standards for these industrial wind installations. I should add that I have seen 4 additional patients living close to the large Sheffield and Lowell projects, as well as an individual living near another single NPS 100KW turbine in Vergennes. All presented with similar, though not identical, symptoms to those described in my testimony.
That there have already been so many complaints here in Vermont related to wind turbines suggests that the current noise standards may be inadequate. Either the utilities have been regularly out of compliance with the current existing standards ( Shirley Nelson’s detailed daily records suggest this has indeed occurred with some regularity ) and/or that the scientific data and studies upon which the current noise standards are based is incomplete, or possibly just plain wrong.
Over the past 2 years I have reviewed much of the relevant scientific literature, and out of my 42 years of experience and perspective as a clinician, respectfully offer the following observations and comments.
Firstly, I do not doubt at all that these large turbines can and do cause serious health problems in a significant number of persons living nearby, even though the vibrational-acoustic mechanisms behind this harm are not yet completely understood (1,5). Repetitive sleep disruption is the most often cited adverse effect, and disturbed sleep and its resulting stress over time is known to cause or exacerbate cardiovascular illnesses (2), chronic anxiety and depression, as well as worsening of other pre-existing medical problems . This is especially concerning for the most vulnerable among us … children, the elderly, those who are naturally sensitive to sound, or prone to motion sickness or migraine headaches, and, as mentioned, those who are unwell to start with.
The position adopted by developers of large industrial wind projects, and thus far supported by regulatory and health agencies, has been that there is no evidence of a direct effect on health from wind turbines; rather, that the claimed adverse health effects are indirect, due mainly to the individual’s negative attitude about the wind turbines ( so-called “nocebo” effect ), and therefore it is their fault, it’s all in their heads, and so on. Not only is this incorrect, it is disingenuous. There is simply no clinical justification for ignoring harm being done to individuals and communities, whether direct or indirect, on these grounds… simply put, harm is harm, whatever the mechanism.
However, good evidence for direct adverse effects has existed since the mid-80’s when Neil Kelley headed a group of researchers, under the auspices of the US Department of Energy and NASA, and found conclusive evidence that adverse effects, very similar to those that describe “wind turbine syndrome”, were due primarily to very low frequency sound and inaudible infrasound (6). This role of infrasound was subsequently confirmed by Kelley’s team under controlled laboratory conditions, and resulted in a complete redesign of turbines from the downwind trestle-mounted turbines to today’s upwind turbine on a single massive tower. Furthermore, he recommended protective maximum levels of this low frequency sound.
[T]he joint radiation levels (expressed in terms of acoustic intensity and measured external to a structure) in the 8, 16, 31.5 and 63 Hz standard (ISO) octaves should not exceed band intensity threshold limits of 60, 50, 40 and 40 dB (re 1 pWm –2) more than 20% of the time. These figures compare favorably with a summary of low-frequency annoyance situations by Hubbard.
( It is worth noting that very often infrasound levels are higher inside a building than outside, the structure acting as a resonating chamber and amplifying the lower “vibration” frequencies. Thus measurements for low frequency sound should be made inside the structure as well as outside. Also, low frequency sound levels are not only building design and geometry specific, but also site specific, especially in a place like Vermont where the topography and climactic conditions are so variable. There may be unacceptable indoor infrasound levels in one home, while another home over the hill may have undetectable or very low levels. )
The wind industry’s assertion that the Kelley study is irrelevant and that infrasound levels are negligible with the current, newer turbine design and may be ignored is unfounded, and more recent evidence confirms this ( 2012 Falmouth study by Ambrose and Rand ( Bob Thorne’s excellent quality of life study in 2011 (12); Steven Cooper’s preliminary results in Australia, final results due in September 2014 (11); and others ). The aforementioned studies were performed by independent professional acousticians not connected to the wind industry. Incidentally, the severely affected patient described in my 2012 testimony never did perceive any audible noise from the turbine ( and this is quite typical, the sound is more felt than heard ), nor did he harbor any feelings pro or con about the installation when his problems began, though after he understood the source of his ill-health, I have no doubt that the “nocebo” effect may have added to his stress, adding insult to injury. He has since abandoned that home, and is once again sleeping soundly and feeling well.
The current sound standards, based as they are on dBA weighted acoustic measurements, gives particular weight to audible frequencies in the soundscape, but very little or no weight to low sound frequencies and infrasound, particularly below 10 Hz, which comprises a significant proportion of the sound generated by large turbines . People do not hear dBA, they hear qualitatively different sounds, birds, insects, running water, wind in the trees, etc. … basing noise criteria solely on this single number ignores the unique nature of the sound produced by large wind turbines, with its constantly changing loudness, frequency, harmonics, pitch, and impulsive quality. It is precisely these qualities that make the sound feel so intrusive and annoying, especially in quiet rural environments where these projects are usually located (12). Parenthetically, the word “annoying” is somewhat misleading, as it implies a minor, temporary, or occasional nuisance that perhaps might be mostly ignored, rather than what it is: a repetitive stressor that can degrade one’s short and long term health and well being, and from which there is no escape over the lifetime of the project short of having to abandon one’s home.
