Resource Documents: Minnesota (8 items)
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Author: Overland, Carol
Minn. R. 7030.0400 is the MPCA’s noise rule, setting standards for industrial noise. It was developed to limit industrial noise, from a noise source on the ground to a “receptor” on the ground. ISO 9613-2 was also developed to measure ground based noise reaching a ground based receptor.
A primary input is the “ground factor” set to address conditions on the ground, the ground effect, between the noise source and the receptor:
7.3 Ground effect (Agr)
7.3.1 General method of calculation
Ground attenuation, Agr, is mainly the result of sound reflected by the ground surface interfering with the sound propagating directly from source to receiver.
While there may be some reflected sound reaching the “receptor” (that is such an obnoxious term for people!), the sound from a wind turbine with a hub height of 300 feet or more! That’s a direct path to the “receptor.” The ground, grasses, corn, trees, buildings, do not get in the way.
The ground factor to be used for wind turbines is ZERO.
Dr. Schomer stated this clearly and thoroughly in the Highland Wind docket in Wisconsin (PSC Docket 2535-CE-100).
The use of a 0.0 ground factor for wind is standard practice, and that a 0.5 ground factor is NOT appropriate for wind because it’s elevated. This was inadvertently confirmed by Applicant’s Mike Hankard in the Badger Hollow solar docket, also in Wisconsin (PSC Docket 9697-CE-100):
The model that we use has been shown to predict conservatively with 0.5. I mean, 0.5 ground factor is used in probably – well, with the exceptiion perhaps of wind turbine projects which are different because the source is elevated. But for projects like a typical power plant, a solar plant where the sources are relatively close the ground, I would say 90 to 99 percent of the studies use 0.5. And when consultants like myself go out ad measure these plants after they’re cpmnstricted tp verify our modeling assumptions, that assumption checks out as being, if anything, overpredicting the levels. So there’s no need to – there would be no justification to use something like a .2 or .3 which would predict yet higher levels because we’re already demonstrating that the model is probably overpredicting. So that would not be justified for those reasons.
Who cares? Well, it’s bad enough that in that WI PSC Highland Wind docket, when the applicants couldn’t comply with the state’s wind noise limit, they redid their noise “study” using the inappropriate ground factor of 0.5 to give them more compliant numbers – they moved the goal posts, garbage in, garbage out. They think they can do that in Minnesota too, and are trying oh so hard in the Freeborn Wind docket (PUC Docket 17-410).
Last September, 2018 that is, Freeborn Wind did a deal with Commerce, admitted to in its “Request for Clarification/Reconsideration” pleading:
Freeborn Wind requests the Commission clarify its Site Permit to adopt Section 7.4, as proposed by Freeborn Wind and agreed to by the Department and MPCA, in place of the current Sections 7.4.1 and 7.4.2, to both ensure consistency with the Order and avoid ambiguity in permit compliance.
Freeborn Wind’s September 19, 2018, Late-Filed proposal for Special Conditions Related to Noise outlines the agreement reached between Freeborn Wind, the Department and the MPCA on this issue.
(fn. citing Late Filed—Proposed Special Conditions Related to Noise (Sept. 19, 2018), eDocket No. 20189-146486-01).
In this deal, they put language in the permit that was a fundamental shift in noise monitoring, one for which there is no justification under the noise modeling standards, whether state or ISO 9613-2 – that of using a 0.5 ground factor.
The language in the proposed special conditions requires Freeborn Wind to submit updated modeling and/or proposed mitigation demonstrating that modeled wind turbine–only noise will not exceed 47 db(A) L50-one hour at receptors. Specific guidance is included regarding the modeling assumptioins to be used. Specifically, proposed Section 6.1 directs Freeborn Wind to follow the NARUC ISO 9613-2 standard with a 0.5 assumed ground factor. As reflected in the special condition language, setting a turbine-only noise limit at 47 dB(A), using the specified model assumptioins, ensures that the Project will not cause or significantly contribute to an exceedance of the MPCA Noise Standards. This limit is supported in this record by expert testimony from Mr. Mike Hankard and the MPCA’s 2015 Noise Guide, both stating the 3 dB(A) is the generally recognized minimum detectable change in environmental noise levels. To illustrate, when nighttime background sound levels are at 50 db(A) L50-one hour, a maximum turbine-only contribution of 47 db(A) L50-one hour would result in a non-significant increase in total sound of less the 3 dB(A).
