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Resource Documents: Americas (4 items)


Unless indicated otherwise, documents presented here are not the product of nor are they necessarily endorsed by National Wind Watch. These resource documents are shared here 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. • The copyrights reside with the sources indicated. As part of its noncommercial effort to present the environmental, social, scientific, and economic issues of large-scale wind power development to a global audience seeking such information, National Wind Watch endeavors to observe “fair use” as provided for in section 107 of U.S. Copyright Law and similar “fair dealing” provisions of the copyright laws of other nations.

Date added:  January 22, 2021
Illinois, Indiana, Michigan, Minnesota, SitingPrint storyE-mail story

Farmers vs. lakers: Agriculture, amenity, and community in predicting opposition to United States wind energy development

Author:  Bessette, Douglas; and Mills, Sarah

Utility-scale wind energy is now the largest source of renewable electricity in the US. Wind energy’s continued growth remains contingent upon finding adequate resource potential and transmission capacity, along with communities willing to host turbines. While previous research on the social acceptance of wind has relied predominantly on case studies, resident surveys, and reviews of development practices and strategies, here we use a new method. We use a wind contention survey of energy professionals (n = 46) to assess the contention associated with 69 existing wind farms in four US Midwest states and identify underlying characteristics, i.e., agricultural, land-use, and demographic characteristics, that may have predisposed communities to either support or oppose wind farm development. We then use publicly available data to parameterize and model those characteristics using wind farm contention as our dependent variable. Our analysis shows that a greater proportion of production-oriented farming and fewer natural amenities in a community are associated with reduced opposition to wind farm development. Additionally, and perhaps counterintuitively, communities with a greater percentage of residents that voted Republican in the 2016 Presidential election demonstrate less opposition. Rather than negating the need for employing best practices in community engagement, stakeholder development, and participatory decision-making processes, this study can help prepare developers for the type of reception that might await them in potential host communities.

Douglas L. Bessette, Department of Community Sustainability, Michigan State University, East Lansing
Sarah B. Mills, Graham Sustainability Institute, University of Michigan, Ann Arbor

Energy Research & Social Science, Volume 72, February 2021, 101873
doi: 10.1016/j.erss.2020.101873

Download original document: “Farmers vs. lakers: Agriculture, amenity, and community in predicting opposition to United States wind energy development

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Date added:  December 8, 2020
Health, Iowa, NoisePrint storyE-mail story

Cardiologist investigation and response to industrial wind turbines in the rural residential countryside regarding concerns of adverse health effects

Author:  Johnson, Ben

Executive Summary

While ongoing for decades, more recently recorded consecutive years of rising oceans and mean global temperatures with increasing patterns of intensifying storms and fires have only heightened Man’s resolve to fundamentally change worldwide dependence on fossil fuels. We are now responding with a sense of urgency. “Renewable” energies, particularly wind and solar, among other renewable sources, have been promoted as “winning solutions”. Photovoltaic (solar) energy has become more affordable and is utilized more in sunnier locales. Commercially, beginning in northern Europe, Industrial wind turbines have, over three decades, spread rapidly across the globe. With increases in size to achieve increased power generation capacity, they appeared in the U.S. initially as a novelty but have been rapidly proliferated without a “proper introduction”. Seemingly simple and intuitively harmless in design and implementation, when placed too close to human habitation, serious problems have occurred. It is as though we “leaped before we looked”.

I am a Cardiologist who specialized in heart rhythm problems and I am providing a personal statement primarily focused on the adverse health effects (AHEs) arising from industrial wind turbines (IWTs).

A bit of history ties my interest to this concern

Over two years ago, the “legitimacy” of industrial wind turbines as a source of SAFE and sustainable electricity was suddenly thrust into my life. This appeared as a “benign letter” from a local energy provider. Proposed, was a 52-turbine farm to be erected close to my property… a place protected by a conservation easement for having a few remnant prairie hillsides. In the surrounding miles, grazing and row-crop agriculture was the focused livelihood. These communities are the definition of an extremely quiet “rural residential” landscape. I knew almost nothing about wind turbines and, like nearly everyone, thought they were quiet, good for the world and assumed they were safe. In the ensuing weeks, public meetings were held where interested citizens had a chance to voice their opinions and concerns. Despite very time-limited presentations, it became obvious that opinions had rapidly polarized, shifting the debate from county vs an outside faceless large corporation to neighbor vs neighbor. Mid-American Energy (MAE), the Wind contractor, was there to answer questions but provided no hand-outs nor substantial didactic information. They sat in a group being largely silent, they only returned brief, limited answers when questioned. There was an industry physician-consultant from Boston who presented his opinions but no facts or data, and directly dismissed that noise related complaints were “real”. Instead, (he implied) that those complaints were mostly imaginary physical or mental consequences from the presence of the IWTs. Any reasonable person present walked away after the meetings having no idea what health ramifications from IWTs might occur. The word “obfuscation” (the action of making something obscure, unclear or unintelligible) appeared in my mind.

Wind Energy’s position about adverse health effects

In these initial Board of Adjustment, and then later Board of Health meetings, Wind Energy maintained their “position”:

1) that Industrial Wind Turbines are safe – yet without qualifications of how that self-designation of “SAFE” was given” – no studies, records and evaluations of structure failures, etc. They almost always follow the “safe statement” with boasting of the number of IWTs they have placed in Iowa and the revenue to the state, jobs created, and on and on, but never have provided evidence that scientifically proves “they are safe”. Wind energy has limited “original” investigative research. Often a panel judges whether existing data supports the assertions by scientists that IWTs do cause AHEs. The subsequent peer review become akin to judging “opinions with opinions”. Importantly, “indirect” impacts, which Wind Energy routinely ignores, are just as significant to the people who are impacted as are “direct” impacts. In fact, there is an enormous amount of data linking IWTs noise emissions to direct and indirect AHEs. Thorough and objective reviews of Wind energy’s claims have been challenged and previously “debunked” (Punch and James, 2016). When challenging Wind Energy’s representatives with the assertion that “industrial wind turbines have never been proven or shown to be safe”, the don’t respond – almost as a “taught response”. Yet, after a Board of Health meeting, even one of the “pro-wind” Iowa Environmental Council academic speakers did agree with me that IWTs have not been proven to be safe.

2) that they (MAE) receive very few complaints… eventually they resolve. They contend that the “nocebo effect” accounts for most resident complaints. In this context, the nocebo effect is the association of symptoms and complaints “brought-on” by existing negative attitudes toward IWTs.

3) that there is no credible evidence that IWTs cause cardiovascular disease or metabolic disease.

4) that they reluctantly admit that some of “their studies” show that IWTs cause “annoyance” but reflect that it has no substantial health impact. Wind Energy, never comments about IWT-associated “severe annoyance” that causes resident evacuations of their home (which is also considered an adverse health effect).

5) that they will not admit that IWT noise causes sleep disruption. Strongly connected to this is their assertion that infrasound and low-frequency noise (ILFN) as a product of IWTs, accounts for a small part of the IWT noise and that infrasound cannot be heard and therefore cannot cause harm. Indeed, they firmly contend that ILFN is of no concern and strongly insist it should not be regulated.

I have carefully reviewed Wind Energy’s position on all these adverse health effects. I have searched for definitions, textbooks, articles, and the presence and quality of reported peer-review. When defending their assertion that IWTs are safe, Wind Energy speaks both slowly, and definitively then “hides” behind the spoken words “no credible evidence”. A reasonable person would ask “What would Wind Energy consider as credible evidence” and, as a concerned resident, what “credible evidence” have you produced that proves that IWTs are safe?

Purpose of this manual

In this manual, I have collected information – first for myself – to clarify and resolve my questions and concerns. As the answers became evident (though admittedly difficult to find, clarify and integrate), the story of how this “intrusion” happened became clear and I share it with you. This manual will hopefully later serve as a resource for all who will question what health risks (as known in 2020) may be associated with living close to industrial wind turbines. This information took several years to collect. The process by which Wind Industry acquires county permitting is “rushed through” in literally only several weeks making this information, given that inconsiderate timeline, virtually unobtainable.

In this manual, I present evidence supporting my opinion that Industrial Wind Turbines (IWTs) will cause adverse health effects when located near residential properties in formerly quiet rural residential communities. Beyond the potential serious health implications… we all need to fully understand and reflect carefully on the full implication of what these behemoth oscillating blades mounted high on towers will do to our personal and social and environmental communities.

I present relevant aspects of IWT-generated noise – including noise classification and its quantitative labeling through frequency and decibels measures and types of weighting through various filter types and how accurate noise exposure quantification is affected by filtering choices. The unique characteristics of IWT noise are reviewed and compared with other environmental noises. I will review the categories of noise frequencies across the entire range of emission of IWTs and important aspects of noise propagation and attenuation. Please view the table of contents for contained subjects; ALL of these subjects are relevant. The reader must NOT stop at the simple debate of “he said vs she said” about health impacts. I found the answers largely in what “wasn’t said” and past “acoustical history” and current corporate behavior.