It is worth repeating here that the current Public Service Board threshold of 45 dBA of audible sound, averaged over an hour, has never been proven safe or protective, and that most studies agree that audible sound should not exceed 35 dBA, or 5dBA above normal background sound levels. (this is especially important in rural areas where background noise is minimal). The level should be a maximum , not an hourly average. Above 35 dBA there are likely to be significantly more complaints, particularly difficulty sleeping.
Before concluding, I would like to emphasize that the bulk of scientific evidence for adverse health effects due to industrial wind installations comes in the form of thousands of case reports like the patient I described. One or two sporadic anecdotal cases can legitimately be viewed with a wait-and-see skepticism, but not thousands where the symptoms are so similar, along with the ease of observing exposure and measuring outcomes, wherever these projects have been built. I agree with Epidemiologist Carl Phillips, who opined that “these case reports taken together offer the most compelling scientific evidence of serious harm. Just because the prevailing models have failed to explain observed adverse health effects does not mean they do not exist”, and, as he succinctly, though in my opinion a bit too harshly, concluded: “The attempts to deny the evidence cannot be seen as honest scientific disagreement and represent either gross incompetence or intentional bias” (13).
I am aware that the members of the PSB bear a heavy responsibility for Vermont’s overall energy future and have many other issues on their plate besides this one. Rather than presenting you with a long list of literature references most of which would likely go unread ( but they are included just in case ), I recommend a careful review of just one study in particular: Bob Thorne, a professional acoustician in Australia, presented an excellent and well thought out clinical study to the Australian Senate in 2011 (12). It really does cover the waterfront, including WHO quality of life measures, audible and infrasound measurements, and health measures, in a balanced and scientific way. For your convenience there is a hard copy of this study included with my presentation today.
His comprehensive ( including the full sound spectrum, not only dBA weighted sound ) and protective recommendations for sound criteria are reasonable, and if adopted, would be likely more acceptable to neighboring households and communities. However, given that wind developers are these days building bigger turbines atop taller towers in order to maximize power generation and profits, adoption of these safer limits would necessitate siting the installations farther from dwellings. A 1-2 km setback is not nearly sufficient; significant low frequency sound pressure measurements have been recorded in homes 3-6 miles from large projects in Australia.
The outcomes of the study are concerned with the potential for adverse health effects due to wind farm modified audible and low frequency sound and infrasound. The study confirms that the logging of sound levels without a detailed knowledge of what the sound levels relate to renders the data uncertain in nature and content. Observation is needed to confirm the character of the sound being recorded. Sound recordings are needed to confirm the character of the sound being recorded.
The measures of wind turbine noise exposure that the study has identified as being acoustical markers for excessive noise and known risk of serious harm to health (significant adverse health effects)
1. Criterion: An LAeq or ‘F’ sound level of 32 dB(A) or above over any 10 minute interval, outside;
2. Criterion: An LAeq or ‘F’ sound level of 22 dB(A) or above over any 10 minute interval inside a dwelling with windows open or closed.
3. Criterion: Measured sound levels shall not exhibit unreasonable or excessive modulation (‘fluctuation’).
4. Criterion: An audible sound level is modulating when measured by the A-weighted LAeq or ‘F’ time-weighting at 8 to 10 discrete samples/second and (a) the amplitude of peak to trough variation or (b) if the third octave or narrow band characteristics exhibit a peak to trough variation that exceeds the following criteria on a regularly varying basis: 2dB exceedance is negligible, 4dB exceedance is unreasonable and 6dB exceedance is excessive.
5. Criterion: A low frequency sound and infrasound is modulating when measured by the Z- weighted LZeq or ‘F’ time-weighting at 8 to 10 discrete samples/second and (a) the amplitude of peak to trough variation or (b) if the third octave or narrow band characteristics exhibit a peak to trough variation that exceeds the following criteria on a regularly varying basis: 2dB exceedance is negligible, 4dB exceedance is unreasonable and 6dB exceedance is excessive.
6. Definitions: ‘LAeq’ means the A-weighted equivalent-continuous sound pressure level ; ‘F’ time-weighting has the meaning under IEC 61672-1 and ; “regularly varying” is where the sound exceeds the criterion for 10% or more of the measurement time interval  of 10 minutes; and Z-weighting has the meaning under AS IEC 61672.1 with a lower limit of 0.5Hz.
7. Approval authorities and regulators should set wind farm noise compliance levels at least 5 dB(A) below the sound levels in criterion (1) and criterion (2) above. The compliance levels then become the criteria for unreasonable noise.
Measures (1-6) above are appropriate for a ‘noise’ assessment by visual display and level comparison. Investigation of health effects and the complex nature of wind turbine noise require the more detailed perceptual measures of sound character such as audibility, loudness, fluctuation strength, and dissonance.