The day before the Commission’s meeting, they filed for a “Special Condition,” and oh, was it special:
At the meeting, they presented a chart with made up numbers on it, not supported by any noise study:
This chart was shown for a few seconds at most, it was not provided in the “Late Filing” above, and there were no copies for parties or the public. Did Commissioners get a copy? Who knows …
The Commission then granted the site permit! There were a few rounds before we got to where we are today, with Xcel Energy acquiring the project, and with a new site plan, bigger turbines, and some specific site permit amendments. In its permit amendment application, Xcel Energy is now the owner of Freeborn Wind, and Xcel wants to use larger Vestas V120 turbines rather than the V116.
From testimony in the original Freeborn Wind hearing, and in an Affidavit submitted by Commerce-EERA’s Davis:
7. It is generally understood that turbine noise output increases with higher blade tip speeds …
(Aff. of Davis, EERA Motion, 20181-139379-01)
In its permit amendment application, Xcel Energy is now the owner of Freeborn Wind, and Xcel wants to use larger turbines. In so doing, they have filed a noise study, Attachment E, utilizing that 0.5 ground factor. Xcel’s claim is that they’re using a 0.5 ground factor because the permit specifies that:
This Xcel filing is the first noise study in the Freeborn Wind record to utilize a 0.5 ground factor.
This Xcel filing is the first noise study in the Freeborn Wind record following the ALJ’s recommendation of denial:
The Administrative Law Judge concludes that Freebron Wind has failed to demonstrate that the proposed Project will meet the requirements of Minn. R. 7030.0040, the applicable Minnesota Noise Standards. Therefore, the Administrative Law Judge respectfully recommends that the Commission either deny Freeborn Wind’s Application for a Site Permit, or in the alternative, provide Freeborn Wind with a period of time to submit a plan demonstrating how it will comply with Minnesotat’s Noise Standards at all times throughout the footprint of the Freeborn Wind Project.
There’s a 3 dB(A) margin of error – even using Hankard’s numbers, look at the yellow lines right up against the homes, and look at the blue 50 dB(A) lines and how many homes are inside of those lines:
Turbine noise at the hub for the V120s can be maximum of 110.5 dB(A), and serrated edges provide an option to reduce noise (which Xcel says it plans on using for some turbines), per the Vestas spec sheet.
Compliance? Modeling with the improper 0.5 ground factor doesn’t come close to demonstrating compliance, instead it demonstrates a high probability of non-compliance. It demonstrates that using the proper ground factor for wind, it won’t do the modeling, likely (assuredly) because the project cannot comply. Freeborn Wind could not demonstrate that it could comply with state noise standards as originally designed with the smaller wind turbines and the proper modeling ground factor, and now Xcel Energy wants to use larger turbines. Larger turbines are noisier … once more with feeling:
7. It is generally understood that turbine noise output increases with higher blade tip speeds …
And now we see, hot off the press, the Plum Creek wind project (PUC Docket WS-18-700), proposed by Geronimo …
Vestas 150 and 162 turbines, 5.6 MW each! The noise for the V150 is a maximum of 104.9 dB(A), and for the V162 is a maximum of 104.9 dB(A), with “sound optimized modes available.” That’s in the brochure.
They have provided a noise study, BUT, much is NOT PUBLIC:
And I wonder why … well, it says that they’re not using a ground factor of 0.0. Look at p. 48 of the sound study above, deep breathe and take a peek:
They’re using a ground factor of 0.7 !
For this analysis, we utilized a ground factor of G=0.7, which is appropriate for comparing modeled results to the L50 levels.
18A 2-dB uncertainty factor was added to the turbine sound power per typical manufacturer warranty confidence interval specifications. 18Generally accepted wind turbine modeling procedure calls for a ground absorption factor of G=0.5, with a 2-dB uncertainty factor added to the manufacturer’s guaranteed levels, to predict a maximum LEQ(1-hr). In this case the state limit utilizes and L50 metric instead of maximum LEQ(1-hr), which means a ground factor of G=0.7 can be used.
They say it again on p. 62, elsewhere too:
How stupid do they think we are?
How stupid do they think Commerce-EERA is? … oh … never mind …
Anyway, here are the sound study maps based on that bogus 0.7 ground factor – look how many homes are affected:
Geronimo gets the gong:
The applicants know exactly what they’re doing.
At least twice in the Freeborn record I have asked whether the Commissioners understand “0.5 ground factor” and “0.0 ground factor” and have been vigorously assured that yes, they do understand. And Commerce-EERA staff? You’re responsible for doing the footwork on these siting applications. Do you understand?