I will highlight important historical events that add to the context of today’s IWT regulation. For example, we need to be fully aware that VERY in-depth evaluations were done in the mid-1980s by NASA and the Dept of Energy-funded research. Scientists (N.D. Kelley, et. al.), in their thorough (basic science-level) investigations, were asked to evaluate the potential possible implementation of IWTs for adverse impacts. Their focus was on understanding the physics of wind turbine operation and energy production. They also studied noise types produced by IWTs and observed and reported on the first confirmed cases of adverse health effects that developed with IWT prototypes up to 4 MW in generating capacity. Their initial determinations of ILFN and associated serious AHEs were first raised then and remain relevant to this day, although ignored by Wind Energy and its proponents. Also revealing is the history of acoustical evaluation of health-impacted occupants of some newly erected buildings from the 1970s to 1990s that was characterized as “sick-building syndrome”. Recognized in affected subjects, were similar symptoms connected to working near gas-fired turbines. Careful evaluations confirmed that ILFN from indoor HVAC (heating/cooling units) produced the symptoms. Fortunately, buildings can be re-designed, defects in air ducts fixed, and additional sound insulation placed, but the only way to eliminate ILFN from IWTs is to turn them off or distance them from residents and their property far enough away that the ILFN can no longer be heard nor “perceived”.

There are other issues besides adverse health effects

It is important to ask questions and demand that they be answered; DO NOT assume that what Wind Energy is telling you is correct. Questions, such as “where did these setbacks come from? How, based on what we know, can we have setback distances that are so close and still be considered ‘safe’? Whose responsibility is it to review these setbacks and decide if they are safe? How did Wind Energy’s proclamation that ILFN ‘is not a health concern’ ever become “accepted?” Why is potentially harmful noise pollution allowed to trespass across the private land of non-participating neighbors – particularly when pollution regulation for other industries occurs up to/at the property line?” I still ask whether the MAE’s land easements (for the entire host property) and the value of that land is used as collateral for the financing of the purchase and erection of the wind farms? If it is, what happens to that land ownership in the event that America comes to: 1) reject the denial of Wind Energy’s adverse health consequences, and also 2) see that Wind Energy is not “green” and requires concomitant availability of back-up natural gas-burning that essentially negates any “renewable” aspects and 3) realize that the real cost of that electricity is roughly 3 times the cost of conventional electric power/kw of energy produced once the subsidies are factored out. Shouldn’t we be building energy power plants that work nearly all the time (instead only one-third) and have a productive life of at least 40-50 years and 4) understand the extraordinary expense not only to maintain a functioning turbine but also related to eventual turbine/site decommissioning and non-recyclable blade disposal costs.

Where does all that money come from? Fifty-eight-year leases are a long time – generations come and go, political party majorities and Presential decrees that control the narratives keep flipping and MUCH better power production sources will become available. We need to think more about this before “leaping further.”

I include in “Part 9” important findings while searching for an explanation of why inflicting harm on people living in host communities is “acceptable”. To understand why things don’t make sense you often have to explore the motives of – (in this case, including, but not limited to) Wind Energy. Beyond the motives, are the real actions and developed agendas that allow an industry to secure, maintain and perpetuate “their narrative.” I have included several examples of what some would call “blatant” deception. For example, there is a formal presentation made by a Danish healthcare practitioner (Dr. Johansson) to Vestas’ executives where “the truth was told” but his warnings were ignored. I will leave the reader to draw his own conclusions. Sadly, the whole process continues largely unchanged. Wind Energy apparently deems their current approach as a successful business plan and continues their practices largely unchanged. We, as the users who consume electricity, have a right to know the truth behind the industry’s talking points.

It would be unfair to criticize wind energy production as an answer to global warming without offering other solutions. That said, one might assume that if an obvious better choice was available without all the problems and negative health impacts as I have reviewed, it would’ve been pursued. However, there are alternatives that are ignored. My comments are listed in part 10, “Carbon Management”.

Stay focused on the “broad” definition of health

When the public or politicians are asked if wind turbines are dangerous or cause health problems, they sometimes “mentally imagine” the worst – post-apocalyptic or post-wartime images or even human suffering with death and hospitalization of the order we now see with the Covid-19 pandemic. Even “captured” politicians, proponents, and/or Wind Energy trade organizations couldn’t sell that when subjected to any scientific scrutiny. Instead, we need to remain “broad-minded” to what health actually is – which is NOT limited to a defined set of continuously disabling symptoms that evolve in everyone over the short term and likely affects everyone the same. It is also not limited to a health effect that is progressive until death develops or when eventual disease syndromes become established with an established diagnosis. Adverse health consequences of environmental noise can be the asymptomatic (unrecognized) development of hypertension or vascular atherosclerosis or insulin resistance or can be much simply defined as the “the loss of wellbeing”. Indeed, some of the most common and impactful adverse health effects may come “as” headaches, tinnitus, dizziness, subtle confusion, unexplained loss of ambition or productivity, emotional lability or obvious or subtle depressive symptoms. Noise adverse health effects may initiate and accelerate disease progression, that may, when combined with genetic or known “accelerators” of disease (smoking, alcohol abuse, etc.) over a life-time, manifest as a recognized cardiovascular disease event – stroke, fatal or nor-fatal heart attacks.

The World Health Organization (WHO) defines “health” as a state of complete physical, mental and social wellbeing… The WHO definition links health explicitly with wellbeing and conceptualizes health as a human right requiring physical and social resources to achieve and maintain. Mental and physical health are inextricably connected, thus highlighting that “annoyance” – at almost any level – can contribute to adverse health effects (AHEs). As described by DeFrock (Australian), “Annoyance is a non-quantitative word that implies mildness in common use. A more accurate general descriptor would be mild, serious or ‘intolerable’ impacts.” In the context of this report, “annoyance” generally means “High Annoyance” where it can result in indirect adverse health impacts. But even “mild” annoyance can create a negative or disagreeable reaction (which is NOT the nocebo effect) that can create a loss of wellbeing. Wellbeing refers to a positive rather than neutral state, framing health as a positive aspiration. Wellbeing is defined as “the state of being comfortable, healthy or happy”. Shouldn’t we protect an individual right to health and happiness – that defines wellbeing – by limiting intrusive noise pollution at one’s private property line?

Cardiovascular disease explained (simplified)

In the Cardiology world, “atherosclerosis” is a term describing the development of (lipid (fats)-filled plaques) that get sequestered within the superficial inner layer of arteries that is contained by a “thin fibrous cap”. These are initiated and develop through a complex process simply characterized as “inflammation”. Standard cardiac “risk factors, e.g. smoking, diabetes and others) facilitate atherosclerosis development. As plaque evolves, there is a complex action via cellular and neurohumoral processes that appear to be quite similar to those seen originating from other triggering sources. Some of those sources include small-sized air pollution particulates, PTSD, and of particular importance, environmental noise. In my medical practice I treat atrial fibrillation. Nearly half of those patients also have obstructive sleep apnea (OSA) which is thought to have significant adverse inflammatory triggering that may promote concomitant ischemic heart disease, hypertension and insulin resistance. Although likely less intense as a “stressor” than OSA, I believe IWTs act similarly through a stress related inflammatory pathway to promote cardiovascular disease.

With noise as the trigger, it is thought cardiovascular disease is promoted from “from an increased physiologic stress response” from noise levels “in excess of defined intensities”. It appears there are noise thresholds (which the WHO has attempted to define). Similar to OSA, it may also occur indirectly through noise-associated sleep disturbance which then produces a “stress response” via the sympathetic limb (“fight or flight”) of the autonomic nervous system. The autonomic nervous system can trigger vessel inflammation which then can promote atherosclerosis. In general, the more and longer the stress continues, the older the individual (with more time to develop larger and more “unstable” plaques), the more the likelihood that disease will become evident or “expressed”. With often unpredictable sudden “stress response triggers and/or anatomical plaque instability,” the plaque ruptures, exposing the lipid-rich core that initiates “local clotting” that may enlarge and propagate causing potential artery closure that quickly produces a state of deprived “down-stream” oxygen delivery. In the heart, when this happens, it causes a heart attack – termed “myocardial infarction”. Health means living a life where such consequences become less likely through avoiding or mitigating “unconscious inflammatory bodily responses” that promote the genesis of disease states. Atherosclerosis development should never, minimally, suddenly or eventually be allowed to continue so as to produce cardiovascular disease “endpoints”.