To exclude careful independent well designed case studies like Thorne’s ( and others ) in a review of the scientific literature that purports to be thorough is, I repeat, a serious omission and is not “scientific”. Careful consideration of these independent well done studies, if nothing else, should encourage regulatory agencies to adopt a much more precautionary approach to the siting of today’s very big industrial wind projects in order to adequately protect public health. For better or worse, in today’s “information age” we are perhaps too fascinated by computers and mountains of data, but truth is truth, wherever you find it, even in small places.
Thank you very much for taking the time to address this issue, and for listening.
SANDY REIDER MD
PO BOX 10
EAST BURKE, VT 05832
Many thanks to Sarah Laurie, CEO of the Waubra Foundation, for her tireless work, and generosity in sharing so much information. www.waubrafoundation.org.au
1. Pierpont, Nina. 2009. From the executive summary of her peer reviewed study. http://waubrafoundation.org.au/resources/wind-turbine-syndrome-executive-summary/
2. Capuccio et al. 2011. Sleep Duration predicts cardiovascular outcomes: a systemic review and meta-analysis of prospective studies. European Heart Journal 32:1484-1492. http://waubrafoundation.org.au/resources/sleep-duration-predicts-cardiovascular-outcomes/
3. Nissenbaum, M, Hanning, C, and Aramini, J. 2012. Effects of industrial wind turbines on sleep and health. Noise and Health, October. https://www.wind-watch.org/documents/effects-of-industrial-wind-turbine-noise-on-sleep-and-health/
4. Shepherd, D, et al. 2011. Evaluating the impact of wind turbine noise on health related quality of life. Noise and Health, October. http://waubrafoundation.org.au/resources/evaluating-impact-wind-turbine-noise-health-related-quality-life/
5. Arra, M, and Lynn, Hazel. 2013. Powerpoint presentation to the Grey Bruce Health Unit, Ontario: Association between wind turbine noise and human distress. http://waubrafoundation.org.au/resources/association-between-wind-turbine-noise-and-human-distress/
6. Kelley, ND, et al. 1985. Acoustic noise associated with Mod 1 turbine, its impact and control. http://waubrafoundation.org.au/resources/kelley-et-al-1985-acoustic-noise-associated-with-mod-1-wind-turbine/
7. James, Richard. 2012. Wind turbine infra and low frequency sound: warning signs that went unheard. Bulletin of Science, Technology and Society 32(2):108-127, accessed via Professor Colin Hansen’s submission to the Australian Federal Senate Inquiry Excessive Noise from Windfarms Bill (Renewable Energy Act) November 2012 http://waubrafoundation.org.au/resources/testimony-hansenc-excessive-noise-bill-inquiry-submission/. James references another useful bibliography of references of the early NASA research, compiled by Hubbard & Shepherd, 1988: Wind turbine acoustic research—bibliography with selected annotation; http://waubrafoundation.org.au/resources/hubbard-h-shepherd-k-nasa-wind-turbine-acoustics-research/
8. Hubbard, H. 1982. Noise induced house vibrations and human perception. http://waubrafoundation.org.au/resources/hubbard-h-1982-noise-induced house vibrations-human-perception/
9. Ambrose, Stephen, and Rand, Robert. 2011. Bruce McPherson infrasound and low frequency noise study. http://waubrafoundation.org.au/resources/bruce-mcpherson-infrasound-low-frequency-noise-study/
10. Schomer, Paul, et al. 2013. A proposed theory to explain some adverse physiological effects of the infrasonic emissions at some wind farm sites. http://waubrafoundation.org.au/resources/schomer-et-al-wind-turbine-noise-conference-denver-august-2013/
12. http://waubrafoundation.org.au/resources/wind-farm-generated-noise-and-adverse-health-effects/. Also see: Thorne, Bob. 2011. The Problems With “Noise Numbers” for Wind Farm Noise Assessment. Bulletin of Science, Technology and Society 31:262. DOI: 10.1177/0270467611412557. http://bst.sagepub.com/content/31/4/262
13. Phillips, Carl. 2011. Properly interpreting the Epidemiological evidence about the health effects of Industrial Wind turbines on nearby residents. Bulletin of Science, Technology and Society vol 31 No 4 (August 2011) pp 303-315. http://waubrafoundation.org.au/resources/properly-interpreting-epidemiologic-evidence-about-health-effects/
Author: Nelson, Donna
RE: Open Meeting Agenda Item 29; Project No. 42079; Discussion and possible action on electric reliability; electric market development; ERCOT oversight; transmission planning, construction, and cost recovery in areas outside of ERCOT; SPP Regional State Committee and electric reliability standards and organizations arising under federal law.
As discussed at the April 17th open meeting, I would like to open a project to look at ERCOT’s prospective system upgrades, ancillary services, and the transmission planning process related to renewable resources, as well as problems that have arisen as part of the CREZ build-out. The unique characteristics and often-remote locations of renewable resources pose challenges to the electric grid, and those challenges are increased as the volume of wind on the system increases. For example, some of the series compensated transmission lines that are part of the CREZ build- out can cause sub-synchronous oscillation issues that must be resolved in order to avoid damage to the transmission grid and generation resources. The Panhandle region is currently experiencing so much interest from wind developers that there is a concern that the overall system strength will be negatively affected unless the infrastructure is updated.