If they do not understand, or misunderstand, they’ve got some learnin’ and edumacation to do. If they DO understand, and are approving site permits knowing that the modeling is off, that ground factor is misused, they’re complicit. They’re knowingly afflicting those who have to live with the noise sound levels that exceed Minnesota state standards.
As we saw in Bent Tree, where the noise standard compliance is in question, it is Commerce’s job to do the noise monitoring and deal with the problem. Once a turbine is up, there aren’t many options other than “shut down the turbines” or “buy out the landowners.” How many landowner buy-outs do you think we need before it’s admitted there’s a problem? Why is it so hard to develop responsible, precautionary, and respectful siting? Why is there resistance? The costs of their failure to do so are … well … we may see exactly what those costs are.
Commissioners and Commerce staff, make sure you know how the state noise standard and ISO 9613-2 was designed, how it is to be used, and what ground factor means.
If you know what it means, and are siting turbines using 0.5 and 0.7, you are responsible.
Brian R. Zelenak, Manager, Regulatory Administration, Xcel Energy, February 8, 2011 – re: Nobles Wind Energy Project, Minnesota, 1.5-MW turbines. [download]
A conservative estimate for a decommissioning expense is approximately four-hundred forty-five thousand dollars ($445,000) per turbine (2009 dollars).*
*Includes allowance for salvage value and based on total dismantling cost estimate for the project of 8.7% of the total plant balance of $510,965,406, equaling an estimated dismantling cost [of] $44.5 million or $445,000 per turbine. [NWW note: The Nobles project consists of 134 1.5-MW turbines, not 100, which would make the assumed 8.7% decommissioning cost $332,000 per turbine (2009 dollars).]
[$445,000 in 2009 is equivalent to $533,000 in 2019, $332,000 to $397,000.]
Wenck Associates, April 2017 – re: Palmer’s Creek Wind Farm, Minnesota, 2.5-MW turbines. [download]
The estimated cost to decommission Palmer’s Creek Wind Farm was provided by Fagen, Inc., construction contractor, in a letter dated November 16, 2016. The estimate is considered to be the current dollar value (at time of approval) of salvage value and removal costs. The estimated salvage value of each turbine will be based upon the worst-case scenario assuming the only salvage value of the turbine is from scrapping the steel. The estimate was based upon the total weight of one turbine, which is 275 tons consisting primarily of steel. Because it does not separate the scrap value of all the constituent materials, the estimate is very conservative. Also, it is highly likely that there would be opportunities for re-sale for reuse of all or some of the turbines or turbine components. Based on the current estimate, the cost of decommissioning is $7,385,822 with a potential scrap return value of $445,500 [net cost of $385,573 per turbine, $403,881 in 2019 dollars].
Henry Blattner, Senior Estimator, Blattner Energy, to Ryan Pumford, Nextera Energy, 2017 – re: Tuscola Wind III, Michigan, 2-MW turbines. [download]
To mobilize a crew and equipment, take down a GE wind turbine and haul off site the cost would be $675,000.00. Assuming a salvage value of $150 per ton and weight of 188 tons for the steel in the turbine and tower we [would] be able to reduce this cost by $28,200. The total price minus the salvaged steel would be $646,800.00.
Author: Rosenquist, Kristi
A Report for the Legislative Energy Commission, 10/19/2017 —
Many Minnesotans report sleep deprivation, migraine headache, vertigo and ringing in the ears after large wind turbines are installed near their homes. Some have left their homes.
MN Department of Health identified low-frequency noise as the most likely cause and confirms that the health of some Minnesotans is being harmed by wind turbines.
Setback distance between a turbine and a home is based on wind turbine noise. State agencies concur that they understand so little about wind turbine noise they cannot even enter into rulemaking on wind turbine noise.
Minnesotans who are harmed have no recourse.
European countries more experienced with wind turbines than Minnesota have setbacks that are 10 times the height of the turbine to the blade tip at its highest point (5000 feet for large modern wind turbines).
- Site permit setback distance from homes is based on “noise” even though the State knows so little about turbine noise they cannot enter into rulemaking on the topic.
- Minnesotans’ homes are inside the turbine Safety Evacuation Zone.
- What studies does the PUC have in front of it and how did they respond?
- Citizens whose health and peaceful enjoyment of their private property are harmed by wind turbines have no recourse.
- PUC approved research of LFN by the University of Minnesota that fails to study LFN in homes and the health of people living next to turbines.