World Health Organization comments on wind turbines (2018 report)

Acceptable environmental noise exposure levels are defined in the Oct. 2018 WHO report for aircraft, rail, general industry, and road traffic sources, with “strong recommendations”. That rating reflects the quality and the amount of the scientific data relevant to those studied noise sources. Also, in that publication – for the first time – a suggested “conditional” exposure level for wind turbine noise exposure being expressed as “Lden” was published. Lden means average sound Level: day, evening, and night of AUDIBLE noise as “averaged” over a 24-hour period with penalties of 5 dBA for evening periods, and 10 dBA for nighttime periods. It is measured using an sound meter set to use the “dBA” filter and weighted by time of day for the penalties. That filter is the most common one promoted by Wind Energy in turbine acoustics and is “centered” around 1000 hertz. The problem with this is that it does not accurately reflect the acoustic energy of ILFN. The conditional wind turbine noise level exposure was a limit of 45 dBA Lden, equal to that of aircraft noise but substantially lower (more restrictive) than railway or road traffic. Assuming wind turbines operate 24 hours a day this limit is equivalent to a 38 dBA Leq 24-hour average sound level. The data review committee of the WHO document recommended “policymakers implement suitable measures to reduce exposure from wind turbines in that population exposure to levels above the guideline values”. The “conditional” recommendation reflected that the data was not “robust enough (statistically, due to small numbers of subjects)” to support a “strong” recommendation. Importantly, they commented that there was no data suggesting that there was no risk. It is worth noting that the WHO’s 38 dBA Leq 24 hour average is what would be calculated using the American National Standards Institute (ANSI) and Acoustical Society of America (ASA) Standard S12.9 Part 4 for assessing Land Use Compatibility. It is important to consider that the pre-specified health outcome evidence used was mostly limited to more serious adverse health consequences such as ischemic heart disease (atherosclerotic- disease related), hypertension (elevated sympathetic tone and acquired loss of normal vessel relaxation related) as well as the prevalence of highly-annoyed populations (outdoors). Because wind turbine sound fluctuates as much as 11 dBA above the average this level would not eliminate stress from moderate annoyance or sleep disturbance.

I have also included “noise response curves” for severe annoyance in the appendix of part 6 (Adverse Health Effects) from the Wind Farm Noise Textbook (Hansen, Doolan, Hansen, 2017) that show published data (2001, 2008, 2016) from several studies. These two graphs IMPORTANTLY reflect an even greater annoyance from IWTs (which is dominated by low frequency noise) than what is reflected by dBA measurements (measuring only audible noise) as was used in the WHO report. This highlights that IWT noise is commonly described as “distinctly annoying” and is composed of noise from nearly all portions of the noise spectrum, rumble, roar and whoosh type sound. Indeed, the omnipresent component of ILFN is a real and prominent contributor to increased annoyance from IWT noise. IWT noise can be even heard when below background noises like leaf rustle, comprised of mainly mid and high frequency sound in communities at night likely due our perception of that low frequency noise component. Annoyance derived across the “wide-range” of frequency components of IWT noise NEEDS be accounted for when enacting “protective wind ordinances.”

It is remarkable (to my knowledge) that Wind Energy has not commented on these incredibly high-level scientific assessments of potential concerns of environmental noise. The WHO virtually echoes that IWTs have never been shown to be safe. The WHO also clearly moves toward the level of declaration I make in this manual: that IWTs have AHEs including possibly serious cardiovascular effects. In fact, there is strong credible evidence that IWTs produce serious AHEs.

I would suggest separate regulatory noise limits for both audible and ILFN noise exposures with both 40 dBA (for audible) and 60 dBC (for ILFN) noise limits – each expressed as “shall-not-exceed” dBA or dBC (Lmax(fast)). Compliance with these limits shall be measured by Class 1 sound level meters set to use the “fast” measurement circuits. Other circuits incorporate averaging which will understate the fluctuating character of wind turbines that is the likely cause of annoyance, sleep disturbance, and other AHEs. Despite that MAE would like to suggest otherwise, dBC measuring tools are “standard” on professional grade sound measuring equipment which can measure both at the same time. Noise levels can be easily obtained at the property line. Prior regulatory parameters of setback distances (e.g. 1500 feet) or 45 to 50 dBA as Leq averaged sound levels) will NOT be protective of human adverse health effects. They do NOT account for fluctuating audible and ILFN acoustic energy – that have been correlated to AHEs, or the location of non-participating residences on their properties. When any wind contractor sites a turbine, they should include a design safety factor to be certain that during periods of fluctuating sound emissions the project will not exceed either of those noise limits or it will be “out of compliance”. If they are uncertain about audible and ILFN propagation/attenuation or the accuracy of computer modeling, then a greater distance-separation or use of a quieter wind turbine make and model should be used so as to completely eliminate the potential of harming residents”. Sound limits are carefully defined to protect residents and should not reflect a compromise to facilitate industrial development. Non-compliance or less restrictive noise limits that result in resident harm is NOT acceptable as reasonable “collateral damage”. Of note, George Hessler published a 2004 article that proposed dBC criteria in residential communities for low-frequency noise emissions from industrial sources that do not have fluctuating sound as a primary characteristic.

What are the noises that IWTs make?

IWT noise includes regular, dominant “pulsing” sensations perceived as either audible fluctuations in the sound or as bodily “pressures” due to air compression of the flowing air mass. These pressure waves are caused by changes in the lift of each of the 3 blades as they pass in front of the huge supporting tower. Also, as the blades rotate through the frequently vertically-stratified moving air mass, they may, under heavy “loading” conditions, lose lift (or stall) producing perceptible rhythmic swishing/thumping sound to which residents can become sensitized. Residents can often perceive these fluctuations as “whooshes” or “thumps” at considerable distances, well over a half mile – which is quite disagreeable and difficult to block from one’s awareness and may occur at a distance where the IWT cannot yet be seen, especially during the night when people are sleeping in quiet bedrooms. There is a rhythmic pulsation generated at the trailing-edge blade noise by the steady rotation speed that produces “blade-swish whooshes and thumps” and irregular, low-frequency “roar” from the blades due to in-flow turbulence. Collectively, there is a continuum of frequencies stretching from pressure pulsations at infrasonic frequencies 0.5 Hz (cycles per second) up through the normal hearing range of 1000 to 2000 Hz that are generated by each turbine. The sound immissions from each wind turbine also interact with nearby turbines to produce a constantly changing and distracting medley of fluctuating sound- called amplitude modulation. Depending on the frequency amplitude modulation of IWTs, ILFN is both heard and perceived and easily evokes mental and physical stress. Unlike “less complex” daily noises, IWT noise does not become “accepted” by our perception processes and then unconsciously ignored. The subtle but constant changes make it difficult to impossible to ignore. Further, residential construction of residential homes for sound insulation does not effectively block the lower frequency noises. Further, people have a right to sleep with open windows which effectively eliminate any protection offered by walls and roofs. Trying to mask IWT noise by producing bland artificial “background” noise inside a home can only mitigate some portions – but not all of “stress-creating” wind turbine noise. As coping residents engage in their daily tasks, while the turbines operate above, only a momentary lapse of that focus will remind them of the enveloping dome that separates them from the peaceful world they once enjoyed.

Included important historical insights into wind energy claims

I have included in Part 9 a number of related events, letters and a copy of a speech that unveil what Wind Energy (Vestas – largest worldwide producer of IWTs) has done to advance their “narrative” centered around the promotion of IWTs.

When the state of New South Wales (NSW) in southeastern Australia approached Vestas about implementing IWT power, the state government presented to Vestas an initial draft of guidelines that contained low frequency noise regulation that outlined that state’s proposed future “recognition, acceptance and treatment” of ILFN. In the beginning of that March, 2012 letter, Vestas in their “Executive Summary” response letter, immediately made clear their opinions about careful, science-based, health-protective regulations that would govern implementation of a new energy technology in NSW. They bluntly summarized: “Vestas opposes the Draft Guidelines, primarily because of the sheer number of additional requirements and barriers that would be placed in front of the wind energy industry without any clear evidence, justification or demonstrated need for this additional regulation”. By that time (2012), there had been several years of rigorous publications by scientific investigators and acousticians as well as likely thousands of reports of adverse effects including forced home evacuations. In general, NSW concerns were raised that mostly involved human health – in all forms. These included setbacks (proposed at 2 km), visual amenity, noise, health, decommissioning, auditing and compliance, environmental impact statements, property values, blade throw, conditions of consent and compliance as well as others. Vestas’ extraordinarily self-serving retorts to each of these concerns were “abrupt and terse” (and without basis) – other than they are viewed as too restrictive to advance IWT introduction – which they admit was the primary issue. Comments about noise from NSW in the draft were recommended to “be deleted in their entirety” so as “not to give the impression that the NSW Government places any credibility in the false claims of the anti-wind activist groups on the topic of health impacts”. Decommissioning concerns were raised by NSW. Vestas did support a decommissioning and rehabilitation plan in the environmental assessment report, however, did not support the requirement to provide a decommissioning bond, nor have periodic updates in anticipated costs and implied that wind farm operators would maintain their assets for as long as possible since wind is “free.” Vestas did not support the adoption of the noise guidelines as they claimed they were: unnecessary, discriminatory, and unclear. Again, the word “obfuscation” comes to mind. It should remain absolutely clear to any entity regulating IWTs into their jurisdiction that all these topics (and more) raised here ARE relevant and need to be addressed in writing in any Wind Ordinance; if it is not clarified, then compliance cannot be enforced.