The Federal Production Tax Credit was started in 1992 in order to spur a developing technology and allow it to gain the momentum necessary to make it commercially viable. Now, 22 years later, there can be no doubt that renewable technology-especially wind and solar-are mature industries. Every year when Congress extends the Production Tax Credit we are told that it will be the last year. Although the credit expired in December, the Senate Finance Committee recently approved a $13 billion, two-year renewal. I fear that this credit will once again be extended.
The Federal Production Tax Credit distorts wholesale electric markets, including the ERCOT market. With wholesale rates that hover around $40 per MWh in ERCOT, a federal program that pays wind generators $23 per MWh ultimately destroys the economic underpinnings of the wholesale competitive electric market. As wind installations continue and wind capacity in our market becomes a larger percentage of ERCOT capacity, not because it makes sense from an economic standpoint but because investment is driven by a federal government subsidy, our market faces the very real possibility of losing base load generation. As former Senator Phil Gramm stated in a December 25, 2012 Wall Street Journal article: “The costs of wind subsidies are extraordinarily high – $52.48 per one million watt hours generated, according to the U.S. Energy Information Administration. By contrast, the subsidies for generating the same amount of electricity from nuclear power are $3.10, from hydropower 84 cents, from coal 64 cents, and from natural gas 63 cents.”
While this Commission has no ability to change what Congress does, we do have an obligation to Texans to periodically review whether our rules appropriately assign cost to those who cause those costs. I would like to explore the costs of system upgrades, the costs to maintain and operate the current system, and the allocation of those costs specifically related to renewable resources.
Some of the transmission lines built as part of CREZ include series compensation that has the potential to cause sub-synchronous oscillation if the series capacitors that have been installed are taken out of bypass mode. This issue is a consequence of expanding the system to access resources that are located far from load centers. This Commission needs to decide how to address the existing problem, how to avoid this problem in the future, and how to resolve the cost allocation issues o f mitigating this risk.
Due to the amount of wind generation that we are now expecting on the transmission lines in the Panhandle, stability concerns and weak system strength will present significant challenges in that area. ERCOT has released a study that recommends system upgrades to address this issue. The transmission facilities in the Panhandle region installed as a part of CREZ included reactive equipment to support 2,400 MW of wind. As we see wind online in excess of 2,400 MW, the system strength will suffer. Under weak grid conditions, a small variation of reactive support results in large voltage deviations. These potential grid stability issues raise fundamental policy questions. For example, should we ask electric customers to fund further investment in the transmission system to improve stability or should some of the risk be borne by generators? When I review the PURA provisions that approved construction ofthe CREZ lines, it is obvious to me that the Texas Legislature intended that wind developers should have skin in the game but we need to further flesh out what that means as wind generation becomes an increasingly large percentage of installed capacity in the ERCOT market.
ERCOT is currently evaluating an ancillary services redesign, which gives us an opportunity to examine our current mix of services, those contemplated for the future, and the costs associated with these products. One of the reasons that ERCOT is exploring potential improvements to ancillary services is because some new resources expected to be added to the ERCOT system bring with them additional challenges. Given ERCOT’s changing resource mix, I would like to look at whether there are ancillary services costs that are incurred specifically because of the unique nature ofrenewable resources.
The ERCOT Board instructed ERCOT to review its transmission planning process. One issue
that I would like to explore here at the Commission is whether the production cost savings test, most recently adopted by the Commission in March 2012, is appropriate for analyzing the
benefits of transmission projects, especially projects to address transmission limitations and voltage stability mitigation that will be needed to address a system heavily weighted with wind generation, with a production cost ofzero.
I request that Commission Staff open a project with the title “ERCOT Planning and System Costs Associated with Renewable Resources.” If we encounter major policy issues in this rulemaking that we believe cannot be resolved by PURA, we can seek Legislative guidance by including these topics in our Scope of Competition report.
I look forward to discussing this with you at the open meeting.
TO: Commissioners Kenneth W. Anderson, Jr., and Brandy D. Marty
FROM: Chairman Donna L. Nelson
DATE: May 29, 2014
Author: Poser, Hans; et al.
Over the last decade, well-intentioned policymakers in Germany and other European countries created renewable energy policies with generous subsidies that have slowly revealed themselves to be unsustainable, resulting in profound, unintended consequences for all industry stakeholders. While these policies have created an impressive roll-out of renewable energy resources, they have also clearly generated disequilibrium in the power markets, resulting in significant increases in energy prices to most users, as well as value destruction for all stakeholders: consumers, renewable companies, electric utilities, financial institutions, and investors.
Accordingly, the United States and other countries should carefully assess the lessons learned in Germany, with respect to generous subsidy programs and relatively rapid, large-scale deployment and integration of renewable energy into the power system. This white paper is meant to provide further insight into the German market, present an objective analysis of its renewable policies, and identify lessons learned from Germany, and to a lesser degree, other European countries.