- Audible Noise – agreement that 40 dB(A) should be the limit, but no good measurement protocol to determine if it is met.
- Low-Frequency Noise is the problem. Measurable – but no standards.
- What should the Minnesota Legislature adopt for a siting standard?
- Appendix: Partial list of wind turbine LFN and health studies in PUC Docket 09-845
Download original document: “Wind Turbine Siting in Minnesota: A Report for the Legislative Energy Commission”
Download presentation (view below): “Presentation to the Legislative Energy Commission, October 19, 2017”
Author: Hayward, Steven; and Nelson, Peter
In recent years, the state of Minnesota has pursued a series of increasingly aggressive renewable energy and “clean energy” policies that cost electricity consumers billions of dollars, without achieving its ambitious environmental protection goals.
Minnesota law sets out ambitious state energy policy goals. The primary goal would have the state reduce greenhouse gas emissions 15 percent below 2005 levels by 2015, 30 percent by 2025, and 80 percent by 2050. State law incorporates a number of additional energy policy goals aimed largely at supporting these greenhouse gas reduction targets. In particular, the state’s renewable energy standard requires utilities to generate a substantial portion (25 to 30 percent) of electricity from renewable sources, mostly wind.
Historically, Minnesota enjoyed the advantage of relatively cheap electricity, with rates typically 18 percent less than the national average. However, since spending an estimated $10 billion on building wind farms and billions more on new and upgraded transmission lines, Minnesota has lost this competitive advantage with little to show for it, except higher electric bills. As electricity generation from carbon free wind approaches 20 percent of total generation, Minnesota has not experienced any appreciable reduction in greenhouse gas emissions relative to the U.S. average.
This report evaluates Minnesota’s energy policy and reaches five main findings that buttress one conclusion: Minnesota’s aspirational energy policy is a grand exercise in virtue signaling that does little to reduce either conventional pollution or greenhouse gas emissions.
Minnesota has lost its advantage on electricity pricing. Between 1990 and 2009, the retail price of electricity in Minnesota was, on average, 18.2 percent lower than the national average. However, in just seven years, this price advantage has completely disappeared. February 2017 marked the first month the average retail price of electricity in Minnesota rose above the U.S. price. (Data are available dating back to 1990.) If in the past seven years Minnesota would have maintained its historic price advantage versus the rest of the country, the state’s consumers would have paid nearly $4.4 billion less than what the actual cost of electricity turned out to be.
Minnesota’s energy policy primarily promotes wind power. Minnesota’s energy policy emphasizing renewable energy is mostly an electricity policy, which represents only about 40 percent of the state’s total energy consumption. Because Minnesota’s geography is not suitable for large-scale solar power, it aims, to date, for only modest increases in solar. As such, Minnesota’s energy policy is primarily a wind-energy policy.
Minnesota’s energy policy is failing on its own terms, as it has not achieved a significant reduction in CO2 emissions. While Minnesota was losing its advantage on electricity pricing, it did not see any significant decreases in CO2 emissions. CO2 emissions in Minnesota declined by 6.6 percent from 2005 (the peak year for CO2 emissions in both the U.S. and Minnesota) to 2014 (before starting to rise again). This decline is one-third less than the decline experienced by the nation as a whole, which saw greenhouse gas emissions drop 9.3 percent during the same time period. Looking at just emissions from the electric power sector, emissions in Minnesota dropped by slightly more than the U.S. However, since 2009, the state has made little to no progress on emissions even as electricity generation by wind increased by 92 percent.
To satisfy Minnesota’s renewable energy standard, an estimated $10 billion dollars has been spent on building wind farms and billions more on transmission. In the past five years, Minnesota utilities have reported using wind power from wind farms totaling 5,000 megawatts of nameplate capacity to meet the requirements of the state’s renewable energy standard. Based on industry cost estimates for building new generating capacity, ratepayers are committed to covering an estimated $10 billion for constructing these wind farms and billions more for the transmission needed to move this new power to market. On top of these upfront costs, ratepayers are on the hook for ongoing wind energy maintenance costs, property taxes, and replacement power needed when the wind doesn’t blow.
Steven F. Hayward, Ph.D., senior resident scholar, Institute of Governmental Studies, University
of California at Berkeley, and author of the 2011 Almanac of Environmental Trends.
Peter J. Nelson, J.D., vice president and senior policy fellow, Center of the American Experiment
Download original document: “Energy Policy in Minnesota: The High Cost of Failure”