ILFN: convenient flip-flopping by wind energy for their agendas

Further, to have health protective IWT noise regulation, as noted many times, recognition and regulation of ILFN is “critical”. It is also my opinion when reviewing several “lines of historical action and commentary by Wind Energy” that Wind Energy recognized (certainly no later than the mid-1990s) the “threat” of ILFN to their business. As mentioned earlier, N.D. Kelley clearly identified the existence and the health threat from ILFN in the mid-1980s. In the same letter (above) and then in another one just a year before, Vestas reveals that they knew “true implications of ILFN and its health concerns”. In the response to NSW suggested guidelines, Vestas denied that ILFN was a cause of AHEs and proclaimed: 1) it is therefore unnecessary to require the prediction and monitoring of low frequency noise emission from wind turbines, 2) the existing and well- validated industry standard models for acoustic propagation are not designed to deal with frequencies at the low end of the audible spectrum, specifically because noise emissions in this band are not considered to pose issues likely to affect the surrounding environment, 3) “accordingly” Vestas suggests the removal of the requirements to measure low frequency noise from the Draft Guidelines. Yet, less than a year earlier, Vestas AU had written a letter to the Danish EPA claiming that a new low frequency noise limit for wind turbines could not be met because there were no design changes to modern utility scale wind turbines that could further reduce wind turbine noise to meet the new low frequency limits. On the one hand they claim there is no problem, and on the other hand they claim that there is no solution to a problem that they admit is a characteristic of wind turbines. (My comment: There is something rotten in Denmark). It is clear to me that Vestas recognized that ILFN would be a defining concern for IWTs – particularly as power generating capacity increased (which Vestas was rapidly designing and implementing for future designs). The newer larger MW models use longer the blades and slower hub rpm. This results in more ILFN than for earlier lower MW models with shorter blades and faster rotation speeds. The Wind Industry has adopted Vestas’ stance about ILFN importance. We, as the potential residents to be affected and possibly suffer harm, need to clarify for ourselves the true existence of and potential harm from ILFN and react responsibly by regulating these harmful emissions generated by IWTs – especially with increasingly larger models that are more often being “clumped” together.

The need for informed consent when known unknown risks exist

The proposed affected residents, by a super-majority, opposes the plan (for Arbor Hills Wind Facility, Madison County) based on concerns of adverse health risks. At the same time, only a small-minority of easement owners (22%) actually live on the property and would have to endure the same health consequences. Reportedly they are not allowed, by contract, to raise health-related concerns that might arise while residing at the property. How this affects people living on that property to farm the land is not known. Having spoken to residents about their “signing experience” with a wind industry, they didn’t recall that the representative declared the turbines “safe”. They did, however, clearly remember that there was no listing or mentioning of possible adverse events, reports of serious or mild annoyance nor potential longer-term cardiovascular consequences. This failure to disclose potential risks to the participating landowner OR the non-participating (but still noise-affected neighboring resident) is bothersome and reflects a lack of due-diligence, oversight, and protective jurisprudence. With decades of ongoing concern and innumerable science-supported reports of occurring harm and well-researched plausible serious adverse health effects being published, one could reasonably describe the omission of informed consent as a failure of duty of the party seeking the easement to properly notify the lease of known risks. (Writer comment: While I not an attorney, very similar scenarios occur in human research where volunteers are asked to participate in a “condition” where there are unknown (or let alone known) potential health risks in return for financial compensation. To a reasonable person, such easement contracts demand greater transparency and much higher levels of subject protection. While it is true that Wind Industry contractors are not involved in a “medical study” per se, they are entering into a contract with potential known and unknown health consequences for which a consideration of payment is given in exchange for accepting the potential harmful consequences of exposure to that added risk, (IWT noise emissions).

This “manual” is to promote a clearer and accurate description of industrial wind turbines

I have written this personal statement for myself to collect, consider and organize the mass of information and misinformation present on IWTS. I personally have known the feelings of surprise, bewilderment, confusion, and hopeless frustration upon learning that a large industrial complex could be permitted into quiet rural residential locales that is zoned for agriculture. At county meetings where citizens voiced their concerns “on both sides” of the argument, there were some that mentioned it was their “right” to be able to earn income from the leasing of their property. Of those relatively few, there was no one that I can recall that said that it was acceptable that wind turbines could then produce noise that would actually harm their neighbors. None mentioned that their neighbors also have a “right” to enjoy the peaceful use of their properties. The authors of a comprehensive textbook “Wind Farm Noise” distilled all the conflicting pro- or anti-wind rhetoric in a simple declaration: “it is time to stop debating whether or not a problem exists. It is well known that wind farm noise does result in sleep disturbance and health effects for some people and the time has come to decide what to do about it. The fact remains that some people are so affected by wind farm noise that their health suffers and some are forced to leave their home in order to achieve an acceptable quality of life.” We need to respect each other and look for energy solutions that make sense and most residents agree about. I have desperately sought for the truth as minimal information or, (upon fact-checking), frequently incorrect information was given by a power company who planned to produce a “secure profit”. I hope this “true” version of truth is useful to those who need to make important decisions, protect themselves and their property and assist for clarification of concepts regarding Industrial wind turbine implementation and regulation. When finally understood in “all in its convoluted and conflicting enormity”, it will hopefully be clear where the real questions remain.

Points to remember: Returning to my initial assumptions upon hearing that IWTs might be placed closely to my property, I mentioned that “I thought they were quiet, good for the world and assumed they were safe”. Exploring much further, I now know that NONE of those are true. IWTs make a lot of distressing noise, when examined as a “possible solution for climate change” they don’t make sense given cost, limited life, intermittency, dependence on CO2-producing energy back-up and affordable and adequate battery technology is possibly “beyond reach” and, they are clearly NOT safe for myriad number of reasons which I tried to describe in detail. IWTs cause adverse health effects with that definition being consistent with WHO definitions and currently practiced health care. We are now in an era in science where we know that environmental factors – particular noise – can and does cause adverse health effects which can include serious cardiovascular consequences. Advances in understanding the consequences of disturbed sleep raise concern for contributing to the development of Alzheimer’s disease. Shortened sleep duration has been highly correlated with cardiovascular disease development and endpoints of hypertension and ischemic heart disease.

We know the brain while “sleeping” can still be “aware” of noise (when it reaches a certain intensity (loudness) threshold and responds to it through body motility, even full awakening or “regressing” in its process of reaching various stages where vital restorative recovery of normal brain function occurs. Sleep disruption occurs with audible and, likely more importantly with IWTs, with lower frequency noise. The WHO has recently listed wind turbines as a potentially important source of environmental noise. While “high-level correlative data” does not exist yet, the WHO lists noise thresholds for potential disease development at levels lower than road traffic. Other analyses using severe annoyance metrics that include ILFN exposure drive the threshold noise levels much lower yet. Observing current, more inclusive definitions of health, IWTS do produce AHEs as annoyance (from mild to severe), and have been shown to disrupt normal sleep stage progression.

Utilizing metrics of biologic plausibility, as described by Sir Austin Bradford Hill, if met, can establish a “causal link” between WTN and AHEs for epidemiological purposes. As examined by Jerry Punch and Rick James in their 2016 comprehensive review (ref. in text), all 9 of The Bradford Hill criteria have been identified in the scientific literature as pertinent to the relationship between IWT noise and AHEs. Dr. Hill states, “None of my nine viewpoints can bring indisputable evidence for or against the cause-and-effect hypothesis and none can be required as a sine qua non. What they can do, with greater or less strength, is to help us to make up our minds on the fundamental question – is there any other way of explaining the set of facts before us, is there any other answer equally, or more likely than cause and effect?” In his final address observation, he asserts: “All scientific work is incomplete – whether it be observational or experimental. All scientific work is liable to be upset or modified by advancing knowledge. That does not confer upon us a freedom to ignore the knowledge we already have, or to postpone the action that it appears to demand at a given time.”

Finally, included at the end of part #15, Mathias Basner, MD, PhD – who is considered a world leader on health effects from environmental noise, produced an editorial (2019) where he reviewed the potential impacts of noise on our health. He acknowledged the problem of smaller populations in currently available studies which make statistical powering of conclusion difficult. He has stressed that NONE of the wind noise guidelines data from the 2018 WHO report found an “absence of risk”. He finished his comments with “the fact that more studies are needed should not lead us to postpone the urgently needed protection of the population from noise.” The knowledge we have acquired so far IS SUFFICIENT to take preventive actions and substantiate them with respective legal noise regulation.

We have all learned that all people suffer to some extent– it is part of being human. But to intentionally force suffering upon affected citizens for the financial benefit of others is immoral. To “mentally take refuge away from guilt” by assuming huge “pinwheels spinning in a neighbor’s field are silent” and believing Wind Energy’s mantra of ‘no credible evidence’ that IWTs cause human harm is patently disrespectful, unprofessional, immoral, and grossly irresponsible. We can and must do better.

Needed declarations

1) I am a Cardiologist who specializes in heart arrhythmias (Electrophysiologist) who focuses on abnormal fast and slow heart rates/patterns, implantable device (pacemakers, defibrillators) therapy, and have participated (investigated, published and presented) clinical research for decades. I also have been privileged to be involved with human research and served as the Chairman of the City-Wide Investigative Review Board overseeing the ethical conduct of ongoing local clinical trials. In those patient trials, high standards of participant protection and adverse event evaluation was paramount. I am drawn to understand the societal (local and international) impacts of IWTs – particularly health. I also felt compelled, through my years of human research experience, to protect the health, safety and welfare of myself and my fellow citizens.