The rapid growth of renewable energy in Germany and other European countries during the 2000’s was due to proactive European and national policies aimed at directly increasing the share of renewable production in their energy mixes through a variety of generous subsidy programs. Two main types of subsidy programs for renewable power developed in Europe include feed-in tariffs (FITs), which very quickly became the policy of choice for Germany and many other European countries, and quota obligation systems.
FITs are incentives to increase production of renewable energy. This type of subsidy guarantees long-term (usually for 20 years) fixed tariffs per unit of renewable power produced. These fixed tariffs normally are independent of market prices and are usually set by the government, but can be structured to be reduced periodically to account for technology cost decreases. The level of the tariffs normally depends on the technology used and the size of the production facility. Because of their generosity, FITs proved capable of quickly increasing the share of renewable power, but since the FITs are set administratively, it is difficult to meet renewable energy goals in the most cost-effective way possible.
The quota system is the European equivalent to the Renewable Portfolio Standard used in the United States. Whereas FIT programs set the price for the resources and let the market achieve whatever level it can at that price, the quota system is a market based system that sets the desired amount of renewable resources and lets the market determine its price. Under the quota system, compliance is proven through renewable certificates that can usually be traded.
Germany used FITs to help finance its energy policy, “Energiewende” (the energy transformation), that calls for a nuclear-free and carbon-reduced economy through a vast deployment of renewable technologies.
Because FITs levels were administratively driven and slow to adapt to the evolution of the solar market, the incentive became excessively generous, which initiated an uncontrolled development of renewables, which, in turn, created unsustainable growth with a myriad of unintended consequences and lessons learned. Accordingly, this analysis will focus on Germany, whose FIT policies allowed it to realize the highest production of non-hydro renewable electricity (wind and solar) in Europe.
The most important lessons learned include:
- Policymakers underestimated the cost of renewable subsidies and the strain they would have on national economies. As an example, Germany’s FIT program has cost more than $412 billion to date (including granted and guaranteed, but not yet paid FIT). Former German Minister of the Environment Peter Altmaier recently estimated that the program costs would reach $884 billion (€680 billion) by 2022. He added that this figure could increase further if the market price of electricity fell, or if the rules and subsidy levels were not changed. Moreover, it is estimated that Germany will pay $31.1 billion in subsidies for 2014 alone. A recent analysis found that from 2008 to 2013, Germany incurred $67.6 billion (€52 billion) in net export losses because of its high energy costs, compared to its five leading trade partners. Losses in energy intensive industries accounted for 60 percent of the total losses. This was further highlighted by a recent International Energy Agency report, which stated that the European Union (EU) is expected to lose one-third of its global market share of energy intensive exports over the next two decades due to high energy prices, expensive energy imports of gas and oil, as well as costly domestic subsidies for renewable energy.
- Retail prices to many electricity consumers have increased significantly, as subsidies in Germany and the rest of Europe are generally paid by the end users through a cost- sharing procedure. Household electricity prices in Germany have more than doubled, increasing from €0.14/kilowatt hour (kWh) ($0.18) in 2000 to more than €0.29/kWh ($0.38) in 2013. In Spain, prices also doubled from €0.09/kWh in 2004 to €0.18/kWh in 2013 ($0.12 to $0.23) while Greece’s prices climbed from €0.06/kWh in 2004 to €0.12/kWh in 2013 ($0.08 to $0.16). Comparatively, household electricity prices in the United States average $0.13/kWh, and have remained relatively stable over the last decade.
- The rapid growth of renewable energy has reduced wholesale prices in Germany, with adverse consequences on markets and companies. Large subsidies and guaranteed interconnection to the grid for renewable energy led to unexpected growth over the last 10 years in Germany and elsewhere. The merit order in Germany’s wholesale markets switched as renewables, with a zero variable cost of production, take precedence over thermal plants. As a result, wholesale prices in Germany for base load have fallen dramatically from €90-95/megawatt hour (MWh) in 2008 to €37/MWh in 2013. This has created a large amount of load and margin destruction for utilities that built and financed thermal plants. Many new gas-fired power plants have been rendered uneconomical, leaving owners to shore up their balance sheets by undertaking large divestitures of some of their holdings, as well as by reducing their operational costs. The impact to utilities’ shareholder value has been dramatic and has come on top of the impact of the global financial crises, and, in the case of Germany, the decommissioning of nuclear power. The German utilities have seen their stock plunge by nearly 45 percent since 2010. Some power plant operators in Germany and other countries, like the United Kingdom, are now calling for capacity payments to ensure that reliability is maintained and not threatened by the shutdown of various thermal power stations.
- The wholesale pricing model has changed as a result of the large renewable energy penetration. In the past, wholesale prices followed the demand curve, but in Europe they now react to the weather; going down when the sun shines and the wind blows, and up when—at times of high demand—the sun does not shine and the wind does not blow. Price forecasts and power trading require more skill sets and different know-how, including weather forecasting.
- Fossil and nuclear plants are now facing stresses to their operational systems as these plants are now operating under less stable conditions and are required to cycle more often to help balance renewables’ variability. Investments in retrofits will be required for these plants in order to allow them to run to these new operational requirements. Moreover, renewable resources are dramatically changing thermal plants’ resource planning and margins. As a result, many of these plants are now being retired or are required to receive capacity payments in order to economically be kept online.
- Large scale deployment of renewable capacity does not translate into a substantial displacement of thermal capacity. Because of the variability of wind and solar, there are many hours in the year during which most generation comes from thermal power plants, which are required to provide almost complete redundant capacity to ensure the reliability of the system. In turn, grid interventions have increased significantly as operators have to intervene and switch off or start plants that are not programmed to run following market- based dispatching. For instance, one German transmission operator saw interventions grow from two in 2002 to 1,213 in 2013. It is higher amounts of renewables with low full load hours relative to the total portfolio of power production that creates greater variability and strains on the grid. In the case of Germany, it is the large-scale deployment of both wind and solar that has impacted the entire system.
- Large-scale investments in the grid are being required to expand transmission grids so they can connect offshore and onshore wind projects in the north of Germany to consumers in the south of the country. The total investment cost for the build-out of German onshore and offshore transmission systems is estimated to be around $52 billion (€40 billion) over the next 10 years. Moreover, the grids are now being challenged to meet the dynamic flows of variable renewables and require significant additional investment to accommodate increased penetration of renewables. All of these costs will ultimately be passed on to electricity consumers. This has not gone unnoticed in Germany or in the EU. A report was released in late February 2014 by an independent expert commission mandated by the German government, which concluded that Germany’s current program of incenting renewables is an uneconomic and inefficient means to reduce emissions and therefore should be stopped. Moreover, the European Commission released new guidelines on April 9, 2014, with effect starting in 2017 that will correct market distortions. It will essentially ban all FIT subsidies and introduce technology agnostic auctions as the only incentives for renewables.
- Overgenerous and unsustainable subsidy programs resulted in numerous redesigns of the renewable support schemes, which increased regulatory uncertainty and financial risk for all stakeholders in the renewable energy industry. As the lessons above show, some European renewable energy regulatory regimes were inappropriately structured, gamed by market players, or made obsolete by market conditions. As a result, governments and regulators corrected unsustainable regulatory regimes by reducing the level of subsidies, sometimes retroactively, and modifying the rules of the programs. These changes often resulted in significant value destruction to various renewable players and their respective investors. This continued regulatory uncertainty across Europe is increasing the cost of capital to European renewable companies, which the rating agency Fitch just recently highlighted as the most likely sector in the European energy market to receive a downgrade in 2014.
These lessons learned are important and provide factual analyses to assist other countries’ electric industry stakeholders’ in creating more technically-efficient, cost-effective and sustainable ways to integrate renewable energy.
U.S. stakeholders should take into consideration the lessons learned from Germany and Europe:
Utilities should incorporate those lessons into their strategic planning, load forecasting, financial planning, trading, and regulatory affairs organizations. Decisions about current and future investments should then be made with this new analysis in mind.
Renewable companies should calculate appropriately the true costs of grid enhancements, capacity, and other important measures when submitting their plans to commissioners, investors, and other stakeholders.
Legislators and regulators should use the lessons learned from large scale integration of renewables in Germany and elsewhere in Europe to ensure a stable transition of renewables as part of the overall power portfolio while ensuring high reliability of power, stability of pricing to all users, as well as minimal value destruction to both utilities and renewable companies.
Finally, consumers must be made aware of the tradeoffs to a large portfolio of renewables and the necessary requirement for a smooth transition as part of the overall power portfolio.
In conclusion, the lessons learned in Europe prove that the large-scale integration of renewable power does not provide net savings to consumers, but rather a net increase in costs to consumers and other stakeholders. Moreover, when not properly assessed in advance, the rapid, large scale integration of renewables into the power system will ultimately lead to disequilibrium in power markets, as well as value destruction to renewable companies, utilities, and their respective investors. The U.S. has the opportunity to incorporate these lessons learned to ensure the sustainable growth of renewable energy over the long-term, for the benefit of all customers.
Felix ab Egg
FAA Financial Advisory (Finadvice), Adliswil, Switzerland
Author: Martuzzi, Marco; and Kriebel, David
Better health, better environment, better science: better use the precautionary principle.
Article 174 of the Amsterdam Treaty of the European Union says “Community policy on the environment […] shall be based on the precautionary principle”. European law, at its highest level, is explicit and uncompromising. As promotion and protection of human health is one of the key motivations of environmental preservation, the provision of the Treaty is good news for public health too. In fact the importance and relevance of the precautionary principle in the health domain has been attracting growing interest. Ministers of health, together with ministers of environment of the Member States in the World Health Organization (WHO) European Region (52 of them in 2004) declared: “We reaffirm the importance of the precautionary principle as. a risk management tool, and we therefore recommend that it should be applied […]”. These are only two of many acts or laws where the precautionary principle is referred to. So what is this principle and why is it important for public health as well as the environment?