2) I am not an Acoustician. An Acoustician is defined as an expert in the branch of physics concerned with the properties of sound. I have, however, corresponded at length with several Acousticians who have “specialized” their acoustical practice into the understanding, measurement and regulation of industrial wind turbine noise. They have shared with me their acquired in-depth understanding of IWT noise and its impact on people – from the details of measuring and interpreting noise to the impacts of that noise on people’s lives. They have directly talked and worked with the victims of IWT noise exposure. They have been invited into these unfortunate people’s homes and first-hand have measured, experienced and, on several occasions, have themselves suffered serious adverse health events from those noise exposures. They, through their professional lives, have seen the unfolding of IWT introduction around the world, interacted with key both pro- and anti-wind experts, and from their unique vantage point, provided a clearer understanding of the “real issues” and the history behind those issues. They have presented at national societal meetings, offered insightful theories and clarifications to their worldwide colleagues, published peer reviewed papers, testified in court trials, and at the request of governments. They are members of the Institute of Noise Control Engineering (INCE) and/or the Acoustical Society of America (ASA). The INCE/ASA Member has experience in noise impact assessment, the effects of noise on people, and control (complaints, annoyance, noise specifications) and is committed to their Canon of Ethics for unbiased professional services whose first mission is to protect the public’s health and welfare. They are motivated to move forward into the “headwinds of greed and misinformation” because as professional experts, “they care about people”.

3) The origins of the information I have presented and summarized, I believe to be reliable, verifiable and accurate. I, in no way, have manufactured history, slandered nor created (recently popularized) “alternative facts”. I have expressed personal opinions based on collected information that I believe to be factual. My “physician opinions” come from four decades of interviewing, examining patients and applying basic human physiology and medical science in the effort to protect and improve their lives. I have read and re-read reviews and individual papers from both sides of the argument. In the enormous “confusion” of pro- and anti- Wind information, I have tried to focus on the quality of data being mindful of bias and full disclosure of and composition of reported “peer review” entities. I have looked specifically for the origins of noise regulation and the process by which current IWT siting practices became established.

W. Ben Johnson, M.D.
December 7, 2020

Table of Contents
Introductory Letter to Board of Zoning (Part 1)
Manual Design and Suggestions for Use
Part 2: Sleep
I Have Seen the “Face” of Industrial Wind Turbine (IWT) Harm
Disturbed Sleep – A Worsening Modern Health Epidemic Recent “Key” Medical
Studies Linking Inadequate Sleep to Cardiovascular Events
A YouTube Documentary Worth Seeing
Disturbed Sleep from IWT Noise Emissions
Appendix: 2009 WHO Summary of Sleep Effects and Noise Thresholds
Part 3: Wind – Basics
Sound Spectrum Defined by Frequency
Sound Measurement and Filtering
Shadow Flicker
Source of IWT Noise
Primer on Sound
Amplitude Modulation
Variable Noise Related to Blade Angle
Wind Turbine Noise is Distinctly Annoying
“Worst Case Conditions” Sound Propagation Models
Wind Speeds at Night: Contrary to Common Perception
Part 4: IWT Emission – Types
Perception Thresholds, Serious Potential Consequences with Larger IWT Power
Generating Capacity
Clear Lessons from N.D. Kelley Pioneering Studies
Infrasound Emission from IWTs Do Exist
Long-Range Propagation of Infrasound
IWT Separation and Infrasound
Sound Propagation and Computer Modeling
Low Frequency Sound
Appendix: (textbook) Inner and Outer Hair Cell Responses, Hearing Thresholds in Infrasound and Lower-Frequency Sound Spectrum
Part 5: History
Wind Energy’s Wind Ordinance Preference: Derived for Profit Where Did It Come From and Will It Protect Human Health?
Early ILFN Recognition from Turbines and HVAC Systems – Striking Similarity with Industrial Wind Turbine Emissions and Symptoms
Hearing vs. Perceiving – Both Can Produce AHEs
Wind Energy Concedes “Annoyance” Exists, but Offers Other Excuses
NASA and DOE Funded Research – First (and Lasting) Confirmation of IWT
Emissions and Associated Health Effects – Now Denied by Wind Energy
1500-Feet Setback Recommendation by MAE and Its Historical Origen
Pathway to Subsequent Adoption Worldwide
Where Is U.S. Federal-Level Oversight?
Part 6: Adverse Health Effects
Bob Thorne, PhD – IWT Study (2012) and Textbook (2014) 61 Annoyance
Low-Frequency Sound
Infrasound Recognition and AHEs
Perception of Infrasound by a Deaf Woman
Infrasound Perception from Wind Turbines and the Inner Ear – Dr. Salt
Measuring Infrasound
IWT Noise and The Development of Cardiovascular Disease
What is Going On: Deep Dive into a Much Deeper Pond
Obstructive Sleep Apnea – A Model to Consider for IWT Effects
World Health Organization Comments
Appendix: Home Vacating Article – Carmen Krogh
Health Canada Study – Annoyance Related to Turbine Nois
Textbook: Wind Farm Noise (cover and author list)
Annoyance of IWT Noise vs. Other Environmental Sources
Wind Turbine Signature (Infrasound) – 2 Examples
Part 7: Other Select Topics
Nocebo Effect
Sound Perception
Human Rights and Social Justice
Vulnerable Populations
Potential Concerns of IWTs in Proximity to Schools
Increased Cardiovascular Disease Associated with Life in Rural Areas
Recent U.S. Upward-Trending Death Rates from Hypertension
Electricity Costs
Decommissioning Implications
Litigation: A Replacement of Science and Failure of Leadership
Blade Throw: We Need to Have Written, Model-Specific Safety Information
Appendix: European Electricity Prices vs. Extent of Installed “Renewable” Energy Sources
Part 8: Peer Review
IRB Process: Gold Standard Evaluation of Safety That Has Never Been Done
Causality – Professor A.B. Hill
ACWEA Report
Part 9: Searching for an Explanation of Why Harm Is Acceptable … A View Toward the “Dark Side”
Wind Energy/Vestas – Behind the Scenes
Attack on a Science Leader Who Told the Truth
Wind Energy Self-Protecting Ordinance Writing
Declaring “Fact” Through Misuse of Standard Acoustical Instruments
Appendix: 2005 BWEA and 2020 AWEA IWT Health Claims
Danish Physician (Mauri Johansson) Addresses Vestas “Central”: A Profile of Courage
Vestas’ Response to Australian Regulation Attempts to Control Noise
Vestas Protest of Increased Noise Control of Low-Frequency Noise
Part 10: Carbon Management
We Agree on Some Things
Planet of the Humans
Hard Realities That Are Catching Up and Now Demand Action
Renewable Options Without IWT Risks
An Extraordinary Opportunity for Iowa
Appendix: National Geographic Projection of Electrical Generation by 2050
Part 11: Applied Regulation of Noise
Relevance of Background Noise
Lmax vs. Leq – Relating to an Open or Closed Window
(Audible) dBA Calculations (as a Function of Distance) for the V-110 IWT
Outside to Inside Noise Reduction
Windows – Open or Closed?
Relationship Between Night Noise and Health Effects
Loudness Variation over the Sound Spectrum
Part 12: Ordinance Examples and Regulation
Siting Turbines: Considerations
Setback Proposals
Additional Published Sound Limits
Part 13: Recommendations
Site Retooling
Need to Have Wind Ordinance Specify ANSI Standards
Wind Farm Noise (textbook) Wind Ordinance Recommendations
Part 14: Expedited “Part” Summaries
Part 15: Conclusions, Appendix – Mathias Basner

Download original document: “A Madison County, Iowa, cardiologist’s investigation and response to industrial wind turbines in the rural residential countryside regarding concerns of adverse health effects and exploration of the relevant accompanying larger issues

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Date added:  September 20, 2020
Grid, WashingtonPrint storyE-mail story

Wind Power and Clean Energy Policy Perspectives

Author:  Benton, Wash., Public Utility District

Executive Summary

Clean energy technology and public-policy development continue to be in the news and at the forefront of much political debate and discussion. While wind power has emerged as a popular choice for helping meet greenhouse gas emission reduction goals, reasonable questions continue to be raised regarding its ability to cost-effectively contribute to the powering of modern civilization and how the lifecycle environmental and ecological impacts compare to other types of technologies.

With Washington State’s passage of the Clean Energy Transformation Act (CETA) in 2019 and the current schedule for expiration of renewable energy federal tax credits, there is a resurgence in proposed wind power development activity in the Pacific Northwest (PNW), including projects proposed for eastern Washington and Benton County specifically.

As developers and many elected officials tout the economic and environmental benefits of wind farms, Benton PUD believes it is important for our customers and the general public to hear utility perspectives. Unlike the narrower focus of some wind power interests, utilities must balance environmental benefits and concerns with costs and power grid reliability; and we will be held accountable if we fail on any of these dimensions.