Born in the environmental domain in the 1970s, the precautionary principle gained political profile in the 1980s and 1990s, and has attracted the attention of many involved in matters of environmental protection. Despite its resonance, there is no unanimously agreed definition of the principle. Quite simply, it is usually taken to state that lack of scientific certainty must not be used as a reason to ignore or postpone preventive or remedial action when there are other good reasons to do so, as has happened many times in the past. The prescription to err on the side of caution, the “better safe than sorry” approach, may seem little more than common sense. Indeed it is implied by the principles of clinical medicine, in particular by the principle of non-maleficence, more familiar to the public health profession. The concept of precaution is deeply rooted in the history of public health, and environmental health is no exception. Several established risk factors, such as air, water and soil contaminants, are known for their adverse effects on human health. The best strategy for dealing with these is prevention, and some prudence in, for example, setting protection standards, as when safe levels are divided by factors of 10 or more to allow for possible inaccuracy in risk estimates. But this is not the crucial area of application of the precautionary principle. Prevention applies to known causes; precaution, strictly speaking, is more relevant for uncertain determinants, complex scenarios, suspected risk factors, unpredictable circumstances.
Caution may be common sense, but such common sense seems to be badly needed, and in big supply, at times when we are faced with increasing complexity and uncertainty, when potential health threats can be far-reaching and irreversible; when technological development and societal organisation evolve fast enough to outpace, in numerous cases, the accumulation of data, knowledge .and evidence; when the adverse consequences of policies may be felt at great distances, or by future generations. In areas such as climate change, chemical safety, genetically modified organisms and nanotechnologies, to mention just a few, the potential for health damage is great. The deterioration or loss of life support systems, the persistence of ubiquitous endocrine-disrupting chemicals, the cross-breeding of genetically modified species, the introduction of nanoparticles in human tissues, for example, may be harmful to health through direct but also indirect effects; some of these effects can be difficult to detect and measure, but with serious consequences, perhaps borne by the most vulnerable, or elsewhere, or tomorrow. Pointing out that many of us live longer and better than never before is of limited relevance: we are highly uncertain of what scenarios we might be facing, and we do not know how likely different outcomes are; furthermore, we do not know what these outcomes might be at all. Often, we do not know what we do not know.
The precautionary principle, however, is not only about uncertainty, ignorance and caution, but also about policy and action. Applying precaution does not result in systematically rejecting new technologies or in a “zero tolerance” attitude. On the contrary, despite the lack of a universally accepted definition, several implications on how to exercise precaution while dealing with uncertainty emerge in several formulations of the precautionary principle and can be seen as its distinctive elements: (1) the principle suggests to adjust the balance of burden of proof from the need to prove that agents or technologies are harmful before they are removed or controlled (an onus usually borne by recipients) to the duty (for the proponents or beneficiaries) to demonstrate that they can be used safely; (2) it stresses the fundamental importance of participation, openness and transparency in decision making under uncertainty, recognising that participatory models of decision-making are an almost inevitable response to high uncertainty and complexity; (3) it recommends that, when faced with a possible threat, alternative courses of action should be considered and explored, preferably before arriving at the awkward evaluation of acceptable levels of risks, where one might have, for example, to assign monetary values to life and death. After all, the precautionary principle was born as the German Vorsorgeprinzip – that is, the “foresight” principle, a more positive concept than precaution, which emphasises a proactive, anticipatory, imaginative attitude according to which preventing or bypassing exposures and possible adverse effects is preferable to mitigating them or analysing whether they are worth the benefits.
What about scientific evidence? Science has a central role to play to achieve these goals, especially when used critically. Invoking the use of sound science to support decisions is ambiguous: “evidence-based” policy, meant to imply “evidence-determined” decisions, is not a realistic option in modem governance. The direct translation of evidence into wise decisions is, in fact, fraught with difficulties. First, defining and framing the policy question is a social process, not an expert task. Second, the same evidence can have different implications depending on the underlying ethical viewpoint, especially when a utilitarian framework clashes with a deontological one. Third, evidence on the problem may be solid and abundant, while evidence on the solutions (costs and acceptability of policies, for example) may be scant. Fourth, the expert-driven process of identifying optimal decisions in the light of available knowledge is vulnerable to manipulation by vested interests. And so on.