While Benton PUD acknowledges wind power development in the PNW will likely continue as Washington State utilities respond to the 2025 CETA deadline for eliminating coal-fired energy and in response to nearby state and corporate clean energy mandates and goals, we do not support further development of wind power in the PNW for the following primary reasons:

1) Benton PUD’s current power supply is hydro and nuclear based and is over 93% “non- emitting” by Washington State standards. While we are ahead of the clean energy curve, we do experience supply deficits during hot summer months and deeply cold winter periods. To cover these deficits, we make power market purchases from generation resources that can be counted on to run on the days and hours needed (dispatchable). Since wind power relies on natural weather conditions decoupled from electricity demand, it is not dispatchable generation and therefore will not help us resolve our seasonal energy deficit problems.

2) The PNW’s hydroelectric generation resources are the foundation of a reliable and clean energy supply that has historically resulted in Washington State contributing no more than 0.5% to the nation’s annual total greenhouse gas (GHG) emissions from electricity production; even with soon to be retired coal-fired power plants in the mix. Further development of wind power in the PNW will not result in consequential reductions in national or global GHG emissions attributable to Washington State utilities and will do very little to mitigate the increasing risk of northwest power grid blackouts; which could grow to a 26% probability by 2026 if utilities are unable to replace the reliable generating capacity of shuttered coal plants.

3) The low availability of wind power requires utilities to continue paying for dispatchable generation capacity that may run infrequently but is still sized to meet most of the peak energy demand on the grid. This “double paying” is why electricity rates in countries and states with high wind penetrations are rising despite the declining costs of this popular renewable energy source. Benton PUD believes further wind power development will unnecessarily contribute to increases in northwest utility retail electricity rates which could erode the economic development advantage low rates has given our region for many years.

4) Energy production from wind farms in the PNW is often high during periods of maximum hydro generation contributing to energy gluts that can drive short-term market prices to zero or even to negative values due to federal tax credits received by wind power. To minimize the net cost of hydro generation the region needs for year-round flexible and reliable electricity, the value of surplus hydro energy sales needs to be maximized. Building more wind farms in the PNW will contribute to untimely energy supply gluts and low short- term market prices which reduces surplus hydro energy sales revenues, increases net hydro power costs and puts upward pressure on retail rates Benton PUD and other utilities charge our customers.

5) Benton PUD believes the best long-term, sustainable and environmentally responsible strategy toward meeting the CETA goal of 100% clean electricity in Washington State by 2045 could be to transition coal power to natural gas and then natural gas to nuclear. It is estimated wind power requires 30 to 45 times as much land and about 10 times as much concrete and steel to produce the equivalent power of nuclear. In addition, a recent study estimates that assuming hydro and nuclear power in the PNW stay in place, meeting a theoretical 100% clean electricity goal in our region using wind (and solar) power would require a land area 20 to 100 times the area of Seattle and Portland combined.

6) Benton PUD supports Energy Northwest (EN) in their efforts to develop small modular reactor (SMR) technology. However, we are concerned continued large-scale investments in PNW wind power projects will contribute to increases in the normally surplus annual energy supplies in the region thereby eroding the hourly energy supply opportunities needed by SMRs to achieve economic feasibility. Maintaining the existing Columbia Generating Station operations while expanding SMR technology development and possible manufacturing in the Tri-Cities represent opportunities for economic stability and growth in an area with a long history of grid-scale energy production and world class scientific research capabilities.

As some legislators and certain advocacy groups continue to call for more wind power while simultaneously calling for removal of hydro-electric dams, Benton PUD believes it is important for our customers and citizens of Washington State to hear the utility side of the energy story. To this end, we are committed to facilitating education and outreach efforts based on the premise that all energy choices represent economic and environmental tradeoffs and that consideration of utility business models and the physics of the power grid matter when taking a position to promote one form of power generation technology over another.

Existing wind farm development in Washington State and along the northern Oregon border has already resulted in the industrialization of previously scenic hillsides, canyons and desert vistas in the region in and around Benton County. Before Benton PUD customers and citizens throughout our region accept further sacrifice of the natural beauty and open spaces that are part of our way of life, we want them to know there are other options we should be asking our legislators and utility industry leaders to urgently and seriously consider. This is the reason for this report and for our formal declaration that Benton PUD does not support further development of wind power in the PNW.

Existing Power Resources and Loads

Despite clean energy policies and trends favoring wind and solar power, continued development of wind farms in the northwest is not expected to be necessary or beneficial to serving the interests of Benton PUD customers for at least the next decade or more. This is primarily due to our hydro and nuclear rich wholesale power supply contract with the Bonneville Power Administration (BPA) which entitles Benton PUD to annual energy amounts that are normally greater than what is consumed by our customers. In addition, our BPA contract in combination with other energy purchases and contracts results in a power supply that is already over 93% “non-emitting” and clean by Washington State standards.

With this said, it is important to recognize Benton PUD does face significant power supply challenges under the terms and conditions of our current BPA contract. These challenges are rooted in the timing of BPA energy delivery which does not always align with our customer demand for electricity. Benton PUD is a “summer peaking” utility with our highest customer demand being driven by irrigated-agriculture pumping operations combined with high residential and business air conditioning; see FIGURE 1.


As a “Slice” customer of BPA, Benton PUD has rights to a fixed percentage of the electricity generated by BPA resources for any given hour of the year which can be highly variable. As BPA resources are predominantly hydro-electric, the variability is driven by the timing and quantity of runoff from snowpack as well as short term precipitation events which must be managed to serve interests that compete with power generation; including fish and wildlife, flood control, river navigation and recreation.

To gain further perspective, it is instructive to know that Benton PUD’s annual allocation of BPA wholesale energy in typical water years delivers about 225 average megawatts (aMW) which is more than our total annual customer retail energy consumption forecast beyond the year 2030. On average, our BPA supply is currently 11 aMW more than our customers consume on an annual basis. However, while Benton PUD currently has a “long” annual energy supply position, we do experience regular seasonal energy supply deficits in the summer and on occasion can come up short during deep cold periods in the winter. These seasonal energy supply shortfalls, referred to as capacity deficits, are a function of Benton PUD’s dependence on the availability of “fuel” (river flows) for BPA’s hydro resources which can vary significantly from year-to-year and month-to-month; see FIGURE 2.


Under Benton PUD’s Slice contract with BPA, they are required to guarantee delivery of firm monthly energy represented by the combined total of a “Block” and “Critical Slice” amount. The “Above Critical Slice” is the amount of energy BPA is forecasting will be available to Benton PUD but not guaranteed. Slice customers can re-sell surplus energy received from BPA when supply exceeds what is required to serve customer loads but in return must accept and independently manage the risk that loads may be higher than the available BPA supply.

Any forecasted capacity deficits require Benton PUD to make purchases from wholesale electricity markets in order to augment our long-term power supply contracts. Consequently, we have people, processes and contracts in place to be sure our customer electricity demand is completely supplied on an hourly and around the clock basis. Benton PUD’s wholesale electricity purchases are typically made in short-term monthly, weekly, day-ahead and hourly markets from generation resources that can be counted on to run on the days and hours needed (dispatchable). These dispatchable generation resources provide needed capacity to cover energy supply deficits that occur on the hottest and coldest days of the year.

Since wind power relies on natural weather conditions decoupled from electricity demand, it is not a dispatchable generation resource and therefore development of more wind power will not help Benton PUD resolve our seasonal capacity deficit problems; particularly our most acute deficits which occur in summer months with very low levels of wind. We are also concerned that preferences for wind power risk under investment in dependable and dispatchable natural-gas generation plants most utilities believe will be essential for replacing the capacity of coal-fired plants being rapidly retired and shut down in the Pacific Northwest and throughout the western United States.

While wind energy developed on a large scale can be a substitute for much of the annual energy produced by fossil-fueled power plants, it cannot provide the equivalent capacity required for balancing electricity supply and demand on an around the clock basis, and under a wide variety of weather conditions. Because the northwest is so dependent on the availability of water for hydro-electric generation, the coldest and hottest days of a year in which water resources are at a critically low level are of particular concern for electric utilities and is why other reliable and dispatchable generation must be standing by and ready to run on demand. When power grid supply does not meet demand on a moment-by-moment basis, blackouts can occur. Benton PUD is concerned that a deepening dependence on wind power as a replacement for energy produced by coal plants in the northwest could have serious consequences in the not-too-distant future if grid operators are faced with the simultaneous occurrence of drought conditions (low hydro power production), extreme temperatures, low wind and not enough dispatchable electricity generators to meet peak customer demands.

To gain further perspective, it is also instructive to consider Benton PUD’s 11 aMW “long” BPA annual energy position in the context of customer growth which is currently forecasted to result in an increase of about 0.4 aMW of energy consumption per year. This relatively low growth rate is driven by our continued investments in effective conservation measures as well as improvements in the energy efficiency of new homes and businesses. In the simplest analysis, Benton PUD’s expected annual supply of BPA power represents over 27 years of customer growth which means we are not currently looking to add substantial amounts of “baseload” annual energy to our power supply portfolio from wind power or other resources.

With this said, new large loads associated with electricity intensive businesses or industry locating in Benton PUD’s service territory are a wild card that could require acquisition of new generation resources. Another resource acquisition driver could be preferences for wind and solar power which are often used to brand businesses as sustainable. In either case, given the requirements of Washington State’s Clean Energy Transformation Act (CETA) and other clean energy policies and preferences in adjacent states and regions, wind and solar power may be the only significant energy resources available to meet a future Benton PUD need. While not ideal, we would choose solar power over wind given that solar energy production curves are better aligned with our summer peaking load profile and would contribute to reducing our regular summer capacity deficits on most days.

Existing Wind Power Resources

Currently, Benton PUD’s power supply portfolio includes wind energy through direct contracts from the Nine Canyon (9 MW) and White Creek (9.1 MW) projects delivering about 5.7 aMW of total energy on an annual basis. These contracts were initiated by Benton PUD in response to the qualifying renewable energy requirements of Washington State’s Energy Independence Act (EIA) which initially did not include energy from existing hydro generation.

In addition to direct wind power purchases, Benton PUD’s contract with BPA includes an allocation of about 1.4 aMW of their wind portfolio’s annual energy production. All the wind resources in Benton PUD’s portfolio along with BPA’s hydro generation resulting from incremental improvements to turbine-generator efficiency (incremental hydro) are considered EIA qualifying renewable energy. This means energy from these resources provide a renewable energy credit (REC) for every megawatt-hour of electricity generated.

REC allocations and purchases are how Benton PUD meets the renewable portfolio standard (RPS) currently required by EIA mandates. In 2020 Benton PUD will need a total of about 30 aMW of REC allocations and purchases each year to meet the current 15% RPS requirement. We plan to meet our compliance requirement with 7.1 aMW of total wind power RECs from Nine Canyon, White Creek and BPA; 2.6 aMW of BPA incremental hydro REC allocations; and 20.4 aMW of REC purchases from other entities, including wind farms.

It is important to emphasize that a REC is a certificate corresponding to the environmental attributes of energy produced from qualifying renewable resources and does not necessarily represent purchases of physical electricity. While Benton PUD has contractual rights to the electricity produced by the Nine Canyon and White Creek projects, it is usually surplus to our annual customer energy requirements except under a worst-case low hydro generation scenario.

With that said, Benton PUD’s share of Nine Canyon’s physical electricity is always scheduled to supply our load with the net effect during low customer load periods of increasing our BPA hydro surplus which we sell in regional wholesale electricity markets. Due to power scheduling complexities, Benton PUD’s share of the White Creek project’s physical electricity is bundled with other utility shares and sold to another counterparty at a price currently well below the relevant market power index. This below index pricing is an indicator of the reduced value of wind energy compared to other more dependable generation resources.

Revenues from the sales of physical electricity attributed to Nine Canyon and White Creek are considered as offsets to the total annual cost of Benton PUD’s EIA renewable-energy compliance which is budgeted to be $3.8 million in 2020. We expect to continue to rely on REC purchases as the primary means for meeting EIA mandates with some relief possible in 2030, depending on CETA rules which are currently under development.

Benton PUD considers the incremental cost and dependence we have on continued operation and development of wind and solar power for REC purchases as a perverse outcome of EIA mandates given our extraordinarily clean power supply and surplus annual hydro and nuclear- based energy position.

Surplus Energy and Market Sales

With respect to Benton PUD’s net annual surplus of energy, it is important to understand the timing of when most surplus hydro generation occurs. For Benton PUD, the best combination of market price and volume of surpluses occurs in January through March with the highest volume and lowest prices occurring in April and May. When our hydro supply exceeds customer demand, our BPA contract allows us to sell the surplus energy into wholesale electricity markets. The revenues generated by our sales have the effect of buying down our annual wholesale power costs.

Energy production from wind farms in the northwest can also be high during periods of maximum hydro generation contributing to energy gluts that can drive market prices to zero or even to negative values due to federal tax credits received by wind power. The wholesale electricity market distortions created by wind power tax credits combined with the availability of abundant and low-priced natural gas has driven market prices to very low levels in recent years. Consequently, the value of Benton PUD surplus hydro energy sales has been significantly reduced from over $50 million in 2008 to under $20 million today.

While there are efforts underway centered on possible expansion of the Western Energy Imbalance Market (EIM) to an extended day ahead market (EDAM) that could increase the economic value of BPA hydro flexibility and capacity, Benton PUD believes further development of wind power in existing “energy only” wholesale markets will continue to contribute to the devaluation of hydro. To be clear, Benton PUD believes abundant and low-cost natural gas has been the major driver of wholesale electricity price reductions but building more wind farms will contribute to downward pressure on prices.

Overall, the erosion of the market value of hydro energy has resulted in upward pressure on the prices BPA charges Benton PUD and consequently on the retail rates we charge our customers. Since 2007, BPA’s revenues derived from market sales have dropped from over $400 million to under $200 million in some years which leaves them looking to their ratepayers to make up the difference. Benton PUD’s net power supply costs are budgeted to be $84 million in 2020 which is up 40% since 2010 when actual costs were $60 million.

Oversupply and Curtailments

Additional concerns regarding the development of more wind power are oversupply and curtailments which are well described in a report developed by Harvard University for the Bonneville Power Administration in May 2018.

… As more intermittent renewable energy is added to the grid it creates oversupply, particularly during low demand hours, when generation exceeds load. Oversupply causes low or negative prices for wholesale energy during periods of overgeneration. When scheduled generation exceeds scheduled demand in the hour-ahead market, the price of energy falls below zero in an attempt to balance supply and demand. After accounting for changes in generation and load between the hour-ahead and real-time markets, if generation still exceeds load and there are no more generators willing to receive payments to reduce their output, then balancing authorities must order generators to curtail output to maintain system frequency. Negative bids often represent the lost opportunities for the generator to take advantage of tax credits for renewable energy production.

… Due to the Pacific Northwest’s reliance on hydroelectricity, oversupply becomes more problematic in the springtime when both river flows and wind generation are high. Under those circumstances, extra water can be spilled from the dams so that it does not contribute to oversupply, but too much spill exceeds water quality standards and can harm fish and other aquatic species. If water cannot be spilled, it must be passed through the hydropower turbines, thus generating electricity.

For conditions like these, BPA implemented the Oversupply Management Protocol, under which non-hydrogeneration is displaced to protect aquatic life and maintain system reliability. Displacement decisions are made according to a least-cost displacement cost curve that lists generation in order of cost, from the least cost facility to the highest-cost facility, until the required displacement quantity is achieved. After a federal court case concluded in 2011, BPA enacted a new protocol that compensated wind generators for lost revenues from curtailment and assigned the costs of curtailing generation during oversupply events to BPA transmission customers. (Patricia Florescu and Jack Pead, “Realizing the Value of Bonneville Power Administration’s Flexible Hydroelectric Assets”, Mossavar-Rahmani Center for Business & Government, Harvard University, May 2018)

While Oversupply Management Protocol costs have not been extremely high (BPA’s displacement costs of OMP were around $4.87 million in 2018 and $2.2 million in 2017 https://www.bpa.gov/Projects/Initiatives/Oversupply/Pages/Annual-Oversupply-Review.aspx) relative to other costs incurred by Benton PUD through our BPA transmission contract, we are concerned more wind power on the grid will contribute to increases in BPA costs and will add more complexity to the already difficult balancing act of managing river flows to meet the competing interests of power generation, environmental stewardship, barging operations, flood control and recreation.

Pacific Northwest Resource Adequacy Challenges

The Pacific Northwest’s clean hydroelectric generation resources are unmatched anywhere in the United States and are the primary reason Washington State contributed on average no more than 0.5% to the nation’s annual total greenhouse gas emissions from electricity production each year between 1980 and 2017 (U.S. Energy Information Administration, “State Carbon Dioxide Emissions Data” https://www.eia.gov/environment/emissions/state/); even with coal plants in the mix.

While our already clean electricity sector is the envy of the nation, policy makers in Washington State have set the course for 100% clean by 2045 through passage of the Clean Energy Transformation Act (CETA). While a long-term goal like this is clearly aspirational at this point, the near-term consequences of CETA’s underlying requirements are significant and very

concerning when it comes to maintaining power grid reliability. The most consequential requirements are the explicit removal of coal power from utility portfolios by 2025 and the “social cost of carbon” which must be used as a cost adder when utilities evaluate investments in new generation resources. As intended by legislators, this cost adder will have a chilling effect on investments to construct new natural-gas power plants which utilities would normally consider to be the logical replacement for dispatchable capacity associated with retiring coal plants.