Rather than determining univocally the preferable course of action, available evidence and scientific reasoning must be part of the deliberative process, perhaps on par with the other interests and values at play. The literature on the precautionary principle has paid considerable attention to these questions. For a start, the assumptions and limitations of science must be realised and made explicit. For example, epidemiological enquiry following the Popperian scheme, of hypothesis generation and testing typically has high specificity and low sensitivity – that is, false positives are penalised more heavily than false negatives. As taught in textbooks, the recurrent snags of epidemiological studies, such as measurement error, exposure misclassification and many forms of bias, push risk estimates towards the null more often that the other way around; complex questions on broad health determinants are broken down into workable operational research goals – an often necessary reductionist strategy that makes it difficult to recompose the full picture. These intrinsic characteristics, per se, are not a good reason for rejecting the current scientific paradigm (in the Kuhnian sense), if only because a new paradigm has yet to be articulated. Nonetheless, enhanced methods are needed for knowing, describing and dealing with uncertainty. Innovative tools are desirable for more comprehensive risk assessment and comparison of alternatives, for studying upstream health determinants, multi-causality, complex systems. Thus, precaution requires more and better science. As precaution can also stimulate technological innovation and create new markets through the development and production of cleaner alternatives, the precautionary principle is best seen as an overarching concept, which “has relevance to the whole risk assessment, management and communication process”, as declared by European Ministers in the 4th Ministerial Conference on Environment and Health.
The debate on these themes is instructive, sometime controversial, but fascinating, and has been instrumental for reflecting critically about public health, its environmental determinants, the relevance of scientific evidence and its use in decision-making-generally speaking, about science and society. We hope that the debate continues and involves more people engaged in public health.
Occupational and Environmental Medicine, 2007;64:569-570. doi: 10.1136/oem.2006.030601
Dr Marco Martuzzi
WHO European Centre for Environment and Health, Rome Office, WHO Regional Office for Europe
The reactionary principle: inaction for public health
Martuzzi’s commentary on the precautionary principle is welcome and timely. I will make a few largely supportive comments while perhaps anticipating and addressing some concerns that readers may have.
The 1998 Wingspread consensus statement characterised the precautionary principle this way: “when an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically”. The statement went on to list four central components of the precautionary principle:
- taking preventive action in the face of uncertainty;
- shifting the burden of proof to the proponents of an activity;
- exploring a wide range of alternatives to possibly harmful actions; and
- increasing public participation in decision-making.
A skeptical reader may ask: isn’t this just a fancy new name for what any responsible public health scientist has always done?
On the contrary, precaution brings important new insights into occupational and environmental health policy and the science which informs it. To illustrate this, it may be useful to give a name to the policy framework in which occupational and environmental health research currently operates: it is the reactionary principle. Under this system, anyone is free to introduce a new hazard into the environment, and governments must wait until an overwhelming body of evidence is accumulated before intervening. Each new regulatory action is challenged with the objective of slowing down or stopping public oversight of production and distribution of chemicals and technologies. We can see reactionary principle inaction in the unconscionable delays in regulating a long list of hazards whose risks were clear long before effective actions were taken to control them: asbestos, benzene, dioxins and PCBs. While these are “old” hazards, a reactionary approach is evident as well in many current controversies in our field, including the potential health risks from: hexavalent chromium, artificial butter flavouring, and the antimicrobial agent triclosan.
The reactionary principle operates through these key components (referring back to the list for precaution may be useful):
- requiring incontrovertible evidence of harm for each hazard before taking preventive action;
- placing the burden on the public (or government agencies) to show that each chemical, material or technology is harmful;
- not considering potential health and environmental impacts when designing new materials and technologies; and
- discouraging public participation in decision-making about control of hazards and introduction of new technologies.
Perhaps framing the status quo this way helps the reader to see the kinds of changes in the science/policy interface which Martuzzi and others are advocating.
What can be done to shift from reaction to precaution? One important step would be to reduce. the corrupting influence of economic interests on; the evidentiary base of environmental health regulation. Recent evidence documents how some corporations seek to impede regulation through the intentional manufacturing of uncertainty about the hazardousness of their products. Clearly, removing conflicts of interest and intentional manipulation of data would make it easier to act in a more precautionary way. But there is more that we can do as responsible public health scientists. I will mention two examples.
Causal inference is a critical step in the recognition and control of hazards, and epidemiologists play an important role. We are taught to distinguish causation from correlation using guidelines like those of Bradford Hill. A precautionary approach would emphasise that this judgement is not purely scientific; our public health responsibility requires that we ask “when do we know enough to act as if something is causal?” This will depend not only on the strength of evidence but also on the availability of alternative ways of achieving the same social good (how essential are artificial butter flavour and antimicrobial socks?), and on the consequences of inaction or acting in error.
When we continue to study the same known hazards while thousands of widely dispersed chemicals remain without basic toxicology, we may inadvertently be promoting inaction by implying that more must be learned before action can be taken. To avoid this, environmental and occupational health scientists can learn from colleagues in climate science. There is now a (nearly) global consensus that human impact on climate is likely to have serious negative consequences. Climate scientists have managed to communicate an important yet complex message: much more needs to be learned about climate AND we know enough that we cannot remain silent about the need for action. These scientists have stepped out of their roles as data gatherers and analysts, and spoken publicly about the need for action.
While striving to do the best science possible, we should be aware of the potential impact of our research and of our social responsibility to do science that protects human health and the environment. The precautionary principle is useful in focusing attention on the need for this balance.
Occupational and Environmental Medicine, 2007;64:573. doi: 10.1136/oem.2006.031864
Dr David Kriebel
School of Health and Environment, University of Massachusetts, Lowell