Unfortunately, CETA along with other anti-fossil-fuel sentiment in Oregon and California energy policies has put northwest utilities in a position where it appears only wind and solar power along with batteries, pumped hydro and customer load curtailments (demand response) will be allowed to try and solve utility capacity deficits. The problem is that science, economics and project development cycle times indicate the politically preferred technologies are not ready to provide solutions at the scale needed to mitigate the already unacceptable increase in the risk of blackouts projected for the Pacific Northwest beginning in 2021 (Northwest Power and Conservation Council, “Pacific Northwest Power Supply Adequacy Assessment for 2024”: October 2019). In their most recent assessment, the Northwest Power and Conservation Council (NWPCC) estimates that accelerated coal-plant retirements could increase the likelihood that generating capacity will not be adequate for meeting demand to a level of 26% by 2026. This is well above the 5% threshold established as the limit for an adequate regional power supply.

Benton PUD is a relatively small player in the northwest grid, but our seasonal capacity deficits are significant. This is why we joined forces with other members of the Public Generating Pool (PGP) and several investor owned utilities to co-fund a study by E3 Consulting (Energy+Environmental Economics, “Resource Adequacy in the Pacific Northwest”: Public Generating Pool, March 2019) of what will be required to maintain power grid reliability in the Pacific Northwest while further de-carbonizing the electricity sector. This study found that deep de-carbonization is possible but that natural gas fired generation will be needed to maintain power grid reliability; it would just run infrequently.

While development of wind farms may be politically fashionable and appeal to many in the general public as a harmonization of nature with electricity production, the science and economics indicate powering modern civilization with intermittent generation resources like wind and solar power comes at a high financial and environmental cost. E3’s study concludes that increasing the Pacific Northwest’s inventory of wind power from the 2018 level of 7 gigawatts to a level of 38 gigawatts by 2050 (38 gigawatts of nameplate wind power capacity is what E3 determined would be required in an optimal scenario to reduce greenhouse gas emissions from electricity production by 80% below 1990 levels; an often-quoted goal from the Intergovernmental Panel on Climate Change (IPCC)) would only result in an effective capacity contribution from wind of 19%. In other words, a more than fivefold investment in wind power which E3 estimates would cover an area as much as 37 times the combined areas of Seattle and Portland, would only allow regional utilities to count on 19% of the capital investment to produce electricity when it is most critically needed. The E3 study also estimates the area required to achieve a theoretical 100% clean electricity sector in the northwest using only wind and solar power (assuming existing hydro and nuclear stay in place) would require a land area as much 100 times the combined areas of Seattle and Portland.

On November 12, 2019 Benton PUD Commissioners adopted Resolution 2523 in support of actions to ensure electric sector resource adequacy in the Pacific Northwest. This resolution provides a sound argument for why northwest utilities have serious concerns regarding the reliability of the northwest power grid and why Benton PUD questions the wisdom of continued development of large numbers of wind farms in our region when we are facing potentially serious consequences associated with power grid blackouts.

Other Considerations

The “fuel” for wind power is dilute and intermittent requiring additional investments in backup generation technologies to meet the always-on requirements of power grids. While developers and advocates often tout continued reductions in the cost of wind energy, the low availability of wind power requires utilities to continue paying for dispatchable generation capacity that may run infrequently but is sized to meet most of the peak energy demand on the grid. This “double paying” is why electricity rates in countries and states with high wind penetrations have risen significantly amid claims of low-cost renewable energy.

CETA together with the Energy Independence Act (EIA) appears to have established an undefined increase in Washington State’s renewable portfolio standard (RPS) which will undoubtedly lead to some level of double paying in Washington State. Establishing preferences for wind and solar energy with no accompanying targets for greenhouse gas (GHG) emission reductions in the electricity sector has been shown through comprehensive study to result in unnecessary increases in the cost of electricity while not reducing GHG emissions in the most cost-effective manner possible (Energy+Environmental Economics, “Pacific Northwest Low Carbon Scenario Analysis – Achieving Least-Cost Carbon Emissions Reductions in the Electricity Sector”: Public Generating Pool, December 2017).

Additionally, the land area required for wind turbine construction and transmission lines needed for grid interconnections can be immense and the negative ecological and environmental impacts of this “energy sprawl” may outweigh the perceived or real benefits. Benton PUD believes lifecycle economic and environmental impacts expected to result from further development of wind power need to be scrutinized to a much higher degree with greater recognition of issues like the global impacts of raw materials mining and the disposal of wind turbine blades which are currently destined for landfills.

Benton PUD acknowledges every source of energy production takes a toll on the environment but believes wind power is often given a pass due to its popularity with policy makers and many in the general public. One source estimates wind power requires about 30 to 45 times as much land to produce a comparable amount of power as nuclear and that concrete and steel requirements for wind are about 10 times greater (Robert Bryce, “Power Hungry – The Myths of “Green” Energy and the Real Fuels of the Future”: Pages 84, 91). We believe these are important and relevant considerations as investments are made in power generation projects that will have long lasting environmental and financial impacts.

Benton PUD supports provisions of CETA that count hydro and nuclear energy toward the 100% clean by 2045 objective. However, we believe a more cost-effective and potentially less risky trajectory toward this goal would have been to allow for the transition from coal to natural gas and to promote an increase in the development of nuclear energy as the best long-term and sustainable strategy. We believe it is reasonable to suggest the most balanced and environmentally responsible actions you can take to “clean up” the electricity sector is to produce as much low or non-emitting electricity as possible in the smallest area possible. This seems to be best accomplished with energy dense fuels like natural gas and uranium.

Benton PUD supports EN in their efforts to develop small modular reactor (SMR) technology. However, we are concerned continued large-scale investments in wind power will substantially increase the normally surplus annual energy supplies in the Pacific Northwest (PNW) thereby eroding the hourly energy supply opportunities needed by SMRs to achieve economic feasibility. According to the Bonneville Power Administration (BPA) (Bonneville Power Administration, “2018 Pacific Northwest Loads and Resources Study”: April 2019, Section 3) the generating potential from federal and non-federal hydro projects in the PNW can vary by almost 7,000 aMW annually and by almost 14,000 aMW in some months, depending on project operations and the availability of water. But even in the worst water years, the PNW region is projected to have annual firm energy surpluses for the next ten years, assuming the region’s 4,000 MW of uncommitted independent power producer (IPP) generation capacity is available to serve regional loads. Adding to this “long” regional energy position with continued development of large-scale wind farms does not bode well for the development of SMR based generating projects given their relatively high capital costs and the need for lots of run time in order to reduce energy production costs to levels that will make them competitive with other technologies.


It appears additional wind farm development in the Pacific Northwest (PNW) is gaining momentum and is a foregone conclusion in the minds of many legislators, members of the general public and even some utilities. Benton PUD believes it is reasonable to question whether continuing to favor investments in intermittent wind power and putting up roadblocks to the development of dispatchable natural-gas power plants is more about environmental virtue signaling than it is about serving the best interests of the citizens of Washington State.

There is no denying the fact that thanks to abundant PNW hydro energy, Washington State has historically been one of the lowest contributors to electricity sector greenhouse gas (GHG) emissions in the United States and that electricity sector contributions to total statewide GHG emissions have been only 16% to 19% (Department of Ecology State of Washington, “Washington State Greenhouse Gas Emissions Inventory: 1990- 2015 Report to the Legislature,”: December 2018, Publication 18-02-043, Pg. 6, Table 2), even with coal plants in the mix. Put another way, what urgent “dirty energy” problem are we attempting to solve through the aggressive timelines and technology restrictions of the Clean Energy Transformation Act (CETA) that is worth sacrificing vast amounts of our natural landscapes and risking blackouts that jeopardize the health, safety and wellbeing of northwest electricity customers?

While language exists within CETA requiring future reporting to the governor’s office to address concerns with power grid reliability, it appears legislators do not believe the risk of blackouts is real. If they did, they would accept the results of already existing utility studies and immediately begin to work on modifications to CETA to remove disincentivizes for the development of dispatchable natural gas plants needed for replacing retiring coal-plant capacity. So, at this point, investor owned utilities are announcing plans for new wind power projects to meet CETA deadlines, and along with all northwest utilities, are hoping the efforts of the Northwest Power Pool (NWPP) to develop power-generation resource adequacy standards can be completed and implemented in time to avoid blackouts (Northwest Power Pool Resource Adequacy: https://www.nwpp.org/about/workgroups/12).

Benton PUD strongly supports the efforts of the NWPP, but we do not support further development of wind power in the PNW. We believe continued investments in large-scale wind farm development in the PNW will: (1) contribute very little to keeping the regional power grid reliable and will not help Benton PUD solve our seasonal energy deficit problems; (2) contribute to the devaluation of hydro-generation assets and put upward pressure on retail rates Benton PUD and other utilities charge our customers; (3) risk underinvestment in needed dispatchable capacity today and future investments in visionary advancements in nuclear energy technology; (4) further sacrifice scenic hillsides, canyons and desert vistas in our region for little if any net environmental benefit.

Benton Public Utility District
Rick Dunn, General Manager
Commissioners: Barry Bush Jeff Hall Lori Sanders
July 14, 2020

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Date added:  August 6, 2020
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Easement for Wind Energy Development: Triple H Wind Project

Author:  Infinity Power Partners

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